Corrective Action Plans

Finding 532 (2021-006)

Significant Deficiency 2021

TX

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.430

Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over compliance with Payroll - Significant Deficiency Recommendation: The auditor recommends that the Entity implement controls for documenting and retaining information to indicate the Entity follows the require...

Deficiencies in Activities Allowed, Allowable Costs, and Period of Performance Controls over compliance with Payroll - Significant Deficiency Recommendation: The auditor recommends that the Entity implement controls for documenting and retaining information to indicate the Entity follows the requirements over 2 CFR section 200.430(i), and that alll pay rates be reviewed for approval and propriety. Action Taken: EPHCC will implement additional controls to ensure the following: 1. All employees must submit an approved timesheet or time and effort for each pay period. 2. All payroll transactions for staff from staffing agencies need to be reviewed by the accounting manager to ensure invoice has correct rate and that staff is paid for all hours worked on timesheet. 3. Upon hiring staff from staffing agencies, EPHCC shall document and retain information that all pay rates are reviewed byt the CEO for approval and propriety. Responsible Official: Chief Financial Officer, Lizabeth Romero Timeline for Implementation: Effective by May 2023

View Audit 1055 Questioned Costs: $1

Finding 352 (2021-001)

Significant Deficiency 2021

Wicomico County Housing Authority

MD

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency

Views of Responsible Officials: The Authority will review and enhance our policies and procedures over payroll processing, to ensure all timesheets have visual approval by supervisor, and employee files obtain copy of the annual board approved salary worksheet.

View Audit 724

Finding 351 (2021-004)

Material Weakness 2021

Western Kentucky Refugee Mutual Assistance Society, Inc.

KY

Questioned Costs Allowable Costs / Cost Principles

2021-004 Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing Number 93.566) Recommendation: Implement and enforce a policy that employees must complete adequate time sheets that list duties and grant that should be charged for time. Action Taken: Aft...

2021-004 Refugee and Entrant Assistance State/Replacement Designee Administered Programs (Assistance Listing Number 93.566) Recommendation: Implement and enforce a policy that employees must complete adequate time sheets that list duties and grant that should be charged for time. Action Taken: After discussion with the Kentucky Office of Refugees regarding their recommendation for manual bi-weekly timesheets, this method was instituted in February 2023, at WKRMAA, Inc. A compilation of these timesheets is prepared and reviewed with each payroll to assure proper allocation of hours by employees and allocation of financial numbers. Monthly meetings with program managers to discuss their employees and the time allocations are also held to ensure invoicing reflects the correct representation of work performed. Contact Person: Cathy J Palmer, CFO (beginning 09/17/2022)

View Audit 721 Questioned Costs: $1

Finding 169 (2021-001)

None 2021

City of Watertown

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

July 25, 2023 Audit Finding Reference: 2021-001 Document Policies & Procedures Over Federal Awards Planned Corrective Action: The City of Watertown will formalize written policies and procedures related to federal awards as required under the Uniform Guidance. Specifically for cash management, ...

July 25, 2023 Audit Finding Reference: 2021-001 Document Policies & Procedures Over Federal Awards Planned Corrective Action: The City of Watertown will formalize written policies and procedures related to federal awards as required under the Uniform Guidance. Specifically for cash management, allowable costs, program income/requesting reimbursement, eligibility determination, equipment, and real property management, subrecipient monitoring, and period of performance. We will also update the existing written policies for procurement to include standards of conduct over conflicts of interest and procedures for evaluating vendors for suspension and debarment. We anticipate having the procedures completed by the end of calendar year 2023. Megan Langan, City Auditor 617-972-6460 mlangan@watertown-ma.gov

View Audit 254

Finding 1214949 (2020-004)

Material Weakness 2020

HOUSING AUTHORITY OF THE CITY OF LITTLE ROCK, ARKANSAS

CA

Allowable Costs / Cost Principles Special Tests & Provisions Eligibility

Finding 2020-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, and 21.019 Material Noncompliance Non Compliance Mater...

Finding 2020-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, and 21.019 Material Noncompliance Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance Criteria: The Authority must maintain complete and accurate accounts and other records for the program in accordance with HUD compliance requirements. Condition: The Authority did not maintain complete and accurate accounts and other records in accordance with HUD compliance requirements including Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility, Reporting, and Special Tests and Provisions. Context: The Authority was unable to provide requested documentation at the time of audit to properly test the HUD compliance requirements. Known Questioned Costs: Unknown Cause: There is a material weakness in internal controls over compliance related to the maintenance of tenant files, wait lists, inspection reports and other records. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster and Public and Indian Housing Program are in material non- compliance with the compliance requirements of the program. Recommendation: We recommend that the Authority implement a process whereby Authority documents are stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows its internal control over compliance processes and procedures related to the Housing Voucher Cluster and Public and Indian Housing Programs to remedy the aforementioned deficiencies. Byran McClellan, CFO, will be responsible to implement this corrective action by December 31, 2021.

View Audit 401725

Finding 1179805 (2020-009)

Material Weakness 2020

Commonwealth Healthcare Corporation

MP

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Finding No.: 2020-009 CFDA Program: 93.268 Immunization Cooperative Agreement Area: Period of Performance Questioned Costs: $4,343 Contact Person(s): Program Administrator, Director of DGFI, and Chief Financial Officer Corrective Action Plan: CHCC does not concur the findings and the questioned cost...

Finding No.: 2020-009 CFDA Program: 93.268 Immunization Cooperative Agreement Area: Period of Performance Questioned Costs: $4,343 Contact Person(s): Program Administrator, Director of DGFI, and Chief Financial Officer Corrective Action Plan: CHCC does not concur the findings and the questioned cost. The transaction cited were for emergency repairs of Vaccine Refrigerators. The repairs were done within the period of performance ending June 30, 2020 ($2,990 was for Service date of December 20, 2019; and $1,353 was for service date February 28, 2020). No purchase order was prepared for the emergency service. A ratification memo was approved for payment processing by the Chief Financial Officer and the Chief Executive Officer. CHCC believes that the repairs on the Refrigerators that are used to store vaccines are reasonable and necessary, especially during the period wherein CHCC was responding to the COVID-19 Proposed Completion Date: On-going

View Audit 392188

Finding 1175575 (2020-008)

Material Weakness 2020

Dewey County

OK

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.317 § 200.318 § 200.327 § 200.84

The County will make sure that all federal documentation is maintained by each district for inspection and will ensure it is accurately reported on the SEFA.

View Audit 389362

Finding 1175574 (2020-007)

Material Weakness 2020

Dewey County

OK

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

The County will include discussion of all required compliance requirements for each federal program presented in our Officers’ meetings.

View Audit 389362

Finding 1175573 (2020-006)

Material Weakness 2020

Dewey County

OK

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

The County will include all federal grant discussion in our Officers’ meetings so that all Elected Officials are aware. We will discuss the Control Environment, Risk Assessment, Information and Communication, and Monitoring for all federal grants.

View Audit 389362

Finding 1175572 (2020-005)

Material Weakness 2020

Dewey County

OK

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions § 200.303 § 200.317 § 200.318 § 200.327 § 200.84

I am aware of the audit findings involving FEMA Disaster 4315. I apologize for the delayed response letter. On behalf of Dewey County District 2, we want to assure you we are here to help and assist in anything you or your office may need from myself, or from any District 2 employee.

View Audit 389362

Finding 1173827 (2020-005)

Material Weakness 2020

Rhode Island Disaster Medical Assistance Team, Inc.

RI

Period of Performance Allowable Costs / Cost Principles

Implement or strengthen review procedures to ensure all costs charged to federal awards are incurred within the approved performance period by February 28, 2026. Train personnel responsible for grant accounting on the importance of verifying dates of service, invoice dates, and award period limitati...

Implement or strengthen review procedures to ensure all costs charged to federal awards are incurred within the approved performance period by February 28, 2026. Train personnel responsible for grant accounting on the importance of verifying dates of service, invoice dates, and award period limitations by March 31, 2026. Consider implementing system-based controls that prevent posting expenditures with dates outside the award period, including automated alerts and approval workflows by April 30, 2026. Establish a grant closeout checklist that includes verification of all expenditure dates and identification of any costs incurred after the period of performance by May 31, 2026. Conduct monthly reviews of pending expenditures during the final quarter of each award period to identify and prevent late charges by June 30, 2026.

View Audit 387509

Finding 1173826 (2020-004)

Material Weakness 2020

Rhode Island Disaster Medical Assistance Team, Inc.

RI

Allowable Costs / Cost Principles Cash Management

Implement or strengthen review procedures to ensure all costs charged to federal awards are supported by appropriate documentation by February 28, 2026. Provide training to staff responsible for grant accounting to ensure understanding of federal documentation requirements, including Uniform Guidanc...

Implement or strengthen review procedures to ensure all costs charged to federal awards are supported by appropriate documentation by February 28, 2026. Provide training to staff responsible for grant accounting to ensure understanding of federal documentation requirements, including Uniform Guidance standards for allowable costs by April 30, 2026. Establish a pre-payment review process requiring verification of supporting documentation before expenditures are processed and charged to federal awards by May 31, 2026. Develop and implement an expenditure approval checklist documenting review of allowability, allocability, reasonableness, and supporting documentation by June 30, 2026.

View Audit 387509

Finding 1161837 (2020-005)

Material Weakness 2020

City of Mount Vernon

NY

Questioned Costs Allowable Costs / Cost Principles Material Weakness § 200.430

Management Response: Due to turnover program pay records such as timesheets and equivalent documentation could not be located. The missing files had been stored on a drive maintained by a former employee and could not be recovered. The City implemented a records retention policy in 2023 and establis...

Management Response: Due to turnover program pay records such as timesheets and equivalent documentation could not be located. The missing files had been stored on a drive maintained by a former employee and could not be recovered. The City implemented a records retention policy in 2023 and established a system to ensure that all documentation supporting expenditures is properly gathered, organized, and retained in compliance with federal requirements.

View Audit 371774 Questioned Costs: $1

Finding 1159773 (2020-008)

Material Weakness 2020

Program of Academic Exchange

NY

Questioned Costs Allowable Costs / Cost Principles § 200.430

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 will, going forward, establish an effort verification reporting system. This system will accurately capture the effort spent by each employee on specific grants, ensuring proper allocation of wages and salaries to the respective federal awards. Dije Kucana, Comptroller, effective immediately

View Audit 370332 Questioned Costs: $1

Finding 573285 (2020-006)

Material Weakness 2020

Richmond Housing Authority

CA

HUD Housing Programs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

The recommendations have since been addressed and implemented. The Authority maintains a comprehensive list of all owned and insured assets within our Asset Repositioning strategy document. The Housing Authority will establish an electronic filing system to securely store all declarations of trust. ...

The recommendations have since been addressed and implemented. The Authority maintains a comprehensive list of all owned and insured assets within our Asset Repositioning strategy document. The Housing Authority will establish an electronic filing system to securely store all declarations of trust. In accordance with PHI Notice 2014-14, the Housing Authority will formally request the release of the Declaration of Trust (DOT) from HUD prior to the closing or transfer of the title of any public housing property.

View Audit 364071

Finding 573281 (2020-002)

Material Weakness 2020

Richmond Housing Authority

CA

Questioned Costs Allowable Costs / Cost Principles

The Authority staff will follow the City’s processes by having management review invoices/charges for approval then will be scanned and attached to the payment records in MUNIS.

View Audit 364071 Questioned Costs: $1

Finding 565329 (2020-004)

Material Weakness 2020

Native Village of Paimiut

AK

Allowable Costs / Cost Principles Special Tests & Provisions § 200.302

Management will work with their consultant and develop written policies and procedures over their federal awards in accordance with the requirements of the Uniform Guidance.

View Audit 359155

Finding 525045 (2020-009)

Material Weakness 2020

Consortium of Universities for the Advancement of Hydrologic Science, Inc.

MA

Cash Management Allowable Costs / Cost Principles Eligibility § 200.307

Finding Reference Number: MW2020-009 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately ...

Finding Reference Number: MW2020-009 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2020 program income. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI uses a single payment gateway to segregate payments appropriately per event and per grant. Program income for subsequent years has been reported to NSF annually and appropriate staff and policies are in place to ensure future compliance. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

View Audit 344351

Finding 525040 (2020-004)

Material Weakness 2020

Consortium of Universities for the Advancement of Hydrologic Science, Inc.

MA

Allowable Costs / Cost Principles Reporting § 200.512

Finding Reference Number: MW2020-004 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI is curr...

Finding Reference Number: MW2020-004 Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: NA Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI is currently delinquent on the filing of audits from fiscal years 2020-2023. The organization is treating audit filings as the top priority and is working carefully through the audit backlog with qualified auditors that are currently engaged for audits 2020-2022. The delays in filing will continue into calendar year 2025, at which time it is expected that the audit package for the year ended December 31, 2024 will be filed on time to the Federal Audit Clearinghouse. Changes to CUAHSI’s accounting system, personnel, duties, and processes help ensure future audit preparation and support are streamlined, accurate, and timely. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: 2025-09-30

View Audit 344351

Finding 519935 (2020-005)

Material Weakness 2020

Health & Education Housing Service, INC

MA

Internal Control / Segregation of Duties HUD Housing Programs Reporting

2020-005 - Reporting - Material Weakness Recommendation: Management should ensure timely completion of a Uniform Guidance audit, as required. Action Taken: Historically, Uniform Guidance Data Collection Form submissions were scheduled by the sponsor. In April 2019, the management agent experienc...

2020-005 - Reporting - Material Weakness Recommendation: Management should ensure timely completion of a Uniform Guidance audit, as required. Action Taken: Historically, Uniform Guidance Data Collection Form submissions were scheduled by the sponsor. In April 2019, the management agent experienced significant staff turnover including the Chief Financial Officer. The Entity's fiscal year fiscal year 2019 closed shortly thereafter. Management Agent Staff were unaware the required fiscal year 2019 and subsequent audit(s) had not been scheduled by the Sponsor; Covid 19 hit shortly thereafter. This issue went unaddressed throughout the pandemic, followed by the resignation of the Management Agent Accounting Manager in 2021, a position that remained vacant for nearly a year. The Management agent engaged with a CPA firm to conduct the 2019, 2020 and 2021 audits.

View Audit 339371

Finding 519932 (2020-002)

Material Weakness 2020

Health & Education Housing Service, INC

MA

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

2020-002 - Allowable Costs/Cost Principles - Material Weakness Recommendation: We recommend that HES develop and implement procedures and controls to ensure management fee payment amounts are in accordance with the management agreement, and we recommend that funds be immediately returned to HES from...

2020-002 - Allowable Costs/Cost Principles - Material Weakness Recommendation: We recommend that HES develop and implement procedures and controls to ensure management fee payment amounts are in accordance with the management agreement, and we recommend that funds be immediately returned to HES from the management agent. Action Taken: This finding resulted from a single mischaracterized sponsor contribution, followed by the subsequent departure of competent accounting staff who could have corrected the issue. Corrective action was taken beginning in fiscal year 2022 when this issue was identified by competent accounting staff during which intercompany balances were reconciled and have been balanced routinely in subsequent fiscal years. The management agent has already taken steps and has repaid the amount in question, with final resolution pending the completion of the audit(s) in question.

View Audit 339371 Questioned Costs: $1

Finding 516471 (2020-009)

Material Weakness 2020

Consortium of Universities for the Advancement of Hydrologic Science, Inc.

MA

Allowable Costs / Cost Principles Cash Management Program Income § 200.307

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific t...

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHSI impacting audit year 2020: CUAHSI uses a single payment gateway for registration on CUAHSI events and was able to accurately document and produce grant-specific totals for audit year 2020 program income. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI uses a single payment gateway to segregate payments appropriately per event and per grant. Program income for subsequent years has been reported to NSF annually and appropriate staff and policies are in place to ensure future compliance. Name of Contact Person: 􀁸 Maureen S. Ako, Director of Finance 􀁸 Telephone: (339)221-5400 􀁸 Email: msabino@cuahsi.org Projected Completion Date: NA; is complete

View Audit 334379

Finding 512851 (2020-001)

Material Weakness 2020

Dairyland Power Cooperative

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

2020 ‐ 001: Material Weaknesses in Internal Controls over Compliance— Activities Allowed and Allowable Costs for Non-payroll expenses, Period of Performance, Reporting, and Special Test and Provisions. Compliance requirement Corrective Action Activities Allowed/Allowable Costs and Period of Perform...

2020 ‐ 001: Material Weaknesses in Internal Controls over Compliance— Activities Allowed and Allowable Costs for Non-payroll expenses, Period of Performance, Reporting, and Special Test and Provisions. Compliance requirement Corrective Action Activities Allowed/Allowable Costs and Period of Performance Microsoft D365 was implemented in 2022 as the ERP system for Dairyland Power. Microsoft D365 will allow for project tracking ensuring appropriate approval workflows specific to federal assistance programs. Workflows will be set to ensure costs are routed to personnel who have authority to approve and also have knowledge of cost allowability as stipulated by the federal award. The system also supports historical data requirements by allowing retention of documents withing the system at the transaction level. The use of the Microsoft D365 ERP will ensure the evidence of approval for non-payroll expenses would be appropriately logged and retained within the system. This corrective action is currently in place. Reporting and Special Test and Provision Dairyland Power has recently established Grant Policies to ensure that internal processes are managed in compliance with federal awards. An Allowable Cost Policy was created to clearly define roles and responsibilities for the management of federal awards and also identifies the review and approval process of reimbursement requests/reports. A multi-layer approval process for the approval of reimbursement exists. The Project manager, in coordination with the Grant Specialist and the Compliance Team, will review federal project costs and prepare reimbursement reports per the instructions. The reimbursement request/report will then be submitted to the Grant Manager, who will review the reimbursement request/report for cost allowability and completeness. Upon approval from the Grant Manager, the reimbursement request will be forwarded to the Treasury Manager who will review, approve, and submit the request through the proper submission channel by the deadline. Evidence of review will be saved for documentation purposes. Dairyland Management will conduct an annual review of the established Grant Policies or reassess them when necessary. Employees at Dairyland who participate in the federal award process will be provided with training on the Grant Policies. This corrective action is currently in place. In addition to the above corrective action, Dairyland Power has also engaged an external audit service to conduct a review of the design and operating effectiveness of Dairyland’s grant process internal controls. The purpose is to provide Dairyland with a comprehensive assessment of the existing Dairyland internal control processes and policies related to federal awards. Expected completion of this audit is January 2025. Anticipated Completion Date — January 2025 Responsible Party — Tim Lightfoot, Controller

View Audit 330601

Finding 508335 (2020-002)

Material Weakness 2020

Elle Foundation

LA

Questioned Costs Allowable Costs / Cost Principles

SSVF Policies and Procedure Guide will be updated at the agency CARF retreat to reflect the process of transactions related to SSVF and updated retention polices and documentation requirements.

View Audit 328911 Questioned Costs: $1

Finding 505140 (2020-003)

Significant Deficiency 2020

Development Bank of American Samoa

AS

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

General Disbursements Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Name of Contact Persons: Faaeteete Sio and Venetta Holi Corrective Action: DBAS will establish a set procedure to follo...

General Disbursements Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Name of Contact Persons: Faaeteete Sio and Venetta Holi Corrective Action: DBAS will establish a set procedure to follow both Finance Department and Loans Department and ensure approval procedures are followed through before loan disbursements are issued. Proposed Completion Date: Ongoing

View Audit 327808

Corrective Action Plans

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