Corrective Action Plans

Finding 406 (2022-003)

Material Weakness 2022

Pioneercare

MN

Reporting Questioned Costs Allowable Costs / Cost Principles § 200.303

Federal Agency Name: U.S. Department of Agriculture Department of Health and Human Services Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Financial...

Federal Agency Name: U.S. Department of Agriculture Department of Health and Human Services Program Name: Community Facilities Loans and Grants Cluster Federal Financial Assistance Listing #10.766 COVID‐19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Federal Financial Assistance Listing #93.498 Finding Summary: Eide Bailly LLP prepared our consolidated schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule. Responsible Individuals: Nathan Johnson, CEO Corrective Action Plan: Having auditors assist with preparing the consolidated schedule of expenditures of federal awards (Schedule) is not unusual. We will continue to be aware of the financial reporting requirements relating to PioneerCare’s consolidated schedule of expenditures of federal awards and internal control that impact financial reporting. Anticipated Completion Date: Ongoing

View Audit 857

Finding 376 (2022-002)

Material Weakness 2022

Flagler County, Florida

FL

Questioned Costs Allowable Costs / Cost Principles

The Financial Services Department implemented a three‐step remedy which included working with the implementing department to insert their director as a review and approval step, improving tracking capabilities by amending internal reporting and documenting support, and changing reimbursement request...

The Financial Services Department implemented a three‐step remedy which included working with the implementing department to insert their director as a review and approval step, improving tracking capabilities by amending internal reporting and documenting support, and changing reimbursement request submittals to a monthly schedule. As stated within the “Effect Section” of the finding, these actions have already been implemented. Contact Person – E. John Brower, Financial Services Director Completion Date – Already implemented

View Audit 797 Questioned Costs: $1

Finding 313 (2022-002)

Significant Deficiency 2022

Palmer Senior Citizens Center, Inc.

AK

Questioned Costs Allowable Costs / Cost Principles

Federal Award Finding: 2022-002 Significant Deficiency in Compliance and Internal Controls over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Heather Grato, Controller Corrective Action: Matsu Senior Center will ensure that they implement policies and procedures to address in...

Federal Award Finding: 2022-002 Significant Deficiency in Compliance and Internal Controls over Compliance - Allowable Costs/Cost Principles Name and Contact Person: Heather Grato, Controller Corrective Action: Matsu Senior Center will ensure that they implement policies and procedures to address internal control over record retention to include move of office. The organization has also hired both a new Finance Manager and Accounting Consultant to aid in creating and implementing policies and procedures. Proposed Completion Date: 06/30/2024

View Audit 588 Questioned Costs: $1

Finding 304 (2022-002)

Significant Deficiency 2022

Caminar Latino Inc.

GA

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

Condition Upon review of the indirect cost calculations throughout the fiscal year, it was noted that there was no documentation of review and approval of three of the seven calculations tested. The auditors were able to review the drawdown reconciliations performed by the Caminar Latino and determi...

Condition Upon review of the indirect cost calculations throughout the fiscal year, it was noted that there was no documentation of review and approval of three of the seven calculations tested. The auditors were able to review the drawdown reconciliations performed by the Caminar Latino and determine the reports were materially accurate; however, no evidence of a formal supervisory review and approval of the reconciliation was maintained on-file in these three instances. Correction action As of Q4 2022, the Atlanta-based Co-CEO and the Chief of Programs and Administration have instituted a process of review and approval of drawdown reconciliations prior to drawdown to review for accuracy of calculations and to ensure that previous drawdown amounts are accurately recorded. A Finance Manager was hired in April 2023, and the responsibility of ongoing drawdown reconciliation and calculation of invoice amounts has shifted to the Finance Manager position. Monthly invoices and drawdowns are being reviewed and approved by the Co-CEO and Chief of Programs and Administration prior to drawdown. Responsible Person Co-CEO and Chief of Programs and Administration Anticipated completion date Completed - This process is currently in place.

View Audit 574

Finding 289 (2022-001)

Material Weakness 2022

Town of Hempstead Housing Authority

NY

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

Finding 2022-00 I - COCC deficit and the use of LIPH funds in violation of HUD Rule Auditee's Response and Planned Corrective Action The Authority is working to gather the information necessary to complete an analysis of the benefits charged to each AMP and COCC for the above referenced finding. T...

Finding 2022-00 I - COCC deficit and the use of LIPH funds in violation of HUD Rule Auditee's Response and Planned Corrective Action The Authority is working to gather the information necessary to complete an analysis of the benefits charged to each AMP and COCC for the above referenced finding. There is a meeting scheduled for October 16, 2023. HUD has been informed regarding the status of the finding. Planned Implementation Date of Corrective Action: December 2023 Person Responsible for Corrective Action: Ed Cumming, Executive Director

View Audit 514

Finding 223 (2022-003)

Significant Deficiency 2022

Five Towns Community Center INC

NY

Questioned Costs Allowable Costs / Cost Principles

FTCC concurs with this finding and will make every attempt to create time studies to support salary allocations in the future.

View Audit 465 Questioned Costs: $1

Finding 218 (2022-001)

Material Weakness 2022

Valor Christian College

OH

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

Comments on Findings and Recommendations: Valor Christian College concurs with the finding and recommendations in the finding. Actions T...

Comments on Findings and Recommendations: Valor Christian College concurs with the finding and recommendations in the finding. Actions Taken or Planned: The Valor Christian College Finance Department and the Valor Christian College CFO will increase controls over the process to ensure that no recruitment advertising expenses are attributed to CARES ACT funds. The amount of orginally atrributed advertising expenses has been reallocated to allowable items/expenses.

View Audit 443

Finding 180 (2022-002)

Significant Deficiency 2022

Guam Housing and Urban Renewal Authority

GU

Subrecipient Monitoring Special Tests & Provisions Allowable Costs / Cost Principles

Finding #2022-002 Emergency Solutions Grant Program Special Tests and Provisions – Obligation, Expenditure and Payment Requirements Views of Responsible Officials and Planned Corrective Action GHURA agrees with the recommendation to review and process payment requests from subrecipients within the...

Finding #2022-002 Emergency Solutions Grant Program Special Tests and Provisions – Obligation, Expenditure and Payment Requirements Views of Responsible Officials and Planned Corrective Action GHURA agrees with the recommendation to review and process payment requests from subrecipients within the 30-day time frame. Responsible Party: Katherine Taitano, Chief Planner, and Jerricho Garcia, General Accounting Supervisor Anticipated Date of Completion: September 30, 2024

View Audit 281

Finding 1241633 (2021-006)

Material Weakness 2021

Commonwealth Healthcare Corporation

MP

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Finding No.: 2021-006 AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Area: Activities Allowed or Unallowed Allowable Cost/Cost Principles Questioned Costs: $-0- Contact Person(s): Chief Financial Officer, Division of Grants and Financial Integrity Corrective Action Plan: CHCC c...

Finding No.: 2021-006 AL Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds Area: Activities Allowed or Unallowed Allowable Cost/Cost Principles Questioned Costs: $-0- Contact Person(s): Chief Financial Officer, Division of Grants and Financial Integrity Corrective Action Plan: CHCC concurs with the findings. Payroll procedures will be revised to review the calculation of any new differential and review of creation and activation of new pay types to ensure that there is no over or underpayment of benefits. Aside from this preventative control, any supplemental payroll for premium payment shall be reviewed by the Comptroller for compliance to the specific regulations before payment processed. Responsible Official: Comptroller and Payroll Proposed Completion Date: 12/31/2026

View Audit 415697

Finding 1240043 (2021-008)

Material Weakness 2021

Akiachak Native Community

AK

Allowable Costs / Cost Principles Material Weakness Reporting § 200.430

Finding 2021-008 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Management will strengthen internal controls over payroll and review personnel files for adequate p...

Finding 2021-008 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Management will strengthen internal controls over payroll and review personnel files for adequate pay rate documentation. Proposed Completion Date: October 31, 2026

View Audit 414657

Finding 1240042 (2021-007)

Material Weakness 2021

Akiachak Native Community

AK

Allowable Costs / Cost Principles Material Weakness Reporting

Finding 2021-007 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Improvements will be made to documentation procedures for payables and cash disbursements to accommo...

Finding 2021-007 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Improvements will be made to documentation procedures for payables and cash disbursements to accommodate the minimum requirements for grant regulations and audit purposes. Proposed Completion Date: October 31, 2026.

View Audit 414657

Finding 1238396 (2021-003)

Material Weakness 2021

Native Village of Shaktoolik

AK

Allowable Costs / Cost Principles Material Weakness

2021-003 – Allowable Costs/Cost Principles – Material Weakness in Internal Control over Compliance Name and Contact Person: Desiree Rock, Tribal Administrator Corrective Action Plan: Management will ensure that personnel action forms are documented and saved in the employee files. Proposed Completio...

2021-003 – Allowable Costs/Cost Principles – Material Weakness in Internal Control over Compliance Name and Contact Person: Desiree Rock, Tribal Administrator Corrective Action Plan: Management will ensure that personnel action forms are documented and saved in the employee files. Proposed Completion Date: December 31, 2025

View Audit 413260

Finding 1228541 (2021-001)

Material Weakness 2021

THE LIGHTHOUSE, INC.

HI

Allowable Costs / Cost Principles HUD Housing Programs Reporting § 200.512

We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.

View Audit 410163

Finding 1228536 (2021-001)

Material Weakness 2021

WELLNESS HOUSE INC

HI

Allowable Costs / Cost Principles HUD Housing Programs Reporting § 200.512

We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.

View Audit 410161

Finding 1228531 (2021-001)

Material Weakness 2021

WELLNESS HOUSE INC

HI

Allowable Costs / Cost Principles HUD Housing Programs Reporting § 200.512

We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.

View Audit 410159

Finding 1228525 (2021-001)

Material Weakness 2021

HONOLULU HOUSE, INC.

HI

Allowable Costs / Cost Principles HUD Housing Programs Reporting § 200.512

We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.

View Audit 410157

Finding 1228520 (2021-001)

Material Weakness 2021

THE NEWHOUSE INC

HI

Allowable Costs / Cost Principles HUD Housing Programs Reporting § 200.512

We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.

View Audit 410155

Finding 1224510 (2021-015)

Material Weakness 2021

Quality Community Health Care, Inc.

PA

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

Criteria Under the Uniform Guidance (2 CFR Part 200, Subpart E), recipients of federal awards must maintain documentation to support costs charged to federal programs, including indirect costs. The documentation should demonstrate that costs are allocable, allowable, and in accordance with the appro...

Criteria Under the Uniform Guidance (2 CFR Part 200, Subpart E), recipients of federal awards must maintain documentation to support costs charged to federal programs, including indirect costs. The documentation should demonstrate that costs are allocable, allowable, and in accordance with the approved indirect cost rate agreement, if applicable. Condition and Context QCHC was unable to provide sufficient records to substantiate costs charged to federal grants. As a result, we were unable to determine the accuracy or allowability of both direct and indirect costs recorded. Furthermore, due to this lack of supporting documentation, we could not verify whether indirect costs were charged, nor could we confirm that any indirect cost calculations were based on an appropriate and complete base of direct costs or were calculated properly in accordance with the approved indirect cost rate agreement. Recommendation We recommend that management implement procedures to ensure that all indirect costs claimed under federal grants are supported by adequate documentation, including detailed allocation methodologies and supporting records, in accordance with federal regulations. Views of Responsible Officials and Planned Corrective Actions QCHC acknowledges the finding and has implemented the following corrective actions: I. QCHC has implemented Section 600- Cost Accounting Policies of the Accounting Manual, which deals with the measurement, assignment and allocation of costs to various cost objectives. 2. QCHC has established Policy 619- Direct and Indirect Costs, which requires that costs benefiting more than one cost objective be consistently treated as indirect costs, and costs necessary for the overall operation of the organization be treated as management and general costs.3. QCHC has implemented the Draw Down Policy & Procedure (Policy #308 DRAWDOWN) which establishes that expenditures of Federal award funds are monitored and allowable in accordance with the terms and conditions of the Federal award and with the federal cost principles in CFR Part 75 Subpart E. 4. QCHC has established Policy 303 - Incurred Cost, which requires that outlays or expenditures represent charges made to the project or program and may be reported on an accrual basis. 5. QCHC has implemented procedures to maintain detailed records of all direct and indirect costs charged to federal grants, including detailed allocation methodologies and supporting records, in accordance with federal regulations.

View Audit 407750

Finding 1224508 (2021-014)

Material Weakness 2021

Quality Community Health Care, Inc.

PA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Criteria In accordance with the Uniform Guidance, the costs charged to federal funds must comply with the cost principles of 45 CFR Part 75, Subpart E, and any other requirements or restrictions on the use of federal funding. Condition and Context QCHC was unable to provide the approval of timesheet...

Criteria In accordance with the Uniform Guidance, the costs charged to federal funds must comply with the cost principles of 45 CFR Part 75, Subpart E, and any other requirements or restrictions on the use of federal funding. Condition and Context QCHC was unable to provide the approval of timesheets and the payroll allocation for 60 selections for payroll control testing. Recommendation We recommend that management implement procedures to ensure that timesheets and related approvals are adequately maintained and supported. Views of Responsible Officials and Planned Corrective Actions QCHC acknowledges the finding and has implemented the following corrective actions: 1. QCHC has implemented Policy 911 - Labor Distribution Reporting, which establishes that charges to awards for salaries and wages, whether treated as direct costs or indirect costs, will be based on documented payrolls approved by a responsible supervisory official. 2. QCHC has established that employees are responsible to use the ADP time clock to record their time worked, with supervisors/managers having full access to monitor their department time in/out and leave. 3. QCHC has implemented the Draw Down Policy & Procedure (Policy #308 DRAWDOWN) which establishes that salary and wage charges are supported by a system of internal controls which provides reasonable assurance that they are accurate, allowable, properly allocated and in compliance with the organization's policies and procedures. 4. QCHC has established that employee timesheets are completed electronically and supervisors approve hours worked which are processed by the Accounts Payable Manager, with a salary allocation maintained to track and reconcile the assignment of the Organization's salaries and wages to all grant programs. 5. QCHC has implemented Policy 917 -Timely Submission of Timesheets and Penalties, which establishes that until an accurate and complete timesheet is submitted to the payroll clerk, an employee will not be paid during that pay cycle.

View Audit 407750

Finding 1224506 (2021-013)

Material Weakness 2021

Quality Community Health Care, Inc.

PA

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

Criteria Recipients of federal grants are required by federal regulations (Uniform Guidance, 2 CPR Part 200) to maintain documentation demonstrating that cash receipts correspond to drawdowns based on actual, allowable costs incurred. Drawdowns for Federal awards should be properly supported with re...

Criteria Recipients of federal grants are required by federal regulations (Uniform Guidance, 2 CPR Part 200) to maintain documentation demonstrating that cash receipts correspond to drawdowns based on actual, allowable costs incurred. Drawdowns for Federal awards should be properly supported with relevant forms and reports to substantiate the costs incurred and evidence management review and approval. Condition and Context For the year ended July 31, 2021, QCHC recorded cash receipts related to their federal awards totaling $3,535,567. However, QCHC was unable to provide evidence that these amounts represent drawdowns from the federal grants. The only available documentation substantiates the receipt of cash, without linking it to eligible grant expenditures. Recommendation We recommend that management establish procedures to ensure that documents supporting all drawdown requests are properly retained. Such requests should also be reviewed and approved prior to the request being made, with this approval documented and retained. Views of Responsible Officials and Planned Corrective Actions QCHC acknowledges the finding and has implemented the following corrective actions: l. QCHC has implemented the Draw Down Policy & Procedure (Policy #308 DRAWDOWN) which establishes that drawdown of Federal funds must be made in accordance with the immediate needs of the award terms, to minimize time between request and expenditures, and funds will not be drawn down 5 business days prior to disbursement. 2. QCHC has established procedures requiring the preparation of a justification table of all staff members allocated to the federal grant fund, division of annual salaries by 26 pay periods per year, and preparation of SF-270 (Request for Advance or Reimbursement). 3. QCHC has established that the Chief Financial Officer is responsible for monitoring program cash flow needs and submitting drawdown requests in a timely manner to assure adequate coverage of program needs. 4. QCHC has implemented a review and approval process requiring the Chief Financial Officer and Chief Executive Officer to review, approve and execute the applicable drawdown. 5. QCHC has established that HRSA expenses are tracked in the accounting system by revenue source fund codes by the HRSA budget name, with accounts receivable related to grants recorded when a copy of the HRSA request is received.

View Audit 407750

Finding 1217409 (2021-001)

Material Weakness 2021

Crater Regional Workforce Investment Board

VA

Eligibility Allowable Costs / Cost Principles

The Crater Regional Workforce Development Board obtained a waiver beginning in PY24 to service the WIOA Title 1 Program (instead of using an outside service provider as was the case for PY21) which has led to additional internal controls including but not limited to: 1. Streamlining of enrollment to...

The Crater Regional Workforce Development Board obtained a waiver beginning in PY24 to service the WIOA Title 1 Program (instead of using an outside service provider as was the case for PY21) which has led to additional internal controls including but not limited to: 1. Streamlining of enrollment to a singular assigned staff who has been trained specifically around enrollment/eligibility criteria. 2. Review of every enrollment by CRWDB leadership staff directly after enrollment to identify and correct any missing information. 3. Audit of every file open during the course of a program year at least 2 times during that PY by staff other than the staff who completed the initial enrollment.

View Audit 403603

Finding 1217317 (2021-007)

Material Weakness 2021

Country Doctor Community Health Centers

WA

Allowable Costs / Cost Principles Cash Management Questioned Costs § 200.403

2021-007 Cash Management Corrective action planned: Drawdown Support and Timing: Processes have been implemented to ensure all drawdowns are supported by adequately documented, individually identifiable expenditures and are made only after costs have been incurred. Documentation Standards: Standard ...

2021-007 Cash Management Corrective action planned: Drawdown Support and Timing: Processes have been implemented to ensure all drawdowns are supported by adequately documented, individually identifiable expenditures and are made only after costs have been incurred. Documentation Standards: Standard requirements are now in place to maintain complete supporting documentation for each draw, including linkage to underlying expenses. Review and Approval Controls: Formal review procedures have been established, requiring documented evidence of supervisory review and approval prior to submission of draw requests. Anticipated completion date: Completed in 2022 Contact person responsible for corrective action: Angela Treptow, Interim Finance Director

View Audit 403489

Finding 1214952 (2021-004)

Material Weakness 2021

HOUSING AUTHORITY OF THE CITY OF LITTLE ROCK, ARKANSAS

CA

Allowable Costs / Cost Principles Questioned Costs Special Tests & Provisions

Finding 2021-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster and Public and Indian Housing Program Assistance Listing Numbers: 14.871, 14.879, and 14.850 Material Noncompliance Non Compliance Material to the Financial Statements: Y...

Finding 2021-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster and Public and Indian Housing Program Assistance Listing Numbers: 14.871, 14.879, and 14.850 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, 2022.

View Audit 401726

Finding 1213652 (2021-002)

Material Weakness 2021

City of Soap Lake

WA

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.318

Finding ref number: 2021-002 Finding caption: The City did not have adequate internal controls for ensuring compliance with procurement requirements and charged expenditures that lacked support for the Water and Waste Disposal Systems for Rural Communities program. Name, address, and telephone of Ci...

Finding ref number: 2021-002 Finding caption: The City did not have adequate internal controls for ensuring compliance with procurement requirements and charged expenditures that lacked support for the Water and Waste Disposal Systems for Rural Communities program. Name, address, and telephone of City contact person: Peter Sharp, 239 2nd Ave SE, Soap Lake, WA 98851, 509-246-1211 Corrective action the auditee plans to take in response to the finding: The City acknowledges that due to staff turnover during this period, federal procurement policies, documentation for professional services and other service fees could not be located during the audit. The City will immediately study these issues and implement comprehensive corrective measures: Corrective Actions: Procurement Documentation and Monitoring: 1. Comprehensive Procurement Policy Review and Revision – The City will conduct an immediate review of existing procurement policies against federal requirements (2 CFR Part 200, Subpart D) to identify all gaps. The City will revise and adopt updated procurement policies that conform to the most restrictive requirements and include all required procedures for: • Solicitation and award procedures for public works contracts • Small purchase quotation requirements • Architectural and engineering services procurement procedures • Piggyback purchasing authorization and procedures • Cost and price analysis requirements • Bonding requirements for construction contracts • All other required procurement procedures under federal regulations 2. Standards of Conduct Policy Development – The City will immediately develop and adopt written standards of conduct procedures as required by federal regulations (2 CFR Part 200.112), establishing conflict of interest policies and certification requirements for all City officials and employees involved in federal award transactions. 3. Staff Training and Certification – Implement mandatory training for all procurement personnel and department heads to ensure full understanding and compliance with updated policies. All staff will be required to acknowledge and certify compliance with standards of conduct policies. 4. Establish a system to review and document compliance with procurement policies on all federally-funded transactions, including periodic audits to verify conformance. Financial Controls and Documentation: - Established comprehensive document retention policies requiring all expenditure supporting documentation to be maintained for the required retention period - Implemented approval workflows requiring supervisory review of all federal grant expenditures before payment Federal Grant Management: - Developing formal federal grant administration procedures compliant with 2 CFR Part 200 Uniform Guidance requirements - Established pre-approval processes for all federal program expenditures - Implemented monthly reconciliation procedures for all federal grant activities - Will establish quarterly internal compliance reviews to ensure ongoing adherence to federal requirements Anticipated date to complete the corrective action: Q1 2026

View Audit 400574

Finding 1213600 (2021-002)

Material Weakness 2021

Richmond Housing Authority

CA

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

Finding Reference Number: SA2021-002: Lack of Supporting Documentation for Expenditures Assistance Listing Number: 14.850 Assistance Listing Title: Public and Indian Housing Name of Federal Agency: Department of Housing and Urban Development Contact Person: Antoinette Terrell, Executive Director Cor...

Finding Reference Number: SA2021-002: Lack of Supporting Documentation for Expenditures Assistance Listing Number: 14.850 Assistance Listing Title: Public and Indian Housing Name of Federal Agency: Department of Housing and Urban Development Contact Person: Antoinette Terrell, Executive Director Corrective Action Plan: Staff have implemented procedures requiring that all invoices, contracts, purchase orders, and supporting records be scanned and attached in MUNIS at the time of processing. A new review workflow ensures supervisory approval before expenditures are charged to federal funds. The Authority is conducting retroactive file recovery where possible and implementing staff training on documentation requirements under 2 CFR Part 200. These improvements will ensure expenditures are fully supported, allowable, and readily accessible for audit. Completion Date: May 1, 2023

View Audit 400515

Corrective Action Plans

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