Corrective Action Plans

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The District will reconcile the Human Resources spreadsheet to the Grant Information to the payroll information entered into Skyward. Currently underway checking personnel by personnel, initiating needed updates and changes.
The District will reconcile the Human Resources spreadsheet to the Grant Information to the payroll information entered into Skyward. Currently underway checking personnel by personnel, initiating needed updates and changes.
The District will reconcile the Human Resources spreadsheet to the Grant Information to the payroll information entered into Skyward. Currently underway checking personnel by personnel, initiating needed updates and changes.
The District will reconcile the Human Resources spreadsheet to the Grant Information to the payroll information entered into Skyward. Currently underway checking personnel by personnel, initiating needed updates and changes.
The District will use the Federal Uniform Grant guidance to ensure that the all costs are allowable. Any individual that is charged to a federal grant will keep time and effort reporting documentation.
The District will use the Federal Uniform Grant guidance to ensure that the all costs are allowable. Any individual that is charged to a federal grant will keep time and effort reporting documentation.
Name of Contact Person: Paul Taylor, Superintendent. Recommendation: We recommend the District implement internal controls to ensure their procurement policy is followed. We also recommend updating their contracts with all required language, including the Buy American clause. Correction Action: We w...
Name of Contact Person: Paul Taylor, Superintendent. Recommendation: We recommend the District implement internal controls to ensure their procurement policy is followed. We also recommend updating their contracts with all required language, including the Buy American clause. Correction Action: We will implement internal controls to ensure our procurement policy is followed. We will also update our contracts with all required language, including the Buy American clause. Proposed Completion Date: Immediately.
Recommendation: We recommend that the District implement procedures and controls to ensure that only eligible students are included on the MARSS listing. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The ...
Recommendation: We recommend that the District implement procedures and controls to ensure that only eligible students are included on the MARSS listing. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to work on establishing procedures and controls to ensure that only eligible students are included on the MARSS listing. Official Responsible for Ensuring CAP: Tanner Spawn, Business Manager. Planned Completion Date for CAP: June 30, 2026.
Recommendation: We recommend that the District implement procedures and controls to ensure the journal entries are accurate before posting. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will ...
Recommendation: We recommend that the District implement procedures and controls to ensure the journal entries are accurate before posting. Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to the Finding: The District will continue to work on implementing procedures and controls to ensure all journal entries are reviewed and accurate before posting. Official Responsible for Ensuring CAP: Tanner Spawn, Business Manager. Planned Completion Date for CAP: June 30, 2026.
Corrective Action Plan 2 CFR § 200.511(c) December 3, 2025 U.S. Department of Environmental Protection The Connecticut Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent accounting firm: Seward and M...
Corrective Action Plan 2 CFR § 200.511(c) December 3, 2025 U.S. Department of Environmental Protection The Connecticut Department of Public Health respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent accounting firm: Seward and Monde, 296 State Street, North Haven, CT 06473 Audit Period: July 1, 2024 – June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Federal Award Finding No. 2025-001 – Cash Management Auditors’ Recommendation: DPH should continue its efforts to timely review transactions initially recorded to base grant SIDs, reclassify those expenditures and initiate the drawdown request. DPH should ensure that federal drawdowns align with the immediate cash needs to administer the program. Planned Corrective Action: The Department has since initiated reconciliation of the accounts to ensure that all expenditures are aligned with their proper set-aside awards as well as beginning to drawdown from respective set-aside accounts. Anticipated Completion Date: June 30, 2026 Official responsible for implementation of corrective action plan: Chukwuma Amechi, Fiscal Administrative Manager 2 CT Department of Public Health (860) 509-7233
2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurr...
2025-001 Costs Incurred Beyond the Period of Performance Criteria: According to 2 CFR §§200.1, 200.308, 200.309, 200.344, and 200.403(h), a non-Federal entity may only charge allowable costs incurred during the approved budget period of the Federal award’s period of performance, and any costs incurred before the Federal award was made that were authorized by the Federal awarding agency or pass-through entity. All financial obligations incurred under the Federal award must be liquidated within the required time period. Costs incurred outside the approved period of performance are unallowable and constitute questioned costs. Client’s Response: During the grant cycle, the Organization submitted for an extension but did not receive confirmation of said extension. During the current fiscal year, the Organization has implemented additional controls to ensure that all grant funding is expended within the timeframe allotted. Proposed Implementation Date – 12/31/2025 Name of Contact Person – John Edwards, Sr. Email: jledwards@umadaop.org Phone: 419-255-4444
Finance department will set up the coding process and begin including Departments that match project codes for all federal programs. Corrective Action Owner: Lisa Peacock, Comptroller with assistance from the Senior Accountant, and report to Francesca Rattray, CEO
Finance department will set up the coding process and begin including Departments that match project codes for all federal programs. Corrective Action Owner: Lisa Peacock, Comptroller with assistance from the Senior Accountant, and report to Francesca Rattray, CEO
Management will review the claims list for completeness and accuracy before presenting the list to the board for approval.
Management will review the claims list for completeness and accuracy before presenting the list to the board for approval.
Management will review the claims list for completeness and accuracy before presenting the list to the board for approval.
Management will review the claims list for completeness and accuracy before presenting the list to the board for approval.
Condition: The Intermediate School District (ISD) did not have internal controls in place to ensure that all the expenditures included in the quarterly claims for reimbursement were allowable. Planned Corrective Action: The ISD will review the process used by the local districts to report quarterly ...
Condition: The Intermediate School District (ISD) did not have internal controls in place to ensure that all the expenditures included in the quarterly claims for reimbursement were allowable. Planned Corrective Action: The ISD will review the process used by the local districts to report quarterly expenditures for the Administrative Outreach program. We will then create a process that ensures that the local districts provide supporting documentation that allows us to monitor the quarterly submission amounts for accuracy. Contact person responsible for corrective action: Chris Frank, Asst. Superintendent for Business Anticipated Completion Date: 1/31/2026
Auditor Description of Condition and Effect: During testing, we identified 1 instance out of 40 disbursement selections tested in which the District was unable to provide supporting documentation for charges incurred under the grant. Additionally, we noted 15 instances out of 40 selections tested wh...
Auditor Description of Condition and Effect: During testing, we identified 1 instance out of 40 disbursement selections tested in which the District was unable to provide supporting documentation for charges incurred under the grant. Additionally, we noted 15 instances out of 40 selections tested where the District could not provide evidence of review and approval for grant expenditures. Finally, we identified 3 instances out of 40 selections tested where the hours reported on timesheets did not agree with the hours charged to the grant. The District’s failure to maintain supporting documentation for certain grant expenditures, provide evidence of review and approval, and accurately report time charged to the grant increases the risk of noncompliance with federal requirements under 2 CFR Part 200. These deficiencies create an increased risk of questioned costs which could ultimately lead to disallowed costs and the potential repayment of grant funds to the granting agency. Additionally, inaccurate reporting and weak internal controls diminish the reliability of financial information submitted to the grantor, reduce accountability, and heighten the risk of errors or fraudulent activity. Auditor Recommendation: We recommend that the District review its written policies and procedures over federal awards to ensure that controls are in place that will require that all expenditures for either payroll or disbursements have the appropriate documentation and evidence of review and approval prior to payment. Corrective Action: The District will review its written policies and procedures over federal awards to ensure that all expenditures have the appropriate documentation and evidence of review and approval prior to payment. Responsible Person: Maria Gistinger, Interim Chief Financial Officer Anticipated Completion Date: June 30, 2026
The Authority immediately implemented enhanced financial control measures to strengthen oversite of not only the accounts payable process, but the financial operations. These measures include the adoption of dual control for all ACH transactions, ensuring that no single individual has unilateral aut...
The Authority immediately implemented enhanced financial control measures to strengthen oversite of not only the accounts payable process, but the financial operations. These measures include the adoption of dual control for all ACH transactions, ensuring that no single individual has unilateral authority to initiate and approve electronic payments or to issue paper checks. Prior to any payments being processed, the Chief Executive Officer (CEO) receives a preliminary invoice listing for review and approval. New vendor requests (typically provided by procurement) are processed by the finance department; and, in addition to the required W-9, their standing on Sunbiz.org is reviewed and documented in their vendor file. All documents provided by the new vendor are saved electronically and attached to their vendor file in the Authority's software. Additionally, new financial control policies were adopted by the Palatka Housing Authority's Board of Commissioners at their December 16, 2025 meeting. The new policy follows HUD's financial management training resource suggestions and the finance staff will meet monthly with the CEO to review current financials. All staff will be trained on the new policies by January 31, 2026 providing everyone with the updated requirements. The Authority has also hired an Interim Chief Financial Officer with over 20 years of public housing accounting experience and is actively searching for a permanent staff accountant and CFO, thus ending the fee accountant contract. This brings all accountability back to the in-house team. If the Department of Housing and Urban Development has questions regarding this plan, please contact Oche Bridgeford, Executive Director at (386) 329-0132.
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Findin...
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2025-002 (a) Comments on the Finding and Recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action Taken - The Authority will establish internal tracking and reminder systems to ensure all required reports, including the final P&E and AMCC, are completed and submitted to HUD by the required due dates. Grant reporting responsibilities will be clearly assigned, and submission deadlines will be monitored by the Director of Finance to prevent future delays. These procedures will be implemented immediately. (c) Planned Implementation Date - The Authority plans to implement procedures during the year ending March 31, 2026 to resolve the reported finding.
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: We have implemented a new policy that requires the Superintendent to review and sign-off on all outgoing EFT and ACH payments. We have implemented a new policy that requires the Superintendent to review and sign-off on all bank statements. Respons...
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: We have implemented a new policy that requires the Superintendent to review and sign-off on all outgoing EFT and ACH payments. We have implemented a new policy that requires the Superintendent to review and sign-off on all bank statements. Responsible Party(ies): • Superintendent and Board of Education Anticipated Completion Date: June 30, 2026
Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Alth...
Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Although the Organization calculated the capped allowable salaries for each employee, the allocations entered into the payroll system reflected full gross wages rather than the capped amounts, resulting in the excess salaries. Individual(s) Responsible for Corrective Action: Philip Kneer, CFO Brandon Gilbert, Corporate Compliance Officer / Co-Director of HR April Bledsoe, / Co-Director of HR Planned Corrective Action: Integrate automatic HRSA salary cap checks into payroll and HRIS systems. Create salary cap flags that prevent or warn when charges exceed allowable rates. Implement quarterly salary compliance audits comparing employee salaries to HRSA limits. Anticipated Completion Date: Update payroll system control within the HRIS/Payroll system by February 28, 2026 First quarterly salary compliance audit to be completed by February 26, 2026
Finding 2025-001: Allocation Documentation – Significant Deficiency in Internal Control over Allowable Costs/Cost Principals Name of Contact: Lisa Pearce, Business Manager Corrective Action Plan: To ensure payroll costs charged to multiple federal funds are properly reviewed, approved, and documente...
Finding 2025-001: Allocation Documentation – Significant Deficiency in Internal Control over Allowable Costs/Cost Principals Name of Contact: Lisa Pearce, Business Manager Corrective Action Plan: To ensure payroll costs charged to multiple federal funds are properly reviewed, approved, and documented in compliance with federal, state, and institutional regulations. This procedure ensures transparency, accuracy, and appropriate record retention. Reviews allocation documents; ensures proper coding. Scope: Applies to all employees whose salary or wages are distributed across two or more federal grants, cost centers, or funding sources. Responsibilities: Grant Manager/Project Director • Reviews and certifies accuracy of payroll allocations based on actual effort. • Completes Grant application according to determined allocations. • Verifies compliance with grant requirements/restrictions Business Manager • Reviews allocation documents; ensures proper coding • Verifies compliance with funding requirements/restrictions; maintains documentation for audit and retention Payroll Specialist • Processes approved changes to payroll distribution. * All approvals should be dated and signed (electronic or physical signature). Documentation and Retention: • File the following documents together: o Approved Payroll Allocation Form o Effort certification or time/effort report o Any related correspondence or justification memo. • Retain for at least 3 years after the final expenditure report for the relevant federal award, or longer if required by grantor. Periodic Review: • Conduct at least semi-annual reviews to confirm payroll allocations reflect actual work performed. • Adjust allocations as necessary and re-document approvals. Proposed Completion Date: This procedure was established in the first quarter of FY26. Full implementation of the procedure will be complete by end of FY26 Respectfully Submitted: Lisa Pearce 11/12/2025 ____________________________ __________________________ Lisa Pearce Date Business Manager
Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that ...
Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that these assessments were not formalized or consistently documented in a standardized format, as required by 2 CFR § 200.332(c). To address this gap, BRAC USA will develop and implement written procedures and a standardized subrecipient risk assessment tool to be completed and filed prior to issuing Federal subawards. The tool will capture required criteria, including prior audit results, prior performance under similar awards, financial stability indicators, internal control considerations, and any recent staffing or systems changes. These procedures will be incorporated into BRAC USA’s Fiscal Policies and Procedures Manual. The results of each risk assessment will be used to tailor the level and nature of ongoing subrecipient monitoring, and records will be maintained in the grant file to evidence compliance with 2 CFR § 200.332(c). Planned Completion Date: April 30, 2026
Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk tha...
Corrective Action Plan Finding Reference: 2025-001 – Allowable Activities/Allowable Costs Federal Program: CFDA 84.010 – Title I Fiscal Year Ended: June 30, 2025 Corrective Action Plan Condition The audit identified weaknesses in internal controls over payroll charges to Title I, creating a risk that costs may be charged to the program in error. Root Cause Although program coding is built into the payroll system during employee setup, controls were not consistently documented or monitored, particularly for staff working across multiple funding sources and for private school Title I employees. A lack of secondary review allowed for one miscoding error and inconsistent position information between contracts and timesheets. Corrective Actions to Be Taken 1. Payroll Coding Review: Implement a second-level review process, led by the Business Manager, to verify all federal program payroll coding each pay period before submission. 2. Position Alignment: Require a monthly reconciliation of contracted positions against timesheet records to ensure consistency. 3. Private School Documentation: Effective immediately, require written wage documentation from private schools for all Title I-funded employees, with documents retained for audit purposes. 4. Update the written procedures related to federal and state funded payroll charges and provide refresher training for payroll and program staff by December 31, 2025. Responsible Officials - Business Manager – Oversight and monitoring of corrective actions - HR/Payroll Specialist – Implementation of payroll coding and reconciliation procedures - Title I Coordinator – Verification and retention of private school documentation Completion Date All corrective actions will be fully implemented by December 31, 2025. Monitoring and Sustainability The District will conduct quarterly internal reviews of Title I payroll activity, maintaining a monitoring log, requiring time and effort sheets and retaining documentation in the business office. Annual refresher training will be provided to ensure ongoing compliance with federal requirements. Views of Responsible Officials The District concurs that stronger documentation and monitoring are necessary. Program coding is established in the payroll system during employee setup, and controls exist to ensure proper allocation. The purpose of the timeclock system is to log hours. The issue arose due to insufficient secondary review rather than the absence of program coding. Immediate corrective measures have already been taken, and the District is committed to implementing the above actions to ensure full compliance with 2 CFR 200.303 and 2 CFR 200.430(g).
Following the district's normal grant process with ESSER III was very difficult. ESSER III was a three-year grant. This made the process of reviewing, monitoring and amending extremely difficult. Using a normal year-to-year grant process, with carryover and a new application each year, the district ...
Following the district's normal grant process with ESSER III was very difficult. ESSER III was a three-year grant. This made the process of reviewing, monitoring and amending extremely difficult. Using a normal year-to-year grant process, with carryover and a new application each year, the district could have avoided the issues that led up to this finding. That being said, the district will implement a process that allows for improved planning for expenditures and an improved monitoring of the approved budget. Through proper planning, the "last-minute" spending would be avoidable. In addition to improving the planning process, the district has implemented monthly meetings between the Director of Business Services and the Federal Programs Director. The focus of these meetings will be to complete a monthly review of planned expenses, recorded expenses, the general ledger budget within our accounting system and the budget approved in Nexsys. This monthly review, will allow the district to ensure that expenditures are classified and recorded properly. This also allows for spending to align with the approved budgets for all federal grants. This process is in addition to the approval process that is in place within the district's accounting sysem, Munis. All expenses are approved by building administrators, central office, the Business Director and then, finally, the Shepherd Board of Education as the final approval. The planned monthly meeting process for the monthly review of our federal grants will have the most impact on continued improvement of the district's internal control process.
Finding 2025-002 Lack of Internal Controls over Activities Allowed and or Unallowed and Allowable Costs/Activities – Cash Disbursements Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD will modify the written credit card policy that details rules for using the c...
Finding 2025-002 Lack of Internal Controls over Activities Allowed and or Unallowed and Allowable Costs/Activities – Cash Disbursements Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: YFSD will modify the written credit card policy that details rules for using the card, which includes employees taking responsibility for the use of the credit card and for the safekeeping of the credit card. Credit cards will be limited to the Superintendent, BOE President and the Academic Director. The cardholder will follow the general purchasing processes that begin with approval to purchase. Procedures for reporting credit card use with monthly reconciliations with receipts will be shared with cardholders. DocuSign will be used for electronic signature approval. Proposed Completion Date: Implemented July 1, 2025.
Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which...
Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which is updated every time a vendor payout is made and tracks that payment to the reimbursement request and the final payment by the pass-through agency. This process ensures that a payout is not included in a payout request multiple times. The Staff Accountant also maintains a tracker of all reimbursement requests to track with the program budgets and for inclusion in the MIP accounting system. In addition, new personnel are involved in the process with a more formal approval and authorization process implemented. The Organization’s staff has communicated these duplicate requests to the appropriate personnel at the granting agency and are coordinating the repayment of the excess funds as determined by the granting agency. Contact person responsible for corrective action: Tom Sakos, Chief Financial Officer, and Jenny Cuitiva, Accounting Manager Anticipated Completion Date: May 1, 2025 for implementing controls and November 30, 2025 for communicating with the granting agency.
Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics...
Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics reports are reviewed before submission. Name of the contact person responsible for corrective action: Lauren Syrup, Business Manager Planned completion date for corrective action plan: June 30, 2026
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services s...
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services staff. • Roles and responsibilities for ConApp enrollment data review have been clarified to prevent future manual errors. Preventive Measures to Avoid Recurrence: 1. Dual Verification of ConApp Enrollment Data • The Accountant in Fiscal Services will now compare and confirm the ConApp enrollment counts to certified CALPADS Fall 1 data before submission and certification. • A second-level review by the Coordinator of Teaching and Learning Department certifying the ConApp. 2. Documentation & Recordkeeping • Any adjustments to pre-populated enrollment numbers will require written justification and supporting documentation (e.g., CALPADS reports, email confirmations). Responsible Parties: • Fiscal Services Accountant – Responsible for matching the ConApp enrollment counts to CALPADS Fall 1 and maintaining backup documentation. • Coordinator, Teaching and Learning Department – Support in verifying site-level data. Completion Date: • Immediate clarification and assignment of review responsibilities were completed in October 2025.
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