Corrective Action Plans

Finding 1169316 (2024-003)

Material Weakness 2024

CITY OF MAYVILLE

ND

Allowable Costs / Cost Principles

Corrective Action Taken or Planned: Grant projects and non-grant projects will not have combined invoices. Contact person(s) responsible for correction action: Gail Olstad, City Auditor Anticipated Completion Date: Quarter 2, prior to the start of the 2025 audit

View Audit 382268

Finding 1169193 (2024-004)

Material Weakness 2024

Colorado Coalition Against Domestic Violence

CO

Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.403

Along with hiring the above consultants, VFC also hired a new Finance, Grants and Administration Manager. This person is now ensuring that all expenditures have receipts and are properly approved by the Interim Executive Director. In addition, revised policies and procedures for both supporting and ...

Along with hiring the above consultants, VFC also hired a new Finance, Grants and Administration Manager. This person is now ensuring that all expenditures have receipts and are properly approved by the Interim Executive Director. In addition, revised policies and procedures for both supporting and approval documentation will be included in the updated accounting policies and procedures manual. The expected completion date is December 31, 2025.

View Audit 382065

Finding 1169192 (2024-003)

Material Weakness 2024

Colorado Coalition Against Domestic Violence

CO

Allowable Costs / Cost Principles § 200.302

See response to finding 2024-001 for information about newly hired consultants. The budget vs. actual reports are now being prepared on a regular basis and documentation will be maintained to demonstrate compliance. The expected completion date is September 30, 2025.

View Audit 382065

Finding 1169126 (2024-001)

Material Weakness 2024

Ontario School District

OR

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

The District will implement a formal review and approval process for indirect charge calculations to ensure that these calculations are consistent with the data recorded in the accounting system. This plan has been implemented during the 24-25 school year.

View Audit 381908

Finding 1169097 (2024-001)

Material Weakness 2024

Boys & Girls Clubs of Indianapolis, Inc.

IN

Allowable Costs / Cost Principles § 200.403

We agree with the recommendation and it was implemented effective 7/1/2025.

View Audit 381850

Finding 1168997 (2024-003)

Material Weakness 2024

Cypress Hills Local Development Corporation, Inc.

NY

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

The issue noted primarily reflects isolated lapses in documentation and oversight during a period of staff transition. Since that time, management has reinforced internal controls over both payroll and non-personnel expenditures to ensure that allocations are properly documented, reviewed, and appro...

The issue noted primarily reflects isolated lapses in documentation and oversight during a period of staff transition. Since that time, management has reinforced internal controls over both payroll and non-personnel expenditures to ensure that allocations are properly documented, reviewed, and approved before posting. In addition, all staff involved in charging costs to federal grants are being retrained on documentation standards and cost allocation procedures. The two OTPS invoices cited by the auditors were for overhead costs (payroll processing fees and general liability insurance) that are allocated based on allocation percentages and typically do not go through a separate approval process. The Agency is reinforcing supervisory review to ensure journal entries are created and approved by separate individuals and the accounting system was updated to prevent all staff members (without exception) from initiating and approving entries.

View Audit 381653

Finding 1168947 (2024-008)

Material Weakness 2024

City of Redondo Beach

CA

Allowable Costs / Cost Principles HUD Housing Programs Significant Deficiency § 200.430

Recommendation: We recommend that the City review and update internal controls to ensure that supporting documentation for allowable time charges to grant programs is properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...

Recommendation: We recommend that the City review and update internal controls to ensure that supporting documentation for allowable time charges to grant programs is properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff has updated timekeeping for individuals charging partial time to the Housing Section 8 program to track actual hours spent rather than through budget allocation. Staff has in addition identified a method by which the City can produce supervisor approval documentation through the financial system’s electronic workflow. Names of the contact persons responsible for corrective action: Stephanie Meyer (Finance Director), Elizabeth Hause (Community Services Director) Planned completion date for corrective action plan: December 30, 2025

View Audit 381471

Finding 1168901 (2024-003)

Material Weakness 2024

Town of Montville, Connecticut

CT

Allowable Costs / Cost Principles Significant Deficiency § 200.334

COVID 19 ARPA Local Fiscal Recovery EXP – Assistance Listing No. 21.027 Recommendation: We recommend the Town design controls to ensure all documentation is retained in accordance with the Uniform Guidance record retention requirements under 2 CFR 200.334. Explanation of disagreement with audit find...

COVID 19 ARPA Local Fiscal Recovery EXP – Assistance Listing No. 21.027 Recommendation: We recommend the Town design controls to ensure all documentation is retained in accordance with the Uniform Guidance record retention requirements under 2 CFR 200.334. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will implement a policy to ensure all documentation is retained in according with Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Julie Chapman, Director of Finance Planned completion date for corrective action plan: December 2025

View Audit 381301

Finding 1168832 (2024-010)

Material Weakness 2024

City of Banning

CA

Allowable Costs / Cost Principles Cash Management Significant Deficiency § 200.303

Finding 2024-010 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds passed-through the State Water Resources Control Board Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: A00059, 2024 Finding Summary: Allowable Cos...

Finding 2024-010 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds passed-through the State Water Resources Control Board Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: A00059, 2024 Finding Summary: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control Corrective Action Plan: Prior to the 2024 audit process being completed, the city experienced significant staff turnover particularly in the Finance Department. The city is in the process of recruiting various key positions including Finance Director, Deputy Finance Director and Accounting Supervisor. This will ensure all proper processes are followed. Responsible Individual(s): Finance Director (short-term part-time staff); Deputy Finance Director (Vacant); Purchasing Manager (Vacant) Anticipated Completion Date: January 2026

View Audit 381038

Finding 1168831 (2024-009)

Material Weakness 2024

City of Banning

CA

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.302

Finding 2024-009 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds passed-through the State ...

Finding 2024-009 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: 2021 Program: COVID-19 Coronavirus State and Local Fiscal Recovery Funds passed-through the State Water Resources Control Board Federal Financial Assistance Listing Number: 21.027 Federal Grantor: U.S. Department of Treasury Award No. and Year: A00059, 2024Finding Summary: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control and Instance of Non-Compliance Corrective Action Plan: The city is in the process of updating its Purchasing Policy and will include language on allowable costs and cost principles that are compliant with Title 2 C.F.R. Section 200. The process may be delayed with the absence of a Purchasing Manager. Responsible Individual(s): Finance Director (short-term part-time staff); Deputy Finance Director (Vacant); Purchasing Manager (Vacant) Anticipated Completion Date: December 2026

View Audit 381038

Finding 1168795 (2024-004)

Material Weakness 2024

Fredonia-Moccasin Unified School District No. 6

AZ

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

2024-004 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS / COST PRINCIPALS Program: Education Stabilization Fund – ESSER II and ESSER III Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21...

2024-004 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS / COST PRINCIPALS Program: Education Stabilization Fund – ESSER II and ESSER III Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111175-01A and 21FESIII-111175-01A Questioned Costs: None Type of Finding: Material weakness in internal controls Condition/Context: For five of seven journal entries tested for the Education Stabilization Fund program, the District did not have documentation supporting that the entry was reviewed and approved by an individual separate from the preparer. Corrective Action: The District will review its process for preparing and recording journal entries to include a step to have the entries reviewed and approved by someone other than the preparer. In addition, the journal entries will include supporting schedules and documentation to explain why the entry is being prepared. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Dorene Mudrow, Superintendent

View Audit 380935

Finding 1168690 (2024-001)

Material Weakness 2024

Oregon Impact

OR

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Finding Reference Number: 2024-001 -Weakness in Controls over Accounting and Financial Reporting Description of Finding: At 6/30/2024 the Organization's current assets are less than its current liabilities, resulting in a deficit in net assets. Analysis found a material weakness in the Organization'...

Finding Reference Number: 2024-001 -Weakness in Controls over Accounting and Financial Reporting Description of Finding: At 6/30/2024 the Organization's current assets are less than its current liabilities, resulting in a deficit in net assets. Analysis found a material weakness in the Organization's controls over identifying and recording vendor bills that resulted in incorrectly omitting allowable costs from program grant expense reimbursement requests. Additionally, the Executive Director performed staff level program functions that were billed at their higher wage rate resulting in payroll costs in excess of allowed budget costs that were disallowed for reimbursement. Not properly identifying and requesting reimbursement for allowable program costs and incurring payroll costs in excess of allowed budgets has strained on the Organization's operating cash flows resulting in deficits and delays in satisfying the accounts payable obligations to the police agencies for which reimbursed funds have been requested. Statement of Concurrence or Nonconcurrence: The Organization agrees with the finding as presented. Corrective Action: The Organization has implemented a dual-review process for all grant expenses to ensure that eligible costs are identified and submitted as a means to reduce misidentification of expenses for allowed activities. Staff will also receive updated training on allowable expense categories to reduce misinterpretation. In monitoring payroll activities, the Organization has revised its grant payroll allocation process to ensure that duties performed under specific roles are billed at the appropriate rate. Future budgets will more clearly distinguish between roles and corresponding pay rates to prevent overages. All projects will undergo budget-to-expense reconciliation on a monthly basis to safeguard against missed claims and ensure that grant resources are maximized without exceeding allowable limits. Name of Contact Person: Janelle Lawrence, Executive Director Phone: 503-303-4954 E-mail: janelle@oregonimpact.org Projected Completion Date: June 30, 2026

View Audit 380665

Finding 1168647 (2024-001)

Material Weakness 2024

HIR Wellness Institute, Inc.

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Views of Responsible Officials at Auditee: We recognize that the necessary documentation was unavailable during the audit. To address this issue, we are collaborating with professionals to ensure that all documentation is properly generated and securely stored for future retrieval of processes that ...

Views of Responsible Officials at Auditee: We recognize that the necessary documentation was unavailable during the audit. To address this issue, we are collaborating with professionals to ensure that all documentation is properly generated and securely stored for future retrieval of processes that we already have in place. We have engaged a new bookkeeping firm to assist us in continuing consistent monthly processes and accurate documentation. Additionally, we are implementing a monthly checklist to track our internal controls, highlighting our ongoing review and approval processes. We will ensure that all expenses are reviewed monthly and approved with initials by either the Chief Executive Officer or Chief Financial & Outreach Officer on invoices and receipts. This review will also encompass all bank and credit card statements. Furthermore, we will ensure that all staff compensation documents are updated and reviewed annually to keep them current. This comprehensive process will form an integral part of our financial internal control checklist. While we have established internal controls, recent staff changes during the audit process made it challenging to locate all necessary documentation. This absence of documentation stemmed from these transitions, and we are actively working to improve our documentation procedures moving forward.

View Audit 380599

Finding 1168608 (2024-003)

Material Weakness 2024

Laurens County, Georgia

GA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.318 § 200.326

Response/Corrective Action Plan: We concur with the finding and will revise the procurement policy as well as the internal control policies and procedures specific to the County to be in alignment with the Uniform Guidance requirements. Upon completion, the new policy will be provided to all departm...

Response/Corrective Action Plan: We concur with the finding and will revise the procurement policy as well as the internal control policies and procedures specific to the County to be in alignment with the Uniform Guidance requirements. Upon completion, the new policy will be provided to all department heads to ensure proper compliance in the utilization and disbursement of federal funds.

View Audit 380517

Finding 1168530 (2024-001)

Material Weakness 2024

Palmyra Area Inter-faith Housing Council and Affiliates

PA

Allowable Costs / Cost Principles HUD Housing Programs Reporting

Management agrees to maintain separate trial balances for the allocation of cash, property and equipment, interest rate swap asset and loans payable between Palmyra Area Interfaith Housing Council and Palmyra Interfaith Manor HUD Project No. 034-EH015. Management notes that this represents a differe...

Management agrees to maintain separate trial balances for the allocation of cash, property and equipment, interest rate swap asset and loans payable between Palmyra Area Interfaith Housing Council and Palmyra Interfaith Manor HUD Project No. 034-EH015. Management notes that this represents a difference of opinion from the prior auditors, who found the financial records of the two entities to be properly reconciled through the use of schedules to separate the council and project’s allocation of cash, property and equipment, interest rate swap asset and loans payable between the Council and the Project for 19 years with no consequence.

View Audit 380368

Finding 1168518 (2024-001)

Material Weakness 2024

The Conservation Innovation Fund

DC

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

Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. This FY 24 Program Audit immediately preceded the FY 25 Single Audit in fall 2025. Given this timi...

Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. This FY 24 Program Audit immediately preceded the FY 25 Single Audit in fall 2025. Given this timing, the earliest possible implementation of corrective action is in FY 26. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements which involves timesheets that record actual time spent on a funding source and are accompanied by supervisorial approvals. This system has been formally documented in the FY 26 update to the CIF Financial Policy and includes annual training for staff responsible for managing payroll allocations and Federal reporting. Charges to Federal awards for salaries and wages are now based on records that accurately reflect the work performed. The records are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The records support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.

View Audit 380327

Finding 1168472 (2024-003)

Material Weakness 2024

Mana Maoli

HI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties HUD Housing Programs § 200.430 § 200.516

Mana Maoli has implemented a practical review and reconciliation step as part of payroll processing. This step compares approved timesheets to payroll register hours to help ensure that payroll allocations to federal programs are based on accurate records. This reconciliation is integrated into the ...

Mana Maoli has implemented a practical review and reconciliation step as part of payroll processing. This step compares approved timesheets to payroll register hours to help ensure that payroll allocations to federal programs are based on accurate records. This reconciliation is integrated into the existing payroll workflow to avoid added administrative burden. Management will conduct periodic reviews of payroll records and refine the process as needed to maintain reasonable assurance of accuracy, recognizing that the goal is continuous improvement. Anticipated completion date: December 31, 2026

View Audit 380292

Finding 1168471 (2024-002)

Material Weakness 2024

Mana Maoli

HI

Allowable Costs / Cost Principles § 200.302 § 200.403

During the FY2024 audit, Mana Maoli began implementing improvements to strengthen documentation practices for federal expenditures. These improvements include: Incorporating a centralized electronic system for retaining invoices, receipts, and other supporting documentation. Reinforcing existing app...

During the FY2024 audit, Mana Maoli began implementing improvements to strengthen documentation practices for federal expenditures. These improvements include: Incorporating a centralized electronic system for retaining invoices, receipts, and other supporting documentation. Reinforcing existing approval procedures as part of the disbursement workflow. Providing targeted staff reminders and guidance on documentation expectations related to federal awards. Conducting periodic spot-checks of documentation to confirm consistency and identify any areas needing clarification. These steps are designed to strengthen controls using the organization’s existing capacity and tools. Mana Maoli will continue monitoring the process and making incremental refinements as needed. Anticipated completion date: June 30, 2026

View Audit 380292

Finding 1168372 (2024-001)

Material Weakness 2024

City of Stevenson

WA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Stevenson January 1, 2024 through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Stevenson January 1, 2024 through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls and did not comply with federal wage rate requirements. Name, address, and telephone of City contact person: Wesley Wootten, City Administrator PO Box 371 Stevenson, WA 98648 509-427-5970 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The City will strengthen oversight of federally funded projects by enhancing internal review and documentation processes. 1. A project compliance tracking form will be created and used for each project to document required wage rate verifications, funding sources, reporting deadlines, and accounting setup. This form will be reviewed and updated annually to ensure compliance with current federal requirements. 2. The City will also create a reimbursement tracking system to monitor project reimbursements and ensure consistency with the SEFA. 3. Staff responsible for project and grant administration will attend training opportunities related to federal compliance and wage rate requirements to ensure continued understanding and adherence. Anticipated date to complete the corrective action: December 31, 2025

View Audit 380170

Finding 1168325 (2024-004)

Material Weakness 2024

Borough of Orwigsburg

PA

Allowable Costs / Cost Principles § 200.403 § 200.405

Finding reference: 2024-004 - Inappropriate Allocation of Expenses The following steps were taken to bring the Borough into compliance. 1. Both the accounting specialist and the Borough Manger have implemented a tracking system to cross reference and monitor compliance of both payments and receipts ...

Finding reference: 2024-004 - Inappropriate Allocation of Expenses The following steps were taken to bring the Borough into compliance. 1. Both the accounting specialist and the Borough Manger have implemented a tracking system to cross reference and monitor compliance of both payments and receipts of all grant funds. 2. Implemented June 2025.

View Audit 380127

Finding 1168319 (2024-002)

Material Weakness 2024

Wickliffe City School District

OH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430 § 200.516

The District Director of Student Services will monitor and make sure that all personnel who serve under federal programs have their time properly documented using semi-annual certification forms or other appropriate time and effort methods.

View Audit 380077

Finding 1168237 (2024-009)

Material Weakness 2024

Heritage University

WA

Allowable Costs / Cost Principles § 200.430

Planned corrective actions: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Heritage continues to work on the process to improve with further training. Name of Respon...

Planned corrective actions: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Heritage continues to work on the process to improve with further training. Name of Responsible Party: 1. Rachel Castijella, Grant Accountant 2. Terri Slack, Fiscal Agent 3. Ivan Banks, Interim Provost 4. Joanne Fernandez, Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

View Audit 380015

Finding 1168229 (2024-008)

Material Weakness 2024

Heritage University

WA

Allowable Costs / Cost Principles § 200.430

Planned corrective actions: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Heritage continues to work on the process to improve with further training. Name of Respon...

Planned corrective actions: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Heritage continues to work on the process to improve with further training. Name of Responsible Party: 1. Rachel Castijella, Grant Accountant 2. Terri Slack, Fiscal Agent 3. Ivan Banks, Interim Provost 4. Joanne Fernandez, Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated completion date: 6/30/2026

View Audit 380015

Finding 1168221 (2024-002)

Material Weakness 2024

Heritage University

WA

Allowable Costs / Cost Principles § 200.430

Planned Corrective Action: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Even though DOE noted that “this finding resolved and closed.”, Heritage continues to work ...

Planned Corrective Action: Heritage implemented a new system, however Heritage continues to encounter mistakes on correctly completing the time & efforts due to the differences in length of faculty contracts. Even though DOE noted that “this finding resolved and closed.”, Heritage continues to work on the process to improve with further training. Name of Responsible Party: 1. Rachel Castijella, Grant Accountant 2. Terri Slack, Fiscal Agent 3. Ivan Banks, Interim Provost 4. Joanne Fernandez, Controller 5. Sagrario Armenta Jimenez, CFO 6. Dr. Christopher Gilmer, President Anticipated Completion Date: 6/30/2026

View Audit 380015

Finding 1168197 (2024-002)

Material Weakness 2024

Detroit Health Care for the Homeless Dba Advantage Health Centers

MI

Cash Management Allowable Costs / Cost Principles Reporting § 200.305

AHC has fully implemented enhanced reconciliation procedures to ensure that all grant drawdowns are reconciled to the general ledger prior to submission, with supporting documentation retained electronically. Quarterly internal audits of drawdown packets are conducted to ensure compliance with feder...

AHC has fully implemented enhanced reconciliation procedures to ensure that all grant drawdowns are reconciled to the general ledger prior to submission, with supporting documentation retained electronically. Quarterly internal audits of drawdown packets are conducted to ensure compliance with federal requirements. These improvements eliminate timing discrepancies and strengthen federal cash management controls. All federal expenditures year-to-date have been verified. It is important to note that AHC did not maintain a single consolidated record of drawdown support but instead retained multiple supporting documents. Despite this documentation issue, all drawdowns were found to be in compliance with HRSA guidelines and were determined to represent allowable costs.

View Audit 380010

Corrective Action Plans

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