Corrective Action Plans

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Finding: Material weakness in internal control over period of performance Corrective action: Pacific Forum will incorporate policies into expense management and financial reporting guidelines to ensure all expenditure is completed within the period of performance and reviews by management are proper...
Finding: Material weakness in internal control over period of performance Corrective action: Pacific Forum will incorporate policies into expense management and financial reporting guidelines to ensure all expenditure is completed within the period of performance and reviews by management are properly documented. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over allowable costs and compliance with requirement for written documentation of transactions review required for federally funded awards Corrective action: PFI has adopted a policy to document transaction reviews. Email approval documentation is requi...
Finding: Material weakness in internal control over allowable costs and compliance with requirement for written documentation of transactions review required for federally funded awards Corrective action: PFI has adopted a policy to document transaction reviews. Email approval documentation is required for all transactions, including initial approval by the Program Director and final approval by the Executive Director. This policy will be incorporated into PFI expense management policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Management will complete the audit filing with the federal audit clearinghouse by the deadline going forward.
Management will complete the audit filing with the federal audit clearinghouse by the deadline going forward.
09.744060 Basic Field Grant Grant Period: 1/1/2024 – 12/31/2024 Contract Number: 744060 U.S Department of Justice 16.575 Victims of Crime Act Grant Periods: 10/1/23-9/30/24 and 10/1/24 – 9/30/25 Contract Number: 4055104; 4055105 Supreme Court of Texas Basic Civil Legal Services Program Grant Period:...
09.744060 Basic Field Grant Grant Period: 1/1/2024 – 12/31/2024 Contract Number: 744060 U.S Department of Justice 16.575 Victims of Crime Act Grant Periods: 10/1/23-9/30/24 and 10/1/24 – 9/30/25 Contract Number: 4055104; 4055105 Supreme Court of Texas Basic Civil Legal Services Program Grant Period: 9/1/2023 – 8/31/2025 Contract Number: 26030 2024-003 Internal Controls and Compliance over Allowable Costs and Activities – Payroll (Material Weakness and Material Noncompliance) Recommendation: We recommend the Organization review its timekeeping policies and procedures and provide additional training to employees to ensure time sheets are retained for all payroll transactions to support the allocation of compensation. We also recommend the Organization review and refine its policies to reconcile the percentage of hours charged on the time sheets to the budget estimates used to bill Federal and State grantors. This should be done in conjunction with monthly or quarterly billings (or other determined regular interval), at fiscal year end, and at the end of the grant year (if different from the Organization’s fiscal year). Corrective Action: AVDA implemented a formal Timekeeping and Payroll Compliance Policy in June 2025. All employees funded by Federal or State grants are now required to complete bi-weekly electronic functional time sheets that identify time spent on tasks by budgeted grant(s). Supervisors must review and approve all time sheets prior to submission. The Director of Finance will reconcile budget estimates to actual hours monthly, and quarterly reviews will ensure accuracy in allocations. Training on grant timekeeping standards (2 CFR §200.430) was provided to all program directors and staff in July 2025. Responsible Parties: - Lisa Mikosh, Director of Finance - Marcello Gonzales, Bookkeeper - Maisha Colter, CEO (policy approval and oversight) Date Corrected: August 15, 2025
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs ...
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs against program requirements and other relevant background documentation. For finding 2024-012, Cayuga will review relevant lease terms and program requirements. If, upon full evaluation, Cayuga Centers concurs that such costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. For steps to resolve the underlying control deficiency asserted or implied in this finding, please see Cayuga Centers’ response to Findings 2024-001 through 006 above.
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs ...
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs against program requirements and other relevant background documentation. For finding 2024-012, Cayuga will review relevant lease terms and program requirements. If, upon full evaluation, Cayuga Centers concurs that such costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. For steps to resolve the underlying control deficiency asserted or implied in this finding, please see Cayuga Centers’ response to Findings 2024-001 through 006 above.
As discussed above Cayuga Centers has engaged grants management advisors who will assist in evaluating this specific finding. To the extent that the finding merely asserts that indirect cost bases were improperly calculated in prior periods, please see Cayuga Centers’ response and actions steps with...
As discussed above Cayuga Centers has engaged grants management advisors who will assist in evaluating this specific finding. To the extent that the finding merely asserts that indirect cost bases were improperly calculated in prior periods, please see Cayuga Centers’ response and actions steps with respect to findings 2024-001 through 006. If, upon full evaluation, Cayuga Centers concurs that indirect costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs.
Cayuga Centers does not fully understand the scope of this asserted finding. It will, however, work with its auditors to fully assess this finding. As discussed above, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted findings. To the exte...
Cayuga Centers does not fully understand the scope of this asserted finding. It will, however, work with its auditors to fully assess this finding. As discussed above, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted findings. To the extent that the costs referenced in this finding are unallowable, Cayuga Centers will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. To the extent this finding asserts control failures, please see Cayuga Centers’ response to Findings 2024-005 and 006 above.
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the...
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the drawdown process generally, Cayuga Centers has established a review protocol requiring that draws include only qualified expenditures incurred or expected within three business days. All draw requests require dual approval from both finance and program staff. A centralized draw request log is being maintained, including supporting documentation and reconciliation records. With respect to Finding 2024-008, Cayuga Centers does not entirely agree with the auditors’ assertion that accrued vacation expense was improperly included in draw requests. Under certain circumstances, costs of paid time off may be treated as incurred based on PTO earned, rather than PTO-paid. See 2 C.F.R. § 200.431(b). Cayuga Centers will further evaluate this asserted finding with the grants management advisors described above. To the extent there may be any compliance discrepancy, Cayuga Centers will take further appropriate action.
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the...
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the drawdown process generally, Cayuga Centers has established a review protocol requiring that draws include only qualified expenditures incurred or expected within three business days. All draw requests require dual approval from both finance and program staff. A centralized draw request log is being maintained, including supporting documentation and reconciliation records. With respect to Finding 2024-008, Cayuga Centers does not entirely agree with the auditors’ assertion that accrued vacation expense was improperly included in draw requests. Under certain circumstances, costs of paid time off may be treated as incurred based on PTO earned, rather than PTO-paid. See 2 C.F.R. § 200.431(b). Cayuga Centers will further evaluate this asserted finding with the grants management advisors described above. To the extent there may be any compliance discrepancy, Cayuga Centers will take further appropriate action.
This finding is, in part, due to a gap in adequate personnel and oversight within the Finance Department for a brief period of time. As stated above, Cayuga Centers has contracted for Chief Financial Officer and Controller services as a near-term measure to fill gaps and improve processes. Further, ...
This finding is, in part, due to a gap in adequate personnel and oversight within the Finance Department for a brief period of time. As stated above, Cayuga Centers has contracted for Chief Financial Officer and Controller services as a near-term measure to fill gaps and improve processes. Further, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding in conjunction with Finding 2024-005 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. The new Finance Team leadership have reinstated use of the class system in our general ledger to allocate direct costs to specific programs and clearly separate non-reimbursable expenses. Monthly reconciliations will be performed to ensure qualifying costs align with cash draw requests. Accounting staff have or will receive targeted training on cost allocation principles and documentation standards to support this effort.
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding and address it accordingly. Cayuga Centers has also begun the process of working with its main federal funder regarding this item and will coordinate closely with that funder in res...
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding and address it accordingly. Cayuga Centers has also begun the process of working with its main federal funder regarding this item and will coordinate closely with that funder in resolving it. As an immediate action step, Cayuga Centers is reinforcing training for all grant management personnel, emphasizing the distinction between allowable and unallowable costs. The Training Department is developing a virtual curriculum to issue to all required staff. A pre-approval process was introduced for all grant-funded expenditures, and program managers will be required to certify compliance before expenses are submitted for reimbursement.
Cayuga Centers has changed key leadership positions and contracted in the near-term for Chief Financial Officer and Controller services. The new leadership team is working transparently to resolve internal control issues asserted in the audit report. To prevent future instances of management overrid...
Cayuga Centers has changed key leadership positions and contracted in the near-term for Chief Financial Officer and Controller services. The new leadership team is working transparently to resolve internal control issues asserted in the audit report. To prevent future instances of management override, Cayuga Centers has implemented standardized procedures to ensure grant expenditures are properly classified in our financial system. Each transaction are supported by detailed documentation, including invoices, receipts, and grant-specific identifiers. Individuals responsible for grant oversight will undergo mandatory training to deepen their understanding of grant requirements, allowable costs, and reporting obligations. Additionally, Cayuga Centers is working to ensure open communication between staff and the Board. Under new leadership, the agency continues to enforce its Non-Retaliation Policy (Whistleblower). The Acting President’s office is establishing quarterly “Grant Compliance Forums” for employees to raise concerns related to grant administration.
Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-008: Cash Management - Inadequate Authorization and Supporting Documentation for Reimbursement Requests (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Fin...
Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-008: Cash Management - Inadequate Authorization and Supporting Documentation for Reimbursement Requests (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: A standardized reimbursement packet and formal approval workflow will be created. All reimbursement requests will be routed for required approvals. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: The Finance Department will conduct monthly reconciliations and reviews of reimbursement submissions.
Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-007: Activities Allowed or Unallowed / Allowable Costs - Insufficient Budget-to-Actual Reviews (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: Th...
Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-007: Activities Allowed or Unallowed / Allowable Costs - Insufficient Budget-to-Actual Reviews (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: A monthly review checklist and variance analysis template will be adopted. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: The internal audit function will conduct semiannual reviews to confirm adherence to established review procedures.
Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-006: Activities Allowed or Unallowed / Allowable Costs - Inadequate Chart of Accounts Segregation for Unallowable Costs (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreemen...
Section III – Major Federal Awards Programs – Findings and Questioned Costs (Cont.) Finding 2024-006: Activities Allowed or Unallowed / Allowable Costs - Inadequate Chart of Accounts Segregation for Unallowable Costs (Material Weakness) (Cont.) Corrective Action Plan (CAP) Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Management will implement a comprehensive redesign of the chart of accounts, including the creation of new account codes and subaccounts to clearly identify unallowable costs. In addition, management will ensure that staff receive training on the revised coding structure. Official Responsible for Ensuring CAP: Finance Manager will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is December 31, 2025. Plan to Monitor Completion of CAP: The Finance Department will conduct quarterly internal reviews to ensure the proper use of the revised account codes and to verify the accuracy of cost classifications.
Finding Number: 2024-003 Planned Corrective Action: The Grants Department Manager and Chief Financial Administrator will ensure the County submits quarterly OCJS amounts that match County accounting records each quarter. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Rob ...
Finding Number: 2024-003 Planned Corrective Action: The Grants Department Manager and Chief Financial Administrator will ensure the County submits quarterly OCJS amounts that match County accounting records each quarter. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Rob Grant, Grants Department Manager and Ben Cowdery, Chief Financial Administrator
Finding Number: 2024-005 Planned Corrective Action: The Special Projects Manager will ensure the County does not charge Indirect Costs in excess of the de minimis rate of 10 percent of modified total direct costs. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Philip Scha...
Finding Number: 2024-005 Planned Corrective Action: The Special Projects Manager will ensure the County does not charge Indirect Costs in excess of the de minimis rate of 10 percent of modified total direct costs. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Philip Schaffer, Special Projects Manager
Assistance Listing 14.231 Emergency Solutions Grants Program Views of the Responsible Officials and Corrective Action Plan: The Office of Homeless Services acknowledges the finding. The delays in processing invoices were due to heightened fiscal oversight implemented after it was determined that the...
Assistance Listing 14.231 Emergency Solutions Grants Program Views of the Responsible Officials and Corrective Action Plan: The Office of Homeless Services acknowledges the finding. The delays in processing invoices were due to heightened fiscal oversight implemented after it was determined that the Office had exceeded its budget allocation. As a result, all invoices for OHS-contracted services were subject to additional layers of review beyond the standard OHS and Finance approval process. These invoices were routed to the Managing Director’s Office before payment authorization, which extended the normal processing timelines. To prevent recurrence, the Office of Homeless Services will strengthen its invoice-processing policies and procedures to ensure timely review and payment of all subrecipient invoices, consistent with applicable federal requirements. Now that the enhanced review protocols are no longer in effect, OHS will reestablish standard review timelines and reinforce internal expectations for prompt processing. OHS will also provide guidance to fiscal staff on escalation procedures should future budgetary reviews impact invoice timeliness. These corrective actions will support improved compliance and reduce the likelihood of processing delays. Contact Person: Jerome Hill, Director of Compliance, OHS, 215-686-0371
The Child Care and Development Division is working towards compliance with federal requirements for license-exempt health and safety monitoring with an anticipated completion date of July 1, 2029, assuming additional resources are secured. This plan has been outlined in Appendix A of the Federal Fis...
The Child Care and Development Division is working towards compliance with federal requirements for license-exempt health and safety monitoring with an anticipated completion date of July 1, 2029, assuming additional resources are secured. This plan has been outlined in Appendix A of the Federal Fiscal Year 2025-27 State Plan for California with Administration of Children and Families (State Plan). The State Plan can be provided upon request. Estimated Implementation Date: July 1, 2029 Contact: • Jeff Fowler, Child Care Administration Bureau Chief • Central Operations Branch • Child Care and Development Division • California Department of Social Services
The difference in reporting deadlines between the ACF-696 and SEFA reports will consistently result in a known discrepancy. To address this, as of September 2025, CDSS started conducting year-end reconciliations between the two reports to validate and confirm these discrepancies. Estimated Implement...
The difference in reporting deadlines between the ACF-696 and SEFA reports will consistently result in a known discrepancy. To address this, as of September 2025, CDSS started conducting year-end reconciliations between the two reports to validate and confirm these discrepancies. Estimated Implementation Date: March 2026 Contact: • Daniel During, Federal Reporting Section Chief • Accounting and Fiscal Systems Branch • Finance and Accounting Division • California Department of Social Services
To ensure timely reporting, the Federal Reporting Section (FRS) has ensured that all staff understand the final deadline and all key milestones along the way. The FRS has broken down the report into smaller, manageable tasks within individual deadlines which help avoid last-minute rushes and ensure ...
To ensure timely reporting, the Federal Reporting Section (FRS) has ensured that all staff understand the final deadline and all key milestones along the way. The FRS has broken down the report into smaller, manageable tasks within individual deadlines which help avoid last-minute rushes and ensure steady progress. The FRS conducts regular check-ins to discuss progress, address any challenges early, and adjust the plan as needed to prevent delays. Estimated Implementation Date: Implemented in November 2024. Contact: • Daniel During, Federal Reporting Section Chief • Accounting and Fiscal Systems Branch • Finance and Accounting Division • California Department of Social Services
The EDD has policies, procedures, and training in place instructing employees to include applicable penalty amounts when establishing overpayments in the database. When the overpayment for the sample in question was established, the employee did not follow the proper procedure to include the penalty...
The EDD has policies, procedures, and training in place instructing employees to include applicable penalty amounts when establishing overpayments in the database. When the overpayment for the sample in question was established, the employee did not follow the proper procedure to include the penalty. EDD accepts this oversight and is committed to reviewing its applicable policies and procedures to ensure they are clear, and the penalty requirements are emphasized. Regarding internal controls, EDD leverages a process known as the Field Office Basic Evaluation System (FOBES). This process includes a standardized form that is utilized by leadership to evaluate the quality of their employees’ work on a variety of processes, including overpayment processing. EDD continues to review and modernize the existing assessment form and FOBES process to ensure effectiveness and consistency while evaluating employee compliance with policies and procedures Estimated Implementation Date: Currently Implemented Contact: Diane Underwood, Division Chief, Unemployment Insurance Branch, California Employment Development Department
Recognizing that the finding does not include any questioned costs, EDD agrees with the recommendation as it relates to the need for a formal reconciliation process between the U.S. DOL (DOL) ETA Financial Report, form ETA-9130 (ETA-9130) and the general ledger. EDD will take steps to formally docum...
Recognizing that the finding does not include any questioned costs, EDD agrees with the recommendation as it relates to the need for a formal reconciliation process between the U.S. DOL (DOL) ETA Financial Report, form ETA-9130 (ETA-9130) and the general ledger. EDD will take steps to formally document the process, including roles and responsibilities, a more regular reconciliation schedule and a plan to resolve variances with documented approvals. Also, as recommended, updates will be made to financial reporting procedures and staff that are part of this process will receive training. Estimated Implementation Date: June 2026 Contact: Diane Underwood, Division Chief, Unemployment Insurance Branch, California Employment Development Department
Views of Responsible Officials and Planned Corrective Action The necessary instructions were given to the accounting staff in order to comply with the reporting requirements established by each federal grant that the Municipality currently manages. Responsible Official: Mrs. Irma M. Vargas Aguirre, ...
Views of Responsible Officials and Planned Corrective Action The necessary instructions were given to the accounting staff in order to comply with the reporting requirements established by each federal grant that the Municipality currently manages. Responsible Official: Mrs. Irma M. Vargas Aguirre, Finance and Budget Director Implementation Date: December 31, 2025
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