Corrective Action Plans

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Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: The Organization should ensure proper review and approval over expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: The Organization should ensure proper review and approval over expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: YSS engaged a project manager in September 2023 to provide oversight on the two major construction projects taking place, Rooftop Gardens and Ember Campus. The project manager reviews the work being performed to ensure alignment with the progress billing on the monthly AIA pay applications. The project manager submits the invoice for approval to the CFO who, with the CEO, approves payment and the invoice is sent YSS accounts payable to processes payment. Name of the contact person responsible for corrective action: Danielle Fineran Planned completion date for corrective action plan: June 30, 2026
The City will establish and adopt written policies for federal awards.
The City will establish and adopt written policies for federal awards.
United Way will ensure all disbursements related to major program are allowable.
United Way will ensure all disbursements related to major program are allowable.
The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. Dur...
The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 4 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis prior to March 31, 2025. In April 2025, the University remediated this policy and procedure. No exceptions were identified during the remediation period, and the finding is considered remediated. In April 2025, to address this finding and strengthen compliance, the University initiated the following corrective actions. First, the University worked with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change ensures that the University’s procurement processes are more consistent with federal standards. Second, a new requirement was implemented, mandating that a price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form documents the University’s independent price analysis. Third, the University provided targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new price analysis requirement. The training emphasized the importance of maintaining contemporaneous documentation in procurement files. Finally, the University implemented enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of a price analysis retained in the procurement files. Primary responsibility for implementing and monitoring this corrective action plan rests with Beth Connelly, Senior Director of Procurement Operations, 216-368-6332.
The City will establish and adopt written policies for federal awards.
The City will establish and adopt written policies for federal awards.
Finding Number: 2025-002 Planned Corrective Action: The City concurs with the finding and will take the following actions in response: • 100% Federally Funded Employees: Columbus Public Health will require all employees whose salaries are 100% funded by a single federal award to comply with 2 CFR § ...
Finding Number: 2025-002 Planned Corrective Action: The City concurs with the finding and will take the following actions in response: • 100% Federally Funded Employees: Columbus Public Health will require all employees whose salaries are 100% funded by a single federal award to comply with 2 CFR § 200.430 through after-the-fact time and effort certifications completed quarterly of the grant period. These certifications will confirm that 100% of the employee’s actual work performed was allocable to the federal award and will include both employee certification and supervisory review. They will be due 30 days following the quarterly end date. In addition, CPH will implement enhanced internal monitoring procedures, including periodic activity verification and supervisory attestation by the Fiscal Analyst, to ensure that work performed aligns with the grant’s scope and that payroll charges are accurate and properly supported;• Partially Federally Funded Employees: Employees whose salaries are allocated across multiple funding sources will follow full federal time and effort reporting requirements in accordance with 2 CFR § 200.430. These employees will complete afterthe- fact time and effort reporting reflecting the actual distribution of work performed across all cost objectives. Reported time will be supported by appropriate documentation and will not be based on budget estimates. Supervisors will review and formally sign off on reported time and effort on at least a quarterly basis to ensure accuracy, reasonableness, and alignment with actual activities. Additional internal monitoring, including periodic review and payroll-to-activity reconciliation reviewed by the Fiscal Analyst, will be conducted to ensure compliance and proper allocation of personnel costs. Anticipated Completion Date: 7/1/2026 Responsible Contact Persons: Anita Clark, Assistant Health Commissioner, Columbus Public Health Katie Pettiford, Fiscal Manager
As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are bei...
As noted in the audit, a changeover in payroll systems occurred during FY2025. The new system provides improved reporting capabilities that facilitate better oversight of staffing assignment percentages and should help resolve this issue moving forward. In addition, all GA Division locations are being directed to review staffing assignments in the payroll system to verify accuracy. Furthermore, Area Command finance staff will continue to work alongside the staff involved with the Veterans’ program to ensure compliance.
Condition: On May 15, 2025, ISBE communicated to the District that ARP ESSER recipients had until May 24, 2025 to liquidate obligations and that the District needed to submit its expenditure report to ISBE by May 21, 2025 for ISBE to process and submit to the U.S. Department of Education by the new ...
Condition: On May 15, 2025, ISBE communicated to the District that ARP ESSER recipients had until May 24, 2025 to liquidate obligations and that the District needed to submit its expenditure report to ISBE by May 21, 2025 for ISBE to process and submit to the U.S. Department of Education by the new deadline. On May 21, 2025, the District submitted a claim for reimbursement of expenditures totaling $4,343,814. The expenditures comprising this claim by date incurred and liquidated were as follows: $1,668,710 incurred through May 21, 2025 and liquidated as of that date $31,692 incurred through May 21, 2025 but not liquidated as of that date $325,805 incurred from May 21, 2025 through June 30, 2025 and liquidated as of June 30, 2025 $531,321 incurred from May 21, 2025 through June 30, 2025 but not liquidated as of June 30, 2025 $1,786,286 incurred after June 30, 2025 At May 21, 2025 and June 30, 2025, expenditures totaling $2,675,104 and 2,349,299, respectively, out of the $4,343,814 claimed for reimbursement were not incurred, not liquidated or both and, therefore, did not qualify for reimbursement based on the Federal statutes, regulations and the terms and conditions of the Federal award in effect at those dates. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Responsible Person: Dr. Maureen M. White, Superintendent Anticipated Completion Date: June 30, 2026
2025-005 – Noncompliance and Deficiency in Internal Control over Cash Management Corrective Action: The District will implement a documented review and approval process for each Federal reimbursement request prior to submission, including verification of calculations, agreement to supporting documen...
2025-005 – Noncompliance and Deficiency in Internal Control over Cash Management Corrective Action: The District will implement a documented review and approval process for each Federal reimbursement request prior to submission, including verification of calculations, agreement to supporting documentation, and allowability within the reimbursement period. The reimbursement package, review documentation, and approval will be retained in accordance with the District’s records retention policy for each applicable grant award. Management will not submit reimbursement requests until the documented review is complete and any identified discrepancies are resolved. Responsible Officials: Fire Chief Gerard Tarleton Anticipated Completion Date: September 2026
Management concurs with the findings and auditors’ recommendations to enhance internal controls to ensure compliance with the RD requirements. Furthermore, we would like to note that the questioned costs was paid from project cash for the ultimate benefit of improving the property for the tenants. T...
Management concurs with the findings and auditors’ recommendations to enhance internal controls to ensure compliance with the RD requirements. Furthermore, we would like to note that the questioned costs was paid from project cash for the ultimate benefit of improving the property for the tenants. The substantial rehabilitation tax credit transaction planned by the owner is anticipated to start within the next fiscal year will significantly enhance the living standards and experience for the tenants. The funds used for purposes directly related to the operations of the project will be repaid with the planned closing of the Low-Income Housing tax credit transaction during fiscal year 2026 unless an approval is granted by RD for payment of the questioned costs that will ultimately benefit the tenants of Rotary Commons. Furthermore, internal controls over funds used for purposes unrelated to the Corporation are being strengthened to prevent future noncompliance.
The District does monthly close outs and balances which total expenditures and revenues to ensure proper monthly closing procedures. During each year-end closeout, a period H file is created. The Treasurer will ensure moving forward that the totals submitted to ODEW and the District’s expenditures t...
The District does monthly close outs and balances which total expenditures and revenues to ensure proper monthly closing procedures. During each year-end closeout, a period H file is created. The Treasurer will ensure moving forward that the totals submitted to ODEW and the District’s expenditures tie out. As far as TitIe I is concerned, yearly Financial expenditure reports (FER) are filed and approved by ODEW. All (FER) in 2023, 2024 and 2025 have been submitted by District approved by ODEW.
Corrective Action Planned: Management reviewed this instance and performed a detailed analysis of our internal controls, procedures and other like transactions. Management concluded that it was an isolated incident that occurred due to the timing and processing of the voided transaction and the tran...
Corrective Action Planned: Management reviewed this instance and performed a detailed analysis of our internal controls, procedures and other like transactions. Management concluded that it was an isolated incident that occurred due to the timing and processing of the voided transaction and the transition to a new grant year. Vivent Health has implemented additional controls including dual review of grant year-to-date expenditures and system and reporting enhancements that will identify and prevent changes related to prior periods. Specific steps taken are: 1) retrained accounts payable team on void check procedure, 2) implemented a system enhancement that does not permit a user to enter any transaction type to a prior month that has been closed (also planned for new financial system to be implemented by September 2026), 3) examined all void check transactions for any grant-related expenditures that crossed the last two fiscal years with no instance of duplicate invoicing identified, and 4) implemented dual review of running a YTD general ledger report for all grants and comparing total expenditures for the grant period versus total expenditures claimed in the prior month. Name(s) of Contact Person(s) Responsible for Corrective Action: Erin Crandall, VP Finance Anticipated Completion Date: These actions were implemented February 2026 and will be documented throughout the current fiscal year, with completion at fiscal year-end (August 31, 2026). Vivent Health is implementing a new ERP system in September 2026 and will ensure these controls are in place.
Corrective Action Plan Finding No. 2025-004 Condition – The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds...
Corrective Action Plan Finding No. 2025-004 Condition – The District submitted an expenditure report for $19,165,569 for the quarter ending March 31, 2025, which included amounts that were properly obligated but not yet expended as of the report date. The District reported $14,638,097 in ESSER funds on the Schedule of Expenditures of Federal Awards (SEFA), resulting in an unsupported difference of $4,527,472. Plan – The District will implement additional review processes to ensure material errors are detected and corrected. The District requested all ESSER obligated funds as of March 2025 as directed by the state. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official
Views of Responsible Officials: Management concurs with the finding. During FY2025, the organization experienced significant disruption related to Federal stop-work orders and associated cost-reduction measures, including staff terminations and the discontinuation of certain legacy systems during th...
Views of Responsible Officials: Management concurs with the finding. During FY2025, the organization experienced significant disruption related to Federal stop-work orders and associated cost-reduction measures, including staff terminations and the discontinuation of certain legacy systems during the transition and integration of operations with Global Communities. As a result, for some employees in the audit sample—particularly those who separated from the organization prior to the FY2025 attestation cycle—management was unable to retrieve employee-signed conflict of interest attestations for the immediately preceding period because the systems and files used to capture and retain those acknowledgments were no longer accessible, and responsible personnel were no longer employed. Management notes that, for a portion of the employee population, the FY2025 ethics training included a conflicts of interest section requiring employee acknowledgment; however, system limitations affected the ability to produce individual, employee-named attestations for all sampled employees in a format suitable for audit evidence. Planned Corrective Actions: Following the operational integration with Global Communities, management is strengthening controls over conflict of interest compliance by: (1) requiring conflict of interest acknowledgment at onboarding and on a periodic basis thereafter through a standardized process; (2) maintaining a centralized tracking mechanism to monitor completion status; (3) retaining documentation in a centralized repository/personnel record to ensure retrievability; and (4) performing periodic monitoring to confirm completion and retention across headquarters and field locations. These actions are intended to improve documentation, transparency, and ongoing compliance with conflict of interest requirements and standards of conduct.
Views of Responsible Officials: Management concurs with the finding. During FY2025, in response to Federal stopwork orders and related cost reduction measures, IntraHealth experienced significant disruption, including staff terminations and the planned integration of operations with Global Communiti...
Views of Responsible Officials: Management concurs with the finding. During FY2025, in response to Federal stopwork orders and related cost reduction measures, IntraHealth experienced significant disruption, including staff terminations and the planned integration of operations with Global Communities. As part of this transition, the legacy timekeeping system was retired at the end of its renewal period, with the intent to move to Global Communities’ timekeeping process shortly thereafter. During the interim period, time for the remaining staff was captured using manual timesheets. In two instances, documented supervisory approval could not be located because the employees’ supervisor separated from IntraHealth during the transition period. Planned Corrective Actions: Effective April 1, 2025, all IntraHealth staff transitioned to Global Communities following the completion of operational integration, IntraHealth has transitioned to Global Communities’ timekeeping and payroll process using ADP, which includes electronic time entry, supervisor review/approval workflow, and centralized record retention. Management believes this materially strengthens controls by reducing reliance on manual documentation, and improving the retention and retrievability of approvals. Management will also reinforce the requirement that time records are approved prior to payroll processing and will perform periodic monitoring to confirm compliance with the approval control.
Finding Number: 2025-002 Management concurs with the finding. However, the cut-off finding relates to Subrecipient expenses for contract ended in February 2025 and was not renewed. The Organization has no other subrecipients expenses.
Finding Number: 2025-002 Management concurs with the finding. However, the cut-off finding relates to Subrecipient expenses for contract ended in February 2025 and was not renewed. The Organization has no other subrecipients expenses.
Finding 2025-002 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The testing of property, operations, and distributions detected one instance of underpayment of...
Finding 2025-002 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The testing of property, operations, and distributions detected one instance of underpayment of an expense based upon review of supporting invoices and the allocation of the expense. Corrective Action Plan: The invoice approval form will include a note stating that, before completing a disbursement of funds, the request must include supporting documents including allocation calculations and approvals. Accounts Payable staff retraining on allocation calculations has been completed, and the calculation formulas have been updated. Responsible Individuals: Mary Morgan, Executive Director Anticipated Completion Date: April 2026
Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Corrective Action Plan The City will submit pay...
Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Corrective Action Plan The City will submit payment to HUD for the $249,565 of questioned costs. Additionally, the City will update its written program and financial policies and procedures per 24 CFR 570.200(g) which should outline how the City of Corpus Christi will monitor compliance with both of the Administrative and Planning expenditure tests and will provide HUD with a certification stating Planning and Community Development staff received training regarding the limitation on planning and administration costs for origin year grants. Person(s) Responsible Jennifer Buxton, Interim Director of Planning and Economic Development Anticipated Completion Date The City has completed all corrective actions.
Finding 2025-11 Name of Contact Person: Dena Howell, Finance Officer Corrective Action Plan: Management intends to implement controls to ensure the Child Nutrition program is not charged indirect costs in excess of the allowable limit. Proposed Completion Date: As soon as possible.
Finding 2025-11 Name of Contact Person: Dena Howell, Finance Officer Corrective Action Plan: Management intends to implement controls to ensure the Child Nutrition program is not charged indirect costs in excess of the allowable limit. Proposed Completion Date: As soon as possible.
2025-006 – Allowable Costs/Cost Principles Corrective action plan: Contractors have been tasked with training and implementation during fiscal year 2026. Revised accounting staff structure will provide better on-going implementation and monitoring compliance. Personnel responsible for corrective act...
2025-006 – Allowable Costs/Cost Principles Corrective action plan: Contractors have been tasked with training and implementation during fiscal year 2026. Revised accounting staff structure will provide better on-going implementation and monitoring compliance. Personnel responsible for corrective action: Heather King, Interim Chief Operating Officer Estimated corrective action completion date: March 2026
The Organization will develop and implement formal written policies and procedures to ensure that payroll charges to federal awards are based solely on actual costs incurred, in compliance with federal requirements. As part of this effort, the Organization will require all employees whose salaries a...
The Organization will develop and implement formal written policies and procedures to ensure that payroll charges to federal awards are based solely on actual costs incurred, in compliance with federal requirements. As part of this effort, the Organization will require all employees whose salaries are charged in whole or in part to federal awards to complete time and effort documentation for each payroll period. This documentation will accurately reflect the actual hours worked on federal program activities as well as other activities, as applicable. Supervisors or designated management personnel will review and approve all time and effort reports on a timely basis. Evidence of this review, including signatures or electronic approvals, will be maintained in accordance with record retention policies. The approved time and effort documentation will serve as the basis for allocating personnel costs to federal awards. The Organization will ensure that payroll charges are adjusted, if necessary, to align with actual time worked. Documentation supporting these allocations will be retained and made available for audit or review. Training will be provided to all relevant staff to ensure understanding and consistent application of the new procedures. Implementation of these policies and procedures will occur June 15 2026, and ongoing monitoring will be conducted to ensure compliance.
Condition: The District incurred program expenditures that were not charged in accordance with the approved grant budget. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. The District will strengthen internal controls to e...
Condition: The District incurred program expenditures that were not charged in accordance with the approved grant budget. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. The District will strengthen internal controls to ensure expenditures are reviewed for compliance with the approved grant budget prior to being claimed for reimbursement. Going forward, the District will compare expenditures to the approved budget detail and ensure costs are charged to the appropriate budget category.Responsible Person: Dr. Mable Alfred, Interim Superintendent. Anticipated Completion Date: June 30, 2026
Condition: The District claimed expenditures that did not have adequate supporting documentation, such as invoices, receipts, purchase orders and proof of payment. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Grant exp...
Condition: The District claimed expenditures that did not have adequate supporting documentation, such as invoices, receipts, purchase orders and proof of payment. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Grant expenditures will be reviewed and approved by appropriate personnel prior to reimbursement requests being submitted. Responsible Person: Dr. Mable Alfred, Interim Superintendent. Anticipated Completion Date: June 30, 2026
Per the recommendation to adopt a procedure to determine the allowability of cost per 2 CFR 200.302(b){7), our existing financial management policy covers the allowable cost principles in various sections within the policy. However, we will add in a section to our policy per the federal rule giving ...
Per the recommendation to adopt a procedure to determine the allowability of cost per 2 CFR 200.302(b){7), our existing financial management policy covers the allowable cost principles in various sections within the policy. However, we will add in a section to our policy per the federal rule giving a procedure on documenting and determining if specific costs are allowable or not and in conformance. This action should be resolved before October 31st.
2025-06 Allowability of Rental Assistance Payment- Unallowable Program Expenditure Federal Agency- US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control o...
2025-06 Allowability of Rental Assistance Payment- Unallowable Program Expenditure Federal Agency- US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compliance, Noncompliance Other Matter Recommendation - Agate Housing and Services, Inc. strengthen internal controls to ensure all expenditures charged to the Continuum of Care Program are allowable and comply with applicable federal and program requirements. Corrective action - Agate Housing and Services, Inc agrees with the finding and is in the process of strengthening its controls over its review of program expenditures prior to submitting requests for reimbursement. An additional layer of review/approval by the Director of Contracts and the Chief Operating Officer prior to submission has been implemented. Name of contact person(s) responsible for corrective action - Elizabeth Macha rt, Director of Housing Programs and Sara Wenzel, Associate Director Time Limited Housing Completion date - Management implemented the additional layer of review/approval beginning January 2026.
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