Corrective Action Plans

Finding 561487 (2022-005)

Material Weakness 2022

PA

Cash Management Internal Control / Segregation of Duties Material Weakness

Finding 2022-005: Lack of Management Oversight over Drawdown Requests As the previous employees responsible for these functions did not perform them effectively, the organization now has such in place, whereas a drawdown process has been implemented. As the organization’s drawdowns are typically des...

Finding 2022-005: Lack of Management Oversight over Drawdown Requests As the previous employees responsible for these functions did not perform them effectively, the organization now has such in place, whereas a drawdown process has been implemented. As the organization’s drawdowns are typically designated to cover payroll costs, this process now includes the following: • A drawdown allocation schedule for the employee’s making up the amount requested • A budget breakdown by department for the amounts making up the drawdown request • A supporting schedule and related invoices for amounts to be reimbursed (e.g., malpractice insurance, etc.) • A completed Standard Form (SF) 270 that tracks the applicable grant amounts previously drawdown that also specifies the amount to be currently drawn.

View Audit 357068

Finding 560149 (2022-016)

Material Weakness 2022

Oregon Coast Community Action

AL

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

The Energy program has been current on the required reporting since the referenced audit period. The program is aware of the grants' requirements now. Additionally, ORCCA plans to utilize grant tracker system with the ability to send reminders for important dates to avoid future delinquent reporting...

The Energy program has been current on the required reporting since the referenced audit period. The program is aware of the grants' requirements now. Additionally, ORCCA plans to utilize grant tracker system with the ability to send reminders for important dates to avoid future delinquent reporting that was experienced during the audit period. The system will be utilized by the program directors as well as finance team (Finance Director, Accounting Manager, Program Fiscal Compliance Coordinator) working with grants/directors. ORCCA's current process at the Energy program level has already improved to ensure proper documentation of eligibility. The Energy program director and staff are implementing this internal control at the program level to review the supporting documents and information and proper coding to the correct period. Responsible party: Bonnie Foroudi, Finance Director Estimated completion date: December 31, 2025

View Audit 356132

Finding 555302 (2022-003)

Significant Deficiency 2022

Chicago Minority Supplier Development Council, Inc.

IL

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.344

Finding 2022-003, Cash Management - Repeating Finding 2021-003 Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Corrective Action: We agree with the auditor's comments and...

Finding 2022-003, Cash Management - Repeating Finding 2021-003 Federal Agency: U.S. Department of Commerce Program Name: MBDA Business Center Assistance Listing #: 11.805 Questioned Costs: None Corrective Action: We agree with the auditor's comments and actions stated in the recommendation. CMSDC will update its policies and procedures to include procedures for reconciling expenditures to cash drawdowns monthly. Contact Person: Jose Robles Michelena, Executive Vice President Completion Date: June 30, 2024

View Audit 353941

Finding 555241 (2022-004)

Material Weakness 2022

Community Health Service, Inc.

MN

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

1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax fi...

1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax filings, and third-party payroll contracts. *A secure, organized system will be implemented for storing payroll-related documents, whether physical or digital. This will include utilizing secure cloud storage or an enterprise document management system with restricted access controls. *We will conduct a quarterly review to ensure that documents are being retained for the appropriate time frame and securely disposed of when no longer required. 2. Implement Stronger Controls During Payroll Provider Transitions: *We will formalize and document the process for changing third-party payroll providers. This process will include detailed steps for due diligence, transition planning, data transfer procedures, and ensuring continuous payroll processing during the transition period. *A project team will be assigned for every payroll provider change to ensure proper planning, including backup and contingency plans, data verification, and communication with both internal and external stakeholders. *A comprehensive review of the transition will be conducted after each change, including a reconciliation of payroll records to ensure that all data is accurately transferred, and all systems are functioning properly. 3. Vendor Oversight and Service Level Agreements (SLAs): *We will ensure that future contracts with third-party payroll providers include clear Service Level Agreements (SLAs) outlining the provider's responsibilities in terms of document retention, data security, and transition procedures. This will ensure that providers maintain the necessary standards and practices for managing payroll-related documents.

View Audit 353875 Questioned Costs: $1

Finding 555092 (2022-007)

Significant Deficiency 2022

Saint Anthony Health Ministries and Subsidiaries

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303

2022-007 Maintenance of Documentation of Internal Control Over Compliance Finding: Under Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations,...

2022-007 Maintenance of Documentation of Internal Control Over Compliance Finding: Under Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure that documentation to evidence the operation of internal controls, such as supervisory reviews. The Corporation did not have sufficient documentation that internal controls were in place and operating effectively for control activities required for assessment of activities allowed or unallowed and for allowable costs/cost principles. The Corporation also did not have sufficient documentation that internal controls were in place and operating effectively for monitoring procedures required for cash management and reporting compliance requirements. Corrective Actions Taken or Planned: Due to turnover of key positions responsible for grant submission, supporting documentation that was kept on these individuals’ computers was not saved, passed on, nor stored in a central storage location so that the new hires that were brought in to replace these individuals as well as others in the department could view them. In August 2023, the Corporation provided education and training to the staff regarding identifying documentation and files related to the annual SEFA as well as establishing a central departmental drive to store the documentations so that others can locate them when necessary. Name of contact person responsible for corrective action: Jamie Mack, Vice President of Finance

View Audit 353678

Finding 554927 (2022-005)

Material Weakness 2022

Recovery Solutions of Northeast Ohio

OH

Questioned Costs Cash Management Subrecipient Monitoring

Align Reimbursement Requests with the General Ledger Ensure that all reimbursement requests are directly tied to actual expenditures recorded in the general ledger, minimizing reliance on manual tracking. 1. 2022-005: We will ensure that all reimbursement requests are accurately aligned with t...

Align Reimbursement Requests with the General Ledger Ensure that all reimbursement requests are directly tied to actual expenditures recorded in the general ledger, minimizing reliance on manual tracking. 1. 2022-005: We will ensure that all reimbursement requests are accurately aligned with the general ledger by basing them solely on actual, recorded expenditures. This will reduce reliance on manual tracking methods and promote transparency, accuracy, and compliance in grant reporting. Implement a Systematic Reconciliation Process Establish a structured reconciliation process that links each reimbursement request to paid expenses, with supporting documentation readily available for review. 2. A formal reconciliation process will be implemented to connect each reimbursement request to the corresponding paid expenses. Supporting documentation will be organized and readily accessible for internal review and external audits, ensuring a complete and accurate audit trail. Strengthen Real-Time Grant Cash Flow Tracking Utilize existing accounting software to have a real-time tracking system for grant-related cash flow to ensure compliance with reimbursement-based grant requirements. 3. We will utilize our existing accounting software to enable real-time tracking of grant-related cash inflows and outflows. This will improve our ability to monitor available funds, ensure timely reimbursement submissions, and remain compliant with reimbursement-based grant requirements. Assign a Grant Compliance Lead Designate a finance or administrative team member to oversee cash management compliance, ensuring consistency and acting as the primary point of contact for grant related financial matters. 4. A dedicated member of the finance or administrative team will be assigned as the Grant Compliance Lead. This individual will oversee all aspects of grant cash management compliance, maintain documentation standards, and serve as the primary point of contact for grant-related financial matters. Conduct Monthly Reconciliation Meetings Facilitate monthly reconciliation meetings between finance and program teams to align financial records with program expenditures and address any discrepancies proactively. 5. Monthly reconciliation meetings will be held between the finance and program teams to review financial records, align them with program expenditures, and proactively address any discrepancies. This collaboration will support accurate reporting and effective grant management.

View Audit 353523 Questioned Costs: $1

Finding 553813 (2022-002)

Significant Deficiency 2022

Greater Harvest Church

TN

Cash Management

We will ensure that meal count documents are accurate and reported correctly for reimbursement. Additionally, we will use checks and balance system using two or more people to calculate accurate and verifiable number of meals correctly, thoroughly, and efficiently. We are implementing an automation ...

We will ensure that meal count documents are accurate and reported correctly for reimbursement. Additionally, we will use checks and balance system using two or more people to calculate accurate and verifiable number of meals correctly, thoroughly, and efficiently. We are implementing an automation system that will track, record and input data for reporting purposes. The new system is called KidKare by Minute Menu to improve this process

View Audit 352469

Finding 553812 (2022-001)

Significant Deficiency 2022

Greater Harvest Church

TN

Cash Management Internal Control / Segregation of Duties

We will ensure that meal count documents are accurate and reported correctly for reimbursement. Additionally, we will use checks and balance system using two or more people to calculate accurate and verifiable number of meals correctly, thoroughly, and efficiently. We are implementing an automation ...

We will ensure that meal count documents are accurate and reported correctly for reimbursement. Additionally, we will use checks and balance system using two or more people to calculate accurate and verifiable number of meals correctly, thoroughly, and efficiently. We are implementing an automation system that will track, record and input data for reporting purposes. The new system is called KidKare by Minute Menu to improve this process.

View Audit 352469

Finding 553719 (2022-004)

Material Weakness 2022

Ao: Advocating Opportunity, Inc.

OH

Allowable Costs / Cost Principles Cash Management

Allowable Costs Services for Victims of Human Trafficking – Assistance Listing No. 16.320 Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting...

Allowable Costs Services for Victims of Human Trafficking – Assistance Listing No. 16.320 Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director for allowability before submitting the request to the awarding agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file. Name of the contact person responsible for corrective action: Megan Mattimoe, Executive Director Planned completion date for corrective action plan: June 1, 2025

View Audit 352319

Finding 553715 (2022-003)

Material Weakness 2022

Ao: Advocating Opportunity, Inc.

OH

Cash Management

Cash Management Services for Victims of Human Trafficking – Assistance Listing No. 16.320 Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to t...

Cash Management Services for Victims of Human Trafficking – Assistance Listing No. 16.320 Recommendation: We recommend the Organization design controls to ensure the draw down requests and related support are formally reviewed and approved by the Executive Director before submitting the request to the awarding agency and that the support is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Organization will put a formal layer of review after preparation of the draw down request and support and before submission to the awarding agency and make sure the approved support is kept on file. Name of the contact person responsible for corrective action: Megan Mattimoe, Executive Director Planned completion date for corrective action plan: June 1, 2025

View Audit 352319

Finding 553676 (2022-001)

Material Weakness 2022

City of Pekin

IL

Cash Management Reporting Internal Control / Segregation of Duties

The Director of Finance, along with staff, has implemented new procedures to identify and record retainage payable entries.

View Audit 352243

Finding 544484 (2022-001)

Significant Deficiency 2022

Coosa Valley Regional Services and Development Corporation

GA

Internal Control / Segregation of Duties Cash Management Reporting

2022-001: Segregation of Duties Name of contact person: Stacey Holbrook, Executive Director Corrective Action: Duties and functions will be reviewed to determine where segregation needs to occur. The duties will be separated as much as possible and alternative controls will be implemented to c...

2022-001: Segregation of Duties Name of contact person: Stacey Holbrook, Executive Director Corrective Action: Duties and functions will be reviewed to determine where segregation needs to occur. The duties will be separated as much as possible and alternative controls will be implemented to compensate for lack of segregation. However, the risk of not segregating certain duties is not worth the additional costs. Nonfinancial employees will be trained and provide some assistance. Proposed completion date: The Board will implement the above procedure immediately.

View Audit 351154

Finding 544478 (2022-011)

None 2022

Marian High School

IN

Cash Management Special Tests & Provisions School Nutrition Programs

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and allocate all appropriate expenses in a timely fashion. The Business Manager has implemented these accounting changes. This proc...

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and allocate all appropriate expenses in a timely fashion. The Business Manager has implemented these accounting changes. This process was completed in October of 2022.

View Audit 351152

Finding 544475 (2022-010)

Material Weakness 2022

Marian High School

IN

Questioned Costs Allowable Costs / Cost Principles Cash Management

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and ascertain that all appropriate expenses are disbursed only for the federally funded department. The Business Manager has impleme...

Management agrees with the finding and has established a monthly meeting between the Business Manager and the Cafeteria Director in order to review the monthly budget and ascertain that all appropriate expenses are disbursed only for the federally funded department. The Business Manager has implemented these accounting changes as of September 2022.

View Audit 351152 Questioned Costs: $1

Finding 540863 (2022-108)

Significant Deficiency 2022

Pancare of Florida, INC

FL

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.328

2021-108 Lack of Documentation Related to Reporting Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance ...

2021-108 Lack of Documentation Related to Reporting Condition: The Organization did not maintain proper documentation in support of reporting requirements. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. Source documentation for grant reporting is retained and maintained in grant folders on the shared drive for future reference. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

View Audit 350520

Finding 540862 (2022-105)

Material Weakness 2022

Pancare of Florida, INC

FL

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Condition: The Organization made drawdowns after month-end based on budgeted period expenses rather than actual salary expenses to support the amounts being requested for reimbursement. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional support...

Condition: The Organization made drawdowns after month-end based on budgeted period expenses rather than actual salary expenses to support the amounts being requested for reimbursement. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization has reviewed and updated its grant drawdown procedures to include only actual cost and for the request to be reviewed and approved by someone other than the preparer prior to submission. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

View Audit 350520

Finding 540861 (2022-102)

Significant Deficiency 2022

Pancare of Florida, INC

FL

Cash Management § 200.303

2022-102 Lack of Cash Management Documentation Condition: The Organization made drawdowns after month-end based on budgeted period expenditures and therefore could not be agreed to the actual approved wages paid prior to the reimbursement request. Insufficient documentation was kept to clearly docu...

2022-102 Lack of Cash Management Documentation Condition: The Organization made drawdowns after month-end based on budgeted period expenditures and therefore could not be agreed to the actual approved wages paid prior to the reimbursement request. Insufficient documentation was kept to clearly document that the amount requested was reviewed for accuracy. Corrective Action Planned: The Organization has hired a new Chief Financial Officer as well as additional supporting staff within the finance department. The Organization’s policy and procedures related to support documentation retention has been evaluated and updated. Supporting documentation for all drawdown requests are retained by grant. The corrective action for this finding has been approved and implemented by the Organization. Person Responsible for Corrective Action: Joe Derry, Chief Financial Officer Anticipated Completion Date: Implemented

View Audit 350520

Finding 540610 (2022-004)

Significant Deficiency 2022

Schoodic Institute at Acadia National Park

ME

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

Audit Finding Reference 2022-004 Improve Controls Over Cash Management & Application of Indirect Cost Rate Planned Corrective Action: Federal reimbursement requests will include at least two or more individuals. Review of the reimbursement request, including the application of the indirect rate, ...

Audit Finding Reference 2022-004 Improve Controls Over Cash Management & Application of Indirect Cost Rate Planned Corrective Action: Federal reimbursement requests will include at least two or more individuals. Review of the reimbursement request, including the application of the indirect rate, will be formally documented and a copy of the documentation will be maintained in our records. Planned Implementation Date of Corrective Action: March 14, 2025 Persons Responsible for Corrective Action: Kirk Geadelmann, Finance Director Tyler Piebes, Bookkeeper Nick Fisichelli, President & CEO

View Audit 350382

Finding 540607 (2022-002)

Significant Deficiency 2022

Schoodic Institute at Acadia National Park

ME

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

Audit Finding Reference: 2022-002 Document Policies & Procedures Over Federal Awards Planned Corrective Action: Uniform Guidance Policies & Procedures was presented, reviewed & approved by the Schoodic Institute Board of Directors on July 10, 2023. Planned Implementation Date of Corrective Acti...

Audit Finding Reference: 2022-002 Document Policies & Procedures Over Federal Awards Planned Corrective Action: Uniform Guidance Policies & Procedures was presented, reviewed & approved by the Schoodic Institute Board of Directors on July 10, 2023. Planned Implementation Date of Corrective Action: July 10, 2023 Person Responsible for Corrective Action: Kirk Geadelmann, Finance Director

View Audit 350382

Finding 538766 (2022-005)

Significant Deficiency 2022

New Hampshire Children's Trust

NH

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

Audit Finding Reference: 2022-005 Improve Controls Over Cash Management and Application of Indirect Cost Rate Planned Corrective Action: Having the Executive Director review and approve state and federal invoices prior to final submission. An indirect analysis spreadsheet was also created to track ...

Audit Finding Reference: 2022-005 Improve Controls Over Cash Management and Application of Indirect Cost Rate Planned Corrective Action: Having the Executive Director review and approve state and federal invoices prior to final submission. An indirect analysis spreadsheet was also created to track and adjust indirect rate, if necessary, across all sub-contracts receiving federal funds. Planned Implementation Date of Corrective Action: Implemented Executive Director approval on 5/26/2023 for state invoices, which include federal funds that are passed through to NHCT. Indirect analysis spreadsheet implemented on 7/1/2023. Person Responsible for Corrective Action: Director of Finance

View Audit 349473

Finding 538760 (2022-002)

Significant Deficiency 2022

New Hampshire Children's Trust

NH

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

Audit Finding Reference: 2022-002 Update Documented Policies and Procedures Of Federal Awards Planned Corrective Action: Update Financial Policies and Procedures to reflect Uniform Guidance language surrounding areas of deficiency. Planned Implementation Date of Corrective Action: Implemented 12/6...

Audit Finding Reference: 2022-002 Update Documented Policies and Procedures Of Federal Awards Planned Corrective Action: Update Financial Policies and Procedures to reflect Uniform Guidance language surrounding areas of deficiency. Planned Implementation Date of Corrective Action: Implemented 12/6/2023 upon becoming aware of the deficiency. Revised Financial Policies and Procedures to reflect the changes. Person Responsible for Corrective Action: Director of Finance

View Audit 349473

Finding 529159 (2022-003)

Material Weakness 2022

Oregon Coalition Against Domestic & Sexual Violence

OR

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

Contact person(s) responsible: Associate Director, BB Beltran Recommendation: The Coalition should establish monitoring procedures to ensure that charges to federal awards and other funders are adequately documented and approved and comply with all established policies. Specifically, adequate docume...

Contact person(s) responsible: Associate Director, BB Beltran Recommendation: The Coalition should establish monitoring procedures to ensure that charges to federal awards and other funders are adequately documented and approved and comply with all established policies. Specifically, adequate documentation should include original itemized invoices or receipts, and clear documentation of review and approval. Management Response: NEW Corrective Action Plan: OCADSV implemented a third-party service for tracking the Coalitions costs by program in January of 2023. The submission, coding, approval and payment are processed within this software, which also allows for an audit trail of the processes performed by user and quick access to scanned original documentation. Quarterly budget expense reimbursements are prepared and submitted for review to the Associate Director and/or the Grants Manager. The monthly/quarterly reports are reviewed and approved, with general ledger support, before sending them to the funding agency as the quarterly invoice for reimbursements. Anticipated completion date: 09/30/24

View Audit 347141

Finding 528808 (2022-004)

None 2022

Saraland Manor, Inc.

MS

Cash Management HUD Housing Programs

We agree that surplus cash deposit was not made in FY2020, and the recommendations described above. Management will deposit any surplus cash required into the residual receipts in future periods.

View Audit 346857

Finding 528807 (2022-003)

None 2022

Saraland Manor, Inc.

MS

Cash Management HUD Housing Programs

We agree that surplus cash deposit was not made in FY2019, and the recommendations described above. Management will deposit any surplus cash required into the residual receipts in future periods.

View Audit 346857

Finding 528730 (2022-002)

None 2022

Greater Chatham Initiative

IL

Reporting Cash Management

GCI has since hired a dedicated contractor who submits vouchers consistent with the City of Chicago's due dates. This assumes that the City of Chicago also follows its own guidelines, provides contracts, and processes vouchers in a timely manner. Estimated Correction Date January 1, 2023.

View Audit 346791

Corrective Action Plans

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