Corrective Action Plans

Finding 3045 (2022-006)

Material Weakness 2022

TX

HUD Housing Programs Special Tests & Provisions Cash Management

Finding 2022-6 - Special Tests and Provisions: In accordance with the Project's regulatory agreement with HUD, management shall establish a residual receipts account and make deposits into the account in accordance with HUD requirements (within 90 days after the close of the fiscal year). Disburseme...

Finding 2022-6 - Special Tests and Provisions: In accordance with the Project's regulatory agreement with HUD, management shall establish a residual receipts account and make deposits into the account in accordance with HUD requirements (within 90 days after the close of the fiscal year). Disbursements from such fund may be made only after written consent is received from HUD. Management's View: Management acknowledges finding and simultaneously underscores this was was an internal facing situation. Proposed Corrective Action: Management will ensurethat all proper approvals from HUD are obtained before making a withdrawals from residual receipts account. Anticipated Correction Date: Payments are done automatically on a monthly basis.

View Audit 4999

Finding 3019 (2022-001)

Significant Deficiency 2022

Monroe County Board of Education

GA

School Nutrition Programs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

FA 2022-001 Strengthen Controls over Special Reporting Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assis...

FA 2022-001 Strengthen Controls over Special Reporting Compliance Requirement: Reporting Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199; 225GA324N1199 Questioned Costs: None Identified Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the monthly Claims for Reimbursement process. Corrective Action Plans: The School District has returned to collection Free and Reduce applications and recording the student meals accordingly. Estimated Completion Date: July 1, 2022 Contact Person: Chris Johnson, CGFM, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

View Audit 4890

Finding 2987 (2022-019)

Significant Deficiency 2022

Government of Guam

GU

Questioned Costs Cash Management

Findinq No.: 2022-019 Cash Management Responding Agency:Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director (DOA) The agency disagrees with this finding. Per Homeowner's Assistance Fund guidance, funds are requested from the US Treasury and remitted in advance. This i...

Findinq No.: 2022-019 Cash Management Responding Agency:Department of Administration (DOA) Responsible Personnel: Edward M. Birn, Director (DOA) The agency disagrees with this finding. Per Homeowner's Assistance Fund guidance, funds are requested from the US Treasury and remitted in advance. This is not a reimbursement program and not subject to the State Cash Management lmprovement Act as is the case for other funding advances under the American Rescue Plan Act of 2021 .

View Audit 4883 Questioned Costs: $1

Finding 2623 (2022-002)

Significant Deficiency 2022

Minford Gardens Housing Development Fund Company, INC

NY

Questioned Costs HUD Housing Programs Cash Management

Finding Reference Number: 2022-2 Recommendation The Company must deposit $53,053 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Compl...

Finding Reference Number: 2022-2 Recommendation The Company must deposit $53,053 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Completion date or proposed completion date: June 2023 Action(s) taken or planned on the finding As of June 2023, management has deposited $53,053 into the residual receipts reserve.

View Audit 4425 Questioned Costs: $1

Finding 2577 (2022-004)

Material Weakness 2022

The Salvation Army Golden State Division

CA

Questioned Costs Cash Management Subrecipient Monitoring § 200.3 § 200.305

REFERENCE # 2022-004 CASH MANAGEMENT – MATERIAL WEAKNESS- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Non-Federal Entities Other Than States- Non-federal entities must minimize the time elapsi...

REFERENCE # 2022-004 CASH MANAGEMENT – MATERIAL WEAKNESS- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Non-Federal Entities Other Than States- Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Questioned Costs: Cannot be determined Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Corrective Action Plan: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

View Audit 4368 Questioned Costs: $1

Finding 2576 (2022-003)

Significant Deficiency 2022

The Salvation Army Golden State Division

CA

Questioned Costs Subrecipient Monitoring Cash Management

REFERENCE # 2022-003 OTHER - BASIS OF ACCOUNTING – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Basis of Accounting —Uniform Guidance states the basis of accounting used may be a special pu...

REFERENCE # 2022-003 OTHER - BASIS OF ACCOUNTING – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Basis of Accounting —Uniform Guidance states the basis of accounting used may be a special purpose framework. However, it does state that the determination of when an award is expended must be based on when the activity related to the federal award occurs. Uniform Guidance also states for Grants, cost reimbursement contracts, cooperative agreements, and direct appropriation type of contracts, the federal expenditure or expense should be reported when the transaction occurs. Uniform Guidance further states, the auditee should also be able to reconcile amounts presented in the financial statements to related amounts in the schedule of expenditures of federal awards. Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division report to the pass-through entity on an accrual basis. Division’s schedule of expenditures of federal awards is presented on the accrual basis of accounting. Of the Sixty (60) files selected for testing: • Five (5) prior year expenditures were included in Division’s current year schedule of expenditures of federal awards. Questioned Costs: Cannot be determined Recommendation: We recommend Division report program expenditures in the year expenditures were accrued. Corrective Action Plan: The Division will report program expenditures in the year expenditures were accrued. Step 1 Action Date: Ongoing Final Implementation Date:h 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

View Audit 4368 Questioned Costs: $1

Finding 2556 (2022-005)

Significant Deficiency 2022

Arc Community Services, INC

WI

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.305

We concur with the recommendation, and a formalized and independently monitored process was implemented to reconcile refundable advances routinely and in coordination with the recognition and allocation of allowable costs effective August of 2023.

View Audit 4353

Finding 2406 (2022-004)

Significant Deficiency 2022

Town of Liberty

NC

Cash Management

The Town should implement internal controls to safeguard against these types of policies to ensure that they are not repeat or future findings.

View Audit 4134

Finding 2360 (2022-002)

None 2022

Community Health Alliance

NV

Cash Management Reporting

The Center has established clear reporting calendars with due dates. With significant turnover within accounting and finance departments, this responsibility has been reassigned and monitored by the CFO.

View Audit 4057

Finding 2314 (2022-001)

None 2022

City of Chelsea

MA

Questioned Costs Allowable Costs / Cost Principles Cash Management

Condition: The City charged the same invoice to two separate federal awards. Corrective Action Planned: This issue has been remedied. The City has corrected this and reversed the charge to the federal grant, reimbursed the grant funder, and filed a revised final grant report. This was an oversigh...

Condition: The City charged the same invoice to two separate federal awards. Corrective Action Planned: This issue has been remedied. The City has corrected this and reversed the charge to the federal grant, reimbursed the grant funder, and filed a revised final grant report. This was an oversight in the management of high volume COVID related grants totaling $10.3M with over 1,000 transactions, and reclassifications had occurred between the two as expenditures became ineligible. Moving forward, the City will take steps to ensure direct expenditures and limit the need for reclassifications. Anticipated Completion Date: October 31, 2023 Contact: Edward M. Dunn, City Auditor

View Audit 3965 Questioned Costs: $1

Finding 2293 (2022-001)

None 2022

Bellevue School District No. 405

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding caption: The District did not have adequate internal controls to ensure compliance with federal requirements for allowable activities and costs. Name, address, and telephone of District contact person: Jenny Hall, Director of Budget 12111 NE 1st Street Bellevue, WA 98005 (425) 456 - 4069 Cor...

Finding caption: The District did not have adequate internal controls to ensure compliance with federal requirements for allowable activities and costs. Name, address, and telephone of District contact person: Jenny Hall, Director of Budget 12111 NE 1st Street Bellevue, WA 98005 (425) 456 - 4069 Corrective action the auditee plans to take in response to the finding: The Bellevue School District concurs with this finding. The Budget Department’s internal procedures will be updated to include instructions for budget analysts to verify the correct indirect rate is used when preparing and reviewing grant claims. A shared document showing the historical indirect rates will continue to be updated annually and used as a reference to verify the correct rate is used in any given fiscal year. When preparing claims for reimbursement, a budget analyst will compare the indirect rate that is hard-coded in OSPI’s iGrants claim system to the calculated maximum indirect rate allowable for the fiscal year in which expenditures are incurred to ensure the correct indirect rate is used. When reviewing the claims for reimbursement, the reviewer will check the grant claim for accuracy, including verifying the indirect rate on the grant claims agrees to the calculated maximum indirect rate allowable. Anticipated date to complete the corrective action: September 30, 2023

View Audit 3931 Questioned Costs: $1

Finding 2102 (2022-002)

Material Weakness 2022

Lincoln Hall

NY

Allowable Costs / Cost Principles Cash Management Material Weakness

For the year ended June 30, 2022 audit, the audit team noted that payroll, personnel costs, and other than personnel service expenses were not being allocated by cost center on a monthly basis. This issue resulted in errors in the amount charged to various programs resulting in the need for a materi...

For the year ended June 30, 2022 audit, the audit team noted that payroll, personnel costs, and other than personnel service expenses were not being allocated by cost center on a monthly basis. This issue resulted in errors in the amount charged to various programs resulting in the need for a material allocation adjustment. In accordance with Uniform Guidance 200.405, costs that benefit multiple programs should be allocated to the programs based on the proportional benefit. Lincoln Hall did not have the adequate cost allocation mechanisms in place to properly allocate expenses throughout the year. We have been taking several steps to address the issue with allocating costs. The Federal Award Finding and Questioned Costs Finding Number 2022-002 is a result of the initial way in which the general ledger and payroll systems were set up, requiring the majority of allocation work to be done manually in Excel. These manual allocations were done in detail after fiscal year-end to ensure our financial statements at year-end were not misstated. However, this detailed allocation work was not being done on a monthly basis. We have upgraded the Serenic Navigator accounting system two times to improve its accounting capabilities and have also implemented additional allocation processes including allocation of payroll expenses of federal awards. We currently use line-item allocations in The Serenic Navigator for direct costs that are allocated when invoices are paid. During FY 2022 we are continuing to review and revise our process in order to allocate expenses (particularly payroll costs) in the general ledger on a monthly basis for allocations in the past that were performed at the end of the fiscal year. The goal of our corrective actions is to significantly limit the material reallocation of costs by function at year-end and provide us with accurate cost allocations on a monthly basis. This will allow for more accurate reporting on a month-to-month basis and, therefore, will generate more timely and accurate financial information, thereby improving our compliance with cash management during the grant period.

View Audit 3654

Finding 1758 (2022-007)

Material Weakness 2022

Arkansas Baptist College

AR

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Management does not agree with the auditor as the Department of Education Payment Analysis verifies the amount requested on Form 270 and approves payment as requested. A subsequent adjustment to a student’s financial aid does not affect the original 270. Every financial aid draw is based on known...

Management does not agree with the auditor as the Department of Education Payment Analysis verifies the amount requested on Form 270 and approves payment as requested. A subsequent adjustment to a student’s financial aid does not affect the original 270. Every financial aid draw is based on known facts as of that date.

View Audit 3046

Finding 1683 (2022-002)

Significant Deficiency 2022

The Warrior Alliance, Inc.

GA

Questioned Costs Allowable Costs / Cost Principles Cash Management

Finding 2022-002 ...

Finding 2022-002 Recommendation: The Organization’s management should ensure all expenses submitted are reimbursable. Corrective Action: The Organization will ensure someone familiar with allowable costs are preparing the payment reimbursement requests. Person Responsible for Corrective Action: President/CEO Anticipated Completion Date for Corrective Action: The corrective action will be immediately implemented in response to the auditor’s recommendation. If there are questions regarding this corrective action plan, please call Scott Johnson, President/CEO, at (404) 210-1776.

View Audit 2952 Questioned Costs: $1

Finding 1556 (2022-006)

Material Weakness 2022

Sangamon County, Illinois

IL

Questioned Costs Cash Management § 200.303

Action taken in response to finding: County department personnel changes have been implemented which address this deficiency. New department personnel have been properly trained by County Auditor staff as well as State grantor personnel to ensure correct grant reporting. Department supervising staff...

Action taken in response to finding: County department personnel changes have been implemented which address this deficiency. New department personnel have been properly trained by County Auditor staff as well as State grantor personnel to ensure correct grant reporting. Department supervising staff will monitor draw request documentation. Name(s) of the contact person(s) responsible for corrective action: Dave MacDonna, Community Resources Director. Eric Black, Chief Deputy Auditor. Planned completion date for corrective action plan: October 2, 2023

View Audit 2802 Questioned Costs: $1

Finding 1526 (2022-004)

Significant Deficiency 2022

State of Iowa

IA

Cash Management

The agency implemented a revised cash management policy for federal programs. Included in the policy and procedure are review of ledger activity, instances in which federal programs reflect excess cash on hand, immediate review of the programs revenues and expenses is performed. In addition, federal...

The agency implemented a revised cash management policy for federal programs. Included in the policy and procedure are review of ledger activity, instances in which federal programs reflect excess cash on hand, immediate review of the programs revenues and expenses is performed. In addition, federal funds drawn that exceed defined thresholds require additional approval from the Accounting and Finance Bureau Chiefs and or the Department’s Chief Financial Officer.

View Audit 2795

Finding 1497 (2022-006)

None 2022

County of Lee, Virginia

VA

Questioned Costs Subrecipient Monitoring Cash Management

Management is evaluating and will implement a process and agreements to comply with subrecipient monitoring requirements going forward

View Audit 2759 Questioned Costs: $1

Finding 1486 (2022-005)

Material Weakness 2022

Coshocton County

OH

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.403

The AOS team has already contacted CCJFS. They are aware of the issue and will take the necessary steps to avoid making this mistake in the future. The Auditor’s office will closely monitor the reporting and coding of expenditures against grant resources.

View Audit 2756 Questioned Costs: $1

Finding 1334 (2022-001)

Material Weakness 2022

Advance Housing Dmn, Inc.

NJ

HUD Housing Programs Cash Management Material Weakness

Funds were withdrawn from residual receipts reserve to cover the housing expenses since the subsidy payments were delayed considerably by HUD. This was discussed with the HUD representative and we were informed to utilize the residual receipts reserve, as needed until HUD released the subsidy funds....

Funds were withdrawn from residual receipts reserve to cover the housing expenses since the subsidy payments were delayed considerably by HUD. This was discussed with the HUD representative and we were informed to utilize the residual receipts reserve, as needed until HUD released the subsidy funds. The funds were deposited back into the residual reserve account.

View Audit 2488

Finding 1330 (2022-003)

Material Weakness 2022

Demarest Farms 2, Inc.

NJ

HUD Housing Programs Cash Management Material Weakness

When management of the Project became aware that the funds were withdrawn for needed repair and renovations to the Project from the residual receipts reserve, the funds were transferred back to the residual receipts account.

View Audit 2487

Finding 1329 (2022-002)

Material Weakness 2022

Demarest Farms 2, Inc.

NJ

Cash Management HUD Housing Programs Material Weakness

Management of the Project was aware they are responsible for complying with laws and regulations and that they are to remit any surplus cash funds to the residual receipts account within 60 days following the end of the fiscal year. Management remitted the 2021 excess of $17,102 on December 14, 2022...

Management of the Project was aware they are responsible for complying with laws and regulations and that they are to remit any surplus cash funds to the residual receipts account within 60 days following the end of the fiscal year. Management remitted the 2021 excess of $17,102 on December 14, 2022. Management remitted the 2020 excess of $18,386 on March 18, 2022.

View Audit 2487

Finding 1143 (2022-002)

Material Weakness 2022

Shalom Health Care Center, Inc.

IN

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

Shalom Health Care Center, Inc. is reclassifying payroll allocations to better align with the departments and funding sources. Shalom Health Care Center, Inc. is working with the payroll company to match the allocations in the payroll system to better identify cost allocation of payroll and funding ...

Shalom Health Care Center, Inc. is reclassifying payroll allocations to better align with the departments and funding sources. Shalom Health Care Center, Inc. is working with the payroll company to match the allocations in the payroll system to better identify cost allocation of payroll and funding source.

View Audit 2190

Finding 939 (2022-001)

Material Weakness 2022

Kinteel Residential Campus INC

NM

Allowable Costs / Cost Principles Cash Management

Contact Person: Veryl Begay, Business Manager Anticipated Completion Date: December 31, 2023 Planned Corrective Action: On December 19, 2017, KRCI set up an account with Atlantic Coast Life to “invest funds”. The initial investment was $388,532 and the amount was presented to the Account Represen...

Contact Person: Veryl Begay, Business Manager Anticipated Completion Date: December 31, 2023 Planned Corrective Action: On December 19, 2017, KRCI set up an account with Atlantic Coast Life to “invest funds”. The initial investment was $388,532 and the amount was presented to the Account Representative in the form of a cashiers check. On August 8, 2018, KRCI opened a second account with Atlantic Coast Life in the amount of $74,799. The annuitant and only signatory on record is a Board member. The past three audits have indicated that these accounts are a finding because they are not insured by the FDIC or any other acceptable entity. The Director has reached out to Atlantic Coast Corporate Office to close out or surrender these accounts.

View Audit 1787

Finding 916 (2022-001)

None 2022

Pilgrim Towers, Inc.

CT

HUD Housing Programs Cash Management Reporting

Finding No. 2022-001: Federal Awards Federal Program Information: Assistance Listing Program Title and Number: Flexible Subsidy Loan #14.164 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: NI A Description of Finding: The Flexible Subsidy Loan "Residual Receipts...

Finding No. 2022-001: Federal Awards Federal Program Information: Assistance Listing Program Title and Number: Flexible Subsidy Loan #14.164 Federal Agency: U.S. Department of Housing and Urban Development Pass-through Entity: NI A Description of Finding: The Flexible Subsidy Loan "Residual Receipts note" clause 3(a) cites that the entire principal together with interest is immediately due and payable when the HUD Section 202 mortgage is paid off. The agency appears to be in default as it has not yet established terms or'repayment with HUD. Statement of Concurrence: Pilgrim Towers, Inc. concurs with the audit finding. Corrective Action: Pilgrim Towers, Inc. will be following up with its HUD field representative to determine the next steps for repayment related to the Flexible Subsidy loan. They continue to follow-up with HUD to attempt to receive a response. Name of Contact Person: Pat Thatcher, Executive Director, patthatcherl@gmail.com Projected Completion Date: December 31, 2023

View Audit 1699

Finding 892 (2022-005)

None 2022

Lawrence County, Missouri

MO

Cash Management Eligibility

The County has procedures in place to ensure federal funds are disbursed in a timely fashion and will take particular care to assure the procedures are followed so such an oversight doesn't occur again.

View Audit 1651

Corrective Action Plans

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