Corrective Action Plans

Finding 529816 (2023-008)

Significant Deficiency 2023

MT

Cash Management § 200.500

Hill County is responsible for complying with Uniform Guidance and all compliance requirements as required by the contract and federal award documents for reimbursement grants, as it relates to recording of the related award expenditures. Prior to payment of expenditures with award funds, recipients...

Hill County is responsible for complying with Uniform Guidance and all compliance requirements as required by the contract and federal award documents for reimbursement grants, as it relates to recording of the related award expenditures. Prior to payment of expenditures with award funds, recipients must verify proper account and fund recording, pursuant to 2 CFR section 200.500. The coding of the invoices has improved. There is a detailed list of how each vendor should be coded. There are still times invoices need to transfer to a different fund in order to utilize the funding more efficiently. The grant coordinator has discussed everything. The tracking sheets are double checked with county accounting system. The transfers that are done have already been approved and paid. The expenditures are transferred to match the grant coordinator. Expenditure transfers can be done if the expenditure was incorrectly codes.

View Audit 347804

Finding 528805 (2023-003)

None 2023

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 346856

Finding 528804 (2023-002)

None 2023

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 346856

Finding 528313 (2023-001)

Significant Deficiency 2023

Georgia Association of Conservation Districts, Inc.

GA

Internal Control / Segregation of Duties Cash Management Reporting

2020-01: Segregation of Duties Name of contact person: Katie Sponberger, 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...

2020-01: Segregation of Duties Name of contact person: Katie Sponberger, 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. The costs of segregating certain duties exceeds the benefit and therefore, nonfinancial employees will be trained to provide some assistance in these areas. Proposed completion date: The Board will implement the above procedure immediately.

View Audit 346370

Finding 526661 (2023-002)

Material Weakness 2023

Foresthill Union School District

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District agrees and has already implemented processes to ensure receivables are created with each claim created in CNIPS

View Audit 345656 Questioned Costs: $1

Finding 526546 (2023-005)

Material Weakness 2023

Dunseith Public School District No. 1

ND

Internal Control / Segregation of Duties Cash Management Reporting

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date is June 30, 2025.

View Audit 345466

Finding 526464 (2023-003)

Significant Deficiency 2023

Okanogan County Child Development Association

WA

Internal Control / Segregation of Duties Cash Management Significant Deficiency

Recommendation: The Association establish controls that allow for the timely and accurate recording of grants and contracts receivable from reimbursement-based awards in the same period as their corresponding expenditures. Explanation of disagreement with audit finding: There is no disagreement with...

Recommendation: The Association establish controls that allow for the timely and accurate recording of grants and contracts receivable from reimbursement-based awards in the same period as their corresponding expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Containment Through this audit process and staff turnover, tasks have been distributed and processes have been implemented immediately to meet the expectations that an AR transaction be entered into the fiscal system within a timely manner of one week or sooner. Root Cause Due to a lack of knowledge of the new software system. Not all information was migrated into the new software system in a timely manner, making it difficult to use at its full potential. OCCDA had a large turnover in the fiscal team during the audit process. The transition to the new fiscal software was during the height of the COVID-19 pandemic, making it difficult to complete training and migration of the new system. Action Taken Immediately in 2023, the fiscal team implemented adding reports/documentation to all requests for funding to allow for better tracking and record keeping. Newly hired staff have established a clear understanding of the naming conventions for clarity and accurate reporting. Tasks have been realigned to specific positions so that all duties are covered and responsibilities are defined. This will ensure that all fiscal tasks are completed timely and accurately establishing controls for reimbursement funding. Training has been provided for the fiscal team on the internal processes and procedures to ensure the timely entry of all data and the importance of accurate monthly reports. We have reorganized the chart of accounts in support of the software consultants, we have added additional program numbers to track grants separately by funding year to allow us to close each grant yearly. Our Fiscal Assistant has been trained to complete all accounts receivable. Receivable billings are completed in the month that they are performed. All receipts are recorded in the month they are received. Monthly reports continue to be sent out each month for the Leadership team to review, allowing for transparency and additional reviews and accuracy. All bank reconciliations were completed and brought up to date in 2023. The GL accounts were updated for better separation and grant tracking. Updated our policy and procedures for recording revenue in the same period it occurred. We have updated internal controls and procedures for reconciling and reviewing all revenue and expenses regularly.

View Audit 345386

Finding 526324 (2023-004)

Material Weakness 2023

Community Resource Center, Inc.

CO

Questioned Costs Allowable Costs / Cost Principles Cash Management

As noted in the finding, the significant staff turnover and financial constraints during the audit period caused some disruption in our ability to provide the necessary documentation for certain transactions. In light of this, we have developed and implemented a corrective action plan to ensure full...

As noted in the finding, the significant staff turnover and financial constraints during the audit period caused some disruption in our ability to provide the necessary documentation for certain transactions. In light of this, we have developed and implemented a corrective action plan to ensure full compliance with 2 CFR 200, grant agreements, and cost principles going forward. 1. Strengthening Documentation Procedures: o Community Resource Center, Inc. has committed to implementing a process in which all transactions will be supported by actual invoices and all reimbursement requests will be submitted with corresponding supporting documentation. This will include both the original invoices and any other necessary backup materials. o Community Resource Center, Inc. is working with a financial consultant (start date on November 1, 2024), to audit and refine the the financial systems, with particular emphasis on improving the accuracy and transparency of our documentation processes. The financial consultant will also assist in ensuring that all future costs align with the requirements of the funding agency and the OMB guidelines. 2. Review and Update of Internal Controls: o In response to the finding, Community Resource Center, Inc. has begun revising internal controls to ensure that adequate checks and balances are in place, especially in times of staff turnover. This includes designing more robust systems for tracking and documenting all costs related to grants, ensuring that all documentation is easily accessible for audit and review purposes. o A dedicated team will be assigned to monitor compliance with the internal control processes, and we will conduct regular internal reviews to verify that supporting documentation for all transactions is complete, timely, and accurate. 3. Contingency Planning for Staff Turnover: o Recognizing the impact of turnover, Community Resource Center, Inc. is formalizing a contingency plan for future staff changes. This plan will include clear guidance on the retention and transfer of all financial records, as well as designating backup staff with sufficient training and authority to oversee and maintain compliance with all financial requirements. We will also implement cross-training for key financial personnel to ensure continuity and consistency in the event of unexpected departures. 4. Ongoing Staff Training: o Community Resource Center, Inc. is committed to providing ongoing training to staff responsible for financial reporting and compliance. This will ensure that all staff involved in grant transactions understand the requirements set forth in 2 CFR 200 and other applicable regulations. Community Resource Center, Inc. will also work with the financial consultant to identify and address any skill gaps within the team. 5. Monitoring and Audit of Corrective Actions: o Community Resource Center, Inc. will establish regular internal monitoring and audits of these corrective actions to ensure they are being followed effectively. This will include periodic spot-checks of transaction documentation to ensure completeness and accuracy, as well as regular reviews of our internal controls and procedures to ensure their ongoing effectiveness.

View Audit 345263 Questioned Costs: $1

Finding 525947 (2023-007)

Significant Deficiency 2023

Glacierland Resource Conservation and Development Council, Inc.

WI

Cash Management Reporting Matching / Level of Effort / Earmarking

Finding: 2023-007 • Condition: We identified differences in the amounts of costs reported to grantors compared to actual costs incurred during those periods. • Planned Corrective Action: Financial policies created will identify a double check system in which the bookkeeper and the Executive Directo...

Finding: 2023-007 • Condition: We identified differences in the amounts of costs reported to grantors compared to actual costs incurred during those periods. • Planned Corrective Action: Financial policies created will identify a double check system in which the bookkeeper and the Executive Director must both review the documentation for a given period to ensure accuracy. Contact Person: Katherine Jaeger Anticipated Date of Completion: 2/21/2025

View Audit 345115

Finding 525896 (2023-001)

Material Weakness 2023

Moses Lake School District No. 161

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls and did not comply with allowable activities and allowable costs requirements. Name, address, and telephone of District contact person: Mitch Thompson 1620 S. Pioneer Way Moses Lake, WA 98837 (...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls and did not comply with allowable activities and allowable costs requirements. Name, address, and telephone of District contact person: Mitch Thompson 1620 S. Pioneer Way Moses Lake, WA 98837 (509) 766-2650 Corrective action the auditee plans to take in response to the finding: While the district concurs with the finding that it didn’t have adequate internal controls during the 2022-23 school year, the district disagrees that the monies were not spend on allowable costs under the grants. The district has changed leadership as well as accounting staff. Following the change, the new Executive Director of Finance & Operations instituted measures to ensure that the district complies with grant claims and journal entry procedures. One of the changes was that the person who inputs the journal entries has those entries reviewed by another person. This means that if the Accounting Supervisor inputs the journal entry, the Executive Director of Finance & Operations reviews the entry for accuracy as well as if the expenditures are allowable under the new account code(s). One of the other changes put into place was the implementation of uploading the supporting documentation into the accounting system the district uses so that the documentation doesn’t get lost or misplaced. The district realizes the importance of verifying expenditures and internal reviews to ensure accuracy and these two actions by the district will ensure compliance and proper internal controls. Anticipated date to complete the corrective action: 12/31/2024

View Audit 345047 Questioned Costs: $1

Finding 525594 (2023-001)

Material Weakness 2023

Child Start, Inc.

MT

Questioned Costs Allowable Costs / Cost Principles Cash Management

Invalid Journal Entries (Compliance) Recommendation: We recommend the Organization perform a thorough year-end review which should include comparing current balances to the prior year, reviewing details of account balances, as necessary, and reviewing journal vouchers posted during the year for reas...

Invalid Journal Entries (Compliance) Recommendation: We recommend the Organization perform a thorough year-end review which should include comparing current balances to the prior year, reviewing details of account balances, as necessary, and reviewing journal vouchers posted during the year for reasonableness, prior to submitting reimbursement requests for federal programs. Management’s Response: We concur with the recommendation, and the corrective action will be implemented as of January 31, 2025.

View Audit 344694 Questioned Costs: $1

Finding 525591 (2023-004)

Material Weakness 2023

Child Start, Inc.

MT

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

Recommendation: We recommend the Organization obtain a better understanding of the accounting system to allow for a thorough year-end close and review process. The year-end review should include reviewing current balances compared to the prior year, reviewing grant drawdowns near year-end to ensure ...

Recommendation: We recommend the Organization obtain a better understanding of the accounting system to allow for a thorough year-end close and review process. The year-end review should include reviewing current balances compared to the prior year, reviewing grant drawdowns near year-end to ensure they are recognized in the fiscal year the related costs were incurred, agreeing federal revenues earned to federal expenditures for cost-reimbursable grants, and reviewing details of account balances, as necessary, prior to providing the trial balance for audit. Management’s Response: We concur with the recommendation, and the corrective action will be implemented as of January 31, 2025.

View Audit 344694

Finding 525544 (2023-002)

Significant Deficiency 2023

Communities in Schools of Georgia, Inc.

GA

Allowable Costs / Cost Principles Cash Management Reporting

Communities In Schools of Georgia acknowledges the audit recommendation and is committed to strengthening internal controls related to journal entries and supporting documentation. During fiscal year 2024, we took the following actions to improve the integrity of our finance processes and controls ...

Communities In Schools of Georgia acknowledges the audit recommendation and is committed to strengthening internal controls related to journal entries and supporting documentation. During fiscal year 2024, we took the following actions to improve the integrity of our finance processes and controls over compliance with federal grant requirements: • Engaged Senior Finance Contractor • Initiated Search for Permanent full-time CFO • Completed implementation of new accounting software Under the leadership of our newly hired CFO, we are continuing to improve our finance processes by implementing the following measures: • Internal Controls for Journal Entries • Segregation of Duties • Workflow Approvals • Training and Process Standardization By implementing these measures, we aim to strengthen financial oversight and ensure accurate financial reporting and compliance with federal grant requirements. We appreciate the auditors’ recommendations and remain committed to establishing and maintaining robust internal controls.

View Audit 344624

Finding 525311 (2023-006)

Significant Deficiency 2023

Second Harvest Community Foodbank

MO

Cash Management Reporting

We agree with the auditor’s comments and the following action will be taken to improve this situation. Second Harvest staff are currently engaged with outside resources and support to develop an appropriate cost segregation plan which will address direct costs and indirect costs including salary, f...

We agree with the auditor’s comments and the following action will be taken to improve this situation. Second Harvest staff are currently engaged with outside resources and support to develop an appropriate cost segregation plan which will address direct costs and indirect costs including salary, fringe benefits, and non-salary costs. Through this process a spreadsheet will be developed to better distribute costs appropriately across all federal programs operated by Second Harvest and efforts supported through additional funding sources. This corrective action will be implemented by February 1, 2025.

View Audit 344536

Finding 525281 (2023-001)

Material Weakness 2023

African American Child Wellness Institute

MN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

To: U.S. Department of Health and Human Services-Passed through Minnesota Department of Human Services RE: Single Audit Corrective Action Plan (CAP) for the fiscal year ended December 31, 2023 Name and address of independent accounting firm: BWK Rogers PC 431 South Seventh Street, Suite 2424 Minn...

To: U.S. Department of Health and Human Services-Passed through Minnesota Department of Human Services RE: Single Audit Corrective Action Plan (CAP) for the fiscal year ended December 31, 2023 Name and address of independent accounting firm: BWK Rogers PC 431 South Seventh Street, Suite 2424 Minneapolis, MN 55415 African American Child Wellness Institute submits the following corrective action plan for the year ended December 31, 2023. Please contact Akinyele Akinsanya at 763-522-0100. Finding 2023-001 Noncompliance-Allowable Costs/Costs Principles Material Weakness ALN 93.958 Block Grants for Community Mental Health Services Pass-through Entity Identification Number GRK 213195 U. S. Department of Health and Human Services Minnesota Department of Human Services Condition: Expenses charged to the federal grant cannot be traced into the Organization’s general ledger. Invoices submitted to the pass-through agency for reimbursement also cannot be traced into the general ledger. Actions Planned in Response to the Finding: It is clear to management that the Organization needs to boost its accounting team to fulfil effective reporting that could easily be traced into the organization’s general ledger. As a result, the organization will recruit and hire a full-time accountant to work with the current team. Further steps may be required including replacing the organization’s current accounting software that will identify and record expenditure specific to each cost centers for each federal grant. The in-house accountant will also be required to obtain additional training in Uniform Guidance and federal grant management and create a system of financial reporting to record expenditure directly to each federal grant award. Official Responsible for Ensuring the CAP: Chief Operating Officer Planned Completion Date for the CAP: March 15, 2025

View Audit 344524 Questioned Costs: $1

Finding 524860 (2023-002)

Material Weakness 2023

A+ Arts Academy

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management

Construction projects for A+ Arts were facilitated by the management company with approval from the Board of Directors. Although the likelihood of additional construction projects being done in the future using Federal dollars since ESSER funds are no longer available is very remote, the management ...

Construction projects for A+ Arts were facilitated by the management company with approval from the Board of Directors. Although the likelihood of additional construction projects being done in the future using Federal dollars since ESSER funds are no longer available is very remote, the management company is aware of the prevailing wage and certified payroll requirement and will make sure any future projects adhere to these requirements.

View Audit 344218

Finding 524631 (2023-001)

None 2023

Town of Kearny

NJ

Questioned Costs Cash Management Eligibility

Project Worksheets for FEMA reimbursements will be made available for the audit

View Audit 344064 Questioned Costs: $1

Finding 524563 (2023-001)

Significant Deficiency 2023

Housing Forward

TX

Questioned Costs Allowable Costs / Cost Principles Cash Management

Below is Housing Forward’s response to the audit finding for fiscal year 1/1/2023 through 12/31/2023. Federal Award Finding Finding 2023-001: Allowable costs and activities – significant deficiency in internal controls over compliance and compliance finding specific to payroll allocation.  Funding ...

Below is Housing Forward’s response to the audit finding for fiscal year 1/1/2023 through 12/31/2023. Federal Award Finding Finding 2023-001: Allowable costs and activities – significant deficiency in internal controls over compliance and compliance finding specific to payroll allocation.  Funding Source: Coronavirus State and Local Fiscal Recovery Funds ALN 21.027 (CSLFRF).  Condition: During allowable cost and activities testing for the CSLFRF grant, 2 out of 40 timesheets tested did not agree to the number of hours charged to the grant.  Cause: Although the 2 timesheets were filled out completely, signed and reviewed by a supervisor, there was an error in the data entry into the accounting software. Amounts were calculated correctly but inadvertently assigned to the wrong grant. GL detail was provided to the funder as part of the monthly reporting, but neither the funder nor Housing Forward staff noticed this error.  Management’s Response: Management understands the importance of correctly charging time to funders. Housing Forward will continue its timesheet review process and utilize employee timesheets that clearly indicate funding sources and allocate payroll costs based on these records. Housing Forward will implement a second review of the payroll entry at the time it is entered into the accounting system to ensure that errors are corrected before payroll costs are charged to funders. This began in January 2025. The second reviewer will be the VP of Finance/CFO or her designee. In later FY25 the organization also plans to implement a timekeeping software that integrates with the accounting software to prevent future data entry errors. Sincerely, Sarah Kahn Sarah Kahn President & CEO

View Audit 343995 Questioned Costs: $1

Finding 524401 (2023-002)

Material Weakness 2023

Sinai Health System and Affiliates

IL

Questioned Costs Period of Performance Subrecipient Monitoring § 200.308 § 200.309 § 200.403

Condition: Controls did not identify that expenses submitted to the State were outside of the period of performance. Planned Corrective Action: Background: Sinai began the process of risk assessment in the government grants area at the end of 2022. At that time, Sinai engaged outside counsel to as...

Condition: Controls did not identify that expenses submitted to the State were outside of the period of performance. Planned Corrective Action: Background: Sinai began the process of risk assessment in the government grants area at the end of 2022. At that time, Sinai engaged outside counsel to assist in this process. In December of 2023, Sinai created the Office of Government Grant Administration (OGGA) and developed a comprehensive grant compliance policy and procedure. The Audit and Compliance Committee of the Board was updated on this initiative. In 2024, the OGGA created a Grant Compliance Manual which sets forth processes and procedures in grant management to ensure compliance with government regulations. Unfortunately, these controls were not implemented until after the relevant time period at issue in this audit. In 2025, Sinai is continuing to improve its compliance procedures with respect to government grants, and has developed the following plan: 1. Working Group: Sinai will implement a process of convening a Working Group for each government grant, which will consist of a representative from Finance, the OGGA, and the stakeholder involved (i.e., nursing, medicine, etc.) The Working group will be responsible for, among other things, ensuring that that the reported qualifying expenditures are incurred during the period of performance of the grant. In other words, allowable costs will be discussed early in the process, so that there is fulsome understanding among the key individuals involved. 2. Record-Keeping: The OGGA will also establish shared folders to house all of the pertinent documentation relative to the grant. 3. Invoice/Supporting Documentation Review. The Grant Accounting Manager will review all invoices and other supportive documentation to ensure that allowable costs are submitted for reimbursement. This compliance check will be completed prior to submission of the documentation for reimbursement. Monthly reviews of these activities will be performed by the Grant Accountant, the Compliance Grant Manager, and other OGGA staff as needed. Proactive review to prevent or resolve issues in the upcoming month’s billings should be pursued. 4. Annual Assessment. The Chief Compliance Officer, with the assistance of the General Counsel, will meet with the OGGA team annually to assess procedures and risk controls; a report of this assessment will be made to the Audit and Compliance Committee of the Board of Directors Contact person responsible for corrective action: Dimas Ortega - Vice President of Finance, Deputy Chief Financial Officer Anticipated Completion Date: 06/30/2025

View Audit 343640 Questioned Costs: $1

Finding 523669 (2023-001)

Significant Deficiency 2023

Fair & Balanced Pf Pa, Inc.

PA

Questioned Costs Cash Management Significant Deficiency

We understand the importance of proper review of reimbursement requests and are working to improve our system.

View Audit 343096 Questioned Costs: $1

Finding 523546 (2023-002)

Significant Deficiency 2023

Pennsylvania Housing Finance Agency

PA

Questioned Costs Cash Management HUD Housing Programs

U.S. Department of Housing and Urban Development Housing Trust Fund Program – Assistance Listing No. 14.275 Recommendation: CLA recommended that PHFA review their procedures around administrative expenses charged to the HTF program. Explanation of disagreement with audit finding: There is no disa...

U.S. Department of Housing and Urban Development Housing Trust Fund Program – Assistance Listing No. 14.275 Recommendation: CLA recommended that PHFA review their procedures around administrative expenses charged to the HTF program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PHFA will implement electronic time tracking, this will replace the current manual process of preparing timesheets that are entered into a database used to accumulate administrative expenses charged to federal programs. PHFA is currently in the process of implementing a Human Capital Management system that will allow employees to track the time they work on federal programs. Name of the contact person responsible for corrective action: Adrianne Trumpy, Director of Accounting Planned completion date for corrective action plan: July 1, 2024

View Audit 342838 Questioned Costs: $1

Finding 523544 (2023-007)

Significant Deficiency 2023

Alternatives, Inc.

IL

Cash Management Reporting

Due to limited staffing resources, the Organization was not able to ensure maintenance of adequate documentation. The Organization has made efforts to ensure that proper documentation is maintained and accessible by necessary staff.

View Audit 342835

Finding 523400 (2023-002)

Significant Deficiency 2023

Houston Recovery Center, Lgc

TX

Cash Management Reporting Significant Deficiency

Finding #2023-002 – Significant Deficiency. Major federal programs: U. S. Department of Treasury, Assistance Listing #21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed through Harris County, Texas, Contract #220163, Contract year: 12/01/22 – 12/31/24, Assistance Listing #93...

Finding #2023-002 – Significant Deficiency. Major federal programs: U. S. Department of Treasury, Assistance Listing #21.027, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Passed through Harris County, Texas, Contract #220163, Contract year: 12/01/22 – 12/31/24, Assistance Listing #93.788, Opioid STR, Passed through the Texas Health and Human Services Commission, Contract #HHS000357900001, Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23, Passed through the University of Texas Health Science Center, San Antonio, Contract #HHS000561800001, Contract year: 09/01/21 – 08/31/22. Other federal programs: U. S. Department of Health and Human Services:, Assistance Listing #93.243, Substance Abuse and Mental Health Services Projects of Regional and National Significance, Contract #5H79TI080624-03, Contract year: 09/30/21 – 09/29/22, Contract #5H79TI080624-04, Contract year: 09/30/22 – 09/29/23, Passed through the City of Houston Health Department, Assistance Listing #93.243, Contract #H79SP080300, Contract years: 11/01/21 – 10/31/22, 11/01/22 – 10/31/23 and 06/08/21 – 06/30/23, Assistance Listing #93.959, Block Grants for Prevention and Treatment of Substance Abuse, Passed through the Texas Health and Human Services Commission, Contract #HHS000130500019. Contract years: 09/01/21 – 08/31/22 and 09/01/22 – 08/31/23. Condition and context: Houston Recovery Center is required to submit monthly reimbursement requests for five of its federal programs; one program requires reimbursement requests based on achievement of certain milestones rather than time. Out of a sample of 17 requests for the five reimbursement programs, we found six did not have evidence of review and approval as required by Houston Recovery Center’s policies and procedures. Recommendation: Training should be provided to ensure that policies and procedures regarding independent review and approval are followed. Planned corrective action: Houston Recovery Center will strengthen its internal control policies and procedures over independent review and approval of grant payment requests by shifting the primary review and approval process from the Chief Executive Officer (CEO) to the Chief Operating Officer (COO). The COO has full knowledge of allowable costs and has more availability than the CEO, which will make it easier to ensure that our policies and procedures are followed on a consistent basis. The CEO will continue in this role as backup to the COO to ensure immediate access for needed approval. We believe we have a strong system in place used by our accounting department to ensure all expenses underlying the grant payment requests are reviewed, checked for accuracy, and properly approved which further supports the reimbursement policies and procedures. Responsible officer: Leonard Kincaid, Executive Director. Estimated completion date: November 1, 2023.

View Audit 342673

Finding 523390 (2023-004)

Material Weakness 2023

Hope Community Services, Inc.

OK

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Cash Management § 200.303 § 200.403

Department of Health and Human Services, Passed Through Substance Abuse and Mental Health Services Administration, Section 223 Demonstration Programs to Improve Community Mental Health Services Listing 93.829, H79SM085287, 8/31/2022- 8/30/2023 Allowable Activities or Unallowed, Allowable Costs/Cost ...

Department of Health and Human Services, Passed Through Substance Abuse and Mental Health Services Administration, Section 223 Demonstration Programs to Improve Community Mental Health Services Listing 93.829, H79SM085287, 8/31/2022- 8/30/2023 Allowable Activities or Unallowed, Allowable Costs/Cost Principles, Cash Management, and Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: As part of the audit, Eide Bailly LLP identified that the process for allocating payroll or time worked to respective federal programs was insufficient and did not substantiate allowability under the federal award guidelines. Responsible Individuals: Chief Financial Officer and Chief Human Resources Officer Corrective Action Plan: In December 2024, changes were made to the payroll system to improve tracking of time worked and appropriate allocations to respective federal grant programs. Completion Date: December 2024

View Audit 342657

Finding 522901 (2023-004)

Significant Deficiency 2023

Clarkson University

NY

Questioned Costs Cash Management Internal Control / Segregation of Duties § 200.303

Management accepts this finding and notes that the University’s policy regarding drawdowns was updated in August 2023 to clarify our procedures to include a secondary review by someone other than the preparer of the drawdown request. “Awards from federal agencies are not paid in full or in advance a...

Management accepts this finding and notes that the University’s policy regarding drawdowns was updated in August 2023 to clarify our procedures to include a secondary review by someone other than the preparer of the drawdown request. “Awards from federal agencies are not paid in full or in advance at the time they are awarded to the University. Instead, the University is required to draw funds down from the federal agencies payment systems periodically to reimburse the University for its expenses on all of our federal grants. The Research Accountant accesses the federal payment systems periodically to prepare cash drawdowns for reimbursement of expenditures on federal grants at the University. The Research Accountant receives a report on all sponsored projects. That list of grants can be used to run an expense detail report for the period of time that the reimbursement request is covering on a monthly schedule throughout the year. That list of grants can also be used to check that our records are up to date and accurate as far as award amounts and budgets are concerned. The payment request amount is calculated as the difference between the Cumulative Expenses as of the end date of the month you are doing the drawdown for and the Cumulative Expenses as of the last day of the period the last drawdown was requested. This calculation is done on each active award and the sum of all of the calculated payment requests is the total amount of the drawdown to be requested. The payment calculations are reviewed and approved by either the Sr. Research Accountant, Associate Controller or Controller. In the event the Sr. Research Accountant prepares the drawdown, the Associate Controller or the Controller must review and approve prior to submission. After receiving approval, whoever initiated the drawdown will submit and certify the drawdown. In no circumstance, shall the preparer submit and certify without first obtaining approval from the Associate Controller or Controller.” It has also been the practice in the Controller’s Office that drawdowns are posted to the General Ledger by the AR Specialist/Cashier as they appear in the M&T bank account which the bank reconciliation process is then separate from and performed by someone other than the person preparing the drawdown. The Controller’s Office also documented Drawdown Procedures in order to clarify the process. In July 2023, the Controller’s Office added an additional Research Accountant bringing the staff from one to two employees to better share and segregate job duties.

View Audit 342222 Questioned Costs: $1

Corrective Action Plans

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