Corrective Action Plans

Finding 375948 (2021-001)

Significant Deficiency 2021

Middle Tennessee Electric Membership Corporation

TN

Questioned Costs Cash Management Eligibility

Since the date of the deficiency was identified, the MTE Finance Department recalculated the allowable costs for the project worksheet #136175 and submitted a revised worksheet to FEMA. We met with the employees responsible for completion and filing of eligible costs with FEMA. We believe this was a...

Since the date of the deficiency was identified, the MTE Finance Department recalculated the allowable costs for the project worksheet #136175 and submitted a revised worksheet to FEMA. We met with the employees responsible for completion and filing of eligible costs with FEMA. We believe this was an isolated incident due to preparation and submittal on our behalf by an independent contractor. We will have an employee of the Finance Department perform a review of any future projects submitted for reimbursement.

View Audit 295000 Questioned Costs: $1

Finding 375454 (2021-003)

Material Weakness 2021

Hale County Hospital

AL

Reporting Cash Management Eligibility

We are implementing policies to address the audit finding 2021-003 as follows: We have implemented a policy to ensure that all future Provider Relief Fund reporting is reviewed prior to filing. Anticipated completion date: September 30, 2024

View Audit 294509

Finding 375383 (2021-011)

None 2021

Cleveland County

OK

Questioned Costs Allowable Costs / Cost Principles Eligibility

21.019 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirements - Coronavirus Relief Fund The Cleveland County Board of County Commissioners (BOCC) will implement policies and procedures to ensure compliance with applicable grant requirements. Specifically,...

21.019 Noncompliance with Activities Allowed or Unallowed and Allowable Costs/Cost Principles Requirements - Coronavirus Relief Fund The Cleveland County Board of County Commissioners (BOCC) will implement policies and procedures to ensure compliance with applicable grant requirements. Specifically, the BOCC will ensure grant funds are expended on allowed costs as set forth by the grant. Anticipated Completion Date: On Going April 2021 Responsible Contact Person: Rod Cleveland,Chairman BOCC

View Audit 294443 Questioned Costs: $1

Finding 371938 (2021-003)

Significant Deficiency 2021

Martin University

IN

Student Financial Aid Matching / Level of Effort / Earmarking Eligibility

Enrollment reporting procedures should be strengthened Corrective action: The University submitted a correction action plan that was acceptable by DOE. and implemented effective 9/1/2022. Person responsible: Qiana Hall, Associate VP of Enrollment Services Anticipated Completion Date: Completed

View Audit 293212

Finding 370593 (2021-014)

Material Weakness 2021

Kickapoo Tribe in Kansas

KS

Eligibility Material Weakness Significant Deficiency

Finding 2021-014 Eligibility Individual(s) Responsible: Paul Austin, Program Director with supervision from Grace Ross, Tribal Treasurer Action: Will ensure that all patients provide eligibility documentation. Anticipated Completion Date: September 2024

View Audit 292271

Finding 370054 (2021-009)

Material Weakness 2021

Delaware County

OK

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.403

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

View Audit 291562 Questioned Costs: $1

Finding 369848 (2021-013)

Material Weakness 2021

Trinity Community Housing CORP

IL

Eligibility HUD Housing Programs

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291369

Finding 369835 (2021-022)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman

View Audit 291368

Finding 369833 (2021-020)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman

View Audit 291368

Finding 369832 (2021-019)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman

View Audit 291368

Finding 369831 (2021-018)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman

View Audit 291368

Finding 369830 (2021-017)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman

View Audit 291368

Finding 369829 (2021-016)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

Eligibility HUD Housing Programs

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman

View Audit 291368

Finding 369828 (2021-015)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

HUD Housing Programs Eligibility

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that all payroll records are available for examination purposes. Responsible party: Eric Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291368

Finding 369741 (2021-005)

Material Weakness 2021

New Vision Foundation

MN

Questioned Costs Eligibility Material Weakness

Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation Auditor recommends the Organization attend training, review federal requirements, and fully understand the eligibility requirements of children they can serve if they apply for funding with this program again. Explanati...

Child and Adult Care Food Program - Assistance Listing No. 10.558 Recommendation Auditor recommends the Organization attend training, review federal requirements, and fully understand the eligibility requirements of children they can serve if they apply for funding with this program again. Explanation of disagreement with audit finding The Child and Adult Care Food Program was created as an emergency response during the COVID-19 pandemic. In such an emergent situation, management believes the federal government acted in good faith to meet the needs of the country by contracting with regional sponsoring organizations. New Vision Foundation was selected by the sponsoring organization to be a community-based food provider to culturally-specific populations. All activities related to the program were expressly approved by the sponsoring organization. The finding of material noncompliance is overstated. Management followed all guidelines and fulfilled all obligations outlined by Feeding Our Future. In addition, Feeding Our Future indicated that management should sign up all children requesting to be part of the program which was approved per a waiver provided by USDA. Management was not notified that the waiver had not been renewed after June 30, 2020. Action taken in response to finding The program noted was discontinued at the end of 2021. If the Organization enters into any other federal funding, we will consult with experts on compliance requirements from the start of the grant. Name of the contact person responsible for corrective action Hussein Farah, Executive Director Planned completion date for corrective action plan N/A

View Audit 291230 Questioned Costs: $1

Finding 369636 (2021-002)

Significant Deficiency 2021

Mobile Housing Authority

AL

Eligibility HUD Housing Programs Significant Deficiency

MHA will review and enhance as necessary the program’s existing quality control (QC) daily data validation reports to include a measure that cross-checks existing reports in the Yardi system of record and aids in validating data routinely submitted to HUD’s PIC system. In 2023, MHA implemented a Hou...

MHA will review and enhance as necessary the program’s existing quality control (QC) daily data validation reports to include a measure that cross-checks existing reports in the Yardi system of record and aids in validating data routinely submitted to HUD’s PIC system. In 2023, MHA implemented a Housing Specialist-II team lead to oversee staff processing annual reexaminations in accordance with 24 CFR 982.516. This team member is responsible for ensuring families are notified in a timely manner and if they do not comply with the annual reexamination requirement, they receive termination notices in compliance with HUD and MHA Administrative Plan requirements. This information will be maintained in the program file. Responsible Person: Magdalene Watkins, Program Administrator Projected Completion Date: March 31, 2024

View Audit 291023

Finding 369290 (2021-025)

None 2021

Saint Augustine's University

NC

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an auto...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an automated solution to gather information and documentation required for Financial Aid Verification. Inceptia uses innovative technology to apply progressive rules for automatically or manually approving verification. Furthermore, it provides efficient and effective processes to help institutions remain compliant by organizing documents, streamlining award packaging, and allowing staff to manage the verification process. It provides the institution with the internal controls it needs over its Title IV funding. The Financial Aid Staff also can manually verify students if needed. With Colleague and Inceptia, SAU now has a more unified operating system for systematic processes. If a student has been flagged for verification, Colleague will not allow staff to award the student financial aid. One of the award eligibility rules is "Verification Complete." If students fail to pass this rule, they will not be awarded financial aid. Colleague gives the Financial Aid Staff greater control over the disbursal of Title IV funds and prevents the FAO from disbursing aid to students who are ineligible to receive it. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369285 (2021-020)

None 2021

Saint Augustine's University

NC

Student Financial Aid Eligibility Reporting

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolve...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolved. Utilizing Colleague's software, the financial aid office can now accurately assess our students' aid eligibility to ensure they are appropriately awarded. Colleague has Award Eligibility Criteria (AEC) rules invoked at transmittal to determine if the student is eligible to receive loan funds. Items this rule checks for include half-time enrollment, completion of Entrance Interview, Satisfactory Academic Progress, etc. AEC is primarily used as a criterion a student must pass before aid can be transmitted to Accounts Receivable. There are two sets of rules on the AEC form: Eligibility Criteria for Awarding and Eligibility Criteria for Transmitting. These rules monitor students' aggregate loan limits, SAP, as defined by Uniform Guidance rules and requirements for federal awards, and provide SAU with the internal controls needed for their Title IV program. The Financial Aid Director follows Ellucian Colleague’s best practice recommendations. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 367046 (2021-002)

Significant Deficiency 2021

Housing Authority of the City of West Bend

WI

HUD Housing Programs Eligibility Reporting

Finding 2021-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2020-005 Federal Program: Section 8 Housing Choice Vouchers. Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numb...

Finding 2021-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2020-005 Federal Program: Section 8 Housing Choice Vouchers. Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.516, the Housing Authority must conduct a reexamination of family income and composition at least annually. Third-party verification of family income, value of assets, expenses deducted from income, and other factors that affect adjusted income must be obtained and documented. The Housing Authority must determine income eligibility and calculate the tenant's rent payment using the documentation from third-party verification in accordance with 24 CFR part 5 subpart F. The Housing Authority is also required to submit HUD-50058, Family Report, for each examination per 24 CFR part 908. The amount paid for housing assistance payments (HAP) must correspond to HUD-50058. Condition/Context: No documentation of family income, composition, third-party verification, or HUD‑50058 were provided for one of the twenty five tenants selected for testing for the required reexamination during the fiscal year. Our sample was not statistically valid. Questioned Costs: Housing assistance payments for the tenant noted above is not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the eligibility determinations done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old. Effect: The Housing Authority may be making inaccurate or ineligible HAP payments on behalf of tenants. Recommendation: The Housing Authority should ensure their vendors properly maintain documentation regarding eligibility determinations. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program vouchers.

View Audit 290205

Finding 366655 (2021-002)

Material Weakness 2021

Alameda County Deputy Sheriff's Activities League Inc.

CA

Procurement, Suspension & Debarment Eligibility Material Weakness

Findings: Activities Allowed or Unallowed- Internal Controls that were designed to ensure that JAG program related expenses were actually incurred were ineffective in certain circumstances. Status: Resolved. Corrective Action: DSAL has removed all ineligible expenses from the ACSO-JAG grants accou...

Findings: Activities Allowed or Unallowed- Internal Controls that were designed to ensure that JAG program related expenses were actually incurred were ineffective in certain circumstances. Status: Resolved. Corrective Action: DSAL has removed all ineligible expenses from the ACSO-JAG grants accounts.

View Audit 289562

Finding 366451 (2021-007)

Material Weakness 2021

US Helping Us, People Into Living, Inc.

DC

Eligibility

Views of Responsible Officials and Corrective Action: HRSA, and subsequently DC Health/HAHSTA, reinstated site visits (record audits) in FY21. Us Helping Us passed all audits (with a score of 90 or greater) in FY21 and FY22. In addition, Us Helping Us has worked closely to understand the eligibility...

Views of Responsible Officials and Corrective Action: HRSA, and subsequently DC Health/HAHSTA, reinstated site visits (record audits) in FY21. Us Helping Us passed all audits (with a score of 90 or greater) in FY21 and FY22. In addition, Us Helping Us has worked closely to understand the eligibility requirements, especially the necessary documentation, for the new Regional EIS service category, which utilizes an HIV status neutral approach. In addition, DC Health/HAHSTA has released Service Standards for this Ryan White Part A service category, which includes participant eligibility criteria and required documentation. Us Helping Us continues to adhere to these Service Standards.

View Audit 16114

Finding 11920 (2021-006)

Material Weakness 2021

Redevelopment Authority of the County of Berks

PA

Questioned Costs Allowable Costs / Cost Principles Eligibility

The Authority launched the Emergency Rental Assistance Program (ERAP) with little administrative guidance from the U.S. Treasury. The Authority contracted with the Berks Coalition to End Homelessness (BCEH) to undertake various aspects of the Emergency Rental Assistance Program and in the late fall...

The Authority launched the Emergency Rental Assistance Program (ERAP) with little administrative guidance from the U.S. Treasury. The Authority contracted with the Berks Coalition to End Homelessness (BCEH) to undertake various aspects of the Emergency Rental Assistance Program and in the late fall of 2021, the Authority began reviewing all case documentation provided by BCEH. This review eliminated the vast majority of the errors noted. The Authority also updated case documentation checklists as well as provided training for staff involved with ERAP.

View Audit 15886 Questioned Costs: $1

Finding 11141 (2021-004)

Significant Deficiency 2021

Kama'aina Care, Inc.

HI

Questioned Costs Eligibility

For the COVID-19 Coronavirus Relief Fund, conducting reviews prior to incurring expenditures was not feasible. The funds were awarded in advance based on child capacity and not based on actual expenses. These funds permitted the allocation of previous expenses and were also required to be expended w...

For the COVID-19 Coronavirus Relief Fund, conducting reviews prior to incurring expenditures was not feasible. The funds were awarded in advance based on child capacity and not based on actual expenses. These funds permitted the allocation of previous expenses and were also required to be expended within a brief period of time. However, we have since become aware of the Code of Federal Regulation, specifically 2 CFR part 200 which provides uniform guidance on funds such as the COVID-19 Coronavirus Relief Fund. We are currently and will continue to review and familiarize ourselves with 2 CFR 200. To enhance compliance, we will establish standardized documentation protocols as part of our ongoing Policy and Procedure updates. The credit balance of $19,706 remains with the vendor as they were not able to supply our demands in a timely manner due to the need to supply the public’s demand for Covid supplies during the same time. We are prepared to return these funds to the pass-through entity from which it came.

View Audit 14921 Questioned Costs: $1

Finding 11140 (2021-003)

Material Weakness 2021

Kama'aina Care, Inc.

HI

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

We received large amounts of COVID-19 Coronavirus Relief Funds through three pass-through entities. As the funds allowed for expenses from the onset of Covid-19 epidemic to be allocated, this required the reallocation of an excessive number of aged transactions in the general ledger system. Due to i...

We received large amounts of COVID-19 Coronavirus Relief Funds through three pass-through entities. As the funds allowed for expenses from the onset of Covid-19 epidemic to be allocated, this required the reallocation of an excessive number of aged transactions in the general ledger system. Due to inadequate staffing, the task of adequately re-coding expenses for the various grants was not fulfilled. We have continued to work knowing that total grant funds received for the period, most especially for payroll, did not exceed total expenses for a specific program. In support of this, a payroll detail report from March 2020 – July 2021 will be prepared with the identification of which grant it allocated to. What is referred to as the bonus is considered part of the employee’s compensation. These payroll expenditures resemble commissions. They constitute a form of remuneration tied to predefined monthly objectives. The determination of these bonuses follows a defined formula and is disbursed monthly to employees in roles that involve overall supervision and the individual supervision of their program which encompasses managing staff, children, and programming. After this fiscal year 2021 audit experience, we comprehend the necessity to adequately allocate expenses and generate reports for each pass-through agency. Since January of 2023, we have invested time, effort, and funds in the upgrade of the general ledger system which is inclusive of features such as grant tracking and reporting.

View Audit 14921 Questioned Costs: $1

Finding 10109 (2021-003)

Material Weakness 2021

Hill & Dales General Hospital and Subsidiary

MI

Allowable Costs / Cost Principles Eligibility Material Weakness § 200.303

Finding 2021-003 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Federal Financial Assistance Listing: #93.498 Finding Summary: The Organization did not have an adequate internal control policy in place to ensure revie...

Finding 2021-003 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Federal Financial Assistance Listing: #93.498 Finding Summary: The Organization did not have an adequate internal control policy in place to ensure review and approval of the lost revenue calculation and report submitted to the Department of Health and Human Services for Period 1. Responsible Individuals: Renee Henry, Director of Finance Corrective Action Plan: Management will implement a control process and policy which includes a secondary review and approval of any future lost revenue calculation and report submitted under the federal program. Anticipated Completion Date: March 31, 2024

View Audit 13756

Corrective Action Plans

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