Corrective Action Plans

Finding 565347 (2023-002)

Significant Deficiency 2023

Community Service Council of Greater Tulsa, Inc.

OK

Eligibility Significant Deficiency

As of 12/06/2024 OKVU implemented the addition of the Asset Calculation Worksheet to the veteran case file. To ensure compliance the requirement was also added to the discharge file QC checklist and the SSVF policy and procedure manual updated. As of 12/11/2024 all case manager staff were provided t...

As of 12/06/2024 OKVU implemented the addition of the Asset Calculation Worksheet to the veteran case file. To ensure compliance the requirement was also added to the discharge file QC checklist and the SSVF policy and procedure manual updated. As of 12/11/2024 all case manager staff were provided training.

View Audit 359166

Finding 565346 (2023-001)

Material Weakness 2023

Community Service Council of Greater Tulsa, Inc.

OK

Eligibility Material Weakness Internal Control / Segregation of Duties

N/A - The Healthy Start Program transitioned to another local non-profit October 31, 2023. The Council will no longer have direct control over their corrective action plan.

View Audit 359166

Finding 564789 (2023-004)

Significant Deficiency 2023

Lifetime Independence for Everyone, Inc. and Subsidiary

TX

Eligibility Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Auditor's Recommendation: The auditor recommends the Organization enhance the design of its control activities and procedures over the reporting of consumer eligibility dates to ensure that date of eligibility agree between the ILS and DRS systems. Management’s Response: The LIFE Inc. staff have re...

Auditor's Recommendation: The auditor recommends the Organization enhance the design of its control activities and procedures over the reporting of consumer eligibility dates to ensure that date of eligibility agree between the ILS and DRS systems. Management’s Response: The LIFE Inc. staff have received training on new measures to ensure that the eligibility dates in the databases are consistent. When new Consumers request assistance through the Purchased Services Program, their intake appointments are scheduled simultaneously with those for the Base Grant Services. This coordination helps guarantee that the dates in both databases match. Due date of completion: May 31, 2025 Responsible Official: Program Director, Lidia Taylor

View Audit 358843

Finding 564731 (2023-003)

Material Weakness 2023

Housing Authority of St. Louis County

MO

Questioned Costs HUD Housing Programs Eligibility

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance M...

Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers and Mainstream Vouchers Federal Assistance Listing Numbers: 14.871 and 14.879 Noncompliance – N. Special Tests and Provisions – Selections from the Waiting List Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: Selections from the Waiting List. The PHA must have written policies in its HCVP administrative plan for selecting applicants from the waiting list and PHA documentation must show that the PHA follows these policies when selecting applicants from the waiting list. Except for as provided in 24 CFR section 982.203(Special admission (non-waiting list)), all families admitted to the program must be selected from the waiting list. “Selection” from the waiting list generally occurs when the PHA notifies a family whose name reaches the top of the waiting list to come in to verify eligibility for admission (24CFR sections 5.410, 982.54(d), and 982.201 through 982.207). Condition: Based upon inspection of the waiting list provided to us during the time of audit, the new move-in list and discussions with management, it could not be determined with any certainty that new move-ins were selected from the wait list in an order that is in accordance with the Authority’s policy. Context: Thirty-two (32) names were selected from the new move-in list and those names were to be traced to the waiting list to verify new move-ins were chosen in an order that was in accordance with the Authority’s policy. It was determined that six (6) out of thirty-two (32) new move-ins selected could not be traced with any certainty back to the Authority's waiting list. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $35,098 14.879 - Mainstream Vouchers - $13,796 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to selections from the waiting list. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers programs are in material non-compliance with the special tests and provisions type of compliance related to selections from the waiting list. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.

View Audit 358812 Questioned Costs: $1

Finding 564729 (2023-001)

Material Weakness 2023

Housing Authority of St. Louis County

MO

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Ma...

Finding 2023-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Assistance Listing Numbers: 14.871, 14.879, and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility. Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 6,531 units. Of a sample size of seventy-seven (77) tenant files, the following was noted: - Section 214 citizen declaration form missing in 15 files - HUD 9887 consent to release information form missing in 2 files - Original application missing in 1 file - Annual inspection missing in 1 file - Lead based paint form missing in 4 files - Verification of income missing in 6 files Our sample size is statistically valid. Known Questioned Costs: 14.871 - Section 8 Housing Choice Vouchers - $36,728 14.879 - Mainstream Vouchers - $13,028 14.EHV - Emergency Housing Vouchers - $1,272 Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor, and will make the several changes to its inspection process to ensure enforcement of Housing Quality Standards (or any subsequent replacement). Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Shannon Koenig, executive director and CEO, is responsible for implementing this corrective action by December 31, 2024.

View Audit 358812 Questioned Costs: $1

Finding 564125 (2023-001)

Material Weakness 2023

Interfaith Community Services, Inc.

MO

Subrecipient Monitoring Internal Control / Segregation of Duties Eligibility

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party Name: Gina Rice Position: Director of Accounting Telephone Number: 816-238-4511 ext 131 Federal Agency U.S. Department of Agriculture Federal Program Emergency Food Assistance Program (Food Commodities) Compliance Requirements E - Eligibility Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will establish a process to ensure required eligibility documentation is maintained in accordance with federal program requirements which will include periodic monitoring and review performed by personnel not directly involved with program administration. Anticipated Completion Date June 2025

View Audit 358231

Finding 564087 (2023-004)

None 2023

Sanford Housing Authority

NC

Questioned Costs HUD Housing Programs Subrecipient Monitoring

2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. ...

2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. Recommendation: The Authority should develop a plan based on budgeting and monitoring of COCC expenses to have the ability to reimburse funds to the Public and Indian Housing Program. Action Taken: To restore financial integrity and ensure proper use of COCC funds, the Authority will take the following actions: 1. COCC Optimization and Budget Reform: Develop and implement a proper, balanced COCC budget that reflects actual operating costs and allocates shared services appropriately. Establish budget accountability protocols, including monthly budget-to-actual reviews and variance reporting to the CFO, CEO, and Board. 2. Training and Capacity Building: Provide training for finance staff on COCC operations, HUD’s Asset Management model, and best practices for cost allocation and shared services. Engage external consultants to support financial modeling and long-term sustainability planning for RAD and LIHTC properties. 3. Shared Services Agreement: Formalize a Consulting and Shared Services Agreement to ensure that COCC services are appropriately billed and reimbursed by other programs. Monitor inter-program transactions to ensure compliance with HUD’s financial management requirements. 4. Salary Allocation and Cost Tracking: Conduct a salary allocation study to ensure that staff time is distributed adequately across programs. Implement time-tracking tools and cost allocation methodologies that align with HUD guidance and OMB Uniform Guidance. Effective Date: June 3, 2025 Contact Information Dr. Michael C. Threatt, Chief Executive Officer Sanford Housing Authority 317 Chatham Street Sanford, North Carolina 27330 (919) 776-7655

View Audit 358177 Questioned Costs: $1

Finding 563919 (2023-009)

Material Weakness 2023

Barclay College

KS

Questioned Costs Student Financial Aid Eligibility

Incorrect Pell Calculations Planned Corrective Action: A process will be implemented to verify Pell is correctly awarded before disbursements are made. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096 Questioned Costs: $1

Finding 563916 (2023-007)

Material Weakness 2023

Barclay College

KS

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Enrollment Reporting to NSLDS Planned Corrective Action: A process will be created to ensure enrollment is reported timely and accurately. Spot checks of NSLDS will be performed on enrollment status throughout the year. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for B...

Enrollment Reporting to NSLDS Planned Corrective Action: A process will be created to ensure enrollment is reported timely and accurately. Spot checks of NSLDS will be performed on enrollment status throughout the year. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563911 (2023-006)

Material Weakness 2023

Barclay College

KS

Student Financial Aid Eligibility Material Weakness

ISIR Comment Resolution Planned Corrective Action: All ISIR comment codes will be resolved before disbursement of federal aid to students. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 563906 (2023-005)

Material Weakness 2023

Barclay College

KS

Eligibility Student Financial Aid Material Weakness

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09...

Satisfactory Academic Progress Planned Corrective Action: The SAP policy will be reviewed or created as needed and a procedure will be implemented based on that policy. Person Responsible for Corrective Action Plan: Lee Anders, Vice President for Business Services Anticipated Date of Completion: 09/30/25

View Audit 358096

Finding 561616 (2023-006)

Significant Deficiency 2023

Ramsey County

MN

Internal Control / Segregation of Duties Student Financial Aid Eligibility § 200.303

Finding Number: 2023-006 Finding Title: Reporting – DHS Social Service Fund (DHS-2556) Program: 93.658 Foster Care – Title IV-E Name of Contact Person Responsible for Corrective Action: Janelle White – Controller for Ramsey County’s Health & Wellness Service Team Enrique Rivera – Fiscal Services ...

Finding Number: 2023-006 Finding Title: Reporting – DHS Social Service Fund (DHS-2556) Program: 93.658 Foster Care – Title IV-E Name of Contact Person Responsible for Corrective Action: Janelle White – Controller for Ramsey County’s Health & Wellness Service Team Enrique Rivera – Fiscal Services Manager for Ramsey County’s Health & Wellness Service Team Corrective Action Planned: Starting in the third quarter of 2024, Ramsey County instituted an additional verification step in the review process to support the determination of accurate cost pool categorization of reimbursable costs for the Random Moment Time Study Reports cost reports. The additional step will be to confirm that on the Summary Tab of the Quarterly Payroll file, the cost codes lines are in sequential order and that the corresponding expense totals match the cost code. The Senior Accountant will do the first review of this step, and the Fiscal Manager will complete the second review. The error on the 2nd quarter 2023 report was remedied and resubmitted in the 2nd quarter of 2024. Anticipated Completion Date: July of 2024 when the 2nd quarter DHS-2556 and DHS 2550 are due to be complete and finalized.

View Audit 357223

Finding 561615 (2023-004)

Material Weakness 2023

Ramsey County

MN

Questioned Costs Subrecipient Monitoring Eligibility § 200.303 § 200.403

Finding Number: 2023-004 Finding Title: Eligibility Program: 21.023 COVID-19 – Emergency Rental Assistance Program Name of Contact Person Responsible for Corrective Action: Daniel Rahkola, Division Director Finance Corrective Action Planned: Staff will be retrained on the procedures to ensure compl...

Finding Number: 2023-004 Finding Title: Eligibility Program: 21.023 COVID-19 – Emergency Rental Assistance Program Name of Contact Person Responsible for Corrective Action: Daniel Rahkola, Division Director Finance Corrective Action Planned: Staff will be retrained on the procedures to ensure compliance with the needed standards. Anticipated Completion Date: June 30, 2025

View Audit 357223 Questioned Costs: $1

Finding 561280 (2023-005)

Material Weakness 2023

Housing Authority of the City of Renton

WA

Eligibility HUD Housing Programs

The auditors reviewed 6 tenant files for initial admission criteria being met, such as Income calculations. Of the 6 files, 5 did not contain supporting documentation of how the income was calculated. Again, those staff are not present coming into FY2024. Of the 6 files reviewed, 3 also did not h...

The auditors reviewed 6 tenant files for initial admission criteria being met, such as Income calculations. Of the 6 files, 5 did not contain supporting documentation of how the income was calculated. Again, those staff are not present coming into FY2024. Of the 6 files reviewed, 3 also did not have 50058’s in the tenant file. And all 6 files could not be traced back to the waitlist to determine proper entrance to the program. In response to the tracking of the waitlist not being tracked on new admissions, there have not been any new HCV vouchers issued from the waitlist since the end of FY2022. RHA has an over utilization of voucher budget authority and has not issued new vouchers from that waiting list nor has RHA opened that waiting list up. RHA administration does not expect to open this waiting list in FY2024 nor FY2025. At the tail end of FY2023, RHA sent the PBV waiting lists over to the contracted third-party management company to track for RHA. Currently, that third-party management company is Allied Residential Management. Halfway through FY2024, RHA converted over to a different Housing Software which has better tracking reports than the prior software. Again, RHA has hired new staff and removed old staff that did not want to learn correct compliance procedures with the HCV department. RHA has a strong team coming into FY2025 now. FY2024 had staff in/out until we found good staff that wanted to learn and retain them.

View Audit 356918

Finding 561279 (2023-004)

Material Weakness 2023

Housing Authority of the City of Renton

WA

HUD Housing Programs Eligibility

Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the 40 tenant files sampled by the auditors, 29 files did not have correct utility allowances calculated; 9 files had 50058’s that did...

Prior RHA staff were not ensuring that the Utility Allowance schedules were being completed correctly and matching up to the 50058, which made the HAP incorrect. Of the 40 tenant files sampled by the auditors, 29 files did not have correct utility allowances calculated; 9 files had 50058’s that did not agree with the HAP payments being paid to the landlords and 22 files had rents that did not fall between 90% and 110% of the HUD FMR for the areas. Staff have been replaced and there are no original HCV staff left that were at RHA when the new CEO took over on March 1, 2023. Staff are consistently being trained every week for a minimum of 1 hour a week for 52 weeks out of the year. An HCV Director has been added to supervise the HCV Staff and audits of the files are being completed by the Director of Housing along with the CEO. These issues should be limited and not commonly found by Auditors during future audits.

View Audit 356918

Finding 561278 (2023-003)

Significant Deficiency 2023

Housing Authority of the City of Renton

WA

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed...

Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed and submitted, that pushed FY2023 Audit to be late. The audit for FY2023 should be completed by the end of April 2025 and then we will be on task to start FY2024 in May and completed by the deadline of September 30, 2025. Then, RHA will stay on task and get these completed within its deadline timeline.

View Audit 356918

Finding 561211 (2023-003)

Significant Deficiency 2023

National Indian Youth Council, Inc.

NM

Eligibility

NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each chec...

NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each check as well as any additional corrective action plans.

View Audit 356835

Finding 561089 (2023-004)

Significant Deficiency 2023

Aid for Aids of Nevada

NV

Eligibility § 200.303

2023-004 Internal Control Over Eligibility and Compliance Over Eligibility - U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee...

2023-004 Internal Control Over Eligibility and Compliance Over Eligibility - U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. For services to be provided under the Housing Opportunities for Persons with AIDS, individuals requesting services must meet criteria under the grant which includes providing identification and validating proof of HIV/AIDS diagnosis, income, rent or mortgage payment, and need for assistance. A full validation of these criteria is required to be performed for any individual receiving assistance. Condition: Of 21 files selected for individuals who received assistance under the grant, one selection included two copies of the same support for the client’s need for assistance that contained differing amounts for that client’s earnings during the same period which may be indictive of fraud in the application process. No documentation was included in the client file addressing the inconsistency and related risk of fraud for the earnings and the client was determined to be eligible for assistance when the existence of duplicative information that was not addressed or resolved would make it not possible to determine eligibility for this client. Cause: AFAN had designed controls such that each client file would be reviewed by the lead case manager for proper support of eligibility requirements. However, this internal control system did not detect the duplicative eligibility support that may have been indicative of fraud in the application process, nor did the internal control system identify the individual as being ineligible before providing assistance to the individual. Context: Management failed to consistently and effectively perform an internal control to address the risk of ineligible individuals receiving financial assistance. Effect: Failure to properly perform controls over the review of the client files could result in providing assistance to individuals who are not eligible. The allowance of individuals to receive or continue receiving services without ensuring they meet the eligibility criteria is a violation of the terms of the federal grant agreement. Repeat Finding: No Recommendation: We recommend management design and implement a system of internal controls whereby a review of client files to ensure eligibility is properly supported is performed before any grant funds are disbursed and that management ensures proper documentation of this review is maintained to support the performance of the control. Views of Responsible Officials and Planned Corrective Actions: Management intends to put in place additional training for case managers to identify eligibility of clients and ensure proper backup is submitted. Supervisors will ensure all backup is included in the case file before being submitted.

View Audit 356711

Finding 560679 (2023-004)

Significant Deficiency 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Allowable Costs / Cost Principles Eligibility School Nutrition Programs

U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in plac...

U.S. Department of Agriculture Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.569 and 10.565 Condition: CACLV does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. CACLV has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respective identifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 2025.

View Audit 356548

Finding 560668 (2023-003)

Material Weakness 2023

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles

U.S. Department of Agriculture Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities duri...

U.S. Department of Agriculture Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 2 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2023. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization developed a schedule to complete monitoring and created a checklist to ensure that all documentation is in the appropriate folder. In addition, the organization began conducting internal audits to ensure the developed processes are being followed. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2024.

View Audit 356548

Finding 560645 (2023-008)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2023-008 Finding Subject: Child Nutrition Cluster – Special Tests & Provisions - Verification Summary of Finding: One individual performs the verification process without documented review/oversight by a second employee not involved in this process. The lack of controls resulted in non-compl...

FINDING 2023-008 Finding Subject: Child Nutrition Cluster – Special Tests & Provisions - Verification Summary of Finding: One individual performs the verification process without documented review/oversight by a second employee not involved in this process. The lack of controls resulted in non-compliance in which the procedures performed at the School Corporation and the resulting supporting documentation provided were insufficient to verify the student's eligibility status of one of three students which were verified during the audit period. Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The verification process will be performed by Pam Frost and reviewed by the Business Manager. Anticipated Completion Date: December 31, 2024

View Audit 356534

Finding 560633 (2023-005)

Material Weakness 2023

Shenandoah School Corporation

IN

School Nutrition Programs Eligibility Cash Management § 200.303

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not b...

FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: The School Corporation stated that 100% of Free/Reduced lunch applications were reviewed during the audit period. However, testing of controls indicated that 100% of Free/Reduced lunch applications were not being reviewed by an individual other than the individual making the initial determination. As a result, three of forty sampled students received the incorrect eligibility status in the system software when compared to supporting documentation (Direct Certifications and/or income-based applications). Contact Person Responsible for Corrective Action: Drew Cooper, Business Manager Contact Phone Number and Email Address: 765-425-7889 dcooper@shenandoah.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Currently all income based applications for free/reduced lunch status are processed by Pam Frost and then reviewed by the Business Manager. Beginning in the 2024-2025 school year Direct Certification students will also be reviewed by the Business Manager. Anticipated Completion Date: August 31, 2024

View Audit 356534

Finding 560566 (2023-004)

Significant Deficiency 2023

Town of Coventry, Rhode Island

RI

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility § 200.213 § 200.303

Finding 2023-004 - Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School Department do not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are ...

Finding 2023-004 - Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding The Town of Coventry and Coventry Public School Department do not have policies and procedures in place to ensure that they do not contract with or make subawards to parties that are suspended or debarred. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management of the Town and School Department will review the district’s suspension and debarment policy and make sure that it is following the criteria as set out in the 2 CFR section 180 of the Uniform Guidance. The policy will then be updated and communicated to all personnel involved in the procurementprocess. Name of Contact Person Robert J. Civetti, CPA, Town Finance Director; Christopher Deverna, CPA, Director of Finance, Coventry Public Schools Projected Completion Date June 30, 2025

View Audit 356492

Finding 560404 (2023-002)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

Eligibility HUD Housing Programs Reporting

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 mov...

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 move-ins and move-outs sampled out of the population (9 total move-ins and 13 total move-outs during the audit period). Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding To address this finding, OJF will take the following actions: 1. Implement regular tenant file reviews at least semi-annually beginning January 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 2. Develop a mandatory training program on compliance requirements for property management site staff to follow by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 3. Revise and distribute existing tenant file management procedures by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 4. Establish a monitoring and feedback system by March 15, 2025 for site staff to seek guidance on or report challenges of file management so that advice can be given and/or corrective action taken a. Responsible party: OJF asset management director and property management portfolio manager 5. Conduct quarterly management reviews beginning 4/15/2025 to discuss and evaluate the effectiveness of above actions a. Responsible party: OJF asset management director and property management portfolio manager

View Audit 356309

Finding 560385 (2023-002)

Significant Deficiency 2023

Public Housing Authority of Butte

MT

HUD Housing Programs Eligibility Reporting

The Public Housing Authority of Butte will contract with the Certified Public Accounting firm to assist with timely submission of the FY 2024 unaudited Financial Data Schedule. This will provide su icient time for the audit to get completed by the audited FASSPHA deadline.

View Audit 356277

Corrective Action Plans

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