Corrective Action Plans

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1. Finding 2026-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight a. Comments on the Finding and Each Recommendation: We acknowledge the condition identified. Historically, certain compliance oversight activities relied heavily on our staff’s operational knowledge and...
1. Finding 2026-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight a. Comments on the Finding and Each Recommendation: We acknowledge the condition identified. Historically, certain compliance oversight activities relied heavily on our staff’s operational knowledge and informal review procedures that were not consistently documented. Following organizational restructuring and personnel transitions, management has begun a broader effort to formalize and strengthen compliance monitoring, supervisory review procedures, and documentation practices across our housing portfolio. b. Action(s) Taken or Planned on the Finding: 1. Monthly Compliance and Financial Oversight Meetings: We are establishing recurring monthly oversight meetings with executive leadership, finance, and housing management personnel to review financial reporting, reserve activity, compliance requirements, tenant-related matters, and operational performance. We plan to document these meetings and retain evidence of supervisory review as part of our compliance monitoring procedures. 2. Expanded Finance and Compliance Oversight Structure: We have added a Director of Housing and Compliance responsible for operational and regulatory compliance oversight and have contracted an Interim CFO who is a licensed CPA. We plan to continue refining roles and further segregating responsibilities among the accounting, compliance, and operational functions to strengthen internal controls and management review. 3. Formalized Compliance Monitoring Procedures: We are developing standardized compliance monitoring procedures, including monthly reserve deposit tracking, supervisory review checklists, documented financial statement review procedures, reconciliation monitoring, and periodic compliance checklists addressing key HUD program requirements. 4. Ongoing Monitoring and Documentation Retention: We will strengthen documentation retention procedures so that evidence of compliance monitoring, supervisory review, and reconciliation activities, as well as support for all certifications submitted to HUD, is consistently maintained and available for future audits and regulatory reviews. c. Anticipated Completion Date: Full implementation is expected to be completed and documented by March 31, 2027.
1. Finding 2026-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight a. Comments on the Finding and Each Recommendation: We acknowledge the condition identified. Historically, certain compliance oversight activities relied heavily on our staff’s operational knowledge and...
1. Finding 2026-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight a. Comments on the Finding and Each Recommendation: We acknowledge the condition identified. Historically, certain compliance oversight activities relied heavily on our staff’s operational knowledge and informal review procedures that were not consistently documented. Following organizational restructuring and personnel transitions, management has begun a broader effort to formalize and strengthen compliance monitoring, supervisory review procedures, and documentation practices across our housing portfolio. b. Action(s) Taken or Planned on the Finding: 1. Monthly Compliance and Financial Oversight Meetings: We are establishing recurring monthly oversight meetings with executive leadership, finance, and housing management personnel to review financial reporting, reserve activity, compliance requirements, tenant-related matters, and operational performance. We plan to document these meetings and retain evidence of supervisory review as part of our compliance monitoring procedures. 2. Expanded Finance and Compliance Oversight Structure: We have added a Director of Housing and Compliance responsible for operational and regulatory compliance oversight and have contracted an Interim CFO who is a licensed CPA. We plan to continue refining roles and further segregating responsibilities among the accounting, compliance, and operational functions to strengthen internal controls and management review. 3. Formalized Compliance Monitoring Procedures: We are developing standardized compliance monitoring procedures, including monthly reserve deposit tracking, supervisory review checklists, documented financial statement review procedures, reconciliation monitoring, and periodic compliance checklists addressing key HUD program requirements. 4. Ongoing Monitoring and Documentation Retention: We will strengthen documentation retention procedures so that evidence of compliance monitoring, supervisory review, and reconciliation activities is consistently maintained and available for future audits and regulatory reviews. c. Anticipated Completion Date: Full implementation is expected to be completed and documented by March 31, 2027.
1. Finding 2026-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight a. Comments on the Finding and Each Recommendation: We acknowledge the condition identified. Historically, certain compliance oversight activities relied heavily on our staff’s operational knowledge and...
1. Finding 2026-001: Lack of Formalized Compliance Monitoring and Documented Management Oversight a. Comments on the Finding and Each Recommendation: We acknowledge the condition identified. Historically, certain compliance oversight activities relied heavily on our staff’s operational knowledge and informal review procedures that were not consistently documented. Following organizational restructuring and personnel transitions, management has begun a broader effort to formalize and strengthen compliance monitoring, supervisory review procedures, and documentation practices across our housing portfolio. b. Action(s) Taken or Planned on the Finding: 1. Monthly Compliance and Financial Oversight Meetings: We are establishing recurring monthly oversight meetings with executive leadership, finance, and housing management personnel to review financial reporting, reserve activity, compliance requirements, tenant-related matters, and operational performance. We plan to document these meetings and retain evidence of supervisory review as part of our compliance monitoring procedures. 2. Expanded Finance and Compliance Oversight Structure: We have added a Director of Housing and Compliance responsible for operational and regulatory compliance oversight and have contracted an Interim CFO who is a licensed CPA. We plan to continue refining roles and further segregating responsibilities among the accounting, compliance, and operational functions to strengthen internal controls and management review. 3. Formalized Compliance Monitoring Procedures: We are developing standardized compliance monitoring procedures, including monthly reserve deposit tracking, supervisory review checklists, documented financial statement review procedures, reconciliation monitoring, and periodic compliance checklists addressing key HUD program requirements. 4. Ongoing Monitoring and Documentation Retention: We will strengthen documentation retention procedures so that evidence of compliance monitoring, supervisory review, and reconciliation activities is consistently maintained and available for future audits and regulatory reviews. c. Anticipated Completion Date: Full implementation is expected to be completed and documented by March 31, 2027.
Oversight Agency for Audit, Morse Elderly Housing Corporation respectfully submits the following corrective action plan for the year ended March 31, 2026. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 3306...
Oversight Agency for Audit, Morse Elderly Housing Corporation respectfully submits the following corrective action plan for the year ended March 31, 2026. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067. Audit period: April 1, 2025 through March 31, 2026 The findings from the March 31, 2026 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2026-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should ensure adherence to and the monitoring of established controls over cash disbursements. Action Taken: Staff training has been provided to ensure proper procedures are followed.
The Village has segregated as many duties as possible given the small accounting staff.
The Village has segregated as many duties as possible given the small accounting staff.
Sliding Fee Discount Program Eligibility and Application Auditor reference: Schedule of Findings and Questioned Costs, page 39 Finding addressed: In a nonstatistical sample of 25 encounters, two patients received sliding-fee adjustments that did not align with the approved discount category based on...
Sliding Fee Discount Program Eligibility and Application Auditor reference: Schedule of Findings and Questioned Costs, page 39 Finding addressed: In a nonstatistical sample of 25 encounters, two patients received sliding-fee adjustments that did not align with the approved discount category based on their documented household income and family size. The auditor reported no questioned costs related to this finding. Planned corrective action 1. Correct the identified exceptions. By November 2026, designated staff under the CFO’s oversight will review the two cited encounters against the board-approved sliding-fee policy and the discount schedule in effect on each service date, verify supporting records of household income and family size, and document the correct category and required account adjustments. Any patient credit or refund identified as due will be processed in accordance with approved billing and collections procedures. 2. Assess extent and system configuration. By December 2026, Finance will conduct a targeted retrospective review of at least 50 additional sliding-fee encounters across applicable service lines, locations, and discount categories. The review will compare documented income and family size with the assigned discount. EHR and billing-system discount tables, effective dates, and any manual override permissions will be checked against the board-approved schedules. Errors will be corrected, and the review will be expanded if a broader issue is identified. 3. Standardize eligibility verification. By December 2026, NHHC will issue a written step-by-step workflow that requires documentation of income, family size, eligibility determination, and application of the correct sliding fee tier before the adjustment is finalized. Manual adjustments or overrides will require a documented reason and supervisory authorization, with an audit trail retained. 4. Provide competency-based training. By January 2027, relevant front-desk, eligibility, registration, and billing personnel will be trained on the approved Sliding Fee Discount Program policy and on the use of the applicable schedule. Completion records and a brief competency validation will be retained. Any policy revisions will be submitted to the governing board for approval before implementation. 5. Monitor sustained adherence. During January and February 2027, Finance will review at least 25 newly processed sliding-fee encounters per month. Results will be reported to the CFO and CEO, with a goal of 100% agreement between documented eligibility and applied discounts. Any discrepancy will be promptly remediated, including additional staff coaching and further sampling until the control is operating effectively. Responsible contacts: Jason Wallace, Chief Executive Officer; Monica Lerma, Chief Financial Officer Anticipated completion: February 2027 Evidence of correction: Two-case correction log and account documentation; retrospective sampling results; approved policy and schedule; validated EHR/billing discount mapping; updated workflow; training and competency records; monthly quality-control samples; and documented supervisory follow-up.
Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee...
Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that the support for the sliding fee discounts is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has recognized and acknowledges the deficiency in internal controls in regards to the determination, recording, and monitoring of the sliding fee discount process. Along with the safeguards that have been implemented previously, we are implementing a process that includes: - verification, during front desk eligibility check that slide information is complete; - if patient qualifies for the slide, note in billing notes, effective dates, slide category, and fee to be collected; - identify patients that are checking in that day and double check slide category and fee to collect; - if there is a discrepancy with any documentation, reach out to slide coordinator.
Contact Person Nadine Boe, CEO Corrective Action Plan Management will work to ensure that the SFS discount applications are completed accurately and that the SFS discounts are recorded accurately in the system by auditing the SFS applications and verifying the SFS in the system matches the SFS appli...
Contact Person Nadine Boe, CEO Corrective Action Plan Management will work to ensure that the SFS discount applications are completed accurately and that the SFS discounts are recorded accurately in the system by auditing the SFS applications and verifying the SFS in the system matches the SFS application. In addition, Management will audit a sample of the SFS discounts on a monthly basis to assure the SFS is applied correctly. Management will also provide additional training to staff as needed and provide further guidance on the internal SFS policies and procedures.
Contact Person Nadine Boe, CEO Corrective Action Plan Management will work to ensure that the SFS discount applications are completed accurately and that the SFS discounts are recorded accurately in the system by auditing the SFS applications and verifying the SFS in the system matches the SFS appli...
Contact Person Nadine Boe, CEO Corrective Action Plan Management will work to ensure that the SFS discount applications are completed accurately and that the SFS discounts are recorded accurately in the system by auditing the SFS applications and verifying the SFS in the system matches the SFS application. In addition, Management will audit a sample of the SFS discounts on a monthly basis to assure the SFS is applied correctly. Management will also provide additional training to staff as needed and provide further guidance on the internal SFS policies and procedures.
In Finding 2026-001, it was reported that the Organization did not properly apply the sliding fee discount for six sliding fee patients tested. In addition, ten patients received discounts without completed applications. Management recognizes the importance of complying with sliding fee guidelines a...
In Finding 2026-001, it was reported that the Organization did not properly apply the sliding fee discount for six sliding fee patients tested. In addition, ten patients received discounts without completed applications. Management recognizes the importance of complying with sliding fee guidelines and the Organization’s sliding fee policy. In response to Finding 2026-001, proper training will be given to employees and sliding fee discounts will be reviewed on a monthly basis by a supervisor to ensure compliance with the sliding fee policy.
NORTHWEST UNIVERSITY Corrective Action Plan For the Year Ended May 31, 2026 Finding Number 2026-001: Significant deficiency in internal controls over compliance with verification requirements. Significant deficiency in internal controls over compliance with verification requirements: For the two stu...
NORTHWEST UNIVERSITY Corrective Action Plan For the Year Ended May 31, 2026 Finding Number 2026-001: Significant deficiency in internal controls over compliance with verification requirements. Significant deficiency in internal controls over compliance with verification requirements: For the two students who received Pell grants of five total students selected for verification testing, verification status was not correctly coded in Common Origination and Disbursement (COD) system. This was the result of an issue in PFAIDS in which verification status code is only reporting for Pell recipients who were selected for verification by the FPS, not for students selected by the school. SFS has reviewed the scope of this issue and determined that these were the only two Pell recipients who were school-selected and verified, and the Verification Status Code for both students has been updated in COD as of 8/11. Contact Person(s): Cynthia Kennedy, Director of SFS; Ryan Porter, CFO; and Bernie Rundquist, Controller Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: The compliance issue was the result of a reporting error within the University’s current financial aid management system. Student Financial Services (SFS) is transitioning to a new financial aid management system in October 2026 and has ensured that the verification status flows correctly through COD reporting. The University goes live with the new system for the 2027-2028 award year. For the remainder of the current 2026-2027 reporting cycle, SFS has implemented a regularly scheduled manual review of COD reporting for students who are school-selected for verification to ensure correct reporting. This review will continue through the duration of processing in the current system. Anticipated completion date: October 2026
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Management will ensure tenant file inspections are completed on an annual basis
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Management will ensure tenant file inspections are completed on an annual basis
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will b...
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will be implemented immediately with more thorough oversight over monthly replacement reserve and escrow disbursements. The Corporation has also applied for a rent increase in July 2026 that has yet to be approved as of this report’s issuance date.
Name: CABUN Rural Health Services, Inc. Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Auditor/Audit Firm: Forvis Mazars, LLP Audit Period: March 31, 2026 Federal Program: Health Center Cluster Anticipated Completion Date: October 2026 Response: The Organization concurs with the...
Name: CABUN Rural Health Services, Inc. Contact Name: Judy Southall, CFO Contact Phone Number: 870-798-4064 Auditor/Audit Firm: Forvis Mazars, LLP Audit Period: March 31, 2026 Federal Program: Health Center Cluster Anticipated Completion Date: October 2026 Response: The Organization concurs with the finding, and management has continued to implement procedures to ensure that eligible patients receive discounts in accordance with the sliding fee scale. Management and all personnel involved will review and determine the appropriate sliding fee discount in order to be in compliance with Uniform Guidance. All patients will be offered an application to participate in the sliding fee discount. Information will be entered into the system as declined or appropriate to arrive at the sliding fee category. The application will then come to Hampton where a billing clerk will review the application for accuracy. The CHC and Insurance tab will reflect the correct sliding fee category. Corrections to the patient account will be made if there are any inaccuracies found. Education will be provided to those making the error and corrective action taken if continued omissions. In the Organizations PMS, the slide is setup as an insurance, if no other insurance is primary the adjustment is automatically made. The PMS has been checked for accuracy of slide categories, adjustment codes and insurance types. CABUN’s Billing and Collections staff will be re-educated on the entire process of sliding fee; from application to ensuring adjustments are made correctly. Reviews will be made by the CIO on a quarterly basis to assure the correct adjust has been made.
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Managemen...
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Management will ensure tenant file inspections are completed on an annual basis
Finding 2026-002: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Managemen...
Finding 2026-002: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Management will ensure tenant file inspections are completed on an annual basis
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: Strengthen internal controls over cash disbursements by prioritizing replacement reserve and escrow deposits as fixed monthly obligations, funded at the start of each month before discretionary payab...
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: Strengthen internal controls over cash disbursements by prioritizing replacement reserve and escrow deposits as fixed monthly obligations, funded at the start of each month before discretionary payables. Action Taken: Corrective action will be implemented immediately with more thorough oversight over monthly replacement reserve and escrow disbursements.
Finding 2026-003: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Managemen...
Finding 2026-003: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Management will ensure tenant file inspections are completed on an annual basis
Finding 2026-002: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: Management should continue efforts to rent the vacant unit and evaluate the reason for the extended vacancy. Management should also monitor vacant units on a regular basis to ensure that appropriate ...
Finding 2026-002: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: Management should continue efforts to rent the vacant unit and evaluate the reason for the extended vacancy. Management should also monitor vacant units on a regular basis to ensure that appropriate actions are taken to maximize extended vacancies and the related loss of revenue. Action Taken: Management is in agreement with the auditor’s findings. Management will ensure vacancies are monitored on an ongoing basis.
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its mont...
Finding 2026-001: Supportive Elderly Housing Section 202 –Assistance Lising # 14.157 Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will be implemented immediately with more thorough oversight over monthly replacement reserve and escrow disbursements.
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation and are present during testing. Action Taken: Management is in agreement with the auditor’s findings. Management has instructed all compliance personnel to review a...
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation and are present during testing. Action Taken: Management is in agreement with the auditor’s findings. Management has instructed all compliance personnel to review all matters related to tenant compliance.
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Management will ensure tenant file inspections are completed on an annual basis
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation Action Taken: Management is in agreement with the auditor’s findings. Management will ensure tenant file inspections are completed on an annual basis
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will b...
Recommendation: In periods of high repair expenditures, prompt submission of replacement reserve reimbursement claims will help replenish operating funds. This will enhance the Corporation’s ability to meet its monthly replacement reserve and other obligations. Action Taken: Corrective action will be implemented immediately with more thorough oversight over monthly replacement reserve and escrow disbursements.
Recommendation: The Corporation should design and implement internal controls to ensure that any advances to a related party are in accordance with contractual regulations and approval. Action Taken: Management is in agreement with the auditor’s findings. Management will attempt to recover the funds...
Recommendation: The Corporation should design and implement internal controls to ensure that any advances to a related party are in accordance with contractual regulations and approval. Action Taken: Management is in agreement with the auditor’s findings. Management will attempt to recover the funds from the related party.
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation. Action Taken: Management is in agreement with the auditor’s findings. Management will ensure internal tenant file inspections are completed on an annual basis.
Recommendation: The Corporation should design and implement internal controls to ensure that all tenant files have proper documentation. Action Taken: Management is in agreement with the auditor’s findings. Management will ensure internal tenant file inspections are completed on an annual basis.
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