Corrective Action Plans

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Finding No. 2024-002 Special Tests: Enrollment Reporting and Gramm-Leach-Bliley Act Compliance / Material Weakness in Internal Controls over Compliance Finding: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Leach-Bliley Act, which...
Finding No. 2024-002 Special Tests: Enrollment Reporting and Gramm-Leach-Bliley Act Compliance / Material Weakness in Internal Controls over Compliance Finding: Instances of noncompliance have been identified around major compliance requirements Enrollment Reporting and Gramm-Leach-Bliley Act, which are both part of special tests identified in the 2024 Compliance Supplement. Additionally, due to a transition in Registrar leadership and concurrent updates to Student Information System (SIS) configurations, a subset of students who had graduated and ceased attendance were incorrectly reported with a “Withdrawn” enrollment status. As part of the institution’s standard enrollment reporting process, student enrollment and graduation data are transmitted monthly from the SIS to the National Student Clearinghouse (NSC). NSC subsequently reports this information to the National Student Loan Data System (NSLDS). Under normal system operations, graduation data should be automatically included with the monthly enrollment transmission and used to determine the correct final enrollment status. However, following the SIS configuration update, the automated linkage between degree conferral data and enrollment status reporting did not function as intended. As a result, certain students with conferred degrees were systemically classified as “Withdrawn” rather than “Graduated” in the enrollment file submitted by the Registrar’s Office. Upon identification of the issue, the Registrar’s Office submitted a help desk ticket to the SIS Helpdesk to document the findings and initiate a technical review of the enrollment reporting configuration. Corrective Actions Taken: A formal help desk ticket was submitted to the SIS Helpdesk to investigate the enrollment status reporting discrepancy. SIS technicians reviewed enrollment reporting configurations and confirmed that graduation data was not being correctly incorporated into the monthly enrollment extract. The Registrar’s Office identified the affected student population and validated degree conferral information against official graduation records. Corrected enrollment statuses have been submitted. Corrective Actions Planned: Concurrently with Fall 2025, SUBSEQUENT OF TERM enrollment report, the Registrar’s Office will submit corrected enrollment records for any additional student to the National Student Clearinghouse (NSC) to ensure that accurate graduation information is transmitted to the National Student Loan Data System (NSLDS). (Due by 01/31/2026) Starting with Fall 2025 graduates, the Registrar’s office will manually update graduation statuses for all identified impacted students to ensure institutional records accurately reflect degree conferral prior to subsequent enrollment reporting cycles. Last, Enrollment reporting procedures will be updated to document revised controls, roles, and review steps, including specific checks related to graduation status accuracy following SIS configuration changes or staffing transitions. Additionally, related to the Gramm-Leach-Bliley Act requirements, IWP acknowledges the repeated finding and has taken immediate steps to ensure full compliance with the Gramm-Leach-Bliley Act requirements outlined in the 2024 Compliance Supplement. Specifically: - Formal Written Information Security Program: A comprehensive written policy is being finalized to address all seven required elements under 16 CFR 314.4(b), including risk assessment, safeguards, and oversight. - Annual Review Process: The CIO will review updates to the Student Financial Aid Cluster within the OMB Compliance Supplement annually to confirm continued compliance. - Policy Approval and Oversight: Once completed, the policy will be reviewed and approved by the EVP to ensure all required elements are included. - Implementation and Training: Staff training will be conducted to ensure awareness and adherence to the security program. - Monitoring and Updates: The Institute will monitor for any changes to federal requirements and update the policy accordingly. The written security program will be completed and implemented by the end of FY2026, with ongoing annual reviews thereafter. Responsibility for oversight rests with the CIO, with final approval by the EVP.
The City will update amounts and descriptions within the Department of Treasury’s reporting portal to ensure all amounts expended are properly reported.
The City will update amounts and descriptions within the Department of Treasury’s reporting portal to ensure all amounts expended are properly reported.
Beginning with FY2026, a new Federal Programs Director and a new Special Education Director was hired by the Board, and a Fiscal Administrator was appointed on August 27, 2025. These new designees will ensure that all federal programs operate within their allowable costs, activities, and budgets.
Beginning with FY2026, a new Federal Programs Director and a new Special Education Director was hired by the Board, and a Fiscal Administrator was appointed on August 27, 2025. These new designees will ensure that all federal programs operate within their allowable costs, activities, and budgets.
The Board of Supervisors will improve its financial reporting process so that it can submit its Single Audit Reporting Package to the federal clearinghouse no later than 9 months after fiscal year-end.
The Board of Supervisors will improve its financial reporting process so that it can submit its Single Audit Reporting Package to the federal clearinghouse no later than 9 months after fiscal year-end.
Corrective Action Taken or Planned: The City will keep all work papers used to prepare the reports as it is not possible to recreate them later after adjusting entries due to limitations in the software. The reports will be provided for Council approval prior to sending vs after as an info item. Con...
Corrective Action Taken or Planned: The City will keep all work papers used to prepare the reports as it is not possible to recreate them later after adjusting entries due to limitations in the software. The reports will be provided for Council approval prior to sending vs after as an info item. Contact person(s) responsible for correction action: Gail Olstad, City Auditor Anticipated Completion Date: Quarter 2, prior to the start of the 2025 audit
The District will implement a formal review and approval process for indirect charge calculations to ensure that these calculations are consistent with the data recorded in the accounting system. This plan has been implemented during the 24-25 school year.
The District will implement a formal review and approval process for indirect charge calculations to ensure that these calculations are consistent with the data recorded in the accounting system. This plan has been implemented during the 24-25 school year.
Recommendation: We recommend management ensures that all transactions are recorded properly. Management Response: The Organization will continue to use our auditors for these additional services.
Recommendation: We recommend management ensures that all transactions are recorded properly. Management Response: The Organization will continue to use our auditors for these additional services.
It is our intent to make necessary financial statement adjustments prior to the audit in the future.
It is our intent to make necessary financial statement adjustments prior to the audit in the future.
We will reevaluate employees handling of cash/checks at outlying locations to ensure there is segregation of duties and reassign duties as necessary to comply with internal controls policy.
We will reevaluate employees handling of cash/checks at outlying locations to ensure there is segregation of duties and reassign duties as necessary to comply with internal controls policy.
The issue noted primarily reflects isolated lapses in documentation and oversight during a period of staff transition. Since that time, management has reinforced internal controls over both payroll and non-personnel expenditures to ensure that allocations are properly documented, reviewed, and appro...
The issue noted primarily reflects isolated lapses in documentation and oversight during a period of staff transition. Since that time, management has reinforced internal controls over both payroll and non-personnel expenditures to ensure that allocations are properly documented, reviewed, and approved before posting. In addition, all staff involved in charging costs to federal grants are being retrained on documentation standards and cost allocation procedures. The two OTPS invoices cited by the auditors were for overhead costs (payroll processing fees and general liability insurance) that are allocated based on allocation percentages and typically do not go through a separate approval process. The Agency is reinforcing supervisory review to ensure journal entries are created and approved by separate individuals and the accounting system was updated to prevent all staff members (without exception) from initiating and approving entries.
Conditions – In 2024, the Organization did not have proper segregation of duties. The Accountant performed, or had access to, all major functions. This individual processed deposits, recorded receipts in the accounting system and reconciled the bank accounts. We did not see evidence of formal review...
Conditions – In 2024, the Organization did not have proper segregation of duties. The Accountant performed, or had access to, all major functions. This individual processed deposits, recorded receipts in the accounting system and reconciled the bank accounts. We did not see evidence of formal review of the bank reconciliations by someone other than the Accountant. This individual also approved expenses and processed payments of expenses. We did not see any evidence of the review of approval of expenditures on the invoices. The Accountant did not sign checks, but there is no evidence that the check signer reviewed the supporting documentation and the Organization’s policies do not indicate the check signer needed to review the supporting documentation. In 2024, journal entries made to the accounting records were made by the Accountant and were not reviewed by a second individual. Recommendation – While we recognize the challenges that smaller organizations such as the Boys and Girls Clubs of Western Nevada may face in fully segregating duties, we recommend taking steps to reduce control gaps wherever feasible. Views of Responsible Officials and Planned Corrective Actions – Management acknowledges the audit findings and agrees that the organization’s rapid and significant growth during 2024 placed increased demands on existing accounting systems, staffing capacity, and internal controls. While financial operations remained functional during this period of expansion, appropriate measures and controls were not fully scaled to match the organization’s growth and increasing complexity. Management views this as a capacity and controls issue driven by unprecedented growth, rather than a lack of commitment to financial accountability or compliance. Leadership recognizes the importance of strengthening internal controls to ensure accurate financial reporting, safeguard assets, and maintain strong governance practices moving forward. To address these findings, management will utilize the SAS 115 letter issued by the auditor as a roadmap for corrective action. Specific planned actions include implementing enhanced internal control procedures, segregating duties where feasible, and improving documentation of accounting processes. In addition, management will increase the Finance Committee's role and oversight to provide regular review and governance of financial operations, policies, and controls. The organization will also implement control sampling and periodic reviews to validate the accuracy and consistency of accounting functions, identify potential weaknesses early, and ensure corrective actions are effective. These measures, combined with ongoing monitoring and committee oversight, will strengthen financial management practices and position the organization to responsibly support continued growth. Management is committed to the timely implementation of these corrective actions and to maintaining strong fiscal stewardship consistent with the organization’s mission and fiduciary responsibilities.
2024-004 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS / COST PRINCIPALS Program: Education Stabilization Fund – ESSER II and ESSER III Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21...
2024-004 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS / COST PRINCIPALS Program: Education Stabilization Fund – ESSER II and ESSER III Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111175-01A and 21FESIII-111175-01A Questioned Costs: None Type of Finding: Material weakness in internal controls Condition/Context: For five of seven journal entries tested for the Education Stabilization Fund program, the District did not have documentation supporting that the entry was reviewed and approved by an individual separate from the preparer. Corrective Action: The District will review its process for preparing and recording journal entries to include a step to have the entries reviewed and approved by someone other than the preparer. In addition, the journal entries will include supporting schedules and documentation to explain why the entry is being prepared. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Dorene Mudrow, Superintendent
Western-Washtenaw Area Value Express, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2024. Auditor: Maner Costerisan, 2425 E. Grand River Ave, Suite 1, Lansing, Michigan 48912 Audit period: The funding from September 30, 2024 schedule of findings and ...
Western-Washtenaw Area Value Express, Inc. respectfully submits the following corrective action plan for the year ended September 30, 2024. Auditor: Maner Costerisan, 2425 E. Grand River Ave, Suite 1, Lansing, Michigan 48912 Audit period: The funding from September 30, 2024 schedule of findings and questioned costs is discussed below. The finding is number consistently with the number assigned in the schedule. Finding - noncompliance with the Uniform Guidance Recommendation: As this was WAVE’s first Single Audit, management was still developing familiarity with Uniform Guidance audit submission requirements. The late submission resulted from an incomplete understanding of the deadlines associated with filing the Data Collection Form (DCF) and audit reporting package with the Federal Audit Clearinghouse (FAC). Action to be taken: To ensure timely submissions in future periods, management is implementing the following corrective actions: 1.Establish a formal written procedure for completing and filing the DCF and Single Auditreporting package in accordance with 2 CFR 200.512. 2.Assign a responsible individual within the finance department to oversee the Single Auditsubmission process and monitor related deadlines. 3.Create a compliance calendar that includes required federal reporting deadlines, including the30-day and 9-month submission rules. 4.Implement an internal review and approval step to confirm the completeness and accuracy of allrequired components prior to submission and to verify that submission occurs within therequired timeframe. 5.Provide training to finance personnel on federal audit reporting requirements and the FACsubmission process. These procedures will ensure future Single Audit submissions are completed on time and in accordance with Uniform Guidance. Anticipated Completion Date: December 31, 2025
The Company does not have the resources and/or staff to prepare the financial statements and notes but will continue to oversee the auditor’s services and review and approve the financial statements and notes.
The Company does not have the resources and/or staff to prepare the financial statements and notes but will continue to oversee the auditor’s services and review and approve the financial statements and notes.
Finding Reference Number: 2024-001 -Weakness in Controls over Accounting and Financial Reporting Description of Finding: At 6/30/2024 the Organization's current assets are less than its current liabilities, resulting in a deficit in net assets. Analysis found a material weakness in the Organization'...
Finding Reference Number: 2024-001 -Weakness in Controls over Accounting and Financial Reporting Description of Finding: At 6/30/2024 the Organization's current assets are less than its current liabilities, resulting in a deficit in net assets. Analysis found a material weakness in the Organization's controls over identifying and recording vendor bills that resulted in incorrectly omitting allowable costs from program grant expense reimbursement requests. Additionally, the Executive Director performed staff level program functions that were billed at their higher wage rate resulting in payroll costs in excess of allowed budget costs that were disallowed for reimbursement. Not properly identifying and requesting reimbursement for allowable program costs and incurring payroll costs in excess of allowed budgets has strained on the Organization's operating cash flows resulting in deficits and delays in satisfying the accounts payable obligations to the police agencies for which reimbursed funds have been requested. Statement of Concurrence or Nonconcurrence: The Organization agrees with the finding as presented. Corrective Action: The Organization has implemented a dual-review process for all grant expenses to ensure that eligible costs are identified and submitted as a means to reduce misidentification of expenses for allowed activities. Staff will also receive updated training on allowable expense categories to reduce misinterpretation. In monitoring payroll activities, the Organization has revised its grant payroll allocation process to ensure that duties performed under specific roles are billed at the appropriate rate. Future budgets will more clearly distinguish between roles and corresponding pay rates to prevent overages. All projects will undergo budget-to-expense reconciliation on a monthly basis to safeguard against missed claims and ensure that grant resources are maximized without exceeding allowable limits. Name of Contact Person: Janelle Lawrence, Executive Director Phone: 503-303-4954 E-mail: janelle@oregonimpact.org Projected Completion Date: June 30, 2026
Views of Responsible Officials at Auditee: We recognize that the necessary documentation was unavailable during the audit. To address this issue, we are collaborating with professionals to ensure that all documentation is properly generated and securely stored for future retrieval of processes that ...
Views of Responsible Officials at Auditee: We recognize that the necessary documentation was unavailable during the audit. To address this issue, we are collaborating with professionals to ensure that all documentation is properly generated and securely stored for future retrieval of processes that we already have in place. We have engaged a new bookkeeping firm to assist us in continuing consistent monthly processes and accurate documentation. Additionally, we are implementing a monthly checklist to track our internal controls, highlighting our ongoing review and approval processes. We will ensure that all expenses are reviewed monthly and approved with initials by either the Chief Executive Officer or Chief Financial & Outreach Officer on invoices and receipts. This review will also encompass all bank and credit card statements. Furthermore, we will ensure that all staff compensation documents are updated and reviewed annually to keep them current. This comprehensive process will form an integral part of our financial internal control checklist. While we have established internal controls, recent staff changes during the audit process made it challenging to locate all necessary documentation. This absence of documentation stemmed from these transitions, and we are actively working to improve our documentation procedures moving forward.
Name of Contact Person Responsible for Corrective Action Plan: Jennifer Brown, Executive Director of Finance Corrective Action Plan: Management will establish procedures to ensure compliance with Wage Rate Requirements and implement necessary associated internal controls. Anticipated Completion Date...
Name of Contact Person Responsible for Corrective Action Plan: Jennifer Brown, Executive Director of Finance Corrective Action Plan: Management will establish procedures to ensure compliance with Wage Rate Requirements and implement necessary associated internal controls. Anticipated Completion Date: Fiscal year 2025
Response/Corrective Action Plan: We concur with the finding and will revise the procurement policy as well as the internal control policies and procedures specific to the County to be in alignment with the Uniform Guidance requirements. Upon completion, the new policy will be provided to all departm...
Response/Corrective Action Plan: We concur with the finding and will revise the procurement policy as well as the internal control policies and procedures specific to the County to be in alignment with the Uniform Guidance requirements. Upon completion, the new policy will be provided to all department heads to ensure proper compliance in the utilization and disbursement of federal funds.
Management agrees to maintain separate trial balances for the allocation of cash, property and equipment, interest rate swap asset and loans payable between Palmyra Area Interfaith Housing Council and Palmyra Interfaith Manor HUD Project No. 034-EH015. Management notes that this represents a differe...
Management agrees to maintain separate trial balances for the allocation of cash, property and equipment, interest rate swap asset and loans payable between Palmyra Area Interfaith Housing Council and Palmyra Interfaith Manor HUD Project No. 034-EH015. Management notes that this represents a difference of opinion from the prior auditors, who found the financial records of the two entities to be properly reconciled through the use of schedules to separate the council and project’s allocation of cash, property and equipment, interest rate swap asset and loans payable between the Council and the Project for 19 years with no consequence.
Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. CIF retrained staff on FFATA reporting deadlines and documentation expectations so that if new sub...
Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. CIF retrained staff on FFATA reporting deadlines and documentation expectations so that if new subawards are entered into in FY 26, this requirement will be met in a timely fashion. Details relating to FFATA reporting requirements are documented in the CIF Subaward Management & Subrecipient Monitoring Policy and Procedures.
Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. This FY 24 Program Audit immediately preceded the FY 25 Single Audit in fall 2025. Given this timi...
Views of Responsible Officials: CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. This FY 24 Program Audit immediately preceded the FY 25 Single Audit in fall 2025. Given this timing, the earliest possible implementation of corrective action is in FY 26. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements which involves timesheets that record actual time spent on a funding source and are accompanied by supervisorial approvals. This system has been formally documented in the FY 26 update to the CIF Financial Policy and includes annual training for staff responsible for managing payroll allocations and Federal reporting. Charges to Federal awards for salaries and wages are now based on records that accurately reflect the work performed. The records are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The records support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Finding 2024-002 Delta Regional Authority ( material weakness): Management recognizes the significance of properly segregating transactions relating to restricted grant programs in our accounting software. To address this issue, we will: 1. Reprogram Accounting Software: We will work with our softwa...
Finding 2024-002 Delta Regional Authority ( material weakness): Management recognizes the significance of properly segregating transactions relating to restricted grant programs in our accounting software. To address this issue, we will: 1. Reprogram Accounting Software: We will work with our software vendor to reprogram or adjust our accounting software to ensure that it can effectively segregate transactions related to restricted grants from other general ledger activities. 2. Revise Account Code Structure: We will review and redefine our general ledger account code structure to create more detailed categories that support accurate tracking and reporting of restricted funds. 3. Training for Staff: We will provide training for relevant staff on the updated accounting procedures to ensure they understand how to correctly use the new accounting software features and reporting structures. 4. Hire grant accountant: We have contracted a Grants Accountant who has already began organizing and file maintenance of grant records as well as working with the CFO, staff accountant and Grants Administrator to consolidate files, records, and supporting documentation for all active grants affecting the current fiscal year and FY 2025. II. Other Cause and Effect Management acknowledges that these weaknesses were caused by oversight from responsible employees and recognizes the risks associated with material misstatements and potential fraudulent activity. To mitigate these risks, we will enhance our internal controls, ensure accountability, and promote a culture of compliance and vigilance within the organization. Conclusion Management is committed to improving our internal controls over financial reporting to ensure compliance with federal regulations and enhance the accuracy of our financial statements. We appreciate the recommendations provided and will implement these corrective actions in a timely manner to strengthen our financial practices and restore stakeholder confidence. We will keep the board informed of our progress in addressing these material weaknesses. Management is dedicated to resolving these material weaknesses in a timely manner and will implement the recommended actions to strengthen our internal controls over financial reporting. We will keep the Board updated on our progress and provide necessary training for our staff to ensure adherence to new procedures. We appreciate the auditors' recommendations and are committed to making the necessary improvements to foster greater transparency and accountability in our financial reporting practices. Finding 2024-002 Delta Regional Authority (Material Weakness) – Accounting has worked with the Abilla System program coordinators and have set up codes within the accounting system to identify grants, restricted and unrestricted, for more effective reporting and identification.
Finding 1168472 (2024-003)
Material Weakness 2024
Mana Maoli has implemented a practical review and reconciliation step as part of payroll processing. This step compares approved timesheets to payroll register hours to help ensure that payroll allocations to federal programs are based on accurate records. This reconciliation is integrated into the ...
Mana Maoli has implemented a practical review and reconciliation step as part of payroll processing. This step compares approved timesheets to payroll register hours to help ensure that payroll allocations to federal programs are based on accurate records. This reconciliation is integrated into the existing payroll workflow to avoid added administrative burden. Management will conduct periodic reviews of payroll records and refine the process as needed to maintain reasonable assurance of accuracy, recognizing that the goal is continuous improvement. Anticipated completion date: December 31, 2026
CORRECTIVE ACTION FINDING 2024-005 - SEGREGATION OF DUTIES Anticipated Date of Completion: December 31 , 2025 Name of Contact Person: Jordan Sarmo, Business Manager Management Response: The District will continue to refine the segregation of duties within the business office as staffing levels allow...
CORRECTIVE ACTION FINDING 2024-005 - SEGREGATION OF DUTIES Anticipated Date of Completion: December 31 , 2025 Name of Contact Person: Jordan Sarmo, Business Manager Management Response: The District will continue to refine the segregation of duties within the business office as staffing levels allow. With recently filled positions, the District will assign responsibil ities in a manner that reduces risk and ensures adequate separation of key accounting functions is maintained.
CORRECTIVE ACTION FINDING 2024-004 - CASH MANAGEMENT AND RECONCILIATION OF ACCOUNTS Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Jordan Sarmo, Business Manager Management Response: The District will strengthen controls over cash management by performing month ly reconcil...
CORRECTIVE ACTION FINDING 2024-004 - CASH MANAGEMENT AND RECONCILIATION OF ACCOUNTS Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Jordan Sarmo, Business Manager Management Response: The District will strengthen controls over cash management by performing month ly reconciliations of all cash and investment accounts and by implementing supervisory review procedures. These measures will improve the accuracy of federal program reporting and overall financial reporting rel iability.
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