Corrective Action Plans

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Finding 2024-009: Reporting – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not maintain copies of performance-related reports submitted to the grantor for the Title V program. Corrective Action: Management is implementing a formal process t...
Finding 2024-009: Reporting – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not maintain copies of performance-related reports submitted to the grantor for the Title V program. Corrective Action: Management is implementing a formal process to retain all supporting documentation for performance-related reports submitted to grantors in accordance with Federal requirements. NACA is also hiring and training a Grant Director to strengthen oversight of grant reporting, compliance, and documentation requirements. As part of the monthly and grant reporting process, staff will ensure that copies of all submissions are saved. A review step will also be added to confirm that all required documentation has been retained prior to final submission. Management will continue to evaluate and adjust processes as needed to ensure compliance and completeness. Name of Person Responsible: Walter McCullough, CFO and finance staff Anticipated Date of Completion: May 31, 2026
UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported b...
UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026
UCM will strengthen internal controls over TANF eligibility determinations by formalizing written procedures that clearly identify the documentation required to support each eligibility criterion before assistance is provided. The procedures will define required documentation for financial eligibili...
UCM will strengthen internal controls over TANF eligibility determinations by formalizing written procedures that clearly identify the documentation required to support each eligibility criterion before assistance is provided. The procedures will define required documentation for financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, applicable legal eligibility requirements, and work participation requirements when applicable. UCM reviewed and discussed the findings with the auditor, Senior Director of Finance, and Chief Program Officer. UCM also reviewed the Virginia Department of Social Services post-training materials on TANF Employment Advancement Eligibility Determination Training, and clarified identified areas of the findings with the Virginia Department of Social Services as they relate to the subrecipient signed contract. UCM designed new Screening Guidelines for incoming program participants, including a documented supervisory review and approval process, which were completed on April 16, 2026. The new screening guidelines require participant files to include sufficient documentation supporting eligibility determinations and require supervisory review before assistance is provided. A supervisor or designated reviewer will verify that the participant file contains the required eligibility documentation, that eligibility criteria have been met, and that the assistance is consistent with TANF requirements, VDSS guidance, the subrecipient contract, and program guidelines. UCM reviewed and trained staff on the new eligibility screening guidelines, acceptable documents, and income requirements on April 28, 2026. Staff responsible for TANF eligibility determinations, case management, direct assistance, and grant compliance will continue to receive training as needed to ensure they understand TANF documentation requirements and maintain complete and accurate participant files. UCM will also periodically monitor participant files to confirm continued compliance and identify any additional training or process improvements needed. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Case Managers VDSS Program Consultant Anticipated Completion Date: Substantially completed as of April 28, 2026. Ongoing implementation, supervisory review, staff training, and monitoring will continue during the program year.
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges noncompliance with federal reporting timelines.  Create a compliance calendar listing all federal reporting deadlines, including the Data Collection Form due date and interim milestones for audit completion.  Designat...
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges noncompliance with federal reporting timelines.  Create a compliance calendar listing all federal reporting deadlines, including the Data Collection Form due date and interim milestones for audit completion.  Designate outsourced finance team as the responsible official for preparing and submitting the Data Collection Form, with the CEO as backup, and require written confirmation of submission to management and the Finance Committee.  Incorporate a year-end compliance checklist into closing procedures to verify preparation and timely filing of the Data Collection Form.  Provide training to leadership and finance staff on federal reporting requirements and consequences of late submissions.
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges gaps in VOCA employee file documentation.  Implement a standardized checklist for VOCA and other grant-funded employees that includes required acknowledgements (nondiscrimination, drug-free workplace, confidentiality, ...
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges gaps in VOCA employee file documentation.  Implement a standardized checklist for VOCA and other grant-funded employees that includes required acknowledgements (nondiscrimination, drug-free workplace, confidentiality, and related forms).  Educate HR staff in auditing best practices, emphasizing complete and accurate employee files and the specific grant documentation required.  Schedule periodic reviews of VOCA-funded employee files (at least quarterly) to verify that all required documents are present and current, with results reported to management.
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges discrepancies in VOCA data metrics reported.  Utilize and document a consistent process and tools (such as Client Trackmanagement or database system) for effective tracking and reporting of all VOCA program metrics.  ...
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges discrepancies in VOCA data metrics reported.  Utilize and document a consistent process and tools (such as Client Trackmanagement or database system) for effective tracking and reporting of all VOCA program metrics.  Establish a routine for random and planned internal audits of reported metrics, comparing reports to source data to verify accuracy and completeness.  Provide training on proper reporting procedures, best audit practices, and data entry accuracy for all staff involved in VOCA data collection and reporting. Tracking and Documentation:  Organize all VOCA program reports by grant name, month, and year, with reports and supporting source documents maintained together and two signatures (Program Manager and Department Director) to confirm the process.  Ensure all staff sign off on VOCA-related training topics, with documentation saved in their personnel folder.  Conduct internal audits of VOCA performance data on a routine basis (monthly & quarterly) to ensure ongoing compliance and accuracy.
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges deficiencies in reconciliation of reimbursement claims. • Implement a standardized reimbursement reconciliation worksheet that ties each grant claim to the general ledger, payroll reports, and underlying invoices prior ...
Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges deficiencies in reconciliation of reimbursement claims. • Implement a standardized reimbursement reconciliation worksheet that ties each grant claim to the general ledger, payroll reports, and underlying invoices prior to submission. • Require documented review and approval of each claim by the designated finance team member, confirming that claimed amounts are allowable, supported, and within the grant period. • Provide staff training on claim preparation, reconciliation, and documentation retention expectations.
Finding 2024-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part ...
Finding 2024-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing rigorous documentation and archiving framework. We are prioritizing the development of standardized file-handling protocols, the implementation of a uniform record-keeping system, and the execution of comprehensive staff training to e...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing rigorous documentation and archiving framework. We are prioritizing the development of standardized file-handling protocols, the implementation of a uniform record-keeping system, and the execution of comprehensive staff training to ensure that all eligibility and non-cooperation evidence is preserved, organized, and readily accessible for audit and verification purposes. Action Steps: 1. Implement a new "Uniform Record Retention & Archiving SOP" that mandates a specific organization, labeling, and storage legend for all participant files, ensuring uniform accessibility across all regions. 2. Revise the Eligibility Documentation Checklist that must be completed for every participant, specifically requiring proof of child support referrals and, where applicable, non-cooperation determinations. 3. Formalize the communication protocol between the IV-A (ADSEF) and IV-D (Child Support) agencies to ensure prompt notification and documentation of non-cooperation instances, as required by 45 CFR §264.30(b). 4. Conduct a mandatory regional training curriculum for all regional staff on the importance of file maintenance, the specific requirements for child support referrals, and the legal protocols for handling non-cooperation cases. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Gerhil Medina Baez Auxiliary Administrator Operational Services
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a verification framework. We are prioritizing the formalization of inter-agency data sharing agreements, the implementation of standardized income validation protocols, and the execution of a comprehensive training program to ensure a...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a verification framework. We are prioritizing the formalization of inter-agency data sharing agreements, the implementation of standardized income validation protocols, and the execution of a comprehensive training program to ensure all regional staff adhere to federal IEVS requirements. Action Steps: 1. MOU Formalization – Execute and maintain active Memoranda of Understanding (MOUs) with all relevant agencies to secure legal access to real-time wage, unemployment, and benefit data. 2. Develop and mandate a new "Income Eligibility Validation SOP". This protocol will strictly forbid reliance on sworn statements alone and will require technicians to cross-reference application data against verified external agency sources. 3. Integrated Data Exchange Protocol – Implement a recurring, automated schedule for the ingestion of SWICA, UC, and BENDEX/SSA data into our internal eligibility systems, ensuring data is available to technicians at the point of application and during quarterly reviews. 4. Implement a Training Curriculum – Launch a recurring, mandatory training program for all regional eligibility technicians and supervisors, focusing on federal IEVS requirements, standardized data validation procedures, and the legal consequences of non-compliance. 5. Implement a monthly "Eligibility Quality Assurance" review, where central-level management audits a sample of case files to ensure that income has been verified against external sources as required by the State Plan. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Gerhil Medina Baez Auxiliary Administrator Operational Services
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive internal control framework for EBT operations. We are prioritizing the development of current, formal written procedures, the implementation of a rigorous supervisory review cycle, and the enforcement of mandatory trai...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive internal control framework for EBT operations. We are prioritizing the development of current, formal written procedures, the implementation of a rigorous supervisory review cycle, and the enforcement of mandatory training to ensure that all EBT transactions are fully reconciled, documented, and compliant with federal requirements. Action Steps: 1. ERP-Driven Reconciliation - Configure the ERP system to automatically ingest and reconcile EBT Daily Activity and Payment Summary files against federal drawdowns (PMS/SF-425) and General Ledger expenditure records. 2. Updated Procedures Manual - Develop and approve a new "EBT Reconciliation Procedures Manual" that integrates the ERP's automated workflows, superseding the 2012 document and establishing frequency, roles, and oversight. 3. ERP Variance Reporting - Utilize the ERP to generate "Exception Reports" for any unmatched transactions between EBT disbursements and federal drawdowns. 4. Staff Training & ERP Integration - Execute mandatory training for all staff on the ERP’s automated reconciliation capabilities and the new standardized SOPs for verifying EBT settlement accuracy. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget
VIEWS OF RESPONSIBLE OFFICIALS We are resolving these deficiencies by leveraging the new Government ERP system, scheduled for launch in July 2026. This platform will provide the essential functionality to properly configure our Chart of Accounts, ensuring that all TANF and PTTA administrative expend...
VIEWS OF RESPONSIBLE OFFICIALS We are resolving these deficiencies by leveraging the new Government ERP system, scheduled for launch in July 2026. This platform will provide the essential functionality to properly configure our Chart of Accounts, ensuring that all TANF and PTTA administrative expenditures are automatically segregated by federal award and Assistance Listing Number (ALN). This system will be the foundation for accurate, traceable, and reconcilable financial reporting, supported by robust internal controls and multi-level supervisory oversight. Action Steps: 1. ERP Chart of Accounts Configuration – Configure the ERP system with a granular Chart of Accounts that strictly segregates TANF and PTTA administrative expenditures, ensuring every transaction is coded to the correct federal grant and ALN. 2. Automated Reporting Workflow – Utilize the ERP's financial reporting modules to generate ACF-196TR reports directly from the General Ledger, ensuring reported expenditures are 100% traceable to source transactions. 3. Digital Reconciliation Workpaper – Require the ERP to generate an automated "Reconciliation Package" for every ACF-196TR submission, which links reported line items directly to General Ledger accounts, eliminating discrepancies. 4. Staff Training & ERP Stabilization – Execute comprehensive training for all finance staff on the new ERP accounting structure, reconciliation modules, and federal reporting requirements, ensuring the system is utilized for full audit compliance. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget
VIEWS OF RESPONSIBLE OFFICIALS ADFAN appreciates the observations presented in the audit and acknowledges the importance of strengthening its reporting processes. The agency recognizes that staffing limitations within the Finance Division have affected the ability to perform timely reviews and ensur...
VIEWS OF RESPONSIBLE OFFICIALS ADFAN appreciates the observations presented in the audit and acknowledges the importance of strengthening its reporting processes. The agency recognizes that staffing limitations within the Finance Division have affected the ability to perform timely reviews and ensure adequate segregation of duties. Additionally, the Finance Procedures Manual referenced during the audit was approved in 2009 and is currently undergoing a comprehensive revision to reflect the agency’s present operational structure and accounting practices. ADFAN is committed to improving its internal controls, enhancing staff training, and implementing the necessary measures to ensure full compliance with federal reporting requirements moving forward. IMPLEMENTATION DATE December 31, 2026 RESPONSIBLE PERSON Yazmín Cruz Colón, Budget Director
VIEWS OF RESPONSIBLE OFFICIALS ADFAN reaffirms its commitment to strengthening its financial reporting processes and ensuring full compliance with federal requirements. The agency will ensure that the SF 425 is completed using the appropriate accounting basis consistent with the financial system in ...
VIEWS OF RESPONSIBLE OFFICIALS ADFAN reaffirms its commitment to strengthening its financial reporting processes and ensuring full compliance with federal requirements. The agency will ensure that the SF 425 is completed using the appropriate accounting basis consistent with the financial system in use, and that all reported expenditures reconcile accurately with the accounting database. A reviewer will be designated to support the verification of information entered by the preparer, and a structured review process will be implemented prior to report submission. These corrective actions will be undertaken while acknowledging the current staffing limitations within the finance area and the ongoing revision of the Procedures Manual. Interim operational guidance will be provided to personnel to promote consistency and compliance until the updated manual is finalized. IMPLEMENTATION DATE December 31, 2026 RESPONSIBLE PERSON José A. Ruiz Quiñones, Interim Director of Finance
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive internal control framework. We are prioritizing the development of formal written policies, the standardization of regional data reporting, and the implementation of a rigorous oversight system to ensure all TANF progr...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive internal control framework. We are prioritizing the development of formal written policies, the standardization of regional data reporting, and the implementation of a rigorous oversight system to ensure all TANF programmatic reports are complete, accurate, and filed on time. Action Steps: 1. Revise the Protocol of “TANF – Reporting Procedures Manual" that defines the full data lifecycle: collection, regional validation, quality control, supervisory review, and submission. 2. Regional Standardization – Establish mandatory, standardized templates for all regional offices to report programmatic data, ensuring uniformity and minimizing data entry errors. 3. Reporting Calendar & Oversight – Implement a master’s "Federal Reporting Calendar" that tracks all due dates for ACF-199, ACF-209, and other reports, with automated alerts sent to management 30 days prior to submission. 4. Training & Certification – Launch a mandatory training curriculum for all staff involved in reporting, focusing on 45 CFR Part 265 standards, data accuracy, and the consequences of reporting failures. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Gerhil Medina Baez Auxiliary Administrator Operational Services Johana Hernandez Andaluz TANF Program Director
VIEWS OF RESPONSIBLE OFFICIALS To resolve this, we are integrating these reporting requirements into the new Government ERP system, scheduled for launch in July 2026. This platform will provide the capability to generate accurate General Ledger data and automated financial reports, ensuring that all...
VIEWS OF RESPONSIBLE OFFICIALS To resolve this, we are integrating these reporting requirements into the new Government ERP system, scheduled for launch in July 2026. This platform will provide the capability to generate accurate General Ledger data and automated financial reports, ensuring that all LIHEAP performance data is traceable to verified accounting sources and subject to multi-level supervisory approval workflows. Action Steps: 1. ERP-Driven Financial Reporting – Configure the ERP system to generate General Ledger reports that align precisely with LIHEAP financial data requirements. The ERP will serve as the "Single Source of Truth," eliminating discrepancies between accounting and reporting. 2. Automated Reconciliation Workflows – Utilize the ERP’s native reconciliation engine to automatically match expenditure records against reported LIHEAP budget obligations, ensuring figures are accurate and validated before submission. 3. Segregation of Duties (SOPs) – Formalize protocols where the ERP system enforces mandatory "Preparer-Approver-Certifier" roles. This ensures that performance data compiled by program staff is independently validated against ERP financial records by a supervisor. 4. Training on ERP Reporting – Train all staff on how to use ERP reporting modules for financial data extraction and the new protocols for reconciling this data with programmatic LIHEAP performance metrics. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Nesvia Fontanez Marín Principal Accountant Federal Reports
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all reported Maintenance-of-Effort (MOE) expenditures are internally consistent, fully supported by source documentation, and reconciled prior to submission. We will formalize these processes ...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all reported Maintenance-of-Effort (MOE) expenditures are internally consistent, fully supported by source documentation, and reconciled prior to submission. We will formalize these processes through new protocols and dedicated oversight to guarantee the integrity of our federal reporting IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Nesvia Fontanez Marín Principal Accountant Federal Reports
VIEWS OF RESPONSIBLE OFFICIALS For the purpose of strengthening compliance with the requirements established under the Federal Funding Accountability and Transparency Act (FFATA) and other applicable federal regulations, ACUDEN developed a Standard Operating Procedure (SOP) that establishes clear an...
VIEWS OF RESPONSIBLE OFFICIALS For the purpose of strengthening compliance with the requirements established under the Federal Funding Accountability and Transparency Act (FFATA) and other applicable federal regulations, ACUDEN developed a Standard Operating Procedure (SOP) that establishes clear and uniform guidelines for the collection, validation, and reporting of information related to federal funds. This procedure defines the responsibilities of the areas involved in the management of federal awards, promotes the timely submission of accurate and complete reports, and ensures that processes related to the identification and reporting of eligible subawards are carried out. IMPLEMENTATION DATE July 15, 2026 RESPONSIBLE PERSON Rafael E. Vargas Ortiz Deputy Administrator
VIEWS OF RESPONSIBLE OFFICIALS To resolve these systemic issues, the Government of Puerto Rico is transitioning to a new Enterprise Resource Planning (ERP) system, scheduled for live launch in July 2026. This modern platform will centralize our financial data and provide the necessary automation to ...
VIEWS OF RESPONSIBLE OFFICIALS To resolve these systemic issues, the Government of Puerto Rico is transitioning to a new Enterprise Resource Planning (ERP) system, scheduled for live launch in July 2026. This modern platform will centralize our financial data and provide the necessary automation to ensure that all federal reports are accurate, traceable to source documentation, and subject to multi-level supervisory approval workflows. Action Steps: 1. ERP Implementation & Workflow – Deploy the new ERP system to centralize all financial accounting. The system will be configured to require distinct user roles for the preparation, review, and certification of federal reports. 2. Automated Traceability – Utilize ERP reporting tools to ensure all administrative expenditures are linked to valid source documentation (e.g., invoices, payroll registers), providing a clear audit trail from report to General Ledger. 3. Implement report validation tool – No federal report may be submitted until an independent, designated official has digitally validated the report against source accounting records. 4. Reconciliation SOPs – Formalize a written SOP requiring monthly reconciliations of reported federal expenditures against the ERP database. These reconciliations will be retained as evidence of review for audit purposes. 5. Training & Accountability – Conduct mandatory training for all staff on new reporting workflows and the importance of segregation of duties, ensuring all personnel understand their responsibility in maintaining accurate financial data. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all grant funds are timely obligated and expended in accordance with 45 CFR §96.14. We will achieve this by integrating strict monitoring protocols into our operations, ensuring that the risk ...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all grant funds are timely obligated and expended in accordance with 45 CFR §96.14. We will achieve this by integrating strict monitoring protocols into our operations, ensuring that the risk of Non-Compliance is identified and escalated to the federal agency in writing as required. Action Steps: 1. Protocol Development & Review – Develop new "Period of Performance Management Protocols" and conduct a comprehensive review of all existing financial reporting procedures to ensure alignment with 45 CFR §96.14. 2. Implement a Warning System – that alerts management 90 days before the end of the obligation period if funds remain unobligated, triggering an immediate internal review. 3. Automated ERP Obligation Tracking – Configure the new Government ERP system to track obligation deadlines at the grant and activity level, providing real-time visibility into the availability of funds and pending commitments. 4. Communication & Escalation SOP – Establish a formal SOP requiring that any anticipated non-compliance be communicated to the federal awarding agency in writing at least 60 days prior to the expiration of the obligation period, with all approvals archived centrally. 5. Segregation of Duties 6. Staff Training – Conduct mandatory training for all staff responsible for grant management on the Period of Performance requirements, including the legal consequences of unauthorized report amendments. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Nesvia Fontanez Marín Principal Accountant Federal Reports Rodolfo Ayala Muñoz Cash Management
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all participant files are complete, accurate, and readily available for audit as required by federal regulations. Action Step: 1. Standardized Documentation Checklist- Implement a mandatory, u...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous compliance framework to ensure all participant files are complete, accurate, and readily available for audit as required by federal regulations. Action Step: 1. Standardized Documentation Checklist- Implement a mandatory, uniform "Eligibility Documentation Checklist" that must be completed for 100% of non-PAN/TANF applicants, ensuring ID, residency, and utility evidence are present before approval. 2. Supervisory Sign-off - Require a supervisor to perform a "Document Completeness Review" for every non-PAN/TANF file before the benefit is authorized. Files lacking mandatory documentation will be rejected by the system/workflow automatically. 3. Analysis of the Existing File Uniformity Procedure for Compliance Verification – Assessment of the physical and digital filing layout across all regions. A uniform legend and organization protocol will be mandated to facilitate monitoring and eliminate systemic filing errors. 4. Compliance Training - Execute mandatory, recurring training sessions for all regional staff on document requirements and the legal necessity of preserving records for the full three-year federal mandate. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Gerhil Medina Baez Auxiliary Administrator Operational Services Marta Soto Ayala NAP Program Director Johana Hernandez Andaluz TANF Program Director
VIEWS OF RESPONSIBLE OFFICIALS ACUDEN is committed to reinforcing our eligibility determination process by standardizing review workflows. We are prioritizing the completion of all missing documentation for affected files and ensuring that every future Eligibility Certificate reflects the required t...
VIEWS OF RESPONSIBLE OFFICIALS ACUDEN is committed to reinforcing our eligibility determination process by standardizing review workflows. We are prioritizing the completion of all missing documentation for affected files and ensuring that every future Eligibility Certificate reflects the required technical and supervisory validations to guarantee compliance. The following corrective actions will be implemented: 1. ACUDEN will recruit at least two (2) staff members to support the implementation of the eligibility verification protocol and ensure adequate capacity for document review. 2. A verification protocol will be established to confirm that all required supporting documents are present and complete prior to finalizing eligibility determinations. A standardized checklist will be created to ensure no document is missing, including during data migration processes. 3. ACUDEN will implement a mandatory dual- verification procedure for all Eligibility Certificates, requiring both the Technician and the Coordinator to sign prior to issuance. IMPLEMENTATION DATE September 2026 RESPONSIBLE PERSON Child Care Director – Sidnia Velez Assistant Administrator for Human Resources – Alex Lopez
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to a fundamental restructuring of our cash management lifecycle. By migrating drawdown processes into our ERP system, we will ensure that every request is supported by system-generated documentation, enforced through systematic segregation of duties,...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to a fundamental restructuring of our cash management lifecycle. By migrating drawdown processes into our ERP system, we will ensure that every request is supported by system-generated documentation, enforced through systematic segregation of duties, and fully reconciled against the general ledger in real-time. Action Step: 1. ERP-Based SOP Manual-Implement of the Procedure Manual of ERP system. This manual will supersede legacy documentation and clearly map every procedural step to a specific ERP function. 2. Systemic Segregation ERP is configurated to enforce mandatory "Preparer" and "Approver" roles. The system will prevent a single user from both creating and authorizing a drawdown request, ensuring logical segregation of duties. 3. Automated Reconciliation-Implement a system-level control where the ERP automatically reconciles drawdown requests. Any variance will trigger a "Pending Review" flag, preventing unauthorized processing. 4. Real-Time Supervisory Review-Require supervisors to conduct an audit of all drawdown documentation directly within the ERP interface. No request will be released for funding without a digital system approval following a reconciliation review IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget
VIEWS OF RESPONSIBLE OFFICIALS ADFAN concurs with the finding. The agency acknowledges the requirement to maintain written procedures in accordance with 2 CFR §200.302, including procedures related to cash management and the determination of allowable costs under federal awards. The condition identi...
VIEWS OF RESPONSIBLE OFFICIALS ADFAN concurs with the finding. The agency acknowledges the requirement to maintain written procedures in accordance with 2 CFR §200.302, including procedures related to cash management and the determination of allowable costs under federal awards. The condition identified was impacted by limited staffing resources within the Finance Area, which affected the timely completion and formalization of the required written procedures. In addition, the Finance Procedures Manual is currently under review and revision to ensure compliance with Uniform Guidance requirements and to strengthen internal controls over federal programs. As corrective action, ADFAN is completing the update and formalization of the Finance Procedures Manual, which will incorporate the written procedures required by Uniform Guidance. Upon completion, the revised manual will be formally approved, communicated to relevant personnel, and implemented across the agency. Management will also continue assessing staffing needs and resource allocation within the Finance Area to support the ongoing maintenance and monitoring of financial policies and procedures. IMPLEMENTATION DATE December 31, 2026 RESPONSIBLE PERSON Rafael López Arocho Assistant Administrator on Administration
VIEWS OF RESPONSIBLE OFFICIALS The data will be evaluated by the IT department to verify the controls in place at the time the files identified as duplicates were issued. Regarding the issuance, the IT department acknowledges an error in the file transmission, which resulted in the information not b...
VIEWS OF RESPONSIBLE OFFICIALS The data will be evaluated by the IT department to verify the controls in place at the time the files identified as duplicates were issued. Regarding the issuance, the IT department acknowledges an error in the file transmission, which resulted in the information not being matched against the issuance. The data will be available as reference for evaluation. For reconciliation purposes, work will be performed efficiently and within the established timeframes to ensure that all transactions are recorded promptly in the system. This will enable the accurate completion of the reconciliation process, as well as the recording of issuances and any other related transactions, in accordance with established procedures. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Carmen Ramírez IT Director
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