Corrective Action Plans

Finding 560791 (2024-002)

Material Weakness 2024

NY

Allowable Costs / Cost Principles Material Weakness Reporting § 200.516

Views of Responsible Officials: All Astraea staff members are required to complete timesheets. Astraea’s internal processes were reviewed and overhauled in December 2021 (midway through FY2022) with department heads determining how their direct reports would spend time on various Astraea work stream...

Views of Responsible Officials: All Astraea staff members are required to complete timesheets. Astraea’s internal processes were reviewed and overhauled in December 2021 (midway through FY2022) with department heads determining how their direct reports would spend time on various Astraea work streams and projects. This information is detailed in a level of effort (LOE) spreadsheet tracked against timesheets and budgets regularly. However, the processes for instituting regular updates to the LOE spreadsheet and timesheet allocations remained time-consuming and highly manual in FY2023 – which we believe resulted in misallocations. Astraea is currently reviewing internal processes to ensure, 1) that review and revision of the LOE spreadsheet and timesheet allocations can happen in a timely manner with less administrative burden, and 2) allowance of a more detailed review of the payroll allocation approval and entry process. As of January 1, 2025, a new finance system was implemented allowing for greater sophistication, consistency and automation of these processes. We do not expect to see this finding upon completion of our FY25 audit.

View Audit 356562

Finding 560659 (2024-001)

Material Weakness 2024

Dermott Special School District

AR

Subrecipient Monitoring Internal Control / Segregation of Duties School Nutrition Programs

The District will establish and maintain internal controls that will safeguard District assets to the best of their abilities.

View Audit 356537

Finding 560621 (2024-002)

Material Weakness 2024

Clarinda Community School District

IA

Internal Control / Segregation of Duties

The working plan is for one person to deposit money, one person to enter receipts into Software, and one person to reconcile the bank statements. Accounts Payable - we have a chain of approval for requisitions - building Principal, Superintendent, Director of Finance, and Accounts Payable Clerk.

View Audit 356530

Finding 560591 (2024-001)

Significant Deficiency 2024

American Psychiatric Association Foundation

DC

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Views of Responsible Officials: The Grants manager and Grants Compliance manager positions had turnover in 2024. The search for their replacements continues. With various temporary staff filling the roles in 2024, delays occurred in meeting reporting deadlines. Management has reviewed all agreements...

Views of Responsible Officials: The Grants manager and Grants Compliance manager positions had turnover in 2024. The search for their replacements continues. With various temporary staff filling the roles in 2024, delays occurred in meeting reporting deadlines. Management has reviewed all agreements to ensure its tracking tools reflect all relevant due dates for financial and narrative reports, as required by the agreements. These tracking tools will be monitored monthly to ensure timely submissions of reports by the established due dates.

View Audit 356509

Finding 560570 (2024-001)

Significant Deficiency 2024

City of Culver City

CA

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Name of Contact Person: Elizabeth Shavelson, Assistant Chief Financial Officer Corrective Action: The City has established a timeline and identified milestones for its audit and financial reporting process for the Fiscal Year Ended June 30, 2025. The City will initiate the process much earlier to a...

Name of Contact Person: Elizabeth Shavelson, Assistant Chief Financial Officer Corrective Action: The City has established a timeline and identified milestones for its audit and financial reporting process for the Fiscal Year Ended June 30, 2025. The City will initiate the process much earlier to allow more time for completion and will continue to track and monitor is progress against its established milestones throughout the process. Along with filling vacant staff positions, the City has engaged a consultant to assist the Finance Department in developing and enhancing documentation specific to financial reporting procedures. The City has also been working with its financial software support team to streamline certain ERP system configurations in order to improve the City’s financial reporting process. Proposed Completion Date: 12/31/2025

View Audit 356501

Finding 560552 (2024-001)

Material Weakness 2024

Home Share 092-Hd017

MN

HUD Housing Programs Cash Management Material Weakness

Supportive Housing for Persons with Disabilities (Section 811) – Assistance Listing No. 14.181 Recommendation: It is recommended that the Project continue to monitor the deposit of Home Share funds into Accord’s operating account & transfer the funds in a timely manner. In addition, a review of the ...

Supportive Housing for Persons with Disabilities (Section 811) – Assistance Listing No. 14.181 Recommendation: It is recommended that the Project continue to monitor the deposit of Home Share funds into Accord’s operating account & transfer the funds in a timely manner. In addition, a review of the bank reconciliation should be documented to support that the deposits were reviewed and transferred timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have taken corrective action to ensure that funds are transferred to the appropriate account in a timely manner and have strengthened our review procedures to confirm compliance. We are actively working with Remit Plus & Sunrise Bank to prevent future delays and ensure ongoing compliance with federal regulations. Name(s) of the contact person(s) responsible for corrective action: Jes Cuoco Planned completion date for corrective action plan: May 31, 2025

View Audit 356481

Finding 560528 (2024-002)

Significant Deficiency 2024

Town of Townsend

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.1

Condition: Obligations and expenditures were overstated by $93,955 on the March 31, 2024 Project and Expenditure report. Corrective Action Planned: Town Administrator will work with CSS Capital Strategic Solutions LLC to potentially amend the filing with the Treasury. Anticipated Completion Date...

Condition: Obligations and expenditures were overstated by $93,955 on the March 31, 2024 Project and Expenditure report. Corrective Action Planned: Town Administrator will work with CSS Capital Strategic Solutions LLC to potentially amend the filing with the Treasury. Anticipated Completion Date: End of 2025 Contact: Town Administrator Nelson Mui, nmui@townsendma.gov, 978-597-1700 x1703

View Audit 356423

Finding 560523 (2024-001)

Material Weakness 2024

California Community Foundation

CA

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.303 § 200.324

Name of Auditee: California Community Foundation (CCF) Audit Period: Year Ended June 30, 2024 Finding Reference #: 2024-001 – Procurement Finding Description: The Foundation did not document the required cost or price analysis for procurement actions exceeding the Simplified Acquisition Threshold pr...

Name of Auditee: California Community Foundation (CCF) Audit Period: Year Ended June 30, 2024 Finding Reference #: 2024-001 – Procurement Finding Description: The Foundation did not document the required cost or price analysis for procurement actions exceeding the Simplified Acquisition Threshold prior to receiving bids or proposals, as required by 2 CFR 200.324 and 2 CFR 200.303. Corrective Action Planned: CCF acknowledges the finding and will enhance compliance with federal procurement standards by reinforcing staff training on cost and price analysis requirements, strengthening internal oversight mechanisms, and implementing a formalized process to ensure proper documentation is completed and retained. Periodic reviews and audits will verify adherence to these standards and maintain consistent implementation. Anticipated Completion Date: Corrective action will be implemented by November 30, 2024. Responsible Official(s): Jose Najera, Sr. Compliance & Operations Officer (213) 452-6218 - jnajera@calfund.org Management Comments: CCF remains committed to compliance with federal regulations and will take all necessary steps to ensure this issue is resolved. While existing procurement policies include the requirements noted in 2 CFR 200.324, these corrective actions will ensure that the implementation and documentation processes meet federal standards.

View Audit 356422

Finding 560522 (2024-003)

Significant Deficiency 2024

Aclamo

PA

Subrecipient Monitoring Reporting Significant Deficiency

Reporting – reports submitted to the county for the ARPA contract were not retained, effective internal controls were not in place to ensure proper document retention. ACLAMO acknowledges and agrees with Finding 2024-003 regarding the lack of effective internal controls to ensure the retention of re...

Reporting – reports submitted to the county for the ARPA contract were not retained, effective internal controls were not in place to ensure proper document retention. ACLAMO acknowledges and agrees with Finding 2024-003 regarding the lack of effective internal controls to ensure the retention of reports submitted to the County under the ARPA contract. To address this issue, the Interim Executive Director, in coordination with the Financial Team, has taken the following corrective actions: Quarterly Report Oversight: The Interim Executive Director will assume responsibility for submitting all required quarterly reports related to ARPA funding. This ensures a single point of accountability for timely and accurate reporting. Document Retention and Audit Readiness: Immediately following each report submission, ACLAMO will request confirmation of receipt and a copy of the submitted report from the County. These documents will be promptly uploaded and stored in ACLAMO’s Financial Team SharePoint Site to ensure secure access and proper audit documentation. Internal Control Enhancements: ACLAMO will also implement a formal tracking system (such as a report log) to document submission dates, confirmation receipts, and responsible staff members. This log will be reviewed quarterly by the Financial Team to ensure completeness and compliance. Staff Training: Relevant team members will receive training on proper document retention procedures, the importance of audit trails, and use of the SharePoint system to reinforce accountability and sustainability of this corrective action. ACLAMO is committed to improving its reporting systems and internal controls to ensure compliance with all federal and contractual requirements and to promote transparency and accountability.

View Audit 356420

Finding 560521 (2024-002)

Significant Deficiency 2024

Aclamo

PA

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.318

Procurement – policies related to procurement for the APRA contract were not followed, effective internal controls were not in place to ensure policies related to procurement were followed. ACLAMO acknowledges and agrees with Finding 2024-002 regarding the lack of adherence to procurement policies a...

Procurement – policies related to procurement for the APRA contract were not followed, effective internal controls were not in place to ensure policies related to procurement were followed. ACLAMO acknowledges and agrees with Finding 2024-002 regarding the lack of adherence to procurement policies and internal controls under the ARPA (American Rescue Plan Act) contract. To address this issue, the Interim Executive Director and the Financial Team have taken immediate steps to strengthen compliance and oversight. Specifically: Oversight and Delegation: ACLAMO and its Board of Directors have agreed to hire a full-time finance director for the organization. In conjunction with the ongoing designated Construction Manager, these individuals will ensure that all procurement and financial reporting actions are in accordance with internal policies and federal guidelines stated in the contract, and that project documentation is compiled and securely stored in a timely manner for audit readiness. Infrastructure Committee Procedures: The Interim Executive Director, alongside other members of ACLAMO management, are committed to developing and implementing standardized procedures for documenting meetings and procurement-related decisions, in collaboration with a delegate from the Infrastructure Committee. These procedures are being led by ACLAMO and will involve the designated Construction Manager to monitor compliance with standardized procedures & reporting throughout the project, that meeting minutes are properly recorded by the grantor's requirements, and that all activities are compliant with the grant and contract requirements. The Infrastructure Committee delegate’s role will be to ensure alignment and transparency. Training and Capacity Building: To ensure consistent application of procurement policies, ACLAMO will provide and require mandatory training for all staff involved in procurement and contract management. Training will cover federal procurement standards, internal procedures, and documentation protocols. Policy Review and Update: As part of our continuous improvement efforts, ACLAMO will conduct a comprehensive review of its procurement policy to ensure it fully aligns with federal Uniform Guidance (2 CFR 200) and make updates where needed. The revised policy will be disseminated to all relevant personnel. ACLAMO is committed to strengthening internal controls, ensuring transparency, and maintaining full compliance with all contractual and federal requirements.

View Audit 356420

Finding 560494 (2024-001)

None 2024

Electric Power Research Institute, Inc.

CA

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Research and Development Cluster – Department of Energy Publication Compliance Requirements Views of Responsible Officials: EPRI agrees with this finding. We are developing corrective actions to create a centralized archive of government publications, and a process with an owner to ensure that gover...

Research and Development Cluster – Department of Energy Publication Compliance Requirements Views of Responsible Officials: EPRI agrees with this finding. We are developing corrective actions to create a centralized archive of government publications, and a process with an owner to ensure that government publications are reviewed and approved before they are released outside of EPRI. Expected Completion Date: June 30, 2025, including a catch-up review of all 2025 government publications. Contact Person Jennifer Hill, Government Controller

View Audit 356410

Finding 560493 (2024-002)

Material Weakness 2024

Western States Cancer Research Ncorp

CO

Subrecipient Monitoring Cash Management Material Weakness

Responsible Official’s Response: Management agrees with the recommendation to establish and follow a documented internal control process over the review of cash management. Staff will work to develop an appropriate internal control process and once the process has been developed staff will document ...

Responsible Official’s Response: Management agrees with the recommendation to establish and follow a documented internal control process over the review of cash management. Staff will work to develop an appropriate internal control process and once the process has been developed staff will document in writing, the process and review it with department leaders. Additionally, staff members working in areas concerning this process will be trained to ensure process adherence.

View Audit 356401

Finding 560491 (2024-002)

Material Weakness 2024

Clear Lake Community School District

IA

Internal Control / Segregation of Duties

We will continue to monitor our procedures and implement additional controls where possible.

View Audit 356392

Finding 560477 (2024-003)

Significant Deficiency 2024

Marin City Health and Wellness Center

CA

Special Tests & Provisions Eligibility Internal Control / Segregation of Duties

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Sliding fee patients will be scheduled with an enrollment counselor to review options, including sliding f...

View of Responsible Officials and Planned Corrective Actions: MCHWC understands and agrees with the finding. Measures have been taken or will be taken for immediate resolution as follows: a) Sliding fee patients will be scheduled with an enrollment counselor to review options, including sliding fee. b) Sliding fee applications will be reviewed and recommended by the respective clinic manager. c) Sliding fee applications will go through a final approval by the Chief Operations Officer. d) Due to staff limitations, the revenue cycle (billing) team will sample applications through the year.

View Audit 356367

Finding 560443 (2024-001)

Significant Deficiency 2024

Northern Tier Community Action CORP

PA

Eligibility Internal Control / Segregation of Duties

Northern Tier Community Action Corporation concurs with the audit finding. The Organization did not maintain all client information in accordance with the requirements set forth by the grantor Agency. The Weatherization Department of the Organization had employee turnover in the 2023/2024 Fiscal Y...

Northern Tier Community Action Corporation concurs with the audit finding. The Organization did not maintain all client information in accordance with the requirements set forth by the grantor Agency. The Weatherization Department of the Organization had employee turnover in the 2023/2024 Fiscal Year including the Director of Weatherization, which caused a disruption in maintain client files. The Organization has reviewed the current system for maintaining files and identified any gaps in compliance with the grantor Agency requirement. The Organization then developed and implemented controls for maintaining client files that align with the grantor Agency’s requirements and provided training to all relevant personnel. This will ensure that the Organization is in compliance with all guidelines set forth by the grantor Agency. Northern Tier Community Action Corporation has implemented the above controls as of the report date.

View Audit 356353

Finding 560440 (2024-004)

Material Weakness 2024

Village of Turtle Lake

WI

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Procurement Policy The Recommendation: The Village should formally adopt policies and procedures which meet Uniform Guidance procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Village w...

Procurement Policy The Recommendation: The Village should formally adopt policies and procedures which meet Uniform Guidance procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The Village will draft and approve a procurement policy in compliance with Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Karrie Stanford, Treasurer. Planned completion date for corrective action plan: The activities outlined above will be completed by September 30, 2025.

View Audit 356344

Finding 560416 (2024-005)

Significant Deficiency 2024

Delta Research and Educational Foundation

DC

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials: DREF is in the process of hiring a part-time CFO to review all financial reports.

View Audit 356325

Finding 560411 (2024-002)

Material Weakness 2024

Westwood Community School District

IA

Internal Control / Segregation of Duties Reporting

The District will review internal control procedures and implement as current staff allows. The District did hire a 2nd secretary to hlep with of the segregation of duties such as activity cash boxes etc. in FY22.

View Audit 356317

Finding 560363 (2024-002)

Significant Deficiency 2024

Fort Cherry School District

PA

Internal Control / Segregation of Duties HUD Housing Programs

Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased becaus...

Recommendation: Ideally, the District would hire the number of staff necessary to segregate all duties. However, we realize segregation of duties is not practical, if not impossible. Because of this internal control situation, the responsibility of the Business Manager is greatly increased because the Board must rely on her knowledge of the everyday operations to discover any material changes in the School District’s financial position. Management’s Response: The School District recognizes that the limited number of staff adds to the risk associated with the daily operations. To mitigate this risk, the Business Manager has to take an active role in the day-to-day operations of the Business Unit. She actively reviews all reconciliations and receipts to ensure they are posted to the accounting system properly. In addition, she approves all check disbursements and is reviewing the general ledger on a consistent basis.

View Audit 356273

Finding 560362 (2024-002)

Significant Deficiency 2024

Distinctive Schools

IL

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties § 200.430

Finding Number – 2024-001 Procurement Finding & 2024-002 Payroll Finding Planned Corrective Action 1. Policy Development: Draft a comprehensive procurement policy that aligns with federal standards and addresses all required elements, including conflict of interest provisions and procurement methods...

Finding Number – 2024-001 Procurement Finding & 2024-002 Payroll Finding Planned Corrective Action 1. Policy Development: Draft a comprehensive procurement policy that aligns with federal standards and addresses all required elements, including conflict of interest provisions and procurement methods. 2. Approval Process: Present the drafted policy to leadership or the governing body for review and approval. 3. Implementation: Roll out the approved procurement policy to all relevant departments and stakeholders. 4. Training: Conduct training sessions to ensure staff understand and comply with the new procurement procedures. 5. Monitoring: Establish a system to regularly review procurement activities for compliance with the policy and federal regulations. 6. Implement a system of internal controls to ensure payroll charges are supported by accurate records reflecting actual work performed. This system should include regular reconciliation of estimated payroll allocations with actual time worked and documented certifications by employees or supervisors. Anticipate Completion Date – May 31, 2025 Responsible Contact Person – Monique Langston, Grant Director

View Audit 356269

Finding 560361 (2024-001)

Significant Deficiency 2024

Distinctive Schools

IL

Procurement, Suspension & Debarment Significant Deficiency Internal Control / Segregation of Duties § 200.318

Finding Number – 2024-001 Procurement Finding & 2024-002 Payroll Finding Planned Corrective Action 1. Policy Development: Draft a comprehensive procurement policy that aligns with federal standards and addresses all required elements, including conflict of interest provisions and procurement methods...

Finding Number – 2024-001 Procurement Finding & 2024-002 Payroll Finding Planned Corrective Action 1. Policy Development: Draft a comprehensive procurement policy that aligns with federal standards and addresses all required elements, including conflict of interest provisions and procurement methods. 2. Approval Process: Present the drafted policy to leadership or the governing body for review and approval. 3. Implementation: Roll out the approved procurement policy to all relevant departments and stakeholders. 4. Training: Conduct training sessions to ensure staff understand and comply with the new procurement procedures. 5. Monitoring: Establish a system to regularly review procurement activities for compliance with the policy and federal regulations. 6. Implement a system of internal controls to ensure payroll charges are supported by accurate records reflecting actual work performed. This system should include regular reconciliation of estimated payroll allocations with actual time worked and documented certifications by employees or supervisors. Anticipate Completion Date – May 31, 2025 Responsible Contact Person – Monique Langston, Grant Director

View Audit 356269

Finding 560359 (2024-002)

None 2024

First Housing Corporation D/b/a Cathedral Manor

CT

HUD Housing Programs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

We concur with the auditors finding as follows: During the years ended July 31, 2019, 2020, 2021, 2022, 2023 and 2024, management did not fully repay the loan advanced from the reserve for replacements upon receipt of the Section 8 subsidy that was outstanding at July 31, 2018. The loan in the amo...

We concur with the auditors finding as follows: During the years ended July 31, 2019, 2020, 2021, 2022, 2023 and 2024, management did not fully repay the loan advanced from the reserve for replacements upon receipt of the Section 8 subsidy that was outstanding at July 31, 2018. The loan in the amount of $19,337 is deemed to be an unauthorized distribution. As of July 31, 2024, the amount due to the reserve for replacement has been partially repaid. The remaining amount due as of July 31, 2024 is $9,669. b. Action(s) Taken or Planned on the Finding As of July 31, 2024, two installments were made in the amount of $4,834 for a total of $9,668. This has been deposited by the lender Walker & Dunlop to the repairs for reserve escrow account. The balance now owed on the repayment comes to $9,669. The updated loan agreement signed was signed on 3/14/24 to repay the balance of the loan borrowed to the Lender a payment of $100 each month until the loan is repaid in full.

View Audit 356265

Finding 560358 (2024-001)

None 2024

First Housing Corporation D/b/a Cathedral Manor

CT

HUD Housing Programs Internal Control / Segregation of Duties

2. Finding 2024-001 – Major Federal Award Programs Audit a. Comments on the Finding and Recommendation We concur with the auditors finding as follows: During the years ended July 31, 2019, 2020, 2021, 2022, 2023 and 2024, management did not make the required residual receipts reserve deposit in the ...

2. Finding 2024-001 – Major Federal Award Programs Audit a. Comments on the Finding and Recommendation We concur with the auditors finding as follows: During the years ended July 31, 2019, 2020, 2021, 2022, 2023 and 2024, management did not make the required residual receipts reserve deposit in the amount of $81,489 that was required within 90 days of year ended July 31, 2018, as required by HUD. The residual receipts amount has not been deposited as of the date of this report. b. Action(s) Taken or Planned on the Finding As of July 31, 2024, the amount due to the residual receipts has not been deposited, until the property is in a positive cash flow position, we are not able to commit to any type of repayment plan and we are looking for forgiveness on the amount.

View Audit 356265

Finding 560340 (2024-001)

Significant Deficiency 2024

West Valley School District No. 363

WA

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE West Valley School District No. 363 September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code o...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE West Valley School District No. 363 September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal Title I assessment system security requirements. Name, address, and telephone of District contact person: Ayesha Horton, Chief Financial Officer 2805 N Argonne Rd, Spokane, WA 99212 (509) 924-2150 Corrective action the auditee plans to take in response to the finding: The district acknowledges that a Test Security Building Plan (TSBP) was not on file for our Kindergarten Center during the 2023–24 school year. While all required testing assurances were submitted and staff received appropriate test security training, we recognize that the omission of a formal TSBP represents a lapse in documentation and controls. This oversight occurred during a period of staffing transition in the district’s assessment position, which contributed to the gap in plan submission for the Kindergarten Center. We appreciate the auditor's recommendation and have taken corrective action to address this issue. For the 2024–25 school year, we have verified that TSBPs are on file for all buildings where standardized assessments will be administered, including the Kindergarten Center. Looking ahead to the 2025–26 school year, our Kindergarten Center will no longer administer standardized assessments, as kindergarten students will transition back to their neighborhood elementary schools. This organizational change will further streamline compliance with OSPI’s assessment system security requirements. Anticipated date to complete the corrective action: 6/13/2025

View Audit 356251

Finding 560334 (2024-001)

Significant Deficiency 2024

South Coastal Counties Legal Services, Inc. and Affiliate

MA

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

April 22, 2025 Cognizant or Oversight Agency for Audit South Coastal Counties Legal Services, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street ...

April 22, 2025 Cognizant or Oversight Agency for Audit South Coastal Counties Legal Services, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit Period: January 1, 2024 - December 31, 2024 The findings from April 22,2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - FINANCIAL STATEMENT AUDIT FINDING SIGNIFICANT DEFICIENCY 2024-001 Seperation of Justice Center Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are sperately accounted for to ensure proper seperation consistent with LSC requirements. We understand management has submitted a correction action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and developed a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to ensure that compliance with the corective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Mulitple aspects of the plan has been implemented, with full compliance expected in 2025. FINDING - FEDERAL AWARD PROGRAM AUDIT SIGNIFICANT DEFICIENCY LEGAL SERVICES CORPORATION 2023-001 Seperation of the Justice Center The significant deficiency relates to the Federal Funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under assistance listing number 09.112087. Recommendation: We recommend management examine their interal processes and policies on how activies for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a corrective action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably relayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and develiped a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to enure that compliance with the correction action plan with result in adequate separation between entities under Title 45 of the Code of Fedearl Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2025. If Legal Services Corporation has questions regarding this plan, please call Christopher Oldi, Executive Director at (774) 488-5950 Sincerely yours, Christopher Oldi Executive Director

View Audit 356232

Corrective Action Plans

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