Corrective Action Plans

Finding 544423 (2024-004)

None 2024

City of Oxnard

CA

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

The Department will conduct a formal review of its processes and policies to identify potential weaknesses in the payroll timekeeping and approval process, and will update its policies and procedures to align with the roles and responsibilities of those involved in rostering and timekeeping. The dep...

The Department will conduct a formal review of its processes and policies to identify potential weaknesses in the payroll timekeeping and approval process, and will update its policies and procedures to align with the roles and responsibilities of those involved in rostering and timekeeping. The department has already taken corrective action to ensure that duty chiefs are finalizing the rosters before the end of their shift and making it the responsibility of the timekeeper to initiate action when finalization by the Duty Chiefs has not occurred so the timekeepers review process can be completed.

View Audit 351106

Finding 544390 (2024-002)

Material Weakness 2024

North General Aids Housing Development Fund Corporation

NY

Questioned Costs HUD Housing Programs Allowable Costs / Cost Principles

As of March 26, 2025, these amounts have been credited back to the company through the central disbursement accounting system. Management will implement reviews on a quarterly basis to ensure that only expenses related to the Corporation are included in expenses and will review indirect allocation...

As of March 26, 2025, these amounts have been credited back to the company through the central disbursement accounting system. Management will implement reviews on a quarterly basis to ensure that only expenses related to the Corporation are included in expenses and will review indirect allocations to ensure only appropriate expenses approved in the HUD budget will be included in expenses.

View Audit 351045 Questioned Costs: $1

Finding 544387 (2024-002)

Material Weakness 2024

Seward County

NE

Internal Control / Segregation of Duties Reporting

The County has discussed the finding but must consider the cost of adequate segregation of duties when determining the use of tax money.

View Audit 351044

Finding 544386 (2024-002)

Material Weakness 2024

Easton Valley Community School District

IA

Internal Control / Segregation of Duties Reporting

The District will evaluate its internal controls and find ways to be the most efficient with them with a limited number of staff.

View Audit 351035

Finding 544368 (2024-001)

Material Weakness 2024

River City Education Organization, Inc.

FL

Internal Control / Segregation of Duties

Bold City is continuing to collaborate with BuildingHope and is also coordinating with a 3rd party to perform an operations compliance review. Some of the missing documentation in the Charter Ace platform was a result of Bold City transitioning over to the platform during the fiscal year. Going forw...

Bold City is continuing to collaborate with BuildingHope and is also coordinating with a 3rd party to perform an operations compliance review. Some of the missing documentation in the Charter Ace platform was a result of Bold City transitioning over to the platform during the fiscal year. Going forward, appropriate supporting documentation will be uploaded to Charter Ace for all the disbursments and all the cash disbursment procedures will be followed. In addition, Bold City believes Building Hope did have appropriate access to all necessary accounts and expense databases but will verify this going forward. Bold City will follow and imolement the reccomendations af the auditor.

View Audit 351014

Finding 544363 (2024-003)

Significant Deficiency 2024

Ontrack Inc.

OR

Subrecipient Monitoring Reporting Significant Deficiency

Contact Person Mark Bell Director of Finance vcc.m.bell@ontrackroguevalley.org Explanation and Specific Reasons for Disagreement With the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned 1. Establish FSRS Reporting Policy and Proced...

Contact Person Mark Bell Director of Finance vcc.m.bell@ontrackroguevalley.org Explanation and Specific Reasons for Disagreement With the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned 1. Establish FSRS Reporting Policy and Procedures o The Organization will develop and implement a formal Subaward Reporting Policy to ensure that all first-tier subawards of $30,000 or more are reported in FSRS in compliance with 2 CFR Part 170. 2. Assign Responsibility and Oversight o A specific staff member within the Grants department will be designated as the FSRS Reporting Coordinator and will be responsible for verifying the completeness and accuracy of subaward reporting and for timely submission to FSRS. o A pre-submission review will be conducted by the FSRS Reporting Coordinator to verify that subawards over $30,000 are captured and reported. 3. Implement Internal Controls and Review Checkpoints o All subawards will be reviewed as part of the pre-award and post-award grant workflow to determine FSRS applicability. o A pre-submission review will be conducted by the Grants Compliance Officer to verify that subawards over $30,000 are captured and reported. 4. Monitoring and Audit Trail Documentation o FSRS submissions will be documented and retained in the grant file along with confirmation of submission and reporting screenshots. Anticipated Completion Date September 30, 2025

View Audit 351003

Finding 544359 (2024-002)

Significant Deficiency 2024

New Mexico Coalition Against Domestic Violence

NM

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

To ensure accountability and timely completion, management conducts periodic meetings to review upcoming deadlines and confirm that the departments responsible have completed and submitted the required reports. These meetings serve to reinforce compliance, address any potential delays proactively, a...

To ensure accountability and timely completion, management conducts periodic meetings to review upcoming deadlines and confirm that the departments responsible have completed and submitted the required reports. These meetings serve to reinforce compliance, address any potential delays proactively, and ensure adherence to all reporting obligations.

View Audit 350999

Finding 544358 (2024-001)

Significant Deficiency 2024

New Mexico Coalition Against Domestic Violence

NM

Internal Control / Segregation of Duties

To prevent unauthorized changes, to strengthen payroll and time management controls and ensure proper oversight, controls related to the approval process for staff changes and timesheets will be enforced.

View Audit 350999

Finding 544357 (2024-002)

Significant Deficiency 2024

College of Our Lady of the Elms

MA

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.328 § 200.329

Reporting, Significant Deficiency, Other Matters Federal Agency: U.S. Department of Education Federal Program Name: Fund for the Improvement of Postsecondary Education Assistance Listing Number: 84.116 During testing it was noted that the College did not submit the required annual report. Recomme...

Reporting, Significant Deficiency, Other Matters Federal Agency: U.S. Department of Education Federal Program Name: Fund for the Improvement of Postsecondary Education Assistance Listing Number: 84.116 During testing it was noted that the College did not submit the required annual report. Recommendation: We recommend the College should establish a policy that provides the guidance required to comply and address regulatory reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has since communicated key personnel changes to the US DOE and is working to finalize and submit the Annual Performance Report that is currently due to regain good standing with the financial reporting compliance requirement. Name(s) of the contact person(s) responsible for corrective action: Sarah Simard, Controller Planned completion date for corrective action plan: April 2025

View Audit 350993

Finding 544352 (2024-003)

Material Weakness 2024

Center Point-Urbana Community School District

IA

Internal Control / Segregation of Duties Reporting

The District will continue working on improving our procedures to fully ensure proper segregation of duties possible with the current staff.

View Audit 350991

Finding 544349 (2024-002)

Significant Deficiency 2024

City of Bell, California

CA

Reporting Matching / Level of Effort / Earmarking Program Income

Finding 2024-002 Reporting – Internal Control and Compliance over Reporting City will incorporate more regular reconciliations of ARPA Expenditures to ensure better tracking and accurate reporting. To comply with reporting requirements the City will be revising the SLFRF reporting for the upcoming y...

Finding 2024-002 Reporting – Internal Control and Compliance over Reporting City will incorporate more regular reconciliations of ARPA Expenditures to ensure better tracking and accurate reporting. To comply with reporting requirements the City will be revising the SLFRF reporting for the upcoming year due on April 30, 2025. Responsible Person: Director of Finance Expected Implementation Date: July 1, 2025

View Audit 350982

Finding 544180 (2024-009)

Significant Deficiency 2024

Delaware State University

DE

Questioned Costs Internal Control / Segregation of Duties Significant Deficiency § 200.414

2024-009 Research and Development Cluster – Federal Assistance Listing Nos. Various – Indirect Cost Rate Recommendation: We recommend management and the applicable grant individuals to properly validate the rate being used in the calculation to the grant agreement. Explanation of disagreement with a...

2024-009 Research and Development Cluster – Federal Assistance Listing Nos. Various – Indirect Cost Rate Recommendation: We recommend management and the applicable grant individuals to properly validate the rate being used in the calculation to the grant agreement. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Funds Accounting (RFA) team will ensure updated SOPS include checks and balances to include a review process to make sure that the IDC amount matches the award documents. Automate process within the ERP systems, as applicable. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya A. Cardwell Planned completion date for corrective action plan: December 2026

View Audit 350927 Questioned Costs: $1

Finding 544178 (2024-007)

Significant Deficiency 2024

Delaware State University

DE

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.308 § 200.309 § 200.403

2024-007 Research and Development Cluster – Federal Assistance Listing Nos. 84.017 and 47.081 – Period of Performance Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related ...

2024-007 Research and Development Cluster – Federal Assistance Listing Nos. 84.017 and 47.081 – Period of Performance Recommendation: We recommend that the University review and revise their current procedures in place and provide training to employees within the grant and finance functions related to the grant reconciliation and recording process to ensure expenses are reflected prior to the grant ending and recorded in the correct period on the SEFA. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: Restricted Funds Accounting (RFA) team has restructured with new leadership and added all new staff. RFA will train new staff, develop and update policies and procedures, and automate processes within ERP systems, as appropriate. RFA is creating current and updated SOPS for each task and making sure the current staff is learning processes the correct way; this includes reconciliation and recording in the correct period. Name(s) of the contact person(s) responsible for corrective action: Director of Accounting, Tonya Cardwell. Planned completion date for corrective action plan: December 2026

View Audit 350927

Finding 544177 (2024-006)

Material Weakness 2024

Delaware State University

DE

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking § 200.303

2024-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation o...

2024-006 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, 84.033 and 84.268 – Gramm-Leach-Bliley Act (GLBA) Recommendation: We recommend the University review is policies and procedures and update the information security plan to be GLBA compliant. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Division of Information Technology will implement a comprehensive user account deactivation procedure. The user account deactivation procedure will significantly reduce security risks, ensure compliance with regulatory requirements, and protect sensitive information from unauthorized access. Name(s) of the contact person(s) responsible for corrective action: Executive Director of Network Services, Russell Weaver & Vice President / CIO, Darrell McMillon Planned completion date for corrective action plan: June 2025

View Audit 350927

Finding 544176 (2024-005)

Significant Deficiency 2024

Delaware State University

DE

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

2024-005 Student Financial Assistance Cluster – CFDA Nos. 84.063, 84.033 and 84.268 – Credit Balances Recommendation: We recommend that the University reevaluate its process to ensure that credit balances on student accounts due to the application of title IV funds are refunded within 14 days. Expla...

2024-005 Student Financial Assistance Cluster – CFDA Nos. 84.063, 84.033 and 84.268 – Credit Balances Recommendation: We recommend that the University reevaluate its process to ensure that credit balances on student accounts due to the application of title IV funds are refunded within 14 days. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: ERP (Banner) system was being used to generate reporting for credit balances. A glitch was discovered using this process due to application of payment. Student Accounts change the reporting method to Argos, which provided a more accurate and timely report of all credit balances regardless of the disbursement term. Name(s) of the contact person(s) responsible for corrective action: AVP of Student Accounts, Carold Boyer-Yancy & Senior Associate Director of Operations, Lindsay Sands Planned completion date for corrective action plan: December 2024

View Audit 350927

Finding 544175 (2024-004)

Significant Deficiency 2024

Delaware State University

DE

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior...

2024-004 Student Financial Assistance Cluster – Federal Assistance Listing Nos. 84.007, 84.063, and 84.268 – Outstanding Refund Checks Recommendation: We recommend the University review policies and procedures around outstanding student refund checks to ensure the checks are returned to the ED prior to the 240-day deadline. Explanation of disagreement with audit finding: There is no disagreement to the audit finding. Action taken in response to finding: The Assistant Controller will implement review procedures for timely reconciliation of bank and ledger accounts & maintain an accurate listing of those discrepancies. This information will be timely shared with respective teams to address. Name(s) of the contact person(s) responsible for corrective action: Assistant Controller, Clifton Smith, II. Planned completion date for corrective action plan: July 2025

View Audit 350927

Finding 544140 (2024-005)

Significant Deficiency 2024

Washington Adventist University

MD

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Action taken in response to finding: Washington Adventist University will review Institutional charges used in R2T4 to ensure that all institutional charges used in R2T4 calculations are accurate and align with federal definitions. Regular training sessions will be conducted for staff involved in R...

Action taken in response to finding: Washington Adventist University will review Institutional charges used in R2T4 to ensure that all institutional charges used in R2T4 calculations are accurate and align with federal definitions. Regular training sessions will be conducted for staff involved in R2T4 process to ensure they understand the requirements and procedures and also implement a system of review calculations and R2T4 cases before submission. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025

View Audit 350924

Finding 544138 (2024-002)

Material Weakness 2024

Washington Adventist University

MD

Student Financial Aid Internal Control / Segregation of Duties Cash Management § 200.303

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to impro...

Action taken in response to finding: Washington Adventist University (WAU) is evaluating its current internal control and will make the necessary improvements so as to assure accuracy and compliance with the laws and regulations applicable to WAU. Furthermore, WAU will map internal control to improve segregation of duties where possible and follow the Committee of Sponsoring Organizations of the Treadway Commission best practices for small business. Name(s) of the contact person(s) responsible for corrective action: Alfred Taylor Planned completion date for corrective action plan: June 30, 2025.

View Audit 350924

Finding 544096 (2024-002)

Significant Deficiency 2024

New Reach, Inc.

CT

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding No. 2024-002: Compliance Reporting Description of Finding: The Organization submitted periodic reports that did not reconcile to the accounting records and were not submitted by the due date. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Ac...

Finding No. 2024-002: Compliance Reporting Description of Finding: The Organization submitted periodic reports that did not reconcile to the accounting records and were not submitted by the due date. Statement of Concurrence or Nonconcurrence: The organization agrees with this finding. Corrective Action: In August 2024 the Organization engaged the services of an outside consultant who is a practicing CPA with extensive experience auditing not-for profit organizations. Policies and related procedures have been implemented to ensure the books and records are closed on a monthly basis and all reports are reviewed for agreement with the accounting records and approved prior to being filed. Name of Contact Person: Kellyann Day Chief Executive Officer, (203) 492-4866, kday@newreach.org Projected Completion Date: The project is anticipated to be completed during fiscal year 2025.

View Audit 350907

Finding 544078 (2024-001)

Material Weakness 2024

Gaudenzia Inc.

PA

Allowable Costs / Cost Principles Eligibility Matching / Level of Effort / Earmarking

2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of S...

2024-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: HOME Investment Partnership Program Assistance Listing Number: 14.239 Pass-Through Agencies: City of Philadelphia, Redevelopment Authority: Venango – Loan Thompson Street – Loan County of Schuylkill - Home Investment Partnerships and Housing Trust Funds Programs: Fountain Springs - Loan Mayor and City of Baltimore: Baltimore Housing - Park Heights Women and Children - Loan Condition: As part of the eligibility requirement for the HOME Investment Partnership program, we are required to review files of client residents who were provided residential drug and alcohol treatment services at the Organization’s locations in Venango (Re-Entry), Fountain Springs, Thompson Street, and Park Heights Women and Children. We sampled a total of 40 resident clients at these four locations covered by HOME loans and requested documentation within client resident files, including proof of residency, proof of income (low income or homeless), and lease or housing agreement (depending on program requirements). Of the 40 resident client files reviewed, management was unable to provide any proof of income or determination of homelessness or residency for 24 files. Recommendation: We recommend that management adopt policies and procedures including both the communication of compliance requirements between staff and locations and the development of documentation and processes to assist in how income eligibility is determined. This includes management developing certain income verification documents that can be used as part of the intake process for determining the eligibility of the residential client. In addition, process will need to be developed for the redetermination of income if a residential client has lived over a year at a particular location. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Gaudenzia, Inc believes that had the requisite documentation been completed, it would have been in compliance with the low-income compliance requirement as the referral sources that were used to place the clients in the program are all coming from CBH as well as other MCO funded partners. These referral sources are typically Medicaid clients and are typically well below the low-income requirement thresholds. Action taken in response to finding: Gaudenzia, Inc has incorporated existing low-income eligibility procedures to the Project Home Loans program sites to be in full compliance of the eligibility requirements. These procedures will be reinforced within our programs to ensure the requisite documentation is in place. Name of the contact person responsible for corrective action: Nikant Ohri, Chief Financial Officer, nikant.ohri@guadenzia.org (610) 860-2061 Planned completion date for corrective action plan: June 30, 2025

View Audit 350881

Finding 544075 (2024-001)

Material Weakness 2024

Williams Unified School District No. 2

AZ

Subrecipient Monitoring Material Weakness Reporting

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 7,2025 Planned Corrective Action: WUSD2 has designed and implemented an effective internal ...

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Brianne Ford, Business Manager Anticipated Completion Date: April 7,2025 Planned Corrective Action: WUSD2 has designed and implemented an effective internal control procedure to ensure that the federal reporting is tracked and completed in a timely manner. The Business Manager and Federal Programs Director will meet monthly to review grant funding and reporting. This will include any deadlines for submissions of grants and reporting.

View Audit 350877

Finding 544074 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Reno

NV

HUD Housing Programs Eligibility Significant Deficiency

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that the Authority reviews the controls in place to ensure that income reported within the HUD-50058 is supported through 3rd party verification. Explanation of disagreement with audit finding: There is...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that the Authority reviews the controls in place to ensure that income reported within the HUD-50058 is supported through 3rd party verification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since the audit findings were noted, the RHA immediately implemented a 3rd party approval process for all 50058 transactions. For 60 days, the Senior Property Manager and the Compliance Specialist will review all completed recertifications performed by Property Managers to ensure compliance with all HUD regulations prior to approving the 50058 in our software system. Upon approval, the Senior Property Manager or the Compliance Specialist will sign off on the recertification packet prior to it being scanned to the tenant’s file. If errors are found, the Property Manager will be advised to make the necessary corrections/changes. Once the corrections are made it will be resubmitted to the Senior Property Manager or Compliance Specialist for approval. After 60 days, an assessment of all errors noted will be completed to determine if there are consistent errors occurring which warrant additional training or if specific Property Managers require additional support with continued review of all recertifications. If a Property Manager’s work was free of errors after the initial 60 days, then a random selection of 25% of their work product will be reviewed monthly and signed off on the recertification packet prior to being scanned to the tenant’s file. The Asset Management Administrator or Director of Asset Management will pull a random selection of 10% of the approved recertifications that the Senior Property Manager and Compliance Specialist approved to also verify their accuracy in approving files. RHA is also sending all Property Managers through the Nan McKay HCV and Public Housing Rent Calculation training which will take place in person from February 18, 2025, through February 20, 2025. This will be at least the second time each Property Manager will complete this training since their hire date. Name(s) of the contact person(s) responsible for corrective action: Kristin Scott Planned completion date for corrective action plan: May 1, 2025 (ongoing for regular quality control efforts).

View Audit 350875

Finding 544063 (2024-001)

Material Weakness 2024

Brandywine Community Resource Council Dba Claymont Community Center

DE

Reporting Internal Control / Segregation of Duties

Management acknowledges the recommendation and has begun considering controls consistent with the recommendation. Appropriate year-end closing procedures will be written to document required reconciliations and related internal controls over completeness and accuracy.

View Audit 350868

Finding 544057 (2024-002)

Significant Deficiency 2024

Intecare, INC

IN

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

2024-002 Supportive Services for Veteran Families – Assistance Listing No. 63.033 Recommendation: CLA recommends the control process be reviewed and enhanced to ensure consistency in obtaining proper approvals. Explanation of disagreement with audit finding: There is no disagreement with the audit...

2024-002 Supportive Services for Veteran Families – Assistance Listing No. 63.033 Recommendation: CLA recommends the control process be reviewed and enhanced to ensure consistency in obtaining proper approvals. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Adjusted who was responsible for payroll approvals. Name(s) of the contact person(s) responsible for corrective action: Lara Williams Planned completion date for corrective action plan: 11/1/2024

View Audit 350867

Finding 544054 (2024-001)

Significant Deficiency 2024

Intecare, INC

IN

Reporting Significant Deficiency Internal Control / Segregation of Duties

SIGNIFICANT DEFICIENCY 2024-01 Financial Reporting Recommendation: The organization should ensure: • Internal controls are in place and performed throughout the year to enable an efficient year end closing process. • Documentation of the performance of internal reviews over reconciliations and jour...

SIGNIFICANT DEFICIENCY 2024-01 Financial Reporting Recommendation: The organization should ensure: • Internal controls are in place and performed throughout the year to enable an efficient year end closing process. • Documentation of the performance of internal reviews over reconciliations and journal entries is retained and is readily available. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An external application is now being used to track reviews of journal entries and reconciliations to make up for this being a missing feature in the accounting system. Name(s) of the contact person(s) responsible for corrective action: Noah Masson Planned completion date for corrective action plan: 8/1/2024

View Audit 350867

Corrective Action Plans

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