Corrective Action Plans

Finding 560537 (2023-001)

Material Weakness 2023

CO

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

The District will establish policies and procedures to be followed to ensure proper review, approval and recording of federal expenditures.

View Audit 356444

Finding 560486 (2023-002)

Material Weakness 2023

Town of Sturbridge, Massachusetts

MA

Material Weakness Internal Control / Segregation of Duties

Finding 2022-002 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Wh...

Finding 2022-002 – Education Stabilization Fund – AL No.’s 84.425D & 84.425U Department of Education Massachusetts Department of Elementary and Secondary Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the school department provided time and effort certifications that did not agree to the payroll records, and were not dated at the time of approval. Questioned Costs: Unknown Context: During our test of payroll transactions of the ESSER II and ESSER III grants it was noted that the time and effort certifications did not agree to the payroll records and were not dated. Effect: The Town of Sturbridge was not in compliance with the time and effort certification requirements. Cause: Due to staffing changes, time and effort documents were not completed in a timely manner. Identification as a Repeat Finding: N/A Recommendation: We recommend the Town of Sturbridge follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and agree with the payroll records, and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Responsible for Corrective Plan: Director of Business and Finance Estimated Completion Date: October 2024 Action Taken: Moving forward the school department bookkeepers will work to ensure time and effort certifications are completely in a timely fashion.

View Audit 356376

Finding 560431 (2023-001)

Material Weakness 2023

The Center for Black Women's Wellness, Inc.

GA

Cash Management Internal Control / Segregation of Duties § 200.303 § 200.305

Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement. Grantee Response and Corrective Action Plan 2023-001: We concur...

Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement. Grantee Response and Corrective Action Plan 2023-001: We concur with this finding and have implemented measures to mitigate the repetition or additional occurrences. Previously draw down documentation was uploaded to a shared folder, in which the CEO and Fiscal Manager had access. In 2024, we implemented additional procedures to document review of drawdowns and supporting documentation. Additionally, documentation includes attaining the CEO signature on draw down documentation before the draw down is made. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024

View Audit 356331

Finding 560406 (2023-003)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Finding Reference Number: 2023-003 Condition: In September 2023, HUD suspended its HAP subsidy to the Organization due to noncompliance regarding the tenant recertifications requirements under the HAP Contract. Recommendation: We recommend that control systems are put in place to ensure there are re...

Finding Reference Number: 2023-003 Condition: In September 2023, HUD suspended its HAP subsidy to the Organization due to noncompliance regarding the tenant recertifications requirements under the HAP Contract. Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding OJF has completed all overdue tenant recertifications. To prevent future delinquent recertifications, OJF will conduct a root cause analysis by January 15, 2025 to identify gaps in the current process. Once gaps are identified, procedures will be updated to provide clear guidelines and timelines to staff. By February 15, 2025, OJF will implement a tracking system for tenant recertifications, including supervisory review of all tenant files. By March 15, 2025, relevant OJF staff will undergo training on compliance with HUD requirements. This will include the creation of a compliance calendar. OJF’s senior management team and board of directors will monitor progress towards these goals. Progress reports will be drafted no later than April 15, 2024

View Audit 356309

Finding 560404 (2023-002)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

Eligibility HUD Housing Programs Reporting

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 mov...

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 move-ins and move-outs sampled out of the population (9 total move-ins and 13 total move-outs during the audit period). Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding To address this finding, OJF will take the following actions: 1. Implement regular tenant file reviews at least semi-annually beginning January 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 2. Develop a mandatory training program on compliance requirements for property management site staff to follow by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 3. Revise and distribute existing tenant file management procedures by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 4. Establish a monitoring and feedback system by March 15, 2025 for site staff to seek guidance on or report challenges of file management so that advice can be given and/or corrective action taken a. Responsible party: OJF asset management director and property management portfolio manager 5. Conduct quarterly management reviews beginning 4/15/2025 to discuss and evaluate the effectiveness of above actions a. Responsible party: OJF asset management director and property management portfolio manager

View Audit 356309

Finding 560393 (2023-004)

Material Weakness 2023

Bakersfield, American Indian Health Project INC

CA

Reporting Internal Control / Segregation of Duties

Establish and Maintain a Reporting Calendar: A comprehensive grant reporting calendar will be implemented to track all financial and performance reporting deadlines. Calendar will include due dates, responsible staff, and required supporting documentation. Assigned Clear Roles and Responsibilities:...

Establish and Maintain a Reporting Calendar: A comprehensive grant reporting calendar will be implemented to track all financial and performance reporting deadlines. Calendar will include due dates, responsible staff, and required supporting documentation. Assigned Clear Roles and Responsibilities: Each grant report will have a designated preparer and reviewer. The Controller will be responsible for ensuring that all reports reconcile to the general ledger before submission. Implemented Standardized Reporting Procedures: A written Grants Reporting and Procedure Manual will be developed outining step-by-step procedures for preparing, reviewing, and submitting reports. Reports will only be submitted after reconciliation with the accounting system and documented approval from the Finance Director or Controller. Training and Capacity Building: Staff responsible for grant reporting will receive annual training on federal compliance requirements, Uniform Guidance, and internal procedures. Training sessions will include examples of common reporting errors and reconciliation best practices. Monitoring and Internal Reviews: The Finance Director will conduct a monthly compliance check to verify timely completion and accuracy of each report. Quarterly internal audits will be conducted to assess adherence to the reporting procedures and controls.

View Audit 356287

Finding 560390 (2023-003)

Material Weakness 2023

Bakersfield, American Indian Health Project INC

CA

Reporting Internal Control / Segregation of Duties

Reporting Calendar and Schedule: A grant reporting calendar will be created and maintained, outlining all required reporting deadlines for each funding source, including due dates, responsible staff, and required documentation. The calendar will be reviewed weekly by the Finance Director to ensure u...

Reporting Calendar and Schedule: A grant reporting calendar will be created and maintained, outlining all required reporting deadlines for each funding source, including due dates, responsible staff, and required documentation. The calendar will be reviewed weekly by the Finance Director to ensure upcoming deadlines are met. Assignment of Responsibilities: Clear responsibilities will be assigned to specific personnel for each step of the reporting process, including data preparation, report drafting, internal review, and final submission. A checklist will be used for each report to document the review proceduress and ensure all elements are completed accurately and timely. Reconciliation Procedures: All reports will be reconciled to the general ledger and supporting schedules prior to submission to ensure consistency and accuracy. Supporting documentation will be attached to each report file to provide an audit trail. Internal Review Process: A second-level review by the Controller or Finance Director will be required before reports are submitted to funding agencies. Review will include verifying accuracy, completeness, and agreement with accounting system data. Training and Internal Controls: Staff responsible for report preparation will undergo annual training on grant compliance requirements, Uniform Guidance, and reporting accuracy. Internal controls will be documented in Grants Management Policy and Procedures Manual, including reporting guidelines. Monitoring and Follow-Up: Compliance with the reporting calendar and procedures will be tracked monthly. Any missed or delayed reports will be investigated, and corrective actions taken immediately.

View Audit 356287

Finding 560337 (2023-002)

None 2023

Near West Side Multi-Service Corporation

OH

Internal Control / Segregation of Duties

We will implement a comprehensive review process to ensure all required documentation is included. This will involve regular audits of case files, enhanced training for staff on documentation requirements, and the development of a standardized checklist to ensure completeness.

View Audit 356241

Finding 560336 (2023-001)

None 2023

Near West Side Multi-Service Corporation

OH

Reporting Internal Control / Segregation of Duties

We will implement stricter adherence to deadlines and ensure that all reports are filed on time. Measures will include setting up reminder systems and providing additional training to staff on the importance of meeting these deadlines.

View Audit 356241

Finding 560310 (2023-003)

Material Weakness 2023

Windsor Housing Authority

CT

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accou...

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accountant and Auditors to make sure deadlines are realistic, coordinated and attainable. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 560111 (2023-003)

Significant Deficiency 2023

Town of Enfield

NH

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

We will implement more internal training with the Accounts Payable department to ensure manifests are signed.

View Audit 356131

Finding 560097 (2023-002)

Significant Deficiency 2023

Central Area Rural Transit System, Inc.

AK

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expendit...

Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expenditures to determine single audit status, and file corresponding reports in a timely manner. Expected Completion Date June 30, 2025

View Audit 356074

Finding 560093 (2023-003)

Significant Deficiency 2023

Murray County

MN

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

Finding Number: 2023-003 Finding Title: Special Tests and Provisions – Davis‐Bacon Act Name of Contact Person Responsible for Corrective Action: Heidi E. Winter, County Auditor-Treasurer Corrective Action Planned: County staff will obtain and properly review the certified payrolls received from a...

Finding Number: 2023-003 Finding Title: Special Tests and Provisions – Davis‐Bacon Act Name of Contact Person Responsible for Corrective Action: Heidi E. Winter, County Auditor-Treasurer Corrective Action Planned: County staff will obtain and properly review the certified payrolls received from all contractors and subcontractors for compliance with the Davis‐Bacon Act and Title 29 U.S. Code of Federal Regulations Part 5 and ensure documentation exists to support monitoring of and compliance with this requirement. Anticipated Completion Date: December 31, 2024

View Audit 356059

Finding 560044 (2023-001)

Significant Deficiency 2023

Wisconsin Cheese Makers Association

WI

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

Comments on findings and recommendations Management should implement a process to evaluate and allocate expenses on a regular basis. Actions taken or planned Management implemented a process to evaluate and allocate expenses based on employee estimates of time spent by function and proportion of th...

Comments on findings and recommendations Management should implement a process to evaluate and allocate expenses on a regular basis. Actions taken or planned Management implemented a process to evaluate and allocate expenses based on employee estimates of time spent by function and proportion of the association’s floor space utilized by each employee during the year. Anticipated completion date July 1, 2023

View Audit 355972

Finding 560005 (2023-003)

Significant Deficiency 2023

Ida B Wells, INC

CT

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding; Reference Number: 2023-003 Description of Finding: The audit and reporting package were not submitted by the due date April 30, 2024. Finding is a significant deficiency. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will ensu...

Finding; Reference Number: 2023-003 Description of Finding: The audit and reporting package were not submitted by the due date April 30, 2024. Finding is a significant deficiency. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will ensure that there is an adequate level of appropriately trained and experienced personnel and that internal controls over financial reporting will function properly to submit the audit and reporting package timely. Name of Contact Person: Kimalee Williams, CEO - Faith Asset Management, LLC, (860) 528-5000, kimalee@faithassetmgt.com Projected Completion Date: July 31, 2026

View Audit 355922

Finding 559956 (2023-005)

Significant Deficiency 2023

Mental Health Association in Orange County, Inc.

NY

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

• Finding 2023-005 – Compliance and Significant Deficiency in Internal Control over compliance with Allowable Costs: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with the audit finding. o Corrective Action Plan: MHA updated internal procedures to assure the Assista...

• Finding 2023-005 – Compliance and Significant Deficiency in Internal Control over compliance with Allowable Costs: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with the audit finding. o Corrective Action Plan: MHA updated internal procedures to assure the Assistant Director of Housing is reviewing rent calculations to assure there are not data entry issues, when there are questions in the program about what should qualify as “income” an internal discussion is held with the Director of Corporate Compliance and the Clinical Director of Behavioral Health Services. The Assistant Director of Housing and Care Coordination will notify all staff responsible for administering HUD programs of the policy changes and train those staff accordingly. All trainings are expected to be completed by May 2025. o Person Responsible: Director of Corporate Compliance o Expected Date of Completion: May 15, 2025

View Audit 355894

Finding 559955 (2023-004)

Significant Deficiency 2023

Mental Health Association in Orange County, Inc.

NY

Special Tests & Provisions HUD Housing Programs Significant Deficiency

• Finding 2023-004 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: The utility calculation is updated annually ...

• Finding 2023-004 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: The utility calculation is updated annually by the Director of Corporate Compliance using the new tables provided by Pathstones which is received at the end of each year. This was implemented for 2024. The agency has developed, revised and implemented internal controls in the form of written program policies and procedures to ensure that the agency is in compliance with changes to regulatory requirements. Utility calculation is updated annually and verified by the Director of Corporate Compliance to reflect the current utility allowances within 30-days of publication. The Assistant Director of Housing and Care Coordination will notify all staff responsible for administering HUD programs of the policy changes and train those staff accordingly by May 2025. o Person Responsible: Director of Corporate Compliance o Expected Date of Completion: May 15, 2025

View Audit 355894

Finding 559954 (2023-003)

Significant Deficiency 2023

Mental Health Association in Orange County, Inc.

NY

Special Tests & Provisions HUD Housing Programs Significant Deficiency

• Finding 2023-003 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: MHA uses the official HUD COC Rent Determinat...

• Finding 2023-003 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: MHA uses the official HUD COC Rent Determination worksheets, as well as an external vendor (Affordable Housing Network) to establish that reasonable rents are charged for comparable apartments. Worksheets are now updated annually and verified by the Director of Corporate Compliance. The Assistant Director of Housing and Care Coordination will notify all staff responsible for administering HUD programs of the changes and train those staff accordingly. The external contract was established in mid-2024, and is still being used. o Person Responsible: Director of Corporate Compliance. o Date of Completion: June 10, 2024.

View Audit 355894

Finding 559945 (2023-007)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: Currently, the Authority is tracking all utility consumption for future OpFund application.Proposed Completion Date: Immediately

View Audit 355868

Finding 559942 (2023-004)

Material Weakness 2023

Kings Mountain Housing Authority

NC

HUD Housing Programs Internal Control / Segregation of Duties

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: A budget for FYE 9/30/25 was approved by the Board in their October 2024 meeting.Proposed Completion Date: Immediately

View Audit 355868

Finding 559941 (2023-003)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KMHA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for deposits and bank reconciliations to ensure proper accountability. Bank ...

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KMHA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for deposits and bank reconciliations to ensure proper accountability. Bank statements will be provided directly to the Fee Accountant monthly. The reconciliation of all bank accounts in a timely manner is a key component of good controls over cash. The reconciliation of the bank balance with the book balance (i.e., general ledger) is necessary to ensure that:All receipts and disbursements are recorded, which is an essential process for ensuring complete and accurate monthly financial statements;Checks are clearing the bank in a reasonable timeframe;Items reconciled are appropriate and are being recorded;Fraudulent claims can be discovered and investigated; andReconciled cash balance agrees to the general ledger cash balance.Each bank account will be reconciled by the fee accountant returned.This documentation will be made available to the Authority’s auditorProposed Completion Date: Immediately

View Audit 355868

Finding 559940 (2023-002)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: Internal actions have been taken to prevent this from happening again.Proposed Completion Date: Immediately

View Audit 355868

Finding 559681 (2023-001)

Material Weakness 2023

Muslim Youth for Positive Impact

CO

Reporting Internal Control / Segregation of Duties

Management acknowledges that adjustments to deferred revenue, receivables, and revenue were required.

View Audit 355577

Finding 559265 (2023-002)

Significant Deficiency 2023

Oklahoma City Innovation District, Inc.

OK

Eligibility Reporting Matching / Level of Effort / Earmarking § 200.512

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays e...

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays earlier in the audit process. Action Taken: Management agrees with the finding and will take steps to improve the timeliness of the audit process. Anticipated completion date: June 30, 2025 Name of contact person and title: Jeffrey Seymour, President / CEO

View Audit 355490

Finding 559162 (2023-002)

Material Weakness 2023

Hamilton County Hospital District

TX

Reporting Internal Control / Segregation of Duties

orrective Action Plan for Finding 2023-002 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to e...

orrective Action Plan for Finding 2023-002 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to ensure reports are prepared using complete and accurate information. We will increase compensating controls for introducing additional oversight and review for future COVID-19 Provider Relief Fund reporting. Tammy Schreiber, CFO, will be responsible to ensure this is accomplished. The District had enough lost revenues during Period 4 that the error determined in Finding 2023-002 will not result in a conflict with funding received. The Corrective Action Plan will be implemented by September 30, 2025.

View Audit 355389

Corrective Action Plans

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