Corrective Action Plans

Finding 508444 (2023-007)

Significant Deficiency 2023

MD

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Significant Deficiency and Noncompliance over Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of Augu...

Significant Deficiency and Noncompliance over Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients’ information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. Prior to the completion of the SEFA, the City instituted training sessions with the agencies to ensure that the reporting is understood by the agencies, with special emphasis on subrecipient payments being reported properly. Additionally, the City will give access to the grant report upon which the SEFA is based. The City will keep a check list to ensure that all agencies respond to the grant certification to ensure that all agencies review the grant data. Based on FY 23 training and feedback the City is expanding that training schedule to begin with agency preparation in November 2024. Additionally, the corrective actions for grants have included citywide trainings in the fourth quarter FY24 led by the Grants Management Office and BAPS on key grant accounting functions in Workday; including for example, Billing, Creating an Award, Sub Recipients with each training having between 50-70 agency grant staff attending. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: December 2024

View Audit 329082

Finding 508428 (2023-005)

Material Weakness 2023

Town of Livermore Falls

ME

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

CORRECTIVE ACTION PLAN (Concerning Finding 2023-005) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-005 The current Town Manager was appointed by...

CORRECTIVE ACTION PLAN (Concerning Finding 2023-005) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-005 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and us using the new Internal Controls Policy that addresses this deficiency. Additionally, Department Heads are required to turn in no later than Thursday by 9 am, invoices to be paid on that week’s warrant. The Treasurer has been given authority by the Town Manager to contact Department Heads and request that they come to the office weekly to turn in invoices. All invoices must have the appropriate expense code and be signed by the Department Head. Anticipated Completion Date: This was completed January 23, 2024.

View Audit 329052

Finding 508418 (2023-001)

Significant Deficiency 2023

Fremont County Association of Governments

WY

Internal Control / Segregation of Duties Significant Deficiency

FINDING 2023-001: SEGREGATION OF DUTIES Classes of financial transactions have been segregated to the extent possible among the existing employees. However, because of the limited number of employees involved in the accounting and bookkeeping functions, a corrective action plan to remedy the lack of...

FINDING 2023-001: SEGREGATION OF DUTIES Classes of financial transactions have been segregated to the extent possible among the existing employees. However, because of the limited number of employees involved in the accounting and bookkeeping functions, a corrective action plan to remedy the lack of segregation of duties is not cost justified. Rather, each level of management, the Board of Directors and Administrator, are aware of the concept of "segregation of duties" and are also aware of potential problems that may occur when accounting and bookkeeping duties cannot be segregated. Because there is awareness, each level of management is charged with the responsibility to follow-up on any circumstances or transactions that they perceive to be unusual. Contact person: Tim Nichols Anticipated completion date: Unknown

View Audit 329047

Finding 508412 (2023-002)

Material Weakness 2023

East Union Community School District

IA

Internal Control / Segregation of Duties

Due to the limited number of office staff, achieving complete segregation of duties presents challenges. However, the District has carefully reviewed and strengthened its control procedures to ensure the highest level of internal control feasible under these circumstances.

View Audit 329035

Finding 508407 (2023-002)

Material Weakness 2023

Sanilac County Community Mental Health Authority

MI

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.431

Condition: Accrued PTO time was adjusted as of September 30, 2023, however certain employees were transferred over to the grant program that had accrued PTO as of September 30, 2022 that was not taken into account. As a result, the grant was charged PTO time for amounts that had been accrued in prio...

Condition: Accrued PTO time was adjusted as of September 30, 2023, however certain employees were transferred over to the grant program that had accrued PTO as of September 30, 2022 that was not taken into account. As a result, the grant was charged PTO time for amounts that had been accrued in prior years in other programs and activities. Recommendation: Schedule should be revised to take into account the PTO time employees have prior to being transferred into the grant activities Planned Corrective Action: A new schedule has been created that will calculate only the increase in PTO cost year over year per individual and used to accrue PTO cost at year end. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

View Audit 329033 Questioned Costs: $1

Finding 508404 (2023-002)

Material Weakness 2023

Newport Borough Water Authority

PA

Material Weakness Reporting Internal Control / Segregation of Duties

The Authority did not realize quarterly reports were required and was never asked by USDA for these. USDA was contacted and the Authority has been informed that a quarterly Balance Sheet and Profit and Loss Statement will fulfill this requirement. The past due reports will be sent to USDA this mon...

The Authority did not realize quarterly reports were required and was never asked by USDA for these. USDA was contacted and the Authority has been informed that a quarterly Balance Sheet and Profit and Loss Statement will fulfill this requirement. The past due reports will be sent to USDA this month and going forward, quarterly reports will be forwarded to USDA within 30 days of the end of each quarter.

View Audit 329026

Finding 508392 (2023-002)

Significant Deficiency 2023

Think of US

DC

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

Views of Responsible Officials: In 2024, Think of Us took steps to address this issue by appointing new executive leadership, including a President and Fractional CFO and engaging a proven accounting firm with demonstrated expertise in nonprofit accounting.

View Audit 329011

Finding 508374 (2023-001)

Significant Deficiency 2023

Life Management, Inc.

NJ

Reporting Internal Control / Segregation of Duties

Corrective Action Plan • A full year calendar will be constructed, reminding Barbara Havlik, Eexecutive Director of Life Management, Inc., of the dates for which reports are due with regard to Federal Grant Agreements/Awards. The calendar will also have reminders; including: o A reminder will go ...

Corrective Action Plan • A full year calendar will be constructed, reminding Barbara Havlik, Eexecutive Director of Life Management, Inc., of the dates for which reports are due with regard to Federal Grant Agreements/Awards. The calendar will also have reminders; including: o A reminder will go out to RPM developer, Joe Portelli, three weeks prior to the report due date, so that a meeting can be set up within a week to review and prepare for report submission. o A copy of the report for submission will be reviewed by Barbara Havlik and Joe Portelli two days prior to the submission date, and both parties shall retain a copy of report to be submitted. • The report will be submitted on time by Joe Portelli, according to Federal Requirements, and Barbara Havlik will check with Joe Portelli to make certain that Federal Agency was in fact received the report.

View Audit 328982

Finding 508369 (2023-004)

Significant Deficiency 2023

Ford County, Kansas

KS

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking § 200.305

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine...

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Grantee Response: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

View Audit 328978

Finding 508305 (2023-001)

Significant Deficiency 2023

Chester County Conservation District

PA

Allowable Costs / Cost Principles Cash Management Reporting

2023-002: 2023-001 – Grant Project Payroll Tracking Reports Contact Person: Christian Strohmaier, cstrohmaier@chesco.org, 610-455-1370 Condition: Per review of the District’s internal payroll tracking reports, it was noted that while employees keep a detailed list of time worked each day, no specif...

2023-002: 2023-001 – Grant Project Payroll Tracking Reports Contact Person: Christian Strohmaier, cstrohmaier@chesco.org, 610-455-1370 Condition: Per review of the District’s internal payroll tracking reports, it was noted that while employees keep a detailed list of time worked each day, no specific documentation was maintained within the tracking reports of which projects relate to the ACAP grant program to support the hours being charged to the program each quarter. Corrective Action: Increased programmatic responsibilities make it necessary for all staff to accurately record their completed activities and the time spent upon them. Technical staff historically have reported this way, with activity stated, hours spent, and which program the activity relates to recorded. Each technical staff employe has an individual report maintained in Excel that is updated daily. This model will be used for administrative staff as well for their time spent in support of these programs. Proposed Completion Date: December 1, 2024

View Audit 328878

Finding 508289 (2023-002)

Significant Deficiency 2023

Black Family Development, Inc.

MI

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

The finding was due to a change in Key Personnel for a project director role that also included a decrease in the level of effort from 100% to 75% from the date of hire on 10/31/23 until 8/19/24. BFDI subsequently submitted a request for retroactive approval of this change on 10/28/2024. The Proje...

The finding was due to a change in Key Personnel for a project director role that also included a decrease in the level of effort from 100% to 75% from the date of hire on 10/31/23 until 8/19/24. BFDI subsequently submitted a request for retroactive approval of this change on 10/28/2024. The Project Director’s Level of Effort was increased to 100% as of 8/19/24.

View Audit 328838

Finding 508278 (2023-002)

Significant Deficiency 2023

Douglas County

MN

Eligibility Reporting Significant Deficiency § 200.303

Recommendation: It is recommended County management add an additional control review over the eligibility of casefile reviews. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will continue to designate a...

Recommendation: It is recommended County management add an additional control review over the eligibility of casefile reviews. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will continue to designate an internal reviewer to continually review the casefile eligibility determinations throughout the year. Name of the contact person responsible for corrective action plan: Jill Frisell, Finance Director Planned completion date for corrective action plan: December 31, 2024

View Audit 328814

Finding 508276 (2023-001)

Significant Deficiency 2023

Gloucester County Division of Social Services

NJ

Questioned Costs Eligibility Internal Control / Segregation of Duties

#1 - 1 case continued to receive monthly benefits during 2023 when records indicated that the case should have closed in 2022. Consolidated Report Listing FB021 will be reviewed by supervisor to ensure WFNJ cases are redetermined appropriately. #2 and #3 - 1 case was incorrectly coded as being exe...

#1 - 1 case continued to receive monthly benefits during 2023 when records indicated that the case should have closed in 2022. Consolidated Report Listing FB021 will be reviewed by supervisor to ensure WFNJ cases are redetermined appropriately. #2 and #3 - 1 case was incorrectly coded as being exempted from lifetime limit. 1 case was coded as being exempted from lifetime limit; however, the GCDSS cannot locate supporting documentation. Share Data Warehouse (SDW) ‘TANF and GA Clock’ report & SDW ‘WFNJ Clock’ report will be reviewed by supervisor to ensure correct exemption coding. #2 and #3 Staff will receive refresher DIMs case separator training. All clerical DIMs staff will receive refresher DIMs procedure and indexing training. In-house QC spot checks by Supervisors.

View Audit 328808 Questioned Costs: $1

Finding 508250 (2023-004)

Significant Deficiency 2023

U. S. Telecommunications Training Institute

DC

Procurement, Suspension & Debarment Significant Deficiency Matching / Level of Effort / Earmarking § 200.318

Views of Responsible Officials and Planned Corrective Actions: USTTI formalized a procurement policy be in compliance with 2 CFR 200 subsequent to December 31, 2023. USTTI management has distributed and communicated the policy with all USTTI employees. USTTI management will ensure the policy is prop...

Views of Responsible Officials and Planned Corrective Actions: USTTI formalized a procurement policy be in compliance with 2 CFR 200 subsequent to December 31, 2023. USTTI management has distributed and communicated the policy with all USTTI employees. USTTI management will ensure the policy is properly enforced and that all procurement actions are documents in writing in vendor and contractor files.

View Audit 328771

Finding 508206 (2023-001)

Material Weakness 2023

Young Women's Christian Association of Newburyport

MA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Pursuant to Standards for Internal Control in the Federal Government, Principle 16-Performing Monitoring Activities, management should monitor its internal control system through ongoing monitoring and separate evaluations including but not limited to comparisons, reconciliations and other routine a...

Pursuant to Standards for Internal Control in the Federal Government, Principle 16-Performing Monitoring Activities, management should monitor its internal control system through ongoing monitoring and separate evaluations including but not limited to comparisons, reconciliations and other routine actions. Young Women’s Christian Association of Newburyport, d/b/a YWCA Greater Newburyport, its Affiliate and Subsidiaries’ is in the process of developing internal control procedures over reconciliation and recognition of Federal funds. The person responsible for this periodic reconciliation of Federal funds will indicate their review keeping documentation of their analysis on file with the accounting office. John Feehan, Executive Director, is responsible for implementing this corrective action plan.

View Audit 328674

Finding 508045 (2023-003)

None 2023

Town of Clinton

MA

Subrecipient Monitoring Period of Performance Reporting § 200.344

2023-003: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout proced...

2023-003: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures have been updated in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds)

View Audit 328582

Finding 508041 (2023-002)

Significant Deficiency 2023

Town of Clinton

MA

Cash Management School Nutrition Programs Significant Deficiency

2023-002: Significant Deficiency in Internal Controls and Compliance Finding -Child Nutrition Cluster ALN (10.553, 10.555,10.559): The District’s school lunch office-maintained production records and manual count sheets for the elementary school and high school instead of using the point-of-sale sys...

2023-002: Significant Deficiency in Internal Controls and Compliance Finding -Child Nutrition Cluster ALN (10.553, 10.555,10.559): The District’s school lunch office-maintained production records and manual count sheets for the elementary school and high school instead of using the point-of-sale system for tracking student meal counts. (Questioned Costs: None) The Town of Clinton/School Department will utilize and maintain the point-of-sale system consistently in all district school buildings to track student meals counts. Already implemented at the start of FY25 school year.

View Audit 328582

Finding 508034 (2023-005)

Material Weakness 2023

Fredonia-Moccasin Unified School District No. 6

AZ

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Material Weakness

2023-005 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS / COST PRINCIPALS Program: Education Stabilization Fund – ESSER II and ESSER III Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21...

2023-005 ACTIVITIES ALLOWED OR UNALLOWED AND ALLOWABLE COSTS / COST PRINCIPALS Program: Education Stabilization Fund – ESSER II and ESSER III Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111175-01A and 21FESIII-111175-01A Questioned Costs: None Type of Finding: Material weakness in internal controls Compliance Requirement: A. Activities Allowed or Unallowed; B. Allowable Costs / Cost Principals Condition/Context: For one of three payroll related journal entries tested for the Education Stabilization Fund program, the District did not have documentation supporting that the entry was reviewed and approved by an individual separate from the preparer. Corrective Action: The District will review its process for preparing and recording journal entries to include a step to have the entries reviewed and approved by someone other than the preparer. In addition, the journal entries will include supporting schedules and documentation to explain why the entry is being prepared. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Dorene Mudrow, Superintendent

View Audit 328565

Finding 508033 (2023-004)

Material Weakness 2023

Fredonia-Moccasin Unified School District No. 6

AZ

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

2023-004 ACTIVITIES ALLOWED OR UNALLOWED Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111175-01A and 21FESIII-111175-01A Questioned Costs: $13...

2023-004 ACTIVITIES ALLOWED OR UNALLOWED Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111175-01A and 21FESIII-111175-01A Questioned Costs: $133,105 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: A. Activities Allowed or Unallowed Condition/Context: During our testing of expenditures, it was noted that eleven expenditures with a total of $133,105 were not included within the Education Stabilization Fund budget as approved by the Arizona Department of Education. Corrective Action: The District will ensure all expenditures are approved by the SEA before purchase. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Dorene Mudrow, Superintendent

View Audit 328565 Questioned Costs: $1

Finding 508032 (2023-006)

Material Weakness 2023

Dakota Rural Water District

ND

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.318 § 200.326

Environmental Protection Agency, passed through State of North Dakota Department of Environmental Quality Federal Financial Assistance Listing 66.468 Capitalization Grants for Drinking Water Procurement, Suspension, Debarment Material Weakness in Internal Control Over Compliance Finding Summary: The...

Environmental Protection Agency, passed through State of North Dakota Department of Environmental Quality Federal Financial Assistance Listing 66.468 Capitalization Grants for Drinking Water Procurement, Suspension, Debarment Material Weakness in Internal Control Over Compliance Finding Summary: The District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Responsible Individuals: General Manager (Vacant) and Jan Lee, Office Manager Corrective Action Plan: The District will review the applicable 2 CFR 200 sections and implement procedures necessary to ensure compliance with all of these requirements Anticipated Completion: December 31, 2024

View Audit 328549

Finding 507805 (2023-003)

Significant Deficiency 2023

Tazewell County, Illinois

IL

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Management will ensure that all grant reports submitted to federal agencies are reviewed and approved by the Tazewell County manager overseeing the grant prior to submission. The County will review and approve all necessary supporting documents including certified payrolls to verify compliance with ...

Management will ensure that all grant reports submitted to federal agencies are reviewed and approved by the Tazewell County manager overseeing the grant prior to submission. The County will review and approve all necessary supporting documents including certified payrolls to verify compliance with federal reporting requirements and guidelines. When outside consultants are engaged to aid in grant administration, the appropriate Tazewell County manager will be responsible for reviewing and approving all required reporting and supporting documentation prepared on the County’s behalf.

View Audit 328308

Finding 507058 (2023-014)

Significant Deficiency 2023

The Howard University

DC

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR ...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025 Anticipated Completion Date: December 31, 2024

View Audit 328267 Questioned Costs: $1

Finding 507052 (2023-013)

Significant Deficiency 2023

The Howard University

DC

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporti...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024. Anticipated Completion Date: December 31, 2024

View Audit 328267

Finding 506686 (2023-012)

Significant Deficiency 2023

The Howard University

DC

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

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts and Warren Petty, Chief Human Resource Officer Corrective Action: The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts and Warren Petty, Chief Human Resource Officer Corrective Action: The certificates listed in the finding were untimely because the employees’ costing allocations were not entered into the system timely. As a result, their earnings were not allocated to grants when the certification process was run, and the employees did not receive their certificates. The employees did receive certificates once costing allocations were updated and the labor cost transfer requests were submitted. The following corrective actions have been put in place to address this finding. A task force led by Human Resources and Grants and Contracts is reviewing the employee cost allocation process with a focus on improving timeliness and accuracy. Employee cost allocations dictate how earnings are to be allocated between internal departmental codes and sponsored projects. Cost allocations directly impact effort certifications in addition to billing and reporting, and they are imperative for resolving this finding. Committee meetings occur bi-weekly to resolve concerns relating to the cost allocation process and to discuss additional business process updates/ changes as necessary. Cost center managers and other employees responsible for submitting costing allocations will receive additional training on how the costing allocations must be entered into Workday and on the importance of timely submissions. Updates to the effort certification business process were tested and migrated to the production environment as of July 1, 2023. The updates expand the pool of secondary approvers by adding Principal Investigators to the process. Anticipated Completion Date: June 30, 2025

View Audit 328267

Finding 506325 (2023-011)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from f...

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. Action Steps: 1. Communication a. Create Current Researcher Email List Serv for distribution of information/reminders. b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements. c. We will distribute information regarding this finding to our researchers every quarter via the listserv. d. Completion: The first distribution will occur on October 1, 2024 2. Develop Training Materials a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications. b. Include examples of compliant and non-compliant publications. c. Completion: Second Quarter of FY 2025 3. Campus-Wide Training a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method. b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project. c. Completion: Second Quarter of FY 2025 4. Award Specific Training a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings. 5. Ongoing Monitoring and Compliance a. Maintain records of all training attendance. b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications. c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements. d. Non-compliant Faculty will not be able to submit proposals if training is delinquent. Anticipated Completion Date: June 30, 2025

View Audit 328267

Corrective Action Plans

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