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Finding 499523 (2023-001)
Significant Deficiency 2023
1. Explanation of Disagreements with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The finance department will establish policies and procedures to ensure reports are reviewed appropriately. 3. Official Responsible for Ensuring CAP: Debra ...
1. Explanation of Disagreements with Audit Finding: There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding: The finance department will establish policies and procedures to ensure reports are reviewed appropriately. 3. Official Responsible for Ensuring CAP: Debra Olsen, Finance Director, is the official responsible for ensuring corrective action of the deficiency. 4. Planned Completion Date for CAP: December 31, 2024. 5. Plan to Monitor Completion of CAP: The Council will be monitoring this corrective action plan. Sincerely, Debra Olsen Finance Director
View of Responsible Official: On September 25, 2024, we notified AmeriCorps of this finding and are seeking concurrence from the AmeriCorps SCP Advisory Council for our programs. Finding resolved timeline: October 15, 2024. Designated of employee position responsible for meeting this deadline: Bruce...
View of Responsible Official: On September 25, 2024, we notified AmeriCorps of this finding and are seeking concurrence from the AmeriCorps SCP Advisory Council for our programs. Finding resolved timeline: October 15, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, president and Authorized Representative.
View of Responsible Official: We have undertaken additional training and review of regulations in this area to assure compliance. Finding resolved timeline: December 1, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President and program Authoriz...
View of Responsible Official: We have undertaken additional training and review of regulations in this area to assure compliance. Finding resolved timeline: December 1, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President and program Authorized Representative
View Audit 322381 Questioned Costs: $1
FINDING 2023-002 Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2022 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Material Weakness, Modifie...
FINDING 2023-002 Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2022 Pass-Through Entity: N/A Compliance Requirements: Reporting Audit Findings: Material Weakness, Modified Opinion Condition: The City had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties that would likely be effective in preventing, or detecting and correcting, noncompliance. Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the Department of Treasury (Treasury). The reporting periods, as well as the respective due dates, are based upon type of recipient and its population, as well as the recipient's allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The City was classified as a metropolitan city with a population below 250,000 residents that received an allocation of less than $10 million in Coronavirus State and Local Fiscal Recovery Funds (CSLFRF). As, annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. Context: The City submitted one P&E report during the audit period; however, a single employee prepared and submitted the P&E report without a review or oversight process in place to prevent, or detect and correct errors. In addition, the P&E report was not properly supported by the City’s records. All but $100,000 of the expenditures were reported under the Eligible Use Category of “Administrative Expenses.” However, the City’s expenditures during the audit period consisted of assistance to business and households, sewer infrastructure, and tourism support, none of which qualified as Administrative Expenses. Furthermore, the City reported that it was electing to take the Revenue Loss Standard Allowance, but the amount reported as Revenue Loss was $0. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City of Crawfordsville management will follow the following process. 1. Before processing request from designated organizations the Clerk Treasurer and Mayor or a designated person, will review documentation and approve for payment/claim processing. 2. After approval a claim will be submitted to the Clerk Treasurer office for payment. 3. Clerk Treasurer will prepare and submit monthly expenditure report to the Mayor or designated person. 4. Annually before the Clerk Treasurer, reports to the U.S. Treasury expenditures the Clerk Treasurer and Mayor, or designated person, will review and confirm expenditures. 5. Clerk Treasurer will submit report to U.S. Treasury following prompts. 6. Clerk Treasurer will notify Mayor of the annual report submission. Responsible Party and Timeline for Completion: Clerk Treasurer and the submission that takes place in 2024 (2023 report).
Recommendation: The Authority should review and enhance its internal controls to ensure every timesheet is reviewed and approved by the hourly employee's supervisor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ...
Recommendation: The Authority should review and enhance its internal controls to ensure every timesheet is reviewed and approved by the hourly employee's supervisor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will review and enhance our policies and procedures over payroll processing, to ensure all timesheets have visual approval by supervisor, and employee files obtain copy of the annual board approved salary worksheet. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2024
Recommendation: The Authority should review and enhance its internal controls to ensure: · the utility allowance schedules are reviewed and updated as necessary at least annually; and units are inspected annually under HQS. Explanation of disagreement with audit finding: There is no disagreement wit...
Recommendation: The Authority should review and enhance its internal controls to ensure: · the utility allowance schedules are reviewed and updated as necessary at least annually; and units are inspected annually under HQS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority specialist responsible for file maintenance and recertifications during fiscal year 2022 and early 2023 is no longer with the Agency. The Authority has experienced staff now in place to perform these services. The Authority will revisit our policy and procedures over recertification, HQS, and file maintenance to ensure documentation is maintained and is in compliance with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2024
Recommendation: The Authority should review and enhance its internal controls to ensure: . management obtains and reviews documentation supporting United States of America citizenship; . tenants provide release forms prior to obtaining necessary documentation; . management verifies income listed on ...
Recommendation: The Authority should review and enhance its internal controls to ensure: . management obtains and reviews documentation supporting United States of America citizenship; . tenants provide release forms prior to obtaining necessary documentation; . management verifies income listed on the HUD Form 50058; and recertifications are consistently reviewed and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority specialist responsible for file maintenance and recertifications during fiscal year 2022 and early 2023 is no longer with the Agency. The Authority has experienced staff now in place to perform these services. The Authority will revisit our policy and procedures over recertification and file maintenance to ensure documentation is maintained and is in compliance with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2024
Condition - Evidence of certain payroll expenses transactions under the United States Department of Homeland Security program was not maintained by management. Recommendation -We recommend that management review procedures and change as necessary to ensure evidence is maintained to support the payro...
Condition - Evidence of certain payroll expenses transactions under the United States Department of Homeland Security program was not maintained by management. Recommendation -We recommend that management review procedures and change as necessary to ensure evidence is maintained to support the payroll expense transactions. Views of Responsible Officials and Planned Corrective Actions - Management understands and agrees with this finding. Management noted this was due to the payroll software conversion and the timing of the federal award. Policies are being reviewed and new procedures put in place as needed to ensure documentation of proper compliance. Anticipated Date of Completion - In progress. Action Taken -We have reviewed the recommendations and will be discussing potential improvements in the near future. Person Responsible for Corrective Action Plan - Colette Martin, Chief Financial Officer.
Condition - The District has internal control weaknesses with respect to segregation of duties over cash receipts and disbursements. Recommendation -We recommend that the District implement procedures to mitigate its segregation of duty weaknesses as much as possible including review processes by th...
Condition - The District has internal control weaknesses with respect to segregation of duties over cash receipts and disbursements. Recommendation -We recommend that the District implement procedures to mitigate its segregation of duty weaknesses as much as possible including review processes by the Chief Executive Officer and/or Chief Financial Officer. Views of Responsible Officials and Planned Corrective Actions - Management agrees with the finding and will consider controls such as review processes that will mitigate its segregation of duty weaknesses. Anticipated Date of Completion - In progress. Action Taken -We have reviewed the recommendations and will be discussing potential control improvements in the near future. Person Responsible for Corrective Action Plan - Colette Martin, Chief Financial Officer.
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanat...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanat...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanat...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanat...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanat...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024
2023-003 Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria....
2023-003 Housing Choice Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend that the Authority review its system of internal control related to the policies and procedures in place to mitigate the risk of noncompliance with the requirements of the stated criteria. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director Planned completion date for corrective action plan: 12/31/2024
U.S. Department of Housing and Urban Development 2023-002 Housing Choice Voucher Cluster – All Programs Recommendation: We recommend that the Authority’s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Explanation of disagr...
U.S. Department of Housing and Urban Development 2023-002 Housing Choice Voucher Cluster – All Programs Recommendation: We recommend that the Authority’s management reviews the accounting information which is the best means of preventing and detecting errors and irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In order to remedy and mitigate audit findings that have been building over the past several years, PHA has moved to a task-based model, and have begun using production trackers for transparency. After a program management staffing change in March 2024, PHA is now pulling SEMAP reports monthly and conducting internal file audits to monitor program compliance. Name(s) of the contact person(s) responsible for corrective action: Deborah Madsen, Executive Director
FINDING 2023-003 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jessica Thome, Controller Contact Phone Number and Email Address: (812) 244-2360 and Jessica.thome...
FINDING 2023-003 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Jessica Thome, Controller Contact Phone Number and Email Address: (812) 244-2360 and Jessica.thome@terrehaute.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have utilized an outside consulting service to assist in the reconciliation of expenditures. Quarterly P&E Reports will be completed by the Controller and reviewed and approved by the Mayor. Anticipated Completion Date: Qtr3 P&E report required by end of Oct 2024
CORRECTIVE ACTION PLAN FOR THE YEAR ENDED SEPTEMBER 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the audi...
CORRECTIVE ACTION PLAN FOR THE YEAR ENDED SEPTEMBER 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended September 30, 2023. Finding 2023-001 Responsible Party Name: Peggy Scott Position: Manager Telephone Number: (660) 339-7235 Federal Agency U.S. Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities – Section 811 Compliance Requirements N- Special Tests and Provisions Findings Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditors’ finding. Corrective Action We will follows our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date July 31, 2024
Effective Jan 2024 ACHD too corrective action for lack of time sheets on federal grants to ensure that all time is officially being tracked by a time sheet instead of a percentage-based mechanism Additionally, while ACHD indicates that expenses were reported accurately and timely to the funder, we w...
Effective Jan 2024 ACHD too corrective action for lack of time sheets on federal grants to ensure that all time is officially being tracked by a time sheet instead of a percentage-based mechanism Additionally, while ACHD indicates that expenses were reported accurately and timely to the funder, we will ensure that all costs are recorded in the appropriate job numbers for the respective periods in a timely manner.
We review each invoice monthly as they are submitted. Most of the review is insuring the items being invoiced are eligible under HUD and making sure the amounts are added correctly. We will review more closely the match submitted. Match for HUD is now reported based on the entire funding and not by ...
We review each invoice monthly as they are submitted. Most of the review is insuring the items being invoiced are eligible under HUD and making sure the amounts are added correctly. We will review more closely the match submitted. Match for HUD is now reported based on the entire funding and not by individual grants. All match from all HUD programs is added together and submitted on one final report at the end of each funding year. The requirement is 25% on all budget lines except for Leasing. However, if one program’s match is short of the 25% requirement, the overall CoC is responsible for the full match so additional DHS admin costs are used to represent the additional match needed. For our FY22-23 annual report to HUD, we submitted 30.47% in match for the overall funding. This amount did not include any additional HMIS (data system) costs, Allegheny Link (our coordinated entry system) costs or additional DHS admin costs. With these additional eligible activities, our matching amount could have been over 50%. Therefore, even if some identified items were considered ineligible our match would not be in jeopardy since we have a lot of eligible costs that DHS covers that would be considered match.
View Audit 322276 Questioned Costs: $1
Recommendation – We recommend the Center provide proper training to employees to ensure that the sliding fee discounts are being properly applied and documented. In addition to implementing policies and procedures to ensure the sliding fee discounts are being properly monitored and supervised on a ...
Recommendation – We recommend the Center provide proper training to employees to ensure that the sliding fee discounts are being properly applied and documented. In addition to implementing policies and procedures to ensure the sliding fee discounts are being properly monitored and supervised on a periodic basis to ensure compliance. Action Taken – We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. Additional staff training on slide fee discounts is in place and monthly review and testing of compliance with Center sliding fee discount policy is ongoing.
The Garden is in the process of reviewing its policy surrounding the review process for federal expenditures. The Garden will be implementing an approval process for all expenses on credit cards and other federal charges. Accounting will only charge the expense to the grants once it has verified t...
The Garden is in the process of reviewing its policy surrounding the review process for federal expenditures. The Garden will be implementing an approval process for all expenses on credit cards and other federal charges. Accounting will only charge the expense to the grants once it has verified the expense has gone through the proper approval channels.
Medical Assistance Program – Assistance Listing No. 93.778 Wisconsin Medicaid Cost Reporting (WIMCR) – State ID N/A Recommendation: CLA recommends the County develop and implement a process to require formal review and approval of the WIMCR reports prior to the submission of the report to the stat...
Medical Assistance Program – Assistance Listing No. 93.778 Wisconsin Medicaid Cost Reporting (WIMCR) – State ID N/A Recommendation: CLA recommends the County develop and implement a process to require formal review and approval of the WIMCR reports prior to the submission of the report to the state to help ensure that the data reported are accurate and complete. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Upon the prior year finding 2022-001, staff implemented the County’s existing review and approval process for grants administration for WIMCR program reporting effective September 27, 2023. However, the WIMCR report reviewed was submitted on August 5, 2023, prior to the corrective action. Name(s) of the contact person(s) responsible for corrective action: Jennifer Jossie Planned completion date for corrective action plan: September 27, 2023
FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as we...
FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Recipients are required to submit quarterly or annually Project and Expenditure (P&E) reports to the U.S. Department of the Treasury (Treasury). The reporting periods, as well as the respective due dates, are based on the type of recipient and the recipient’s population, as well as the recipient’s allocation amount. Information to be reported includes projects funded, expenditures, and contracts for the appropriate reporting period. The County was classified as a metropolitan county with a population below 250,000 residents that received an allocation of less than $10 million in State and Local Fiscal Recovery Funds. As such, the initial P&E report, covering the period from March 3, 2021 to March 31, 2022, was required to be submitted to the Treasury by April 30, 2022. The subsequent annual reports are to cover one calendar year and must be submitted to the Treasury by April 30 each year. The County submitted one P&E report during the audit period, which was obtained from the Treasury's website. Although one employee prepared the P&E report and another reviewed the entries, the system of internal controls was not effective in preventing, detecting, or correcting errors. The data submitted included amounts which should not have been included and amounts which were not supported by the County’s records. Errors identified included the following: • Total Cumulative Obligations were overstated by $907,630. • Total Cumulative Expenditures were overstated by $4,332,524. The lack of effective internal controls and noncompliance were isolated to the P&E Report submitted during the audit period. Contact Person Responsible for Corrective Action: Britt Ostler Contact Phone Number and Email Address: (765) 659-6330 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: INDIANA STATE BOARD OF ACCOUNTS 29 The County received guidance from a consultant in regards to reporting the SLFRF. The consultant had advised “if the County planned to spend $5M, then the total cumulative “obligations” would be $5M. Per review of the SBOA, two figures in the 2023 P&E Report were miscalculated: Cumulative Obligations and Cumulative Expenditures. The Cumulative Obligations reported should be the amount contracted for the project plus any change orders. The Cumulative Expenditures should be the amount expended in prior years, if any, plus the amount expended until March 31st of the year the P&E Report is dated. The current period for the 2023 P&E Report covered April 1, 2022 to March 31, 2023. Future P&E Reports submitted for this grant will use this understanding of Cumulative Obligations and Cumulative Expenditures and will be prepared by the County Auditor and reviewed by a second individual prior to submission. Anticipated Completion Date: April 1, 2025
Finding 2023-001- Special Tests Contact Person: William Bane Management Response: Management acknowledges that there were not sufficient controls in place prior to September 28, 2023, to ensure written consent from HUD prior to incurring new debt or lease arrangements. The three lease arrangements i...
Finding 2023-001- Special Tests Contact Person: William Bane Management Response: Management acknowledges that there were not sufficient controls in place prior to September 28, 2023, to ensure written consent from HUD prior to incurring new debt or lease arrangements. The three lease arrangements in question were all entered prior to the controls put in place on September 28, 2023. Current Management had previously established effective controls to ensure written consent is obtained prior to incurring any new debt or lease arrangements.
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