Corrective Action Plans

Finding 513385 (2023-002)

None 2023

Stoneboro Development Corporation 033-11048

PA

Procurement, Suspension & Debarment HUD Housing Programs Reporting § 200.512

Stoneboro Development Corporation Stoneboro, Pennsylvania November 18, 2024 U.S. Department of Housing and Urban Development City Crescent Building 10 South Howard Street Baltimore, Maryland 21201-2505 Stoneboro Development Corporation respectfully submits the f...

Stoneboro Development Corporation Stoneboro, Pennsylvania November 18, 2024 U.S. Department of Housing and Urban Development City Crescent Building 10 South Howard Street Baltimore, Maryland 21201-2505 Stoneboro Development Corporation respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended June 30, 2023 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2023-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely payment of the mortgage payments and escrow deposits. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Additionally, the new management company is working with the lender to make additional mortgage payments and escrow deposits as cash flow permits. Finding 2023-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reported package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. Finding 2023-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due dates. Action Taken: We agree with Finding 2023-003 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure the annual financial reports to HUD are submitted once the audits are back on track with the scheduled due dates. Finding 2023-004: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management and the board of directors work to improve occupancy and submit special claims requests to HUD for vacant units to improve cash flow to ensure timely monthly deposits to the replacement reserve account are made as required. Action Taken: We agree with Finding 2023-004 described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company is increasing advertising to fill vacancies and submitting special claims requests to improve the cash flow. Finding 2023-005: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all disbursements from project operations. Action Taken: We agree with Finding 2023-005 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all disbursements from project operations. Finding 2023-006: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Market Interest Rate, Assistance Listing #14.155 Recommendation: We recommend that management ensure supporting documentation is maintained for all cash receipts of the project. Action Taken: We agree with Finding 2023-006 and the recommendation described in the accompanying schedule of findings and questioned costs. Effective June 1, 2023, the board of directors contracted with a new management company. The new management company will ensure supporting documentation is maintained for all cash receipts of the project. If HUD has questions regarding this corrective action plan, please call (412) 246-9213. Sincerely yours, Trisha Jester Director of Multifamily Housing Arbors Management, Inc. Managing Agent

View Audit 331232

Finding 513381 (2023-001)

Material Weakness 2023

New Jersey City University

NJ

Student Financial Aid Material Weakness Reporting

The University agrees with the finding and acknowledges the finding was also reported in the previous fiscal year. Despite high staff turnover, the Director of the Financial Aid Office and in collaboration with the Controller’s Office the issue is being addressed for any future reporting.

View Audit 331221

Finding 513379 (2023-003)

Material Weakness 2023

New Jersey City University

NJ

Student Financial Aid Subrecipient Monitoring Cash Management

The University agrees with the finding. The University has had a significant amount of staff turnover and reorganization in FY 2023 in the financial aid office. The Interim Director of Financial Aid is collaborating with the controller’s office to make sure that the University has internal controls ...

The University agrees with the finding. The University has had a significant amount of staff turnover and reorganization in FY 2023 in the financial aid office. The Interim Director of Financial Aid is collaborating with the controller’s office to make sure that the University has internal controls in place over Federal programs to assure that the Pell reporting requirements are executed in compliance with Federal statutes, regulation and terms and conditions of the federal award. The University is investing in making sure that the Financial Aid Office is staffed and create policy and procedure that assure that we improve internal controls on the Pell process.

View Audit 331221

Finding 513371 (2023-006)

Material Weakness 2023

Catholic Charities of the Diocese of Camden

NJ

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

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Homeland Security Passed through Cumberland Co...

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Homeland Security Passed through Cumberland County: Grant No. 39 5962 00 Grant No. ARPA R 5962 00 Emergency Food and Shelter National Board Program AL# 97.024 11/2021 12/2023 11/2021 12/2023 Passed through Salem County Board of Social Services Grant No. ARPA R 6028 00 11/2021 12/2023 Passed through Atlantic County Grant No. 39 5948 00 Grant No. ARPA R 5948 00 Passed through Cape May County Grant No. ARPA R 5960 00 Grant No. 39 5960 00 11/2021 12/2023 11/2021 12/2023 11/2021 12/2023 11/2021 4/2023 2023-006 -Activities Allowed and Allowable Costs (Significant Deficiency) Statement of Condition Supportive service expenditures were processed and paid for ineligible participants. Criteria Emergency Food and Shelter National Board Program (EFSP) funds may be used for food and related expenses (such as transporting food/food preparation and serving equipment); mass shelter; other shelter (such as hotels and motels); and rent/mortgage and/or utility assistance limited to one month. Cause Due to lack of supervisory oversight, several employees falsified participant documents whereby ineligible individuals with personal relationships to these employees receive assistance payments. Effect Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Management also notified the State of New Jersey Department of Community Affairs Office of Auditing. ,roj"':::;: Charities USt\, www.catholiccharitiessouthjersey.org 1845 Haddon Avenue, Camden, NJ 08103 I "I'd: 856-342-4100 I Fax: 856-342-4180 Recommendation Management should strengthen controls over documentation required for participants to receive assistance payments along with controls over review of documentation in participant files and processing of these payments. View of Responsible Officials Management agrees with the recommendation and has begun implementing additional procedures to ensure that applicant files are complete and that case files and support are being reviewed by supervisory personnel. Corrective Action: The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: a W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. a Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc... o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. www.catholiccharitiessouthjersey.org 1845 Haddon Avenue, Camden, NJ 08103 I Tel: 856-342-4100 I Fax: 856-342-4180 Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above.

View Audit 331207

Finding 513361 (2023-005)

Material Weakness 2023

Catholic Charities of the Diocese of Camden

NJ

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

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Health and Human Services Temporary Assistance ...

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Health and Human Services Temporary Assistance for Needy Families (TANF) - AL #93.558 Passed through Camden County Health Department: Grant No. None Available 1/2022 12/2022 Grant No. None Available 1/2023 12/2023 Passed through Cumberland County Office on the Aging and Disabled Grant No. None Available 1/2022 12/2022 Grant No. None Available 1/2023 12/2023 Passed through Salem County Board of Social Services Grant No. None Available 1/2022 12/2022 Grant No. None Available Passed through Gloucester County 1/2023 12/2023 Grant No. None Available 1/2022 12/2022 Grant No. None Available 1/2023 12/2023 Passed through New Jersey Department of Human Services Division of Family Development Grant No. SF22009 10/2021 9/2022 Grant No. SF23009 10/2022 9/2023 2023-005 - Activities Allowed and Allowable Costs and Eligibility (Significant Deficiency) Statement of Condition Supportive service expenditures were processed and paid for ineligible participants. Criteria TANF funds monthly cash assistance payments to low-income families with children. The Homeless Veterans Comprehensive Service Programs Act of 1992 (Public Law 102-590) established the VA Homeless Providers Grant and Per Diem Program to fund the costs of creating or improving transitional supportive housing facilities or services centers, and grants to support case managers to assist Veterans in attaining or retaining permanent housing. Cause Due to lack of supervisory oversight, several employees falsified participant documents whereby ineligible individuals with personal relationships to these employees receive assistance payments. ,,o,s::::;: C:h.1riries USA. www.catholiccharitiessouthjersey.org 1845 Haddon Avcll1le, Camden, NJ 08103 I Td: 856-342-4100 I Fax: 856-342-4180 Effect Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Management also notified the State of New Jersey Department of Community Affairs Office of Auditing. Recommendation Management should strengthen controls over documentation required for participants to receive assistance payments along with controls over review of documentation in participant files and processing of these payments. View of Responsible Officials Management agrees with the recommendation and has begun implementing additional procedures to ensure that applicant files are complete and that case files and support are being reviewed by supervisory personnel. Corrective Action: The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc... o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. • Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. www.catholiccharitiessouthjersey.org 1845 Haddon Avenue, Camden, NJ 08103 I Td: 856-342-4100 I Fu.: 856-3424180 Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org stions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone ii address above.

View Audit 331207

Finding 513357 (2023-004)

Material Weakness 2023

Catholic Charities of the Diocese of Camden

NJ

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

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Veterans Affairs Direct Award: Grant No. 12 NJ...

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Veterans Affairs Direct Award: Grant No. 12 NJ 053 55 Grant No. 12 NJ 053 22 VA Homeless Providers Grant and Per Diem Program AL# 64.033 9/2021 9/2023 10/2021 3/2023 Grant No. 12 NJ 053 HL 9/2021 9/2023 Grant No. 12 NJ 053 LT 8/2022 9/2026 Grant No. 12 NJ 053 23 9/2021 9/2023 2023-004 - Activities Allowed and Allowable Costs (Significant Deficiency) Statement of Condition Supportive service expenditures were processed and paid for ineligible participants. Criteria The Homeless Veterans Comprehensive Service Programs Act of 1992 (Public Law 102 590) established the VA Homeless Providers Grant and Per Diem Program to fund the costs of creating or improving transitional supportive housing facilities or services centers, and grants to support case managers to assist Veterans in attaining or retaining permanent housing. Cause Due to lack of supervisory oversight, several employees falsified participant documents whereby ineligible individuals with personal relationships to these employees receive assistance payments. Effect Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Management also notified the State of New Jersey Department of Community Affairs Office of Auditing. Recommendation Management should strengthen controls over documentation required for participants to receive' assistance payments along with controls over review of documentation in participant files and processing of these payments. View of Responsible Officials Management agrees with the recommendation and has begun implementing additional procedures to ensure that applicant files are complete and that case files and support are being reviewed by supervisory personnel. Corrective Action: Theim.proper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc... o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in Febr·uary 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB. Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. Mandated the universal use of ETO Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above.

View Audit 331207

Finding 513354 (2023-003)

Material Weakness 2023

Catholic Charities of the Diocese of Camden

NJ

Questioned Costs Internal Control / Segregation of Duties Eligibility

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Housing and Urban Development Emergency Solutio...

Diocese of Camden Single Audit Corrective Action Plan For the Fiscal Year Ended June 30, 2023 Re-submitted: November 25, 2024 Wipfli LLP 1502 London Road, Suite 200 Duluth, MN 55812 Attn: Michelle Swoboda, CPA FEDERAL AWARD FINDING U.S. Department of Housing and Urban Development Emergency Solutions Grant Program AL# 14.231 Passed through State of New Jersey Department of Community Affairs: Grant No. 2019 02156 036106 8/2020 3/2023 Grant No. 2022 02156 0337 00 7/2021 7/2023 Grant No. 2022 02156 0339 00 4/2022 7/2023 Grant No. 2022 02156 0338 00 4/2022 9/2023 Grant No. 2022 02156 0052 08 12/2019 9/2023 Grant No. 2020 02156 0042 08 12/2019 9/2023 Grant No. 2020 02156 0042 04 12/2019 9/2023 Grant No. 2019 02156 0361OS 12/2018 9/2023 2023-003 - Activities Allowed and Allowable Costs (Significant Deficiency) Statement of Condition Supportive service expenditures were processed and paid for ineligible participants. Criteria ESG funds may be used for five program components: street outreach, emergency shelter, homelessness prevention, rapid re-housing assistance, and HMIS; as well as administrative activities. The five program components and the eligible activities that may be funded under each are set forth in 24 CFR 576.101 through 576.107. Cause Due to lack of supervisory oversight, several employees falsified participant documents whereby ineligible individuals with personal relationships to these employees receive assistance payments. Effect Management became aware of the improprieties and hired an independent forensic investigator. The forensic investigator identified improper disbursements to ineligible participants along with other disbursements that required further research, inconclusive, insufficient, unverified, and LLC discrepancy disbursements. Management also notified the State of New Jersey Department of Community Affairs Office of Auditing. Recommendation Management should strengthen controls over documentation required for participants to receive assistance payments along with controls over review of documentation in participant files and processing of these payments. www.catholiccharitiessouthjersey.org 1845 Haddon A\-enue, Camden, NJ 08103 I Tel: 856•342-4100 I Fu: 856---3424180 Serving si.,;: counties of Southern Nev,1Jersey: Atlantic, Camden, Cape May; Cumbedand, Gloucester & Salem View of Responsible Officials Management agrees with the recommendation and has begun implementing additional procedures to ensure that applicant files are complete and that case files and support are being reviewed by supervisory personnel. Corrective Action: The improper activity was identified in October 2023 and the following actions were subsequently taken: • Two caseworks and a supervisor were terminated. • The agency's Executive Director retired. • The agency's Controller was temporarily elevated to Interim Administrator, overseeing day-to-day operations and reviewing all agency disbursements. • The central accounting department revised the check processing procedures to ensure that the following documentation accompanied housing related check requests: o W-9 signed by the vendor o A signed Promissory Agreement from the client, landlord and caseworker if the agency is paying Rent/Sec Dep. o Proof of Ownership for the property (Deed, Tax bill, NJ Parcels website) documentation. The Proof of Ownership documentation must match the W-9. Management has taken steps to ensure that the rental properties for which assistance will be rendered are in fact owned by the landlord stated on the lease. o Copy of an executed rental lease. o Rent Ledger, or a letter from the Landlord on their letterhead detailing client past and overdue charges/payments. Should include dates, amounts, etc... o Proof of Hardship - case management notes detailing hardship are sufficient for the Accounting Dept, although not necessarily sufficient for the requirement of the grant. • Policy changes with regard to check distribution have been modified. All checks are mailed directly to the vendor/payee from the central accounting department. • Two supervisors replaced the one terminated supervisor in order to ease the amount of supervision duties tasked to one person. • A new Executive Director for the Organization was hired in February 2024. • Created and filled the position of Grants Compliance Specialist. This position is responsible to: o Review, revise and create, where needed, policies/procedures to ensure that 0MB Uniform Administrative Requirements are being considered and followed in the administering of all grant funding. o Responsible for regularly reviewing client files on a judgmental basis in order to ensure adherence to the agency's policies and procedures. Mandated the universal use of ETD Case Management Solution as the soul repository of client information, case notes with a link to electronic client documentation files on the agency network. This provides electronic access to client case files as well as an electronic audit trail. Projected Completion Date As mentioned, the actions note above have been implemented. Management and the Grant Compliance Specialist continue to review, modify and communicate policies/procedures with all case management staff. Contact Person Robert Waite, Controller 856-342-4186; robert.waite@camdendiocese.org If you have questions or concerns regarding this Plan, please reach out to Robert Waite, Controller using the phone number or email address above. Robert T Waite, Controller

View Audit 331207 Questioned Costs: $1

Finding 513339 (2023-002)

Material Weakness 2023

School Administrative Unit No. 16

NH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.430

The SAU Grant's Coordinator will be responsible for ensuring the annual grant certification form for salary employees is completed and maintained.

View Audit 331205

Finding 513261 (2023-003)

Significant Deficiency 2023

School Administrative Unit No. 16

NH

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

SAU16 has policy DAF in all the school districts, expect the SAU. We will ask the joint board to adopt policy DAF.

View Audit 331205

Finding 513243 (2023-001)

Significant Deficiency 2023

Boys and Girls Clubs of Toledo and the Toledo Newsboys Association

OH

Cash Management Internal Control / Segregation of Duties

Auditor Description of Condition and Effect. We selected a sample of disbursements that were charged to the grant. Of this sample, 5 out of 40 disbursements had questioned costs. Two disbursements had amounts submitted for reimbursement but no actual costs were incurred by the Organization. Another ...

Auditor Description of Condition and Effect. We selected a sample of disbursements that were charged to the grant. Of this sample, 5 out of 40 disbursements had questioned costs. Two disbursements had amounts submitted for reimbursement but no actual costs were incurred by the Organization. Another two disbursements included expenses for other clubs outside the grant agreement that was charged to the grant. The last disbursement was missing supporting documentation for the costs charged to the grant. As a result of this condition, the Organization did not fully comply with the requirements of the Uniform Guidance. Auditor Recommendation. We recommend that the Organization verify that costs submitted for reimbursement are valid and allowable expenses. Additionally, the Organization needs to properly allocate costs in accordance with the grant agreements. Corrective Action. Management concurs with the finding. The Organization will ensure valid and allowable expenses, including proper allocation of costs, are remitted through enhancement of the current review processes. Responsible Person. Stacy Holman, Chief Financial Officer. Anticipated Completion Date. December 31, 2024.

View Audit 331186

Finding 513084 (2023-003)

Material Weakness 2023

Allen County

IN

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

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the four required quarterly P&E reports and the annual Recovery Plan Performance Report during the audit period; however, a single employee prepared and...

FINDING 2023-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Summary of Finding: The County submitted the four required quarterly P&E reports and the annual Recovery Plan Performance Report during the audit period; however, a single employee prepared and submitted each report without a review or oversight process in place to prevent, or detect and correct, errors. Contact Person Responsible for Corrective Action: Chris Cloud, Chief of Staff Contact Phone Number and Email Address: 260-449-4752 / chris.cloud@allencounty.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: To correct Finding 2023-003, the Chief of Staff to the Board of Commissioners will have the Controller to the Board of Commissioners review the P&E Reports and the Recovery Plan Performance Report prior to being electronically submitted to the Department of Treasury via its State and Local Fiscal Recovery Funds portal. If errors are discovered by the Controller, the Chief of Staff will correct the electronic entry prior to submission. Anticipated Completion Date: This CAP will be completed by October 31, 2024, the deadline for submitting the third quarter 2024 P&E Report.

View Audit 331014

Finding 513083 (2023-002)

Material Weakness 2023

Allen County

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management § 200.303

FINDING 2023-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Summary of Finding: (copied from SBOA Findings document provided) The Allen County Department of Health (Department of Health), a department within Allen County,...

FINDING 2023-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Federal Agency: Department of the Treasury Summary of Finding: (copied from SBOA Findings document provided) The Allen County Department of Health (Department of Health), a department within Allen County, was awarded the Health Issues and Challenges grant through the Indiana Department of Health financed through the American Rescue Plan Act (ARPA) for the purposes of funding programs that focus on the improvement of chronic disease, specifically, elevated blood lead level reduction. As part of sound management of the Federal award, the Department of Health was responsible for implementing a system of internal control that would ensure compliance with the applicable requirements. The Department of Health did not properly design or implement such a system. The Department of Health was required to submit data through the online portal, National Electronic Disease Surveillance System (NEDSS) Base System (NBS), monthly beginning in October 2022. The submitted data included program specific metrics relating to patient case management of certified Elevated Blood Lead Levels (EBLLs). The Department of Health was also required to ensure environmental investigation activities completed, including risk assessments and environmental inspections, were documented in the Indiana I-LEAD database monthly by a licensed Lead Risk Assessor. Environmental investigation activities performed by the Department of Health were documented in the Indiana I-LEAD database by a licensed Lead Risk Assessor who was an employee of the Department of Health. Similarly, case management activities performed were documented in the NEDSS Base System (NBS). Once activities were documented in the I-LEAD and NBS systems, the activities were further documented in a spreadsheet by the Lead Risk Assessor (for I-LEAD activities) and the Case Management Coordinator (for NBS activities). The spreadsheet was reviewed by the Director of the Environmental Services Division and the Finance Director monthly. The Finance Director then used the spreadsheet to prepare the monthly reimbursement requests and sent the monthly reimbursement requests to the Indiana Department of Health. We determined through inquiry with the Director of the Environmental Services Division and the Finance Director that while there was a review of the monthly spreadsheet, there was not a second review of the spreadsheet back to the activities reported in I-LEAD and NBS for accuracy. Additionally, the Finance Director prepared and submitted the reimbursement requests to the State without a second review or oversight process in place to prevent, or detect and correct, errors prior to submission. The lack of internal controls was a systemic issue throughout the audit period. Recommendation We recommend that management of the Health Department design and implement a proper system of internal controls, including policies and procedures that would provide segregation of duties to ensure appropriate reviews, approvals, and oversight are taking place to ensure reports are complete and accurate. ………………………… Contact Person Responsible for Corrective Action: JENNIFER MILLER (Finance Director) Contact Phone Number and Email Address: 260-449-7358 (Jennifer.miller@allencounty.us) Views of Responsible Officials: We concur with the finding Explanation and Reasons for Disagreement: N/A Description of Corrective Action Plan: We were unaware of a requirement for a secondary review of each document/spreadsheet/database input/task that was conducted prior to submission to the Finance Director (defining the completed cases for which to invoice the State), and a requirement for a secondary review of the invoice/billing documents prior to submission to the State. We were informed that the State review process (as was described to SBOA staff) was the check and balance needed which ensured we had appropriately entered the data into the required database(s) and that we had then subsequently billed for those very same appropriately completed and entered cases. However, when we were informed of the outcomes of the SBOA audit and the subsequent need for a corrective action plan (CAP) relative to their findings, we moved quickly to begin the development of the CAP -- as we do now understand that despite the inaccurate instructions we were given, we did not appropriately do what the law requires locally relative to ensuring accurate completion of duties under grant contracts before submission for reimbursement. THE PLAN (which will be added as a new “Grants” section in our existing Finance Internal Controls policies): For all grants (reimbursable or deliverables-based), once a contract is near completion or upon execution, a primary and secondary staff member will be identified for each step of the database entry (as an example, and this will follow whatever the duties are defined by the grant and a primary responsible staff member will be defined per grant duty needs) as well as for the invoicing/billing documentation process. The primary staff member(s) will be responsible for doing what is defined in the grant contract (a duty, task, data entry, invoice creation, etc.) and the secondary staff member will be responsible for verifying the work of the primary staff member(s). (In some cases, when there are diverse duties and more than one primary staff member is needed to do the duties of the grant, there may be several primary staff members assigned to various duties as needed) If disparities are encountered (such as errors or omissions) in any step related to the above duties, they will first be reported the primary staff member for likely easy correction or resolution. If a pattern exists or repetitive errors are identified through the review and verification process, the secondary reviewer will report the issue(s) to the Department Administrator to make a determination as to whether the primary staff member’s duties are transferred to another staff member, or if the person is simply re-educated. The goal will be to ensure there is an appropriate check and balance step (as well as remediation/correction step if warranted) in place for all tasks and documentation completion as it relates to grant-funded duties and invoicing. Anticipated Completion Date: We will follow this practice for any new grants accepted by the Allen County Department of Health effective 9/17/2024.

View Audit 331014

Finding 513048 (2023-003)

Significant Deficiency 2023

Golden Valley Electric Association, Inc. and Subsidiary

AK

Subrecipient Monitoring Reporting Significant Deficiency § 200.512

Finding 2023-003 Deadline for Federal Single Audit – Reporting - Noncompliance and Significant Deficiency in Internal Control Over Compliance Name of Contact Person: Sarah J. Villalon, CFO Planned Corrective Action: Management agrees with the finding and plans to establish processes and procedures t...

Finding 2023-003 Deadline for Federal Single Audit – Reporting - Noncompliance and Significant Deficiency in Internal Control Over Compliance Name of Contact Person: Sarah J. Villalon, CFO Planned Corrective Action: Management agrees with the finding and plans to establish processes and procedures to ensure the audit is completed timely and the reporting package is submitted within the required timeframe. Anticipated Completion Date: March 31, 2025

View Audit 330951

Finding 513047 (2023-002)

Significant Deficiency 2023

Golden Valley Electric Association, Inc. and Subsidiary

AK

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2023-002 Reporting - Noncompliance and Significant Deficiency in Internal Control Over Compliance Name of Contact Person: Sarah J. Villalon, CFO Planned Corrective Action: Management agrees with the finding and will complete the missing information in future progress reports submitted to the...

Finding 2023-002 Reporting - Noncompliance and Significant Deficiency in Internal Control Over Compliance Name of Contact Person: Sarah J. Villalon, CFO Planned Corrective Action: Management agrees with the finding and will complete the missing information in future progress reports submitted to the State of Alaska. Anticipated Completion Date: December 31, 2024

View Audit 330951

Finding 513032 (2023-001)

Material Weakness 2023

City of Redfield

SD

Material Weakness Reporting Internal Control / Segregation of Duties

When federal compliance issues arise, the City Finance Officer will communicate them to the Mayor.

View Audit 330908

Finding 512982 (2023-001)

None 2023

City of Shawnee, Oklahoma

OK

Reporting Internal Control / Segregation of Duties

2023-001 - Filing with the State Auditor and Federal Audit Clearinghouse Condition: The city did not submit its audit report to the State Auditor prior to the deadline of six months after the end of the fiscal year ending June 30, 2023. Additionally, the city did not submit its audit report to the ...

2023-001 - Filing with the State Auditor and Federal Audit Clearinghouse Condition: The city did not submit its audit report to the State Auditor prior to the deadline of six months after the end of the fiscal year ending June 30, 2023. Additionally, the city did not submit its audit report to the FAC within nine months from the year ending June 30, 2023. In conjunction with our FY2023 single audit, please see the City's corrective action plan below: Management recognizes the need to submit its single audit reports to the State Auditor and FAC in accordance with the required deadlines to remain comliant with requirements. Management will make an effort to correct thier timeliness and file within the appropriate deadlines going forward. Expected completion date: 09/16/2024 Party Responsible: Kimberly Smith, Finance Director/Treasurer Contact Information: kimberly.smith@shawneeok.org

View Audit 330809

Finding 512949 (2023-002)

Material Weakness 2023

Regional School Unit 9 Dba Mt Blue Regional School District

ME

Special Tests & Provisions Internal Control / Segregation of Duties

Finding 2023-002 – Wage Rate Requirements Contact Person Responsible for Corrective Action: Alison Gamache, Director of Finance Corrective Action: As of 9/1/2023 all prime construction contracts in excess of $2,000 awarded by the school district will include a provision for compliance with the Davis...

Finding 2023-002 – Wage Rate Requirements Contact Person Responsible for Corrective Action: Alison Gamache, Director of Finance Corrective Action: As of 9/1/2023 all prime construction contracts in excess of $2,000 awarded by the school district will include a provision for compliance with the Davis-Bacon Act. The school district will also provide a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The contracts will also include a provision for compliance with the Copeland "Anti-Kickback" Act. Anticipated Completion Date: By June 30, 2025

View Audit 330756

Finding 512922 (2023-002)

Material Weakness 2023

City of Gloversville, New York

NY

Internal Control / Segregation of Duties § 200.512

The City transitioned auditors in 2023 and as a result was unable to complete its audit timely. The City intends to meet the September 30, 2025 filing deadline for its December 31, 2024 Federal Single Audit

View Audit 330679

Finding 512906 (2023-003)

Significant Deficiency 2023

Barry County, Missouri

MO

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

Due to changes in the federal reporting system, we had problems getting the information to upload to the federal reporting site. Reporting began well before the due date, and reaching out for assistance has proven unfruitful. In future reporting, every effort will be made to ensure timely submission...

Due to changes in the federal reporting system, we had problems getting the information to upload to the federal reporting site. Reporting began well before the due date, and reaching out for assistance has proven unfruitful. In future reporting, every effort will be made to ensure timely submissions.

View Audit 330670

Finding 512849 (2023-001)

Material Weakness 2023

Decatur-Morgan County Port Authority

AL

Internal Control / Segregation of Duties

Management agrees with the finding related to lack of segregation of duties and recognizes that due to the size and complexity of the organization this weakness exists

View Audit 330597

Finding 512721 (2023-001)

Significant Deficiency 2023

New Opportunities, Inc. and Affiliates

CT

Internal Control / Segregation of Duties Reporting Significant Deficiency

Finding No . 2023-001: Financial Reporting Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting did not meet timeliness standar...

Finding No . 2023-001: Financial Reporting Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: In fiscal year 2023, the Organization’s accounting processes and internal controls over financial reporting did not meet timeliness standards. As a result, the financial close process including the grant schedule was not completed within the standard period. Statement of Concurrence or Nonconcurrence: Management agrees with the auditors' findings. Corrective Action: Management identified the prior two years of this finding as a lack of proper staffing, which has been corrected. Management will meet the timeliness standards in subsequent fiscal years. Name of Contact Person: Mark E. Kovitch, CFO mkovitch@NewOppInc.org 203-575-4293 Projected Completion Date: July 31, 2025

View Audit 330588

Finding 512705 (2023-001)

Significant Deficiency 2023

Golden Apple Foundation for Excellence in Teaching

IL

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Corrective Action Plan We have scheduled the start of 2024 audit to begin early April 2024 which gives us time to complete the process and file the report with the Federal Audit Clearinghouse on time. Person(s) Responsible: Yomi Ibrahim Timing for Implementation: 2024 Audit Yomi _Ibrahim, VP ...

Corrective Action Plan We have scheduled the start of 2024 audit to begin early April 2024 which gives us time to complete the process and file the report with the Federal Audit Clearinghouse on time. Person(s) Responsible: Yomi Ibrahim Timing for Implementation: 2024 Audit Yomi _Ibrahim, VP of Finance______ Client, Title

View Audit 330548

Finding 512676 (2023-004)

Material Weakness 2023

City of Wausau

WI

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Federal Funding Accountability and Transparency Act- CDBG Community Development Block Grants/Entitlement Grants – Assistance Listing No. 14.218 Recommendation: We recommend the City review the various grant requirements and laws surrounding the CDBG grant program and ensure that any written internal...

Federal Funding Accountability and Transparency Act- CDBG Community Development Block Grants/Entitlement Grants – Assistance Listing No. 14.218 Recommendation: We recommend the City review the various grant requirements and laws surrounding the CDBG grant program and ensure that any written internal control or procedure manuals include all of the required compliance requirements. We also recommend that the City ensure multiple individuals are trained on the administration of the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This process will be added to the CDBG Policy and Procedure Manual to address the audit findings and improve reporting oversight. Name(s) of the contact person(s) responsible for corrective action: Tammy Stratz Planned completion date for corrective action plan: 10/14/2024

View Audit 330477

Finding 512653 (2023-001)

Material Weakness 2023

Child Care Resource Center of Cuyahoga County Dba Starting Point

OH

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.512

Name of Contact Person James Starks, Chief Financial Officer Corrective Action Plan Starting Point has pushed the date of the audit to an early start date. We have revised and implemented stronger internal control and procedures to ensure compliance with and timely submission of a complete and accu...

Name of Contact Person James Starks, Chief Financial Officer Corrective Action Plan Starting Point has pushed the date of the audit to an early start date. We have revised and implemented stronger internal control and procedures to ensure compliance with and timely submission of a complete and accurate Data Collection Form and Single Audit Report package to the Federal Audit Clearinghouse with the appropriate timeframe of nine months after the end of the audit period. Proposed completion date: November 1, 2024

View Audit 330466

Finding 512641 (2023-004)

Material Weakness 2023

University Physician Group

MI

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Upon advice and guidance from external auditors, a Federal Awards Internal Controls document was prepared by University Physician Group.

View Audit 330446

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