Corrective Action Plans

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Management agrees with this finding. Management acknowledges that the Fund’s existing property records have not been sufficiently centralized or detailed to support strong control over capital assets, depreciation, and asset lifecycle monitoring. The Fund will create a centralized fixed asset regist...
Management agrees with this finding. Management acknowledges that the Fund’s existing property records have not been sufficiently centralized or detailed to support strong control over capital assets, depreciation, and asset lifecycle monitoring. The Fund will create a centralized fixed asset register that includes, at a minimum, asset description, asset tag or identifier, acquisition date, placed-in-service date, cost, funding source where applicable, depreciation method, useful life, physical location, condition, custodian or department, and disposal information. Management will also reconcile the register to the general ledger on a periodic basis and formalize policies governing capitalization thresholds, depreciation, transfers, retirements, and write-offs. Corrective action plan: • Develop and populate a centralized fixed asset register for all significant capital assets. • Perform a baseline review of existing capital asset balances and supporting invoices, contracts, and prior schedules to establish completeness. • Reconcile the fixed asset register to the general ledger and investigate differences. • Adopt a written capital asset policy addressing capitalization thresholds, useful lives, depreciation conventions, disposals, and approval requirements. • Perform a physical inventory of capital assets and update records for location, condition, and disposition status. Responsible party/role: Staff Accountant in coordination with the Business Office Manager and oversight from the General Manager. Implementation timeline: The centralized fixed asset register will be established within 120 days of issuance of the audit report. The initial reconciliation to the general ledger and baseline physical inventory will be completed by June 30, 2026, with periodic reconciliations performed thereafter at least quarterly for additions and disposals and annually for full rollforward validation.
Management agrees with this finding. Management acknowledges that balance sheet reconciliations were not performed or reviewed with sufficient consistency and documentation, which increases the risk that errors, omissions, or unauthorized activity may not be identified on a timely basis. Management ...
Management agrees with this finding. Management acknowledges that balance sheet reconciliations were not performed or reviewed with sufficient consistency and documentation, which increases the risk that errors, omissions, or unauthorized activity may not be identified on a timely basis. Management will implement a formal reconciliation process for significant balance sheet accounts, including cash, receivables, payables, debt, accrued liabilities, intercompany or related-party balances if applicable, and other key accounts. Reconciliations will be prepared on a documented monthly or quarterly basis depending on account risk and volume, independently reviewed, and retained in a centralized file. Reconciling items will be investigated and resolved within an established deadline, except where a longer period is justified and documented. Corrective action plan: • Adopt a reconciliation policy identifying each significant balance sheet account, frequency of reconciliation, preparer, reviewer, and required supporting documentation. • Prepare monthly reconciliations for cash, major receivables, major payables, payroll liabilities, and debt accounts; prepare quarterly reconciliations for lower-risk or less active balance sheet accounts. • Require independent review and sign-off by the Finance Manager/Controller or General Manager, as appropriate. • Retain all reconciliation workpapers and supporting schedules in an organized electronic and/or paper file. • Establish a requirement that routine reconciling items be cleared within 30 days after identification, and no later than the subsequent monthly close absent documented management approval. Responsible party/role: Staff Accountant or Bookkeeper as preparer; Business Office Manager as primary reviewer; General Manager for oversight. Implementation timeline: Reconciliation templates and the formal policy will be implemented within 60 days of issuance of the audit report. Full documented monthly and quarterly reconciliations will begin with the next monthly close thereafter, and all significant balance sheet accounts are expected to be covered by September 30, 2026.
Management agrees with this finding. Because the Fund operates with a relatively small administrative staff, complete segregation of incompatible duties is not always feasible. Management and those charged with governance recognize this as an inherent limitation of the current organizational structu...
Management agrees with this finding. Because the Fund operates with a relatively small administrative staff, complete segregation of incompatible duties is not always feasible. Management and those charged with governance recognize this as an inherent limitation of the current organizational structure rather than an intentional departure from sound control practices. To address this limitation, the Fund will strengthen compensating oversight controls. These measures will include increased review of disbursements, bank activity, journal entries, and selected account activity by senior management and periodic reporting to the Board of Directors or its designated governance committee. Existing mitigating controls include management familiarity with operations, review of significant cash disbursements, and governance oversight at regular meetings; however, these controls will be formalized and documented more consistently. Corrective action plan: • Implement a documented monthly review of cash disbursements, bank statements, journal entries, and unusual transactions by the General Manager or equivalent executive not performing day-to-day bookkeeping functions. • Require Board of Directors or finance committee review of summarized financial information, check registers, and budget-to-actual results at regular meetings. • Establish approval thresholds requiring dual review for significant non-routine disbursements, vendor additions, write-offs, and manual journal entries. • Document evidence of supervisory review through sign-off or electronic approval retention. Responsible party/role: General Manager, Business Office Manager, Staff Accountant, and Board of Directors. Implementation timeline: Initial compensating control procedures will be implemented within 90 days of issuance of the audit report, with board-level reporting enhancements in place by June 30, 2026.
VIEWS OF RESPONSIBLE OFFICIALS In response to the single audit finding we will take the following actions. We will establish internal controls that provide certainty, effective monitoring data validation and accountability for those employees who approved expenditures. We will prepare written proces...
VIEWS OF RESPONSIBLE OFFICIALS In response to the single audit finding we will take the following actions. We will establish internal controls that provide certainty, effective monitoring data validation and accountability for those employees who approved expenditures. We will prepare written process in accordance with both state and federal regulations. We will prepare written process in accordance with both state and federal regulations. We will require relevant staff (Staff interacting with procurement, expenditures approval) a comprehensive training program on the requirements of CFR 200. IMPLEMENTATION DATE September 30, 2026 RESPONSIBLE PERSON Ivan Rentas, President
All outstanding audits have been completed. Audits will be conducted annually and completed within six months following the end of each calendar year to ensure ongoing compliance and timely submissions.
All outstanding audits have been completed. Audits will be conducted annually and completed within six months following the end of each calendar year to ensure ongoing compliance and timely submissions.
2023-006 Minutes/Resolutions Material Weakness Recommendation: Written minutes should be prepared for each council meeting along with any approved resolutions/recommendations. The minutes and resolutions should be centrally filed, maintained by the Council’s Secretary, and easily accessible to the a...
2023-006 Minutes/Resolutions Material Weakness Recommendation: Written minutes should be prepared for each council meeting along with any approved resolutions/recommendations. The minutes and resolutions should be centrally filed, maintained by the Council’s Secretary, and easily accessible to the auditor. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.
2023-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at leas...
2023-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at least the signature of one Tribal Council member. Further, individuals who benefit from the loan program should not have complete discretion over recording and processing of advances and repayment. We recommend a complete list of outstanding balances be presented to the Tribal Council, or its designee, for continued monitoring. Action Taken: The SCCHA discontinued the Loan Program as of November 2019. A complete list of balances owed has been submitted to the Tribal Council with the outstanding balances of those whom had signatory authority forwarded to the St. Croix Tribal Court for further repayment actions.
Finding No.: 2023-020 AL Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Area: Special Tests and Provisions - Key Level Management Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Manage...
Finding No.: 2023-020 AL Program: 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Area: Special Tests and Provisions - Key Level Management Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the findings. Financial and Grants Management processes were promulgated in a SOP on September 18, 2024. The SOPs are under review by an external consultant and recommendations made to improve documentation of time and effort allocable under federal awards. (See also 2023-004, 2023-0009) Corrective Action Plan: I. Establishment of Time and Effort SOPs: PSS will finalize and implement a dedicated Time and Effort Reporting SOP. This policy will explicitly define the key management Level of Effort (LOE) requirements by position and mandate the collection of specific supporting records, including Notice of Personnel Action (NOPA) forms, payroll registers, and certified timesheets. The SOP will feature robust internal controls and supervisory review procedures designed to prevent improper payments and ensure accurate labor distribution. II. Standardization of Key Management Records: PSS will obtain and systematically retain NOPA forms or equivalent documentation for all six positions identified in the grant agreement. This documentation will serve as the primary evidence to demonstrate compliance. III. Labor Distribution Monitoring Controls: PSS is implementing ongoing monitoring controls to ensure continued compliance. This includes a periodic internal review of payroll registers against the original grant agreements to verify that the labor costs charged to the award remain consistent with the approved personnel budget and documented effort. Proposed Completion Date: August 2026 Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org
Finding No.: 2023-017 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Private School Participation Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management disagrees with the finding. PS...
Finding No.: 2023-017 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Private School Participation Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management disagrees with the finding. PSS asserts that timely and meaningful consultations were conducted with private school officials prior to making decisions regarding the size, scope, and funding of equitable services for FY2023. Calculations for the equitable share under the Education Stabilization Funds were performed in accordance with federal regulations, ensuring that per-pupil allocations for eligible private school students and teachers were equitable relative to public school expenditures. PSS maintains that consultation timelines, meeting records, and allocation formulas were maintained. While PSS is continuously refining its administrative workflows, the existing documentation and controls were sufficient to satisfy the requirements of 34 CFR § 299.7. Proposed Completion Date: Resolution in progress and on track for completion by August 2026. Name of Contact Person and Title: Contact: Jacqueline Che, Federal Programs Officer Email Address: jacqueline.che@cnmipss.org
Finding No.: 2023-016 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Wage Rate Requirement Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the audit findings. We a...
Finding No.: 2023-016 AL Program: COVID-19 84.425A/84.425X Education Stabilization Fund Area: Special Tests and Provisions - Wage Rate Requirement Questioned Costs: Undeterminable Views of Auditee and Corrective Action Plan: Management’s Position: PSS Management concurs with the audit findings. We acknowledge that our current procurement and contract administration processes did not consistently incorporate the mandatory Davis-Bacon Act labor standard clauses or the subsequent collection of certified payrolls. PSS is committed to implementing a rigorous compliance framework for all federally funded construction and repair projects. Financial, Procurement, and Grants Management policies procedures were promulgated in a SOPs on September 18, 2024. The financial management system was subsequently changed to Tyler Munis to conform with CNMI central government requirements which will enhance capabilities. The SOPs and the Tyler Munis implementation are under review by an external consultant and recommendations made to improve documentation of cost allowability have been received. Payment procedures are being addressed in a separate SOP. Corrective Action Plan: To ensure full compliance with 29 CFR 5.5 and federal wage rate requirements, PSS will implement the following: I. Standardized Construction Contract Template: PSS Legal Counsel and the Procurement Office will develop a standardized "Federal Construction Contract Addendum." This addendum will contain all mandatory Davis-Bacon Act clauses required by 29 CFR 5.5(a)(1)-(10). Effective immediately, no contract or purchase order exceeding $2,000 for construction, alteration, or repair will be executed without the inclusion of this addendum. II. Mandatory Certified Payroll Submission Protocol: PSS will update its "Notice to Proceed" and project management guidelines to explicitly state that progress payments will be withheld until the contractor submits the required weekly certified payrolls. Contractors will be provided with the Form WH-347 (or an equivalent) to ensure they are using the correct reporting format. III. Pre-Construction Compliance Meetings: For all future Davis-Bacon covered projects, PSS will hold a mandatory pre-construction meeting with contractors to clearly communicate their obligations regarding certified payrolls and the posting of the applicable wage decision at the job site. IV. Document Retention and Review Audit: PSS will implement a "Project Close-out Checklist." Finance will not process the final retention payment for any construction project until the Labor Compliance Monitor certifies that all weekly certified payrolls have been received, reviewed, and filed. V. Updated Standard Operating Procedures and Training: PSS will finalize SOPs and policies internal controls with updated internal controls and procedures for required contract clauses and oversight. Checklists will be updated to include a specific control for Davis-Bacon reporting. Require all current contractors and those identified in this audit to submit certified payrolls for 2023 through the span of their contracts for all Davis-Bacon covered work. PSS Procurement and Supply staff will receive refresher training on cost principles annually regarding required contract clauses and documentation to support compliance with requirements. Proposed Completion Date: September 2026 Name of Contact Person and Title: Contact: Michael Jason A. Babauta, Chief Procurement & Supply Officer Email Address: michael.jason.babauta@cnmipss.org
Finding 2023 – 001: Audit Journal Entries Condition: During audit fieldwork, our testing resulted in significant audit adjustments in order to present materially accurate financial statements. Plan: The Village Clerk, along with staff, will review year-end adjustments as part of the audit preparatio...
Finding 2023 – 001: Audit Journal Entries Condition: During audit fieldwork, our testing resulted in significant audit adjustments in order to present materially accurate financial statements. Plan: The Village Clerk, along with staff, will review year-end adjustments as part of the audit preparation process and work to reduce the number of entries proposed by the auditors and prepare fully adjusted financial statements prior to audit fieldwork. Anticipated Date of Completion: Fiscal Year 2024 Name of Contact Person: Colleen Lambert, Village Clerk Management Response: The Village Clerk, along with staff, will review year-end adjustments as part of the audit preparation process and work to reduce the number of entries proposed by the auditors and prepare fully adjusted financial statements prior to audit fieldwork.
Planned Corrective Action: GSIL will continue to strive to maintain adequate staffing levels within the Finance Department to ensure work is completed timely and to maintain documented separation of duties. A Controller position was added and filled recently to add depth to the department and help w...
Planned Corrective Action: GSIL will continue to strive to maintain adequate staffing levels within the Finance Department to ensure work is completed timely and to maintain documented separation of duties. A Controller position was added and filled recently to add depth to the department and help with these efforts. Additionally, vacant positions have included extensive internal and external recruiting efforts and have also recently been filled. Planned Implementation Date of Corrective Action: July 2026 Person Responsible for Corrective Action: Jill Bille, CFO
Corrective Action Plan Details: A. Contact person responsible for corrective action: Name: Alicia Smith Title: Chief Financial Officer B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and da...
Corrective Action Plan Details: A. Contact person responsible for corrective action: Name: Alicia Smith Title: Chief Financial Officer B. Description of corrective action planned: The district will strengthen its internal control systems over reporting to ensure single audit reporting package and data collection form are submitted to the Federal Audit Clearinghouse within established timeframe and financial statements are prepared timely. C. Anticipated completion date of corrective action: Immediately
Action planned in response to finding: 1. Assigned program director and contract specialist to be responsible for the completion of contract terms, with executive oversight. 2. Active USDA portal access always maintained. Name(s) of the contact person(s) responsible for corrective action: Anna Kelle...
Action planned in response to finding: 1. Assigned program director and contract specialist to be responsible for the completion of contract terms, with executive oversight. 2. Active USDA portal access always maintained. Name(s) of the contact person(s) responsible for corrective action: Anna Keller, Finance Manager and Brittany Lucas, Chief Financial Officer Planned completion date for corrective action plan: January 2024
Management Team Ongoing to Fiscal Year 2026 The Authority will conduct annual training on grant management and reporting requirements for all staff involved in the federal programs audit and reporting process. Further, the authority will create checklists of reports required to be submitted to the f...
Management Team Ongoing to Fiscal Year 2026 The Authority will conduct annual training on grant management and reporting requirements for all staff involved in the federal programs audit and reporting process. Further, the authority will create checklists of reports required to be submitted to the federal grantor, to be used to track reporting submission deadlines, including the Federal Audit Clearinghouse (FAC) due date.
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer January 2024 To ensure timely submission of the quarterly compliance reports, the reporting process was updated to remove the multi-level review requirement. Eliminating the multi-level review proc...
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer January 2024 To ensure timely submission of the quarterly compliance reports, the reporting process was updated to remove the multi-level review requirement. Eliminating the multi-level review process allowed management to meet reporting deadlines more efficiently. Further, the Authority will strengthen financial oversight, by requiring all direct reports (monthly to bi-monthly financial reports) be submitted to the CFO. These reports will be used to continuously monitor program performance, identify any discrepancies, and address issues in a timely manner.
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compli...
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compliance with applicable federal regulations
Director of Finance (CDBG-DR Unit), Compliance team, and Chief Financial Officer October 2023 VIHFA has established enhanced internal controls and comprehensive record-keeping protocols. This includes expanded training initiatives for staff and subrecipients, as well as strengthened procedures for r...
Director of Finance (CDBG-DR Unit), Compliance team, and Chief Financial Officer October 2023 VIHFA has established enhanced internal controls and comprehensive record-keeping protocols. This includes expanded training initiatives for staff and subrecipients, as well as strengthened procedures for record retention. The Authority has also updated its policies and standard operating procedures to ensure greater coverage and effectiveness, and is committed to ongoing improvement and consistently meets all compliance requirements through detailed documentation. These measures have been implemented, training has taken place, and policies have been revised.
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compli...
Director of American Rescue Plan (ARP) Programs, Federal program managers, and Chief Financial Officer October 2023 Management remains committed to continuous improvement and has taken corrective actions to strengthen internal controls, ensure proper documentation retention, and maintain full compliance with applicable federal regulations
The County has since implemented corrective actions to strengthen internal controls and ensure compliance moving forward, including: Providing targeted staff training on eligibility requirements, including self-attestation limitations. Implementing a secondary review process for eligibility determin...
The County has since implemented corrective actions to strengthen internal controls and ensure compliance moving forward, including: Providing targeted staff training on eligibility requirements, including self-attestation limitations. Implementing a secondary review process for eligibility determinations and payment calculations when clients self-certify income. Establishing ongoing monitoring procedures, including periodic file reviews. Benton County is committed to maintaining strong internal controls and ensuring compliance with all applicable federal and state requirements. These enhancements are designed to prevent recurrence and support consistent application of program guidelines.
Finding 1218280 (2023-008)
Material Weakness 2023
Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, supporting documentation necessary to verify and document vendor payment was not available, resulting in the inability to obtain sufficient, appropriate audit evidence related to these amou...
Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, supporting documentation necessary to verify and document vendor payment was not available, resulting in the inability to obtain sufficient, appropriate audit evidence related to these amounts. During the testing of ESSER funds, there were 2 instances where the purchase order could not be located and one invoice that could not be located. Corrective Action: The school (LEAD Academy) contracted with New Schools for Alabama (NSFA) during 2023 to handle all their finance and accounting needs. By the end of 2023, the school also transitioned all payroll services to New Schools for Alabama. NSFA helped establish a purchase order procedure and worked with the school to make sure a purchase order or signed contract is in place prior to the purchase of goods and services. Additionally, approval on all invoices is required before NSFA processes them for payment, in order to verify that all goods and services have been received. Prior to 2024, proper procedures were not in place to maintain vendor files and accounts payable documentation. All financial records are now maintained digitally, with the original documents residing at the school. Additionally, NSFA worked with existing staff regarding proper documentation and filing of financial records and helped establish a new filing system. NSFA requires the school to indicate the source of funding for purchases, in order to know how to code the expenditure. We utilize monthly budget to actual reports to verify that expenditures are in line with the approved budget, ensuring that the correct coding has been used. We also ensure that only allowable expenditures are charged to federal funds, based on approved federal Egap applications and budgets.
Management acknowledges the need to strengthen system access controls and will review existing user roles and permissions, implement more restrictive controls over prior-period postings and establish periodic reviews of user access rights.
Management acknowledges the need to strengthen system access controls and will review existing user roles and permissions, implement more restrictive controls over prior-period postings and establish periodic reviews of user access rights.
Management acknowledges the need to evaluate the current check signing and disbursement authorization structure and will consider incorporating governance-level participation and tiered approval thresholds to strengthen oversight.
Management acknowledges the need to evaluate the current check signing and disbursement authorization structure and will consider incorporating governance-level participation and tiered approval thresholds to strengthen oversight.
Management acknowledges the need to strengthen internal controls over the calculation and reporting of TCDRS contributions. The District will implement enhanced review procedures to ensure consistency in the definition and application of eligible compensation and will improve reconciliation processe...
Management acknowledges the need to strengthen internal controls over the calculation and reporting of TCDRS contributions. The District will implement enhanced review procedures to ensure consistency in the definition and application of eligible compensation and will improve reconciliation processes between payroll records and TCDRS reporting.
Management acknowledges the need to strengthen internal controls surrounding the use of District credit cards. In 2024, the District implemented a requirement for the Harbor Master to review all credit card transactions prior to fulfillment of the combined credit card bill. Management is currently e...
Management acknowledges the need to strengthen internal controls surrounding the use of District credit cards. In 2024, the District implemented a requirement for the Harbor Master to review all credit card transactions prior to fulfillment of the combined credit card bill. Management is currently evaluating the form and function of a formalized credit card use agreement and related monitoring procedures.
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