Corrective Action Plans

Finding 391619 (2023-001)

Significant Deficiency 2023

FL

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.302

Additional preventive internal control procedures will be implemented, including an additional level of review of the Schedules and reconciliation. These procedures and internal controls have been implemented as of the date of this report.

View Audit 302073

Finding 391618 (2023-002)

Significant Deficiency 2023

Aspire Health Partners, Inc.

FL

Reporting Internal Control / Segregation of Duties Cash Management § 200.303

Additional preventive internal control procedures will be implemented, including an additional level of review of the Schedules and reconciliation. These procedures and internal controls have been implemented as of the date of this report.

View Audit 302073

Finding 391615 (2023-004)

Significant Deficiency 2023

County of Maui

HI

Subrecipient Monitoring Reporting Significant Deficiency

Ref. No. Compliance and Internal Control over Compliance Findings 2023-004 Reporting - Significant Deficiency Recommendation The County should improve their internal control process to ensure that quarterly reports required by Section 15011 of the CARES Act are completed and submitted on a timel...

Ref. No. Compliance and Internal Control over Compliance Findings 2023-004 Reporting - Significant Deficiency Recommendation The County should improve their internal control process to ensure that quarterly reports required by Section 15011 of the CARES Act are completed and submitted on a timely basis. View of Responsible Officials and Planned Corrective Action Management concurs with the finding as it applies to the special allocation of CARES Act funds. CDBG is implementing a new software program that will improve internal process controls and program efficiency. The software will automatically generate reminder notifications to CDBG staff and subrecipients of upcoming deadlines for quarterly reports. The CDBG Specialist will follow up with a letter to subrecipient to document non-compliance and additional corrective actions, as applicable. A policy and procedures manual for this software program will also be completed. Management further adds that due to a change in administration effective January 1, 2023, the CDBG Program experienced a 100% staff changeover. End Date: Ongoing Responding Person(s): Patience M. K. Kahula, CDBG Program Director Office of the Mayor Phone No. (808) 270-7213

View Audit 302070

Finding 391599 (2023-006)

Material Weakness 2023

St. Francis School District

WI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring

St. Francis School District has taken steps to ensure all transactions expensed to district funds including federal and state funds are properly reviewed by appropriate parties with knowledge of allowable costs and the specific expense incurred. Prior to Items being purchased with grant funds all re...

St. Francis School District has taken steps to ensure all transactions expensed to district funds including federal and state funds are properly reviewed by appropriate parties with knowledge of allowable costs and the specific expense incurred. Prior to Items being purchased with grant funds all requests are to be approved by the budget manager who oversees the specific funds. Orders may only be placed once approval is received from the budget manager and the Director of Finance. Payment of an invoice is not to be made until service has been rendered complete or item has been received in full. Budget managers approve all invoices prior to Director of Finance reviewing for final approval of payment.

View Audit 302062

Finding 391598 (2023-001)

Significant Deficiency 2023

City of La Verne

CA

Reporting Internal Control / Segregation of Duties

The City will take proactive measures to address technical issues that may impede timely submissions. Additionally, the City will update contacts within the necessary agency promptly when staffing changes occur and work closely with relevant federal agencies to resolve technical issues and ensure co...

The City will take proactive measures to address technical issues that may impede timely submissions. Additionally, the City will update contacts within the necessary agency promptly when staffing changes occur and work closely with relevant federal agencies to resolve technical issues and ensure compliance with reporting requirements.

View Audit 302059

Finding 391588 (2023-001)

Material Weakness 2023

Mono County Office of Education

CA

Questioned Costs Special Tests & Provisions Eligibility

April 1, 2024 Finding Number 50000 (2023-001) Noncompliance and Internal Control over Federal Compliance Federal Program – Child Care and Development Fund Cluster – Assistance Listing 93.575 and 93.576, Federal Alternative Payment Corrective Action Plan: Anticipated Completion Date April 30, 2024...

April 1, 2024 Finding Number 50000 (2023-001) Noncompliance and Internal Control over Federal Compliance Federal Program – Child Care and Development Fund Cluster – Assistance Listing 93.575 and 93.576, Federal Alternative Payment Corrective Action Plan: Anticipated Completion Date April 30, 2024 Prior to Mono County Office of Education (MCOE) taking over this program, another agency was responsible for the original eligibility determinations and special tests and provisions, including the files selected for this audit. After discussion about the audit findings, MCOE investigated further, and it was noted that the staff at the time were not following the procedures and forms that were in place. Items were either not completed or filled out correctly in many instances. Since this discovery, MCOE has developed a corrective action plan as follows to adhere to the program’s requirements: • MCOE will ensure that existing and new staff are trained to adhere to the policies and procedures for the program. • MCOE will be conducting annual reviews of all service providers and children served to ensure MCOE is maintaining the required documents on file. • MCOE has developed a double-check procedure to ensure that staff is keeping the required documentation on file for both providers and children served moving forward. I, Jennifer Weston, CBO, will be responsible for the implementation and monitoring of the corrective action plan. Sincerely, Jennifer Weston Chief Business Officer Mono County Office of Education

View Audit 302045 Questioned Costs: $1

Finding 391586 (2023-011)

None 2023

The City of New York

NY

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

Finding No. 2023-011 Department(s): New York City Police Department Program(s): Assistance Listing Number 97.056, Port Security Grant Program Corrective Action(s): While the one (1) piece of equipment that was identified as “active equipment” was in fact disposed of prior to the most recent invent...

Finding No. 2023-011 Department(s): New York City Police Department Program(s): Assistance Listing Number 97.056, Port Security Grant Program Corrective Action(s): While the one (1) piece of equipment that was identified as “active equipment” was in fact disposed of prior to the most recent inventory count, the equipment was not listed as disposed of due to the user (project manager) not completing the final step of the entry. Corrective Action(s): NYPD Grants Unit will schedule one-on-one virtual training with all end users of GTS providing a step-by-step approach on inputting and updating assets in GTS. Upon completion of this training all project managers should be able to successfully complete transactions in GTS maintaining accurate and up to date inventory records from the first (new) entry to the final entry (disposal). These one-on-one sessions will be scheduled and coordinated based on the availability of both individuals (users and trainers) over the course of the next six months. In addition, the NYPD has requested a programming update (to the developer of GTS) which would allow the system to prevent the user from exiting the screen/entry without completing all required fields by providing a prompt feature. Anticipated Completion Date: September 2024 and ongoing Person(s) Responsible for Implementation: Anthony Danna, Deputy Director, NYPD Grants Unit Anthony.Danna@nypd.org (718) 610-8691

View Audit 302042

Finding 391584 (2023-007)

Significant Deficiency 2023

The City of New York

NY

Eligibility Internal Control / Segregation of Duties Student Financial Aid § 200.303

Finding No. 2023-007 Department(s): New York City Administration for Children’s Services Program(s): Assistance Listing Number 93.658, Foster Care – Title IV - E Corrective Action(s): • ACS will review all outstanding non-finalized Redetermination packages and re-request outstanding Court Order...

Finding No. 2023-007 Department(s): New York City Administration for Children’s Services Program(s): Assistance Listing Number 93.658, Foster Care – Title IV - E Corrective Action(s): • ACS will review all outstanding non-finalized Redetermination packages and re-request outstanding Court Orders. • Moving forward, if the hard copy Court Order has not been received by ACS within 90 days of the Permanency Hearing, ACS will request a court transcript of the Permanency Hearing. • ACS will finalize IV-E Redetermination packages if a Reasonable Effort determination finding has not been conferred within four months of the request for court action. • ACS will work with the Office of Court Administration to address challenges in timely completion of hearings and receipt of Court Orders. Anticipated Completion Date: September 2024 Person(s) Responsible for Implementation: Andrew Martin, Executive Director, Central Eligibility Office (212)-341-2816

View Audit 302042

Finding 391582 (2023-013)

Material Weakness 2023

The City of New York

NY

Questioned Costs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2023-013 Department(s): New York City Administration for Children’s Services and New York City Human Resources Administration Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: ACS will work with other agencies to promote co...

Finding No. 2023-013 Department(s): New York City Administration for Children’s Services and New York City Human Resources Administration Program(s): Assistance Listing Number 93.575, Child Care and Development Block Grant Corrective Action(s): ACS: ACS will work with other agencies to promote compliance and internal controls going forward. HRA: In response to the findings, HRA made the following training requests to address the specific findings identified in this audit: 1. Training ID 2344 - Childcare liaisons and Childcare Review Team (CCRT) require training for the appropriate documentation necessary for the approval and provision of childcare. Audit findings confirmed that the staff charged with approval and authorizing childcare will take refresher training about the appropriate documentation requirements (i.e., CS-274w, LDSS 4699, LDSS 4700, etc.). The training will emphasize the requirement that any approved childcare must have support underlying employment/education documentation to justify the provision of the childcare. Childcare is a supportive service, so any childcare must have employment/engagement/education as a condition precedent. 2. Training ID 2343 - The training will include information about the client's employment, rate of pay, frequency of pay, and getting the appropriate documentation into the case records. Audits confirmed that 1) when the agency budgeted income and approved supportive services (i.e., childcare), the record did not have supporting income and employment related documents; 2) training will include the process for budgeting the earned income and applied any earned income disregards. Anticipated Completion Date: April 2024 and ongoing Person(s) Responsible for Implementation: ACS: Rahel Getachew, Associate Commissioner (212)-676-8818. HRA: Ramon E. Flores, Deputy Commissioner, Family Independence Administration (FIA) floresra@hra.nyc.gov

View Audit 302042 Questioned Costs: $1

Finding 391579 (2023-008)

Significant Deficiency 2023

The City of New York

NY

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

Finding No. 2023-008 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH strengthen its intern...

Finding No. 2023-008 Department(s): New York City Department of Health and Mental Hygiene Program(s): Assistance Listing Number 93.323, Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) Corrective Action(s): DOHMH agrees with the recommendation that “DOHMH strengthen its internal controls over the reporting process to include documented review and approval of all financial and special performance reports prior to submission within the required timeframe.” DOHMH Finance will ensure sufficient time to meet and discuss the status of spending and plans for remaining balance before the end of the award period. For example, such meeting will occur at least a month before the end of the award period. DOHMH Finance will ensure sufficient time for review and approval process of the FFR and submit within the required timeframe. For example, send annual FFR for program review at least 2 weeks before the report deadline. Approval deadline date will be added to the approval email and followed up on a consistent basis. The Division of Disease Control will document review of ELC-related reports prior to submission. Anticipated Completion Date: Effective Immediately; 3/20/2024 Person(s) Responsible for Implementation: Anthony Faciane, Assistant Commissioner, afaciane@health.nyc.gov Wai ting Yu, Assistant Commissioner, wyu4@health.nyc.gov Jennifer Carmona, Senior Director, jcarmona@health.nyc.gov Yuming Li, Director, yli@health.nyc.gov Xiu mei Mai, Director, xmai@health.nyc.gov Jenny Tejada, Director, jtejada@health.nyc.gov James Chan, Assistant Director, jchan6@health.nyc.gov Inna Dubrovenska, Assistant Director, idubrovenska@health.nyc.gov Yulia Gudzinskiy, Grants Manager, ygudzinskiy@health.nyc.gov

View Audit 302042

Finding 391569 (2023-009)

Significant Deficiency 2023

The City of New York

NY

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.303 § 200.313

Finding No. 2023-009 Department(s): New York City Department of Investigation Program(s): Assistance Listing Number 16.922, Equitable Sharing Program Corrective Action(s): Based on the recommendations outlined in the audit report, we have developed the following corrective action plan to address...

Finding No. 2023-009 Department(s): New York City Department of Investigation Program(s): Assistance Listing Number 16.922, Equitable Sharing Program Corrective Action(s): Based on the recommendations outlined in the audit report, we have developed the following corrective action plan to address the deficiencies and improve compliance with equipment and real property management requirements. • Strengthen Controls over the Inventory Process: We developed and implemented additional controls over the inventory process to ensure that equipment dispositions are updated in the equipment records, inventories performed are reconciled back to equipment records, and biennial inventory counts are consistently performed over all equipment within the required timeframe. • Training for Personnel: We provide training to all personnel involved in the equipment and real property management process, including property officers and program managers, to ensure they are aware of the new controls and standard operating procedure, and understand their roles and responsibilities related to compliance requirements. • Continuous Monitoring: We developed a continuous monitoring program to ensure that the new controls and procedures are being followed, and to identify any areas for improvement. • We developed Equitable Sharing Program Standard Operating Procedures (“SOPs”) for the New York City Department of Investigation (“DOI” or “Department”) apply to the Department’s use of U.S. Department of Justice (“DOJ”) Equitable Sharing Program (“Program”) funds. These SOPs are intended to complement, not replace, the required guidance found in the “Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies” (July 2018) (“Guide”) and Equitable Sharing Wires (“Wires”), as well as any relevant Department and City policies and procedures. The agency is actively pursuing a centralized inventory management system to improve the effectiveness of inventory management. These corrective actions will help to ensure that federally funded equipment is accurately recorded on inventory records and that inventory is not misplaced, misappropriated, or otherwise disposed of outside of the requirements of federal guidelines. We appreciate the opportunity to address the audit findings, and we are committed to implementing these corrective actions. Anticipated Completion Date: March 31, 2025 Person(s) Responsible for Implementation: Caspar Barrow, Executive Director of Finance/CFO CBarrow@doi.nyc.gov (212)-825-0666 Orane Gordon, Internal Auditor OGordon@doi.nyc.gov (212)-825-0123

View Audit 302042

Finding 391568 (2023-016)

Material Weakness 2023

The City of New York

NY

HUD Housing Programs Eligibility Material Weakness § 200.303

Finding No. 2023-016 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health ...

Finding No. 2023-016 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Number 14.871, Housing Voucher Cluster: Section 8 Housing Choice Vouchers Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period of the waivers until today, from February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow up to ideally have participants comply with requirements but if necessary to terminate assistance for those who do not comply. Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 302042

Finding 391565 (2023-015)

Material Weakness 2023

The City of New York

NY

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Finding No. 2023-015 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance P...

Finding No. 2023-015 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): These deficiencies result from HPD adopting HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of inspections and adverse actions. HPD conducted limited inspections and did not take enforcement action during the waiver period of 2/1/2020 through 12/31/2021. These waivers ended in 2022 in the midst of a significant HPD staffing shortage. HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Housing Maintenance Code inspection team that mirrored the 27 percent experienced in HPD’s rental subsidy program administration team. Although HPD’s COVID-era policies have ceased, and normal processes are now in effect, it will take a significant period of time for full standard operations to resume. Corrective Action(s): 1. Develop a detailed tracking process for routine inspection scheduling. 2. Prioritize inspections for units that are upcoming or those that have gone the longest without an inspection. 3. Develop a detailed tracking and follow up process for enforcing failed inspections. 4. Make every effort to ensure staff vacancy rates are addressed through in house recruitment or other means as needed. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 302042

Finding 391564 (2023-014)

Material Weakness 2023

The City of New York

NY

HUD Housing Programs Eligibility Material Weakness § 200.303

Finding No. 2023-014 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance P...

Finding No. 2023-014 Department(s): New York City Housing Preservation & Development Program(s): Assistance Listing Numbers: 14.249, Section 8 Project-Based Cluster: Section 8 Moderate Rehabilitation Single Room Occupancy 14.856, Section 8 Project-Based Cluster: Lower Income Housing Assistance Program – Section 8 Moderate Rehabilitation Corrective Action(s): During the pandemic, HPD adopted HUD CARES Act waivers, intended to minimize health and safety risks to applicants, participants, owners and staff, and which included the temporary suspension of adverse actions. Although HPD continued to request recertification packages during the period the waivers, February 2020 through December 2021, HPD did not penalize families who did not submit complete recertification packages at that time until more recently. Additionally, HPD is among the City agencies that experienced a staff retention crisis, with attrition rates among its Rental Subsidy Program administrative teams swelling from 12 percent in 2020 to 27 percent in 2022. During the audit period, HPD was experiencing its highest vacancy rate. This meant standard recertifications were delayed because participants did not respond to recertification packages they were asked to complete, HPD did not have the capacity to revoke subsidies for those who did not comply, and the agency had significant backlog as a result of staff vacancies. Though HPD’s vacancy rate improved, it takes significant time to train and prepare staff to do the work. Finally, even though HPD’s COVID-era policies involving adverse action have ceased and normal processes are now in effect, due process requires intensive tracking and follow-up to ideally have participants comply with requirements (but if necessary to terminate assistance for those who do not comply). Therefore, there will be a significant lag between the re-implementation of HPD’s policy to take enforcement actions when recertification packages are not completed or missing and HPD’s actually terminating assistance. Corrective Action(s): 1. Build on existing systems to more closely track recertifications that are mailed and not returned. 2. Develop more robust digital operations that were started during the pandemic leading to reporting capabilities that will help with tracking overdue recertifications. 3. Work more closely with Community Based Organizations that can assist participants complete and return recertification package. 4. Continue close coordination to implement the Housing Access and Stability staffing plan and identify priority hires to onboard critically needed staff timely. 5. Invest in a training team to meet the training needs of new staff. Anticipated Completion Date: April 2025 Person(s) Responsible for Implementation: Dinsiri Fikru, Assistant Commissioner, Division of Program Policy and Innovation, Office of Housing Access and Stability FIKRUD@hpd.nyc.gov

View Audit 302042

Finding 391561 (2023-005)

Significant Deficiency 2023

The City of New York

NY

HUD Housing Programs Internal Control / Segregation of Duties Eligibility § 200.303

Finding No. 2023-005 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Numbers 14.241, Housing Opportunities for Persons with AIDS (HOPWA) Corrective Action(s): HASA will enhance its data management system to flag housing units where rent amounts are repor...

Finding No. 2023-005 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Numbers 14.241, Housing Opportunities for Persons with AIDS (HOPWA) Corrective Action(s): HASA will enhance its data management system to flag housing units where rent amounts are reportedly above the prevailing Fair Market Rent (FMR) limits per bedroom size, and document follow up activities accordingly. Staff will continue to review support documentation during monitoring visits to ensure client rent calculations are current and accurately completed. HASA will continue facilitating monthly technical assistance meetings and convene training sessions with housing providers to address emerging issues and contract compliance findings from monitoring visits. Anticipated Completion Date: April 1, 2024 and ongoing Person(s) Responsible for Implementation: Xiomara Pamela Farquhar, Assistant Deputy Commissioner farquharx@hra.nyc.gov

View Audit 302042

Finding 391560 (2023-004)

Significant Deficiency 2023

The City of New York

NY

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

Finding No. 2023-004 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.241, Housing Opportunities for Persons with Aids Corrective Action(s): HASA will revamp its contract monitoring policies and procedures to ensure sampling of housing inspectio...

Finding No. 2023-004 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.241, Housing Opportunities for Persons with Aids Corrective Action(s): HASA will revamp its contract monitoring policies and procedures to ensure sampling of housing inspection reports and related maintenance and repairs documentation are included to assess compliance with housing quality standards. Documentation reviewed will also include confirmation of apartments’ readiness prior to occupancy and corrective action measures taken to address outstanding deficiencies, including failed inspections. Anticipated Completion Date: April 1, 2024 and ongoing Person(s) Responsible for Implementation: Xiomara Pamela Farquhar, Assistant Deputy Commissioner farquharx@hra.nyc.gov

View Audit 302042

Finding 391558 (2023-002)

Material Weakness 2023

The City of New York

NY

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

Finding No. 2023-002 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): This FY23 audit was conducted on the heels of the FY22 audit where the questioned cost finding is a similar er...

Finding No. 2023-002 Department(s): New York City Human Resources Administration Program(s): Assistance Listing Number 14.239, HOME Investment Partnerships Program Corrective Action(s): This FY23 audit was conducted on the heels of the FY22 audit where the questioned cost finding is a similar error type but significantly decreased to $296 from over $18,000. Included in the FY22 recommended Corrective Action was the onboarding of the Executive Director to shepherd the charge with strengthening the teams’ internal governance, appropriate monitoring and future compliance. Adversely, the onboarding of the executive director was lengthy and only recently finalized in the 2nd quarter of FY24. HRA agrees to strengthen internal controls and the new Executive Director is working with the team to ensure they are intentional in appropriately applying the correct formula for calculating allowable cost, particularly the inclusion of “gross” and not “net” income. The Quality Assurance Tool has been updated including specific sub-items to ensure allowable cost is correctly calculated as well as the other deliverables. Corrective Action(s) • Strengthen internal governance and future compliance. • Executive Director for the Home-TBRA now on board. • Update the Quality Assurance tool that includes sub-items information that supports improved review and approval. • Provide refresher training for staff involved with TBRA to improve performance and outcomes. Anticipated Completion Date: June 30, 2024 and ongoing Person(s) Responsible for Implementation: Dori Hopkins-Figeroux, Director - HTBRA hopkinsfigerouxd@hra.nyc.gov 929-252-6089 Jordan Worrell, Executive Director RAP/HTBRA worrellj@hra.nyc.gov 929-252- 5403 Dwana Abraham, Assistant Deputy Commissioner abrahamd@hra.nyc.gov 929-221-6726

View Audit 302042 Questioned Costs: $1

Finding 391557 (2023-003)

None 2023

The City of New York

NY

Internal Control / Segregation of Duties Special Tests & Provisions HUD Housing Programs

Finding No. 2023-003 Department(s): New York City Department of Human Resources Administration Program(s): Assistance Listing Number 14.231, Emergency Solutions Grants Program Corrective Action(s): The oversight in 2022 (regarding obligation of the 2021 grant) occurred prior to the initiation of...

Finding No. 2023-003 Department(s): New York City Department of Human Resources Administration Program(s): Assistance Listing Number 14.231, Emergency Solutions Grants Program Corrective Action(s): The oversight in 2022 (regarding obligation of the 2021 grant) occurred prior to the initiation of the Corrective Action Plan implemented to strengthen the internal controls based on the FY 2022 Single Audit finding (regarding obligation of the 2020 grant). As indicated in our response to the FY 2022 finding, we will ensure in the future that we strengthen our internal controls to ensure that 100% of the total ESG grant amount is obligated within 180 days of the signed grant agreement. This will include an added layer of review by the Associate Commissioner of Homeless Policy and Innovation, who oversees the unit that obligates the funds in IDIS. Additionally, as communicated in the ICQ, Federal Homeless Policy and Reporting (“FHPR”) and Finance have detailed the following process: • FHPR will notify Finance when the new ESG funding is awarded and the total amount. • Finance will contact OMB to share that a new award was announced and to expect an updated FY budget construct. • FHPR will work with Programs to confirm funding allocations and will send an updated construct to Finance. • Finance will share updated construct with OMB. • FHPR will use updated construct to complete all funding obligations in IDIS. • FHPR will set progressive reminders following ESG award announcements to ensure the 180-day deadline is met. Going forward, these activities and action steps will be completed by a dedicated ESG staff person working within the FHPR team. This new position was created and posted, and a candidate was selected in late 2023; we expect to onboard the selected candidate shortly. Anticipated Completion Date: May 1, 2024 Person(s) Responsible for Implementation: Martha Kenton, Executive Director, Continuum of Care kentonm@dss.nyc.gov 929-221-6283 ESG Project Manager, candidate currently in the onboarding process

View Audit 302042

Finding 391540 (2023-003)

Material Weakness 2023

City of Tucker, Georgia

GA

Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions: The Finance Department has implemented the use of electronic timekeeping that has established supervisory approvals that must occur before timesheets are submitted.

View Audit 302016

Finding 391531 (2023-103)

Significant Deficiency 2023

Espiritu Community Development Corporation

AZ

Subrecipient Monitoring Internal Control / Segregation of Duties

Condition and Context: The School used funding from the grant to complete renovation and construction projects. The School requested the contractors to provide certified payroll reports in the proposal meetings, however they did not obtain the reports from the contractors. Recommendation: The aud...

Condition and Context: The School used funding from the grant to complete renovation and construction projects. The School requested the contractors to provide certified payroll reports in the proposal meetings, however they did not obtain the reports from the contractors. Recommendation: The auditors recommend that the School establish a system of monitoring contracts for construction greater than $2,000 in which the wage rate requirement exists and verify the certified payroll reports are received prior to payment. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: Moving forward, the management team will include the remittance of a certified payroll report in the scope of work when obtaining bids for federally funded construction projects as a primary condition of awarding the contract. Anticipated Completion Date: June 30, 2024

View Audit 302013

Finding 391515 (2023-102)

Significant Deficiency 2023

Espiritu Community Development Corporation

AZ

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.327

Condition and Context: The four quarterly reports were not filed within the 30 days required by the contract. Recommendation: The auditors recommend that the School establish a system of monitoring for the filing of all required reporting and that the chief operating officer review the monitoring ...

Condition and Context: The four quarterly reports were not filed within the 30 days required by the contract. Recommendation: The auditors recommend that the School establish a system of monitoring for the filing of all required reporting and that the chief operating officer review the monitoring list on a regular basis consistent with the timing of report filings. Contact Name: Anastacia Europa Ruiz, Chief Operating Officer Corrective Action Planned: The management team will establish a system for monitoring all required reporting deadlines. This system will be designed to track the filing requirements for each grant and contract, ensuring that deadlines are clearly identified and adhered to. The Chief Operating Officer will be designated as the responsible authority for overseeing the monitoring process. They will review the monitoring list on a regular basis, ensuring that all required reports are filed in a timely manner. The grant team will institute regular compliance reviews to assess our adherence to reporting deadlines and identify any areas for improvement. Anticipated Completion Date: June 30, 2024

View Audit 302013

Finding 391459 (2023-001)

Significant Deficiency 2023

City of Westminster, Maryland

MD

Subrecipient Monitoring Reporting Significant Deficiency

The finance department experienced staff turnover and vacancies during the fiscal year, impacting the fiscal year end close processes. We have consulted with a fractional CFO and are now fully staffed. We are working to remedy the items noted above by assessing our current procedures and implementin...

The finance department experienced staff turnover and vacancies during the fiscal year, impacting the fiscal year end close processes. We have consulted with a fractional CFO and are now fully staffed. We are working to remedy the items noted above by assessing our current procedures and implementing changes for more effective and efficient financial reporting. We are also in the final stages of selecting new ERP software, which would be implemented during fiscal years 2025 and 2026 to allow for more streamlined processes to be implemented. We will be developing comprehensive year end close and audit preparation procedures that will ensure a timely close of the fiscal year.

View Audit 301948

Finding 391442 (2023-003)

Significant Deficiency 2023

City of Humboldt

IA

Reporting Internal Control / Segregation of Duties

A policy and procedure will be established to ensure the annual Project and Expenditure Report is submitted prior to the reporting deadline.

View Audit 301938

Finding 391440 (2023-001)

Significant Deficiency 2023

Community Action Partnership of Oregon

OR

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Corrective Action: Susan Matlack Jones (SMJ) took over as CAPO’s fiscal service provider in July of 2022. The first six months were spent largely cleaning and correcting journal entries from FY22 – a significant task. CAPO did not begin to receive truly accurate and trustworthy financial statements ...

Corrective Action: Susan Matlack Jones (SMJ) took over as CAPO’s fiscal service provider in July of 2022. The first six months were spent largely cleaning and correcting journal entries from FY22 – a significant task. CAPO did not begin to receive truly accurate and trustworthy financial statements until early in 2023. CAPO also experienced two staff losses in the finance department from March through May of 2023. In light of our growth and increased administrative needs, we revised our job posting to increase the level of fiscal skill and responsibility needed for the Finance Manager role. In September of 2023, CAPO was successful in hiring a Finance and Grants Manager with experience in federal fund accounting for Community Action and in SSVF (our major grant). Since that time, he has organized, revamped, and significantly improved internal processes to assure timely review of all finances and reconciliations and works closely with SMJ to assure overall accuracy. Person Responsible: Janet Allanach, CAPO Executive Director Timing for Implementation: Complete as of October 2023

View Audit 301926

Finding 391432 (2023-004)

Material Weakness 2023

County of Nevada

CA

Reporting Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303

The Auditor-Controller’s office will provide additional training to applicable departments to educate staff on appropriate records maintenance related to grant files and the importance documented review and approval processes. This training will provide additional education over appropriate supporti...

The Auditor-Controller’s office will provide additional training to applicable departments to educate staff on appropriate records maintenance related to grant files and the importance documented review and approval processes. This training will provide additional education over appropriate supporting documentation to verify internal controls and compliance requirements are being reasonably followed

View Audit 301919

Corrective Action Plans

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