Corrective Action Plans

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Finding 2023-001 Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 24 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has ...
Finding 2023-001 Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 24 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has updated its policies and procedures to ensure notifications to the National Student Loan Data System are performed timely. In addition, all members of the responsible team will undergo formalized training to ensure their knowledge and proficiency regarding all applicable rules and regulations are kept up to date. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeremy Sivillo, Institutional Registrar Kevin A. Thomas, D.O., Assistant Dean of Institutional Enrollment Management Anticipated Completion Date: Policies and procedure update implementation has been completed. Training for existing staff is to be completed by April 30, 2024. Training material development for new employees will be completed by May 31, 2024
Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Feder...
Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Federal Audit Clearinghouse (FAC) on June 30, 2023, which is prior to June 30, 2023. BVCOG awaits receipt of their audited financial fiscal year 2023 in order to submit them to the FAC. The audited fiscal year 2022 financial statements were submitted separately to HUD on November 22, 2023. HUD approved our submission without notice of delay. Unaudited financial statements for the fiscal year ending 2023 were submitted and accepted by HUD, with no point score deduction penalties or requests for corrective action. The timing of HUD’s Real Estate Assessment Center (REAC) report submission depends on acceptance of the previous unaudited or audited financial statements. The REAC submissions require that each year’s unaudited submission be approved by HUD before the audited submission can be submitted; further, both submissions for a year must be accepted by HUD before the next year’s submissions can be completed. Due to various factors including the COVID-19 pandemic and Winter Storm Uri in 2021, the Fiscal Year 2020 unaudited submission process completed April 2022. Subsequent staff turnover delayed the submission of the audited 2020 submission until August 2023. Once that submission was approved by HUD, the 2021 and 2022 submissions were completed by the end of November 2023. BVCOG realizes its REAC submission procedures rely on institutional knowledge and addressed this risk by engaging an outside CPA firm with personnel knowledgeable of the REAC system. This arrangement ensures additional cross-training opportunities in the future for current finance staff such that, if a key staff person leaves, there will be others in the department who know and understand the procedures necessary for compliance with HUD deadlines. Contact Person Responsible for Corrective Action: Janet Dudding, MBA, CPA, CGFO, Director of Finance Anticipated Completion Date: July 2024
To ensure compliance with grant regulations the school district will implement the following: ● Conduct a comprehensive assessment of existing procedures to identify gaps that led to non-compliance with grant regulations. ● Ensure timely submission of grant applications. ● Maintain detailed document...
To ensure compliance with grant regulations the school district will implement the following: ● Conduct a comprehensive assessment of existing procedures to identify gaps that led to non-compliance with grant regulations. ● Ensure timely submission of grant applications. ● Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. ● Ensure all documentation is easily accessible and systematically organized for audit purposes. ● Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and ONLY with written approval from the Federal awarding agency (as per 2 CFR 200.458). ● Establish a process for obtaining and documenting written approval for pre-award costs. ● Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. ● Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. ● Assign accountability for monitoring and reporting compliance to specific roles within the organization. This implementation of this plan shall be the responsibility of the Russ Kaubris, Business Manager. Starting with the Fiscal Year 2025 grant cycle, procedures to comply will be implemented.
Moving forward, a supervisory review of the move in files will be performed by a different staff member for the Authority than the staff member who initially determined eligibility. This will ensure that the Authority continues compliance with eligibility requirements.
Moving forward, a supervisory review of the move in files will be performed by a different staff member for the Authority than the staff member who initially determined eligibility. This will ensure that the Authority continues compliance with eligibility requirements.
It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to dete...
It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to determine that pledging requirements are adequate to ensure compliance in the future.
Finding 479160 (2023-001)
Significant Deficiency 2023
Finding 2023‐001 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: The County’s quarterly performance reports submitted to the Department of Treasury were not revie...
Finding 2023‐001 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: The County’s quarterly performance reports submitted to the Department of Treasury were not reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Kent Reeves, County Auditor Corrective Action Plan: The County will continue to have the County Auditor prepare the performance reports, with a mechanical review of the report performed by an individual within the Auditor’s Office. Anticipated Completion Date: Fiscal year 2024
Treston Hall, County Administrator, will seek out training opportunities before December 31, 2024 related to the ever changing reporting requirements associated with CLFRF to ensure future reporting periods are properly presented.
Treston Hall, County Administrator, will seek out training opportunities before December 31, 2024 related to the ever changing reporting requirements associated with CLFRF to ensure future reporting periods are properly presented.
Finding 2023-003: Allowable costs – significant deficiency in internal controls over compliance and compliance finding. Management Response All submissions of expenses reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditures char...
Finding 2023-003: Allowable costs – significant deficiency in internal controls over compliance and compliance finding. Management Response All submissions of expenses reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditures charged to the grants agree to the original documents (invoices or 􀆟mesheets) prior to submission or charging to a specific grant
Finding 2023-002: Allowable costs – significant deficiency in internal controls over compliance and compliance finding. Management Response All submissions of expenses reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditures char...
Finding 2023-002: Allowable costs – significant deficiency in internal controls over compliance and compliance finding. Management Response All submissions of expenses reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditures charged to the grants agree to the original documents (invoices or receipts) prior to submission or charging to a specific grant.
Finding 2023-001: Allowable costs – material weakness in internal controls over compliance and compliance finding. Management Response All submissions of 􀆟mesheets and payroll reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditu...
Finding 2023-001: Allowable costs – material weakness in internal controls over compliance and compliance finding. Management Response All submissions of 􀆟mesheets and payroll reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditures charged to the grants agree to the original 􀆟mesheets or payroll prior to submission or charging to a specific grant
BCHS will implement adequate internal control procedures related to account reconciliations and ensure that control process for approval of expenditures is followed.
BCHS will implement adequate internal control procedures related to account reconciliations and ensure that control process for approval of expenditures is followed.
Views of responsible officials: There is no disagreement with the audit finding. A waiver of the funding requirement was obtained for the year ended August 31, 2023. Management will incorporate the funding calculation for the Replacement and Extension Account into the reconciliations to be performed...
Views of responsible officials: There is no disagreement with the audit finding. A waiver of the funding requirement was obtained for the year ended August 31, 2023. Management will incorporate the funding calculation for the Replacement and Extension Account into the reconciliations to be performed and reevaluated monthly.
To prevent the recurrence of financial statement inaccuracies that occurred in FY23, ROE#21 has implemented the following actions to be carried out during the preparation of FY24 financial statements: - Implementing new financial statement reconciliation procedures - Hiring local accounting consult...
To prevent the recurrence of financial statement inaccuracies that occurred in FY23, ROE#21 has implemented the following actions to be carried out during the preparation of FY24 financial statements: - Implementing new financial statement reconciliation procedures - Hiring local accounting consulting services with expertise in Illinois Regional Office of Education financial and operational guidelines - Expanding ROE#21 Professional Development opportunities through collaboration with professional governmental accounting trainers to provide continuing education to internal and regional bookkeepers.
The Corporation contacted the local Continuum of Care and regional HUD office in an effort to verify the required number of units occupied by individuals meeting the definition of "homeless". The local Continuum of Care had no record of the original grant agreement or required number of "homeless" t...
The Corporation contacted the local Continuum of Care and regional HUD office in an effort to verify the required number of units occupied by individuals meeting the definition of "homeless". The local Continuum of Care had no record of the original grant agreement or required number of "homeless" to be served. The Corporation contacted three staff in the regional HUD office, including the staff that had been our representative for annually renewed operation and support service grants for the two projects. Regional HUD staff were not able to provide a copy of the original grant agreements which would indicate the number of persons to be served by each project. HUD staff stated that they do not keep copies of grant agreements longer than seven years. Corporation management will continue to work with HUD personnel to determine the continuing compliance requirements of the Continuum of Care funding received for initial construction or rehabilitation. Corporation management will continue to serve individuals meeting the definition of homelessness at its two projects and document evidence in the file.
Transitional Living for homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to monitor program income and ensure that the funds are being properly used before requesting additional federal funds. This could include regular reporti...
Transitional Living for homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to monitor program income and ensure that the funds are being properly used before requesting additional federal funds. This could include regular reporting on the use of program income and conducting periodic reviews to ensure compliance with program requirements. Additionally, the Organization should review its policies and procedures to ensure they are in compliance with program requirements and make any necessary updates. Finally, the Organization should ensure that all staff members responsible for monitoring program income are properly trained and have a clear understanding of program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During each Payment Management System Draw process, the Finance Director will verify the draw amounts and run a program income and expense report to verify that the amount of miscellaneous expenses for the Transitional Living Program are more than the program income received. A copy of the income and expense statement will be saved in each draw file with the other verification documents. A column for verification initials of this process was added to the ACF Grant Balances Spreadsheet used for recording the draw amounts and dates of the draws. Name(s) of the contact person(s) responsible for corrective action: Julia Montebello, Finance Director Planned completion date for corrective action plan: 4/26/2024
Transitional Living for Homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to ensure that proper documentation and support for eligibility is obtained and reviewed by a qualified individual. Explanation of disagreement with audit...
Transitional Living for Homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to ensure that proper documentation and support for eligibility is obtained and reviewed by a qualified individual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Program Director will conduct Weekly Document Reviews for new and ongoing clients and will also verify eligibility as staff submit weekly request forms for clients to receive services. Weekly Review Schedule: • The Program Director will conduct a review of all documentation once a week. Verification Process: • During the review, the Program Director will verify that all required documents for eligibility is being completed accurately, processed, and documented. Documentation of Review: • The results of this review will be documented on each client’s initial intake form and in Apricot. • The Program Director will sign the intake form to indicate verification and completion of the review and will also document this in Apricot. • By adhering to this procedure, we ensure that all documentation is thoroughly checked and validated on a consistent basis, maintaining the integrity and accuracy of our eligibility process. Name(s) of the contact person(s) responsible for corrective action: Elena Guerra, EYS Program Director. Planned completion date for corrective action plan: ongoing
Transitional Living for Homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to ensure that clients meet eligibility requirements before being enrolled in the program. This could include verifying age at the time of enrollment and ...
Transitional Living for Homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to ensure that clients meet eligibility requirements before being enrolled in the program. This could include verifying age at the time of enrollment and periodically re-verifying eligibility for on-going clients. Additionally, the Organization should review its policies and procedures to ensure that they are in compliance with program requirements and make any necessary updates. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Clearly define eligibility requirements for staff conducting intakes, along with the intake process. Staff and Program Director will reverify eligibility when doing check requests. Two opportunities will be provided for staff each year to revisit eligibility requirements and to provide staff with refresher training. Intake Process: At the time of intake into the program, client’s will be asked for their driver’s license, state ID, permit, tribal ID, or birth certificate. If the client doesn't have any Identification, staff will calculate the client's age using the client's reported date of birth. Staff will then attempt to help the client secure personal vital documents and add copies to the client file for verification. The Program Director will also verify eligibility. Training: Staff to be trained in the spring and fall of each year to revisit eligibility requirements, intake processes, along with agency core values, mission and vision. Name(s) of the contact person(s) responsible for corrective action: Elena Guerra, EYS Program Director Planned completion date for corrective action plan: • Clearly define eligibility requirements for staff by July 1, 2024. • Host trainings by September 30, 2024, and March 31, 2025. • Verify eligibility for new clients and current clients on an ongoing basis.
2023-002 Planned Corrective Action: We agree with the need for updated policies and/or procedures to be codified in the Organization’s Accounting Manual to ensure compliance with the new 2023 LSC Financial Guide requirements. In 2022, 603 Legal Aid drafted a set of accounting policies based on the p...
2023-002 Planned Corrective Action: We agree with the need for updated policies and/or procedures to be codified in the Organization’s Accounting Manual to ensure compliance with the new 2023 LSC Financial Guide requirements. In 2022, 603 Legal Aid drafted a set of accounting policies based on the previous Financial Guide and operations at the time (which included different staffing positions to those in place at present). The Organization currently has a temporary consultant filling in for the Senior Accountant position while a permanent hire is found. Working with the Board Treasurer, he is in the process of updating the 603 Legal Aid 2022 draft of policies to reflect changes in the new LSC Financial Guide as well as operational changes at 603 Legal Aid. This work is expected to be handed off to the permanent Senior Accountant when hired, who will be responsible for ongoing oversight of the Organization’s Accounting Manual to ensure compliance. Responsible Person: Temporary Consultant, Senior Accountant Date of Completion: December 31, 2024
2023-001 Planned Corrective Action: The Organization has already taken the necessary corrective action steps to be in compliance with this regulation. In January 2024, 603 Legal Aid communicated with our LSC Program Officer to review the Board of Directors composition requirements and discuss the pl...
2023-001 Planned Corrective Action: The Organization has already taken the necessary corrective action steps to be in compliance with this regulation. In January 2024, 603 Legal Aid communicated with our LSC Program Officer to review the Board of Directors composition requirements and discuss the plan for bringing the Organization into compliance. A new McCollum attorney joined the Board in January 2024, bringing 603 Legal Aid into compliance. Additionally, the Chair of the Board Development Committee has agreed to create and maintain a running list of Board members for ongoing oversight throughout the year to ensure continued compliance. Responsible Person: Ariel Clemmer Date of Completion: Compliant as of January 2024
Finding 479031 (2023-001)
Significant Deficiency 2023
Corrective Action Plan Name of Auditee: Nutrition, Inc. Name of audit firm: Donovan CPAs Period covered by the audit: October 01, 2022 - September 30, 2023 Corrective action prepared by: Name: Sudie Shaw-Price, Nutrition, Inc. Position: Executive director Telephone number: (317)543-9452 Email addres...
Corrective Action Plan Name of Auditee: Nutrition, Inc. Name of audit firm: Donovan CPAs Period covered by the audit: October 01, 2022 - September 30, 2023 Corrective action prepared by: Name: Sudie Shaw-Price, Nutrition, Inc. Position: Executive director Telephone number: (317)543-9452 Email address: sprice@nutritionincindy.org Current Finding on Schedule of Findings, Questioned Costs, and Recommendations Finding 2023-001 – Financial Statement and Federal Awards Statement of Condition: Nutrition was not segregating duties of accounting and administrative responsibilities for internal control purposes. Status: Coming out of the pandemic impacted the ability to complete the segregation of duties process, due to the lack of staff. As a result, Nutrition is working to develop the processes that will help to implement the procedures that will segregate duties and will continue working with team members to implement processes to segregate duties moving forward. At this time, the development is on-going and will take place when the business growth warrants and supports such an action. Presently, adding additional staff to provide another layer of preparation, review, and monitoring would outweigh the costs.
Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the inte...
Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board had reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.
Finding 479029 (2023-001)
Significant Deficiency 2023
Federal Program Coronavirus State and Local Fiscal Recovery Funds – 21.027 Compliance Requirements Reporting Condition During review of the annual program reporting, it was noted that project expenditures incurred and current period project obligations were not properly noted. Recommendation We reco...
Federal Program Coronavirus State and Local Fiscal Recovery Funds – 21.027 Compliance Requirements Reporting Condition During review of the annual program reporting, it was noted that project expenditures incurred and current period project obligations were not properly noted. Recommendation We recommend the County review its grant reporting procedures and implement controls to ensure that grant reports are completed accurately. Comments on the Finding Recommendation Ellis County staff concur, and we will improve our quality control processes to ensure that reported amounts are accurate. It proves a great point to have these reports checked and double checked by another individual for quality control processes. Actions Taken Prior to completing the next annual reporting period, staff involved with the reporting process will review information provided by the Treasury about the items to be reported upon. We will also have a second person review the numerical values to ensure they are correct per Ellis County reports. Before final submittals to the U.S. Treasury, staff will also meet with the auditor to ensure that all definitions are understood. At that time, any questions that arise will be addressed with an appropriate source before completing the submission.
CSS management will improve its system of internal controls in order to actively track and adhere to reporting requirements outlined in its award agreements.
CSS management will improve its system of internal controls in order to actively track and adhere to reporting requirements outlined in its award agreements.
CSS management will improve staffing and internal controls to ensure compliance with the timely reporting requirements stated in 2 CFR §200.512.
CSS management will improve staffing and internal controls to ensure compliance with the timely reporting requirements stated in 2 CFR §200.512.
Catholic Social Services' management will improve its system of internal controls to correctly identify and present a complete and accurate schedule of expenditures of federal awards.
Catholic Social Services' management will improve its system of internal controls to correctly identify and present a complete and accurate schedule of expenditures of federal awards.
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