Corrective Action Plans

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Management has implemented a comprehensive continuing education program for employees who work on the SSVF program. Monthly internal audits are conducted by the Program leadership team to monitor compliance with funder guidelines.
Management has implemented a comprehensive continuing education program for employees who work on the SSVF program. Monthly internal audits are conducted by the Program leadership team to monitor compliance with funder guidelines.
Management will coordinate with external auditors to ensure timely completion of the audit and to ensure compliance with 2 CFR 200.512 requirements.
Management will coordinate with external auditors to ensure timely completion of the audit and to ensure compliance with 2 CFR 200.512 requirements.
Reporting – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization perform a final review of amounts entered within the UDS report, as compared to the supporting schedules, prior to submission. Explanation of disagreement with audit finding: There is no disagreement with ...
Reporting – Assistance Listing No. 93.224/93.527 Recommendation: We recommend the Organization perform a final review of amounts entered within the UDS report, as compared to the supporting schedules, prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: • Update UDS procedure to pull detail reports on all numbers reported in the UDS. • Add to the UDS procedure a review of detail reports to tie them to UDS report • Add a sign off to UDS report as part of final review that detail reports were pulled and verified. Name of the contact person responsible for corrective action: Keith Flores, CFO Planned completion date for corrective action plan: July 2026
We will improve our internal control procedures related to record keeping and adjustments in order to ensure compliance with the March 31 federal requirement. Implementation Date: During the 2026-2027 fiscal year. Responsible Person: Mrs. Yadira Pereira Nieves Finance Director
We will improve our internal control procedures related to record keeping and adjustments in order to ensure compliance with the March 31 federal requirement. Implementation Date: During the 2026-2027 fiscal year. Responsible Person: Mrs. Yadira Pereira Nieves Finance Director
Finding 1222772 (2025-001)
Material Weakness 2025
Segregation of Duties
Segregation of Duties
Finding 1222772 (2025-001)
Material Weakness 2025
Recommendation: While we recognize the City’s office staff is not large enough to permit an adequate segregation of duties in all respects for an effective internal control structure, it is important that the City be aware of this condition and look for opportunities to improve segregation of duties...
Recommendation: While we recognize the City’s office staff is not large enough to permit an adequate segregation of duties in all respects for an effective internal control structure, it is important that the City be aware of this condition and look for opportunities to improve segregation of duties or add mitigating controls to prevent material misstatement of the financial statements.
Finding 1222772 (2025-001)
Material Weakness 2025
Management’s Response and Actions Planned: The City’s management is aware of this condition and believes that it is not economically feasible to attain the ideal segregation of duties. Management attempts to mitigate the associated risks by doing the following:
Management’s Response and Actions Planned: The City’s management is aware of this condition and believes that it is not economically feasible to attain the ideal segregation of duties. Management attempts to mitigate the associated risks by doing the following:
Finding 1222772 (2025-001)
Material Weakness 2025
1. Identifies areas where the lack of segregation of duties exists and where there are higher risks of errors or fraud occurring.
1. Identifies areas where the lack of segregation of duties exists and where there are higher risks of errors or fraud occurring.
Finding 1222772 (2025-001)
Material Weakness 2025
2. Implements limited segregation to the extent possible to reduce risks without impairing efficiency.
2. Implements limited segregation to the extent possible to reduce risks without impairing efficiency.
Finding 1222772 (2025-001)
Material Weakness 2025
3. Uses the knowledge that management and the Board of Directors have of operations by having them review certain accounting records and reports.
3. Uses the knowledge that management and the Board of Directors have of operations by having them review certain accounting records and reports.
Finding 1222772 (2025-001)
Material Weakness 2025
Monitors the effectiveness of the above actions and makes changes as considered appropriate.
Monitors the effectiveness of the above actions and makes changes as considered appropriate.
Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2025. Planned Corrective Action – The Agency will take all reasonable measures to work with the new auditors to complete the audit process and submit the data coll...
Condition – The data collection form was not submitted within the required time as required by 2 CFR 200.512 for the year ended June 30, 2025. Planned Corrective Action – The Agency will take all reasonable measures to work with the new auditors to complete the audit process and submit the data collection report within the required time period. Anticipated Date of Correction – The 2026 data collection form for the year ended June 30, 2026, will be issued to GSA within the required deadline of the earlier of thirty days after issuance of the 2026 audit or prior to March 31, 2027. Point of Contact: James Williams, Fiscal Officer/Program Director
1. Proposed Corrective Action: Our agency will migrate all time sheets to digital, which will be input and tracked by the employee and submitted each payroll. That timesheet will then be reviewed and approved by the Director of Operations before payroll is disbursed. Digital timesheets will be avail...
1. Proposed Corrective Action: Our agency will migrate all time sheets to digital, which will be input and tracked by the employee and submitted each payroll. That timesheet will then be reviewed and approved by the Director of Operations before payroll is disbursed. Digital timesheets will be available on demand going forward. 2. Timeline for Implementation: This process has already been completed.
Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 –...
Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 – September 30, 2025 The findings from the September 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2025-001 Recommendation: The entity should design and implement stronger internal controls over project funds, including enhanced segregation of duties, documented procurement procedures, conflict-of-interest monitoring, and periodic independent review of project expenditures to ensure compliance with Uniform Guidance. Management Comments: We agree with the facts and circumstances of this finding. Management has taken corrective action in response to this finding. The employees involved are no longer employed in connection with the project, and the matter was reported to the HUD Office of Inspector General. Management has reviewed and strengthened the project's controls over conflict-of-interest monitoring and enforcement of existing time-clock policies. In addition, we have and will continue to perform independent reviews of project expenditures to ensure compliance with Uniform Guidance.
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: GTI management will develop and implement a formal process to track and report subrecipient invoices that have been received but n...
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: GTI management will develop and implement a formal process to track and report subrecipient invoices that have been received but not yet paid. This includes: • Standardized Weekly Report: A report generated and reviewed weekly by Purchasing and Accounts Payable to identify, prioritize, and resolve outstanding actions for timely payment (Control Owners: AP Manager & Purchasing Manager; Implementation: September 30, 2026) • Weekly Invoice Review: The AP Specialist responsible for subrecipient invoices will review weekly to ensure invoices are prioritized and processed, with delays or exceptions escalated promptly to the AP Manager (Frequency: Weekly; Implementation: September 30, 2026) • Periodic Compliance Monitoring: Management will perform ongoing reviews of subrecipient invoice payment activity to monitor compliance with the 30-day payment requirement and adherence to internal policies (Control Owners: AP Manager & Program Revenue Operations; Frequency: Monthly with quarterly oversight; Implementation: Ongoing, formalized by September 30, 2026) Contact person responsible for corrective action: Naté Hoover, Program Revenue Operations Anticipated Completion Date: 9/30/2026
2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditur...
2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditures recorded in the accounting system. These procedures should include a reconciliation of reported amounts to the general ledger and supporting documentation prior to submission, as well as an independent review process to ensure reported information is accurate, complete, and compliant with Uniform Guidance requirements. Corrective Action: UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026
2025-006 Auditor’s Recommendation: UCM should strengthen internal controls over TANF eligibility determinations by developing and implementing written procedures that clearly define the documentation required to support all TANF eligibility criteria. These procedures should require that participant ...
2025-006 Auditor’s Recommendation: UCM should strengthen internal controls over TANF eligibility determinations by developing and implementing written procedures that clearly define the documentation required to support all TANF eligibility criteria. These procedures should require that participant files include sufficient documentation supporting financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, compliance with applicable legal eligibility requirements, and work participation when applicable. In addition, the entity should implement a documented supervisory review and approval process to verify eligibility determinations and supporting documentation prior to the provision of assistance. The entity should also provide training to staff responsible for eligibility determinations to ensure they understand federal TANF documentation requirements and maintain complete and accurate participant files. Corrective Action: UCM will strengthen internal controls over TANF eligibility determinations by formalizing written procedures that clearly identify the documentation required to support each eligibility criterion before assistance is provided. The procedures will define required documentation for financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, applicable legal eligibility requirements, and work participation requirements when applicable. UCM reviewed and discussed the findings with the auditor, Senior Director of Finance, and Chief Program Officer. UCM also reviewed the Virginia Department of Social Services post-training materials on TANF Employment Advancement Eligibility Determination Training, and clarified identified areas of the findings with the Virginia Department of Social Services as they relate to the subrecipient signed contract. UCM designed new Screening Guidelines for incoming program participants, including a documented supervisory review and approval process, which were completed on April 16, 2026. The new screening guidelines require participant files to include sufficient documentation supporting eligibility determinations and require supervisory review before assistance is provided. A supervisor or designated reviewer will verify that the participant file contains the required eligibility documentation, that eligibility criteria have been met, and that the assistance is consistent with TANF requirements, VDSS guidance, the subrecipient contract, and program guidelines. UCM reviewed and trained staff on the new eligibility screening guidelines, acceptable documents, and income requirements on April 28, 2026. Staff responsible for TANF eligibility determinations, case management, direct assistance, and grant compliance will continue to receive training as needed to ensure they understand TANF documentation requirements and maintain complete and accurate participant files. UCM will also periodically monitor participant files to confirm continued compliance and identify any additional training or process improvements needed. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Case Managers VDSS Program Consultant Anticipated Completion Date: Substantially completed as of April 28, 2026. Ongoing implementation, supervisory review, staff training, and monitoring will continue during the program year.
2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedu...
2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedures over Federal award expenditures to ensure costs charged to Federal awards are allowable, allocable, reasonable, properly approved, and adequately supported in accordance with Uniform Guidance. Written procedures will be developed for expenditure review and approval, including documentation of business purpose, budget availability, cost eligibility under the award terms, proper account coding, funding source, supporting documentation, and evidence of approval. UCM will also strengthen controls over direct assistance to client expenditures by requiring documentation of client eligibility, assistance type, amount approved, funding source, program approval, finance review, and evidence of payment. Direct assistance expenditures will be reviewed to ensure they are allowable under the Federal award, consistent with program requirements, properly coded, and adequately supported before payment or reimbursement is processed. UCM will also implement a Federal award expenditure checklist or similar review tool to document review before expenditures are paid, posted, or reported. The checklist will include review of allowability, allocability, reasonableness, budget availability, funding source, supporting documentation, approval, and compliance with applicable Federal award requirements. For direct assistance to clients, the checklist will also confirm client eligibility, approved assistance type, required case documentation, and evidence of payment. Staff responsible for Federal award expenditures, direct client assistance, grant accounting, accounts payable, and program budget management will receive training on the updated procedures and Uniform Guidance requirements. Supporting documentation and evidence of review and approval will be retained with the expenditure records. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Anticipated Completion Date: December 31, 2026
Department of Treasury, Passed through the Department of Agriculture and Natural Resources Federal Financial Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: During the engagement, Eide Bailly LLP noted the annual project and expenditure repor...
Department of Treasury, Passed through the Department of Agriculture and Natural Resources Federal Financial Assistance Listing No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: During the engagement, Eide Bailly LLP noted the annual project and expenditure report submitted during the year ended December 31, 2025, was not reviewed prior to submission and had amounts reported that did not agree to the general ledger system of the City. Responsible Individuals: Kristen Bobzien, Chief Financial Officer Corrective Action Plan: The City will put procedures in place to ensure the annual project and expenditure report is reviewed for accuracy prior to submission. Anticipated Completion Date: December 31, 2026
Required Monthly Deposits Not Made Timely. Criteria: Monthly deposits are required to be made to the replacement reserve account. Condition: Monthly deposits were not made. Deposits were made every few months and total amount deposited ties to the required total deposits for the year. Context: Requi...
Required Monthly Deposits Not Made Timely. Criteria: Monthly deposits are required to be made to the replacement reserve account. Condition: Monthly deposits were not made. Deposits were made every few months and total amount deposited ties to the required total deposits for the year. Context: Required deposits were made but they were not made monthly due to cash flow restraint. Response: The Organization will make the required deposits monthly if cash flow allows. Management expects these corrective actions to ensure future compliance with applicable federal and HUD reporting requirements.
The College acknowledges the finding and agrees that Return of Title IV Funds (R2T4) calculations and related return activity must be accurately calculated, properly documented, and fully traceable. The condition resulted from the absence of formal procedures, lack of documented supervisory review, ...
The College acknowledges the finding and agrees that Return of Title IV Funds (R2T4) calculations and related return activity must be accurately calculated, properly documented, and fully traceable. The condition resulted from the absence of formal procedures, lack of documented supervisory review, and insufficient documentation and reconciliation of student-level return activity. The College is in the process of implementing enhanced controls over the R2T4 process. A monthly structured workflow has been established whereby the Office of Financial Aid prepares and provides a detailed listing of students subject to R2T4 calculations, including institutional return amounts. Accounting independently reviews and verifies the calculated return amounts and processes the return through the federal system, with documented review and approval. The College has eliminated undocumented manual netting adjustments and requires that all R2T4 returns be recorded as distinct transactions supported by a standardized documentation package, including studentlevel calculations, withdrawal determination dates, and institutional return amounts. All activity is maintained in a centralized electronic repository to ensure a complete audit trail. In addition, the College is formalizing written procedures to define roles and responsibilities, establish documentation standards, and require documented supervisory review and approval. Periodic reconciliations will be performed to ensure that student-level return amounts agree to system activity and federal cash activity. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that R2T4 calculations and returns are accurate, properly documented, fully traceable, and compliant with federal requirements, and to prevent recurrence.
The College acknowledges the finding and agrees that reporting to the Common Origination and Disbursement (COD) system must be accurate, complete, and submitted within required timeframes. The condition resulted from the absence of formal procedures and controls to validate key data elements and mon...
The College acknowledges the finding and agrees that reporting to the Common Origination and Disbursement (COD) system must be accurate, complete, and submitted within required timeframes. The condition resulted from the absence of formal procedures and controls to validate key data elements and monitor reporting timeliness. The College is in the process of implementing enhanced controls over COD reporting. The Office of Financial Aid will develop and formalize written procedures governing the reconciliation of awarding and disbursement activity with COD reporting, including defined responsibilities, documentation standards, and review requirements. The College will also engage third-party consultants to review current processes and assist with system enhancements. System configuration and process improvements will be implemented to support the automation of award and disbursement reporting through PeopleSoft. The Office of Financial Aid will implement quality control measures, including systematic validations and documented supervisory review, to ensure accuracy, consistency, and compliance in COD reporting. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that COD reporting is accurate, timely, and properly controlled, and to prevent recurrence.
The College acknowledges the finding and agrees that Cost of Attendance and Satisfactory Academic Progress determinations must be calculated, documented, and reviewed in accordance with federal requirements. The condition resulted from reliance on manual processes, lack of retained supporting docume...
The College acknowledges the finding and agrees that Cost of Attendance and Satisfactory Academic Progress determinations must be calculated, documented, and reviewed in accordance with federal requirements. The condition resulted from reliance on manual processes, lack of retained supporting documentation, and absence of independent review and approval. The College is in the process of implementing enhanced controls over COA and SAP determinations. Formal policies and procedures will be established to define methodologies, documentation requirements, and responsibilities for preparation and review. The College will work with Information Technology and third-party consultants to enhance system configuration and develop automated processes to support calculation and retention of COA and SAP determinations within a controlled environment. In addition, the College will implement quality control measures, including a COA review committee, systematic validations and documented supervisory review, and will retain sufficient supporting documentation to allow for independent recalculation and verification of eligibility determinations. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that eligibility determinations are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.
The College acknowledges the finding and agrees that formal cash management controls are required to ensure that Title IV funds are drawn only for immediate cash needs and are properly supported and documented. The condition resulted from the absence of documented procedures and inconsistent executi...
The College acknowledges the finding and agrees that formal cash management controls are required to ensure that Title IV funds are drawn only for immediate cash needs and are properly supported and documented. The condition resulted from the absence of documented procedures and inconsistent execution of draw preparation, review, approval, and reconciliation processes. The College is in the process of implementing enhanced controls over cash management. Formal written procedures are being established to govern draw calculations, timing, approvals, supporting documentation, reconciliation requirements, and identification and return of excess cash. A standardized draw file will be maintained for each draw, including supporting student-level disbursement detail, reconciliation to eligible expenditures, and documented supervisory approval. The College will also perform and document monthly reconciliations between student disbursement records and federal cash activity. Cash balances will be monitored to ensure funds are drawn only for immediate needs and that excess cash is identified and returned, as necessary. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that draw amounts are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.
View of Responsible Officials: Management agrees with the finding and recommendation. Corrective Action Plan: East-West Center will designate the International Programs Specialist (coordinator of the Graduate Degree Fellowships) to prepare the list of selected students to be offered scholarships dem...
View of Responsible Officials: Management agrees with the finding and recommendation. Corrective Action Plan: East-West Center will designate the International Programs Specialist (coordinator of the Graduate Degree Fellowships) to prepare the list of selected students to be offered scholarships demonstrating clearly that the selections meet the ratio requirement. The Dean of the Education Program will be required to sign off on the list, checking to ensure that the ratio of students meets our designated mandate. If students decline our initial offer, each alternate also will be vetted by the Dean to ensure the balance is maintained. If there is funding uncertainty up until the date required to send invitations, and a different funding source is used as an alternative or backstop, the program will bring these students on a J-visa so that they are able to shift to Federal funds at a later date to ensure that the ratio is maintained. 27 Contact Person: Director and Dean of Professional Development and Education Programs Anticipated Completion Date: May 2026 28
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