Corrective Action Plans

Finding 485095 (2022-003)

Significant Deficiency 2022

OR

Internal Control / Segregation of Duties Questioned Costs Reporting

The Director of Finance and Accounting Manager are working with the Billing Specialists to ensure all invoices are filed in a timely manner to funders. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save ...

The Director of Finance and Accounting Manager are working with the Billing Specialists to ensure all invoices are filed in a timely manner to funders. The importance of understanding the requirements of the agreements has been stressed to the finance team. The team has also been instructed to save on SharePoint all communication with funders regarding changes of when invoices are to be filed when the instructions differ from the agreement. These conversations occurred with the team in July 2024.

View Audit 317889

Finding 485094 (2022-002)

Significant Deficiency 2022

El Programa Hispano Catolico

OR

Special Tests & Provisions Questioned Costs Significant Deficiency § 200.303

The Director of Finance and Accounting Manager will work with the Grants and Contract Accountant to coordinate grant kickoff meetings with Program Directors and Managers to ensure they have procedures in place to meet the requirements for the agreement. These meetings will be held in August and Sept...

The Director of Finance and Accounting Manager will work with the Grants and Contract Accountant to coordinate grant kickoff meetings with Program Directors and Managers to ensure they have procedures in place to meet the requirements for the agreement. These meetings will be held in August and September.

View Audit 317889

Finding 485092 (2022-002)

Material Weakness 2022

East Marshall Community School District

IA

Internal Control / Segregation of Duties

The District continues to have segregation of duties as a priority. We accept the auditor’s guidance and continue to keep the task of segregation of duties as a priority.

View Audit 317885

Finding 484945 (2022-009)

Material Weakness 2022

Garner-Hayfield-Ventura Community School District

IA

Internal Control / Segregation of Duties

Comment Title: Segregation of Duties. Corrective Action Plan: We will evaluate this and attempt to segregate duties as much as possible. Contact Person, Title, Phone Number: Holly Fischer, Business Manager (641) 923-2718. Anticipated Date of Completion: Immediately

View Audit 317789

Finding 484631 (2022-004)

Material Weakness 2022

Corporacion Del Centro De Bellas Artes De Puerto Rico

PR

Questioned Costs Subrecipient Monitoring Material Weakness § 200.512

Action Item Title 2022-004 – Reporting Compliance Requirement Reporting Status (Open: In-process) Condition: Pass-Through Entity Reporting Requirements – The Corporation submitted just two reports during the year, the first and second required submission. Single Audit Reporting Packages – The ...

Action Item Title 2022-004 – Reporting Compliance Requirement Reporting Status (Open: In-process) Condition: Pass-Through Entity Reporting Requirements – The Corporation submitted just two reports during the year, the first and second required submission. Single Audit Reporting Packages – The Corporation did not comply with the Single Audit Reporting Package submission requirements for the years ended June 30, 2022, and 2023. Identified root cause: Lack of understanding of reporting compliance requirements for federal awards. Fiscal year 2022 was the first year for the Corporation to be subjected to a single audit compliance requirement for receiving and expending COVID-19 public health emergency programs. Grantee resolution plan: Pass-Through Entity Reporting Requirements – On July 1, 2022, the Corporation began submitting the monthly requested reports, subject to the Puerto Rico Fiscal Agency and Financial Advisory (AAFAF, as its Spanish acronym), the pass-through entity, required guidelines when funds are obligated. Single Audit Reporting Packages – The Corporation will submit the outstanding Single Audit Reporting Packages. Completion Date: Pass-Through Entity Reporting Requirements - Corrected Single Audit Reporting Packages – August 2024 Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov

View Audit 317516

Finding 484629 (2022-002)

Significant Deficiency 2022

Corporacion Del Centro De Bellas Artes De Puerto Rico

PR

Allowable Costs / Cost Principles Questioned Costs Internal Control / Segregation of Duties § 200.302 § 200.303

Action Item Title 2022-002 – Financial Management and Internal Controls Compliance Requirement Allowable Costs/Cost Principles Status (Open: In-process) Condition Written Policies The Corporation has no written policies for determining the activities allowed or unallowed and the allowability of...

Action Item Title 2022-002 – Financial Management and Internal Controls Compliance Requirement Allowable Costs/Cost Principles Status (Open: In-process) Condition Written Policies The Corporation has no written policies for determining the activities allowed or unallowed and the allowability of costs as described in subpart E, Cost Principles of 2 CFR Part 200. Identified root cause It is the first year for the Corporation to be subjected to a single audit compliance requirement. However, since the Commonwealth of Puerto Rico (the Commonwealth) filed for Title III under the PROMESA, all the instrumentalities of the Commonwealth had to reduce their staff as part of the Fiscal Plan to reduce expenditures. This has disrupted the segregation of duties, which is a key control. Grantee resolution plan Written Policies The Corporation received federal funds for the first time in 2022. For the purposes of purchases or acquisitions, the Corporation is governed by Law of the General Service Administration for the Centralization of Government Purchases in Puerto Rico, Law No. 73 of 2019, which establishes the uniform purchasing process for acquisitions by the Commonwealth. The Corporation will adopt regulations for the use and disbursement of federal funds and comply with the federal regulations. Completion Date Written Policies By June 30, 2025 Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov

View Audit 317516

Finding 484589 (2022-001)

Material Weakness 2022

La'i'opua 2020

HI

Reporting Internal Control / Segregation of Duties

In response to the negative finding of the prior year deficiency noted in the audits, immediate actions have been taken by L2020 to address the issues and prevent reoccurrence in the future. The individuals who were previously responsible for financial reporting and cash management during the audit ...

In response to the negative finding of the prior year deficiency noted in the audits, immediate actions have been taken by L2020 to address the issues and prevent reoccurrence in the future. The individuals who were previously responsible for financial reporting and cash management during the audit are no longer employed at L2020. Going forward, Rebecca “Kawehi” Inaba, appointed as the Executive Director in late 2021, will take charge of ensuring that L2020 remains compliant with all financial requirements, including conducting audits in a timely manner. The organization expresses confidence in her ability to keep L2020 up to date with all financial obligations. In an effort to enhance control and oversight, L2020 will be instituting a quality control review process for all forthcoming report submissions. This measure aims to identify any discrepancies or delays in submissions, enabling corrective actions to be taken promptly. L2020 remains dedicated to upholding transparency and accountability in their financial practices. These proactive steps are crucial in enhancing processes and performance. The organization appreciates understanding and support as they strive for improved financial management practices at L2020.

View Audit 317494

Finding 481302 (2022-007)

Material Weakness 2022

Dunseith Public School District No. 1

ND

Internal Control / Segregation of Duties Questioned Costs Cash Management

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date will be the start of FY-23.

View Audit 317381 Questioned Costs: $1

Finding 481297 (2022-008)

Material Weakness 2022

Dunseith Public School District No. 1

ND

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date will be the start of FY-23.

View Audit 317381

Finding 481294 (2022-005)

Material Weakness 2022

Dunseith Public School District No. 1

ND

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

Contact Person Evan Peltier Planned Corrective Action Dunseith Public School Dist. #1 will implement the recommendation from Brady Martz. Planned Completion Date The planned completion date will be the start of FY-23.

View Audit 317381

Finding 481151 (2022-015)

Significant Deficiency 2022

Unity Health Care, Inc.

MD

Questioned Costs Reporting Internal Control / Segregation of Duties

Management Response #2022-015: Due to staff turnover in prior years and inadequate handover procedures, the reporting requirements under the WIC program was not done as required. Corrective Action Plan: • Training will be provided for the WIC staff that clearly delineates roles and responsibilities...

Management Response #2022-015: Due to staff turnover in prior years and inadequate handover procedures, the reporting requirements under the WIC program was not done as required. Corrective Action Plan: • Training will be provided for the WIC staff that clearly delineates roles and responsibilities for each position in the WIC Dept. This training will separate the tasks of income verification and medical risk assessments under different job titles. Job descriptions and policy/procedures manuals will be updated to memorialize this update. • The Grants program management team will expand upon our current process to ensure eligibility determination is verified and documented. Responsible Party: Tracy Harrison, COO

View Audit 317252

Finding 481150 (2022-014)

Material Weakness 2022

Unity Health Care, Inc.

MD

Subrecipient Monitoring Eligibility Internal Control / Segregation of Duties

Management Response #2022-014: Due to software update with DC Department of Health, the January 1 – March 31, 2022, records were not available, nor were internal reviews of eligibility requirements support available as required. Corrective Action Plan: • The Grants program management team will expa...

Management Response #2022-014: Due to software update with DC Department of Health, the January 1 – March 31, 2022, records were not available, nor were internal reviews of eligibility requirements support available as required. Corrective Action Plan: • The Grants program management team will expand upon our current process to ensure eligibility determination is verified and documented. • Training will be provided to staff on performing income eligibility verification to include taking a screen shot of the eligibility and storing it on a protected shared drive with a de-identified naming convention. This will allow us to have a warehouse of the eligibility verification that can be referenced when needed. It shall be maintained by the WIC Director with limited access and password protection. Policy/procedure manuals for the WIC Dept will be updated to reflect this new requirement and ensure compliance. Responsible Party: Tracy Harrison, COO

View Audit 317252

Finding 481131 (2022-012)

Significant Deficiency 2022

Unity Health Care, Inc.

MD

Questioned Costs Reporting Internal Control / Segregation of Duties

Management Response #2022-012: Due to staff turnover in prior years and inadequate handover procedures, the Federal Funding Accountability and Transparency Act (FFATA) reports were not filed with the granting agencies as required. Corrective Action Plan: The Grants program department will develop p...

Management Response #2022-012: Due to staff turnover in prior years and inadequate handover procedures, the Federal Funding Accountability and Transparency Act (FFATA) reports were not filed with the granting agencies as required. Corrective Action Plan: The Grants program department will develop procedures to ensure that we are compliant in the timely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports. This will be monitored and audited by the Vice President of the grants program at regular intervals. In additional the grants program staff will provide monthly updates to the Finance grants team as to the status of submission as well as copying the team on all submission. Responsible Party: Erin Flior, CSDO

View Audit 317252

Finding 481119 (2022-011)

Significant Deficiency 2022

Unity Health Care, Inc.

MD

Special Tests & Provisions Questioned Costs Internal Control / Segregation of Duties

Management Response #2022-011: Due to turnover of several key financial executives and personnel, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Corrective Action Plan: A procedure will be implemented whereby a secondary review by a Health Center Director ...

Management Response #2022-011: Due to turnover of several key financial executives and personnel, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Corrective Action Plan: A procedure will be implemented whereby a secondary review by a Health Center Director or designee at the respective care site. The approver will sign and date the application or self-attestation form. Training of the appropriate staff will be provided with monitored. Responsible Party: Tracy Harrison, COO

View Audit 317252

Finding 481024 (2022-002)

Material Weakness 2022

Cam Community School District

IA

Internal Control / Segregation of Duties

The District will be redistributing duties in the coming year due to a new staff member. This will separate accounts payable, accounts receivable, payroll, and general ledger.

View Audit 317113

Finding 481007 (2022-004)

Significant Deficiency 2022

City of Groton

SD

Internal Control / Segregation of Duties Questioned Costs Reporting

Finding 2022-004 Finding Summary: In our testing of reporting, we did not have a documented control in place to review reports prior to submission for reporting directly to Department of Treasury. Responsible Individuals: Douglas Heinrich, Finance Officer Corrective Action Plan: We will adopt contro...

Finding 2022-004 Finding Summary: In our testing of reporting, we did not have a documented control in place to review reports prior to submission for reporting directly to Department of Treasury. Responsible Individuals: Douglas Heinrich, Finance Officer Corrective Action Plan: We will adopt controls to have a review process added before the required reports for federal programs are submitted to federal or state agencies. Anticipated Completion Date: December 31, 2024

View Audit 317109

Finding 481006 (2022-003)

Significant Deficiency 2022

City of Groton

SD

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.318 § 200.326

Finding 2022-003 Finding Summary: In testing of procurement, suspension, and debarment, the auditors noted that the City’s procurement policy followed state law which is some cases is less restrictive than federal law. They also noted that the policy does not include the required contract provisions...

Finding 2022-003 Finding Summary: In testing of procurement, suspension, and debarment, the auditors noted that the City’s procurement policy followed state law which is some cases is less restrictive than federal law. They also noted that the policy does not include the required contract provisions that are needed in contracts with federal grants. Responsible Individuals: Douglas Heinrich, Finance Officer Corrective Action Plan: We will assess if we need to adopt a policy for procurement if we receive federal grants in the future. We will be aware of the contract requirements to ensure they are included in contracts which involve federal money. Anticipated Completion Date: December 31, 2024

View Audit 317109

Finding 480993 (2022-002)

Material Weakness 2022

Brookfield Local School District

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.414 § 200.502 § 200.510

All future federal expenditures will be reconciled to the disbursement ledger.

View Audit 317104

Finding 480963 (2022-002)

Material Weakness 2022

Town of Southampton

MA

Internal Control / Segregation of Duties Questioned Costs Material Weakness

Planned Corrective Action: The Town will adopt policies pertaining to federal awards, specifically ARPA, that have been effective and useful in other municipalities. Using established policies from other municipalities will expedite bringing Southampton into compliance. The new policies will esta...

Planned Corrective Action: The Town will adopt policies pertaining to federal awards, specifically ARPA, that have been effective and useful in other municipalities. Using established policies from other municipalities will expedite bringing Southampton into compliance. The new policies will establish controls setting responsibilities and deadlines for timely and accurate submissions. With ARPA funding moving towards an expiration date, these policies will be important to finalize and close-out any awards.

View Audit 317084

Finding 480943 (2022-002)

Significant Deficiency 2022

Cda Midway Plaisance Association

IL

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

Finding 2022-02: The Project has not received any PRAC receipts in 2022 and 2021 or subsequent to the year end. Recommendation: Management needs to work with HUD to process monthly PRAC submission receipts. Action Taken: Management is working with Darletta Baugh, HUD’s project manager regarding...

Finding 2022-02: The Project has not received any PRAC receipts in 2022 and 2021 or subsequent to the year end. Recommendation: Management needs to work with HUD to process monthly PRAC submission receipts. Action Taken: Management is working with Darletta Baugh, HUD’s project manager regarding the non-receipt of the PRAC monthly submission. In addition, Management has delegated the oversight of the PRAC process.

View Audit 317049

Finding 480828 (2022-004)

Material Weakness 2022

Houston Housing Authority

TX

HUD Housing Programs Eligibility Material Weakness

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all deficiencies corrected. During this process if other required documents are found to be missing steps ...

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all deficiencies corrected. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that all HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024.

View Audit 316962

Finding 480825 (2022-003)

Material Weakness 2022

Houston Housing Authority

TX

HUD Housing Programs Questioned Costs Eligibility

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be...

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that a HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024.

View Audit 316962

Finding 480824 (2022-002)

Material Weakness 2022

Houston Housing Authority

TX

HUD Housing Programs Eligibility Material Weakness

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be...

The Houston Housing Authority agrees with this finding. The Houston Housing Authority has for the past several months undertaken a program to review all voucher files for purposes of getting all delinquent recertifications completed. During this process if other required documents are found to be missing steps are being taken to complete the missing documentation and make sure that the files are complete. This review is substantially completed with final completion expected in the third quarter of 2024. Procedures have been implemented with regards to preventing this situation from recurring. Where needed staff will be provided the necessary training to make sure that all HCVP staff have the skills needed to successfully complete their job tasks. To facilitate this training, the Houston Housing Authority has created a training center that is made available to not only Houston Housing Authority staff but also others to provide a wide variety of training classes. Current leadership at the Houston Housing Authority is committed to having a competent trained staff working in the HCVP as well as other departments with the agency. This work is handled by the Voucher Program Operations department. The VP of this department and the Director of this department are primarily responsible for making sure the necessary corrections are made and the fill review is completed within the third quarter of 2024.

View Audit 316962

Finding 480817 (2022-001)

Material Weakness 2022

Houston Housing Authority

TX

Internal Control / Segregation of Duties HUD Housing Programs Material Weakness

The Houston Housing Authority agrees with this finding and related recommendations. During this audit, as these issues arose, notes were taken, evaluation of what had happened was made so that we could make the necessary adjustments to our procedures to prevent the continuation of these issues. In...

The Houston Housing Authority agrees with this finding and related recommendations. During this audit, as these issues arose, notes were taken, evaluation of what had happened was made so that we could make the necessary adjustments to our procedures to prevent the continuation of these issues. In addition, we hired a firm to come in and undertake a review of the finance department. The purpose of this review was to review our existing staffing levels, workloads, experience, etc., for purposes of proposing a reorganization of the finance department to address any deficiencies. We have reviewed the recommendations from this consultant and are in the process of implementing many of the recommended changes. We are in the process of bringing in additional staff to expand the capacity of the Finance department. As we had fallen behind on our audits we anticipated the weaknesses noted in prior audits would continue to be present in future audits. We have been working very diligently to address the issues within the finance department that gave rise to this finding. We fully expect this finding or a similar finding to be present for the 2023 audit as many of the departmental improvements and changes were only recently made and would not have been in place for the majority of 2023.

View Audit 316962

Finding 480688 (2022-003)

Significant Deficiency 2022

Town of Acushnet

MA

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Noncompliance and Significant Deficiency Relate...

Finding 2022-003 – Special Education Cluster – AL No.’s 84.027 & 84.173 Department of Education Massachusetts Department of Elementary and Secondary Education and the Massachusetts Department of Early Education and Care Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Criteria: Where employees work solely or partially on a single Federal program or cost objective, their salaries or wages must be supported by periodic certification that the employee worked on these programs for the period covered by the programs. The certifications should be prepared at least semi-annually, and should be signed by the employee or supervisory official having first-hand knowledge of the work performed by the employee. Condition: During our test of controls over compliance with time and effort certifications the school department was not able to provide evidence that required certifications of time and effort for those employees whose time was spent either completely or partially spent on these programs were performed as required by Uniform Guidance. Questioned Costs: Unknown Context: During our test of payroll transactions of the SPED PL 94-142 grants it was noted that the time and effort certifications were not completed for the employees tested. Effect: The School Department was not in compliance with the time and effort certification requirements. Cause: Staffing turnover in the financial department lead to weakened standard procedures/protocols by inexperienced (temporary) staffing. Identification as a Repeat Finding: N/A Recommendation: We recommend the School Department follow procedures to ensure that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Management Response: Management agrees with the auditors’ findings and will put in procedures and policies to correct the action going forward. Responsible for Corrective Plan: Patrick McIntyre, School Business Manager Estimated Completion Date: Fiscal Year 2024 Action Taken: As required, the School Department ensures that semi-annual certifications and/or monthly certifications are prepared and signed by either the employees and/or supervisory official having first-hand knowledge of the work performed by the employees in a timely manner in order to comply with the time and effort certification requirement. Certifications are filed in grant folders and employee personnel files.

View Audit 316915

Corrective Action Plans

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