Corrective Action Plans

Finding 502482 (2021-013)

Significant Deficiency 2021

MH

Special Tests & Provisions Internal Control / Segregation of Duties

Special Tests and Provisions - Minimizing Duplication of Services under TS and UB Programs: Currently, the CMI Upward Bound program is the only TRIO program in the Republic of the Marshall Islands. Noting the need to formally document that there is no duplication, however, the college will add a qu...

Special Tests and Provisions - Minimizing Duplication of Services under TS and UB Programs: Currently, the CMI Upward Bound program is the only TRIO program in the Republic of the Marshall Islands. Noting the need to formally document that there is no duplication, however, the college will add a question regarding whether a student is participating in any other TRIO program to its Upward Bound application form moving forward. September 30, 2022 Stevenson Kotton VPBAA Pam Kaios UB Director

View Audit 324487

Finding 502481 (2021-012)

Material Weakness 2021

College of the Marshall Islands

MH

Questioned Costs Eligibility Internal Control / Segregation of Duties

Eligibility: The college noted the finding, and the program is working to gather all required documents from current and previous Upward Bound students. The program will use the college’s electronic filing system and the standards described in the Upward Bound grant application moving forward. Sep...

Eligibility: The college noted the finding, and the program is working to gather all required documents from current and previous Upward Bound students. The program will use the college’s electronic filing system and the standards described in the Upward Bound grant application moving forward. September 30, 2022 Stevenson Kotton VPBAA Pam Kaios UB Director

View Audit 324487 Questioned Costs: $1

Finding 502346 (2021-001)

Material Weakness 2021

Community Health Aide Services, Inc.

NY

Questioned Costs HUD Housing Programs Material Weakness

CORRECTIVE ACTION PLAN U.S. Department of Health and Human Services Community Health Aide Services, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2021. Name and address of independent public accounting firm: Bonadio & Co., LLP 100 Corporate Parkway...

CORRECTIVE ACTION PLAN U.S. Department of Health and Human Services Community Health Aide Services, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2021. Name and address of independent public accounting firm: Bonadio & Co., LLP 100 Corporate Parkway Suite 200 Amherst, New York 14226 Audit period: January 1, 2021 December 31, 2021 The material weakness from the December 31, 2021 schedule of findings and questioned costs is discussed below. It is numbered consistently with the numbers assigned in the schedule. Federal Award Finding and Questioned Costs Name of Contact Person: Joel Green, Financial Controller Anticipated Completion Date: December 31, 2024 2021-001 – Material Weakness Corrective Action Plan: Condition: Out of 40 transactions selected for testing, 4 selections were payroll transactions that lacked proper employee and management approval of the effective pay rate and one selection was a rental payment that did not have a supporting lease agreement. Recommendation: Establish policies and procedures to ensure proper retention of transaction documentation and internal control review. Current Status: Policies and procedures are being developed to properly meet the recommendation. If anyone has questions regarding this plan, please call Mr. Joel Green at (716) 285-9681.

View Audit 324388 Questioned Costs: $1

Finding 502335 (2021-007)

Material Weakness 2021

Alfalfa County

OK

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.318 § 200.84

In each of our districts we will practice oversight and due diligence over the documentation of Disaster Grant expenditures. We will review documents to ensure labor rates and equipment rates were those approved FEMA. We will acknowledge our review by signing the documents.

View Audit 324377 Questioned Costs: $1

Finding 502334 (2021-006)

Material Weakness 2021

Alfalfa County

OK

Special Tests & Provisions Allowable Costs / Cost Principles Period of Performance § 200.303

We will research the compliancerequirements for each Major Federal Grant the County receives. Withthe compliance requirements in mind, we will establish policies and procedures to satisfy those requirements and practice oversight over federal grant activity.

View Audit 324377

Finding 502333 (2021-005)

Material Weakness 2021

Alfalfa County

OK

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

The Officers of Alfalfa County will meet to discuss the County-Wide Controls over the administration of Major Federal Programs. After discussing and gaining input from all those involved, written procedures will be approved and distributed.

View Audit 324377

Finding 502205 (2021-002)

Material Weakness 2021

American Association of Physics Teachers, Inc.

MD

Internal Control / Segregation of Duties Material Weakness Matching / Level of Effort / Earmarking § 200.303

Finding 2021-002: Segregation of Duties Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431...

Finding 2021-002: Segregation of Duties Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education) Condition: The Chief Financial Officer is responsible for posting entries into the accounting system without a second level review, and obtaining all bank statements unopened while also having the ability to add or modify payees and unilaterally initiate and authorize electronic fund transfers such as automated clearing house payments. The CFO is also responsible for opening the mail which may contain payments by check, and can manually reduce receivable balances. Views of Responsible Officials and Planned Corrective Actions: AAPT has instituted the segregation of duties of submitting and approval of electronic payments. The senior accountant has been authorized to submit the ACH/Wire transfer requests. The CFO has the authorization of approval of submitted electronic payments. The change was activated around March 15, 2024 The staff will be trained on generating journal entries previous prepared by the CFO and supervised and approve by the CFO – completed date May 15, 2024 The administrative assistant of the CEO will come to AAPT twice weekly to process incoming mail and create an initial recordation log of checks or cash received. The administrative assistant will not have access in any system to enter/modify/delete any information related to checks that are received. Anticipated Completion Date: January 2025 Responsible Official: Michael Brosnan, CFO

View Audit 324370

Finding 502106 (2021-003)

Material Weakness 2021

Apsaalooke Nation Housing Authority

MT

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

2021-003 Finding: Special Tests and Provisions - Cash Collateralization (Compliance; Internal Controls over Compliance) The corrective actions implemented in FY 2022) Extraordinary circumstances beyond ANHA control. ANHA received large deposits from Treasury without notice and did not have the prop...

2021-003 Finding: Special Tests and Provisions - Cash Collateralization (Compliance; Internal Controls over Compliance) The corrective actions implemented in FY 2022) Extraordinary circumstances beyond ANHA control. ANHA received large deposits from Treasury without notice and did not have the proper cash collateralization in place. ANHA has since made agreements.

View Audit 324301

Finding 498574 (2021-004)

Material Weakness 2021

Wishek Hospital Clinic Association D/b/a South Central Health

ND

Questioned Costs Material Weakness Reporting § 200.33

Contact Person Megan Rath 2021-004 Corrective Action Plan The Association will implement that any future report submitted to HHS for Provider Relief Funds be reviewed and approved by a second reviewer from the Association. The Association will also enhance internal controls to ensure proper support...

Contact Person Megan Rath 2021-004 Corrective Action Plan The Association will implement that any future report submitted to HHS for Provider Relief Funds be reviewed and approved by a second reviewer from the Association. The Association will also enhance internal controls to ensure proper supporting calculations. Completion Date The corrective action plan steps were implemented in part in 2022 with continued improvements planned to be in place by October 1, 2024.

View Audit 321318 Questioned Costs: $1

Finding 496370 (2021-104)

Significant Deficiency 2021

Inter-Tribal Council of Nevada, Inc.

NV

Internal Control / Segregation of Duties

We agree with the finding and was primarily due to understaffing and turnover followed by additional staffing challenges during and post COVID 19 pandemic of 2020. Specifically, the program director position had multiple turnovers from 2019 to August 2023, when the current director assumed this role...

We agree with the finding and was primarily due to understaffing and turnover followed by additional staffing challenges during and post COVID 19 pandemic of 2020. Specifically, the program director position had multiple turnovers from 2019 to August 2023, when the current director assumed this role. Since August 2023, the new program director has initiated the integration of training sessions, instructional guides, and additional resources, alongside policy enhancements, to ensure that every WIC participant requiring a nutritional education care plan has it meticulously documented. Presently, we conduct daily audits of charts/files to mitigate instances of incomplete nutritional education care plans on a daily basis. We are presently investigating alternative opportunities to enhance our existing documentation of nutrition care plans, with a focus on improved identification based on appointment types to make up for some shortcomings in the system software used for WIC. Anticipated Completion Date: Ongoing

View Audit 319246

Finding 496357 (2021-101)

Material Weakness 2021

Inter-Tribal Council of Nevada, Inc.

NV

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

We agree with the findings 2021-001, 2021-003, and 2021-004, and acknowledge that this issue has been previously identified in past audits. The repeat occurrence was primarily due to understaffing and turnover within the finance, WIC, CCDF, Head Start, FVPP, and WIC departments, followed by addition...

We agree with the findings 2021-001, 2021-003, and 2021-004, and acknowledge that this issue has been previously identified in past audits. The repeat occurrence was primarily due to understaffing and turnover within the finance, WIC, CCDF, Head Start, FVPP, and WIC departments, followed by additional staffing challenges during and post COVID 19 pandemic of 2020. In addition to the Corrective Action Planned related to Finding 2020-101, with respect to the WIC, CCDF, Head Start and FVPP programs, the Executive Director has required additional training for the Program Directors on internal controls, and relevant fiscal and administrative grant training following review of the prior repeat audit findings. We have been implementing collaboration between program directors and fiscal staff to improve overall compliance for grant funds, including budgeting, reporting, policies and procedures and processes. Anticipated Completion Date: On-going – Final Grants Management Document expected to be presented and adopted by the ITCN executive board by September 30, 2025. The Final FY 2021 Financial Statements, including the Corrective Action Planned will be presented to the executive board and program directors for overview. The Executive Director will be responsible for on-going communication and engagement to improve internal controls, and regularly scheduling meetings for status updates on the Corrective Action Planned and review quarterly reports. Beginning January 2022, we have developed and drafted a grants management handbook as a resource for program and fiscal staff. As we continue to make improvements and amendments to internal processes and policies and procedures, the grants management will be updated, with a final copy presented to the Executive Board for adoption and approval.

View Audit 319246

Finding 485186 (2021-003)

Material Weakness 2021

Metro Area Continuum of Care for the Homeless

NE

Questioned Costs Allowable Costs / Cost Principles Cash Management

Corrective Action Plan For Year Ended December 31, 2021 Contact Person: Jason Feldhaus, Executive Director jason@thresholdcoc.org 402.290.6106 FINDING 2021-003: Allowable Costs All receipts for expenses of the Organization are attached to the transaction in bill.com, which then gets transferred to t...

Corrective Action Plan For Year Ended December 31, 2021 Contact Person: Jason Feldhaus, Executive Director jason@thresholdcoc.org 402.290.6106 FINDING 2021-003: Allowable Costs All receipts for expenses of the Organization are attached to the transaction in bill.com, which then gets transferred to the accounting system, QuickBooks Online. Additionally, backup for landlord payments is saved in a separate folder for reference. Prior to payment approval of an expense, the approver confirms there is adequate backup for the allowable costs. A policy will be included in the updated Financial Policies and Procedures manual in 2024. Reasonable completion date: Already implemented (October 31, 2024 for policy updates) Responsible Party: Jason Feldhaus, Executive Director

View Audit 317998 Questioned Costs: $1

Finding 485128 (2021-003)

Material Weakness 2021

Cheyenne and Arapaho Tribes Department of Housing

OK

HUD Housing Programs Internal Control / Segregation of Duties

2021-003 Condition: Deficiencies Noted in Maintenance of the Cash Receipts and Deposits and the Tenant Accounts Receivable Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be clea...

2021-003 Condition: Deficiencies Noted in Maintenance of the Cash Receipts and Deposits and the Tenant Accounts Receivable Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2022

View Audit 317920

Finding 485127 (2021-002)

Material Weakness 2021

Cheyenne and Arapaho Tribes Department of Housing

OK

Procurement, Suspension & Debarment HUD Housing Programs Internal Control / Segregation of Duties

2021-002 Condition: Deficiencies Noted in Cash Disbursements Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsi...

2021-002 Condition: Deficiencies Noted in Cash Disbursements Steps to resolve: Management agrees with the audit finding and the auditor’s recommendation. We will implement procedures and changes to ensure that this finding will be cleared by the subsequent fiscal year audit. Individual responsible for correction: Mr. Damon Dunbar, Executive Director Timeframe: As of December 31, 2022

View Audit 317920

Finding 484788 (2021-001)

Significant Deficiency 2021

Atlantic County Improvement Authority

NJ

Reporting Internal Control / Segregation of Duties

Recommendation: We recommend the Authority implement a formalized closing process at least on an annual basis for all financial statement areas. The close process should include an in-depth analysis of all significant accounts, including recording all prior-year audit entries. All significant accoun...

Recommendation: We recommend the Authority implement a formalized closing process at least on an annual basis for all financial statement areas. The close process should include an in-depth analysis of all significant accounts, including recording all prior-year audit entries. All significant accounts should have supporting schedules that are prepared and reviewed by separate individuals within the Authority to ensure proper segregation of duties. Furthermore, supporting schedules should agree to the corresponding general ledger accounts. Implementation of these recommendations will improve financial reporting processes and internal controls of the Authority and result in a financial close with minimal proposed adjusting entries. Management’s response: Management will ensure proper segregation of duties and enhanced oversight, providing improved internal controls. Financial procedures and standard operating procedures will be revised, formalized and put into place.

View Audit 317722

Finding 480952 (2021-004)

Significant Deficiency 2021

Luna County

NM

Questioned Costs Subrecipient Monitoring Significant Deficiency

2021-004 – High Intensity Drug Trafficking Areas (HIDTA) Overtime Violation (Signficant Deficiency) (Repeated finding FS 2020-005) - During the FY 2020 audit process it was discovered that Luna County had one employees which did not adhere to the HIDTA Program Policy on limitations of overtime. Luna...

2021-004 – High Intensity Drug Trafficking Areas (HIDTA) Overtime Violation (Signficant Deficiency) (Repeated finding FS 2020-005) - During the FY 2020 audit process it was discovered that Luna County had one employees which did not adhere to the HIDTA Program Policy on limitations of overtime. Luna County management along with the Program Commander and Luna County Sheriff will monitor OT more closely to ensure that no employee exceeds the maximum allowable earnings. Luna County will be monitoring all Federal programs to ensure compliance with contract/award guidelines on combined OT limits. In addition, the one employee this affected is no longer employed, however Luna County will continue due diligence to ensure that OT limits are strictly adhered to.

View Audit 317065 Questioned Costs: $1

Finding 480927 (2021-009)

Material Weakness 2021

Puerto Rico Electric Power Authority

PR

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Management acknowledges the findings and has implemented a corrective action plan to develop Standard Operating Procedures (SOPs) for current Grant management activities in order to assure that only expenditures incurred in each approved Project Worksheet (PW) that are not subsequently disallowed by...

Management acknowledges the findings and has implemented a corrective action plan to develop Standard Operating Procedures (SOPs) for current Grant management activities in order to assure that only expenditures incurred in each approved Project Worksheet (PW) that are not subsequently disallowed by the Federal Agency are included in the SEFA. In addition, the SEFA was amended to reflect PW expenditure in the accrual basis of accounting. Effective June 1, 2021, the Authority transitioned the management and operation of its transmission and distribution network as well as certain back- office functions, including billing, collections and accounting, to a third party. The third-party operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. Management will work to address these findings with the assistance of the third-party operators, where applicable. Also, effective July 1, 2023, the Authority transitioned the management and operation of its generation assets as well as certain back- office functions to a third party. The thirdparty operator is reviewing operating procedures and controls within its responsibilities to make the necessary improvements. In addition, the Authority will also be implementing and monitoring corrective actions taken by the new generation segment operator. Contact Name Responsible for Corrective Action Plan - Nelson Morales Estimated Completion Date - July 2025

View Audit 317030

Finding 480685 (2021-001)

Significant Deficiency 2021

Puerto Rico Office Management and Budget

PR

Subrecipient Monitoring Reporting Significant Deficiency

3 de julio de 2024 Section II – Federal Award Findings and Questioned Costs Finding Number: 2021-001 Agency: Puerto Rico Office of Management and Budget Federal Program: Coronaviru...

3 de julio de 2024 Section II – Federal Award Findings and Questioned Costs Finding Number: 2021-001 Agency: Puerto Rico Office of Management and Budget Federal Program: Coronavirus Relief Fund Assistant listing number: 21.019 Grant Number: N/AV Grant Period: July 1, 2020 through June 30, 2021 Compliance Requirement: Reporting Category: Significant Deficiency and noncompliance over federal program Condition: During our audit of June 30, 2021 financial statement, we noted that single audit report for fiscal year 2020-2021 was not submitted by September 30, 2022. Cause: Missing of internal controls over financial reporting to produce financial statement on timely basis to comply with OMB reporting deadlines. Effect: Non-compliance with the above-mentioned requirement could lead to administrative actions by the grantor. It could also be interpreted as a failure to manage federal awards in compliance with laws, regulations, and provisions of contracts and grant agreements. Recommendation: To improve, execute and monitors accounting periods end closings as planned in order to get a financial statement on time to comply with required deadlines. Also, keep track and communication of federal programs compliances with regulatory parties and among agency’s responsible departments involve and establish a program deadline calendar. Questioned Costs: None Perspective of the information: Single audit report was issued after due date. The information was not drawn from a statistical sample. Calle Cruz #254 Esq. Tetuán, San Juan, PR / PO Box 9023228, San Juan, PR 00902-3228 Management response: 3 de julio de 2024 Section II – Federal Award Findings and Questioned Costs Finding Number: 2021-001 Agency: Puerto Rico Office of Management and Budget Federal Program: Coronavirus Relief Fund Assistant listing number: 21.019 Grant Number: N/AV Grant Period: July 1, 2020 through June 30, 2021 Compliance Requirement: Reporting Category: Significant Deficiency and noncompliance over federal program Condition: During our audit of June 30, 2021 financial statement, we noted that single audit report for fiscal year 2020-2021 was not submitted by September 30, 2022. Cause: Missing of internal controls over financial reporting to produce financial statement on timely basis to comply with OMB reporting deadlines. Effect: Non-compliance with the above-mentioned requirement could lead to administrative actions by the grantor. It could also be interpreted as a failure to manage federal awards in compliance with laws, regulations, and provisions of contracts and grant agreements. Recommendation: To improve, execute and monitors accounting periods end closings as planned in order to get a financial statement on time to comply with required deadlines. Also, keep track and communication of federal programs compliances with regulatory parties and among agency’s responsible departments involve and establish a program deadline calendar. Questioned Costs: None Perspective of the information: Single audit report was issued after due date. The information was not drawn from a statistical sample. Calle Cruz #254 Esq. Tetuán, San Juan, PR / PO Box 9023228, San Juan, PR 00902-3228 Management response: The Puerto Rico Office of Management and Budget (OMB) acknowledges the finding and the importance of complying with the OMB Uniform Guidance for single audits. The following actions have been taken and will continue to be implemented to ensure compliance: 1. Contracting External Audit Firms: o Action Taken: OMB has contracted qualified external audit firms to conduct the single audits to ensure compliance with federal requirements. o Outcome: This measure has resolved the immediate issue of non- compliance by ensuring timely submission of audit reports. The OMB complied with instructions from the Puerto Rico Fiscal Agency and Financial Advisory Authority (AAFAF) regarding reports related to these funds. The OMB presumed that AAFAF was responsible for the final report and audit to the federal government. The OMB will continue monitoring the use and disbursement of federal funds to comply with state and federal regulations. Responsible Officer: Mrs. Nivis González Rodríguez Estimated Completion Date: July 2024

View Audit 316913

Finding 480533 (2021-003)

Significant Deficiency 2021

Central Iowa Shelter & Services

IA

Internal Control / Segregation of Duties Cash Management

We will implement procedures to ensure claims are reviewed and approved by someone independent of the preparer

View Audit 316733

Finding 480519 (2021-003)

Material Weakness 2021

Virginia Commonwealth University Health System

VA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Corrective action plan over control environment over lost revenue COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s procedures for calculating lost revenues for the purposes of PRF reporting should be designed to ensure that audited year end numbers ar...

Corrective action plan over control environment over lost revenue COVID – 19 – Provider Relief Funding (Assistance Listing #93.498) Recommendation: The Authority’s procedures for calculating lost revenues for the purposes of PRF reporting should be designed to ensure that audited year end numbers are reported and/or tied back to amounts that are reported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: As of July 2024, there is no further lost revenue reporting that is required to be reported. Management will implement more robust internal controls in preparation for similar future grant reporting. For lost revenues that have been submitted for PRF that do not tie back to an audited financial statement, a reconciliation will be completed and documented. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 703-629-8155 Planned completion date for corrective action plan: July 31, 2024 and going forward.

View Audit 316713

Finding 480518 (2021-002)

Material Weakness 2021

Virginia Commonwealth University Health System

VA

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Cash Management

Corrective action plan over control environment over completeness and accuracy of expenditures COVID – 19 – Coronavirus Relief Fund (Assistance Listing # 21.019) Recommendation: The Authority’s develop and implement effective internal controls to ensure that expenditures are reviewed for completenes...

Corrective action plan over control environment over completeness and accuracy of expenditures COVID – 19 – Coronavirus Relief Fund (Assistance Listing # 21.019) Recommendation: The Authority’s develop and implement effective internal controls to ensure that expenditures are reviewed for completeness and accuracy to ensure that the terms and conditions are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: This program has ended. Management will enhance its procedures around the completeness and accuracy of expenditure schedules for similar future grant expenditures. Evidence of review and approval of supporting documentation of the expenditures related to report submissions will be documented. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 703-629-8155 Planned completion date for corrective action plan: July 31, 2024 and going forward.

View Audit 316713

Finding 480062 (2021-005)

Material Weakness 2021

Cornerstones Inc, Cornerstones Housing Corporation & Rihc Partners, Lp

VA

Eligibility Material Weakness Internal Control / Segregation of Duties

Cornerstones acknowledges that our files were incomplete. It is our position that the COVID-19 pandemic created immense need to which Cornerstones responded by expanding rapidly and mobilizing funding and program requests that did not receive the benefit of comprehensive planning; the focus was on h...

Cornerstones acknowledges that our files were incomplete. It is our position that the COVID-19 pandemic created immense need to which Cornerstones responded by expanding rapidly and mobilizing funding and program requests that did not receive the benefit of comprehensive planning; the focus was on health prevention, isolation and quarantine activities and temporary shelter for homeless and other low-income, vulnerable seniors and disabled persons. We served those in need and our intake processes and record keeping did not keep pace. Additionally, given the time that has passed since the services in question, it is possible that records that did exist were misplaced. Staff turnover, resulting from the pandemic burden, made it challenging to go back to the work that had been done. In the time since these events Cornerstones has further emphasized the compliance and documentation needs of the case management process, and we have filled turned-over positions with experienced staff that also understand intake and documentation requirements. We have also hired a Senior Director, Finance with over 20 years of federal contracts experience that is an integral part of increased program compliance and operational oversight responsibilities within the Finance/Operations function.

View Audit 316340

Finding 479746 (2021-004)

Material Weakness 2021

Cambria Heights School District

PA

School Nutrition Programs Internal Control / Segregation of Duties Reporting

CONDITION: The District did not maintain a general ledger system of accounting for its Cafeteria Fund which reports the financial activity of the federal National School Lunch and School Breakfast Programs. The financial activity occurring in this Fund is maintained in checkbook fashion during the f...

CONDITION: The District did not maintain a general ledger system of accounting for its Cafeteria Fund which reports the financial activity of the federal National School Lunch and School Breakfast Programs. The financial activity occurring in this Fund is maintained in checkbook fashion during the fiscal year. This is a repeat finding (2020-004) from the previous fiscal year. CRITERIA: Prudent internal control over accounting for federal program funds requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the receipt and use of federal funds as stated in Section 2 CFR Part 200 of the Uniform Guidance. Best practices suggest that the use of a general ledger system of accounting would enable the District to aggregate financial information involving federal funds during the fiscal year in such a manner to properly manage, monitor, and report the financial activity in compliance with federal program guidelines. RECOMMENDATION: During the 2018-2019 fiscal year, the District implemented new accounting software that can readily account for the financial activity of all Funds in a manner like the District’s General Fund. I am recommending that the management of the School District utilize the new accounting software to enter the financial activity (Receipts and Disbursements) of the Cafeteria Fund in a manner like the General Fund. This procedure will significantly enhance the District-wide internal controls over financial reporting for the Cafeteria Fund, as well as provide management the ability to produce meaningful financial reports reflecting the activity in the Cafeteria Fund for prudent oversight by the Board of Education. In addition, this procedure will enable the District to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200 of the Uniform Guidance. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is reviewing its current system of processing the transactions for the Cafeteria Fund to determine the most efficient and effective manner for implementation of a general ledger system of accounting for this Fund as opposed to its current manual process. It is anticipated that the conversion of this Fund into the District’s accounting software can be completed during the 2024-2025 fiscal year to enable the District to comply with the recordkeeping requirements for federal funds as specified in 2 CFR Part 200 of the Uniform Guidance.

View Audit 316302

Finding 479728 (2021-005)

Material Weakness 2021

Cambria Heights School District

PA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.302

CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office o...

CONDITION: The District did not properly record its federal program expenditures for the GEER, ESSER, and ARP ESSER federal grant programs using the various federal funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations. CRITERIA: The Pennsylvania Department of Education (PDE), through the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts requires School Districts to utilize specific funding source codes for federal program expenditures. In addition, Section 2 CFR 200.302(a) and 302(b) of the Uniform Guidance requires non-federal organizations such as the School District to maintain financial records which account for federal funds in such a manner as to be able to properly track the identification and use of federal funds. RECOMMENDATION: I am recommending that the School District properly follow the guidance contained within the PA Office of the Budget, Office of Comptroller Operations Chart of Accounts for recording all expenditures of the School District, most specifically, federal program grant expenditures to 1) enhance internal controls for tracking and monitoring federal program expenditures and 2) comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations. MANAGEMENT’S CORRECTIVE ACTION PLAN: District management is in the process of revising its chart of accounts in the general ledger to properly reflect the funding source codes for federal program expenditures, and other available funding source codes (state and local) as applicable to the District. It is anticipated that the updated chart of accounts will be utilized by the District starting with the 2024-2025 fiscal year to enable the District to enhance its internal controls for tracking and monitoring federal program expenditures and to comply with the recordkeeping requirements for federal funds as specified in Section 2 CFR Part 200.302(a) and 302(b) of the Uniform Guidance and PDE regulations.

View Audit 316302

Finding 479704 (2021-004)

Significant Deficiency 2021

City of Pekin

IL

Internal Control / Segregation of Duties

The Director of Finance, along with staff, will review year-end adjustments as part of the audit preparation process and work to reduce the number of entries proposed by the auditors and prepare fully adjusted financial statements prior to audit fieldwork. The Finance Department will conduct monthly...

The Director of Finance, along with staff, will review year-end adjustments as part of the audit preparation process and work to reduce the number of entries proposed by the auditors and prepare fully adjusted financial statements prior to audit fieldwork. The Finance Department will conduct monthly reconciliations and perform month end closing procedures to better prepare for year end adjustments and audit field work. The Finance Department will review, expand and complete its list of monthly closing procedures and year end adjustment reconciliations prior to audit fieldwork.

View Audit 316258

Corrective Action Plans

Filters