Corrective Action Plans

Finding 7791 (2022-002)

Significant Deficiency 2022

GA

Special Tests & Provisions School Nutrition Programs Significant Deficiency

Finding 2022-002 Golden Harvest Food Bank (GHFB) does not generate the Bill of Lading (BOL) for product being delivered. The USDA instructs vendors to include several numbers to be annotated on the BOL for reporting reasons. These numbers start with 1000, 2000, 3000, 4000, and 5000. There are occas...

Finding 2022-002 Golden Harvest Food Bank (GHFB) does not generate the Bill of Lading (BOL) for product being delivered. The USDA instructs vendors to include several numbers to be annotated on the BOL for reporting reasons. These numbers start with 1000, 2000, 3000, 4000, and 5000. There are occasions where some of these numbers are not included on the accompanying BOL when delivered. GHFB personnel look for any of the above numbers to insure items are TEFAP. As required, GHFB is required to report the receipt of the TEFAP items to the appropriate state entity that manages the TEFAP program. This report requests the 4000 and the 5000 numbers. If either one of those numbers is not on the BOL, the omission is annotated in this report. In addition to these numbers GHFB also maintains a listing of TEFAP products due in the first 15 days of the month and TEFAP products due in the second half of each month. GHFB believes all BOL have been signed by our personnel. Going forward all BOLs will be signed by both the individual who receives the product as well as the warehouse or inventory manager. Person responsible: Norman Stafford...10/1/23 completion date

View Audit 10130

Finding 7789 (2022-007)

Material Weakness 2022

Televerde Foundation, Inc.

AZ

Questioned Costs Cash Management Material Weakness § 200.303

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s internal controls were not designed to properl...

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s internal controls were not designed to properly ensure a review over program expenditures occurred that expenses being incurred and the basis for ultimate reimbursement were incurred within the grant award’s period of performance. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will implement controls that address whether expenses incurred have a basis for reimbursement and are incurred within the period of performance. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: March 2024

View Audit 10124

Finding 7788 (2022-006)

Material Weakness 2022

Televerde Foundation, Inc.

AZ

Questioned Costs Material Weakness Reporting § 200.303 § 200.327 § 200.328

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s existing controls over federal award reporting...

U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s existing controls over federal award reporting did not identify and correct that reports submitted to the grantor were submitted with inaccurate information and that the supporting documentation used to prepare the reports were utilizing budgeted expensed amounts rather than actual. Furthermore, the budgeted expensed amounts from the supporting documentation that were the basis for the amounts to report, did not agree with the ultimate amount reported. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will leverage our general ledger to retain documentation for approval and review of expenditures. We will utilize actual amounts for expenditures and in circumstances where budgeted amounts are needed, we will perform a true-up on a quarterly basis. Management will perform quarterly reviews over financial reporting. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: July 2023

View Audit 10124

Finding 7709 (2022-001)

Material Weakness 2022

Scottsdale Unified School District No. 48

AZ

Questioned Costs Material Weakness Reporting

Corrective Action Plan: The District will ensure its Schedule of Expenditures of Federal Awards is complete and expenditures are properly reported.

View Audit 10075

Finding 7614 (2022-003)

Material Weakness 2022

Community Action Partnership of Oregon

OR

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.305

Corrective Action: The lack of timeliness in payouts to SSVF subrecipients was largely due to the transition CAPO underwent in fiscal providers in 2022, and to a lack of sufficient internal staff to adequately manage the SSVF program’s growing fiscal requirements. The amount of SSVF funding CAPO pa...

Corrective Action: The lack of timeliness in payouts to SSVF subrecipients was largely due to the transition CAPO underwent in fiscal providers in 2022, and to a lack of sufficient internal staff to adequately manage the SSVF program’s growing fiscal requirements. The amount of SSVF funding CAPO passes through has increased significantly since 2021, and existing staffing was insufficient to assure timely tracking of draws and payments. Since moving to SMJ and hiring a Finance Manager, CAPO has improved the fiscal management of this grant considerably. CAPO is also hiring an Account Specialist to be assigned directly to SSVF invoicing and accounting needs. They will be charged to the VA grant and will work with the SSVF Program Manager and CAPO’s Finance Manager to process invoices, draw funds, and issue payments. Person Responsible: Janet Allanach, Rose Bradshaw, SSVF Program Manager; Shane Melton, Finance Manager. Timing for Implementation: Partially complete/In progress until December 31st, 2023, completion.

View Audit 9980

Finding 7613 (2022-002)

Significant Deficiency 2022

Community Action Partnership of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles Reporting

Corrective Action: CAPO was unable to locate Board minutes from FY 22 that indicate any increase in compensation for Janet Merrell (prior Executive Director through May 2022). We have been informed by the Board that the last increase was likely prior to 2020, as she had requested additional time of...

Corrective Action: CAPO was unable to locate Board minutes from FY 22 that indicate any increase in compensation for Janet Merrell (prior Executive Director through May 2022). We have been informed by the Board that the last increase was likely prior to 2020, as she had requested additional time off in lieu of additional salary increases. The last record of an evaluation is in the minutes from a Board meeting in August of 2020. Discussion of compensation would have occurred during an Executive Session and would be in the possession of the Secretary at the time and not in CAPO files. Currently, Executive session notes are kept by the Treasurer and will be carefully retained for and accessible to future audits. Person Responsible: CAPO Board of Directors Timing for Implementation: Complete

View Audit 9980

Finding 7612 (2022-001)

Significant Deficiency 2022

Community Action Partnership of Oregon

OR

Questioned Costs Allowable Costs / Cost Principles Reporting

Corrective Action: Immediately after coming on board in May of 2022, the new Executive Director took action to move CAPO’s fiscal services contract from the current provider to a new accounting firm in Portland, Oregon – Susan Matlack Jones and Associates (SMJ) – as of July 1, 2022. SMJ works with ...

Corrective Action: Immediately after coming on board in May of 2022, the new Executive Director took action to move CAPO’s fiscal services contract from the current provider to a new accounting firm in Portland, Oregon – Susan Matlack Jones and Associates (SMJ) – as of July 1, 2022. SMJ works with several Community Action agencies in Oregon and their expertise is specifically in nonprofit accounting. They worked to resolve accounting issues from the latter half of FY 22 for the purposes of the audit and currently produce timely, accurate financial statements for CAPO management and Board review. As of October 2023, CAPO has also hired an in-house Finance Manager with experience in Community Action and federal fund accounting. Person Responsible: Janet Allanach, CAPO Executive Director Timing for Implementation: Complete as of July 1, 2022.

View Audit 9980

Finding 7547 (2022-003)

Material Weakness 2022

Columbus Community School District

IA

Internal Control / Segregation of Duties Reporting

The district continues to find solutions to help segregate duties with our minimally staffed central office (business manager, HR director & nutrition direct). This year we modified duties of our building secretaries due to being short staffed. This eliminated an additional check & balance measure a...

The district continues to find solutions to help segregate duties with our minimally staffed central office (business manager, HR director & nutrition direct). This year we modified duties of our building secretaries due to being short staffed. This eliminated an additional check & balance measure added a few years ago of the secretary entering receipts into WebLink. The building secretaries continue to write deposit slips & post payment to our student information system. The district’s business manager & HR director will work with board members on the finance & negotiations committee to develop a plan to add more checks & balances to our current operation. We will use the segregation of duties handbook to help with this process.

View Audit 9858

Finding 7531 (2022-002)

Material Weakness 2022

Aplington Parkersburg Community School District

IA

Internal Control / Segregation of Duties Reporting

We will continue to review procedures and re-align duties to obtain the maximum internal control possible.

View Audit 9832

Finding 7497 (2022-002)

Significant Deficiency 2022

Food Export USA - Northeast

PA

Questioned Costs Allowable Costs / Cost Principles Cash Management

DEPARTMENT OF AGRICULTURE. Market Access Program and Agricultural Trade Promotion Program Assistance Listing Number: 10.601 & 10.618. Recommendation: We recommend the Organization ensure the completion of the controls within their policies to ensure an adequate review process is in place prior to ca...

DEPARTMENT OF AGRICULTURE. Market Access Program and Agricultural Trade Promotion Program Assistance Listing Number: 10.601 & 10.618. Recommendation: We recommend the Organization ensure the completion of the controls within their policies to ensure an adequate review process is in place prior to cash disbursement payments and claims submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Food Export-Northeast, under the direction of the new Executive Director /CEO, has undergone a significant restructuring effective July 2023. This restructure has resulted in the installation of a Chief Financial Officer, reporting directly to the Executive Director/CEO. Similar “C-suite” positions now exist in Operations, Programs, and Communications. This has significantly increased the scope and ability for oversight and internal control. Internal policies and procedures are currently under review; any changes to policies and procedures will be made as needed/identified. Increased monitoring and enforcement of existing internal control measures has already resulted in improved completeness and accuracy of financial reporting. In September 2023, the Food Export staff met with FAS staff to review procedures and policies, including meetings with Management to review and evaluate controls. The feedback from those meetings will be incorporated into any updates on procedure. Names of the contact person(s) responsible for corrective action: Brendan Wilson, Food Export Executive Director/CEO; Michelle Rogowski, Chief Operating Officer, Laura England, Deputy Director/Chief Communications Officer; Robert Lowe, CPA, Chief Financial Officer; Teresa Miller, Chief Program and Partnership Officer. Planned completion date for corrective action plan: December 31, 2023. If the U.S. Department of Agriculture has questions regarding this plan, please call Laura England at (215) 599-9738 or contact via email at lengland@foodexport.org.

View Audit 9730

Finding 7458 (2022-004)

Material Weakness 2022

The Methodist Home of Kentucky, Inc.

KY

Questioned Costs Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Action Taken: The Home will review and incorporate internal controls related to the written approval requirement to obtain written approval from the Office of Refugee Resettlement for the acquisition, construction or purchase of major capital improvements.

View Audit 9623 Questioned Costs: $1

Finding 7386 (2022-006)

Significant Deficiency 2022

Change, Inc.

MN

Questioned Costs Reporting Significant Deficiency

Infrequently, the Executive or Associate Director prepares and submits reports. As the organization’s report reviewer, the Executive Director submitted the report as preparer and reviewer. Going forward, the Executive Director will have the Associate Director or Business Director review any Executiv...

Infrequently, the Executive or Associate Director prepares and submits reports. As the organization’s report reviewer, the Executive Director submitted the report as preparer and reviewer. Going forward, the Executive Director will have the Associate Director or Business Director review any Executive Director prepared reports.

View Audit 9524

Finding 7381 (2022-007)

Material Weakness 2022

Change, Inc.

MN

Questioned Costs Material Weakness Reporting

This was a finding on our most recent audit as well (2021-007). Throughout FY23, we worked with our FPO and the Department of Labor to better understand the requirement and have adjusted our procedure as required. All errors have been corrected as of December 31, 2022.

View Audit 9524

Finding 7379 (2022-003)

Material Weakness 2022

Change, Inc.

MN

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

Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon training completion, the team will provide the Finance Committee of the Board of Directors suggested updates ...

Our Associate Director, Business Director and Operations Director will attend procurement, suspension, and debarment training to better learn the 2 CFR sections 200.318 through 200.326. Upon training completion, the team will provide the Finance Committee of the Board of Directors suggested updates to our current policy.

View Audit 9524

Finding 7352 (2022-002)

Significant Deficiency 2022

The Housing Collective, Inc.

CT

Questioned Costs Reporting Significant Deficiency

Finding No. 2022-002: Annual Audit Submission Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the data collection form an...

Finding No. 2022-002: Annual Audit Submission Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: As per the Code of Federal Regulations, Section 200.512 - Report Submission, the audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditors' report, or nine months after the end of the audit period. The due date for the submission was September 30, 2023. The audit and reporting package were not submitted by the due date September 30, 2023. Statement of Concurrence or Nonconcurrence: The organization agrees with the audit finding. Corrective Action: The organization intends to become fully staffed in the Finance Department in order to conduct its financial tasks in a timely fashion. It also intends to have its Finance staff cross-trained to ensure required tasks are conducted in a timely fashion. A timeline has been established and activities have begun for the 2023 audit. This will ensure that the 2023 report is submitted within the timeframe required. Name of Contact Person: David Rich, Executive Director david@shworks.org 860-671-1715 Projected Completion Date: December 12, 2023, this corrective action has been completed and will be maintained.

View Audit 9499

Finding 7331 (2022-001)

Material Weakness 2022

The Housing Collective, Inc.

CT

Internal Control / Segregation of Duties Questioned Costs Material Weakness

Finding No. 2022-001: Financial Reporting Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: In fiscal year 2022, the Organization's accounting processes and internal controls over financial reporting were not functioning timely to s...

Finding No. 2022-001: Financial Reporting Assistance Listing Program Title and Number: All Federal Agency: All Pass-through Entity: All Description of Finding: In fiscal year 2022, the Organization's accounting processes and internal controls over financial reporting were not functioning timely to support generating complete and accurate financial information. The year end was not closed in accordance with the Organization's financial close policy. The books and records were not closed and finalized until many months after year end. Statement of Concurrence or Nonconcurrence: The organization agrees with the audit finding. Corrective Action: The organization intends to become fully staffed in the Finance area in order to conduct its financial tasks in a timely fashion. It also intends to have its Finance staff cross-trained to ensure required tasks are conducted in a timely fashion. This will ensure that the year-end was closed in accordance with the organization's financial close policy and repeated revisions will not be necessary. Name of Contact Person: David Rich, Executive Director david@shworks.org 860-671-1715 Projected Completion Date: December 12, 2023, this corrective action has been completed and will be maintained.

View Audit 9499

Finding 7225 (2022-007)

Significant Deficiency 2022

MacOn and Piatt Counties Regional Office of Education No. 39

IL

Reporting Internal Control / Segregation of Duties § 200.303 § 200.510

CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. PLAN: The ROE will work with the...

CONDITION: The ROE did not have sufficient internal controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) to ensure all federal expenditures during the fiscal year were reported and information in the SEFA was accurately reported. PLAN: The ROE will work with their contracted accounting firm to review financial statements, including the schedule of expenditures of federal awards, to ensure program titles, assistance listing numbers and other pertinent information is accurate for financial statement presentation. ANTICIPATED DATE OF COMPLETION: The anticipated date of completion is December 2023. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

View Audit 9381

Finding 7223 (2022-005)

Significant Deficiency 2022

MacOn and Piatt Counties Regional Office of Education No. 39

IL

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

CONDITION: The ROE did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. PLAN: Past practice and policy during the FY22 audit, allowed for the Business Manager to sign off on purchase orders and requisitions rel...

CONDITION: The ROE did not ensure costs or expenditures were adequately documented, reviewed, and approved to ensure allowability under the federal award. PLAN: Past practice and policy during the FY22 audit, allowed for the Business Manager to sign off on purchase orders and requisitions related to monthly, reoccurring bills. New management is working on updated fiscal policies. A new Accounts Payable employee was hired in March 2023 by ROE management and trained by the Business Manager, along with Program Directors, on procedures for expenditures. Procedures have been put into place to ensure that all expenditures are signed by the Program Director or Assistant/Regional Superintendent to indicate review and approval of expenditures. After being signed by a Program Director or Assistant/Regional Superintendent, the expenditure goes to the Business Office where the Business Manager will check for appropriate signatures and will pass on to Accounts Payable for a final check for appropriate signatures and supporting invoices prior to payment. ANTICIPATED DATE OF COMPLETION: This was implemented in March 2023. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

View Audit 9381

Finding 7222 (2022-002)

None 2022

MacOn and Piatt Counties Regional Office of Education No. 39

IL

Internal Control / Segregation of Duties Period of Performance Reporting § 200.303

CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education. PLAN: New ROE management is providing close oversight for the timely submission of grant expenditure and performance reports. The Regional Superintendent has created a shared calendar...

CONDITION: The ROE did not submit or timely submit the required reports to the Illinois State Board of Education. PLAN: New ROE management is providing close oversight for the timely submission of grant expenditure and performance reports. The Regional Superintendent has created a shared calendar of submission due dates with the Business Manager and Program Directors. Reminders are sent out via email in advance of the due dates, and then management reviews the grant report submissions in IWAS for accuracy and completion before approving and submitting to ISBE. ANTICIPATED DATE OF COMPLETION: This plan was initiated during the new Regional Superintendent’s appointment to office in October 2022 and has been fully implemented since January 2023. CONTACT PERSON: Ms. Jill Reedy, Regional Superintendent

View Audit 9381

Finding 7159 (2022-002)

Significant Deficiency 2022

New Beginning International Ministry Inc.

TN

Reporting Internal Control / Segregation of Duties

The Organization is working with their financial institution to see if statement closing dates can better align with the reporting period. The Organization will perform the reconciliation if no changes can be made with the bank

View Audit 9222

Finding 7158 (2022-001)

Significant Deficiency 2022

New Beginning International Ministry Inc.

TN

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

The Organization is in the process of working to obtain a general ledger system and someone that can assist the Organization in maintaining the system

View Audit 9222

Finding 7096 (2022-004)

Significant Deficiency 2022

The Fishing Partnership Health Plan Corporation D/b/a Fishing Partnership

MA

Internal Control / Segregation of Duties Questioned Costs Allowable Costs / Cost Principles § 200.430

Finding 2022-004 - Strengthen controls surrounding program-related record keeping including increasing the frequency of reconciliation's and program wage allocation procedures to match the payroll cycle. Program Affected Under the U.S. Department of Health and Human Services - Award Year October 1,...

Finding 2022-004 - Strengthen controls surrounding program-related record keeping including increasing the frequency of reconciliation's and program wage allocation procedures to match the payroll cycle. Program Affected Under the U.S. Department of Health and Human Services - Award Year October 1, 2021 - September 30, 2022: Assistance Listing 93.262 Occupational Safety and Health Program Corrective Action The Organization agrees with the finding. The Organization has implemented both time and effort reporting by pay period and wage reconciliations as part of a monthly close process. Responsible individual - JJ Bartlett Completion 9/30/2023

View Audit 9150 Questioned Costs: $1

Finding 7034 (2022-002)

Material Weakness 2022

Isaiah House

NJ

Questioned Costs Allowable Costs / Cost Principles Material Weakness

The Executive Director and Deputy Director will review and approve all reporting submissions to ensure they are being reported timely in accordance with grant requirements.

View Audit 9025

Finding 7008 (2022-001)

Significant Deficiency 2022

The Roskamp Institute, Inc.

FL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

VIEWS OF RESPONSIBLE OFFICIALS AND PLANNED CORRECTIVE ACTION: Management agrees with the finding and will implement a process to maintain all payroll allocations.

View Audit 9020

Finding 6965 (2022-004)

Material Weakness 2022

Fredericksburg Area Health and Support Services, Inc.

VA

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.430

Finding: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. The amount of payroll and related costs discovered to be incorrect was a net...

Finding: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. The amount of payroll and related costs discovered to be incorrect was a net amount of $25, which when projected onto the remaining payroll and related costs that were not tested, amounted to $1,038. Corrective Action Taken or Planned: The Organization will review audit findings and ensure accurate future reimbursements, develop a comprehensive process for verifying time sheets against service delivery, and implement a paper timesheet system in which supervisors must enter time based on timesheets, ensuring 1:1 reimbursement. Name of Contact Person: Jacob Ducey, Grants Manager Phone Number of Contact Person: (540) 907-4555 Projected Completion Date: October 31, 2023

View Audit 9001 Questioned Costs: $1

Corrective Action Plans

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