Corrective Action Plans

Finding 499214 (2023-001)

Material Weakness 2023

Southwest Behavioral Health Services, Inc. and Subsidiaries

AZ

Subrecipient Monitoring Reporting Material Weakness § 200.303

Finding Number: 2023-001- Schedule of Expenditures of Federal Awards (SEFA) Preparation – Material Weakness Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control ...

Finding Number: 2023-001- Schedule of Expenditures of Federal Awards (SEFA) Preparation – Material Weakness Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the federal award to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. This includes properly identifying all federal awards subject to the Uniform Guidance and fairly presenting the required information in the schedule of expenditures of federal awards. Condition: Subsequent to the issuance of the Audit Report on the Consolidated Financial Statements and Supplementary Information for the year ended September 30, 2023, it was discovered that there was an omission of two federal grants with expenditures totaling $1,591,715 from the schedule of expenditures of federal awards. Cause: The Organization did not communicate with Care 1st Health Plan regarding the details of certain contracts to determine the amounts were subject to the Uniform Guidance and were to be included on the schedule of expenditures of federal awards. In addition, Care 1st Health Plan became the Regional Behavioral Health Authority for the Northern Arizona region effective October 1, 2022. Due to this transition, various changes occurred causing uncertainties with classifications of certain types of federal awards as subrecipient awards versus as contractor payments. Effect: The schedule of expenditures of federal awards was understated by $1,591,715, which resulted in the restatement of the previously issued schedule of expenditures of federal awards to correct the omission. Questioned Costs: Not applicable. Recommendation: We recommend that all funding contracts are carefully reviewed to determine whether amounts awarded should be classified as contractor payments or as subrecipient payments. If there is any uncertainty, we recommend that the Organization contact the funding source for clarification. Name of Contact Person: Mike Fett, CFO Phone Number: 602-265-8338 Anticipated Completion Date: September 30, 2024 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish procedures to review all contracts and to if necessary, to communicate with funding sources to ensure that receipts of federal funding are properly classified as being subrecipient versus contractor arrangements to ensure completeness of the Schedule of Expenditures of Federal Awards.

View Audit 322000

Finding 499182 (2023-004)

Significant Deficiency 2023

Shiloh Home Inc.

CO

Reporting Internal Control / Segregation of Duties Significant Deficiency § 200.328

Corrective Action Plan: Management is developing a process to include a periodic review of all compliance aspects related to the grants including financial and performance reporting. This will be completed by December 31, 2024. Individual responsible for corrective action plan: Steven Ramirez

View Audit 321973

Finding 499165 (2023-001)

Significant Deficiency 2023

National Casa Association

WA

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.300 § 200.306 § 200.308 § 200.309 § 200.403

Responsible: Thomas Hoover, Chief Financial Officer Corrective Actions: Updated Finance policies: Specify that documentation of review and approval of costs charged to federal grants be maintained and that costs are recorded in the appropriate grant funding period. Completion Date: July 10, 2024...

Responsible: Thomas Hoover, Chief Financial Officer Corrective Actions: Updated Finance policies: Specify that documentation of review and approval of costs charged to federal grants be maintained and that costs are recorded in the appropriate grant funding period. Completion Date: July 10, 2024. Explanation: Policies have been in place over the coding of costs allocated to federal grants in compliance with CFR 200 and were enhanced in 2023 in response to an OJJDP/OCFO recommendation. Review and approval of costs after being approved by an authorized signer takes place in multiple steps and concludes with preparation of reimbursements and financial grant reports (FFR). In order to further demonstrate compliance as recommended, Management updated Finance policies to capture the documentation and approval of cost allocation methods and coding of costs to federal grants and maintenance of such documentation of Supervisory review and approval. Policies already in place specified that supporting and source documentation be maintained for at least 3 years, in compliance with federal grant requirements. In addition, the updated policy specifies that grant costs be recorded in the appropriate grant funding (fiscal) period. Four transactions sampled were partially or fully recorded in the incorrect funding (fiscal) period, though they were within the grant period.

View Audit 321944 Questioned Costs: $1

Finding 499149 (2023-001)

Significant Deficiency 2023

Finger Lakes Regional Health System Inc. Dba Finger Lakes Health

NY

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

The System will be terminating the contract with the outside third party and bringing administration of the program internal to increase communications and verifications of the start and ending dates of our programs. Monthly meetings will continue to occur with financial aid, finance and the bursar...

The System will be terminating the contract with the outside third party and bringing administration of the program internal to increase communications and verifications of the start and ending dates of our programs. Monthly meetings will continue to occur with financial aid, finance and the bursar to ensure that timing is within regulations. This will be effective January 1, 2025.

View Audit 321924

Finding 499148 (2023-004)

Significant Deficiency 2023

Children's Hospital Medical Center of Akron

OH

Allowable Costs / Cost Principles Cash Management Reporting § 200.303

Finding: Management did not have an internal control in place to review the allowability of the expenses to be allocated to the Congressional Directives grant. Corrective Action Plan: Akron Children's will implement a more detailed review and documentation process for allowable expenses prior to de...

Finding: Management did not have an internal control in place to review the allowability of the expenses to be allocated to the Congressional Directives grant. Corrective Action Plan: Akron Children's will implement a more detailed review and documentation process for allowable expenses prior to determining expenses that are eligible for federal grant reimbursement. Responsible Party: Vice President Finance Completion Date: November 30, 2024

View Audit 321917

Finding 499147 (2023-005)

Material Weakness 2023

Children's Hospital Medical Center of Akron

OH

Matching / Level of Effort / Earmarking

Finding: There was a lack of internal controls over management’s review and approval of documents submitted to the agency portal prior to submission for the Congressional Directives grant. Corrective Action Plan: Akron Children's will implement a review and sign-off process for all documentation to...

Finding: There was a lack of internal controls over management’s review and approval of documents submitted to the agency portal prior to submission for the Congressional Directives grant. Corrective Action Plan: Akron Children's will implement a review and sign-off process for all documentation to be submitted for federal grant requirements. Responsible Party: Vice President Finance Completion Date: November 30, 2024

View Audit 321917

Finding 499146 (2023-003)

Material Weakness 2023

Children's Hospital Medical Center of Akron

OH

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

Finding: Management did not retain sufficient evidence supporting the review and approval of the financial reports prior to submission. Corrective Action Plan: Akron Children’s implemented a review checklist and sign-off process to document controls for the review of the monthly financial reports s...

Finding: Management did not retain sufficient evidence supporting the review and approval of the financial reports prior to submission. Corrective Action Plan: Akron Children’s implemented a review checklist and sign-off process to document controls for the review of the monthly financial reports submitted to the granting agency. Completion Date: October 31, 2023 Corrective Action Plan: Akron Children’s will implement a review checklist and sign-off process to document controls for the review of the quarterly performance reporting. Completion Date: November 30, 2024 Responsible Party: Vice President Finance

View Audit 321917

Finding 499138 (2023-001)

Significant Deficiency 2023

Wireless Infrastructure Association and Affiliates

VA

Cash Management Subrecipient Monitoring HUD Housing Programs § 200.305

WIA management will implement the following corrective action plan: In order to ensure compliance with the timeliness of disbursements of federal funds contemplated under 2 CFR 200.305(b), WIA will implement the following additional procedures for federally-funded expenses. A detailed evaluation ...

WIA management will implement the following corrective action plan: In order to ensure compliance with the timeliness of disbursements of federal funds contemplated under 2 CFR 200.305(b), WIA will implement the following additional procedures for federally-funded expenses. A detailed evaluation of project deliverables and timelines will be conducted by the Project Manager and Project Director for any program subject to compliance with Federal guidelines. The timelines, deliverables and affected funding mechanism(s) will be aligned to determine if there may be a delay beyond a reasonable period which would impact the submission and processing of payments to subcontractors. If it is determined that a delay is possible or likely, consideration will be given to contract amendments which better support the processing of payments aligned with 2 CFR 200.305(b). Further, the Finance team member assigned to the associated program will provide regular guidance to the project team which may include a detailed briefing on the CFR and any relevant concerns with cash management. Disbursements of federal funds will be issued in a timely manner in all instances. The additional set of procedures described above will be implemented in September 2024. In addition, we are currently working through finalizing the contract for Phase 2 of the specific contract related to this finding. We anticipate these negotiations will be completed by October 31st, 2024. Once the Phase 2 agreement has been reached, we will immediately release the Phase 1 funds to the vendor and obtain guidance from The Ohio State University as to the proper disposition of any interest that has been earned by WIA from the withheld Phase 1 payment. Marta Sokol, Chief Financial Officer is the individual responsible for oversight of this corrective action plan. Mrs. Sokol can be reached at 703.535.7447 or Marta.Sokol@wia.org.

View Audit 321912

Finding 499096 (2023-002)

Significant Deficiency 2023

Children's Health System of Texas

CA

Matching / Level of Effort / Earmarking Reporting § 200.303

93.493 Congressional Directives Management did not document the level of effort of key personnel identified as Project Directors which were providing in-kind support to the grant program. Management will implement bi-weekly tracking of effort via Excel spreadsheet by key personnel related to these...

93.493 Congressional Directives Management did not document the level of effort of key personnel identified as Project Directors which were providing in-kind support to the grant program. Management will implement bi-weekly tracking of effort via Excel spreadsheet by key personnel related to these grant projects. The tracking of hours of effort will be maintained along with other grant related documentation by the grant management team. Management will continue to seek clarification with awarding agency to clarify if such tracking can be eliminated. Contact Person: Danielle Wesley, VP Network Service Delivery danielle.wesley@childrens.com 214-456-8988 Expected Completion Date: October 31, 2024

View Audit 321892

Finding 499086 (2023-002)

Significant Deficiency 2023

Sound Generations

WA

Cash Management Reporting Significant Deficiency § 200.303

Type of Finding: Significant Deficiency in Internal Control over Compliance - Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Aging Cluster Assistance Listing Number; 93.044 / 93.045 / 93.053 Federal Award Identification Number and Year: DA23-1109-2023 P...

Type of Finding: Significant Deficiency in Internal Control over Compliance - Reporting Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Aging Cluster Assistance Listing Number; 93.044 / 93.045 / 93.053 Federal Award Identification Number and Year: DA23-1109-2023 Pass-Through Agency: City of Seattle Pass-Through Number(s): DA23-1109 Award Period: January 1, 2023 through December 31, 2023 Criteria or specific requirement: 2 CFR 200.303(a) states that a non-Federal entity must “Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring the Organization of the Treadway Commission (COSO).” Condition: During testing of reporting, it was noted that, for one sample, documentation was not retained of approval of financial reporting. Questioned Costs: None Context: A sample of 9 financial reports was made from a population of 54 total reports. Of the 9 sampled, 1 was missing evidence of authorized personnel review and approval. Cause: In this one instance, verbal approval was given rather than emailed approval. Effect: Without adequate documentation and controls in place to ensure costs are reasonable and intended for the program charged, Sound Generations could incorrectly charge expenditures to the federal program, report fraudulent expenditures, or not request appropriate reimbursement that Sound Generations is entitled to under the terms of the grant. Repeat Finding: No. Recommendation: CLA recommends that documentation is retained as proof of authorized personnel review. Views of responsible officials and planned corrective actions: Sound Generations agrees with the finding. Sound Generations has revised its approval process to include digital signatures with time stamps by authorized personnel on all documentation rather than emailed approvals. Responsible Official: Carlos Rojas, Chief Financial Officer; Christina Hannan, Controller Anticipated Completion Date: March 31, 2024

View Audit 321877

Finding 499076 (2023-001)

Material Weakness 2023

Gary Public Transportation Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.303 § 200.403

CORRECTIVE ACTION PLAN Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and loca...

CORRECTIVE ACTION PLAN Finding 2023-001 - Controls Over Payroll Expenditures (Material Weakness) Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Context: A summary of allowable charges for the grant was prepared for submission. Within a sample of 45, we noted that 25 timecards did not have a documented review. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. The Transportation Department provides a spreadsheet that details time operators work by route. This process is used to align FTA funding streams with routes driven. The spreadsheet is kept by the Transportation Manager and reviewed by the Director of Transportation. These two positions approve time prior to submitting it for processing. The Gary Public Transportation Corporation management had hoped to get its payroll provider to provide a solution to this particular timesheet approval matter. However, the complexity of these timesheets made a resolve too complicated for reasonable implementation. So, a simple solution has been devised. The Transportation Manager and Director shall sign off on a document to stating their review and approval of those timesheets.

View Audit 321864

Finding 499075 (2023-003)

Significant Deficiency 2023

Village of Belleville

WI

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

Anticipated Completion Date: January 1, 2025 Finding 2023-003 Condition The annual deposit to the Reserve Account was tested and found to have been made on March 14, 2023, which is after the required deposit date. This (1 of 1) sample was not statistically valid. Corrective Action Plan Correcti...

Anticipated Completion Date: January 1, 2025 Finding 2023-003 Condition The annual deposit to the Reserve Account was tested and found to have been made on March 14, 2023, which is after the required deposit date. This (1 of 1) sample was not statistically valid. Corrective Action Plan Corrective Action Planned: There are currently no staff working in a capacity to make the transfer who were here or aware of the deadline. The Transfer was made as soon as possible after the error was discovered and a shared calendar event has now been added to ensure this entry is made in a timely manner moving forward. Name(s) of Contact Person(s) Responsible for Corrective Action: Ian Haas, Finance Director/Treasurer will be responsible for this entry moving forward. Anticipated Completion Date: September 1, 2024

View Audit 321862

Finding 499073 (2023-001)

None 2023

Borough of Sharpsville

PA

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.318 § 200.326

September 27, 2024 Borough of Sharpsville State Single Audit Corrective Action Plan For the Fiscal Year Ended 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Borough of Sharpsville To whom it may concern: AUDIT FINDINGS Finding Reference Number: 2023-001 Description o...

September 27, 2024 Borough of Sharpsville State Single Audit Corrective Action Plan For the Fiscal Year Ended 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Borough of Sharpsville To whom it may concern: AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No documented procurement procedures Statement of Concurrence or Nonconcurrence: The Borough of Sharpsville agrees with the finding in Borough of Sharpsville 2023 Single Audit Report Schedule of Findings. Corrective Action: The borough will revise its outdated procurement policy to comply with all state and federal programs which meet uniform guidance. Name of Contact Person: Kenneth P. Robertson, Borough Manager-Secretary/Treasurer (724) 962-7896 krobertson@sharpsville.org Projected Completion Date: Borough of Sharpsville anticipates resolving the audit finding by resolution of borough council at its November 2024 meeting. Any questions or concerns should be directed to Kenneth Robertson at (724) 962-7896. Sincerely yours, Kenneth P. Robertson Borough Manager-Secretary/Treasurer

View Audit 321851

Finding 499071 (2023-001)

Significant Deficiency 2023

Council Towers IV Housing Development Fund Corporation

NY

HUD Housing Programs Special Tests & Provisions Matching / Level of Effort / Earmarking

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Although the Housing Director processed the Final Accoun...

Views of Responsible Officials and Planned Corrective Actions Management agrees with the finding and will implement the auditor's recommendations. The recommendation, if properly implemented, should prevent this condition from arising again. Although the Housing Director processed the Final Accounting Statement in a timely manner and requested that the security deposit be returned to the tenant, the Accounts Payable Department missed the request. As staff have been covering two, sometimes three positions, adequate attention was not given to this item. This year, we have brought additional help to support the Fiscal Department. This support staff has allowed the key members of the fiscal team to work with a manageable workload and at a pace that will ensure that security deposits will be returned within 30 days of a tenant’s departure.

View Audit 321847

Finding 499061 (2023-003)

Material Weakness 2023

Metropolitan School District of Lawrence Township

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2023-003 Finding Subject: COVID- 19 – Education Stabilization Fund – Wage Rate Requirements Summary of Finding: Three construction contracts were paid from the COVID-19 – Education Stabilization Fund grant funds, totaling $5,442,378, during the audit period. The provision that addresses the ...

FINDING 2023-003 Finding Subject: COVID- 19 – Education Stabilization Fund – Wage Rate Requirements Summary of Finding: Three construction contracts were paid from the COVID-19 – Education Stabilization Fund grant funds, totaling $5,442,378, during the audit period. The provision that addresses the Wage Rate requirements was included in all contracts; however, not all applicable contractors complied with the requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. Certified payrolls were not provided to the School Corporation throughout the course of the project for one of three applicable contractors. The school corporation did not have a control in place and operating effectively over the Wage Rate Requirements compliance requirement during the audit period. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will obtain regular contractor certified payrolls for all renovation projects paid for by ESSER to ensure wage requirements are in place. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

View Audit 321827

Finding 499060 (2023-002)

Material Weakness 2023

Metropolitan School District of Lawrence Township

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-002 Finding Subject: COVID- 19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For one of the three reports tested, the report was not supported by the unit...

FINDING 2023-002 Finding Subject: COVID- 19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For one of the three reports tested, the report was not supported by the unit’s records. The financial information provided did not agree with the data submitted in the Reports, therefore we could not determine their accuracy. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will work to ensure the ESSER report amounts tie to the accounting records and will improve record keeping of supporting documentation. If the amounts do not match, District will document support for all claims. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

View Audit 321827

Finding 499028 (2023-003)

Significant Deficiency 2023

Central Minnesota Housing Partnership, Inc.

MN

Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Rural Rental Housing Loans - Federal Assistance Listing #10.415 Recommendation: The Organization should review security deposits as a part of month-end close procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to fi...

Rural Rental Housing Loans - Federal Assistance Listing #10.415 Recommendation: The Organization should review security deposits as a part of month-end close procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will implement a review step during the tracking of security deposits to verify the security deposit asset is equal to or greater than the security deposit liability and will correct any that are underfunded. Names of the contact persons responsible for corrective action: Julie Schueller, Finance Director and Deanna Hemmesch, Executive Director Planned completion date for corrective action plan: December 31, 2024

View Audit 321819

Finding 499013 (2023-002)

Significant Deficiency 2023

Black Belt Community Foundation

AL

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

Management will provide additional training to employees on the Foundation’s fiscal policies and procedures, including policies directly affecting contracts and procurement.

View Audit 321796

Finding 498964 (2023-001)

Material Weakness 2023

Choose New Jersey, Inc.

NJ

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.213

Planned Corrective Action: Choose New Jersey (“CNJ”) understands the findings outlined in the audit report. CNJ has updated its procurement procedures for the federal grant to align with 2 CFR section 200.213 and 2 CFR section 180.300. To ensure that vendors supporting efforts on the federal grant a...

Planned Corrective Action: Choose New Jersey (“CNJ”) understands the findings outlined in the audit report. CNJ has updated its procurement procedures for the federal grant to align with 2 CFR section 200.213 and 2 CFR section 180.300. To ensure that vendors supporting efforts on the federal grant are not suspended or debarred from doing business with the federal government, CNJ has added a task in our Procurement Summary (procurement checklist) that specifically requires the project manager and CAO to verify the vendor’s eligibility in the System for Award Management ("SAM") maintained by the General Services Administration ("GSA") (available at SAM.gov). In addition to the verification that the vendor is NOT prohibited (debarred or suspended) from providing services to or contracting with the United States government, CNJ will retain a copy of the verification for the procurement file. This action will be completed during the vendor evaluation stage of the procurement and before contract is awarded to the vendor. It should be noted that the vendors selected for testing for 2023 were found to be in good standing. Corrective Action incorporation has already begun and will be fully implemented by 10/15/2024. Name of Contact Person: Jen Lenhardt, CAO, Choose New Jersey, Inc. One Gateway Center 11-43 Raymond Plaza West – Suite 1420 Newark, NJ 07102 609.293.1423 jlenhardt@choosenj.com

View Audit 321779

Finding 498957 (2023-006)

Material Weakness 2023

City of Bluffton

IN

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

FINDING 2023-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Of...

FINDING 2023-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All persons involved in the internal control; preparer, reviewer, etc. will be documented on the P&E Report document or with a checklist to show that we actually completed the internal controls we have in our policy. Anticipated Completion Date: immediately

View Audit 321762

Finding 498954 (2023-003)

Material Weakness 2023

City of Bluffton

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Bri Lau...

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Any transfers that happen, will be reviewed, and will have better documentation of what claims made the transfer happen and make sure supporting documentation is attached to the claim to prove the use of the transferred funds. Anticipated Completion Date: Immediately

View Audit 321762 Questioned Costs: $1

Finding 498918 (2023-004)

Material Weakness 2023

Forth

OR

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking § 200.303

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding allocation processes, including ensuring internal controls are in place. It would also be beneficial to eliminate or reduce the amoun...

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding allocation processes, including ensuring internal controls are in place. It would also be beneficial to eliminate or reduce the amount of manual inputs into the allocation process. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments, and the following action will be taken to improve the situation. We will establish written policies and procedures regarding allocation processes, including ensuring internal controls are in place by November 30, 2024. Simultaneously, we will also consider options to eliminate or reduce the amount of manual inputs into the allocation process. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Ronald Tran, Senior Finance Manager Plan completion date for corrective action plan: November 30, 2024

View Audit 321749

Finding 498917 (2023-003)

Material Weakness 2023

Forth

OR

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding firsttier subawards including tracking and proper internal control procedures. Explanation of disagreement with audit findings: there...

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding firsttier subawards including tracking and proper internal control procedures. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and the following actions have been taken to improve the situation. We hired a Contracts & Compliance Manager in 2024 who is now responsible for reporting first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the reporting due date. Additionally, we established written policies and procedures regarding first-tier subawards including tracking and proper internal control procedures. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: September 30, 2024

View Audit 321749

Finding 498916 (2023-002)

Material Weakness 2023

Forth

OR

Cash Management Internal Control / Segregation of Duties Material Weakness § 200.303

Conservation Research and Development Program – Assistance Listing #81.086 Plan completion date for corrective action plan: October 31, 2024 Recommendation: The Organization should establish written policies and procedures regarding invoicing for cost- reimbursement related to federal grants which i...

Conservation Research and Development Program – Assistance Listing #81.086 Plan completion date for corrective action plan: October 31, 2024 Recommendation: The Organization should establish written policies and procedures regarding invoicing for cost- reimbursement related to federal grants which include proper segregation of duties. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments, and the following actions have been or will be taken to improve the situation. We hired a Grants Accountant in 2024 to take over the responsibility of preparing invoices for cost-reimbursement. This allows for the additional control of the Senior Finance Manager reviewing the invoices. This review is now being documented in writing. Additionally, there are procedures in place to ensure if the Senior Finance Manager prepares the invoice, the Director of Finance & Operations reviews and documents approval of the invoice. We will establish written policies and procedures to document this process by October 31, 2024. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Ronald Tran, Senior Finance Manager

View Audit 321749

Finding 498901 (2023-002)

Significant Deficiency 2023

City of Charleston, South Carolina

SC

HUD Housing Programs Period of Performance Reporting

The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

View Audit 321709

Corrective Action Plans

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