Corrective Action Plans

Finding 478944 (2023-020)

Material Weakness 2023

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the mon...

EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Name of the contact person responsible for corrective action: Sheila Tunney, EOEA CFO Planned completion date for corrective action plan: EOEA will complete this corrective action plan following issuance of the final FFY24 federal award, which is expected in August 2024.

View Audit 315520

Finding 478932 (2023-018)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-018 COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER), COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) – Assistance Listing No. 84.425D, 84.425U Action taken in response to the...

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-018 COVID-19 – Elementary and Secondary School Emergency Relief Fund (ESSER), COVID-19 – American Rescue Plan – Elementary and Secondary School Emergency Relief (ARP ESSER) – Assistance Listing No. 84.425D, 84.425U Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Name of the contact person responsible for corrective action: Robert Curtain, Chief Officer for Data and Accountability Planned completion date for corrective action plan: July 1, 2023

View Audit 315520

Finding 478931 (2023-017)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-017 Title I Grants to Local Educational Agencies – Assistance Listing No. 84.010 Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSR...

DEPARTMENT OF ELEMENTARY AND SECONDARY EDUCATION 2023-017 Title I Grants to Local Educational Agencies – Assistance Listing No. 84.010 Action taken in response to the finding: In FY24, internal controls and procedures were implemented to ensure that all required subawards are reported timely to FSRS no later than the end of the month following the month of issuance. Name of the contact person responsible for corrective action: Robert Curtain, Chief Officer for Data and Accountability Planned completion date for corrective action plan: July 1, 2023

View Audit 315520

Finding 478930 (2023-016)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Questioned Costs Eligibility Significant Deficiency § 200.303

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-016 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Action taken in response to the finding: EOHLC has notified Nan McKay of the income ineligibility. Nan McKay and EOHLC agreed with the finding. In February 202...

EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-016 COVID-19 – Emergency Rental Assistance Program – Assistance Listing No. 21.023 Action taken in response to the finding: EOHLC has notified Nan McKay of the income ineligibility. Nan McKay and EOHLC agreed with the finding. In February 2024 Nan McKay sent payment recoupment letters to the landlord and the utility company to attempt to recoup the funds paid on behalf of an ineligible household. EOHLC met with Nan McKay leadership staff on 04/18/2024 to review income eligibility steps for emergency rental assistance programs. Name of the contact person responsible for corrective action: Amy Mullen Planned completion date for corrective action plan: April 18, 2024

View Audit 315520 Questioned Costs: $1

Finding 478926 (2023-014)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-014 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior audit findings related to Federal Financial Repor...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-014 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior audit findings related to Federal Financial Reports (FFR). Prior audit findings were a result of extraordinary turnover within EOLWD’s Finance Office, which resulted in having no staff who were fully dedicated to filing Federal Financial Reports (FFR). The CAP included: (1) filling vacant positions; (2) training new staff in the federal reporting process and requirements; (3) automating business practices; and (4) drafting and implementing an FFR Standard Operating Procedure (SOP). The first three corrective actions identified in the CAP were implemented in FY 2023. The SOP for Federal Financial Reporting was developed in FY 2023 and implemented in FY 2024. The necessary controls for ensuring ETA 9130 reports reflect earmarking requirements and are accurately supported by documentation that support reported balances were implemented with the implementation of the FFR SOP in FY 2024. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: October 1, 2023

View Audit 315520

Finding 478923 (2023-013)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federa...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024

View Audit 315520

Finding 478913 (2023-011)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-011 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior aud...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-011 WIOA Cluster, Employment Service Cluster – Assistance Listing No. 17.258, 17.259, 17.278, 17.207, 17.801 Action taken in response to the finding: In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented to address prior audit findings related to Federal Financial Reports (FFR). Prior audit findings were a result of extraordinary turnover within EOLWD’s Finance Office, which resulted in having no staff who were fully dedicated to filing Federal Financial Reports (FFR). The CAP included: (1) filling vacant positions; (2) training new staff in the federal reporting process and requirements; (3) automating business practices; and (4) drafting and implementing an FFR Standard Operating Procedure (SOP). The first three corrective actions identified in the CAP were implemented throughout FY 2023. The SOP for Federal Financial Reporting was developed throughout FY 2023 and implemented in FY 2024. The necessary controls for ensuring that ETA 9130 reports reflect earmarking requirements and are accurately supported by documentation that support reported balances were implemented with the implementation of the FFR SOP in FY 2024. In addition, the automated business practices cited in the CAP were refined throughout FY 2023 to ensure data in supporting documentation correlates to what is reported on an ETA 9130 report. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: October 1, 2023

View Audit 315520

Finding 478904 (2023-008)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-008 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: The MassHire Department of Career Services (MDCS) budgets WIOA Adult, Youth, and Dislocated Worker funds in accordance with the De...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-008 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: The MassHire Department of Career Services (MDCS) budgets WIOA Adult, Youth, and Dislocated Worker funds in accordance with the Department of Labor’s (DOL) earmarking requirements. This finding is a result of reporting deficiencies cited in the FY 2022 audit. The FY 2022 audit findings were a result of extraordinary turnover within EOLWD’s Finance Office, which resulted in having no staff fully dedicated to filing Federal Financial Reports (FFR). In FY 2023, a Corrective Action Plan (CAP) was drafted and implemented by new staff to address the FY 2022 findings related to reporting. The CAP included developing a Standard Operating Procedure (SOP) for Federal Financial Reports, which was done throughout FY 2023. The SOP was implemented in September of 2023, and should resolve the underlying reporting issues that resulted in this finding. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: October 1, 2023

View Audit 315520

Finding 478902 (2023-007)

Material Weakness 2023

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024

View Audit 315520

Finding 478900 (2023-006)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

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

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-006 Unemployment Insurance, COVID-19 – Unemployment Insurance – Assistance Listing No. 17.225 Action taken in response to the finding: While Massachusetts BAM unit (MBAM) had been making progress in meeting timeliness deadlines, it began suff...

EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-006 Unemployment Insurance, COVID-19 – Unemployment Insurance – Assistance Listing No. 17.225 Action taken in response to the finding: While Massachusetts BAM unit (MBAM) had been making progress in meeting timeliness deadlines, it began suffering setbacks in or around July 2022. MBAM was experiencing difficulties with the SUN server not accepting data and the system adding additional edits that should not have existed. Consistent work with the USDOL Hotline resolved the issues and/or created workarounds. Ultimately the SUN server failed after degrading for a year. The server was unavailable for use sporadically through the year and for four full separate weeks in May, June, and July 2023. Not only were staff unable to submit DCI data but it took additional organizational work of handling unentered cases, additional time to work with the Hotline and test fixes, while needing additional steps to implement work arounds for items that could not be fixed. MBAM continues to utilize work arounds for BAM data entry. Since SWA’s SUN server has become functional again, MBAM has been improving timeliness. MBAM also continues to work with ETA Hotline to report and resolve defects within the SUN system. MBAM management also developed an organizational strategy for the unit to provide its investigators with weekly updates on what cases should be worked on based on batch due dates. A case status report has been developed to provide unit supervisors with the status of each case assigned, expected date of completion, work completed to date on case, and cause for delay. Additionally, MBAM management has developed in-house reporting to track individual investigators. The reports track each investigator, telling management the number of cases closed each week and tracking the aging of Investigations. The manager uses these reports to identify cases to be prioritized based on aging and to quickly identify if a specific investigator is lagging in their case closure. Based on performance, the Manager has coaching sessions with individual investigators a minimum of every two weeks where work prioritization, organization, and any other additional necessary issues are reviewed and discussed. A meeting with all investigators is held weekly to provide education, discuss change to policy/procedure, and provide an open forum for BAM program implementation questions. Monitoring also occurs at the end of each quarter. Based on outcome, discussion of weaknesses and development of new levels of support are discussed and implemented. Name of the contact person responsible for corrective action: Susan Saulnier, Director of UI Performs Planned completion date for corrective action plan: September 30, 2024

View Audit 315520

Finding 478896 (2023-003)

Significant Deficiency 2023

Commonwealth of Massachusetts

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

DEPARTMENT OF ELEMENTARY PUBLIC HEALTH 2023-003 WIC Special Supplemental Nutrition Program for Women, Infants, and Children – Assistance Listing No. 10.557 Action taken in response to the finding: The Department and the WIC Nutrition Program will have all fiscal staff review the Operating Procedur...

DEPARTMENT OF ELEMENTARY PUBLIC HEALTH 2023-003 WIC Special Supplemental Nutrition Program for Women, Infants, and Children – Assistance Listing No. 10.557 Action taken in response to the finding: The Department and the WIC Nutrition Program will have all fiscal staff review the Operating Procedures to refresh themselves of the procedures surrounding Purchase Orders and Expenditures. (Excerpt from Operating Procedures) All Staff should complete a “Request for Purchase” form with all pertinent information such as quotes, renewal notices, conference registration, etc. and submit it to supervisor or Director for initial approval. Once the request is approved, the form is given to a fiscal staff to start the process of encumbering funds through MMARS and preparing a PURCHASE ORDER. At the very least, staff will identify that the service performed is correct and that funds are available and already encumbered to process the payment. All federal payments require a Program Code, and so the fiscal staff need to be sure the appropriate one is entered based on the dates of service or the date of the Purchase Order. Once all documents have been uploaded and submitted, then either the WIC State Director or the Fiscal Director will need to electronically approve the transaction in the Tracking System. The Fiscal Director and the State Director will more thoroughly review the assignment of Program Codes as they pertain to the Federal grant award dates before approving payment documents. This review will involve verifying: • The type of service • Date of service or receipt of item • Date of Purchase Order • Program Codes Name of the contact person responsible for corrective action: Beverly Andrew and Rachel Colchamiro Planned completion date for corrective action plan: April 30, 2024

View Audit 315520

Finding 478895 (2023-001)

Significant Deficiency 2023

National Urban League, Inc.

NY

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Audit Finding Reference: 2023-001 Planned Corrective Action: This finding represents a typo and is attributable to a human error. The error was corrected immediately after the auditor brought it to our attention. The League has strengthened its internal controls over timely submission of subaward...

Audit Finding Reference: 2023-001 Planned Corrective Action: This finding represents a typo and is attributable to a human error. The error was corrected immediately after the auditor brought it to our attention. The League has strengthened its internal controls over timely submission of subaward data in FFATA (Federal Funding Accountability and Transparency Act) reports. NUL Legal Department used to be responsible for generating FFATA reports, as they are authorized with review of new grant agreements as well as related contracts/subrecipients agreements submitted for approval. In prior years some reports were not submitted in time because of continuous turnover in the department in 2021-22. The regular workflow was sometimes interrupted, and new appointees had to catch up following their priority lists. Eventually, at the end of February 2023, the function was moved to the Finance department and a specific position designated for completing FFATA reports. All pending FFATA reports have been completed immediately after that. We keep submitting FFATA reports for new grants as soon as subaward amounts are finalized. In view of the above error, we will establish an additional layer of control over FFATA report accuracy, so the reports are thoroughly reviewed, once entered into the system, and approved by either VP/Director, Budget & Grants or CFO. Overall, we believe the strength of our internal control ensures a timely and complete submission of FFATA reports. Name and Title of Contact Persons: Sidney Evans, Chief Financial Officer; Lisa Davis, Vice-President for Financial Operations; Triva John, Vice-President for Budget & Grants, Konstantin Yurashkevich, Director for Budget & Grants Name of Official: Sidney Evans Title: Chief Financial Officer Date: 05/30/2024

View Audit 315517

Finding 478877 (2023-001)

Significant Deficiency 2023

Housing Authority of the City of Seattle

WA

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.303 § 200.430

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements an adequate review process to ensure costs charged to the grant are reasonable, accurate, and properly allocated. We recommend the Authority perform and document this review qua...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend the Authority implements an adequate review process to ensure costs charged to the grant are reasonable, accurate, and properly allocated. We recommend the Authority perform and document this review quarterly at minimum. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Budget division will continue to send an annual summary at the beginning of the fiscal year for all employees who have split funding for federal and non-federal funds. During the MSS process there will be a coding added if the payroll certification is required by a comment in the system. Monthly the Budget and Payroll Division will have a monthly review of all MSS employee changes during the month to evaluate the payroll certifications for the changes are accurate. Name(s) of the contact person(s) responsible for corrective action: Jared Cummer, CFO and Olivia Hunsinger, Controller Planned completion date for corrective action plan: Progress has been made and full completion is expected 06/30/2024.

View Audit 315516 Questioned Costs: $1

Finding 478873 (2023-003)

Significant Deficiency 2023

Harvest Against Hunger

WA

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: K3422 & K3724 - 2021 Pass-Through Agency: Washington State Department of Agriculture Pass-Through Number(s...

Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: K3422 & K3724 - 2021 Pass-Through Agency: Washington State Department of Agriculture Pass-Through Number(s): E128H7X5KWX5 Award Period: 7/1/21-6/30/23; 11/19/21-6/30/23 Type of Finding: • Significant Deficiency in Internal Control over Compliance Section III – Findings and Questioned Costs – Major Federal Programs Condition: Harvest Against Hunger allocates costs to the program based on the available funding and number of employees working on the project. They do not use the timesheet to record the operating hours for the program, but rather management makes a judgmental decision based on their understanding of program operations during the payroll period. Questioned costs: None Cause: The Organization lacks documentation supporting the allocation determination used to determine payroll amounts charged to the major program. Views of responsible officials: There is no disagreement with the finding. Criteria or specific requirement: Per §200.303, non-Federal entities 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 statues, regulations, and the terms and conditions of the Federal awards." Additionally, non-Federal entities must charge salaries and wages "based on records that accurately reflect the work performed" (§200.430(i)). Effect: Without proper documentation of the payroll allocation used, the Organization could charge time to a federal program that does not reflect true expenditures incurred by that program. Repeat Finding: This is not a repeated finding. Recommendation: The Organization should implement policies for consistently determining time allocation to the federal program, and ensure internal controls help to ensure this allocation is correct and consistently documented

View Audit 315495

Finding 478779 (2023-010)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be mai...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of required reports.

View Audit 315421

Finding 478778 (2023-009)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

Cash Management Period of Performance Subrecipient Monitoring § 200.305

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure funds are disbursed for expenditures incurred prior to requesting reimbursement and that expenditu...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure funds are disbursed for expenditures incurred prior to requesting reimbursement and that expenditures are incurred within the contract’s performance period.

View Audit 315421

Finding 478774 (2023-005)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be mai...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that required reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of required reports.

View Audit 315421

Finding 478773 (2023-004)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will implement policies and procedures to ensure earmarking requirements are completed and evidence of review documented.

View Audit 315421

Finding 478772 (2023-003)

Significant Deficiency 2023

Alameda Health System, A Public Hospital Authority

CA

HUD Housing Programs Reporting Significant Deficiency § 200.303

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be ...

Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding. The Health System will review, modify, and implement policies and procedures over the program to ensure that performance reports are prepared and reviewed by separate individuals. Documentation will be maintained by the program to evidence preparation and review processes and timely filing of annual report.

View Audit 315421

Finding 478710 (2023-002)

Significant Deficiency 2023

Douglas County Government

CO

Reporting Allowable Costs / Cost Principles Period of Performance § 200.303

2023-002 Finding: Allowable Costs and Allowable Activities Status: Corrective action in progress Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Feder...

2023-002 Finding: Allowable Costs and Allowable Activities Status: Corrective action in progress Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) 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 Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards Condition: During testing, we noted that one transaction totaling $1,501,269 related to 2022 activities and was included as an expenditure on the fiscal year 2023 Schedule of Expenditures of Federal Awards. The period of performance for the project began in 2022 and extended through 2023. Corrective Action: To facilitate more accurate and timelier grant reporting the following improvements are proposed: 1. Increased grant training for all departments. The Engineering Department is bringing in CDOT to do this, last year Forvis Mazars provided countywide training and the Finance Department will provide additional training on an ad hoc basis. A full understanding of the requirements of the grants that are being applied for is crucial. 2. Departments receiving grants will provide monthly reconciliations of all grants and provide grant agreements to the Finance Department to ensure accurate reporting on the SEFA (Schedule of Expenditures of Federal Awards). 3. Effective communication is essential to successful reporting and the Finance Department will formalize meetings with departments to address issues that surface and reporting expectations. Person(s) Responsible for Implementation: Jill Janz – Accounting Manager, Christie Guthrie – Assistant Finance Director Implementation Date: 6/1/24 and ongoing

View Audit 315378

Finding 478708 (2023-002)

Material Weakness 2023

Alabama Aerospace and Aviation Schools Inc.

AL

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

2) Finding 2023-002 - The School failed to document proper approval of purchases prior to disbursement of federal funds. Implementation of plan of action - Management will review control policies to ensure that approvals of purchases are documented prior to disbursement of federal funds. Implementat...

2) Finding 2023-002 - The School failed to document proper approval of purchases prior to disbursement of federal funds. Implementation of plan of action - Management will review control policies to ensure that approvals of purchases are documented prior to disbursement of federal funds. Implementation date - Anticipated completion July 30, 2024. Persons responsible for the implementation - The Board of Directors and CEO.

View Audit 315376

Finding 478672 (2023-001)

Material Weakness 2023

Centro Legal De La Raza

CA

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.303

CORRECTIVE ACTION PLAN Summary Schedule of Current Year Audit Findings In accordance with Title 2 CFR 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements under Section 200.511, Audit Findings follow-up, the following detail the summary of current year audit findings (and ...

CORRECTIVE ACTION PLAN Summary Schedule of Current Year Audit Findings In accordance with Title 2 CFR 200 Uniform Administrative Requirements, Cost Principles and Audit Requirements under Section 200.511, Audit Findings follow-up, the following detail the summary of current year audit findings (and the related corrective action plan) is presented below: Finding 2023-001: Inadequate Financial Reporting Condition: The tracking of eligible (billable) costs within the accounting system was inadequate and required a significant amount of work to generate reconciliations of billable costs to contract billings. In additional certain grants were inconsistently reflected as restricted or conditional compared to similar grants. As part of the process to review year end, management identified errors which required adjustments, the most common of which was adjusting revenue between restricted and conditional revenue. Criteria: CFR 200.303, Internal Controls, states that the 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 Organizations of the Treadway Commission (COSO). Additionally, management is responsible for the preparation and fair presentation of the financial statements in accordance with accounting principles generally accepted in the United States of America; this includes the design, implementation and maintenance of internal control relevant to the preparation and fair presentation of financial statements that are free from material misstatement, whether due to fraud or error. Cause: The Organization did not have in place a formal, clear system which reconciled the billings to the funders and related eligible costs or releases related to certain restricted grants. Effect: Significant adjustments were proposed by management during the audit, principally between conditional and restricted revenue. Recommendation: We strongly recommend that all costs are coded directly to a contract within the accounting system and on a monthly or quarterly (at a minimum) basis there is a reconciliation of the billings between the funders and the revenue/costs related to the contracts to assure that all costs have been capture for billings and releases from restrictions. We also recommend detailed reviews/approvals of such reconciliations be performed. Questioned Costs: None identified. Context: While performing initial audit procedures, we requested management to perform a reconciliation of billings and related costs and review its recording of restricted and conditional grants. During management review, errors were identified by management and requested to be corrected. The condition noted is deemed to be systemic in nature. We did not identify any misstatements during our audit once the review was completed by management. Identification as a Repeat Finding: This is not a repeat finding. Management Views and Corrective Action Plan: Management agrees with the finding and recommendation. The Organization implemented a new accounting system effective July 1, 2023, in which substantially all costs are now coded to respective contracts which will provide much easily generatable support for billings. Management is working with the accounting team to implement a new process as part of the monthly closing procedures in which for cost reimbursement contacts there will be a review of revenue compared to costs to ascertain that the billing is accurate and complete. Name and Title of Responsible Official: Eos de Feminis, Interim CFO Planned Completion Date: Completed

View Audit 315304

Finding 478671 (2023-001)

Significant Deficiency 2023

Four Directions Development Corporation

ME

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

As part of internal controls and spenddown grant management, FDDC management regularly evaluates costs that are allowed to be allocated to CDFI if we are underspent for the grant. Management proactively charged specific non-federal funding sources to prevent the dispersion of administrative time as ...

As part of internal controls and spenddown grant management, FDDC management regularly evaluates costs that are allowed to be allocated to CDFI if we are underspent for the grant. Management proactively charged specific non-federal funding sources to prevent the dispersion of administrative time as indirect costs across programs, while continuing the practice of charging time considered indirect to the general administration pool. These salary and fringe charges, constituting the reclassifications, were deemed integral, allowable, reasonable, equitable, and directly allocable to the CDFI awards, rather than indirect. This clarifies the redistribution of staff time from three selected funding sources that offered the greatest flexibility. To support allocation costs, we utilize a Personal Activity Report (PAR) that is maintained in tandem with timecards to ensure management knows the activity performed supports the allocation of allowable expenses. In addition, as part of our analysis, time for fundraising and other non-allowable expenses were excluded as it constitutes an explicitly unallowable use of funds. Our financials undergo monthly reconciliation, with management reviewing spenddown at that time, often aggregating expenses occurring more than 30 days prior. A deliberate strategy to restrict direct billing to grants was employed to prevent overspending grants, utilizing the aforementioned technique, to ensure accurate and allowable expenses are reclassified to the appropriate grants. To address the concern, we reversed the entry to ensure there was no conflicting interpretation between FDDC and the auditor. FDDC plans to enhance internal processes to directly allocate all allowable expenses to the CDFI grant. Given the complexities of our shared understandings, management addressed the finding through the deployment of loan products during this audit period.

View Audit 315302 Questioned Costs: $1

Finding 478570 (2023-002)

Material Weakness 2023

Collaborative for Children

TX

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Finding #2023-002 – Material Weakness and Material Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Passed through the Texas Workforce Commission, Child Care and Development Block Grant, Child Care Business Training, Assistance Listing #: 93.575, Contract N...

Finding #2023-002 – Material Weakness and Material Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Passed through the Texas Workforce Commission, Child Care and Development Block Grant, Child Care Business Training, Assistance Listing #: 93.575, Contract Number: 2920CCQ002, Contract Year: 12/01/19 – 06/30/24. Recommendation: CFC should implement policies and procedures to ensure that any applicable credits be credited to the Federal award either as a cost reduction or cash refund, as appropriate. Planned corrective action: CFC will develop a written policy outlining clear steps for: 1) Identifying and documenting credits associated with reversed invoices. 2)Applying credits within the accounting system to reduce grant costs. 3)Issuing refunds to funding agencies when required. Grant managers and finance personnel will be trained on these new policies and procedures, with an emphasis on the importance of proper credit application for grant compliance. We will also review existing internal controls over grant management to identify and address any additional weaknesses. Additionally, we will work with TWC to resolve the reimbursement of $137,893 and ensure the appropriate credit is applied. Responsible officer: Chief Financial Officer, Alisa Ealy. Estimated completion date: September 30, 2024

View Audit 315200 Questioned Costs: $1

Finding 478564 (2023-002)

Significant Deficiency 2023

Town of Gorham

ME

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

Management’s response/corrective action plan: The Town was unaware of this step in the federal procurement process. The Town has communicated to the departments that administer the grant expenditure that this process needs to be done.

View Audit 315192

Corrective Action Plans

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