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Corrective Action Plans

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Finding 478561 (2023-001)
Significant Deficiency 2023
Town of Gorham
ME
Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
Management response/corrective action: The School had been approved by MDOE to use a specific timecard that was designed to meet compliance with federal grant awards. We have been using that format for many years and the State does accept it for reimbursement purposes. When that form was reviewed du...
Management response/corrective action: The School had been approved by MDOE to use a specific timecard that was designed to meet compliance with federal grant awards. We have been using that format for many years and the State does accept it for reimbursement purposes. When that form was reviewed during the audit, it was determined not to be in compliance. During the summer of 2023, we worked with our federal grant managers to develop a new process for ensuring the correct time and effort documentation is being collected for each type of employee. Templates were provided by our auditors which are now being used consistently throughout the district.
View Audit 315192
Finding 478428 (2023-001)
Material Weakness 2023
Mercy Neighborhood Ministries, Inc.
PA
Internal Control / Segregation of Duties Material Weakness Reporting
Management’s Response: Management has revised MNM’s segregation of duties and compensating controls surrounding financial reporting and has implemented the appropriate safeguards to ensure they are adhered to. MNM has developed written procedures and incorporated the following controls surrounding...
Management’s Response: Management has revised MNM’s segregation of duties and compensating controls surrounding financial reporting and has implemented the appropriate safeguards to ensure they are adhered to. MNM has developed written procedures and incorporated the following controls surrounding cash receipts and disbursements. • Maintenance of a daily log of cash receipts and disbursements • Restrict access to cash and checks to authorized individuals • Maintain adequate supporting documentation for all cash receipts and disbursements • Recount of daily cash receipts by more than one individual for accuracy • Make deposits and post to accounts receivable on a regular basis at a minimum weekly • Safeguard cash and checks for deposits in a secure location (i.e. safe or lockbox) • Cash receipts are verified to daily log and supporting documentation as part of bank reconciliation process • Cash receipt and disbursement detail to be reviewed by Executive Director
View Audit 315127
Finding 478427 (2023-007)
Material Weakness 2023
Cottrellville Township
MI
Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.212 § 200.318
Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal construction grants, the Township will implement controls to ensure verification of debarment, suspension, or exclusion takes place before entering into...
Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal construction grants, the Township will implement controls to ensure verification of debarment, suspension, or exclusion takes place before entering into a covered transaction and that documentation is maintained. The anticipated date of completion is prior to receiving another federal construction grant award.
View Audit 315126
Finding 478426 (2023-006)
Material Weakness 2023
Cottrellville Township
MI
Reporting Subrecipient Monitoring Material Weakness § 200.502 § 200.510
The Township will establish controls to determine federal revenues and if an audit under the Uniform Guidance is required. The anticipated completion date is June 30, 2024.
The Township will establish controls to determine federal revenues and if an audit under the Uniform Guidance is required. The anticipated completion date is June 30, 2024.
View Audit 315126
Finding 478425 (2023-005)
Material Weakness 2023
Cottrellville Township
MI
Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.302 § 200.303 § 200.305 § 200.318 § 200.319
Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal grants, the Township will adopt the required written procedures. The anticipated completion date is prior to receiving another federal award.
Management agrees with the finding. Our current federal project is substantially completed, however, should the Township receive additional federal grants, the Township will adopt the required written procedures. The anticipated completion date is prior to receiving another federal award.
View Audit 315126
Finding 478424 (2023-004)
Material Weakness 2023
Cottrellville Township
MI
Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.318 § 200.319 § 200.327
Management thought the bidding for the Township engineer a number of years ago, met the bidding requirements. In the future, if the Township obtains any federal grant that requires engineering services, the Township will make sure that we bid engineering services. The anticpated completion date is p...
Management thought the bidding for the Township engineer a number of years ago, met the bidding requirements. In the future, if the Township obtains any federal grant that requires engineering services, the Township will make sure that we bid engineering services. The anticpated completion date is prior to receiving another federal grant award requiring engineering services.
View Audit 315126 Questioned Costs: $1
Finding 478411 (2023-004)
Material Weakness 2023
Judith Basin County
MT
Subrecipient Monitoring Matching / Level of Effort / Earmarking
FINDING 2023-004: Late Audit Submission The County will complete our annual audits in a timely fashion as to not exceed federal regulations.
FINDING 2023-004: Late Audit Submission The County will complete our annual audits in a timely fashion as to not exceed federal regulations.
View Audit 315102
Oregon College of Oriental Medicine
OR
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
Finding: 2023-007 Special Tests and Provisions Department’s Response: We concur Corrective Action: To make sure this issue does not occur again, the Director of Financial Aid will include a printout of the institutional charges at the time of the withdrawal to show what the amounts were during t...
Finding: 2023-007 Special Tests and Provisions Department’s Response: We concur Corrective Action: To make sure this issue does not occur again, the Director of Financial Aid will include a printout of the institutional charges at the time of the withdrawal to show what the amounts were during the R2T4 calculations. Contact: Katrina Hitzeman Anticipated Completion Date: Immediately
View Audit 315065
Oregon College of Oriental Medicine
OR
Student Financial Aid Reporting Matching / Level of Effort / Earmarking
Finding: 2023-004 Reporting Department’s Response: We concur Corrective Action: This issue occurred due to communication issues between departments of the college. The withdrawal process will be reviewed with the Director of Financial Aid, Director of Student and Alumni Affairs, and the Dean o...
Finding: 2023-004 Reporting Department’s Response: We concur Corrective Action: This issue occurred due to communication issues between departments of the college. The withdrawal process will be reviewed with the Director of Financial Aid, Director of Student and Alumni Affairs, and the Dean of Research and Postgraduate Studies. So that all are on the same page of deadlines and what the Financial Aid Office needs in order to complete the withdrawal process in a timely manner. Contact: Katrina Hitzeman Anticipated Completion Date: Immediately
View Audit 315065
Oregon College of Oriental Medicine
OR
Student Financial Aid Eligibility Matching / Level of Effort / Earmarking
Finding: 2023-003 Reporting Department’s Response: We concur Corrective Action: This issue occurred while the Director of Financial Aid was out of the office on Leave. This issue was caused by an issue in Populi’s system and a replacement Financial Aid Officer did not know who all was supposed...
Finding: 2023-003 Reporting Department’s Response: We concur Corrective Action: This issue occurred while the Director of Financial Aid was out of the office on Leave. This issue was caused by an issue in Populi’s system and a replacement Financial Aid Officer did not know who all was supposed to be included in the disbursement batch. The process will be updated so that a list of all students who are meant to be in a batch will be listed on a report as their requests come in, then the report will be referenced when creating a disbursement batch to make sure no students are missing. Contact: Katrina Hitzeman Anticipated Completion Date: Summer 2024
View Audit 315065
Finding 478377 (2023-007)
Material Weakness 2023
City of Santa Fe
NM
Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Material Weakness
Recommendation: The auditor recommends the City strengthen the controls in place to provide assurance backup documentation is retained with reports to support amounts reported. The employees responsible for report preparation should be trained to ensure understanding of the relevant Uniform Guidance...
Recommendation: The auditor recommends the City strengthen the controls in place to provide assurance backup documentation is retained with reports to support amounts reported. The employees responsible for report preparation should be trained to ensure understanding of the relevant Uniform Guidance requirements. Additionally, review procedures should be designed to address proper document retention to substantiate information reported. Action Taken: The City agrees with this finding. In November 2022 (about 5 months into FY23) the City hired a new Airport Manager with substantial experience managing municipal airports and overseeing federal funding for airports. Prior to the hire, the Airport Operations Manager was the acting airport manager, but that position was vacated during FY23. There was a period during FY23 between when the Airport Operations Manager left the City and when the new Airport Manager came on board. In CY24 the Finance Director and the Accounting Officer will work with the Airport staff to implement controls and to provide assurance that Federal Financial Reports have adequate supporting documentation and are reviewed and approved prior to submission the grantor agency timely. The City is in the process of identifying a vendor to contract with Airport to assist with federal compliance and provide training to Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will also include helping with developing and documenting standard operating procedures related to documentation requirements and document retention. Due Date of Completion: December 31, 2024 Responsible Official: Emily Oster - Finance Director, James Harries - Airport Manager, Matthew Bonifer - Accounting Officer, Grants Manager (in recruitment)
View Audit 315062
Finding 478374 (2023-004)
Material Weakness 2023
City of Santa Fe
NM
Questioned Costs Matching / Level of Effort / Earmarking § 200.303 § 200.430
Recommendation: The auditor recommends the City strengthen policies and procedures to ensure a review of the general ledger for the federal program to ensure no duplicate costs are charged prior to reimbursement. Additionally, the Finance Department should provide secondary review on all requests fo...
Recommendation: The auditor recommends the City strengthen policies and procedures to ensure a review of the general ledger for the federal program to ensure no duplicate costs are charged prior to reimbursement. Additionally, the Finance Department should provide secondary review on all requests for reimbursements. Action Taken: The City agrees with this finding. When this issue was brought to the attention of the Finance Director and Accounting Officer as material noncompliance, the schedule of expenditures of federal awards (SEFA) was revised to remove the duplicated expenditures. Management proposed an adjusting journal entry prior to the completion of the audit to record the amount of the reimbursement for duplicated expenditures as a liability “due to Federal Government”. The City will work with the awarding agencies to return the funds that were reimbursed incorrectly. When this reimbursement request was done the payroll expenditure data that was used to calculate the reimbursement request was compiled manually by combining multiple reports. This was a manual process. The process has changed, so that now the Airport Administrative Manager gets one report directly from the Payroll Division that contains all Airport payroll expenditure data. In November 2022 (about 5 months into FY23) the City hired a new Airport Manager with substantial experience managing municipal airports and overseeing federal funding for airports. In CY24 the Finance Director and the Accounting Officer will work with the Airport staff to strengthen policies and procedures to ensure a review of the general ledger for the federal program to ensure no duplicate costs are charged prior to reimbursement. Secondary review by the Finance Department or a vendor approved by the Finance Director will be required for all Airport requests for reimbursements. The City is in the process of identifying a vendor to contract with Airport to assist with federal compliance and provide training to Airport staff on relevant Uniform Guidance requirements. The vendor’s scope of work will include performing secondary review of requests for reimbursement and helping with developing and documenting policies and standard opera􀆟ng procedures for requests for reimbursement. In CY24 the City will provide Uniform Guidance training to staff which will include internal controls related to activities allowed and allowable costs over payroll. Due Date of Completion: December 31, 2024 Responsible Official: Emily Oster - Finance Director, James Harries - Airport Manager, Matthew Bonifer - Accounting Officer, Grants Manager (in recruitment).
View Audit 315062 Questioned Costs: $1
Finding 478363 (2023-009)
Material Weakness 2023
Brockton School District
MT
Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.326
FINDING 2023-009: Wage Rage Compliance Response: The District will implement internal controls to ensure compliance requirements of all federal funds received. Contractors will be required to certify that they are complying with prevailing wages if the project is paid with federal funds.
FINDING 2023-009: Wage Rage Compliance Response: The District will implement internal controls to ensure compliance requirements of all federal funds received. Contractors will be required to certify that they are complying with prevailing wages if the project is paid with federal funds.
View Audit 315033
Finding 478324 (2023-004)
Material Weakness 2023
United Way of Acadiana, INC
LA
Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
United Way onboarded a new Finance Director with expertise in developing internal controls for Federal grant programs as of August 2023. We have successfully implemented robust internal controls that have significantly enhanced our operational efficiency. We are confident that as of 2024, this iss...
United Way onboarded a new Finance Director with expertise in developing internal controls for Federal grant programs as of August 2023. We have successfully implemented robust internal controls that have significantly enhanced our operational efficiency. We are confident that as of 2024, this issue has been effectively addressed.
View Audit 314994
United Way of Acadiana, INC
LA
Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking
United Way onboarded a new Finance Director with expertise in developing internal controls for Federal grant programs as of August 2023. We have successfully implemented robust internal controls that have significantly enhanced our operational efficiency. We are confident that as of 2024, this iss...
United Way onboarded a new Finance Director with expertise in developing internal controls for Federal grant programs as of August 2023. We have successfully implemented robust internal controls that have significantly enhanced our operational efficiency. We are confident that as of 2024, this issue has been effectively addressed.
View Audit 314994 Questioned Costs: $1
Finding 478274 (2023-003)
Material Weakness 2023
Village of La Farge, Wisconsin
WI
Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
Finding 2023-003 Condition: Internal controls over federal grants should be in place to provide reasonable assurance that a misstatement in the schedule of expenditures of federal awards would be prevented or detected. Criteria: Non-federal entities who receive federal or state grants or have gra...
Finding 2023-003 Condition: Internal controls over federal grants should be in place to provide reasonable assurance that a misstatement in the schedule of expenditures of federal awards would be prevented or detected. Criteria: Non-federal entities who receive federal or state grants or have grant programs should have documented policies and procedures in place over grants and grant expenditures. Cause: The Village does not have documented policies and procedures in place over grants and grant expenditures. Effect: Without documented policies and procedures, the internal control over federal grants is low, and the risk of misstatement in the schedule of federal awards is high. Auditor’s Recommendation: We recommend that the Village work on written policies and procedures over grants and grant expenditures. Management Response: The Village will work with their auditor to develop and adopt written grant procedures that are in accordance with the Uniform Guidance. Contact Person: Kim Walker Anticipated Completion: Ongoing
View Audit 314951
Finding 478238 (2023-001)
Material Weakness 2023
Town of North Attleborough, Massachusetts
MA
Questioned Costs Period of Performance Subrecipient Monitoring § 200.308 § 200.309 § 200.403
Finding 2023-001 U.S. Department of Education Condition: Tuition invoices and payroll costs were charged to a 2023 grant that were for services rendered prior to the grant start date. Corrective Action Planned: The School will implement procedures to review all manual journal entries for period ...
Finding 2023-001 U.S. Department of Education Condition: Tuition invoices and payroll costs were charged to a 2023 grant that were for services rendered prior to the grant start date. Corrective Action Planned: The School will implement procedures to review all manual journal entries for period of performance compliance before posting to the general ledger. Anticipated Completion Date: Immediately Contact: Gilbert Lefort III, Director of Finance, North Attleborough Public Schools
View Audit 314913 Questioned Costs: $1
Finding 478203 (2023-003)
Material Weakness 2023
Great Rivers United Way, Inc.
WI
Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties
Policies and Procedures over Federal Grants Condition: Internal controls over federal grants should be in place to provide reasonable assurance that a misstatement in the schedule of expenditures of federal awards would be prevented or detected. Criteria: Non-federal entities who receive federa...
Policies and Procedures over Federal Grants Condition: Internal controls over federal grants should be in place to provide reasonable assurance that a misstatement in the schedule of expenditures of federal awards would be prevented or detected. Criteria: Non-federal entities who receive federal or state grants or have grant programs should have documented policies and procedures in place over grants and grant expenditures. Cause: The Organization does not have documented policies and procedures in place over grants and grant expenditures. Effect: Without documented policies and procedures, the internal control over federal grants is low, and the risk of misstatement in the schedule of expenditures of federal awards is high. Auditor’s Recommendation: We recommend that the Organization work on written policies and procedures over grants and grant expenditures. Management’s Response: The Organization will work with their auditor to develop and adopt written grant procedures that are in accordance with the Uniform Guidance. Contact Person: Jan Henry Anticipated Completion: Ongoing
View Audit 314893
Finding 478191 (2023-002)
Significant Deficiency 2023
Alliance Apartments Housing Development Fund Co., Inc.
NY
Cash Management HUD Housing Programs Matching / Level of Effort / Earmarking
We have requested HUD approval to delay reimbursement of the reserves pending receipt of Budget Based Rent increase. We anticipate that this will be approved.
We have requested HUD approval to delay reimbursement of the reserves pending receipt of Budget Based Rent increase. We anticipate that this will be approved.
View Audit 314887
Finding 478178 (2023-003)
Significant Deficiency 2023
Siena Heights University
MI
Student Financial Aid Reporting Significant Deficiency
Condition - Of the 40 students selected for enrollment reporting testing, 1 student did not have their status change updated appropriately. Planned Corrective Action: Management is developing a process between the Registrar's Office and the Office of Financial Aid to determine the proper reporting ...
Condition - Of the 40 students selected for enrollment reporting testing, 1 student did not have their status change updated appropriately. Planned Corrective Action: Management is developing a process between the Registrar's Office and the Office of Financial Aid to determine the proper reporting procedure for changes to enrollment status that fall between reporting windows to ensure timely and accurate reporting to the NSLDS. Contact person responsible for corrective action: Christopher Cox, Registrar Anticipated Completion Date: June 30, 2024
View Audit 314845
Finding 478175 (2023-002)
Material Weakness 2023
Grand Lake Mental Health Center, Inc.
OK
Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.430
Federal Agency Name: Department of Health and Human Services, Assistance Listing No. 93.829 and 93.696 Program Names: Section 223 Demonstration Programs to Improve Community Mental Health Services, Certified Community Behavioral Health Clinics Expansion Grants Finding Summary: Appropriate documentat...
Federal Agency Name: Department of Health and Human Services, Assistance Listing No. 93.829 and 93.696 Program Names: Section 223 Demonstration Programs to Improve Community Mental Health Services, Certified Community Behavioral Health Clinics Expansion Grants Finding Summary: Appropriate documentation to support the allocations of compensation applicable to the referenced programs, or to support allowable costs or that the level of effort requirements, as outlined in the grant contracts were not readily available. Corrective Action Plan: Controls have been put in place to ensure that expenditures of program funds allocated through payroll expense are reviewed and approved by program management and are properly allocated based on time and activities worked consistent with grant requirements. Level of effort requirements as made known in grant contracts will be substantiated by payroll allocations. Responsible Individual: Trica Walters, Chief Human Resources Officer Completion Date: May 2024
View Audit 314844 Questioned Costs: $1
Finding 478162 (2023-003)
Significant Deficiency 2023
Snowy Mountain Development Corporation
MT
Subrecipient Monitoring Matching / Level of Effort / Earmarking Reporting
Responsible Party: Sara Hudson Anticipated Completion Date: July 1, 2024 Corrective Action Plan: Per FFATA Reporting Requirements, and as provided to us (SMD) by our sub awardees, the following information and reporting will commence immediately:  SMD will report and answer the following que...
Responsible Party: Sara Hudson Anticipated Completion Date: July 1, 2024 Corrective Action Plan: Per FFATA Reporting Requirements, and as provided to us (SMD) by our sub awardees, the following information and reporting will commence immediately:  SMD will report and answer the following question in the FSRS system: The sub awardee’s business or organization's preceding completed fiscal year, did its business or organization receive (1) 80 percent or more of its annual gross revenues in U.S. federal Contract, subcontracts, loans, grants, subgrants, and/or cooperative agreements; and (2) $25,000,000 or more in annual gross revenues for U.S. federal contracts, subcontracts, loans, grans, subgrant, and/or cooperative agreements?  If the response indicates "yes" to the question additional compensation data will be collected. SMD will implement FFATA requirements by implementing a section dedicated to FFATA reporting in our Brownfields financial assistance applications. This will enable us to gather the data needed to complete the reporting. SMD has also implemented a project checklist for all of our Brownfield Cleanup Projects, with a check-o􀀁 section dedicated as a second safeguard to ensure the completion of FFATA reporting.
View Audit 314834
Paine College
GA
Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking
Finding 2023-001 - U.S. Department of Education {USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. • The College had a difference in the Fed...
Finding 2023-001 - U.S. Department of Education {USDE), Title IV Student Financial Aid Programs: We observed the following conditions in connection with our testing of the various U.S. Department of Education, Title IV, Student Financial Assistance Programs. • The College had a difference in the Federal Work Study program which was not reconciled to the general ledger. Auditor's Recommendation - The University should implement corrective actions to ensure that the above findings are resolved and will not recur in future periods. Corrective Action - Management concurs with this finding. The College has implemented procedures to ensure that the Federal Work Study program reconciles to the general ledger.
View Audit 314668 Questioned Costs: $1
Finding 477957 (2023-001)
Significant Deficiency 2023
Regis University
CO
Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking
The University has adjusted the enrollment reporting calendar to ensure that updates, including the reporting of the graduation status (DegreeVerify), are certified, throughout the fiscal year, in order to maintain compliance with 34 CFR 682.610. The Office of the Registrar will prepare the certific...
The University has adjusted the enrollment reporting calendar to ensure that updates, including the reporting of the graduation status (DegreeVerify), are certified, throughout the fiscal year, in order to maintain compliance with 34 CFR 682.610. The Office of the Registrar will prepare the certification data during its monthly processes. The certification data will be reviewed for accuracy by the Registrar, who will be responsible for ascertaining timely submittal of the data with the National Student Clearinghouse. The Office of the Registrar has submitted changes to update the reporting of the graduation status (DegreeVerify) from quarterly to approximately every 45 days. This time frame is being tested to ensure timely data sharing between NSC and NSLDS, while optimizing the least amount of duplicate statuses and error warnings. The timing can be adjusted, but will never cause the institution to go out of compliance with the 60-day reporting requirement.
View Audit 314659
Finding 477914 (2023-001)
Significant Deficiency 2023
County of Calhoun
MI
Matching / Level of Effort / Earmarking Significant Deficiency
Finding: 2023-001 – Revenue Loss Calculation (Earmarking) Auditor Description of Criteria, Condition, and Effect: In accordance with the Uniform Guidance, recipients of Coronavirus State & Local Fiscal Recovery Funds may use payments from CSLFRF to replace lost public sector revenue to provide gove...
Finding: 2023-001 – Revenue Loss Calculation (Earmarking) Auditor Description of Criteria, Condition, and Effect: In accordance with the Uniform Guidance, recipients of Coronavirus State & Local Fiscal Recovery Funds may use payments from CSLFRF to replace lost public sector revenue to provide government services. Recipients may use this funding to provide government services to the extent of the reduction in revenue experience due to the pandemic. Under the Final Rule, recipients can elect a one-time “standard allowance” or they can calculate lost revenue based on the formula provide in the Final Rule to determine the amount of funds that can be used for the provision of government services. The County calculated lost revenue for fiscal years 2020-2023; however, certain items included in the calculation are not allowed per the Final Rule. As a result, the amount of revenue loss reported on the SLFRF compliance/P&E reports was incorrect. Auditor Recommendation: Management has revised its internal revenue loss calculation. We recommend the County update the amount on the current quarterly report and ensure that any future calculations are correct. Corrective Action: The County agrees that management has already taken appropriate action and will continue to provide correct calculations of revenue loss for future quarterly reports. The amount of the County’s revenue loss far exceeds the amount of ARPA funds spent within that category, and so this item did not and will not impact the accuracy of the County’s ARPA expenditure reports. Responsible Person: Megan Banning, Finance Director Anticipated Completion Date: December 31, 2024
View Audit 314617
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