Corrective Action Plans

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Finding 1218287 (2023-009)
Material Weakness 2023
Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, and the use of a third-party payroll provider, supporting documentation necessary to verify and document vendor payments and payroll transactions was not available, resulting in the inabili...
Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, and the use of a third-party payroll provider, supporting documentation necessary to verify and document vendor payments and payroll transactions was not available, resulting in the inability to obtain sufficient, appropriate audit evidence related to these amounts. Corrective Action: The school (LEAD Academy) contracted with New Schools for Alabama (NSFA) during 2023 to handle all their finance and accounting needs. By the end of 2023, the school also transitioned all payroll services to New Schools for Alabama. Prior to 2024, a third-party vendor was handling/processing payroll for LEAD Academy. Additionally, procedures were not in place to maintain monthly payroll data (timesheets, leave balances, documentation of annual salaries) prior to 2024. All financial records are now maintained digitally, with the original documents residing at the school. Additionally, NSFA worked with existing staff regarding proper documentation and filing of financial records and helped establish a new filing system. In 2024, payroll processing for the school was transitioned to NSFA, utilizing the state approved accounting/payroll software. Monthly procedures are now in place for the submission, approval and documentation of all payroll transactions. Expected Completion Date: September 30, 2024
Finding 1218280 (2023-008)
Material Weakness 2023
Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, supporting documentation necessary to verify and document vendor payment was not available, resulting in the inability to obtain sufficient, appropriate audit evidence related to these amou...
Responsible Parties: Erik Estill and Russell Raney Finding: Due to the passage of time, the turnover of staff, supporting documentation necessary to verify and document vendor payment was not available, resulting in the inability to obtain sufficient, appropriate audit evidence related to these amounts. During the testing of ESSER funds, there were 2 instances where the purchase order could not be located and one invoice that could not be located. Corrective Action: The school (LEAD Academy) contracted with New Schools for Alabama (NSFA) during 2023 to handle all their finance and accounting needs. By the end of 2023, the school also transitioned all payroll services to New Schools for Alabama. NSFA helped establish a purchase order procedure and worked with the school to make sure a purchase order or signed contract is in place prior to the purchase of goods and services. Additionally, approval on all invoices is required before NSFA processes them for payment, in order to verify that all goods and services have been received. Prior to 2024, proper procedures were not in place to maintain vendor files and accounts payable documentation. All financial records are now maintained digitally, with the original documents residing at the school. Additionally, NSFA worked with existing staff regarding proper documentation and filing of financial records and helped establish a new filing system. NSFA requires the school to indicate the source of funding for purchases, in order to know how to code the expenditure. We utilize monthly budget to actual reports to verify that expenditures are in line with the approved budget, ensuring that the correct coding has been used. We also ensure that only allowable expenditures are charged to federal funds, based on approved federal Egap applications and budgets.
LARS has implemented the following controls to address each element of this finding: HUD CoC Match Tracking: A grant-level match tracking schedule has been established for the CoC program. The schedule documents required match amounts, eligible match contributions, and cumulative match-to-date, and ...
LARS has implemented the following controls to address each element of this finding: HUD CoC Match Tracking: A grant-level match tracking schedule has been established for the CoC program. The schedule documents required match amounts, eligible match contributions, and cumulative match-to-date, and is updated at each reporting period. The Finance Director reviews the schedule prior to each drawdown and at fiscal year-end. Administrative Cost Limitation Monitoring: Written policies and procedures have been updated to include a procedure for monitoring the HUD CoC administrative cost limitation. The Finance Director calculates the limitation at the beginning of each grant year and monitors actual administrative costs on a quarterly basis. Grant Cutoff Procedures: A written grant financial management policy has been adopted that establishes cutoff procedures for recording expenditures within applicable grant performance periods. The accounting system has been configured to flag transactions with dates outside an active grant period for Finance Director review prior to posting. SEFA Preparation and Review: A formal SEFA preparation procedure has been implemented that requires: • A reconciliation of SEFA amounts to the general ledger and underlying grant records • A documented review of all grants and funding sources including state and local grants to determine proper SEFA inclusion and reporting treatment
Condition: The Organization lacked sufficient internal controls to ensure sliding fee discount applications were on file and included all of the necessary information regarding family size and income to support discount determinations made. Further, controls were not sufficient to ensure the correct...
Condition: The Organization lacked sufficient internal controls to ensure sliding fee discount applications were on file and included all of the necessary information regarding family size and income to support discount determinations made. Further, controls were not sufficient to ensure the correct sliding fee discount was applied. Planned Corrective Action: The organization will implement controls to ensure sliding fee applications are maintained and sliding fee adjustments are based on correct family income and resident size. Contact person responsible for corrective action: Charles Berry (CFO) Anticipated Completion Date: 6/30/2026
Management of the Organization has an accounting firm engaged who will perform future required audits.
Management of the Organization has an accounting firm engaged who will perform future required audits.
FINDING 2023-003 - Sliding Fee Discount Program MATERIAL WEAKNESS; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93.224/93 .527, Health Center Program Cluster Compliance Requirement: Special Tests & Provisions Criteria: Section ...
FINDING 2023-003 - Sliding Fee Discount Program MATERIAL WEAKNESS; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93.224/93 .527, Health Center Program Cluster Compliance Requirement: Special Tests & Provisions Criteria: Section 330 of the Public Health Service Act and the HRSA Health Center Program Compliance Manual require health centers to maintain and operate a board-approved Sliding Fee Discount Program that adjusts patient charges based on income and family size using the current Federal Pove1ty Guidelines, applies uniformly to all patients and all in-scope services, and is supported by adequate documentation of eligibility determinations. In addition, Uniform Guidance requires nonfederal entities to establish and maintain effective internal controls over federal programs to provide reasonable assurance of compliance with federal statutes, regulations, and award terms. Condition: During testing of the Sliding Fee Discount Program within the Health Center Cluster, the Center could not provide documentation of the appropriate sliding fee discounts for certain patients in accordance with federal requirements. Context: The condition was identified through testing of the Health Center Cluster as pa1i of the single audit, which included testing patient fee assessments and sliding fee discount application as a special test required under the program. Controls were determined to be ineffective in 2 of 40 test items. Noncompliance was noted in 2 of 25 test items. Statistical sampling was not utilized. Cause: The condition was caused by inadequate internal controls over the implementation and monitoring of the Sliding Fee Discount Program, including limited supervisory review to ensure all sliding fee applications are maintained, reviewed, and properly applied. Effect or Potential Effect: The Center's failure to maintain documentation surrounding sliding fee discounts in accordance with federal requirements increases the risk of noncompliance with Health Center Program requirements and may result in patients being charged amounts not aligned with their ability to pay. The condition also increases the risk of adverse findings during HRSA oversight or other federal monitoring activities. Questioned Costs: No questioned costs were identified as a result of this finding. Repeat Finding: This is not a repeat finding. Recommendation: The Center should enhance internal controls over the Sliding Fee Discount Program by ensuring consistent documentation of income and family size, timely reassessment of eligibility in accordance with policy, consistent application of the board-approved sliding fee discount schedule to all applicable in-scope services, and periodic monitoring and supervisory review to ensure ongoingcompliance. Views of Responsible Officials: Neighborhood Medical Center has implemented quarterly SFDP internal audits and training for the intake staff to improve compliance oversight and documentation accuracy. A standardized audit tracking log documenting charts are reviewed, findings identified and corrective actions completed. An annual refresher for the staff has been implemented. A quick-reference eligibility checklist has also been developed for staff use. Person Responsible for Corrective Action: Ronica Mathis and Shenika Mathews Anticipated Completion Date for Corrective Action: This practice has already been implemented.
FINDING 2023-004- Late Submission of Single Audit and FAC Data Collection Form SIGNIFICANT DEFICIENCY; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93 .011, 93.224/93.527, 93.526, and 93.918 Compliance Requirement: Reporting Cr...
FINDING 2023-004- Late Submission of Single Audit and FAC Data Collection Form SIGNIFICANT DEFICIENCY; NONCOMPLIANCE Identification of the Federal Program: U.S. Department of Health and Human Services; direct awards ALN: 93 .011, 93.224/93.527, 93.526, and 93.918 Compliance Requirement: Reporting Criteria: Uniform Guidance requires nonfederal entities to submit the reporting entity's Uniform Guidance reporting package, including the audit report and completed Federal Audit Clearinghouse (F AC) Data Collection Form, to the F AC within the earlier of 30 calendar days after receipt of the auditor's rep01ts or nine months after fiscal year-end (2 CFR 200. 512( a)). Timely submission of the reporting package is required to facilitate federal oversight of award compliance. Context: The condition was identified during Single Audit testing of reporting requirements applicable to the Health Center Cluster. Sampling was not utilized. Condition: The Center did not submit its required Uniform Guidance reporting package, including the reporting entity's audit report and the FAC Data Collection Form, within the required submission timeframe. Specifically, the Uniform Guidance audit and related FAC Data Collection Form were submitted after the earlier of (1) 3 0 calendar days after receipt of the auditor's reports or (2) nine months after the end of the reporting entity's fiscal year. Cause: Due to a delay in the compiling of records related to the audit, the Center was not in compliance with the reporting requirements. Effect or Potential Effect: Failure to submit the Uniform Guidance audit and F AC Data Collection Form timely increases the risk of noncompliance with Uniform Guidance reporting requirements and may result in delayed federal oversight, increased monitoring by the awarding agency, or the imposition of additional administrative conditions. Questioned Costs: No questioned costs were identified as a result of this finding. Repeat Finding: This is a repeat finding. Recommendation: The Center should strengthen internal controls over Uniform Guidance audit reporting by ·implementing procedures to track submission deadlines, assigning responsibility for timely filing of the audit report and FAC Data Collection Form, and establishing management review processes to ensure compliance with Uniform Guidance reporting requirements. View of Responsible Officials: Neighborhood's prior auditor indicated just before time to begin the audit for FY2022; they would not be able to complete the audit because of staff sho1tages. Two RFPs were issued, and it took the center a year and a half to secure a new auditor. The 2022 and 2023 audits have been completed. Engagement contract has been issued for the 2024 audit.
For 11 of 22 tenant files selected for testing, the Organization was unable to provide both the signed sublease agreement and the master lease agreement. One file lacked both documents. Although the Compliance Supplement does not require these documents for determining rent reasonableness under the ...
For 11 of 22 tenant files selected for testing, the Organization was unable to provide both the signed sublease agreement and the master lease agreement. One file lacked both documents. Although the Compliance Supplement does not require these documents for determining rent reasonableness under the Continuum of Care Program, the Organization’s internal policies require them. Management acknowledges the condition noted. While the Compliance Supplement does not require examination of lease agreements for this program and no instances of noncompliance were identified, we agree that maintaining complete tenant files—including signed sublease agreements and master lease agreements—is an important internal control to support documentation of rent reasonableness and compliance with our own policies. The missing documents resulted from inconsistent file maintenance during the audit period. The Organization has taken steps to strengthen its documentation and retention procedures to ensure all required lease documents are properly maintained and readily accessible going forward.
Finding No.: 2023-005 Area: Level of Effort Views of responsible official and planned corrective actions: Management acknowledges the requirement to comply with the Level of Effort provisions outlined in the grant agreement. Management confirms that the Trust is committed to maintaining adequate syste...
Finding No.: 2023-005 Area: Level of Effort Views of responsible official and planned corrective actions: Management acknowledges the requirement to comply with the Level of Effort provisions outlined in the grant agreement. Management confirms that the Trust is committed to maintaining adequate systems and documentation to demonstrate that all required time, activities, and resources are properly allocated to grant-funded projects. To strengthen compliance, we will continue to ensure that staff maintain accurate timesheets and activity logs, and that these records are reviewed on a regular basis by program and finance personnel. Management will also conduct periodic oversight reviews to confirm that Level of Effort requirements are being met and properly supported by documentation. Contact Person: Melanie Lawrence Aiseam, Chief Financial Officer Expected Completion Date: The Trust started training last year, and this is ongoing.
2023-001 REPORTING Recommendation: Reports prepared by the Executive Director should be reviewed by an independent person to ensure completeness and accuracy. Additionally, the Organization should design a control to ensure reports are submitted in a timely manner in accordance with compliance requi...
2023-001 REPORTING Recommendation: Reports prepared by the Executive Director should be reviewed by an independent person to ensure completeness and accuracy. Additionally, the Organization should design a control to ensure reports are submitted in a timely manner in accordance with compliance requirements. Corrective Action: Community of Hope recognizes that our expansion and growth have made it difficult to maintain full and timely compliance with some reporting criter+B11 ia. As such, we have created a compliance calendar that will alert staff to impending deadlines and requirements. In addition, we recently hired a staff member with compliance being a primary function. She is reviewing grant and policy compliance, making recommendations, and instituting changes to enhance compliance. Responsible party: Drew Warren, Executive Director Date Expected to be Corrected: March 1, 2026
Finding 2023-012 - Single Audit Reporting Auditee's Response and Planned Corrective Action The Town will work with the accounting department, fee accountant, and audit fmn to file the required reports timely. Planned Implementation Date of Corrective Action: January 2026 Person Responsible for Corre...
Finding 2023-012 - Single Audit Reporting Auditee's Response and Planned Corrective Action The Town will work with the accounting department, fee accountant, and audit fmn to file the required reports timely. Planned Implementation Date of Corrective Action: January 2026 Person Responsible for Corrective Action: Fred Costello, T own Supervisor
Finding 1214595 (2023-010)
Material Weakness 2023
The Creek County Clerk’s Office will work with the SEFA preparer to ensure that the correct paid dates are being used when reporting. This should eliminate the actual expenditures differences. We will work to educate all offices involved in the reporting process on financial statement and SEFA utili...
The Creek County Clerk’s Office will work with the SEFA preparer to ensure that the correct paid dates are being used when reporting. This should eliminate the actual expenditures differences. We will work to educate all offices involved in the reporting process on financial statement and SEFA utilizing the paid date, instead of warrant date.
Upon receiving results of the FY21 audit (completed in FY24), TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal billing records (approximately 7.5% additional uplift) was not allowable as it was being calculated. TAS is allowed a 10% de minimis...
Upon receiving results of the FY21 audit (completed in FY24), TAS’ Director of Finance was informed that the inclusion of the Biological Expertise line item on federal billing records (approximately 7.5% additional uplift) was not allowable as it was being calculated. TAS is allowed a 10% de minimis rate on noted FY22 Federal awards, some of which also included a Biological Expertise line item that is budgeted as an hourly rate. TAS had been calculating uplift amounts owed by simply adding the Biological Expertise (7.5%) to the de minimis rate (10%) for a total uplift of 17.5%. This was done at the direction and approval of our federal partners. However, due to Biological Expertise being entered in the federal and approved budgets as an hourly line item and not a percentage TAS was considered out of compliance by using this method of calculation. After the presentation of this finding in mid-2024, TAS adjusted federal billing for administrative expenses to the de minimis rate (10%) as a percentage, unless otherwise noted in the agreement. Anticipated completion date: In effect.
Recommendation: We recommend that management implement a requirement for employees to complete level of effort forms attesting to actual time spent working on the federal program on a regular basis, but no less than annually, during the fiscal period. These forms should be reviewed by a supervisor k...
Recommendation: We recommend that management implement a requirement for employees to complete level of effort forms attesting to actual time spent working on the federal program on a regular basis, but no less than annually, during the fiscal period. These forms should be reviewed by a supervisor knowledgeable of the employee’s activities and grant requirements and retained thereafter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management established a standardized quarterly process for updating Level of Effort (LOE) forms. All completed forms are retained and archived within the organization’s SharePoint environment to support proper documentation and audit readiness. Name(s) of the contact person(s) responsible for corrective action: Deidre Calcoate, Executive Director Planned completion date for corrective action plan: 01/09/2025
Recommendation: We recommend that management implement a requirement for employees to complete level of effort forms attesting to actual time spent working on the federal program on a regular basis, but no less than annually, during the fiscal period. These forms should be reviewed by a supervisor k...
Recommendation: We recommend that management implement a requirement for employees to complete level of effort forms attesting to actual time spent working on the federal program on a regular basis, but no less than annually, during the fiscal period. These forms should be reviewed by a supervisor knowledgeable of the employee’s activities and grant requirements and retained thereafter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management established a standardized quarterly process for updating Level of Effort (LOE) forms. All completed forms are retained and archived within the organization’s SharePoint environment to support proper documentation and audit readiness. Name(s) of the contact person(s) responsible for corrective action: Deidre Calcoate, Executive Director Planned completion date for corrective action plan: 01/09/2026
U.S. Department of the Treasury Internal Control Over General Disbursements Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: Implement a formal way to document the review and approval of transportation costs charged from the Knox County garage to prov...
U.S. Department of the Treasury Internal Control Over General Disbursements Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: Implement a formal way to document the review and approval of transportation costs charged from the Knox County garage to provide evidence that internal controls are effectively designed and implemented. Explanation of disagreement with audit finding: There is no disagreement with the finding regarding the formal documentation of the services and approval of transportation cost charged from the Knox County Service Center (garage.) Action taken in response to finding: Agency vehicles are serviced at the Knox County Service Center (garage), with services billed monthly. Although transportation charges from the County were reviewed monthly, documentation of that review was not formally retained. CAC is implementing the following corrective actions: • Monthly Transportation Costs will be signed and dated by reviewer. • Establish grant compliance documentation retention protocol. • Establish Centralized federal grant compliance documentation repository. Management will perform periodic review to ensure documentation controls are consistently applied. Name(s) of the contact person(s) responsible for corrective action: Misty Goodwin, Chief Executive Officer, Anna Roeder, Chief Financial Officer. Planned completion date for corrective action plan: Documentation procedures were implemented in February 2026 and remain operational with ongoing monitoring.
Auditors’ recommendation: The Organization should modify its operations to the extent possible to improve operating results and stay in compliance with the loan agreement and debt workout agreement with the USDA. Auditee’s response: The Organization recognizes the challenges it is facing and conside...
Auditors’ recommendation: The Organization should modify its operations to the extent possible to improve operating results and stay in compliance with the loan agreement and debt workout agreement with the USDA. Auditee’s response: The Organization recognizes the challenges it is facing and considers its plan a sound approach to reaching compliance with the loan provisions in the debt workout agreement and loan agreement with the USDA.
"Recommendation We recommend that management: ▪ Implement formal procedures to ensure complete documentation of all program activities ▪ Maintain records demonstrating that activities are authorized and aligned with program objectives ▪ Establish centralized recordkeeping and retention policies ▪ Pe...
"Recommendation We recommend that management: ▪ Implement formal procedures to ensure complete documentation of all program activities ▪ Maintain records demonstrating that activities are authorized and aligned with program objectives ▪ Establish centralized recordkeeping and retention policies ▪ Perform ongoing monitoring and review of program activities ▪ Train staff on federal compliance requirements and documentation expectations"
Recommendation We recommend that management: ▪ Establish a formal reporting calendar outlining all required financial and performance reports, including due dates ▪ Implement procedures to ensure reports are prepared accurately, reviewed, and submitted timely ▪ Maintain documentation of submitted re...
Recommendation We recommend that management: ▪ Establish a formal reporting calendar outlining all required financial and performance reports, including due dates ▪ Implement procedures to ensure reports are prepared accurately, reviewed, and submitted timely ▪ Maintain documentation of submitted reports, including confirmation of submission and supporting schedules ▪ Assign clear responsibility for reporting compliance and implement supervisory review controls ▪ Provide training to relevant personnel on federal reporting requirements Strengthening reporting processes will improve compliance, enhance transparency, and ensure that the organization meets its obligations under federal awards.
Finding 2023-001: Preparation of the Schedule of Expenditures of Federal Awards - Significant Deficiency in Internal Control Over Compliance Program: U.S. Department of Health and Human Services – Medicaid Cluster Response and Corrective Action Plan: Management agrees with finding and will develop a...
Finding 2023-001: Preparation of the Schedule of Expenditures of Federal Awards - Significant Deficiency in Internal Control Over Compliance Program: U.S. Department of Health and Human Services – Medicaid Cluster Response and Corrective Action Plan: Management agrees with finding and will develop a written policy and procedure for managing the existence of federal assistance within all contracts. Anticipated Completion Date: by June 30, 2026 Responsible Person: Virginia Lui VP, Controller
A financial consultant was engaged to prepare procedures, workflows and training for a culture of sustained readiness for all audit reports. The issue has been identified causing slow submission of the required clearinghouse filing. The audit itself will be timely going forward with the filing requi...
A financial consultant was engaged to prepare procedures, workflows and training for a culture of sustained readiness for all audit reports. The issue has been identified causing slow submission of the required clearinghouse filing. The audit itself will be timely going forward with the filing requirement date, less than two weeks, as the final date for the audit to be completed, reviewed by the board, responded to by management, and filed.
The Crenulated will request a quarterly in-kind contribution report from DOE and will ensure the in-kind contributions are recorded in the financial statements. The Crenulated plans to hire an in-house Controller with expertise in accounting for grants and review its existing contract with current t...
The Crenulated will request a quarterly in-kind contribution report from DOE and will ensure the in-kind contributions are recorded in the financial statements. The Crenulated plans to hire an in-house Controller with expertise in accounting for grants and review its existing contract with current third-party accounting provider. Anticipated completion date This corrective action plan will begin immediately.
The County Board does not believe the finding is appropriate. The Recipient "partner" was not an elected official at the time of application or award. The funds were utilized to restore a building located in the County and owned by a County resident. The County Board believes that this award falls w...
The County Board does not believe the finding is appropriate. The Recipient "partner" was not an elected official at the time of application or award. The funds were utilized to restore a building located in the County and owned by a County resident. The County Board believes that this award falls within the parameters of economic development, one of the allowable uses of the funds. Again, the Auditor has failed to provide any legal basis for the belief of the Auditing Firm or what legal opinion they relied upon in forming their beliefs.
The County acknowledges delays in the preparation and submission of certain required federal reports, including Statements of Expenditures. These delays were attributable to data availability, process inefficiencies during the ERP transition period, and the timing in which the Statement of Expenditu...
The County acknowledges delays in the preparation and submission of certain required federal reports, including Statements of Expenditures. These delays were attributable to data availability, process inefficiencies during the ERP transition period, and the timing in which the Statement of Expenditures template was provided by the grantor. In response, the County is improving internal workflows by enhancing coordination between program and finance staff, strengthening review procedures, and standardizing reporting processes. These actions are intended to improve both the accuracy and timeliness of reporting as processes continue to be refined within the system environment.
The County acknowledges deficiencies related to the timeliness of federal reporting, including delays in the submission of required financial reports. Certain reports were not submitted within required timeframes due to challenges in obtaining timely and complete data, delays in completing reconcili...
The County acknowledges deficiencies related to the timeliness of federal reporting, including delays in the submission of required financial reports. Certain reports were not submitted within required timeframes due to challenges in obtaining timely and complete data, delays in completing reconciliations during and following the ERP transition, and the timing of required reporting templates provided by the grantor. The County is strengthening reporting procedures by improving coordination between departments, enhancing reconciliation processes, and reinforcing internal timelines for report preparation and review. As system functionality and staff familiarity continue to improve, reporting timeliness is expected to stabilize, with full resolution anticipated in the 2025 audit cycle.
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