Corrective Action Plans

Finding 496176 (2022-001)

Material Weakness 2022

CA

Allowable Costs / Cost Principles Material Weakness Reporting

Reference Number: 2022-001 Name of Contact Person: Tracy Largent Corrective Action: Staff inquired with the State Water Resources Control Board and with our auditors regarding if a single audit would be necessary for the funds received through the Water Arrearages Program. A definitive answer was ...

Reference Number: 2022-001 Name of Contact Person: Tracy Largent Corrective Action: Staff inquired with the State Water Resources Control Board and with our auditors regarding if a single audit would be necessary for the funds received through the Water Arrearages Program. A definitive answer was not available. In the future the District will include all funds that could possibly be considered federal, regardless of confirmation. Proposed Completion Date: 5/12/2023

View Audit 319067

Finding 486169 (2022-004)

Material Weakness 2022

Housing Authority of Brevard County

FL

HUD Housing Programs Material Weakness Special Tests & Provisions

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Excep...

2022-004 Special Tests and Provisions – Selection from the Waiting List Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Condition: 13 out of 123 new admissions were tested. Exceptions were noted as follows: • 3 tenant file errors where the HAP contract was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). • 1 tenant file error where the tenant’s application date, time, and preference did not agree to the date, time, and preference recorded on the waiting list. The tenant should have been housed earlier based on the tenant’s application date, time, and preference. • 1 tenant file had the following errors: o The HAP was not signed by the Authority until after 120 days of the tenant’s move-in date, but was signed by the landlord within 120 days of the tenant’s move-in date (adoption of HUD COVID waiver). o The tenant’s application date and time did not agree to the date, time, on the waiting list. The tenant should have been housed earlier based on their application date, time, and preference. • A separate waiting list was maintained for tenant based mainstream vouchers in the same county or municipality covered by the regular Section 8 waiting list (the mainstream waiting list has currently been exhausted). The Authority’s administrative plan does not allow a separate waiting list for the mainstream vouchers. In addition, the separate tenant based mainstream voucher waiting list was ranked randomly by the Authority’s system through a lottery ranking technique. This is not in compliance with the Authority’s administrative plan, which states that the waiting list should be organized by preference point and then by date and time of application (first come first serve basis). Recommendation: The Authority should correct the deficiencies and ensure staff is aware of acceptable procedures as outlined in the Authority’s Administrative plan. In addition, the Authority should review staffing levels, skill sets and case load. Furthermore, the Authority should utilize an ongoing quality control review process to ensure proper procedures are being followed. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review processes and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.

View Audit 318813

Finding 486166 (2022-003)

Material Weakness 2022

Housing Authority of Brevard County

FL

HUD Housing Programs Eligibility Material Weakness

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: O...

2022-003 Eligibility – Tenant Files Section 8 Housing Choice Vouchers Program – CFDA Number 14.871 Mainstream Vouchers – CFDA Number 14.879 Material Weakness in Internal Control and Material Noncompliance Repeat of Finding from March 31, 2021 (Finding 2021-003, Significant Deficiency) Condition: Out of a total tenant population of approximately 1,775 tenants, 25 files were selected for testing, but testing was suspended after 24 files due to the number of errors. Exceptions were noted as follows: • 1 tenant file error where the Authority performed their rent reasonableness procedures on a 2-bedroom unit for a 1-bedroom unit, and the comparable rents did not appear reasonable. • 1 tenant file had the following errors and correcting the errors would decrease the HAP rent by $23: o 1 error for miscalculation of the tenant’s social security income o 1 error for miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors: o Two members of the household did not check the box on the 214-affidavit form indicating their eligible immigration status, but based on their birth certificates, they have eligible immigration status. o Miscalculation of the tenant’s utility allowance amount. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file error where the utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. • 1 tenant file had the following errors: o The 50058 form reported the wrong number of bedrooms in the unit. o The tenant did not sign the lease agreement. • 1 tenant file error where the tenant’s utility allowance amount was calculated incorrectly. Correcting the utility allowance amount would not change the HAP rent. • 1 tenant file had the following errors & correcting the errors would decrease HAP rent $11: o Miscalculation of the tenant’s social security income o Miscalculation of the tenant’s medical expense. • 1 tenant file had the following errors and correcting the miscalculation of tenant’s income and utility allowance would decrease the HAP by $8.: o Miscalculation of the tenant’s supplemental security benefit o Miscalculation of the tenant’s utility allowance amount. o The tenant’s supplemental security benefit income was coded as social security income when it should have been coded as supplemental income on the 50058 form. o Missing 214-affidavit form for a member in the tenant’s household, but based on their birth certificate, they have eligible immigration status. o Member of the household, over the age of 18, did not sign and date the 9886 form. o The HAP contract was not signed and dated by the Authority. • 1 tenant file error due to a missing signed lead base paint form. • 1 tenant file had the following errors: o The 50058 form incorrectly reported the tenant’s monthly rent. Correcting this error increases the HAP rent by $8. o The lease agreement’s signature page is missing. • 1 tenant file error where the rent reasonableness procedure was performed one month after the tenant’s move-in date. The rent appears reasonable, but should have been performed before the tenant’s move-in date. • 1 tenant file had the following errors: o Missing HAP contract and lease agreement. o Missing rent reasonableness support. • 1 tenant file error for missing rent reasonableness support. • 1 tenant file had the following errors: o The utility allowance amount was calculated correctly but was reported incorrectly on the 50058 form. Correcting this error would not change the HAP rent. o The lease agreement’s signature page is missing. • 1 tenant file had the following errors: o Miscalculation of the tenant’s social security income. Correcting the miscalculation would decrease the HAP by $2. o Miscalculation of the tenant’s annual unreimbursed medical expense. Correcting the miscalculation would have no effect on the HAP rent. o The tenant’s name was reported incorrectly on the 50058 form. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o A member of the household over the age of 18 didn’t sign and date the 9886 form. o General assistance was included as household income when it should have been excluded. Correcting this error would increase the HAP rent by $12. o Missing rent reasonableness support. o The landlord did not sign the lease agreement. • 1 tenant file had the following errors: o A member of the household did not check the checkbox on the 214-form indicating their immigration status. However, based on the tenant’s birth certificate, the tenant has eligible immigration status. o Missing support for total annual unreimbursed childcare costs. o Missing support for total annual unreimbursed medical expense. Recommendation: The Authority should correct the deficiencies noted in the tested files and utilize an ongoing quality control review process on the entire tenant population to ensure proper compliance with the requirements related to tenant eligibility. Ongoing staff training and timely management reviews should be utilized to ensure staff is aware of acceptable procedures. In addition, the Authority should review staffing levels, skill sets and case load. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were unable to provide an ongoing quality control review processes and provide ongoing staff training and timely management reviews. We are focused on implementing such procedures and will review staffing levels, skill sets, and case load for each employee.

View Audit 318813

Finding 485737 (2022-004)

Material Weakness 2022

First Choice Community Healthcare, Inc.

NM

Questioned Costs Allowable Costs / Cost Principles Equipment & Real Property Management

2022-004—Allowable Costs Corrective Action: FCCH Management shall conduct training of human resource and accounting personnel to ensure they understand the requirement for allowable costs under 2 CFR Part 225 and shall follow the principles in 2 CFR Part 200, Subpart E. Current policies and procedu...

2022-004—Allowable Costs Corrective Action: FCCH Management shall conduct training of human resource and accounting personnel to ensure they understand the requirement for allowable costs under 2 CFR Part 225 and shall follow the principles in 2 CFR Part 200, Subpart E. Current policies and procedures shall be reviewed to ensure adequacy of measures to ensure compliance. FCCH leadership shall also be trained in the elements of allowable cost principles. Person Responsible: Shawna Gonzales, Chief Financial Officer and Abigail Jackson, Human Resources Director Completion Date: December 31, 2024

View Audit 318579 Questioned Costs: $1

Finding 485553 (2022-001)

Material Weakness 2022

Jewish Family Services of Silicon Valley

CA

Matching / Level of Effort / Earmarking Material Weakness

Finding 2022-001: Material Weakness in internal controls over compliance for earmarking and material noncompliance for earmarking in the U.S. Refugee Admissions Program: Effect: The Organization may not have met earmarking requirements outlined in the underlying award agreements nor have control...

Finding 2022-001: Material Weakness in internal controls over compliance for earmarking and material noncompliance for earmarking in the U.S. Refugee Admissions Program: Effect: The Organization may not have met earmarking requirements outlined in the underlying award agreements nor have controls to monitor that earmarking requirements were met effectively. Auditor's Recommendation: We recommend that the Organization implement a process to identify the value of direct assistance provided to each eligible refugee as recorded within the financial records. Further, we recommend that internal controls over compliance be implemented to monitor direct aid distribution and meet the earmarking requirements included within the grant terms. Management Response: We agree with the recommendation and have also submitted the following response. In accordance with the U.S. Department of State, Bureau of Population, Refugees, and Migration (PRM) FY 2019 Reception & Placement (R&P) Cooperative Agreement, all affiliates are required to have written documents available for review evidencing the following: · R&P refugee per capita disbursement policy · How refugee per capita funds beyond the $975 minimum are spent (i.e., Flex Funds policy) · Pocket money disbursement policy · Structured training plan for new and existing staff · Policy on protection from sexual exploitation and abuse (PSEA) · Grievance policy · Policy on cultural orientation (CO) delivery and assessment of refugee understanding · Implementation of accountability to affected populations (AAP) framework Jewish Family Services of Silicon Valley ( JFSSV) has adequate policies and procedures and follows the grantor's guidelines on per-capita earmark funds as stated by the Funder. JFSSV will continue to follow the funder-approved policies and procedures, which state the following: “Per capita funds can be paid by the affiliate directly to the third party, or the affiliate may reimburse U.S. ties or clients for purchases as long as receipts are provided evidencing that the purchases were for allowable material needs. If there are per capita funds remaining at the end of the R&P period and all possible material needs have been provided to the case, including paying rent and utilities forward, the affiliate may write a check to the client for the remainder of the funds. The affiliate must ensure that the situation has been thoroughly documented in the case note log and that the case has no outstanding material needs. This option should be considered an exception and used sparingly.” JFSSV makes every effort to provide the minimum amount to all referred clients as required by the funder. JFSSV meets with clients to provide the initial per capita funding and reviews program requirements for the next per capita funding. If the client follows the program, they are funded. Sometimes, clients leave the program or do not provide adequate documents to be funded, resulting in unspent per capita funds. When this occurs, JFSSV follows the Cooperative Agreement #12.9 Availability of Per Capita Funds: A written statement must be submitted on or before December 31, 20xx, as a Post Award Task through [website link] reporting the amount of per capita funds and accrued interest unexpended and available as of September 30, 20xx. This statement must confirm the amount of those funds expended and reported as a part of the quarterly financial reports for October 1, 20xx, through September 30, 20xx. Should the Recipient have any unexpended per capita funds as of the financial report due on March 31, 20xx, such funds must be returned to the Bureau no later than April 30, 20xx. In addition, JFSSV undergoes vigorous monitoring visits, monthly invoice reviews, and program/fiscal audits, which they pass. JFSSV has provided Harshwal & Company LLP with contracts, cooperative agreements, program guidelines, internal Funder-approved policies & procedures, and all testing requirements with client backup. To address the specific concerns raised regarding internal controls over compliance and earmarking requirements, JFSSV will continue to: Enhanced Monitoring Process: JFSSV will continue monitoring processes to track the value of direct assistance provided to each eligible refugee. Internal Controls Implementation: JFSSV will continue reviewing its internal controls to oversee direct aid distribution with the funder and ensure all requirements are met effectively. Documentation and Reporting: JFSSV will continue to review all disbursements to ensure they are thoroughly documented and reported. This will include maintaining receipts, case notes, and other relevant documentation to provide clear evidence of compliance with earmarking requirements.

View Audit 318323

Finding 485461 (2022-004)

Material Weakness 2022

Community Development Partnership

MA

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.303

A consistent and substantiated methodology for accounting for indirect costs to be allocated was implemented in FY 23 and remains in place. Anticipated Completion Date-Completed.Responsible Contact Person-Kathleen Boyce, CFAO

View Audit 318188

Finding 485451 (2022-005)

Significant Deficiency 2022

County of Imperial

CA

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

2022-005 Temporary Aid for Needy Families (TANF) Federal Financial Assistance Listing Number: 93.558 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 1946001347-A7 2022 Compliance Requirements: Eligibility ...

2022-005 Temporary Aid for Needy Families (TANF) Federal Financial Assistance Listing Number: 93.558 Federal Grantor: U.S. Department of Health and Human Services Pass-Through: California Department of Social Services Award No. and Year: 1946001347-A7 2022 Compliance Requirements: Eligibility Type of Finding: Significant Deficiency Management’s or Department’s Response: Imperial County Department of Social Services agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The Count of Imperial, Department of Social Services, is committed to maintaining robust monitoring and oversight controls in place to ensure that applicant eligibility is thoroughly reviewed and approved. The Department will continue to monitor compliance with policies to ascertain that eligibility technicians follow guidelines for redetermination of recipients of need and amount of assistance, including to retain acceptable documentation to support the determinations. The Department will implement enhances training and guidance to include refresher training that will be developed based on needs identified during this review. The training will address any changes in regulations and/or internal processes. Name of Responsible Person: Paula S. Llanas, County of Imperial – Department of Social Services Director Implementation Date: September 1, 2024

View Audit 318179

Finding 485448 (2022-007)

Significant Deficiency 2022

County of Imperial

CA

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

2022-007 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA111008 and 2021 Compliance Requirements: Reporting Type of Finding...

2022-007 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA111008 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: ICWDO acknowledges the recommendation and is actively working on a remedy and on the development of formal policies as recommended, which will assist ICWDO’s fiscal team in ensuring that all reports are appropriately reconciled. ICWDO acknowledges the recommendations from finding 2021-010 related to a formalization of the Administrative/fiscal processes and protocols to ensure that procedures are consistently followed to guarantee that reports agree to the amounts recorded in the general ledger and SEFA. Additionally, the recommendation specifics that protocols to ensure the separation of duties are featured in the policy. ICWDO operates under WIOA guidelines and follows County fiscal/administrative policies. Internal policies that include formal controls and procedures to ensure that monthly reports and general ledgers are consistent, with clear segregation of duties will be formally adopted. Aspects of these policies will include: • Protocol for preparation of monthly reports by the fiscal manager, and approval and signature by ICWDO Director • Protocol for preparation of closeouts that will provide the hierarchy of development, review, and approval for future reference. • Schedule monthly closeout meetings with the fiscal department and administration to ensure that documents are reviewed separately, and issues are addressed promptly. • Protocol for Policy Committee review, comment and direction, and approval for implementation by vote of the full workforce development board. ICWDO anticipates to implement the corrective action by December 31, 2023. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2023

View Audit 318179

Finding 485287 (2022-004)

Significant Deficiency 2022

American Association of Physics Teachers, Inc.

MD

Matching / Level of Effort / Earmarking Significant Deficiency § 200.303

Finding 2022-004: Payroll Federal Programs: Research and Development Cluster: 47.0746 Condition: Payroll approvals for individuals are not always made by individuals who are the employee's supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Vie...

Finding 2022-004: Payroll Federal Programs: Research and Development Cluster: 47.0746 Condition: Payroll approvals for individuals are not always made by individuals who are the employee's supervisors or are otherwise knowledgeable about their level of effort during the payroll periods paid for. Views of Responsible Officials and Planned Corrective Actions: AAPT has made changes to correctly reflect the employee’s assigned supervisor based on the position and job duties of the employees. Anticipated Completion Date: 04/01/2024 Responsible Official: Michael Brosnan, CFO

View Audit 318055

Finding 485286 (2022-003)

Material Weakness 2022

American Association of Physics Teachers, Inc.

MD

Material Weakness Reporting Matching / Level of Effort / Earmarking § 200.302 § 200.508 § 200.510

Finding 2022-003: Reconciliation of Accounts Federal Program: Research and Development Cluster: 47.076 Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials an...

Finding 2022-003: Reconciliation of Accounts Federal Program: Research and Development Cluster: 47.076 Condition: The year-end schedules for federal grants receivable, for net assets, and for vacation payable were not reconciled and needed to be revised and updated. Views of Responsible Officials and Planned Corrective Actions: The outstanding liability due to NSF of $115,244 will be reimbursed when AAPT files the next drawn down request. Anticipated date of drawn down will be by July 31,2024. The senior accountant will be trained to prepare entries previously prepared by the CFO The senior accountant will reconcile accounts, and provide updated current schedules. The CFO will review and approve the entries and schedules prepared by the Senior accountant. Anticipated Completion Date: 08/01/2024 Responsible Official: Michael Brosnan, CFO

View Audit 318055

Finding 485164 (2022-001)

None 2022

Partnership Homes, Inc.

NC

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.512

Partnership Homes, Inc. Greensboro, North Carolina CORRECTIVE ACTION PLAN February 1, 2024 Federal Audit Clearinghouse 1201 East 10t...

Partnership Homes, Inc. Greensboro, North Carolina CORRECTIVE ACTION PLAN February 1, 2024 Federal Audit Clearinghouse 1201 East 10th Street Jeffersonville, Indiana 47132 Partnership Homes, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2022. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended December 31, 2022 The finding from the December 31, 2022 Schedule of Findings and Questioned Costs is discussed below. Findings - Federal Award Programs Audits The finding is numbered consistently with the number assigned in the schedule. Finding No. 2022-001: HOME Investment Partnerships Program , CFDA #14.239 Recommendation: We recommend management ensure that the data collection forms are submitted electronically to the FAC within the required due dates each fiscal year going forward. Management's Response: We agree with Finding 2022-001 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will provide additional oversight to ensure the data collection forms are submitted electronically to the FAC each fiscal year going forward within required due dates. The data collection form for the year ending December 31, 2021 was submitted to the FAC on April 4, 2023. If you have questions regarding this plan, please call Mike Cooke at (336) 707-5289. Sincerely yours, Mike Cooke Executive Director Partnership Homes, Inc.

View Audit 317974

Finding 484708 (2022-001)

Material Weakness 2022

Mark Twain Association for Mental Health Inc.

MO

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Cash Management § 200.302 § 200.430

May 3, 2024 Re: SAMHSA Notice of Award for 6H79SM083161-01M003 MTBH submitted our budget based on anticipated salary costs for new hires, which we believe stayed at or below our actual costs. We made available all necessary documentation requested from payroll, grant-related expenses, grant reports...

May 3, 2024 Re: SAMHSA Notice of Award for 6H79SM083161-01M003 MTBH submitted our budget based on anticipated salary costs for new hires, which we believe stayed at or below our actual costs. We made available all necessary documentation requested from payroll, grant-related expenses, grant reports and timekeeping records to Wade Stables P.C for review. We did not have the grant in our financial software as we were beginning a migration to new software during the early stages of the grant; therefore, we tracked that grant on an excel spreadsheet that annually was provided to our auditors. Most of the staff assigned to the grant were full-time staff, so time allocation was easily tracked. For the few staff that were part-time we had designated codes in our Electronic Medical Record to identify work done on behalf of the grant. In response to Finding 2022-001- B Allowable Costs, we agree with the Statement of Cause citing the exponential growth of the organization regarding preparedness for a first-time grant award of this size being our largest challenge. Initially we were informed we had not received the grant then, due to additional COVID funding, we were invited to participate in the grant with a very short turnaround to finalize budgets and hire staff. Our salaries are consistent with the positions designated in the grant and in a few cases our staff salaries exceeded the allowable costs; therefore, those allowable costs were used to calculate the drawdown. MTBH did not have an established de minimis rate; therefore, we used the 10% designated rate associated with the grant. The interactive Budget Narrative Form template, required per SAMHSA guidelines, had 10% built into the template. If afforded future opportunities to secure a SAMSHA grant, we would be better positioned to execute the financial management in our SAGE software to segregate costs for the purpose of tracking the expenditures associated agency grant operations. Currently all agency expenditures have transferred into SAGE by our Vice President of Finance, Jenny Haught MBA, which would also be the Responsible Official to fiscally manage future grants. Respectfully, Angela Caraway, VP of Clinical Operations

View Audit 317609

Finding 481368 (2022-001)

Material Weakness 2022

Monongalia Health System, Inc. and Subsidiaries

WV

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

Corrective Action Planned: Subsequent to the filing of the Period 1 reports Monongalia Health System, Inc. and Subsidiaries instituted new policies and procedures surrounding the use, tracking and reporting on federal funds, including the Provider Relief Fund and American Rescue Plan Act (ARP) Rural...

Corrective Action Planned: Subsequent to the filing of the Period 1 reports Monongalia Health System, Inc. and Subsidiaries instituted new policies and procedures surrounding the use, tracking and reporting on federal funds, including the Provider Relief Fund and American Rescue Plan Act (ARP) Rural Distribution. Under the new policies and procedures the usage of all funds is accumulated and reviewed on a monthly basis, and all reporting is subjected to reviews by the VP’s of Finance prior to reporting. Name(s) of Contact Person(s) Responsible for Corrective Action: Kevin Gessler, VP of Finance and Rick Scherich, VP of Finance are responsible for effectuating updated procedures Anticipated Completion Date: Updated Policies and procedures were implemented on September 30, 2023

View Audit 317404

Finding 481168 (2022-010)

Material Weakness 2022

Trinity Acres Housing Corporation

IL

Procurement, Suspension & Debarment HUD Housing Programs Matching / Level of Effort / Earmarking

The Corporation will register and apply for PPP Forgiveness via the SBA PPP Direct Forgiveness Portal or contact SBA Customer Service at 877-552-2692.

View Audit 317262

Finding 481153 (2022-001)

Material Weakness 2022

Trinity Acres Housing Corporation

IL

Matching / Level of Effort / Earmarking

The Management Agent will properly review all statement of financial position and statement of activity accounts to determine no material misstatements on a monthly basis.

View Audit 317262

Finding 481134 (2022-017)

Significant Deficiency 2022

Unity Health Care, Inc.

MD

Matching / Level of Effort / Earmarking § 200.303 § 200.306

Management Response #2022-017: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, wh...

Management Response #2022-017: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, which made it extremely difficult to find supporting documentation. Corrective Action Plan: The procedures adopted in 2024 will be formally documented and published that will ensure proper cost sharing or matching are clearly understood and defined. The requirements for matching as well as consistent monitoring metrics will be outlined in the procedures document as well. Greater and enhanced documentation will be properly maintained and available for review as required. Responsible Party: Tamara Barnes, CFO

View Audit 317252

Finding 481117 (2022-009)

Material Weakness 2022

Unity Health Care, Inc.

MD

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.305

Management Response #2022-009: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, wh...

Management Response #2022-009: Due to the staff shortages and turnover in FY2020-2022 the company did not have adequate personnel in place to monitor or document grant activity. Formal documentation of policies and procedures were also deficient. Additionally, documents were not stored centrally, which made it extremely difficult to find supporting documentation. Corrective Action Plan: The following action plans have since been implemented: • During the fourth quarter in 2022, finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • During the fourth quarter in 2022 a new process was implemented to track grant related activities. Prior to any drawdown, the expenses are pulled from the G/L and reviewed. The expenses are entered into a spreadsheet and totaled based on the applicable federal award which has been assigned a client ID in the accounting system. The finance team is notified of the amount due to be drawn for each federal award. That amount is entered into the accounting system as an accounts receivable entry. This process has been formally documented. • Project Budget Reports have been created for each federal award. These reports include the budget, expenses for each month and the revenue (drawdown) incurred for each month. The reports will be reviewed and reconciled by the grants administration staff and finance monthly to ensure all agree with the allocated costs and costs and are in compliance with grant regulations. Once approved by both teams the reports will be routed for signatures. This process was launched in July 2022. • Supporting documentation for all draws will be maintained on a shared network drive so that an adequate audit trail will be established. This drive will be backed up on a regular basis by the Information Technology team. Responsible Party: Tamara Barnes, CFO

View Audit 317252

Finding 481115 (2022-006)

Material Weakness 2022

Unity Health Care, Inc.

MD

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.431

Management Response #2022-006: Due to turnover of several key financial executives and personnel, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Corrective Action Plan: Due to the staff turnover and shortage in 2020-2021, this process was not consistently ...

Management Response #2022-006: Due to turnover of several key financial executives and personnel, the Corporation did not maintain evidence of fringe benefit cost objectives calculations. Corrective Action Plan: Due to the staff turnover and shortage in 2020-2021, this process was not consistently maintained or documented. The following action items have been or will be taken: • In 2022, finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • The grants finance department will also create actual to budget reports in accordance with HRSA guidelines for fringe costs. • The report will be reconciled monthly based on fringe costs allowed by the grant as it relates to the employee class such as part time or providers that may have additional benefits. Adjustments will be recorded in the GL (General Ledger) accordingly. Responsible Party: Tamara Barnes, CFO

View Audit 317252

Finding 481114 (2022-005)

Material Weakness 2022

Unity Health Care, Inc.

MD

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.430

Management Response #2022-005: The time keeping system and process does not currently allow tracking of time based on funded resources. The past practice had been for the finance department manually calculated salary allocations but due to staff turnover in FY2021-22, the process was not consistentl...

Management Response #2022-005: The time keeping system and process does not currently allow tracking of time based on funded resources. The past practice had been for the finance department manually calculated salary allocations but due to staff turnover in FY2021-22, the process was not consistently followed. Corrective Action Plan: The following action items have been or will be taken: • In 2022, the finance team delineated and expanded positions whose primary responsibility is to monitor and manage all grant activities. • Monthly time and effort reports to include recorded time worked under each grant will be sent to the employee and require employee and supervisor approval. • As of 2022 salary/wages are allocated to federal grants based on actual costs received from payroll. • Finance Management will also create actual to budget reports in accordance with HRSA (Health Resources and Services Administration) guidelines for salaries/wages and hours. The report will be reconciled monthly. • Human Resources department will collaborate with the Grants and Finance teams to ensure grants hours is added as an option within the timekeeping system for accurate recording for FY24. Responsible Party: Tamara Barnes, CFO

View Audit 317252

Finding 481089 (2022-004)

Material Weakness 2022

National Casa Association

WA

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

Responsible: Thomas Hoover, CFO Corrective Actions: Update Finance policies to specify that documentation of review and approval of both the costs charged and the allocation methods of costs charged to federal grants be maintained. Completion Date: March 29, 2023 Explanation: Policies have bee...

Responsible: Thomas Hoover, CFO Corrective Actions: Update Finance policies to specify that documentation of review and approval of both the costs charged and the allocation methods of costs charged to federal grants be maintained. Completion Date: March 29, 2023 Explanation: Policies have been in place over the coding of costs allocated to federal grants in compliance with CFR 200 and were enhanced in 2023 in response to an OJJDP/OCFO recommendation. Review and approval of costs after being approved by an authorized signer takes place in multiple steps and concludes with preparation of reimbursements and financial grant reports (FFR). In order to further demonstrate compliance as recommended, Management has updated Finance policies to capture the documentation and maintenance of such documentation of Supervisory review and approval.

View Audit 317239

Finding 481085 (2022-003)

Material Weakness 2022

National Casa Association

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.430

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to document and maintain the documentation of Supervisory review and approval of journal entries charging payroll costs to federal grants; 2) Update Finance policies to review estimates of accrued costs charged to feder...

Responsible: Thomas Hoover, CFO Corrective Actions: 1) Update Finance policies to document and maintain the documentation of Supervisory review and approval of journal entries charging payroll costs to federal grants; 2) Update Finance policies to review estimates of accrued costs charged to federal grants at calendar/fiscal year end to determine whether true-ups to actual costs are necessary. Completion Date: March 29, 2023 Explanation: 1) Review of allocated payroll costs: Payroll processing and recording of costs charged to federal grants has in practice, consistently involved multiple review and approval steps by at least two employees. Detailed records of these steps are maintained in Finance records for each payroll, including the allocated grant costs. However, Management acknowledges that an additional step be added to capture the documentation of review and approval of the payroll journal entries that allocate payroll costs to federal grants. This step was put in place in 2023 to resolve a recommendation from OJJDP/OCFO. Supervisor review and approval is captured directly in the general ledger system. Finance policies have been updated to codify this additional step as recommended. 2) Procedure for trueing up estimates: Three of sixty transactions tested showed that payroll costs were accrued at year end based on the approved grant budget but were not trued up in the new accounting period based on actual costs. The total variance of the three transactions was $6.20. Finance policies have been updated to include evaluating year-end accruals to determine whether a true-up is necessary in the new period as recommended.

View Audit 317239

Finding 480993 (2022-002)

Material Weakness 2022

Brookfield Local School District

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.414 § 200.502 § 200.510

All future federal expenditures will be reconciled to the disbursement ledger.

View Audit 317104

Finding 480844 (2022-003)

Material Weakness 2022

Mt Pleasant Housing Develpment Fund Company

NY

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Finding No. 2022-003; Supportive Housing for the Elderly (Section 202), CFDA 14.157 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended November 30, 2022, the project paid expenses in the amount of $326,282 on behalf of ...

Finding No. 2022-003; Supportive Housing for the Elderly (Section 202), CFDA 14.157 Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Condition During the year ended November 30, 2022, the project paid expenses in the amount of $326,282 on behalf of other affiliates from project cash without HUD approval. The amount due to the project as of November 30, 2022 is $326,282. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $326,282 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $326,282 Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code: B – Allowable Costs/Cost Principles Views of Responsible Officials and Planned Corrective Actions Because the PRAC renewals were so delayed, therefore there was no money available to pay back the project. Furthermore, the insurance costs are tremendous and had to be financed. In order to ensure the payments are applied and paid timely it is best to have the entire amount pulled from one bank account. If each entity were to pay its share it would cause confusion and may result in possible cancellation. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates.

View Audit 316973 Questioned Costs: $1

Finding 480842 (2022-002)

Material Weakness 2022

Casita Park Housing Development Fund Corporation

NY

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Finding 2022-002 Unauthorized loans from project assets Comments on the Finding and Each Recommendation Statement of Condition During the year ended September 30, 2022, the project paid expenses in the amount of $81,886 on behalf of an affiliate from project cash without HUD approval. The amount due...

Finding 2022-002 Unauthorized loans from project assets Comments on the Finding and Each Recommendation Statement of Condition During the year ended September 30, 2022, the project paid expenses in the amount of $81,886 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2022 is $81,886. Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to project operating costs. Effect or Potential Effect The payments of $81,886 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $ 81,886. Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code B – Allowable Cost/Costs Principles Reporting Views of Responsible Officials The Corporation agrees with the finding and the auditor's recommendations have been adopted. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates..

View Audit 316972 Questioned Costs: $1

Finding 480841 (2022-002)

Material Weakness 2022

Lucille Clark Housing Development Corporation

NY

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

2- Finding No. 2022-002; Unauthorized loans from project assets Statement of Condition During the year ended September 30, 2022, the project paid expenses in the amount of $32,736 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2022...

2- Finding No. 2022-002; Unauthorized loans from project assets Statement of Condition During the year ended September 30, 2022, the project paid expenses in the amount of $32,736 on behalf of an affiliate from project cash without HUD approval. The amount due to the project as of September 30, 2022 is $32,736. Criteria Loans are not permitted to be made from project cash without prior authorization from HUD. Cause Procedures were not in place to ensure that cash disbursements of project funds were limited to approved project operating costs. Effect or Potential Effect The payments of $32,736 were unauthorized loans and therefore considered to be questioned costs. Questioned Costs $32,736. Recommendation Management should immediately reimburse the amount due to the project and establish procedures to ensure payments of this nature are not made in the future. Auditor Noncompliance Code B – Allowable Cost/Costs Principles Reporting Views of Responsible Officials The Corporation agrees with the finding and the auditor's recommendations have been adopted. Upon finalizing the audits and submitting to HUD, management intends to request funds from the replacement reserve to enable them to pay down the due from affiliates.

View Audit 316971 Questioned Costs: $1

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