Corrective Action Plans

Finding 3916 (2022-009)

Material Weakness 2022

Union Theological Seminary in the City of New York

NY

Student Financial Aid Matching / Level of Effort / Earmarking Reporting

This Repeat Finding has been acknowledged and corrective action is already in the process of being implemented. In November 2022, Union signed a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as edu...

This Repeat Finding has been acknowledged and corrective action is already in the process of being implemented. In November 2022, Union signed a Master Service Agreement with the National Student Clearinghouse (NSC) to perform enrollment and educational financial industry reporting, as well as education verification and authentication services. National Clearinghouse is the leading provider of educational reporting and data exchange, reporting on 97% of post-secondary student enrollments in the US. Union will be using a secure FTP process to send our enrollment data to NSC for timely and consistent reporting to the National Student Loan Data System (NSLDS). This Spring, Union completed the initial portion of the implementation by uploading a base set of enrollment data to NSC using Spring 2023 enrollment information. This was followed by one round of data clean-up. A second set of enrollment data was transmitted in December 2023. The Registrar and Financial Aid Director have been provided direct access to both NSC and NSLDS. As a backup, the Associate Dean of Academic Administration and Vice President of Admissions and Financial Aid have been granted NSC login credentials in order to ensure continuity of reporting in case of employee absence. The Registrar’s Office plans to begin regular monthly uploads of enrollment data to NSC beginning January 2024.

View Audit 6166

Finding 3872 (2022-003)

None 2022

Camcare Health Corporation

NJ

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.305 § 200.308 § 200.309 § 200.403

Finding Numbers 2022-002 and 2022-003 Planned Corrective Action: To date, management has already started additional training with the team responsible for grants and any communications between them and HRSA. The accounting department has also been advised to insist on more written documentation pri...

Finding Numbers 2022-002 and 2022-003 Planned Corrective Action: To date, management has already started additional training with the team responsible for grants and any communications between them and HRSA. The accounting department has also been advised to insist on more written documentation prior to assigning expenses to grants. Anticipated Completion Date: November 30, 2023 Responsible Contact Persons: Jillian Hudspeth, CEO Christopher Bernardi, CFO

View Audit 6120 Questioned Costs: $1

Finding 3640 (2022-010)

Significant Deficiency 2022

Guam Department of Education

GU

Matching / Level of Effort / Earmarking

Finding No.: 2022-010 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425A Education Stabilization Fund – State Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425A210003 Area: Matching, Level of Effort, Earm...

Finding No.: 2022-010 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425A Education Stabilization Fund – State Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425A210003 Area: Matching, Level of Effort, Earmarking Questioned Costs: $0 Views of Auditee and Corrective Actions: The GDOE disagrees with the finding. GDOE does not meet the definition of a State, nor does GDOE control the direct funding support (appropriations) for elementary and secondary education; or higher education. GDOE can only provide its calculation based on the projected levels of support (for elementary and secondary education) utilizing the formula guidance on MOE calculations issued by USEd. The calculation is based on appropriation levels provided by the Guam Legislature. Additionally, the figures calculated for FY22 are preliminary until the audited financials are provided for final submission of MOE data. Preliminarily, GDOE calculated the OA maintenance of effort to fall short by less than 1%

View Audit 5640

Finding 3636 (2022-006)

Significant Deficiency 2022

Guam Department of Education

GU

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

Finding No.: 2022-006 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Area: Period of Performance Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE agrees with the finding. In GDOE’s Munis system, if the Human Resou...

Finding No.: 2022-006 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Area: Period of Performance Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE agrees with the finding. In GDOE’s Munis system, if the Human Resources (HR) pay records are not accurately updated, GDOE payroll will reflect dated pay tables until such time HR makes the appropriate updates based on the project leads request to update accounts to current grant year. GDOE corrected the improperly charged payroll expenditures to the proper grant year via the journal voucher process. Plan of action and completion date: The GDOE Business Office will perform a monthly review of all transactions to ensure charges are recorded in the appropriate grant year. Additionally, Grant Project Managers and Program Coordinators will timely communicate to the Human Resources and Business Office any changes to accounts charged for federally funded payroll expenditures. Plan to monitor and responsible officials: GDOE Comptroller (vacant), will assign an accountant to monitor the expenditures of federal grants and the corresponding periods of performance and liquidation periods. Grant Project Managers, Federal Compliance review team will be responsible for timely communicating any changes in grant year funding to HR.

View Audit 5640

Finding 3632 (2022-004)

Significant Deficiency 2022

Guam Department of Education

GU

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No.: 2022-004 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education – Grants to States Area: Period of Performance Questioned Costs: $1,835 Views of Auditee and Corrective Actions: GDOE agrees with the finding. During the period of performance in question, the TPF...

Finding No.: 2022-004 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education – Grants to States Area: Period of Performance Questioned Costs: $1,835 Views of Auditee and Corrective Actions: GDOE agrees with the finding. During the period of performance in question, the TPFA issued check no. 2012949 to a vendor in February 2022, within the liquidation period. However, the TPFA indicated that the vendor lost the check and the TPFA re-issued payment to the vendor on January 29, 2023. The untimely reissuance of the check resulted in the transaction occurring one day after the liquidation period expired. Plan of action and completion date: As of April 2023, the TPFA has not been issuing checks to vendors, as the responsibility was returned to the GDOE to process all fiscal transactions within the GDOE Munis. The Business Office will closely monitor grant liquidation dates and payments to vendors. SOPs will be reviewed to update the procedures for monitoring grant period of performance. Plan to monitor and responsible officials: The Deputy of Finance and Administrative Services, Joann Camacho, as well as the GDOE Comptroller (vacant), will assign an accountant to monitor the expenditures of federal grants and the corresponding periods of performance and liquidation periods.

View Audit 5640 Questioned Costs: $1

Finding 3497 (2022-005)

Material Weakness 2022

Mental Health America of Wisconsin, Inc.

WI

Cash Management Reporting Matching / Level of Effort / Earmarking

• Condition: During testing of required financial reports and invoices, we noted differences in the amounts of expenses reported to grantors compared to actual expenses incurred during those periods. • Response Response MHA relies on our accounting representative to ensure that the invoices submitte...

• Condition: During testing of required financial reports and invoices, we noted differences in the amounts of expenses reported to grantors compared to actual expenses incurred during those periods. • Response Response MHA relies on our accounting representative to ensure that the invoices submitted to the accountant each week are added to the appropriate GL account to ensure the cost report reflects the correct amounts being reported to the grantors match the actual expenses incurred. • Planned Corrective Action: Again, monthly meetings reviewing the cost reports and GL together will reduce mistakes like this from MHA and the Accounting Rep. moving forward. MHA and the Accounting Rep will review the expenses being submitted for reimbursement together to ensure expenses incurred match the expenses being reported to the grantor.

View Audit 5476

Finding 3491 (2022-003)

Material Weakness 2022

Mental Health America of Wisconsin, Inc.

WI

Questioned Costs Cash Management Matching / Level of Effort / Earmarking § 200.305

• Condition: During our testing of reimbursement requests, we identified amounts that were requested for reimbursement prior to the expenses being incurred. • Response MHA relies on our accounting representative to ensure that the invoices submitted to the accountant each week are added to the appro...

• Condition: During our testing of reimbursement requests, we identified amounts that were requested for reimbursement prior to the expenses being incurred. • Response MHA relies on our accounting representative to ensure that the invoices submitted to the accountant each week are added to the appropriate GL account to ensure the account is being invoiced for the correct expenses during the proper timeframe. • Planned Corrective Action: During the newly established monthly meetings that will take place, MHA and the Accounting Rep will review the expenses being submitted for reimbursement together to ensure no invoices are submitted in advance.

View Audit 5476 Questioned Costs: $1

Finding 3472 (2022-004)

Material Weakness 2022

Center for Disease Dynamics Economics & Policy Inc.

MD

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.302 § 200.303

Agree with the finding. We will implement the segregation of duties matrix as part of SOPs. We will ensure that authorization and review of cash draws of fedral funds are done by some one other than the individual who initiates and records the transaction . We have implemented the same and Dr EIli (...

Agree with the finding. We will implement the segregation of duties matrix as part of SOPs. We will ensure that authorization and review of cash draws of fedral funds are done by some one other than the individual who initiates and records the transaction . We have implemented the same and Dr EIli (pi) is reviewing and approving the report before each withdrawal. The Finance Head ( Nafih) is withdrawing the fund .Anticipated Completion Date : 12/31/2022 Actual date of implementation :01/24/2023

View Audit 5453

Finding 3440 (2022-001)

Material Weakness 2022

Bossier Office of Community Services, Inc.

LA

Matching / Level of Effort / Earmarking § 200.302

The agency developed a corrective action plan that included creating a new policy and training staff in its use. Bank reconciliations are completed by the Finance Director within 5 to 10 days after receipt of bank statements. After completion of reconciliations, the finance director must provide the...

The agency developed a corrective action plan that included creating a new policy and training staff in its use. Bank reconciliations are completed by the Finance Director within 5 to 10 days after receipt of bank statements. After completion of reconciliations, the finance director must provide the executive director with the bank reconciliation and supporting general ledger for reverification.

View Audit 5404

Finding 3387 (2022-014)

None 2022

City of Philadelphia

PA

Questioned Costs Subrecipient Monitoring Reporting

Assistance Listing 21.023 Emergency Rental Assistance Program (ERAP) ...

Assistance Listing 21.023 Emergency Rental Assistance Program (ERAP) Views of the Responsible Officials and Corrective Action Plan: We disagree with the finding regarding spending reported to the Commonwealth of Pennsylvania. Prior to April 2022, reporting to the state was generated from a reporting dashboard within the Quickbase database. Internal controls checking these reports against raw data revealed an issue with the programming of the dashboard, and beginning in April 2022, reports were generated using raw data downloaded from the portal. Once this issue was detected and resolved, PHDC and the City sent updated and corrected reporting to the Commonwealth, along with a statement detailing our shift in methodology. This shift, and the corrected reports, were accepted by the Commonwealth, as shown in the email chains that were provided to the Controller’s Office. The data underlying the original ERA1 and ERA2 January 2022 reports cited in the finding cannot be recreated since the errors have now been permanently corrected. Auditor’s Comments on Agency’s Response: Regarding the corrected reports provided via email chains with the Commonwealth to our office, we have the following comment: Only one email chain provided had an attached “updated historical check” for ERAP1, submitted to the Commonwealth in July 2022. The historical check included a line item for the month in question, January 2022, but was still reporting the amounts of $173,807 and $22,042 for the Administrative Paid categories (See Table 6). These amounts remain unsubstantiated per our audit testing. Additionally, no corrected reports or updated historical checks were provided via these email chains to address the discrepancies noted for ERAP2 (See Table 7). Contact Person: Dan Gasiewski, Chief Grants Compliance Officer, Grants Office, Office of the Director of Finance

View Audit 5296 Questioned Costs: $1

Finding 3226 (2022-009)

Material Weakness 2022

Mary's Center for Maternal and Child Care, Inc.

DC

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303 § 200.512

Views of Responsible Officials: As detailed in our Policy and Procedure document Mary's Center has developed a detailed pre-audit process to ensure our formal-year end closing occurs with no issues. In preparation for our annual audit, all accounts will be reconciled prior to the beginning of the au...

Views of Responsible Officials: As detailed in our Policy and Procedure document Mary's Center has developed a detailed pre-audit process to ensure our formal-year end closing occurs with no issues. In preparation for our annual audit, all accounts will be reconciled prior to the beginning of the audit period using a detailed workflow. The workflow includes a formalized checklist and workplan with the following tasks that need to be completed:  Patient Receivable Schedule Reconciliation  Patient Revenue Reconciliation  Asset and Liability Accounts Reconciliation Views of Responsible Officials (continued): Pre-Audit reconciliation efforts and adherence to the workflow will be co-led by the Assistant Controller, Director of Grants, and Director of Revenue Initiatives and reviewed by multiple levels of leadership. In addition, to combat the growth of our organization and additional regulations we have implemented or are in the process of implementing the following activities at Mary's Center:  Employed an experienced Grant director to oversee the grant department and optimize productivity and quality;  Actively enlisting the services of an experienced Finance Consultant to perform an assessment of the entire Finance department including current process and staffing needs;  Invested in technologies such as Sage Intacct ERP (industry leader) to replace manual processes;  Budgeted for additional Finance staffing in our upcoming annual budget to combat current capacity issues. Collectively, these processes and staffing updates will ensure Data Collection Forms are submitted timely going forward.

View Audit 5266

Finding 3225 (2022-008)

Significant Deficiency 2022

Mary's Center for Maternal and Child Care, Inc.

DC

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management § 200.303 § 200.414

Views of Responsible Officials: Mary's Center now has a robust process where the agreed upon provisional indirect rate or (if applicable) the specific rate included in the final Grant agreement is the governing default rate used for each Grant. In any scenarios where a change in rate is being reques...

Views of Responsible Officials: Mary's Center now has a robust process where the agreed upon provisional indirect rate or (if applicable) the specific rate included in the final Grant agreement is the governing default rate used for each Grant. In any scenarios where a change in rate is being requested, the Program Manager alerts the Senior Grant Accountant assigned to the grant and provides supporting documentation from the Grant funder of an addendum to the existing Grant agreement. If for any reason the Finance team is using an upward or downward adjustment to the provisional indirect rate or what was agreed upon in the Grant agreement the EVP Finance and Director of Grants must approve this change and notify the EVPs of Health and Programs and Development prior to implementing this change. All changes are documented. In addition, to ensure the rate in the agreement is the same rate being used when invoicing Grant funders, the Finance team conducts a thorough reconciliation process during the year.

View Audit 5266

Finding 3223 (2022-006)

Significant Deficiency 2022

Mary's Center for Maternal and Child Care, Inc.

DC

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Views of Responsible Officials: Mary's Center now has the following process in place to directly address this issue. Please see details below: All cash disbursements must be supported by an automated invoice, contract, and/or valuation documentation in the financial accounting system (Sage Intacct) ...

Views of Responsible Officials: Mary's Center now has the following process in place to directly address this issue. Please see details below: All cash disbursements must be supported by an automated invoice, contract, and/or valuation documentation in the financial accounting system (Sage Intacct) prior to payment. The same process applies for both purchase order and nonpurchase order related invoices. Any individual invoice exceeding $10,000 requires approval from both Department and Finance leadership prior to payment. Monthly Finance Team meetings are held to address staff's outstanding questions/concerns about workflows and processes.

View Audit 5266

Finding 3208 (2022-001)

Material Weakness 2022

Partners in Prevention Education

WA

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Internal Control over Cash Receipts and Disbursements Name of contact person and title: Charlia Messinger, Executive Director Anticipated completion date: 12/31/23 Agency’s response: Concur the organization agrees with this finding and will implement the following:Partners in Prevention Education w...

Internal Control over Cash Receipts and Disbursements Name of contact person and title: Charlia Messinger, Executive Director Anticipated completion date: 12/31/23 Agency’s response: Concur the organization agrees with this finding and will implement the following:Partners in Prevention Education will adopt internal control procedures matching requirements from 2 CFR section 200.303 and other government standards of non-profit financial control. This will be adopted by the Executive Director and Board by December 31, 2023.

View Audit 5229

Finding 3184 (2022-003)

Significant Deficiency 2022

Greenfields Irrigation District

MT

Cash Management Matching / Level of Effort / Earmarking

Planned Corrective Action: The Planned Corrective Action is to instruct future GID Grant Managers the importance of having qualifying receipts or invoices that correspond directly to the amount of Federal funds being requested for reimbursement. To facilitate this successfully, Project costs must be...

Planned Corrective Action: The Planned Corrective Action is to instruct future GID Grant Managers the importance of having qualifying receipts or invoices that correspond directly to the amount of Federal funds being requested for reimbursement. To facilitate this successfully, Project costs must be paid with non-Federal entity funds before summitting a payment reimbursement request from the Grant program funds. Name of Contact Person: Erling A. Juel, District Manager, will be responsible for implementing this corrective action by working with the District’s grant managers to properly implement the corrective action for on-going and current grants. Anticipated completion date: The Corrective Action will be implemented immediately and applied to the administration of on-going Federal grants.

View Audit 5206

Finding 3183 (2022-002)

Significant Deficiency 2022

Greenfields Irrigation District

MT

Matching / Level of Effort / Earmarking Reporting Equipment & Real Property Management

Planned Corrective Action: The Planned Corrective Action is to instruct GID Grant Managers the critical need to and importance of properly documenting the use of GID resources as it applies to the recipient’s in-kind match contribution. The Grant Manager must coordinate with Project Superintendent o...

Planned Corrective Action: The Planned Corrective Action is to instruct GID Grant Managers the critical need to and importance of properly documenting the use of GID resources as it applies to the recipient’s in-kind match contribution. The Grant Manager must coordinate with Project Superintendent on a weekly basis to summarize the GID labor, GID equipment, and GID materials utilized on the grant specific project. Rates applied are those proposed and accepted during negotiation of the governing Grant Agreement. If an item not previously addressed in the Grant Agreement is utilized on the Project and its use is to be claimed, the rate to apply should correspond to the GID’s current rate sheet in effect. Name of Contact Person: Erling A. Juel, District Manager, will be responsible for implementing this corrective action by working with the District’s grant managers to properly implement the corrective action for on-going and current grants. Anticipated completion date: The Corrective Action will be implemented immediately and applied to the administration of on-going Federal grants.

View Audit 5206

Finding 3149 (2022-002)

Significant Deficiency 2022

Garrett County, Maryland Community Action Committee, Inc.

MD

Reporting Matching / Level of Effort / Earmarking

GCCAC will have reports looked at more closely by the VP of Finance before they are submitted.

View Audit 5139

Finding 3141 (2022-002)

Material Weakness 2022

Pike County

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.308 § 200.309 § 200.403

The County plan has been implemented.

View Audit 5115

Finding 3114 (2022-002)

Significant Deficiency 2022

City of Sweetwater, Florida

FL

Reporting Equipment & Real Property Management Matching / Level of Effort / Earmarking § 200.1 § 200.303

The Deputy Finance Director and the Finance Department identified the transactions as potentially being incorrectly recorded; however, it was not identified timely and/or officially addressed, and was not detected by the Grants Administrator as being recorded in the incorrect period. At the moment ...

The Deputy Finance Director and the Finance Department identified the transactions as potentially being incorrectly recorded; however, it was not identified timely and/or officially addressed, and was not detected by the Grants Administrator as being recorded in the incorrect period. At the moment the trial balances and year-end closing procedures were being completed, the City was operating without a Finance Director. The Deputy Finance Director and Finance Department were working diligently to review the accounting and handle various tasks, but were not able to timely address the issue with the specific transactions mentioned above. During June 2023, the City hired a Finance Director which will allow the Deputy Finance Director and staff to improve year-end closing procedures and will provide additional support to the Finance Department to ensure controls in place over financial reporting are sufficient. The Grants Administrator will be more involved in communicating with the Finance Department, at a minimum on a monthly basis, as related to reporting of expenditures that are being funded by federal, state, and local awards.

View Audit 5032

Finding 2977 (2022-012)

Significant Deficiency 2022

Government of Guam

GU

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

Findinq No.:2022-012 Period of Performance Responding Agency: Department of Public Administration (DOA) Responsible Personnel: Edward M. Birn, Director (DOA) The extension was granted by the Department of lnterior.

View Audit 4883

Finding 2971 (2022-011)

Material Weakness 2022

Government of Guam

GU

Questioned Costs Special Tests & Provisions Eligibility

Findinq No.:2022-011 ADP System for SNAP Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Arthur San Augustin, Director (DPHSS) DPHSS agrees with the finding. Effective 1011123 The Bureau of Economic Security, and Division of Public Welfare superviso...

Findinq No.:2022-011 ADP System for SNAP Responding Agency: Department of Public Health and Social Services (DPHSS) Responsible Personnel: Arthur San Augustin, Director (DPHSS) DPHSS agrees with the finding. Effective 1011123 The Bureau of Economic Security, and Division of Public Welfare supervisors are verifying documents and making sure it is complete and uploaded into the system. A checklist will be created to ensure all vital documents are completed and uploaded.

View Audit 4883 Questioned Costs: $1

Finding 2746 (2022-008)

Material Weakness 2022

Coal Valley Water District

IL

Material Weakness Matching / Level of Effort / Earmarking Special Tests & Provisions

The District Treasurer will immediately request that the engineer implement these recommendations.

View Audit 4730

Finding 2745 (2022-007)

Material Weakness 2022

Coal Valley Water District

IL

Material Weakness Reporting Matching / Level of Effort / Earmarking

The District Treasurer will immediately request that the engineer implement these recommendations.

View Audit 4730

Finding 2744 (2022-006)

Material Weakness 2022

Coal Valley Water District

IL

Material Weakness Matching / Level of Effort / Earmarking

The Treasurer will immediately contact the bank and make arrangements to have the account collateralized, and will access the SAMs system to have all funding deposed into the construction account. The District has requested their insurance provider to add the required position fidelity bonding.

View Audit 4730

Finding 2658 (2022-002)

Significant Deficiency 2022

Ruby's Place

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

The Organization will implement a corrective action plan to make sure there are proper internal controls with regards to expenditures. The policy will be updated with guidelines for the approval process. Program managers will be responsible for managing and approving expenditure for programs. Automa...

The Organization will implement a corrective action plan to make sure there are proper internal controls with regards to expenditures. The policy will be updated with guidelines for the approval process. Program managers will be responsible for managing and approving expenditure for programs. Automated bill pay systems like Bill.com have been implemented for documenting the approvals of expenditures. Expected completion and implementation of the purchasing policy: December 2023.

View Audit 4480

Corrective Action Plans

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