Corrective Action Plans

Finding 2829 (2021-005)

Material Weakness 2021

U.s. Civilian Research and Development Foundation

VA

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Reporting § 200.460

CRDF Global will take the following actions to address this finding: • Update CRDF’s timekeeping policy to specifically address direct vs. indirect activities. • Train leadership and all staff in timekeeping compliance with a special emphasis on 2 CFR 200.460, Proposal Costs. • Coach all employees o...

CRDF Global will take the following actions to address this finding: • Update CRDF’s timekeeping policy to specifically address direct vs. indirect activities. • Train leadership and all staff in timekeeping compliance with a special emphasis on 2 CFR 200.460, Proposal Costs. • Coach all employees on CRDF Global’s issue escalation opportunities. • Determine impacts in all applicable time periods. • Implement correction(s) and communicate with impacted stakeholders.

View Audit 4768

Finding 2461 (2021-004)

Significant Deficiency 2021

Community Action Program Committee, Inc.

FL

Matching / Level of Effort / Earmarking

The Committee will continue to address enrollment to comply with our earmarking requirements and will request waivers if necessary.

View Audit 4236

Finding 2458 (2021-001)

Significant Deficiency 2021

Community Action Program Committee, Inc.

FL

Matching / Level of Effort / Earmarking

The Committee will continue to seek nonfederal funding to comply with our match requirements and will request waivers if necessary.

View Audit 4236

Finding 2374 (2020-013)

Material Weakness 2021

Concordia College

NY

Questioned Costs Student Financial Aid Eligibility

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064 Questioned Costs: $1

Finding 2373 (2020-012)

Material Weakness 2021

Concordia College

NY

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064

Finding 2372 (2020-011)

Material Weakness 2021

Concordia College

NY

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Due to the College’s closure, there was no one remaining at the College with access to COD in order to gain access to the necessary information needed to complete the reconciliations.

View Audit 4064

Finding 2371 (2020-010)

Material Weakness 2021

Concordia College

NY

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

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student financial information pertaining to the period under audit.

View Audit 4064

Finding 2370 (2020-009)

Significant Deficiency 2021

Concordia College

NY

Matching / Level of Effort / Earmarking Special Tests & Provisions

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064

Finding 2369 (2020-008)

Material Weakness 2021

Concordia College

NY

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064

Finding 2368 (2020-007)

Significant Deficiency 2021

Concordia College

NY

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064

Finding 2367 (2020-006)

Significant Deficiency 2021

Concordia College

NY

Student Financial Aid Matching / Level of Effort / Earmarking Special Tests & Provisions

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064

Finding 2366 (2020-005)

Material Weakness 2021

Concordia College

NY

Cash Management Student Financial Aid Matching / Level of Effort / Earmarking

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations,...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064

Finding 2365 (2020-004)

Material Weakness 2021

Concordia College

NY

Student Financial Aid Matching / Level of Effort / Earmarking

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College )including key Information technology personnel). The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out.

View Audit 4064

Finding 2364 (2020-003)

Significant Deficiency 2021

Concordia College

NY

Questioned Costs Eligibility Matching / Level of Effort / Earmarking

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical student and financial information pertaining to the period under audit.

View Audit 4064 Questioned Costs: $1

Finding 2363 (2020-002)

Material Weakness 2021

Concordia College

NY

Eligibility Student Financial Aid Matching / Level of Effort / Earmarking

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical financial information pertaining to the period under audit.

View Audit 4064

Finding 2362 (2021-002)

Material Weakness 2021

Concordia College

NY

Reporting Special Tests & Provisions Student Financial Aid

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations...

Management’s Response: Concordia College ceased academic operations in August 2021 and is in the process of winding down its operations and completing its remaining compliance requirements. Subsequent to the announcement of the closure of the College and following the ceasing of academic operations, virtually all employees left their employ with the College. The significant turnover in personnel, transition to outside consultants, and preparing proper teach out and transition plans for remaining students was a much larger focus than compliance requirements, which led to additional time lapsing between the prior year when findings were discovered to the current report being sent out. Additionally, due to the shutdown of Banner and the time taken to complete the audit, it is difficult for the College to obtain historical financial information pertaining to the period under audit.

View Audit 4064

Finding 2056 (2021-004)

Significant Deficiency 2021

Elkhart and St. Joseph Counties Head Start Consortium

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.303

We will ensure all required federal reports have a documented, formal review of the reports before they are submitted to ensure the information submitted is accurate. See anticipated timeline of the procedures below.

View Audit 3569

Finding 2051 (2021-003)

Material Weakness 2021

Elkhart and St. Joseph Counties Head Start Consortium

IN

Equipment & Real Property Management Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.313

We will work the federal government to obtain retroactive approval of the bus purchases as of July 1, 2021. Additionally, going forward any equipment purchases will be reviewed to ensure compliance with all applicable federal equipment pre and post procurement requirements for inventory and maintena...

We will work the federal government to obtain retroactive approval of the bus purchases as of July 1, 2021. Additionally, going forward any equipment purchases will be reviewed to ensure compliance with all applicable federal equipment pre and post procurement requirements for inventory and maintenance of equipment. See anticipated timeline of the procedures below.

View Audit 3569

Finding 2016 (2021-002)

Significant Deficiency 2021

Public Buildings Authority

PR

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Due to goverments closurses tha ocurred during he pandemic, it was impossible to obtain the internal and external information to cumply with the established requirements.

View Audit 3515

Finding 1792 (2021-005)

Material Weakness 2021

Bristol Bay Borough, Alaska

AK

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.516

Finding 2021-005 Activities Allowed and Unallowed, Allowable Costs, Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Name of Contact Person: James Wilson, Borough Manager Corrective Action Plan: The Borough is currently undergoing an upgrade in record r...

Finding 2021-005 Activities Allowed and Unallowed, Allowable Costs, Period of Performance – Material Weakness in Internal Control over Compliance and Noncompliance Name of Contact Person: James Wilson, Borough Manager Corrective Action Plan: The Borough is currently undergoing an upgrade in record retention policies and procedures. Completion Date: December 2023

View Audit 3119 Questioned Costs: $1

Finding 1719 (2021-002)

Significant Deficiency 2021

National Corvette Museum Foundation, Inc.

KY

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

The Museum concurs with the recommendation. The Museum has implemented a new procedure to ensure that any future reporting compliance requirements related to the expenditure of Federal Funds are completed on a timely basis. The Museum strives to continuously identify methods to improve internal cont...

The Museum concurs with the recommendation. The Museum has implemented a new procedure to ensure that any future reporting compliance requirements related to the expenditure of Federal Funds are completed on a timely basis. The Museum strives to continuously identify methods to improve internal controls.

View Audit 2981

Finding 1578 (2021-004)

Material Weakness 2021

Municipality of Añasco

PR

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.403

Training finance staff assigned on management and reports preparation, as required by this federal award. stablish adequate internal control regarding documents, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indi...

Training finance staff assigned on management and reports preparation, as required by this federal award. stablish adequate internal control regarding documents, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds. Key Task / Action Items Locate and document all required reports and reconciliations as required. We are implementing a supervision process and instructions will be given to finance’s staff and personnel to increase the ability to search, identify and produce financial documents and reports. Resources Coronavirus Relief Fund (CRF) PHE-Testing and Contact Tracing 2 CFR Section 200.302 (a) of the Uniform Guidance 2 CFR Section 200.403 Puerto Rico Department of Health; Guidelines for the Writing of Proposals and Request for Funds Directed to the Research System Project for the Municipal Case Investigation and Contact Case Investigation and Municipal Contact Tracing System Project Response to COVID-19. Lead Staff Finance’s Director Federal Program Directors Completion date Estimated completion date of December 31, 2023. Actual Completion Date In progress Implementation Progress/Comments The Municipality used the funds in accordance with the proposal and the guidelines established by AAFAF and PR Department of Health for these purposes. Coronavirus Relief Fund (CRF) Public Health Emergency (PHE) (Testing and Contact Tracing). According to the information obtained from Mr. Carlos R. Nazario Barreto, Senior Business Consultant of the SAB Consulting, regarding the compliance of the Municipality, we were provided with the table of the monitoring of the Proposed Municipal System of Investigation of Cases and Tracking of Contact (SMIRC) of the Municipality of Añasco. The referred table of the monitoring of the Proposed Municipal System of Investigation of Cases and Tracking of Contact of the Municipality of Añasco was send to the external auditor as part of this Corrective Action Plan. The detailed table is maintained by the Municipality as part of the federal program supporting documentation. These funds were initially administered and disbursed by former municipal administration personnel. At the time of the audit, we did not find the documents and reports as the files were not available. Following the Auditor's recommendations and as a corrective action, we are currently working on the review of the fiscal documents submitted by the Municipality to determine if there are any reports that need to be worked on and to submit them to AFFAF, PR-OMB or the agencies concerned.

View Audit 2817

Finding 1577 (2021-003)

Material Weakness 2021

Municipality of Añasco

PR

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.403

Training finance staff assigned on management and reports preparation, as required by this federal award. Establish adequate internal control regarding the activity, filing and custody of reports, as required by the federal awards and the pass-through entity, and in a way that documents and supports...

Training finance staff assigned on management and reports preparation, as required by this federal award. Establish adequate internal control regarding the activity, filing and custody of reports, as required by the federal awards and the pass-through entity, and in a way that documents and supports the compliance with reporting requirements Locate and document all required reports and reconciliations as required. We are implementing a supervision process and instructions will be given to finance’s staff and personnel to increase the ability to search, identify and produce financial documents and reports. The Municipality used the funds in accordance with the proposal and the guidelines established by AAFAF for these purposes according to Coronavirus Relief Fund (CRF) Transfer Application Assistance Program to Municipalities. The detailed report, “Assistance Program to Municipalities Program Closure Report-Añasco” dated 4/11/2023 was send to the external auditor as part of this Corrrective Action Plan. The detailed report is maintained by the Municipality as part of the federal program supporting documentation. These funds were initially administered and disbursed by former municipal administration personnel. At the time of the audit, we did not find the documents and reports as the files were not available. Following the Auditor's recommendations and as a corrective action, we are currently working on the review of the fiscal documents submitted by the Municipality to determine if there are any reports that need to be worked on and to submit them to AFFAF, PR-OMB or the agencies concerned.

View Audit 2817

Finding 1257 (2021-017)

Significant Deficiency 2021

Kentucky State University

KY

Student Financial Aid Matching / Level of Effort / Earmarking

The University concurs with the finding. The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a Graduation Fee is charged. This will be fully functional in FY25.

View Audit 2371

Finding 1256 (2021-016)

Significant Deficiency 2021

Kentucky State University

KY

Student Financial Aid Matching / Level of Effort / Earmarking

The University concurs with the finding The University is currently utilizing the Banner Optimization to develop a message alert within the Student Portal (Wired) when a withdrawal date is entered. This will be fully functional in FY25.

View Audit 2371

Corrective Action Plans

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