Corrective Action Plans

Finding 3183 (2022-002)

Significant Deficiency 2022

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

Questioned Costs Material Weakness Matching / Level of Effort / Earmarking

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

Questioned Costs Material Weakness Reporting

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

Questioned Costs 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

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

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

Finding 2578 (2022-005)

Significant Deficiency 2022

The Salvation Army Golden State Division

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.308 § 200.309 § 200.403

REFERENCE # 2022-005 PERIOD OF PERFORMANCE – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred du...

REFERENCE # 2022-005 PERIOD OF PERFORMANCE – SIGNIFICANT DEFICIENCY- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Compliance Supplement Requirement: A non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance and any costs incurred before the federal awarding agency or pass-through entity made the federal award that were authorized by the federal awarding agency or pass-through entity (2 CFR sections 200.308 200.309 and 200.403(h)). A period of performance may contain one or more budget periods. Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. The Division’s pass-through Contract requires period of performance and also requires funds must be expended by certain date. Of the Sixty (60) files selected for testing We noted that the Division: • For 4 samples, we noted that Division program expenses were recorded prior to Contract starting date. Questioned Costs: Cannot be determined Recommendation: We recommend Division charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Corrective Action Plan: The Division will charge only allowable costs incurred during the approved budget period of a pass-through award’s period of performance and any costs incurred before the pass-through entity made the federal award that were authorized by the pass-through entity. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

View Audit 4368 Questioned Costs: $1

Finding 2577 (2022-004)

Material Weakness 2022

The Salvation Army Golden State Division

CA

Cash Management Questioned Costs Subrecipient Monitoring § 200.3 § 200.305

REFERENCE # 2022-004 CASH MANAGEMENT – MATERIAL WEAKNESS- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Non-Federal Entities Other Than States- Non-federal entities must minimize the time elapsi...

REFERENCE # 2022-004 CASH MANAGEMENT – MATERIAL WEAKNESS- NONCOMPLIANCE Program Name/ALN Emergency Food and Shelter National Board Program (ALN # 97.024) Criteria: Non-Federal Entities Other Than States- Non-federal entities must minimize the time elapsing between the transfer of funds from the US Treasury or pass-through entity and disbursement by the non-federal entity for direct program or project costs and the proportionate share of allowable indirect costs, whether the payment is made by electronic funds transfer, or issuance or redemption of checks, warrants, or payment by other means (2 CFR section 200.305(b)). What constitutes minimized elapsed time for funds transfer will depend on what payment system/method a non-federal entity uses. Under the advance payment method, federal awarding agency or pass-through entity payment is made to the non-federal entity before the non-federal entity disburses the funds for program purposes (2 CFR section 200.3). A non-federal entity must be paid in advance provided that it maintains, or demonstrates the willingness to maintain, both written procedures that minimize the time elapsing between the transfer of funds from the US Treasury and disbursement by the non-federal entity, as well as a financial management system that meets the specified standards for fund control and accountability (2 CFR section 200.305(b)(1)). Condition/Context: Division receive Emergency Food and Shelter National Board Program funds from the U.S. Department Homeland security/FEMA and various pass-through entities. Division receives advance funds from the pass-through agency and incurred program expenditures. Of the Sixty (60) files selected for testing We noted that the Division: (1) Does not have written procedures that minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Questioned Costs: Cannot be determined Recommendation: We recommend Division minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Corrective Action Plan: The Division will strive to minimize the time elapsing between the transfer of funds from the Pass-through entity and disbursement by the Division. Step 1 Action Date: Ongoing Final Implementation Date: 12/31/2023 Name and Phone # Of Person Responsible for Implementation: Jeanne Stromberg, Major, Divisional Finance Secretary (916) 563-3710

View Audit 4368 Questioned Costs: $1

Finding 2556 (2022-005)

Significant Deficiency 2022

Arc Community Services, INC

WI

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.305

We concur with the recommendation, and a formalized and independently monitored process was implemented to reconcile refundable advances routinely and in coordination with the recognition and allocation of allowable costs effective August of 2023.

View Audit 4353

Finding 2385 (2022-001)

Material Weakness 2022

Allen County

OH

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.202 § 200.208 § 200.301 § 200.328

Regional Planning Commission (RPC) has hired a new Executive Director effective March, 2023. RPC also hired a new Finance Director effective September, 2023, who is experienced in public finance and general reporting requirements. Both staff members are dedicated to ensuring proper procedures and pe...

Regional Planning Commission (RPC) has hired a new Executive Director effective March, 2023. RPC also hired a new Finance Director effective September, 2023, who is experienced in public finance and general reporting requirements. Both staff members are dedicated to ensuring proper procedures and performance going forward. Both staff members will review and sign off on the timely and accurate filing of all grant reporting documentation and requirements.

View Audit 4076

Finding 2358 (2022-003)

None 2022

Contemporary Oriental Medicine Foundation

FL

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

A. Comments on Findings and Recommendations: 2022-003 – INCORRECT REFUND CALCULATION We agree with the finding for an incorrect refund calculation. B. Actions Taken or Planned: 2022-003 – INCORRECT REFUND CALCULATION The refund was calculated incorrectly and was caused by not including a scheduled b...

A. Comments on Findings and Recommendations: 2022-003 – INCORRECT REFUND CALCULATION We agree with the finding for an incorrect refund calculation. B. Actions Taken or Planned: 2022-003 – INCORRECT REFUND CALCULATION The refund was calculated incorrectly and was caused by not including a scheduled break of 5 days or more due to the Thanksgiving holiday. This resulted in a refund being transmitted to the Department of Education that should have been retained by the college. The college will credit the $196 to the student’s account and in the future, a more thorough cross-check of the R2T4 will be performed by the Financial Aid office before processing the refund.

View Audit 4043

Finding 2357 (2022-002)

Material Weakness 2022

Contemporary Oriental Medicine Foundation

FL

Reporting Matching / Level of Effort / Earmarking Student Financial Aid

A. Comments on Findings and Recommendations: 2022-002 – LATE AUDIT We agree with the finding for a late audit. B. Actions Taken or Planned: 2022-002 – LATE AUDIT The Board’s Treasurer for 2022 was unable to assist with the 2022 audit due to a health concern. There was delay in getting the informatio...

A. Comments on Findings and Recommendations: 2022-002 – LATE AUDIT We agree with the finding for a late audit. B. Actions Taken or Planned: 2022-002 – LATE AUDIT The Board’s Treasurer for 2022 was unable to assist with the 2022 audit due to a health concern. There was delay in getting the information needed to finalize the financial audit, which then delayed the federal direct loan program audit. This has been rectified with a former Board Treasurer rejoining the Board who has experience from prior years. The college will implement the necessary procedures to prevent future audits from being submitted late.

View Audit 4043

Finding 2356 (2022-001)

Material Weakness 2022

Contemporary Oriental Medicine Foundation

FL

Student Financial Aid Matching / Level of Effort / Earmarking

A. Comments on Findings and Recommendations: 2022-001 – FINANCIAL RESPONSIBILITY We agree with the finding for not meeting the minimum financial standards set forth by the DOE. B. Actions Taken or Planned: 2022-001 - FINANCIAL RESPONSIBILITY The organization incurred a net loss for the year as a res...

A. Comments on Findings and Recommendations: 2022-001 – FINANCIAL RESPONSIBILITY We agree with the finding for not meeting the minimum financial standards set forth by the DOE. B. Actions Taken or Planned: 2022-001 - FINANCIAL RESPONSIBILITY The organization incurred a net loss for the year as a result of additional expenditures related to opening a second location in Bradenton, Florida, and we don’t anticipate these additional expenditures in 2023. We anticipate having operations returning to normal and growing our enrollment with the addition of a second location.

View Audit 4043

Finding 2285 (2022-002)

Significant Deficiency 2022

Boston Architectural College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management’s Corrective Action Plan Finding number: 2022-002 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #’s 84.063, 84.268 Award year: 2022 Corrective Action Plan The BAC will augment last year’s monthly automation of ros...

Management’s Corrective Action Plan Finding number: 2022-002 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #’s 84.063, 84.268 Award year: 2022 Corrective Action Plan The BAC will augment last year’s monthly automation of roster submission with a monthly reconciliation of enrolment status as recorded in our student information system with the data recorded in NSLDS. Management will provide training to those reasonable for reporting enrolment status to NSLDS via the National Student Clearinghouse. This training will include the relevant rules and regulations as well as stress the importance of accuracy and the potential consequences of errors, both to our students and the institution. Timeline for Implementation of Corrective Action Plan The College plans to implement the corrective action plan by October 1, 2023. Contact Person James Ryan, Ph.D. Vice President of Enrollment Management

View Audit 3923

Finding 2102 (2022-002)

Material Weakness 2022

Lincoln Hall

NY

Allowable Costs / Cost Principles Cash Management Material Weakness

For the year ended June 30, 2022 audit, the audit team noted that payroll, personnel costs, and other than personnel service expenses were not being allocated by cost center on a monthly basis. This issue resulted in errors in the amount charged to various programs resulting in the need for a materi...

For the year ended June 30, 2022 audit, the audit team noted that payroll, personnel costs, and other than personnel service expenses were not being allocated by cost center on a monthly basis. This issue resulted in errors in the amount charged to various programs resulting in the need for a material allocation adjustment. In accordance with Uniform Guidance 200.405, costs that benefit multiple programs should be allocated to the programs based on the proportional benefit. Lincoln Hall did not have the adequate cost allocation mechanisms in place to properly allocate expenses throughout the year. We have been taking several steps to address the issue with allocating costs. The Federal Award Finding and Questioned Costs Finding Number 2022-002 is a result of the initial way in which the general ledger and payroll systems were set up, requiring the majority of allocation work to be done manually in Excel. These manual allocations were done in detail after fiscal year-end to ensure our financial statements at year-end were not misstated. However, this detailed allocation work was not being done on a monthly basis. We have upgraded the Serenic Navigator accounting system two times to improve its accounting capabilities and have also implemented additional allocation processes including allocation of payroll expenses of federal awards. We currently use line-item allocations in The Serenic Navigator for direct costs that are allocated when invoices are paid. During FY 2022 we are continuing to review and revise our process in order to allocate expenses (particularly payroll costs) in the general ledger on a monthly basis for allocations in the past that were performed at the end of the fiscal year. The goal of our corrective actions is to significantly limit the material reallocation of costs by function at year-end and provide us with accurate cost allocations on a monthly basis. This will allow for more accurate reporting on a month-to-month basis and, therefore, will generate more timely and accurate financial information, thereby improving our compliance with cash management during the grant period.

View Audit 3654

Finding 1948 (2022-002)

Material Weakness 2022

Municipality of Gurabo

PR

Questioned Costs Reporting Matching / Level of Effort / Earmarking § 200.512

We are working in implementing adequate internal control procedures in order to comply with the submission of all required information for the Single Audit for Fiscal Year 2023.

View Audit 3372

Finding 1916 (2022-002)

Significant Deficiency 2022

Mississippi Center for Justice

MS

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

Organization's Response: MCJ agrees that the salary expense for the one employee noted in the Finding was not correctly allocated. Prior to this Finding, MCJ had already implemented a process that allows review of payroll allocations each per pay period. Since April 2023, a payroll allocation spread...

Organization's Response: MCJ agrees that the salary expense for the one employee noted in the Finding was not correctly allocated. Prior to this Finding, MCJ had already implemented a process that allows review of payroll allocations each per pay period. Since April 2023, a payroll allocation spreadsheet is generated and regularly reviewed for correct grant allocation. Furthermore, since that time, the finance team meets throughout the fiscal year to ensure salaries are being allocated according to grant budgets with the appropriate allocation percentages.

View Audit 3327

Finding 1908 (2022-006)

Material Weakness 2022

South Point Local School District

OH

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

The School District Treasurer will monitor jobs that require prevailing wages and ensure proper payroll records are obtained from the vendor. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Lee Elliott, Treasurer

View Audit 3313

Finding 1848 (2022-006)

Significant Deficiency 2022

Jackson City School District

OH

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

Salaries and benefits for the Fiscal Year in the audit were approved by a prior interim treasurer. New procedures have been put in place the prevent this from happening with the current Treasurer. Anticipated Completion Date: 6/30/2023 Responsible Contact Person: Jared M. Bunting, Treasurer/CFO

View Audit 3216

Finding 1810 (2022-001)

Significant Deficiency 2022

Healthy Relationships California

CA

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

The bookkeeper and external accountant of Healthy Relationships California will collaborate to produce accurate reliable accounting records and financial reports.

View Audit 3151

Finding 1797 (2022-001)

Material Weakness 2022

National Alliance Against Disparities in Patient Health

VA

Allowable Costs / Cost Principles HUD Housing Programs Matching / Level of Effort / Earmarking § 200.303 § 200.431

Timesheets are reviewed by project managers before they are submitted to payroll processing. Additionally, a reconciliation of actual to budgeted hours will be performed on a monthly basis. Documentation of the timesheet reviews will be maintained electronically. Staff time for federal grants will b...

Timesheets are reviewed by project managers before they are submitted to payroll processing. Additionally, a reconciliation of actual to budgeted hours will be performed on a monthly basis. Documentation of the timesheet reviews will be maintained electronically. Staff time for federal grants will be supported by a completed timesheet signed by a project manager. The National Alliance Against Disparities in Patient Health does acknowledge that an additional level of review is justified as our grant volume continues to expand. The verification of work performed on a monthly basis will ensure accuracy. Project managers will meet weekly with the executive team to address any transitional issues. Evidence of this allocation review will be maintained electronically for future inspection and / or presentation to grantors or others with a need to know.

View Audit 3140

Corrective Action Plans

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