Corrective Action Plans

Finding 566966 (2024-003)

Significant Deficiency 2024

FL

HUD Housing Programs Eligibility Material Weakness

2024-003 Housing Choice Voucher Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters This is a repeat finding of 2023-002 from September 30, 2023 (Origi...

2024-003 Housing Choice Voucher Tenant Files: Eligibility Program: U.S. Department of HUD: Section 8 Housing Choice Vouchers (ALN #14.871) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters This is a repeat finding of 2023-002 from September 30, 2023 (Originally reported as Material non-compliance and Material Weakness in Internal Control over Compliance under finding 2019-001 from September 30, 2019) Statement of Condition: Out of a total tenant population of approximately 1,118 vouchers, 25 files were selected for testing, and the following errors were discovered. • 2 tenant files had the following error: o The HAP contract in the tenants’ file was not signed by a representative of Ocala Housing Authority. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will decrease the Housing Assistance Payment by $4. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $23. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates. The 2024 utility allowance rates should have been used. Correcting this error will increase the Housing Assistance Payment by $7. • 1 tenant file had the following error: o The tenant's utility allowance was incorrectly calculated using the 2023 utility allowance rates for a 1-bedroom unit. The 2024 utility allowance rates for a 2-bedroom unit should have been used. Correcting this error will increase the Housing Assistance Payment by $20. 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: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and an HCV Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. The HCV Counselor caseloads have been distributed equitably amongst Counselors to promote efficiency and accuracy while working on each HCV participant's file. The Counselor's caseload is divided alphabetically and assigned by multifamily developments to track and monitor counselors' strength and weaknesses and to determine if additional training and/or monitoring is needed. A Counselor has been assigned to only handle specialty vouchers (EHV, VASH, Homeownership, and FUP). The FSS Coordinator is responsible for the full management of HCV FSS participants. The Authority has hired an Intake Housing Counselor/Portability Specialist to focus on determining eligibility of new applicants pulled from the waitlist and to manage the waitlist. This Counselor also determines eligibility and compiles document packet for portability clients. Internal file reviews are being completed and management will continue to conduct a 10% review for each Counselor's processing of annual recertifications. This percentage may increase if work product indicates a need for more stringent review. To further ensure compliance and accuracy, the HCV Program Manager will review at least 1 out of every 5 intake files. All new admissions move-in files are now being sent to the Compliance Director for review prior to approval. A sample size of 15% is now being reviewed at the end of month by the Compliance Director and Housing Programs Director for compliance. The Authority has had a significant turnover in the HCV department over the past 24 months. All HCV Counselors, except the Counselor handling specialty vouchers, will attend Voucher Specialist training and Nan McKay HCV Rental Calculation Certification training and successfully passed the certification exam during the next 24 months, as budget permits.

View Audit 359829

Finding 566965 (2024-002)

Significant Deficiency 2024

Ocala Housing Authority

FL

HUD Housing Programs Internal Control / Segregation of Duties Eligibility

2024-002 Public Housing Tenant Files: Eligibility Program: U.S. Department of HUD: Public and Indian Housing Program (ALN #14.850) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Statement of Condition: We tested 19 out of approximately 181 tenant files ...

2024-002 Public Housing Tenant Files: Eligibility Program: U.S. Department of HUD: Public and Indian Housing Program (ALN #14.850) Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Statement of Condition: We tested 19 out of approximately 181 tenant files and discovered the following errors: • 1 tenant file had the following error: o A dependent of the household did not check the checkbox on the 214-affidavit form indicating their immigration status. However, based on the dependent’s birth certificate, the dependent is a U.S. citizen. • 1 tenant file had the following error: o The tenant’s childcare income was calculated and reported incorrectly on the 50058 form in the amount of $2,472. Correcting the tenant’s childcare income to $2,237 would decrease the tenant’s rent by $6. • 1 tenant file had the following error: o Support for the tenant’s wage income could not be located. It’s unknown as to whether the tenant’s wage income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $11,172. Correcting the tenant’s social security income to $12,144 for the annual recertification period tested, would increase the tenant’s rent by $25. • 1 tenant file had the following error: o The tenant’s social security income was carried forward from the prior year in the amount of $12,456. Correcting the tenant’s social security income to $13,548 for the annual recertification period tested, would increase the tenant’s rent by $27. • 1 tenant file had the following error: o The tenant’s other source income of $720 was carried forward from the prior year. The tenant’s income was not updated for the annual recertification and it’s unknown as to whether the tenant’s other source income is calculated and reported correctly on the 50058 form and whether the tenant’s rent is calculated correctly. 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: The Authority concurs with this finding. The Authority has an established review, oversight and training process and will continue to improve its review, oversight, and training process to ensure proper procedures are being followed. All audit findings of the files tested have been corrected. The Authority has implemented a quality control system so that every file receives a quality review for appropriate third-party verification and upfront income, and assistance is determined. The agency has created a Family Worksheet and a PH Computation Worksheet to help staff identify errors in calculations and to check for accuracy prior to completing Annual Reexaminations and Interim Recertifications. The agency has changed its filing system to enable staff to thoroughly review all forms prior to admission and during regular recertification and interim adjustment processing. The agency created an “Other Adult” packet to ensure 214 forms and other pertinent are completed for all adult household members. Management will monitor and review counselor’s strength and weaknesses and determine if additional training and/or monitoring is needed.

View Audit 359829

Finding 566941 (2024-001)

Significant Deficiency 2024

College of the Muscogee Nation

OK

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

The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (102 days and 69 days). The statuses of both students are correct with NSLDS. Student 1: Student officially withdrew but withdrawal was not pro...

The College has identified that the dates of enrollment submissions and status changes for the two students identified in the audit were out of compliance (102 days and 69 days). The statuses of both students are correct with NSLDS. Student 1: Student officially withdrew but withdrawal was not processed until the end of the term. Since the withdrawal was not processed in a timely manner, the enollment status and subsequent R2T4 calculation (as noted in finding 2024-002) was delayed. Student 2: Student graduated, and status was updated with NSLDS at 69 days. Due to delayed communication and delayed reporting to NSLDS, CMN will revise institutional policy to clearly define the process and timeline for enrollment status changes. Financial aid staff will seek additional training in enrollment reporting through FSA and/or NSFAA. To further monitor compliance, CMN has already worked with Anthology (student information system) to provide electronic triggers to the financial aid office when a student status changes from active to drop/withdrawal. This electronic, automatic process will provide an additional layer of notification to the financial aid office when a student status change requires further attention.

View Audit 359811

Finding 566935 (2024-001)

Significant Deficiency 2024

Sabine Parish School Board

LA

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.302

All grant-related information is being thoroughly tracked by the employees currently responsible for submitting reimbursement claims. At this time, Janna Wright and Stacy Swindle are the only staff members filing claims. Their process includes running a Flexible Period Report from Munis, generating ...

All grant-related information is being thoroughly tracked by the employees currently responsible for submitting reimbursement claims. At this time, Janna Wright and Stacy Swindle are the only staff members filing claims. Their process includes running a Flexible Period Report from Munis, generating a Statement of Revenues and Expenditures from the legacy system for payroll, printing copies of checks, invoices, timesheets, and any other transaction listed on the reports. They also maintain detailed tracking spreadsheets to monitor both expenses and claims, and they collaborate with Directors to ensure accuracy. Once grant funds are received, the payments will be entered into Munis in a timely manner to maintain accurate financial records.

View Audit 359807

Finding 566904 (2024-001)

Significant Deficiency 2024

Yuma County Water Users' Association

AZ

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Views of the Responsible Officials and Planned Corrective Actions The Yuma County Water Users’ Association acknowledges the findings related to the nonperformance of required quarterly financial reporting under the Infrastructure Investment and Jobs Act (IIJA) loan agreements. The primary cause of t...

Views of the Responsible Officials and Planned Corrective Actions The Yuma County Water Users’ Association acknowledges the findings related to the nonperformance of required quarterly financial reporting under the Infrastructure Investment and Jobs Act (IIJA) loan agreements. The primary cause of this issue was the absence of necessary data—specifically, detailed actual expense information—which was not provided by the Imperial Irrigation District (IID). Without this information, the Association was unable to complete and submit the quarterly reports as required under the terms of the agreement. The Association is fully committed to resolving this issue and ensuring ongoing compliance with all provisions of the loan agreements. We are actively engaging with the relevant parties to obtain the required data and implement measures to prevent future delays in financial reporting. Corrective Actions: To address this issue, the Association will collaborate closely with both the Bureau of Reclamation and the Imperial Irrigation District (IID) to ensure timely receipt of quarterly actual expense data. Specifically: • At the end of each quarter, the Association will issue a formal request to IID for detailed expense data. • Follow-up reminders will be sent as necessary to facilitate timely submission. • This coordination will support the Association’s ability to meet quarterly financial reporting deadlines as required by the IIJA loan agreements. Timeline for Implementation: The corrective actions outlined above will be implemented immediately. Full compliance with quarterly reporting requirements is expected by the end of the second quarter.

View Audit 359771

Finding 566026 (2024-002)

Material Weakness 2024

Lane Community College

OR

Student Financial Aid Reporting Subrecipient Monitoring

2024-002 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Stu...

2024-002 – Special Tests and Provisions - Enrollment Reporting – Material Weakness in Internal Controls over Compliance Student Financial Assistance Cluster Department of Education Federal Assistance Listing Number: 84.063, 84.268 Federal Program Name: Federal Pell Grant Program, Federal Direct Student Loans Federal Award Number: P063P230357, P268K230357 Award Year: 2023-24 Criteria: The National Student Loan Data System (NSLDS) is the Department of Education’s (ED) centralized database for students’ enrollment information under the Pell Grant and the Direct Loan and Federal Family Education Loan programs. Uniform guidance requires institutions to have internal controls in place to ensure attendance changes for students are reported to NSLDS within at least 60 days of when the student attendance change occurs. It is the College’s responsibility to update students' enrollment information timely and accurately as outlined in 34 CFR § 685.309. Condition/context: The auditors selected a sample of 34 students out of a population of 1,454 who had received Federal aid and had withdrawn or graduated from the College during the 2023-2024 fiscal year. The auditors compared the withdrawal or graduation date per the College’s records to NSLDS. The auditors noted eight students were not reported to NSLDS within the 60-day requirement. In addition, the auditors identified ten students who graduated but were not reported as graduated to NSLDS. Corrective Action: LCC reports enrollment to the National Student Clearinghouse: in the second, sixth and the tenth week of each standard term. There is an error report that the Clearinghouse returns with discrepancies in enrollment status which we respond to and correct within five business days. Once all errors are resolved and the report is accepted the NSC will post the data and report to NSLDS. Lane is an open access institution and therefore does not have a formal withdrawal policy. Two weeks after the end of each term, Lane sends the enrollment report and the “degree verify” extract to NSC. We are in the process of reviewing our NSC reporting strategies and including additional staff who will be supporting the process. We are reviewing NSC reporting times to ensure that we are reporting often enough to meet the required 60 day timeline for NSLDS. We are considering moving the enrollment and degree verify extract to a 30 day reporting period to meet the 60 day timeline. Phase 1: Issue an off cycle report to the NSC by June 6th, which is our next anticipated enrollment reporting cycle (week ten). We will send both the enrollment report and the “degree verify” extract to catch any updates to graduation information that may have changed since our last end of term report. Phase 2: Review updates to NSC processes that were issued through Banner and Ellucian and revise the “degree verify” process to capture regular graduation or withdrawal updates outside our standard reporting window. Unless it is discovered that the 30 day cycle does not meet the requirements of the reporting cycle, we will update our processes to - at a minimum - report every 30 days or in alignment with the weeks two, six and ten current enrollment report to the NSC. Additionally, the students noted in the finding will be reviewed to address any potential anomalies with reporting and to identify the cause of why these were not updated. This will be another consideration during the assessment for any updates to our reporting cycles. Following spring term, we will report graduated and withdrawn students, as is our current practice and after student degree awarding is complete. Name of Contact Person Responsible for Corrective Action: Dawn Whiting Anticipated Completion Date for the Corrective Action: A review process of 90 days should result in refined practices and an implementation of those practices to meet required reporting. All reporting changes will be finalized and followed by Aug 21, 2025.

View Audit 359666

Finding 566025 (2024-001)

Material Weakness 2024

Androscoggin Home Health Service, Inc.

ME

Matching / Level of Effort / Earmarking

Condition Found: During the audit we noted the Association has not maintained the reserve balance as required. Response: Androscoggin Home Health Services, Inc. d/b/a Andwell Health Partners will be fully funding the reserve gap in the amount of $84,813.72 in fiscal year 2025. The required reserv...

Condition Found: During the audit we noted the Association has not maintained the reserve balance as required. Response: Androscoggin Home Health Services, Inc. d/b/a Andwell Health Partners will be fully funding the reserve gap in the amount of $84,813.72 in fiscal year 2025. The required reserve will be fully funded to meet the compliance of the Loan Resolution and Letters of Conditions with the United States Department of Agriculture under the federal program, Community Facilities Loans and Grants. Responsible Party: Dr. RJ Gagnon, DBA, MBA, CHFP, CSAF Chief Financial and Operating Officer (207) 777-7740 Anticipated Completion Date: No later than December 31, 2025

View Audit 359662

Finding 566020 (2024-005)

Significant Deficiency 2024

Palm Beach County Housing Authority

FL

HUD Housing Programs Reporting Significant Deficiency

2024-005 – PIC Reporting Housing Voucher Cluster – Assistance Listing 14.781 and 14.879 Recommendation: We recommend that the Authority designate an individual to ensure the HUD-50058s are uploaded into the PIC system accurately and timely. Explanation of disagreement with audit finding: There is...

2024-005 – PIC Reporting Housing Voucher Cluster – Assistance Listing 14.781 and 14.879 Recommendation: We recommend that the Authority designate an individual to ensure the HUD-50058s are uploaded into the PIC system accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Beginning in March 2023, the PBCHA implemented that completion of all reexaminations within its Yardi resident portal. Reexaminations within Yardi provide online workflows that maximize efficiency, streamline compliance, reduce errors, and increase reporting accuracy. As such, the PBCHA has seen improvement in this area. PIC submissions are completed weekly to ensure compliance with eVMS and encourage timely correction of fatal errors. The PBCHA will utilize available dashboards and reports to improve monitoring and oversight to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2025

View Audit 359660

Finding 566005 (2024-002)

Material Weakness 2024

Beaumont Senior Citizens Housing, Inc.

TX

HUD Housing Programs Material Weakness Matching / Level of Effort / Earmarking

CORRECTIVE ACTION PLAN Name and Number of the Project: Beaumont Senior Citizens Housing, Inc. FHA/CONTRACT NO. 114-11227 Audit Firm: M Group, LLP Audit Period: The year ended June 30, 2024 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations...

CORRECTIVE ACTION PLAN Name and Number of the Project: Beaumont Senior Citizens Housing, Inc. FHA/CONTRACT NO. 114-11227 Audit Firm: M Group, LLP Audit Period: The year ended June 30, 2024 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING #2024-002: Section 8 Housing Assistance Payments Program, Assistance Listing: 14.195 and Mortgage Insurance Section 223(f) Insured Loan, Assistance Listing: 14.155 CORRECTIVE ACTION TO BE COMPLETED: The Organization intends to apply for reinstatement of tax-exempt status. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Stewart Grounds, Chief Financial Officer of Arnold-Grounds Apartment Management & Affordable Housing Specialists, LLC.

View Audit 359651

Finding 566003 (2024-001)

Significant Deficiency 2024

Beaumont Senior Citizens Housing, Inc.

TX

HUD Housing Programs Significant Deficiency Matching / Level of Effort / Earmarking

CORRECTIVE ACTION PLAN Name of the Project: Beaumont Senior Citizens Housing, Inc. FHA/CONTACT NO. 114-11227 Audit Firm: M Group, LLP Audit Period: The year ended June 30, 2024 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our aud...

CORRECTIVE ACTION PLAN Name of the Project: Beaumont Senior Citizens Housing, Inc. FHA/CONTACT NO. 114-11227 Audit Firm: M Group, LLP Audit Period: The year ended June 30, 2024 Compliance Review COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING #2024-001: Section 8 Housing Assistance Payments Program, Assistance Listing: 14.195 and Mortgage Insurance Section 223(f) Insured Loan, Assistance Listing: 14.155 CORRECTIVE ACTION TO BE COMPLETED: The Corporation completed and submitted the financials for audit for the years ended June 30, 2024 and 2023. The financial data was submitted into the FASSUB and FAC system. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Stewart Grounds, Chief Financial Officer.

View Audit 359651

Finding 565994 (2024-002)

Material Weakness 2024

Washington Local School District

OH

Subrecipient Monitoring Reporting Material Weakness § 200.328 § 200.330

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Require training for all staff involved in preparing, reviewing, or...

Create a detailed, step-by-step process for federal procurement to ensure compliance and awareness among all staff responsible for spending and reporting federal funds. Washington Local Schools - Federal Grants Management Process Require training for all staff involved in preparing, reviewing, or certifying federal grant reports, prior to beginning any work. Work with a Financial Program Manager at the Office of Budget and Management (Neal Bucklew was the district’s contact on this particular grant) to ensure that all activity reports are submitted correctly and received on time.

View Audit 359647

Finding 565843 (2024-003)

Significant Deficiency 2024

The Antirecidivism Coalition

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.328

To address the finding, ARC will strengthen internal controls related to federal reporting by taking the following actions: 1. Enhance Reporting Oversight: The Finance Manager and Grants and Compliance Officer will assume primary responsibility for monitoring and verifying all federal reporting dead...

To address the finding, ARC will strengthen internal controls related to federal reporting by taking the following actions: 1. Enhance Reporting Oversight: The Finance Manager and Grants and Compliance Officer will assume primary responsibility for monitoring and verifying all federal reporting deadlines and submission requirements. 2. Document Retention Procedure: Additional double checks of record retention will take place in monthly reporting meetings, ensuring that centralized record keeping is complete. 3. Compliance Calendar Audit: A quarterly internal audit of the compliance calendar and reporting checklist will be conducted to verify deadlines are met.

View Audit 359567

Finding 565820 (2024-001)

Significant Deficiency 2024

The Nazareth Project, Inc.

PA

Cash Management Reporting Matching / Level of Effort / Earmarking

Management's Response and Corrective Action Plan: On July 8, 2024, NPI received a reimbursement from ASHA of $741,559 for invoices that NPI received from Nazareth Hospital prior to June 30, 2024. NPI submitted these invoices for reimbursement on June 29, 2024, and recorded the revenue and the receiv...

Management's Response and Corrective Action Plan: On July 8, 2024, NPI received a reimbursement from ASHA of $741,559 for invoices that NPI received from Nazareth Hospital prior to June 30, 2024. NPI submitted these invoices for reimbursement on June 29, 2024, and recorded the revenue and the receivable, but did not record the expense until the funds were remitted to Nazareth Hospital on July 9, 2024. NPI should have recorded the expense and accrued a liability on June 29, 2024, during the same period in which the revenue was recognized. We acknowledge our failure to properly match the grant expense to the grant revenue in the proper accounting period and affirm that our cash basis of accounting was not appropriate to account for this grant. We have implemented a process to reconcile all grant revenues and expenses at the end of each accounting period to ensure proper recording. Further, the Treasurer of the Organization will take a more active role in reviewing the accounting for grants.

View Audit 359527

Finding 565772 (2024-003)

Significant Deficiency 2024

Boys & Girls Club of Huntington County, Inc.

IN

Allowable Costs / Cost Principles Cash Management Significant Deficiency

2024-003 Twenty-First Century Community Learning Centers -Assistance Listing No. 84.287 Significant Deficiency in Internal Control Over Compliance and Noncompliance - Appropriate Internal Control Structure Related to Compliance Requirements A. Activities Allowed or Unallowed, B. Allowable Costs/Cost...

2024-003 Twenty-First Century Community Learning Centers -Assistance Listing No. 84.287 Significant Deficiency in Internal Control Over Compliance and Noncompliance - Appropriate Internal Control Structure Related to Compliance Requirements A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, and C. Cash Management Recommendation: The Auditor recommends the policies in accordance with §200.302 Financial Management paragraph (b) (6) and (b)(7) be written by the Organization, approved by the Board of Directors, and included in the permanent files of the Organization. Planned Corrective Action: We agree with the recommendation, and updated our policies in accordance with §200.302 Financial Management paragraph (b) (7) in December 2024 and will update our policies in accordance with (b) (6) by August 2025.

View Audit 359460

Finding 565727 (2024-001)

Material Weakness 2024

Russell County Board of Education

AL

Questioned Costs Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

The Board will notify all bidders that compliance with the Davis-Bacon Act is mandatory. Furthermore, all construction bid solicitations will include a requirement that the awarded contractor must adhere to the provisions and procedures outlined in the Davis-Bacon Act.

View Audit 359438 Questioned Costs: $1

Finding 565722 (2024-006)

Significant Deficiency 2024

Board of Education of Columbus County Schools

NC

Questioned Costs Matching / Level of Effort / Earmarking

Name of Contact Person:Daniel Nolan, Finance Officer, Corrective Action Plan: Management will implement controls and procedures to ensure that staff responsible for overseeing compliance with Title I requirements understands the 12% administrative expenditure limit. In addition, the Title I budget ...

Name of Contact Person:Daniel Nolan, Finance Officer, Corrective Action Plan: Management will implement controls and procedures to ensure that staff responsible for overseeing compliance with Title I requirements understands the 12% administrative expenditure limit. In addition, the Title I budget will be monitored by Title I staff during the year to ensure that the 12% administrative requirement is not exceeded. Proposed Completion Date: Immediately

View Audit 359425 Questioned Costs: $1

Finding 565687 (2024-006)

Significant Deficiency 2024

Washington County

OR

Eligibility HUD Housing Programs Matching / Level of Effort / Earmarking

Auditor recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for impleme...

Auditor recommendation: The County should develop and implement policies and procedures to ensure that all reports are reviewed by someone other than the preparer. Management response: Agree Target date to complete implementation activities: July 2026 Name of specific point of contact for implementation: Ryan Bansbach, Deputy CFO, Housing, 503.846.8811 Response: The Housing Authority of Washington County (HAWC) is addressing these findings by implementing systems and policies that require secondary review of reports and determinations prior to upward reporting, voucher issuance, or tenant move‐in. HAWC implemented systems in 2025 where the staff preparing and submittng the HUD 52681‐B form will send to the form to the Program Manager or Designee for review and approval stamp before the form is submitted to HUD in the VMS or eVMS system. A checklist has been created and a system updated on routing files after review for eligibility to have a secondary review and final approval prior to issuance of voucher by the program supervisor, program manager or designee. Additional training and internal quality control checks will be implemented to ensure that metric is met. HAWC has also established checklists and procedures to ensure Rent Reasonableness is reviewed and approved prior to tenant move‐in, using a third‐party system to conduct the rent reasonableness determinations. This metric will also be added to the internal quality control procedures to monitor compliance.

View Audit 359401

Finding 565669 (2024-002)

Significant Deficiency 2024

Mobile County Board of School Commissioners

AL

Questioned Costs Matching / Level of Effort / Earmarking Special Tests & Provisions

The board will ensure the schools and central office departments are aware of and follow the federal procurement codes for federal funds.

View Audit 359349 Questioned Costs: $1

Finding 565530 (2024-002)

Material Weakness 2024

It's Time Texas, Inc.

TX

Questioned Costs Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: In response to Finding 2024-002, Healthier Texas has taken corrective action in response to Finding 2024-002 by updating the Time and Effort Certification Policy and revising the semi_x0002_annual certification forms for all staff. An internal review process has been implemen...

Corrective Action Plan: In response to Finding 2024-002, Healthier Texas has taken corrective action in response to Finding 2024-002 by updating the Time and Effort Certification Policy and revising the semi_x0002_annual certification forms for all staff. An internal review process has been implemented by Anely Bautista-Mendiola, Director of Human Resources & Operations, to ensure ongoing compliance with the updated Time and Effort policy. Additionally, the configuration of our Human Resources Information System (HRIS) has been updated to include cost center codes, enhancing the ability to accurately track time allocated to the SNAP-Ed project. All policy changes and system updates were completed by September 30, 2024.

View Audit 359326 Questioned Costs: $1

Finding 565501 (2024-004)

Significant Deficiency 2024

Highland Falls-Fort Montgomery Central School District

NY

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

Finding & Recommendation 2024-004: As per C.R. 170.2 of the Commissioner's Regulations, Purchase Orders must be established to encumber approved budget items for each expenditure in advance of the expenditure. For the ARP Summer Enrichment grant, Purchase Orders were created after the dates of servi...

Finding & Recommendation 2024-004: As per C.R. 170.2 of the Commissioner's Regulations, Purchase Orders must be established to encumber approved budget items for each expenditure in advance of the expenditure. For the ARP Summer Enrichment grant, Purchase Orders were created after the dates of service and the district did not have sufficient internal controls in place to ensure Purchase Orders are created in accordance with the above noted regulation. It is recommended that the District's written procedures addressing internal controls with respect to program requirements be followed to ensure the District is in compliance at all times. Corrective Action: The district concurs and understands the importance of maintaining internal controls in accordance with Commissioner Regulations. By June 30, 2025, Assistant Superintendent Christopher Carballo will review with Business Office Staff the existing procedures for the creation of purchase orders in advance of the expenditure. Additionally, Asst. Superintendent Carballo will review these procedures with clerical staff across the district involved in the creation of purchase orders and will remind district administrators at the start of the new fiscal year that purchase orders need to be established in advance for all expenditures.

View Audit 359289 Questioned Costs: $1

Finding 565487 (2024-039)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

MASSACHUSETTS EMERGENCY MANAGEMENT AGENCY 2024-039 COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend the Agency review and enhance procedures and controls to ensure that costs charged to the program are all...

MASSACHUSETTS EMERGENCY MANAGEMENT AGENCY 2024-039 COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend the Agency review and enhance procedures and controls to ensure that costs charged to the program are allowable, approved, and accounted for properly in the Commonwealth’s accounting system. Action taken in response to finding: MEMA is recognizing the importance of documentation and internal controls. This current fiscal year an Internal Control Group was formed to review, create and overhaul what is needed or needed to be updated. The team primary stakeholders is made up of the CFO, Legal Counsel, Assistant Director for Recovery and Mitigation and Emergency Management Grants Supervisor. We are making the completion of updated Policies and Procedures a priority to address the findings such as the ones being pointed out as a critical piece to the success of the agency going forward. We have found that there has been much to update, and we are doing our best to deliver these much-needed documents as soon as possible. Name(s) of the contact person(s) responsible for corrective action: Randall Lui Planned completion date for corrective action plan: End of the Federal Fiscal Year 9/30/2025

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Finding 565485 (2024-038)

Material Weakness 2024

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

MASSACHUSETTS EMERGENCY MANAGEMENT AGENCY 2024-038 Disaster Grants – Public Assistance (Presidentially Declared Disasters), COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend the Department review and enhanc...

MASSACHUSETTS EMERGENCY MANAGEMENT AGENCY 2024-038 Disaster Grants – Public Assistance (Presidentially Declared Disasters), COVID-19 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) - Assistance Listing No. 97.036 Recommendation: We recommend the Department review and enhance its procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Action taken in response to finding: MEMA is recognizing the importance of documentation and internal controls. This current fiscal year an Internal Control Group was formed to review, create and overhaul what is needed or needed to be updated. The team primary stakeholders is made up of the CFO, Legal Counsel, Assistant Director for Recovery and Mitigation and Emergency Management Grants Supervisor. We are making the completion of updated Policies and Procedures a priority to address the findings such as the ones being pointed out as a critical piece to the success of the agency going forward. Name(s) of the contact person(s) responsible for corrective action: Randall Lui Planned completion date for corrective action plan: End of the Federal Fiscal Year 9/30/2025

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Finding 565484 (2024-037)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

DEPARTMENT OF PUBLIC HEALTH 2024-037 Opioid-STR - Assistance Listing No. 93.788 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior audit year. It should establish procedures and internal controls to ensure that all required subawards are ...

DEPARTMENT OF PUBLIC HEALTH 2024-037 Opioid-STR - Assistance Listing No. 93.788 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior audit year. It should establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Action taken in response to finding: All subrecipient FFATA information will be batched and uploaded to FSRS within 30 days of execution of subcontracts. Each month the FFATA submission receipt and all additional records pertaining to the upload will be saved. The internal Fiscal Compliance Auditor will review FFATA monthly submissions for compliance. Uploads will be made monthly by The Grants team. The Grants team at BSAS has created a Standard Operating Procedure (SOP) to make sure this process is repeated every month. Name(s) of the contact person(s) responsible for corrective action: Windy Senecharles Planned completion date for corrective action plan: July 1, 2025

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Finding 565479 (2024-035)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

Eligibility Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2024-035 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: The Department should enhance its procedures and internal controls to ensure it promptly follows up with participants whose eligibility...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2024-035 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: The Department should enhance its procedures and internal controls to ensure it promptly follows up with participants whose eligibility review identifies errors and that ineligible participants are terminated from the program. Action taken in response to finding: The State will implement the following corrective actions to enhance the oversight within the Eligibility Quality Assurance (EQA) program: • Annual refresher training for supervisory staff The State will perform an annual refresher training for all Team Leaders and Supervisors who are responsible for reviewing and correcting tasks identified by the Eligibility Quality Assurance unit. • Comprehensive training for new supervisory workers The State will ensure that all newly appointed Team Leaders and Supervisors receive a comprehensive training that will include a detailed overview of the eligibility review and correction process established by the Eligibility Quality Assurance unit. • Review of corrections The State will establish a process to assist and remind managers and supervisors that they are expected to review and approve all corrections made by the eligibility workers in response to the Eligibility Quality Assurance Unit findings. Documentations of such corrections will be maintained for audit and monitoring purposes. • Standardized member outreach process for incomplete Employee Sponsored Insurance forms (ESI). The State will develop and implement a standardized process for timely outreach to members whose ESI form is identified as incomplete. Name(s) of the contact person(s) responsible for corrective action: Tosin Adebiyi, Assistant Director of Special Eligibility Programs and Audits Marco Gonzalez, Eligibility Quality Assurance Team Leader Planned completion date for corrective action plan: All corrective actions are targeted for full implementation by December 31st, 2026.

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Finding 565475 (2024-034)

Significant Deficiency 2024

Commonwealth of Massachusetts

MA

Eligibility Special Tests & Provisions Allowable Costs / Cost Principles § 200.303

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2024-034 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: The Department should enhance its procedures and internal controls to ensure it properly monitors high-risk providers and that it maint...

EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2024-034 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Recommendation: The Department should enhance its procedures and internal controls to ensure it properly monitors high-risk providers and that it maintains documentation that claims are paid only to eligible providers. Action taken in response to finding: Providers who are identified as high risk, are sent for fingerprinting. Once the fingerprinting results are received, they are scheduled for a site visit. Business Support Services have reinforced with staff that the site visit must follow the fingerprinting results. Additionally, a checklist will be created for all high-risk providers to ensure that all required steps in the process are completed at enrollment, revalidation or when they are identified as having a credible allegation of fraud or appropriate overpayment. Name(s) of the contact person(s) responsible for corrective action: Janice Wadsworth, MassHealth Director Provider Operations Keith West, Director Special Projects Business Support Services and Chris Silva, Manager Provider Enrollment Business Support Services. Planned completion date for corrective action plan: The checklist will be complete by July 2025.

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Corrective Action Plans

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