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U.S. Department of Housing and Urban Development: The Housing Authority of the County of Contra Costa respectfully submits the following corrective action plan for the year ended March 31, 2025. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River...
U.S. Department of Housing and Urban Development: The Housing Authority of the County of Contra Costa respectfully submits the following corrective action plan for the year ended March 31, 2025. Auditor: Novogradac and Company, LLP Certified Public Accountants 1144 Hooper Avenue Suite 203 Toms River, New Jersey 08753 The findings from the March 31, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Award Program Audit Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871, 14.879 and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 11,032 units. Of a sample size of sixty-nine (69) tenant files, the following was noted: - Declaration of Section 214 Status form was missing in one (1) file - HUD-9886 Authorization for Release of Information was missing in six (6) files - Lead based paint form was missing in one (1) file - HUD-50058 Form applicable to the audit period was missing in seven (7) files Our sample size is statistically valid. Known Questioned Costs: $168,325 Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement.. Views of responsible officials and planned corrective action: We agree with the Auditor’s observations on the inspection of the tenant files and will implement internal control procedures that will ensure compliance of federal regulations. HACCC identified two primary causes of the deficiency and has outlined corrective measures to address them. Firts, HACCC recognized the need for improved training on supervisory tools used to monitor recertification deadlines. Management was retrained in November 2025 on the use of WorkQueue oversight tools and on conducting daily team stand-up meetings to reinforce production goals. Key performance indicators from these meetings flow to management reports and executive leadership for ongoing monitoring. Second, HACCC'S HCV program partnered with Paul Edwards Management and Consulting (PEM) on May 1, 2024. This partnership provided HACCC's HCV program with technical assistance and coverage of positions which had remained vacant from 2021 until recently. Ingrid Layne, Director of Assistance Housing, will be responsible to implement this corrective action by March 31, 2026.
Finding 2025-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Inte...
Finding 2025-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Internal Control over Compliance for Eligibility Finding 2025-003 (continued) Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit and the Authority failed to properly calculate the tenant's rent payments using documentation from third party income verification. Context: There are approximately 834 units. Of a sample size of twenty three (23) tenant files, the following was noted: Original Applications were missing in thirteen (13) files. Citizenship Declarations were missing in five (5) files. Verification of income was missing in eight (8) files. The Authority also failed to properly calculate the rent payments of four (4) tenants by not utilizing documentation from third party income verification. Our sample size is statistically valid. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files and the calculation of rent. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority's response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.
Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871 & 14.EHV Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Int...
Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871 & 14.EHV Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). Finding 2025-001 (continued) Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit and the Authority included income that was miscalculated during the annual recertification. Context: Of a sample size of thirty-seven (37) tenant files, the following information was unavailable for examination at the time of audit: • Original application was missing in one (1) file • Citizenship declaration was missing in one (1) file • Signed lease was missing in one (1) file • Verification of income was missing in four (4) files • HUD form 50058 was not timely filed for one (1) file In addition, three (3) tenants' annual recertifications (HUD-50058 form) included income that was miscalculated. Our sample size is statistically valid. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered and designed a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.
Finding 2025-002 Child Nutrition Cluster #10.555 & #10.553 Condition: The District did not have internal control over compliance procedures designed and implemented for the compliance of Paid Lunch Equity requirements. Views of Responsible Officials: The district's Business Manager is the responsibl...
Finding 2025-002 Child Nutrition Cluster #10.555 & #10.553 Condition: The District did not have internal control over compliance procedures designed and implemented for the compliance of Paid Lunch Equity requirements. Views of Responsible Officials: The district's Business Manager is the responsible official for federal programs. The Business Manager stated that they understand and agree with the finding. Planned Corrective Action: A documented process will be designed and implemented for the review of the Paid Lunch Equity calculation. Person Responsible for Corrective Action Plan: Business Manager Anticipated Completion Date: January 2, 2026
Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which...
Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which is updated every time a vendor payout is made and tracks that payment to the reimbursement request and the final payment by the pass-through agency. This process ensures that a payout is not included in a payout request multiple times. The Staff Accountant also maintains a tracker of all reimbursement requests to track with the program budgets and for inclusion in the MIP accounting system. In addition, new personnel are involved in the process with a more formal approval and authorization process implemented. The Organization’s staff has communicated these duplicate requests to the appropriate personnel at the granting agency and are coordinating the repayment of the excess funds as determined by the granting agency. Contact person responsible for corrective action: Tom Sakos, Chief Financial Officer, and Jenny Cuitiva, Accounting Manager Anticipated Completion Date: May 1, 2025 for implementing controls and November 30, 2025 for communicating with the granting agency.
2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Co...
2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Completion Date – The District intends to work towards resolving this finding for the following year.
Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRT...
Views of Responsible Officials and Corrective Action Plan The District submits the file with the required enrollment information to the National Student Clearinghouse (NSC) two weeks after the start of each term and subsequently on a monthly basis. Part of the reporting process includes running SFRTMST, a baseline process in Ellucian Banner, the District’s Enterprise Resource Planning system, to calculate or update a student’s enrollment time status, which is the date when a change occurred in the enrollment of a student due to either registering in a class(es) or withdrawing from a class(es). The enrollment time status date is included in the enrollment file submitted to NSC. NSC then submits the enrollment information to the National Student Loan Data System (NSLDS). The discrepancy identified for the nine students was between a withdrawal date in Banner versus the enrollment time status date reported to NSC/NSLDS, which was the Banner calculated date. Because of the timing of when the SFRTMST process was ran, some students’ enrollment time status date did not match the registration activity date/enrollment effective date in Banner. After conducting research using the Ellucian Customer Center, the District identified a resolution to address this issue and has already implemented it for Fall 2025. To ensure that the students’ enrollment time status date reported to NSC/NSLDS matches the students’ effective date of their registration activity in Banner, the District activated the Calculate Time Status (Indicator) in SOATERM, a Banner setup, for Fall 2025 and will do so for all terms moving forward. Per Ellucian, when this indicator is set to “Y” a dynamic time status calculation will take place. The District verified that this process works. The issue has been resolved. In addition, the dates for the nine students were corrected in NSLDS. It is important to note that this issue has had no financial impact on the District. The students have been disbursed the correct amount of financial aid. The calculation of financial aid to be disbursed is not based on the enrollment dates reported to NSC and NSLDS.
Condition: Costs charged to ALN 97.036 – Disaster Grants: Public Assistance were also charged to ALN 84.425 - Education Stabilization Fund (Elementary and Secondary School Emergency Relief - "ESSER") in prior fiscal years, indicating potential duplication of expenditures across federal programs. Pla...
Condition: Costs charged to ALN 97.036 – Disaster Grants: Public Assistance were also charged to ALN 84.425 - Education Stabilization Fund (Elementary and Secondary School Emergency Relief - "ESSER") in prior fiscal years, indicating potential duplication of expenditures across federal programs. Planned Corrective Action: The District applied for reimbursement of potentially eligible COVID expenditures in 2022. Per an April 5, 2022 FEMA memo “FEMA Continues Funding to Support the Safe Operations of Schools”, school districts could apply for reimbursement for ESSER funded expenditures, and then upon approval of application shift the funds to general fund. “Schools and school districts may utilize FEMA Public Assistance to receive full reimbursement for costs for the purposes above. Schools and districts may also use Elementary and Secondary School Emergency Relief (ESSER) funding from the U.S. Department of Education as a way to provide the up-front cost for the above health and safety measures, and later seek reimbursement through the FEMA Public Assistance process. For example, a local education agency (LEA) may use ESSER funds for costs that may ultimately be covered by FEMA; however, once it receives funds from FEMA for those costs, it must reimburse the ESSER grant account.” FEMA provided District award notification for COVID testing in December 2024 and January 2025, by this time the ESSER grant had closed on September 30, 2024 and the final expenditure reports for ESSER had been submitted to MDE in November 2024. Therefore the District could not complete the allowable general fund swaps. The District notified Michigan Department of Education and Michigan State Police of the timing issue. Upon request from MI State Police, the District provided documentation that available general funds were available to conduct the swaps if the FEMA approval had been received in a timely manner. Contact person responsible for corrective action: Jeremy Vidito, CFO Anticipated Completion Date: Requested documentation was submitted to Michigan State Police on November 7, 2025
Condition: The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Planned Corrective Action: The Agency agrees with the recommendations above and will im...
Condition: The fiscal year 2025 schedule of federal expenditures of federal awards (SEFA) that was initially provided to the auditors included payroll and fringe expenses that were incorrectly coded to the grant. Planned Corrective Action: The Agency agrees with the recommendations above and will implement a process to ensure that a reconciliation of the listing of grant eligible employees to those employees that were being coded to the Special Education Cluster in the general ledger is performed. Contact person responsible for corrective action: Emily Herbert, Director of Business and Finance Anticipated Completion Date: June 30, 2026
Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments...
Corrective Action Plan: Implement improved payrol l a llocation procedures. redesign and maintain cha11 of accounts we have a lready started. and enhance budget monitoring by monthly meeting with d irectors to go over grants. Hold monthly coordination meetings between finance and program departments to discuss budget performance and funding compliance.
Management agrees with the finding, and will evaluate available personnel to coordinate monitoring procedures to ensure accurate tenant calculations.
Management agrees with the finding, and will evaluate available personnel to coordinate monitoring procedures to ensure accurate tenant calculations.
2025-005 – Medicaid – Allowable Activities and Costs - The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Official – Austin Moore, Business Manager Anticipated Completion Date – The District will correct this in the subseq...
2025-005 – Medicaid – Allowable Activities and Costs - The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Official – Austin Moore, Business Manager Anticipated Completion Date – The District will correct this in the subsequent fiscal year.
We are compiling award letters in our shared drive as they come in so we have all of the pieces needed to complete the schedule of expenditures. We are also enhancing our grant monitoring throughout the year to have a better handle on the grants and accurately report the activity.
We are compiling award letters in our shared drive as they come in so we have all of the pieces needed to complete the schedule of expenditures. We are also enhancing our grant monitoring throughout the year to have a better handle on the grants and accurately report the activity.
2025-002 – Child Nutrition Cluster – Eligibility – The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Heidi Engel, Enrollment & Transportation Coordinator...
2025-002 – Child Nutrition Cluster – Eligibility – The District is aware of the missing eligibility documents for the Child Nutrition program and will implement new procedures and a plan to reduce the missing documentation. Responsible Officials – Heidi Engel, Enrollment & Transportation Coordinator, and Jessica Christensen, District Food Service Manager Anticipated Completion Date – The District will correct this in the subsequent fiscal year.
Strengthening Institutions Program – Department of Education Federal Financial Assistance Listing #84.031 P031A080196 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Section 3 of the Title III Endowment Report for the year ending June 30, 2...
Strengthening Institutions Program – Department of Education Federal Financial Assistance Listing #84.031 P031A080196 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding Summary: Section 3 of the Title III Endowment Report for the year ending June 30, 2024, was completed materially incorrect for Type of Savings Account Security line items and Total Invested line item. Responsible Individuals: Michael Van Surksum, Vice President for Business and Finance Corrective Action Plan: Management will review their current process to ensure reporting requirements are met and amounts are materially correct. Anticipated Completion Date: Already complete – annual report for the year-ending June 30, 2025 has now been submitted with the correct amounts.
Condition: The School District did not have a sufficiently detailed control in place to ensure that the number of meals served and claimed for reimbursement in the Michigan Nutrition Data (MiND) system was supported by School District records of actual meals served. As a result, the School District ...
Condition: The School District did not have a sufficiently detailed control in place to ensure that the number of meals served and claimed for reimbursement in the Michigan Nutrition Data (MiND) system was supported by School District records of actual meals served. As a result, the School District was unable to provide support for the complete number of meals requested for reimbursement, within our audit sample. Planned Corrective Action: The School District will implement a secondary review of the monthly summary sheet used for MIND system claim submission to ensure it fully reconciles with the supporting daily tally sheets. The reviewer will initial and date the summary sheet upon completion of the review. In addition, the newly appointed Food Services Director will establish and maintain an organized filing system (physical and/or electronic) containing all claim-supporting documentation, ensuring records are complete and readily accessible for monitoring or audit purposes. These procedures will be in place effective December 1, 2025 and will be monitored for sustained compliance. Contact person responsible for corrective action: David Bergeron, Assistant Superintendent Anticipated Completion Date: December 1, 2025
Corrective Action: The Finance Director and Business Office will undergo additional training with Tyler Technologies, Michigan School Business Officials, and others to optimize financial processes and transaction processing. The team will adhere to the state business calendar for timely reconciliati...
Corrective Action: The Finance Director and Business Office will undergo additional training with Tyler Technologies, Michigan School Business Officials, and others to optimize financial processes and transaction processing. The team will adhere to the state business calendar for timely reconciliations, budget amendments, and internal control reviews. Responsible Person: Director of Finance
Corrective Action: The Business Office will implement enhanced internal control procedures to ensure that all expenditures are accurately allocated to the appropriate program account, function, and object code. As part of this process, the Director of Finance will perform regular comparisons of actu...
Corrective Action: The Business Office will implement enhanced internal control procedures to ensure that all expenditures are accurately allocated to the appropriate program account, function, and object code. As part of this process, the Director of Finance will perform regular comparisons of actual expenditures to budgeted amounts. This review will help identify potential misstatements, detect coding errors, and ensure that financial transactions are correctly recorded in accordance with state and district accounting requirements. Responsible Person: Director of Finance and Grant Managers
The Administrative Services Office and the Student Affairs Office, or the Grant Manager/Principal Investigator responsible for any specific grants going forward, will work closely with the granting agency to ensure that any unanticipated changes/reductions in funding periods are communicated in time...
The Administrative Services Office and the Student Affairs Office, or the Grant Manager/Principal Investigator responsible for any specific grants going forward, will work closely with the granting agency to ensure that any unanticipated changes/reductions in funding periods are communicated in time to allow the College to effectively close out the grant, or to obtain permission for funding of expenditures that will not be incurred/and or liquidated timely. Anticipated Completion Date: N/A Contact Person(s): Willie Noseep, Vice President for Administrative Services Coralina Daly, Vice President for Student Affairs
Date: October 16, 2025 To: Angela Baker, Finance Director From: Melissa Johnson, Early Education Director CC: Candy Scott, Executive Director Subject: NC Pre-K Audit • Purpose: To provide information on the requested review documentation for 40 child files for an NC Pre-K audit. • Details: While gat...
Date: October 16, 2025 To: Angela Baker, Finance Director From: Melissa Johnson, Early Education Director CC: Candy Scott, Executive Director Subject: NC Pre-K Audit • Purpose: To provide information on the requested review documentation for 40 child files for an NC Pre-K audit. • Details: While gathering requested information for an NC Pre-K audit, it was discovered that 11 of the 40 requested children’s files did not have review information in our online application portal, Survey Apply. The applications were processed following all guidelines and procedures, and supporting documentation is available. These documents include income spreadsheets, scorecards, and the date entered in the APP system. The review information, however, is not available in the online application database, and the reason for this has not been determined. Jennifer Williams, Office Manager, and I have both tried to recover this information without success. The requested files missing this information are Kever Pinto, Jackson Millsap, Brixton Beale, Zoey Matthews, Amir Salimov, Nolan McCowan, Rex Klein, Caleb Bernabe, Joseph Holland, Ocean Davis, and Bryson Bunch. • Outcome/Action Taken: Discovery of this possible glitch in the online application system has led us to put additional processes in place to ensure that this information is available upon request in the future. In addition to maintaining a saved copy of the income spreadsheet and scorecard on our internal server, we will now begin saving a copy of the review for each application that is processed. We are in the process of updating our NC Pre-K guidelines. This change will be reflected in these guidelines.
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being re...
Condition: The Academy does not currently have a control in place where a review of the meal counts entered into the Michigan Nutrition Data (MiND) system takes place, which could result in incorrect reporting of the number of free and reduced priced meals, which could result in the Academy being reimbursed an incorrect amount by the Michigan Department of Education. Planned Corrective Action: The Academy will implement proper procedures and controls to ensure meal counts are reviewed and agree to underlying records of meals served prior to submitting meal claims. Contact person responsible for corrective action: Molly Brown Anticipated Completion Date: 12/01/2025
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