Corrective Action Plans

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CORRECTIVE ACTION PLAN Audit Firm: Winkel Green & Company LLP Audit Period: January 1, 2022 through December 31, 2022 CAP Prepared by: Name: Beth Fetzer-Rice Position: Executive Director Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Fin...
CORRECTIVE ACTION PLAN Audit Firm: Winkel Green & Company LLP Audit Period: January 1, 2022 through December 31, 2022 CAP Prepared by: Name: Beth Fetzer-Rice Position: Executive Director Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2022-001 a. Comments on the Finding and Recommendation. Uniform Guidance stipulates that reimbursements are paid to subrecipients in a timely manner. The Organization did not pay subrecipients in a timely manner for the months of April through December 2022, resulting in $234,254 of untimely reimbursements. b. Action Taken or Planned on the Finding The Organization will meet with subgrantees to establish increased control processes, including outlining documentation requirements, timeframes for reimbursement submission, identifying correct staff contacts for timely communications, and formalizing a timeframe for approving/distributing subrecipient disbursements. The Organization has paid all reimbursements through December 2022 as of August 30, 2023.
View Audit 34608 Questioned Costs: $1
2022-004 Special Tests and Provisions ? Verification of Free and Reduced Price Applications Federal Assistance Listing Number: 10.CNC District is in the process of establishing procedures and controls by the Business Manager to oversee the retention of verification documentation and information ...
2022-004 Special Tests and Provisions ? Verification of Free and Reduced Price Applications Federal Assistance Listing Number: 10.CNC District is in the process of establishing procedures and controls by the Business Manager to oversee the retention of verification documentation and information obtained through the verification process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023
2022-003 Segregation of Duties ? Reporting Federal Assistance Listing Number: 10.CNC Management is cognizant of the District?s internal control structure and continues to evaluate cost effective opportunities to further improve segregation of duties. It is the District?s plan to train an indivi...
2022-003 Segregation of Duties ? Reporting Federal Assistance Listing Number: 10.CNC Management is cognizant of the District?s internal control structure and continues to evaluate cost effective opportunities to further improve segregation of duties. It is the District?s plan to train an individual in the process of submitting claims in order to create a review process of the grant management process. Responsible Official: Karl Volkmann, Business Manager Anticipated Completion Date: June 30, 2023
Finding 2022-003 Name of Contact Person: Terry Dudney, Chief Finance Officer Corrective Action Plan: Management will implement controls and procedures to ensure that expenditures do not exceed DPI allotments. Proposed Completion Date: As soon as possible.
Finding 2022-003 Name of Contact Person: Terry Dudney, Chief Finance Officer Corrective Action Plan: Management will implement controls and procedures to ensure that expenditures do not exceed DPI allotments. Proposed Completion Date: As soon as possible.
View Audit 23893 Questioned Costs: $1
Finding 2022-002 Name of Contact Person: Terry Dudney, Chief Finance Officer Corrective Action Plan: Management will implement controls and procedures to ensure that federal funds are expended in a timely manner. Proposed Completion Date: As soon as possible.
Finding 2022-002 Name of Contact Person: Terry Dudney, Chief Finance Officer Corrective Action Plan: Management will implement controls and procedures to ensure that federal funds are expended in a timely manner. Proposed Completion Date: As soon as possible.
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. A...
Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers program to ensure that established internal control policies are being followed on a timely basis. Adam Bovilsky, Executive Director, is responsible for implementing this corrective action by March 31, 2023.
View Audit 36679 Questioned Costs: $1
Finding 2022-001- Material Weakness and Material Noncompliance over Reporting Contact Person: John Milazzo, VP and CFO Management?s Response: We have determined that certain expenses reported through the Department of Health and Human Services PRF reporting portal for periods 1 and 2 did not re...
Finding 2022-001- Material Weakness and Material Noncompliance over Reporting Contact Person: John Milazzo, VP and CFO Management?s Response: We have determined that certain expenses reported through the Department of Health and Human Services PRF reporting portal for periods 1 and 2 did not reconcile to the underlying expense details by nature and/or function, and therefore did not comply with PRF reporting requirements. We have implemented a monitoring control over PRF reporting to ensure that expenses submitted through the PRF portal are properly classified by nature and/or function, and that such amounts reconcile to the underlying details and accounting records. Completion Date: January 31, 2023
Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 3 and Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.4...
Finding 2022-002 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 3 and Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.498 Finding Summary: Responsible Individuals: Corrective Action Plan: The Organization?s calculation of lost revenue claimed under the federal program as an allowable cost was not subjected to formal review or approval by a separate individual outside of the preparer. Dr. Kenneth D. Varble ? Corporate Controller When summarizing lost revenue for submission, a secondary review of the summary spreadsheet prepared from the underlying supporting records will be documented. This policy will reflect the procedures needed for proper internal controls to provide assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Anticipated Completion Date: December 31, 2023
Finding 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.498 Finding Su...
Finding 2022-001 Federal Agency Name: Department of Health and Human Services Program Name: COVID-19 Provider Relief Fund (PRF) and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year ? Period 4 TIN #411419064 Federal Financial Assistance Listing: 93.498 Finding Summary: The Organization claimed lost revenues attributable to coronavirus in which the final lost revenue calculation did not tie to the HHS Report. In addition, the Organization?s special report submitted to the Department of Health and Human Services (HHS) for Period 4 TIN #411419064 did not have documented review and approval by a separate individual outside of the preparer. Responsible Individuals: Dr. Kenneth D. Varble ? Corporate Controller Corrective Action Plan: A policy will be developed outlining the controls to be followed for filing reports with Federal Agencies. This policy will reflect the procedures needed for proper internal controls to provide assurance that the Organization is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Anticipated Completion Date: December 31, 2023
Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance...
Finding 2022-001 Subject: Medicaid ? Eligibility, Other Matters Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the eligibility compliance requirements that are performed by the Special Education Cooperative on behalf of the School Corporation. Context: The School Corporation participates in a Special Education Co-op. In 2015, the Co-op provided an avenue through a third-party company, for the member school districts to obtain reimbursement for Medicaid services. It was discovered in 2021 that the yearly parental disclosure statements had not been completed for Medicaid eligibility compliance. Due to this oversight, each member school has had to voi transactions through the third-party company and pay back the amount of these transactions from August 9, 2015 through April 23, 2021. The School Corporation?s amount owed was $481,276 for the period identified during 2015-2021. The School Corporation completed a Voluntary Self-Disclosure of Provider of Overpayments Packet through the Indiana Family & Social Services Administration?s Office of Medicaid Policy and Planning Office to reimburse the amounts owed. The amount related to this period July 1, 2020 through June 30, 2022 was indeterminable. The full amount was paid back prior to June 30, 2021. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Parental disclosure statements are completed annually for Medicaid eligibility compliance. This has already been implemented. Responsible Party and Timeline for Completion: Madeline Sandberg, Director of BCNWH Joint Services, 7/1/2021
View Audit 32733 Questioned Costs: $1
FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment ...
FINDING 2022-005 Subject: Special Education Cluster ? Period of Performance Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Period of Performance compliance requirement. Context: The School Corporation was a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Period of Performance compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it difficult to identify which expenditures were from federal funds, or to identify expenditures by federal program, award number, or years. Therefore, we could not test compliance with the period of performance requirements for approximately 48% of the expenditures. The School Corporation did not have adequate procedures in place to ensure that the Cooperative complied with the period of performance requirements. The Cooperative did not have adequate procedures in place to ensure that costs were charged to the programs only during the period of performance, or that all obligations were liquidated within 90 days of the end of the period of performance. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021
FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment r...
FINDING 2022-004 Subject: Special Education Cluster ? Equipment Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the equipment requirements of the Equipment and Real Property Management compliance requirement. Context: The School Corporation is a member of a joint service cooperative (Cooperative). The Cooperative operated the special education programs on behalf of the School Corporation and managed the special education grant funds. Because the grant agreements were between the Indiana Department of Education and the School Corporation, the School Corporation was ultimately responsible for compliance with the grant agreement and the Equipment and Real Property Management compliance requirement. During fiscal year 2021, the School Corporation paid membership fees to the Cooperative out of federal Special Education funds. These membership fees made up approximately 48% of the total federal expenditures reimbursed during fiscal year 2021. The Cooperative accounted for state, local, and federal funds in a single fund. The fund did not separately account for each of the funding sources. This made it indeterminable whether equipment purchases were made by the Cooperative with federal funds, or to identify equipment expenditures by federal program, award number, or years. Therefore, we could not test compliance for approximately 48% of the expenditures. The Cooperative did not have adequate procedures in place to ensure that equipment purchased with grant funds was properly recorded and maintained in the School Corporation's equipment records. The Cooperative also did not maintain records for the disposition of equipment purchased with federal grant funds. The lack of internal controls and noncompliance were systemic issues, which occurred specifically during fiscal year 2021. No reportable findings were noted for fiscal year 2022. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Members of the cooperative are no longer paying their cooperative member fees with federal funds. This was resolved effective 7/1/2021. Responsible Party and Timeline for Completion: Zach Dennis, CFO, 7/1/2021
Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description ...
Finding 2022-003 ? Head Start - Activities Allowed or Unallowed, Allowable Costs- Cost Principles Contact Person Responsible for Corrective Action: Brittany Treesh Contact Phone Number: 260-357-3185 Views of Responsible Official: The school corporation concurs with the finding. Description of Corrective Action Plan: The school corporation will implement additional internal controls to make sure all timesheets have been received and signed by supervisors prior to payroll being completed. Anticipated Completion Date: Garrett-Keyser-Butler Community School District is no longer the LEA for the Head Start Program. However, this will be implemented immediately at the corporation.
Views of Responsible Officials: The District has not identified any payments that are the result of fraud. The District will work on developing procedures to identify and recover payments resulting from fraud. Name of Responsible Person: Pamela Geisler, Budget & Policy Director Implementation ...
Views of Responsible Officials: The District has not identified any payments that are the result of fraud. The District will work on developing procedures to identify and recover payments resulting from fraud. Name of Responsible Person: Pamela Geisler, Budget & Policy Director Implementation Date: Fiscal Year 2023-2024
Views of Responsible Officials: During the COVID 19 pandemic the District experienced turnover in various key positions resulting from a lapse with record keeping. Management will work to ensure that records related to claim reimbursements are retained for a period of three years. Name of Respon...
Views of Responsible Officials: During the COVID 19 pandemic the District experienced turnover in various key positions resulting from a lapse with record keeping. Management will work to ensure that records related to claim reimbursements are retained for a period of three years. Name of Responsible Person: Jennifer LaBarre, Executive Director of Student Nutrition Services Implementation Date: Fiscal Year 2023-2024
View Audit 24006 Questioned Costs: $1
Views of Responsible Officials: District is reviewing the internal procedures related to documenting salaries and wages charged to federal programs and will work with our auditors to ensure we meet this requirement. Name of Responsible Person: Anne Marie Gordon, Interim Chief Financial Officer ...
Views of Responsible Officials: District is reviewing the internal procedures related to documenting salaries and wages charged to federal programs and will work with our auditors to ensure we meet this requirement. Name of Responsible Person: Anne Marie Gordon, Interim Chief Financial Officer Implementation Date: Fiscal Year 2023-2024
View Audit 24006 Questioned Costs: $1
2022-003 Eligibility: Public Housing Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of a total tenant population of approximately 145 tenant files, 15 files were selected for testing. Exceptions wer...
2022-003 Eligibility: Public Housing Tenant Files Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control Material Noncompliance Condition: Out of a total tenant population of approximately 145 tenant files, 15 files were selected for testing. Exceptions were noted as follows: ? 1 tenant file where the Authority was unable to locate certain documents and therefore could not test items such as Form 9886, birth certificates, social security cards, income and deduction support, utility allowance schedules and EIV verification. ? 1 tenant file where dependent?s 214 affidavit was not signed. However, we did note that the dependent was a US Citizen (per review of birth certificate) and therefore eligible for the program. ? 1 tenant file where tenant?s reported income was incorrect on the Form 50058. However, this had no impact on tenant?s rent as this was a flat rent unit. We also noted as part of our new admissions testing (3 selected for testing out of population of 23 new admissions) the following: ? 1 new admission where the applicant and dependent?s Form 214 were not signed. However, it was noted that the applicants were citizens (per review of birth certificate information) and therefore eligible for the program. Auditor?s 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: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were not able to locate certain documents. We will assure that files are complete and are supported with proper documentation.
2022-002 Reporting ? Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control Material Noncompliance Repeat finding of 2021-002 from March 31, 2021 Condition: The Authority?s origi...
2022-002 Reporting ? Inaccurate and Late FDS Submission and Late OMB Data Collection Form Submission Public and Indian Housing Program ? CFDA Number 14.850 Material Weakness in Internal Control Material Noncompliance Repeat finding of 2021-002 from March 31, 2021 Condition: The Authority?s original unaudited FDS filing was materially misstated. In addition, the Authority did not report the CARES Act activity in a separate column of the FDS as required. Also, the unaudited FDS filings were not submitted within the timeframes specified by HUD. The Authority submitted the unaudited FDS filing on May 26, 2023 (of which the normal due date was May 31, 2022). The Authority was also required to submit the audited FDS filing and the OMB Data Collection form to the Federal Audit Clearinghouse (?FAC?) by December 31, 2022 at completion of the single audit, but it was not filed timely, as the audit was completed on August 16, 2023. Recommendation: The Authority should make every effort to file its REAC submissions accurately and timely and submit the OMB Data Collection form timely. Action Taken: We concur with the recommendation. Due to the COVID-19 pandemic and related staff absences and turnover, we were not able to accurately close the books before the HUD specified unaudited and audited FDS filing deadline and unable to timely file the OMB Data Collection Form. We are very focused on ensuring there is adequate staffing and sufficient processes in place in order to be able to close the books prior to submitting a materially accurate unaudited FDS submission for the following fiscal year as well as timely file the audited FDS and OMB Data Collection Form.
Cause Kirkhaven was experiencing significant cash constraints and was not able to make debt payments and escrow payments as they were due. Effect Kirkhaven is out of compliance with the HUD regulatory agreement. Recommendation We recommend that Kirkhaven utilize grant funding if allowable to becom...
Cause Kirkhaven was experiencing significant cash constraints and was not able to make debt payments and escrow payments as they were due. Effect Kirkhaven is out of compliance with the HUD regulatory agreement. Recommendation We recommend that Kirkhaven utilize grant funding if allowable to become up to date in debt principal payments and escrow payments. Management Response Kirkhaven was and continues to be in communication with both HUD and mortgage servicer (Berkadia) with regards to the lack of payment of the October to December mortgage and escrow required payments amounting to $192,947 due to the cash flow challenges. They are aware of the executed CHOW Letter of Intent. Subsequent to year-end, Kirkhaven has made the required interest only payments for October to December and continues to make the monthly interest payments. Kirkhaven also has applied for relief of the required escrow payments, but was subsequently denied. Management will continue to monitor cash flow and if feasible make mortgage principal and escrow payments as able, however, the VAPAP grant proceeds did not include funds for debt payments. Managements position is that since the executed CHOW, intention is to use proceeds to pay of the mortgage balance, that paying the principal earlier versus later is less critical.
Untimely Returns to Title IV (R2T4) Planned Corrective Action: We have trained and implemented processes to correctly determine period lengths and the earned and unearned percentages. We have increased the number of reports used to identify potential withdrawals. To correctly and timely process ...
Untimely Returns to Title IV (R2T4) Planned Corrective Action: We have trained and implemented processes to correctly determine period lengths and the earned and unearned percentages. We have increased the number of reports used to identify potential withdrawals. To correctly and timely process R2T4s, we outsourced the determination and calculation processes to a third-party vendor in November 2022 (this took longer than we anticipated). In March 2023, we were granted additional staffing resources and are in the process of hiring for those positions. To reduce the number of R2T4 calculations required, we also plan to switch from being an institution required to take attendance to a non-attendance taking institution for the 2023-2024 aid year. Person Responsible for Corrective Action Plan: Bryan Taylor, Associate Director of Student Financial Services Anticipated Date of Completion: May 2023
The Board will discuss these recommendations and consider implementing procedures to further segregate duties within our internal control system.
The Board will discuss these recommendations and consider implementing procedures to further segregate duties within our internal control system.
The Organization will establish a monthly procedure to perform all allocations from administrative departments to programs and ensure proper sign-off of allocations.
The Organization will establish a monthly procedure to perform all allocations from administrative departments to programs and ensure proper sign-off of allocations.
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT 2022-018 Low-Income Home Energy Assistance, COVID-19 ? Low-Income Home Energy Assistance ? Assistance Listing No. 93.568 ...
DEPARTMENT OF HOUSING AND COMMUNITY DEVELOPMENT 2022-018 Low-Income Home Energy Assistance, COVID-19 ? Low-Income Home Energy Assistance ? Assistance Listing No. 93.568 Action taken in response to the finding: Going forward, the FFATA will be submitted for LIHEAP by the DCS Fiscal Unit as required by FFATA instructions. Name of the contact person responsible for corrective action: Kristen Crowley Planned completion date for corrective action plan: Report will be filed in FSRS by the end of the month following the month in which the prime recipients are awarded. Next anticipated due date will be November or December 2023.
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-011 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 ...
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-011 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: Reporting has been built to notify responsible parties of the award periods of performance and highlight any issues for corrective action in accordance to previously filed FFATA reporting. In addition, FFATA reporting has been created in EOLWD?s DataMart application. Actions taken are as follows: ? Performed FFATA training ? Created accounts for employee access to FFATA ? Filed existing outstanding and new grant FFATA reports ? Used new reporting to notify responsible parties that a new grant/modification has arrived and requires a FFATA Subaward report filed ? Training for existing staff complete and new staff will be trained accordingly as part of their onboarding. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants, EOLWD Planned completion date for corrective action plan: June 30, 2023
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-010 WIOA Cluster ? Assistance Listing No. 17.258, 17....
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2022-010 WIOA Cluster ? Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: Staffing: Two new Budget Analysts will begin working for EOLWD at the end of June in 2023. These analysts will provide additional capacity for filing 9130s for WIOA. Training: In March and April 2023, EOLWD provided training to new staff on the preparation, certification, and submission of 9130 reports. Staff beginning in June 2023 will be trained during the next 9130 reporting period. Automating Business Practices: EOLWD refined its automated 9130 reporting for the March 31, 2023, reporting period and is finalizing further refinements that will be implemented prior to the next quarterly reporting period. Standard Operating Procedures: EOLWD developed job aides for the preparation of 9130 reports with its new automated processes and is in the process of drafting new Standard Operating Procedures (SOP). These SOPs will be finalized and submitted to DOL by October 1, 2023, as outlined in the corrective action plan schedule provided to DOL. An updated version of this schedule is provided below. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants, EOLWD Planned completion date for corrective action plan: October 1, 2023
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