Corrective Action Plans

Finding 563835 (2024-002)

Material Weakness 2024

OR

Reporting Subrecipient Monitoring Material Weakness § 200.502

Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and ar...

Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. ODI agrees with the auditors’ recommendation. Consistent with response to finding 2024-001, we have reviewed the design and implementation of internal controls procedures around accounting for grants and contracts. This has resulted in revision of our new funding form including identifying federal and nonfederal designations in subcontracts from states, and determination of conditions to ensure compliance with U.S. GAAP. Responsible staff member, Laurie Larson-Lewis, Finance Manager, completion date 5/31/2025.

View Audit 358060

Finding 563814 (2024-004)

Material Weakness 2024

Waimanalo Health Center

HI

Special Tests & Provisions Eligibility Material Weakness

Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2024: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2024Item 2024-004 - Speci...

Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2024: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2024Item 2024-004 - Special Tests and Provisions (Material Weakness) During our audit, we noted that the Center did not properly determine the sliding fee discount of certain eligible patients based on information provided during the patient registration process. Recommendation We recommend that the Center conduct training of all of its personnel who are involved in determining the sliding fee scale of patients. We also recommend that an internal audit of a sample of patient charts be conducted periodically to ensure that patients' sliding fee scale discounts or category is properly and accurately determined based on information provided by patients. Finally, we recommend that such internal audit be documented. Action Taken Management agrees with the finding and will be establishing policies and procedures and conducting training for all personnel involved in determining patients' sliding fee scale to help ensure the accuracy of the process. Management will also implement an internal audit of a sample of patient charts and will ensure that such audits are properly documented. Effectivity Date: June 30, 2025

View Audit 358045

Finding 563799 (2024-002)

Material Weakness 2024

Wallingford Housing Authority

CT

Reporting HUD Housing Programs Material Weakness

Finding Reference Number: 2024-002 Reporting Description of Finding: The required unaudited annual filing with HUD's Real Estate Assessment Center (REAC), for fiscal 2024, was not made by the required deadline of September 15, 2024. In addition, as noted in finding 2024-001, prior audit adjustments...

Finding Reference Number: 2024-002 Reporting Description of Finding: The required unaudited annual filing with HUD's Real Estate Assessment Center (REAC), for fiscal 2024, was not made by the required deadline of September 15, 2024. In addition, as noted in finding 2024-001, prior audit adjustments, there were material misstaments that were not identified and corrected by management. Statement of Concurrence or Nonconcurrence: The Wallingford Housing Authority agrees and accepts the above referenced findings. Corrective Action: The Wallingford Housing Authority currently is procuring a new third-party fee accountant that will prepare and submit all required unfilled filings to the appropriate agencies. The Wallingford Housing Authority will create and maintain a schedule of all required submittal dates.

View Audit 358012

Finding 563613 (2024-002)

Material Weakness 2024

Council of Spanish Speaking Organizations, Inc.

PA

Allowable Costs / Cost Principles Student Financial Aid Subrecipient Monitoring

2024-002 • Material Weakness in Internal Control over Compliance Condition: During our eligibility assessment, we examined 40 files from Community Umbrella Agency 3 (CUA) foster care children to ensure they contained required documents by the City of Philadelphia and Pennsylvania's Department of H...

2024-002 • Material Weakness in Internal Control over Compliance Condition: During our eligibility assessment, we examined 40 files from Community Umbrella Agency 3 (CUA) foster care children to ensure they contained required documents by the City of Philadelphia and Pennsylvania's Department of Human Services (DHS). Our review found missing documents, time gaps between submissions, or untimely paperwork, including the following: (a) 29 CUA Safety Assessments, (b) 30 CUA Safety Plans, (c) 7 CUA PA Model Risk Assessments, (d) 3 CUA Documented Client Visits (Structure Case Notes), (e) FAST Family Advocacy Forms, (f) 17 Life Skills Assessment/ Biopsychosocial Evaluation/ IEP or Ages & Stages Questionnaire (ASQ), (g) 11 School Aged Report Cards, (h) 6 CUA Authorization to Release Information, (i) 9 CUA Immunizations, (j) 3 DHS Court Order Sheets, (k) 14 Child’s Photo, (l) 10 Initial CUA Single Case Plan, (m) 7 Monthly Updates to CUA Single Case Plan, (n) 17 Initial CUA Case Service Conference Summary Report, and (o) 16 Six Month Ongoing CUA Services Conference Summary Report. Furthermore, each child's file needed to contain specific documents from the DHS, which had to be supplied by the department or shown evidence of request by the CUA. Missing documents consisted of: (a) 34 DHS Service Authorization Forms, (b) 21 DHS CUA Provider Referral Forms, and (c) 30 DHS CUA In-Home Services Referral Forms. Recommendation: We recommend that management continue to develop policies and procedures in order to properly include all pertinent documentation within each client file as required by the City of Philadelphia, Department of Human Services. In addition, we recommend that program leadership and/or quality control department performs periodic audits of the client files to ensure all required documentation is included. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. FINDINGS – FEDERAL AWARD PROGRAM AUDITS (CONTINUED) Action taken in response to finding: 1. Hiring of Chief Compliance Officer to oversee Concilio Quality Assurance and Compliance process 2. Staffing of Quality Assurance department 3. Monthly review of client files for accuracy and completeness 4. Additional training of staff to review audit findings and implement corrective action Name of the contact person responsible for corrective action: Albert Essilfie, Chief Financial Officer albert.essilfie@elconcilio.net (215) 627-3100 Planned completion date for corrective action plan: June 30, 2025

View Audit 357894

Finding 563033 (2024-027)

Material Weakness 2024

City of Baltimore, Maryland

MD

Reporting Material Weakness Period of Performance § 200.302 § 200.303

Finding 2024-027 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-023 Auditee’s Corrective Action Plan: BCHD fiscal department contin...

Finding 2024-027 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-023 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established a Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

View Audit 357839

Finding 562904 (2024-023)

Material Weakness 2024

City of Baltimore, Maryland

MD

Subrecipient Monitoring Eligibility Material Weakness § 200.302 § 200.303

Finding 2024-023 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-019 Auditee’s Corrective Action Plan: BCHD fiscal department continues to rev...

Finding 2024-023 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-019 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established a Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

View Audit 357839

Finding 562864 (2024-021)

Material Weakness 2024

City of Baltimore, Maryland

MD

Reporting Subrecipient Monitoring Material Weakness § 200.302 § 200.303

Finding 2024-021 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-016 Auditee’s Corrective Action Plan: The Federal Financial Report (FFR) is a cumu...

Finding 2024-021 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-016 Auditee’s Corrective Action Plan: The Federal Financial Report (FFR) is a cumulative report covering the entire project or award period, which for this grant spans from March 1, 2020, to February 28, 2025. As a result, the cumulative amounts reported on the FFR will not align with the amounts recorded in the general ledger for fiscal year 2024. BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established the Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025

View Audit 357839

Finding 562179 (2024-001)

Material Weakness 2024

Caspian Housing Corporation - Spring Valley Apartments

MI

HUD Housing Programs Procurement, Suspension & Debarment Material Weakness § 200.303

Caspian Housing Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan, PC, 2425 E. Grand River Ave., Suite 1, Lansing, MI 48912 Audit period: Year ended December 31, 2024 The findings from December 31, 2024 schedule o...

Caspian Housing Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan, PC, 2425 E. Grand River Ave., Suite 1, Lansing, MI 48912 Audit period: Year ended December 31, 2024 The findings from December 31, 2024 schedule of finding and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding Number 2024-001 - Material Weakness in Interal Control Over Major Program Complaince Recommendation: Develop and implement comprehensive written policies and procedures that align with Uniform Guidance requirements. Action Taken: We are in agreement with the recommendations and will work to implement the required policies and procedures in accordance with Uniform Guidance during 2025.

View Audit 357783

Finding 562120 (2024-004)

Material Weakness 2024

Jackson Area Concil on Alholism and Drug Dependency

TN

Material Weakness Internal Control / Segregation of Duties

2024 – 004 Disbursements not receiving proper approval - Block Grants for Prevention and Treatment of Substance Abuse – ALN 93.959 (Material Weakness under Government Auditing Standards and Noncompliance) Person responsible for implementing the corrective action: The Board of Directors and Barry Co...

2024 – 004 Disbursements not receiving proper approval - Block Grants for Prevention and Treatment of Substance Abuse – ALN 93.959 (Material Weakness under Government Auditing Standards and Noncompliance) Person responsible for implementing the corrective action: The Board of Directors and Barry Cooper Anticipated completion date of corrective action: June 30, 2025. Repeat finding: No. Planned corrective action: We will retain adequate documented approval on disbursements.

View Audit 357739

Finding 562088 (2024-001)

Material Weakness 2024

Genesee County, Michigan

MI

Eligibility Subrecipient Monitoring Material Weakness § 200.303

Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second empl...

Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review. This was implemented in September of 2024. Contact person responsible for corrective action: Lucy Rosenberg and Michelle Estell Anticipated Completion Date: 09/01/2024

View Audit 357726

Finding 562080 (2024-001)

Material Weakness 2024

Charter Township of Northville

MI

Subrecipient Monitoring Material Weakness Reporting § 200.303

Condition: The Township did not have controls in place surrounding the review of annual performance reporting. Planned Corrective Action: The Township has implemented a formal review process within the Finance and Budget Department to ensure the integrity of annual performance reporting. One staff m...

Condition: The Township did not have controls in place surrounding the review of annual performance reporting. Planned Corrective Action: The Township has implemented a formal review process within the Finance and Budget Department to ensure the integrity of annual performance reporting. One staff member has been designated to compile and complete the performance reports,while a separate finance team member is responsible for conducting an independent review prior to submission. To support this process, an internal timeline has been established to allow sufficient time for thorough review and validation of all performance data before final submission. Contact person responsible for corrective action: Wendy Hillman Anticipated Completion Date: 04/15/2025

View Audit 357711

Finding 562048 (2024-003)

Material Weakness 2024

Brazos Valley Council of Governments

TX

HUD Housing Programs Material Weakness Reporting

In evaluating appropriate corrective action, management separately considered the audited and the unaudited submissions to the HUD REAC system. While the internal controls over these submissions are very similar, differing circumstances affect future corrective actions. Audited Submissions - With re...

In evaluating appropriate corrective action, management separately considered the audited and the unaudited submissions to the HUD REAC system. While the internal controls over these submissions are very similar, differing circumstances affect future corrective actions. Audited Submissions - With respect to the audited submissions, we believe that corrective action was already sufficiently taken during FY24. We note that this finding is a repeat finding from 2023; the focus of that finding was the untimely submission of the 2021 and 2022 submissions. In response to that finding, management increased oversight over the REAC process and engaged an outside CPA firm to provide technical assistance that would increase the speed and accuracy of the submission process. However, the 2023 audit was not completed until July 2024, which was already past the deadline for the 2023 audited submission. Because the audit’s completion is a prerequisite to the audited REAC submission, the delays to the audit’s completion precluded timely submission of the 2023 audited information. We agree with the auditor’s assessment of a state of noncompliance, as this was the only audited submission required to be made during fiscal year 2024. However, we note that no audited submissions have been required to be made since that time, and as such, no additional corrective action has been implemented since the 2023 audit and the corrective action contemplated in that audit’s corrective action plan. Unaudited Submissions - With respect to the unaudited submission, management believes that the submissions were untimely not because of a deficiency in internal control but rather a purposeful delay as a matter of practice. BVCOG has, for several years, held off submitting each year’s unaudited data until after the acceptance of the prior year’s audited submission. This was historically done to help ensure that amounts between REAC, VMS, and BVCOG’s financial system reconciled as closely as possible, and that HUD’s acceptance comments on the audited submission were implemented in the very next submission. BVCOG has not received communication from the granting agency with respect to this practice. However, BVCOG recognizes the importance of regulatory deadlines, and in future years, BVCOG will proceed with the submission of the unaudited information regardless of whether or not a previous year’s audited submission is not yet approved by HUD. We will modify our practices accordingly to ensure that HUD comments on any submission are addressed as timely as possible, with a resubmission when necessary.

View Audit 357642

Finding 562030 (2024-001)

Significant Deficiency 2024

Fife School District No.417

WA

School Nutrition Programs Subrecipient Monitoring Cash Management

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oa...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oak St, Milton, WA 98354 (253) 517-1000 ext 29121 Corrective action the auditee plans to take in response to the finding: The Fife School District implemented the following to Ensure Adequate Internal Controls for Compliance with Federal Eligibility: The Business Services team and Nutrition Services staff have conducted a thorough review of the process of monthly paid lunch equity and modified its procedures including developing a checklist for the process to ensure that it is completed in a timely manner, signed/dated and saved both electronically and in hard copy on a shared district server folder. The Fife School District implemented the following to Ensure Adequate Internal Controls for the annual completion of the Paid Lunch Equity Tool. The Business Services team and Nutrition Services staff have conducted a thorough review of the process of completing both the PLE tool and GL 828 reconciliation and modified its procedures to ensure that it is completed, signed and saved both electronically and in hard copy on a shared district server folder. Further, the Business Services team and Nutrition Services staff have developed a checklist for the completion of the tool and the checking of the box that indicates that we will be opting not to increase meal prices, but instead to demonstrate using the GL 828 Reconciliation (signed and dated) that we have sufficient fund balance to offset the paid lunches and not utilize Federal funds, including calendar reminders and a shared Google Drive to hold all related documents and procedures. Anticipated date to complete the corrective action: 5/16/2025

View Audit 357621

Finding 562025 (2024-002)

Material Weakness 2024

Harriett Buhai Center for Family Law

CA

HUD Housing Programs Material Weakness Reporting

Management has already implemented several new processes and controls related to this finding. These include a change in third party accounting firm to a firm with more robust knowledge of non-profit accounting. Management is also focusing on improving donor documentation, especially for pledges, to...

Management has already implemented several new processes and controls related to this finding. These include a change in third party accounting firm to a firm with more robust knowledge of non-profit accounting. Management is also focusing on improving donor documentation, especially for pledges, to ensure donor intent for the year of use is explicit.

View Audit 357619

Finding 562010 (2024-001)

Material Weakness 2024

High Valley Manor Apartments (an Operating Component of Slvhc, Inc.)

CO

Internal Control / Segregation of Duties Material Weakness Reporting

CORRECTIVE ACTION PLAN Name of Entity: High Valley Manor Apartments Audit Firm: SVA Certified Public Accountants, S.C. Audit Period: Year ended December 31, 2024 Corrective Action Plan Prepared by: Name: Dawn Melgares Position: Executive Director of San Luis Valley Housing Coalition, Inc. Tele...

CORRECTIVE ACTION PLAN Name of Entity: High Valley Manor Apartments Audit Firm: SVA Certified Public Accountants, S.C. Audit Period: Year ended December 31, 2024 Corrective Action Plan Prepared by: Name: Dawn Melgares Position: Executive Director of San Luis Valley Housing Coalition, Inc. Telephone Number: 719-587-9807 1. 2024-001 Finding – Internal control over financial reporting a. Comments on findings and recommendations There is a lack of controls over financial reporting to ensure material misstatements are detected and corrected in a timely manner and the project relies on its auditors to assist in the preparation of the financial statements in accordance with generally accepted accounting principles. b. Actions taken or planned i. Management agent to review processes to ensure transactions are recorded in proper accounts. ii. Management agent will review all audit adjustments and create processes to perform annual account reconciliation of year end balances agree to supporting schedules. c. Anticipated completion date July 31, 2025

View Audit 357607

Finding 561982 (2024-005)

Material Weakness 2024

Colorado Legal Services, INC

CO

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

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization implement a control process to ensure that it meets its matching requirements within the grant period. Explanation of Disagreement With Audit Finding...

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization implement a control process to ensure that it meets its matching requirements within the grant period. Explanation of Disagreement With Audit Finding: Management does not agree with this finding. LSC program letter 22-5 emphasizes the importance of reconciliations of timekeeping reports with labor costs, distribution report or alternative reports. CLS prioritizes this practice of reconciliation and used it during the last months of 2024 to improve internal controls and minimize potential errors. We do not believe that CLA fully and fairly considered CLS’s thorough and complete reconciliation. A “material weakness” is defined as a deficiency “such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected, on a timely basis.” Given that reconciliation is part of our internal control process used to prevent and detect/correct any errors, it should have been fully considered and is unfairly excluded from the review. For this reason, CLS considers that this is not a material weakness as the reconciliation caught and corrected these errors. Finally, the total amount of this finding is very low and should not rise to the level of material weakness. Action Taken in Response to Finding: The Organization is updating the segregation of duties in order to improve the preparation, review and sign steps of the process. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

View Audit 357595

Finding 561981 (2024-004)

Material Weakness 2024

Colorado Legal Services, INC

CO

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs § 200.403

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization consider updating its salaries and wages cost allocation methodology and process to reduce the frequency of manual adjustments based on review of indi...

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization consider updating its salaries and wages cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Explanation of Disagreement With Audit Finding: Management does not agree with this finding. LSC program letter 22-5 emphasizes the importance of reconciliations of timekeeping reports with labor costs, distribution report or alternative reports. CLS prioritizes this practice of reconciliation and used it during the last months of 2024 to improve internal controls and minimize potential errors. We do not believe that CLA fully and fairly considered CLS’s thorough and complete reconciliation. A “material weakness” is defined as a deficiency “such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected, on a timely basis.” Given that reconciliation is part of our internal control process used to prevent and detect/correct any errors, it should have been fully considered and is unfairly excluded from the review. For this reason, CLS considers that this is not a material weakness as the reconciliation caught and corrected these errors. Finally, the total amount of this finding is very low and should not rise to the level of material weakness. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

View Audit 357595 Questioned Costs: $1

Finding 561972 (2024-002)

Material Weakness 2024

Colorado Legal Services, INC

CO

Questioned Costs Allowable Costs / Cost Principles Material Weakness § 200.403 § 200.430

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximiz...

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Additionally, the distribution of expenses in the general fund, which includes LSC and two other funding sources, represents a fair method and allocation. Regarding the questioned costs, CLS disagrees with the finding of material weakness given the extremely low total dollar value. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

View Audit 357595 Questioned Costs: $1

Finding 561967 (2024-001)

Significant Deficiency 2024

Orting School District No. 344

WA

School Nutrition Programs Subrecipient Monitoring Cash Management

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of District contact person: Marci Bannan, Director of Business Services 121 Whitesell S...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of District contact person: Marci Bannan, Director of Business Services 121 Whitesell St NE Orting, WA 98360 Corrective action the auditee plans to take in response to the finding: Eligibility: The District will document the internal controls that are in place for the monthly direct certification downloads and will print the certification download along with saving it electronically so that the files are easy to provide for future audits. Paid Lunch Equity: The District will document the internal controls that are in place for the completion of the PLE tool and ensure that the form is completed appropriately to show the continued use of nonfederal funds that are used yearly to fund the food service account fully. The District will also make sure to ‘print’ the GL 828 tab of the Fund Balance Reporting tool that is done yearly no later than November and sign it immediately after completion of the year end process to provide for the proof that the district has and continues to contribute sufficient nonfederal funds to the food service account. Anticipated date to complete the corrective action: July 31, 2025

View Audit 357586

Finding 561845 (2024-001)

Material Weakness 2024

Wpc Housing Corp. Danford Hall Apartments

MO

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED FEBRUARY 29, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED FEBRUARY 29, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended February 28, 2023. Finding 2024-001 Responsible Party Name: Tamara Wallace Position: Executive Director – Management Agent Telephone Number: 816-233-4250 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Rental and Cooperative Housing (Section 221(d)(4)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditors’ finding. Corrective Action We will ensure that the accounts reconcile to source documents as part of our month-end closing process. Anticipated Completion Date September 30, 2024

View Audit 357505

Finding 561843 (2024-001)

Material Weakness 2024

Teachers College, Columbia University

NY

Student Financial Aid Reporting Subrecipient Monitoring

2024-001 Reporting (Financial) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460, (9/1/2023-8/31/2024) Finding Type: Material Weakness and Noncompliance Responsible personnel: Alyssa Timko, Di...

2024-001 Reporting (Financial) Student Financial Assistance Cluster: U.S. Department of Education Federal Direct Student Loans (ALN 84.268) Federal Grant Numbers and Years: P268K240460, (9/1/2023-8/31/2024) Finding Type: Material Weakness and Noncompliance Responsible personnel: Alyssa Timko, Director of Financial Aid, act2156@tc.columbia.edu, 212 678-3654 Corrective Action Plan: In September 2023, the College identified a technical issue with the manual reporting process for student loan disbursements to COD and determined the existing solution was only partially functioning at that time. While some loan activity was timely and properly reported to COD, other student disbursement transactions were stalled and reported after the 15-calendar day requirement. At that time, the College’s ERP, Banner, job submission process for disbursement reporting to COD was manually initiated by the Office of Financial Aid. The resulting reports were then uploaded through the DOE’s EDconnect, a Windows based software application, using WinSCP file transfer (the same process was used for return files from COD). After an evaluation, it was determined that a new solution and process was required to ensure proper, complete and timely reporting under the regulations. The reporting process was redesigned in October 2023 as part of a plan to automate loan origination and now functions through Automic, a workload automation software. Instead of manually generated files and upload / receipt through EDconnect, student loan disbursement records are now automated to/from COD using TDClient, which is a command software for sending and receiving student aid related information through the DOE’s Student Aid Internet Gateway (SAIG). The new process regularly transfers loan disbursement data to COD. However, the College also determined that a prescheduled pause in the Automic loan origination process at the end of the fiscal year 2024 academic year (in August 2024), which was established in accordance with the regulations, also inadvertently paused loan disbursement reporting and resulted in late submissions. The Office of Financial Aid has also remedied this issue by adding non-standard reporting days to the standard calendar. Along with more frequent and recurring reconciliations of Banner to COD loan disbursement data and ensuring the continuation of disbursement reporting after loan originations are paused at the end the academic year, the College does not anticipate any further late reporting matters and expects all future disbursement data to be reported within 15 calendar days.

View Audit 357504

Finding 561786 (2024-001)

Material Weakness 2024

Boys & Girls Clubs of Benton and Franklin Counties

WA

Allowable Costs / Cost Principles Material Weakness

Federal grants will be recorded in Paycom (our payroll software) showing hours worked on a specific grant (with staff clocking in/out based on time worked) rather than adjustments made to the GL.

View Audit 357442

Finding 561708 (2024-001)

Material Weakness 2024

Global Community Charter School

NY

School Nutrition Programs Cash Management Material Weakness

Global Community Charter School recognizes the management deficiencies cited by MMB+CO as finding 2024-001 in the FY2024 Audited Financial Statements. The following procedures have been implemented to mitigate and/or eliminate further process deficiencies. ● Beginning in August 2024, all participati...

Global Community Charter School recognizes the management deficiencies cited by MMB+CO as finding 2024-001 in the FY2024 Audited Financial Statements. The following procedures have been implemented to mitigate and/or eliminate further process deficiencies. ● Beginning in August 2024, all participating operations staff were retrained and given clarity on the importance of accurate and timely count management. ● At the elementary and middle school, one operations person has been designated as responsible for the monthly count. This individual coordinates all personnel involved in the process and is further responsible for ensuring coverage and accuracy when personnel are shifted around or absent. ● This designated individual also meets with the food preparer weekly to check the provider’s meal count against the school's. ● The designated individual also annotates the weekly/monthly count on a digital worksheet that compares the food providers' count against the schools. ● The Director of Finance audits the worksheet monthly for “reasonability”, accuracy, and consistency. ● Post-audit, the CFO does a final review. If anything anomalous or inconsistent is found, the team will meet to confirm if the changes reflect actual student utilization. If no changes are required, the CFO takes the monthly data and uploads it to the template provided by the NSLP consultant who submits the voucher. In addition to the process outlined above, an ongoing review of student utilization is being conducted to reduce the waste and cost to the school created when too many meals are produced and students do not consume them. This process should allow meals produced to mirror consumption going forward. We implemented this process in mid-August and expect positive realignment and consistency from November 2024 onward.

View Audit 357332

Finding 561685 (2024-003)

Material Weakness 2024

Wilsona School District

CA

Subrecipient Monitoring Material Weakness Reporting

Corrective Action Plan and Views of Responsible Officials There was confusion as to what the data point should be used in regarding reporting FTE count within this federal reporting module by past District staff. Clarity has been provided a strategy has been created and professional development has ...

Corrective Action Plan and Views of Responsible Officials There was confusion as to what the data point should be used in regarding reporting FTE count within this federal reporting module by past District staff. Clarity has been provided a strategy has been created and professional development has been provided. The annual reporting period is currently now open and correct FTE counts will be corrected for all reporting years.

View Audit 357316

Finding 561624 (2024-001)

Material Weakness 2024

Central Kitsap School District No. 401

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Scott McDaniel, Executive Director of Business and Operations or Lara Christopherson, As...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Scott McDaniel, Executive Director of Business and Operations or Lara Christopherson, Assistant Director of Business and Payroll P.O. Box 8 Silverdale, WA 98383 (360) 662-1650 Corrective action the auditee plans to take in response to the finding: 1. Student Supports Office Manager will ensure each staff member requiring time and effort certification is provided with the correct time and effort forms for semiannual or monthly certifications. 2. Student Supports Office Manager tracks time and effort certifications monthly on a spreadsheet; checking for completion, verifying the correct form was used, correctly dated by all parties, and returned within 30 days following the end of the reporting period. The Departmental Administrator will be notified if an employee has not returned a time and effort certification so they can follow-up and address the deficiency. 3. Student Supports Office Manager will review completed time and effort certifications on a monthly basis with the departmental administrator. 4. Student Supports will develop a time and effort training regarding procedures and the importance of completing time and effort certifications. This will ensure all required staff members understand what they need to report and why we need it completed. Time and effort training and detailed instructions will be provided at the beginning of each school year. Anticipated date to complete the corrective action: 09/30/2025

View Audit 357231

Corrective Action Plans

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