Corrective Action Plans

Finding 573854 (2023-001)

Material Weakness 2023

PA

Reporting Material Weakness

BHI has engaged a professional research administration consulting firm to provide guidance on federal grants management activities, compliance requirements and policy and procedure development. BHI meets monthly with the grants management consultant. Furthermore, BHI has implemented procedures to ...

BHI has engaged a professional research administration consulting firm to provide guidance on federal grants management activities, compliance requirements and policy and procedure development. BHI meets monthly with the grants management consultant. Furthermore, BHI has implemented procedures to ensure adequate internal control over financial processes. For one, all the invoicing on all grant and contract accounts are done monthly. The BHI admin/program manager prepares all invoices on a monthly basis which are then reviewed by Chief Operating Officer and finally approved by the Principal Investigator. All financial transactions are recorded in QuickBooks so that bank and credit card accounts can be reconciled monthly. And lastly, an automated solution has been implemented to keep all bill payment and approvals strictly separate.

View Audit 364502

Finding 573841 (2023-002)

Material Weakness 2023

City of Tenino

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding ref number: 2023-002 Finding caption: The City did not have adequate internal controls with federal wage rate requirements. Name, address, and telephone of City contact person: Nancy Reddick, Clerk-Treasurer, 149 Hodgden St S, Tenino, WA 98589, (360) 264-2368. Corrective action the auditee p...

Finding ref number: 2023-002 Finding caption: The City did not have adequate internal controls with federal wage rate requirements. Name, address, and telephone of City contact person: Nancy Reddick, Clerk-Treasurer, 149 Hodgden St S, Tenino, WA 98589, (360) 264-2368. Corrective action the auditee plans to take in response to the finding: The City will include the required wage rate provisions in future contracts and will require weekly certified payroll reports prior to paying the contractor for the appropriate periods. Anticipated date to complete the corrective action: Immediately

View Audit 364492

Finding 573744 (2023-001)

Material Weakness 2023

Florence-Carlton School District 15-6

MT

Material Weakness Reporting Internal Control / Segregation of Duties § 200.512

We have reviewed the deficiencies and have included our responses to each below. 1. Finding # 2023-001 –Late filing of Financial and Audit. Reports had not been filed within nine months after the fiscal year end of Jun. 30, 2023, which should have been by Mar. 31, 2024. Management Response: Flore...

We have reviewed the deficiencies and have included our responses to each below. 1. Finding # 2023-001 –Late filing of Financial and Audit. Reports had not been filed within nine months after the fiscal year end of Jun. 30, 2023, which should have been by Mar. 31, 2024. Management Response: Florence Carlton School District 15-6 has historically filed audit reports in a timely manner to the respective agencies. The district experienced multiple key changes in financial management positions within a short period, which slowed down the audit process. Florence Carlton has filed our audit reports and data collection forms with the state, federal, and credit agencies, but this process also lacked training. Internal control procedures have been outlined and implemented for the future, including the Schedule of Federal Awards, and will continue to be implemented moving forward. The lack of Standard Working Instructions (SWI) contributes to the lack of consistency, compliance, and training. I have developed SWIs with Visual (photos or videos) directions for each step in all areas of a broad base of responsibility of the clerk position.

View Audit 364413

Finding 573437 (2023-004)

Material Weakness 2023

Athens Metropolitan Housing Authority

OH

HUD Housing Programs Subrecipient Monitoring Reporting § 200.328

Finding Number: 2023-004 Planned Corrective Action: The extension was granted and the housing authority kept in contact by email to HUD in regard to the lengthy audit process due to former executive director. Our plan is to be timelier once these issues are rectified. Anticipated Completion Date: Ma...

Finding Number: 2023-004 Planned Corrective Action: The extension was granted and the housing authority kept in contact by email to HUD in regard to the lengthy audit process due to former executive director. Our plan is to be timelier once these issues are rectified. Anticipated Completion Date: May 31, 2025 Responsible Contact Person: Sherrie Boudinot, Zackary Dye

View Audit 364184

Finding 573435 (2023-003)

Material Weakness 2023

Athens Metropolitan Housing Authority

OH

HUD Housing Programs Procurement, Suspension & Debarment Material Weakness

Finding Number: 2023-003 Planned Corrective Action: The Authority has contracted with the Inspection Group and has contracted with HAPCAP to also do inspections to ensure that all inspections are done in time. The Authority has designated a staff person to keep track of abatements and to send an i...

Finding Number: 2023-003 Planned Corrective Action: The Authority has contracted with the Inspection Group and has contracted with HAPCAP to also do inspections to ensure that all inspections are done in time. The Authority has designated a staff person to keep track of abatements and to send an inspector out to do a reinspection within the permitted time frames. If the unit fails a second inspection, in most cases the HAP is abated, or a formal extension is granted on occasion. Anticipated Completion Date: October 2024 Responsible Contact Person: Erica Flanders

View Audit 364184

Finding 573433 (2023-002)

Material Weakness 2023

Athens Metropolitan Housing Authority

OH

HUD Housing Programs Special Tests & Provisions Material Weakness

Finding Number: 2023-002 Planned Corrective Action: The Authority is now in contract with the Nelrod company to do Authority Rent Reasonableness. Anticipated Completion Date: August 2024 Responsible Contact Person: Zackary Dye/Erica Flanders

View Audit 364184

Finding 573390 (2023-010)

Material Weakness 2023

Batavia Local School District

OH

Reporting Subrecipient Monitoring Material Weakness § 200.414 § 200.502 § 200.510

The School District will review the Uniform Guidance requirements and ensure all expenditures are accurately reported on the School District’s Schedule of Expenditures of Federal Awards.

View Audit 364161

Finding 572535 (2023-011)

Material Weakness 2023

Churches United for the Homeless

MN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.328

2023‐011 Reporting - COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Person responsible for corrective action – Devlyn Brooks, Executive Director Corrective action planned – Management will refine job duties and responsibilities related to federal, state, and grant reporting required by g...

2023‐011 Reporting - COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Person responsible for corrective action – Devlyn Brooks, Executive Director Corrective action planned – Management will refine job duties and responsibilities related to federal, state, and grant reporting required by granting agencies. A review process will be established where an employee independent of the report preparation will review the reports to be submitted along with all supporting documentation. A shared drive will be established where copies of all reporting and supporting documentation will be kept for review and any future requests from granting agencies. Planned implementation date of corrective action – Calendar year 2025.

View Audit 363689

Finding 572526 (2023-008)

Material Weakness 2023

Churches United for the Homeless

MN

Questioned Costs Allowable Costs / Cost Principles Cash Management

2023‐008 Allowable Costs and Allowable Activities - COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Person responsible for corrective action – Devlyn Brooks, Executive Director Corrective action planned – Management is working to establish better financial reporting to ensure that costs a...

2023‐008 Allowable Costs and Allowable Activities - COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Person responsible for corrective action – Devlyn Brooks, Executive Director Corrective action planned – Management is working to establish better financial reporting to ensure that costs are appropriately allocated to grants for reimbursement and to establish adequate supporting documentation for all expenditures reimbursed with federal, state, or grant funding. Planned implementation date of corrective action – Calendar year 2025.

View Audit 363689 Questioned Costs: $1

Finding 572520 (2023-006)

Material Weakness 2023

Churches United for the Homeless

MN

Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

2023‐006 Allowable Costs and Allowable Activities - COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Person responsible for corrective action – Devlyn Brooks, Executive Director Corrective action planned – The financial management team is reviewing the requirements for federal expenditures...

2023‐006 Allowable Costs and Allowable Activities - COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Person responsible for corrective action – Devlyn Brooks, Executive Director Corrective action planned – The financial management team is reviewing the requirements for federal expenditures under Uniform Guidance for better understanding of the requirements and to establish appropriate policies and procedures for handling of federal funding. Planned implementation date of corrective action – Calendar year 2025.

View Audit 363689

Finding 572327 (2023-060)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Special Tests & Provisions Material Weakness § 200.334 § 200.337

VIEWS OF RESPONSIBLE OFFICIALS As part of the digitization project process, ADSEF seeks to standardize procedures and ensure the organization and proper location of documents within the files. For this Digitalization project we have available matching funds of approximately 7 million dollars IMPLEME...

VIEWS OF RESPONSIBLE OFFICIALS As part of the digitization project process, ADSEF seeks to standardize procedures and ensure the organization and proper location of documents within the files. For this Digitalization project we have available matching funds of approximately 7 million dollars IMPLEMENTATION DATE December 2027 RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572326 (2023-059)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Special Tests & Provisions Eligibility Material Weakness

VIEWS OF RESPONSIBLE OFFICIALS ADSEF developed a collaborative agreement with ASUME to ensure the digital processing of referrals containing information about the absent parent. IMPLEMENTATION DATE August 2025 RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by i...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF developed a collaborative agreement with ASUME to ensure the digital processing of referrals containing information about the absent parent. IMPLEMENTATION DATE August 2025 RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572325 (2023-058)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Special Tests & Provisions Eligibility Material Weakness

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. Through its Office of Technology and Information, ADSEF used to send the BENDEX list to the regional offices. This proc...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. Through its Office of Technology and Information, ADSEF used to send the BENDEX list to the regional offices. This process was discontinued as of November 2022, when the collaborative agreement with Social Security expired. The SWICA list continues to be processed monthly across all the regions covered by ADSEF. IMPLEMENTATION DATE December 2025 RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572324 (2023-057)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Reporting Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

VIEWS OF RESPONSIBLE OFFICIALS According to the audit recommendation, it is requested that a written process for reconciling EBT Reconciliation Reports be implemented and developed. Additionally, it is recommended that staff be trained in this matter. The Finance Division will be preparing a task fo...

VIEWS OF RESPONSIBLE OFFICIALS According to the audit recommendation, it is requested that a written process for reconciling EBT Reconciliation Reports be implemented and developed. Additionally, it is recommended that staff be trained in this matter. The Finance Division will be preparing a task force to assign roles, provide training, and develop a protocol to improve processes and ensure that EBT Reports are reconciled. Manuals will be amended to establish a clearer written procedure. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572322 (2023-056)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.305 § 200.328 § 200.329

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and ...

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. Once the agreements are finalized, they will be submitted to the auditing firm. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572321 (2023-055)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Reporting Procurement, Suspension & Debarment Subrecipient Monitoring § 200.302

VIEWS OF RESPONSIBLE OFFICIALS The Department of the Family has initiated several corrective actions. Since the first months of Fiscal Year 2024, the Accounting Department has started a review of unliquidated obligations on a monthly basis, canceling any invalid obligations and reporting them in the...

VIEWS OF RESPONSIBLE OFFICIALS The Department of the Family has initiated several corrective actions. Since the first months of Fiscal Year 2024, the Accounting Department has started a review of unliquidated obligations on a monthly basis, canceling any invalid obligations and reporting them in the FY 2024 SSA-4513 report. In fact, Budget and Finance staff had multiple working sessions with PR-DDS personnel to identify and write-off unliquidated obligations that were no longer current. Also, we conducted training for finance and budget staff on accounting controls and administrative cost reporting to ensure compliance with federal regulations. Includes a review of 2 CFR Part 225 on allowable costs (direct allowable and indirect allocable, the difference between direct and indirect costs), reasonable and allocable costs. In addition, we addressed issues of unliquidated obligations (Consultative Examinations (CE) and Medical Evidence of Record (MER), among others). Nevertheless, beginning the first quarter of FY2026, following recent staffing changes in the Finance Department, we are in the process of re-training our team to ensure that unliquidated obligations are reviewed every month and invalid commitments are promptly canceled. To reinforce these practices, the Department of the Family will also deliver a series of new workshops to relevant staff outlining the procedures and best practices for SSA-4513 preparation and POMS compliance. IMPLEMENTATION DATE September 2025 RESPONSIBLE PERSON Office of the Secretariat

View Audit 363366

Finding 572318 (2023-053)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

VIEWS OF RESPONSIBLE OFFICIALS Draft and approve eligibility criteria in accordance with federal reporting requirements. Implement monthly reconciliations between TANF and internal records. Establish a report review committee with designated personnel. It’s important to note that administrative expe...

VIEWS OF RESPONSIBLE OFFICIALS Draft and approve eligibility criteria in accordance with federal reporting requirements. Implement monthly reconciliations between TANF and internal records. Establish a report review committee with designated personnel. It’s important to note that administrative expenses are listed under Letter F of the Family Preservation program. Other expenses that could be considered administrative under different letters—such as materials, payroll, etc.—are related to direct services, since the employees being paid under these accounts are social workers and the materials are used for activities that are part of the direct service. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Families and Children (ADFAN, by the Spanish Acronym)

View Audit 363366

Finding 572317 (2023-052)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.305 § 200.334 § 200.335 § 200.336

VIEWS OF RESPONSIBLE OFFICIALS ADSEF has controls and procedural manuals related to data collection. As part of the digitization project process, ADSEF seeks to standardize procedures and ensure the organization and proper location of documents within the files. Annexes IMPLEMENTATION DATE Up to Dat...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF has controls and procedural manuals related to data collection. As part of the digitization project process, ADSEF seeks to standardize procedures and ensure the organization and proper location of documents within the files. Annexes IMPLEMENTATION DATE Up to Date RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym) AUDITORS’ COMMENT ADSEF did not provide us with a manual describing the data collection process as requested during the auditing procedures. An unsigned and undated Manual was attached to the Corrective Action Plan. Also, ADSEF was required to provide us with the corresponding participant worksheet appendix and the physical file to corroborate the information included in the report. ADSEF provided us with evidence of the hand-completed forms; however, we were not provided with the physical files to validate the information included in each document. This represents a scope limitation.

View Audit 363366

Finding 572316 (2023-051)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.305 § 200.328 § 200.329

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and ...

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. Once the agreements are finalized, they will be submitted to the auditing firm. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572311 (2023-049)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302 § 200.303 § 200.305 § 200.334 § 200.335

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and ...

VIEWS OF RESPONSIBLE OFFICIALS It is recommended, among other things, to establish internal controls that provide certainty, effective monitoring, data validation, and accountability for those employees who execute the reporting processes. To this end, the personnel responsible will be convened and written processes will be issued to expedite the information requests and ensure their rapid submission. This will be in accordance with both state and federal regulations. Once the agreements are finalized, they will be submitted to the auditing firm. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572256 (2023-040)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Eligibility Material Weakness § 200.334 § 200.337

VIEWS OF RESPONSIBLE OFFICIALS As part of the digitization project process, ADSEF seeks to standardize procedures and ensure the organization and proper location of documents within the files. For this Digitalization project we have available matching funds of approximately 7 million dollars. IMPLEM...

VIEWS OF RESPONSIBLE OFFICIALS As part of the digitization project process, ADSEF seeks to standardize procedures and ensure the organization and proper location of documents within the files. For this Digitalization project we have available matching funds of approximately 7 million dollars. IMPLEMENTATION DATE Awaiting System Implementation RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572255 (2023-039)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Eligibility Material Weakness § 200.303

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. As part of its ongoing digitization efforts, ADSEF has incorporated the replacement of the Social Security number with ...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. As part of its ongoing digitization efforts, ADSEF has incorporated the replacement of the Social Security number with a unique identification number. IMPLEMENTATION DATE December 2025 RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym) continue

View Audit 363366

Finding 572253 (2023-038)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Eligibility Material Weakness § 200.303

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. As part of its ongoing digitization efforts, ADSEF has incorporated the replacement of the Social Security number with ...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. As part of its ongoing digitization efforts, ADSEF has incorporated the replacement of the Social Security number with a unique identification number. Anexes: • Comunicación Límite de tiempo de Beneficios Categoría C • Comunicación sobre periodo de certificación Categoría C, próximos a cumplir los 60 meses. IMPLEMENTATION DATE December 2025 RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Finding 572249 (2023-037)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Questioned Costs Allowable Costs / Cost Principles Eligibility

VIEWS OF RESPONSIBLE OFFICIALS Establish a peer or supervisory review process for a percentage of eligibility determinations prior to final approval and implement a common error log to identify areas requiring further training or adjustment of procedures. IMPLEMENTATION DATE During Fiscal Year 2025-...

VIEWS OF RESPONSIBLE OFFICIALS Establish a peer or supervisory review process for a percentage of eligibility determinations prior to final approval and implement a common error log to identify areas requiring further training or adjustment of procedures. IMPLEMENTATION DATE During Fiscal Year 2025-2026. RESPONSIBLE PERSON Sidnia Vélez, Child Care Program Administration for the Care and Comprehensive Development of Children (ACUDEN, by its Spanish Acronym)

View Audit 363366 Questioned Costs: $1

Finding 572248 (2023-036)

Material Weakness 2023

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Eligibility Material Weakness § 200.303

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. As part of its ongoing digitization efforts, ADSEF has incorporated the replacement of the Social Security number with ...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF will assess and develop, together with program directors and program specialists, retraining sessions aimed at technical staff and supervisors. As part of its ongoing digitization efforts, ADSEF has incorporated the replacement of the Social Security number with a unique identification number. IMPLEMENTATION DATE December 2025 RESPONSIBLE PERSON Administration for Socioeconomic Development of the Family (ADSEF, by its Spanish Acronym)

View Audit 363366

Corrective Action Plans

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