Corrective Action Plans

Finding 526112 (2023-004)

Material Weakness 2023

NM

Material Weakness § 200.512

Planned Corrective Action: I feel that there is a fundamental misunderstanding between the audit firm and NMF accounting staff on this issue. During the audit process, NMF accounting staff responded to requests from the auditors in a timely manner. Frequently, we would submit documentation and then ...

Planned Corrective Action: I feel that there is a fundamental misunderstanding between the audit firm and NMF accounting staff on this issue. During the audit process, NMF accounting staff responded to requests from the auditors in a timely manner. Frequently, we would submit documentation and then we would not hear back for weeks. What would be helpful is an agreed upon time frame for the audit and due dates when responses are required. We will meet all due dates. It would be helpful if the Pulakos Accounting web portal for submitting documentation was organized according to the PBC requests using Smart Sheet or a similar software. It would make tracking response much easier. Anticipated Completion Date: January 31, 2025. Responsible Contact Person: Philip Varnum, Finance Director, and Finance Staff

View Audit 345200

Finding 525921 (2023-001)

Material Weakness 2023

Hawkeye Area Community Action Program

IA

Material Weakness Reporting Internal Control / Segregation of Duties

Hawkeye Area Community Action Program, Inc. (HACAP) has migrated our financial accounting software to a data center managed by a 3'' party. A full backup of the database is done daily to both the cloud and to a hard drive that is securely stored. Person(s) Responsible: Paula Mahan, Jim McGoldrock Ti...

Hawkeye Area Community Action Program, Inc. (HACAP) has migrated our financial accounting software to a data center managed by a 3'' party. A full backup of the database is done daily to both the cloud and to a hard drive that is securely stored. Person(s) Responsible: Paula Mahan, Jim McGoldrock Timing for Implementation: Immediate action was taken, and the change was made as soon as the data breach was discovered in October 2023.

View Audit 345096

Finding 525896 (2023-001)

Material Weakness 2023

Moses Lake School District No. 161

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls and did not comply with allowable activities and allowable costs requirements. Name, address, and telephone of District contact person: Mitch Thompson 1620 S. Pioneer Way Moses Lake, WA 98837 (...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls and did not comply with allowable activities and allowable costs requirements. Name, address, and telephone of District contact person: Mitch Thompson 1620 S. Pioneer Way Moses Lake, WA 98837 (509) 766-2650 Corrective action the auditee plans to take in response to the finding: While the district concurs with the finding that it didn’t have adequate internal controls during the 2022-23 school year, the district disagrees that the monies were not spend on allowable costs under the grants. The district has changed leadership as well as accounting staff. Following the change, the new Executive Director of Finance & Operations instituted measures to ensure that the district complies with grant claims and journal entry procedures. One of the changes was that the person who inputs the journal entries has those entries reviewed by another person. This means that if the Accounting Supervisor inputs the journal entry, the Executive Director of Finance & Operations reviews the entry for accuracy as well as if the expenditures are allowable under the new account code(s). One of the other changes put into place was the implementation of uploading the supporting documentation into the accounting system the district uses so that the documentation doesn’t get lost or misplaced. The district realizes the importance of verifying expenditures and internal reviews to ensure accuracy and these two actions by the district will ensure compliance and proper internal controls. Anticipated date to complete the corrective action: 12/31/2024

View Audit 345047 Questioned Costs: $1

Finding 525883 (2023-008)

Material Weakness 2023

County of Solano

CA

Eligibility Material Weakness

Finding 2023‐008 Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Medicaid Cluster Federal Assistance Listing Number: 93.778 Pass‐through: California Department of Health Care Services Award No. and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type ...

Finding 2023‐008 Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Medicaid Cluster Federal Assistance Listing Number: 93.778 Pass‐through: California Department of Health Care Services Award No. and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Eligibility Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County agrees that eligibility determinations and redeterminations including obtaining documentation and verifications should be performed annually to determine if individuals are eligible in accordance with the compliance requirements of the programs. Since the current single audit timeframe, we have made several changes in how we approach overdue redetermination. Maintaining adequate staffing for IHSS clients is an ongoing goal, but not the only approach to this issue. We have increased accountability for our Social Workers’ work by assigning cases to them and following completion of these cases. We are using performance improvement plans and other supports to ensure Social Workers are meeting the performance standard. We have created a more efficient case documentation tool which may save time. Overtime is offered to staff to support extra case work. We participate in State level discussions related to advocacy, budget requests for IHSS administrative funding and related issues. Responsible Individual(s): Gwendolyn Gill, Health Services Administrator Bela Matyas, Chief Deputy Director Anticipated Completion Date: July 1, 2024

View Audit 345033

Finding 525876 (2023-005)

Material Weakness 2023

County of Solano

CA

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Assistance Listing Number: 93.323 Pass‐through: California Department of Public Health Award No. and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compl...

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Epidemiology and Laboratory Capacity for Infectious Diseases Federal Assistance Listing Number: 93.323 Pass‐through: California Department of Public Health Award No. and Year: COVID-19ELC48, COVID-19ELC106, 2021/2022 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective action was implemented in April 2023. Responsible Individual(s): Nina Delmendo, Director of Administrative Services Anticipated Completion Date: April 2023

View Audit 345033

Finding 525873 (2023-004)

None 2023

County of Solano

CA

Eligibility Special Tests & Provisions Material Weakness

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Allowable Costs,...

Federal Agency: U.S. Department of Health and Human Services Program/Cluster: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Pass‐through: California Department of Social Services Award No. and Year: 1946001347 A7, 2022/2023 Compliance Requirement: Allowable Costs, Eligibility, and Special Tests and Provisions Type of Finding: Material Weakness in Internal Control over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Solano County has policies and procedures as well as systematic processes set up to ensure the required collection and documentation of the applicant’s intent to cooperate with child support. It is Solano County’s policy that the Child Support Questionnaire and Notice and Agreements be processed which require workers to: • Conduct an interview either via telephone, or in-person with the applicant, print the forms, and document the County Use Section which requires worker’s signature and date. • Mail the form to the applicant for a wet signature or collect the signature via electronic means. • Upon return, review the CW2.1 form(s) for completeness. • Initiate the required case action(s) based upon information provided on the forms. Solano County has a Quality Assurance Unit of lead workers to conduct 2-3 case reviews per month for all workers. Case reviews are a valuable tool in assessing case accuracy and recognizing quality casework. The case reviews are used to develop and strengthen worker and supervisory skills, provide structure for measuring results, identify, correct and prevent errors, and strengthen accountability to the programs and services we delivery as an agency. Specific corrective actions are outlined below to prevent this error in the future: • The CalWORKs Program Specialist will work with Hiring and Staff Development to strengthen the pertinent CalWORKs Eligibility Handbook sections with verbiage to emphasize the following: o The requirement to review and collect the information needed to complete the notice and agreement (form CW2.1) for child, spousal, and medical support from the applicant. o That the case be authorized according to program rules only after required forms are received by the county, reviewed to ensure that the case is updated with the correct information, documented in the case journal, and the form(s) scanned into the document imaging system. o Highlight these requirements when training this topic. • The CalWORKs Program Specialist will discuss the findings and requirement in the following ways: o Monthly Program Support Forum conducted with managers, supervisors, and lead workers. o Issue a reminder to all staff. o Written material will be published in the Monthly Program Support Newsletter to all staff. Responsible Individual(s): Daniel Horel, Employment and Eligibility Services Manager Thomas West, Employment and Eligibility Services Manager Diana Hernandez, Employment and Eligibility Services Manager Anticipated Completion Date: May 31, 2024

View Audit 345033

Finding 525871 (2023-003)

Material Weakness 2023

County of Solano

CA

Subrecipient Monitoring Reporting Material Weakness § 200.303

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Housing Voucher Cluster Federal Assistance Listing Number: 14.871, 14.879 Pass‐through: n/a – direct award Award No. and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in In...

Federal Agency: U.S. Department of Housing and Urban Development Program/Cluster: Housing Voucher Cluster Federal Assistance Listing Number: 14.871, 14.879 Pass‐through: n/a – direct award Award No. and Year: CA131, 2022/2023 Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Views of Responsible Officials and Corrective Action Plan: The County spent many months contacting multiple agencies trying to report through the FSRS system on the multiple Housing Voucher awards, with no success. The County’s assigned Housing and Urban Development (HUD) office is the San Francisco regional office. Per their director, “These are systems that we don’t work with in HUD PIH so I won’t be able to be of assistance relative to this.” The County is unable to complete FFATA reporting for reasons outside of the County’s control. Responsible Individual(s): James Bezek, Director of Resources Management Anticipated Completion Date: Because the corrective action is outside of the County’s control, we cannot determine an anticipated completion date.

View Audit 345033

Finding 525755 (2023-003)

Material Weakness 2023

Sauk-Suiattle Indian Tribe

WA

Special Tests & Provisions Procurement, Suspension & Debarment Material Weakness

Finding 2023-003 – Special Tests and Provisions – Character Investigations (Material Weakness in Internal Controls over Compliance and Material Noncompliance) Planned Corrective Action: The Tribe will increase the level of background checks regrading all individuals that will encounter ICW children ...

Finding 2023-003 – Special Tests and Provisions – Character Investigations (Material Weakness in Internal Controls over Compliance and Material Noncompliance) Planned Corrective Action: The Tribe will increase the level of background checks regrading all individuals that will encounter ICW children and secure fingerprints checks through an approved agency or credited state, federal or private agency vendor. Name of Responsible Party: Shawnaa Smith Anticipated Completion Date: 12/31/2025

View Audit 344908

Finding 525686 (2023-003)

Material Weakness 2023

Belforest Water Systems, Inc.

AL

Material Weakness Reporting Internal Control / Segregation of Duties

2023-003 – Delinquent and Inaccurate Quarterly Reporting to Lenders – Material Weakness in Internal Controls over Compliance/Material Noncompliance Recommendation: Management should implement a control to ensure that reports related to their grant funding are accurately and timely filed. Action Take...

2023-003 – Delinquent and Inaccurate Quarterly Reporting to Lenders – Material Weakness in Internal Controls over Compliance/Material Noncompliance Recommendation: Management should implement a control to ensure that reports related to their grant funding are accurately and timely filed. Action Taken: The Business Manager created a monthly checklist that includes a monitoring procedure to verify all reporting necessary under contracts and agreements has been accurately prepared and submitted on time. In addition, due dates of required reports are logged on the calendar of the Business Manager. Responsible Person – Business Manager, Marinda Turner Anticipated Completion Date: February 28, 2025

View Audit 344799

Finding 525293 (2023-004)

Material Weakness 2023

African American Child Wellness Institute

MN

Subrecipient Monitoring Material Weakness Reporting

Finding 2023-004 Noncompliance-Reporting Material Weakness ALN 93.958 Block Grants for Community Mental Health Services Pass-through Entity Identification Number GRK 213195 U. S. Department of Health and Human Services Minnesota Department of Human Services Condition: The report for the year ende...

Finding 2023-004 Noncompliance-Reporting Material Weakness ALN 93.958 Block Grants for Community Mental Health Services Pass-through Entity Identification Number GRK 213195 U. S. Department of Health and Human Services Minnesota Department of Human Services Condition: The report for the year ended December 31, 2022, was not filed within the required report submission period. Actions Planned in Response to the Finding: Prior to 2022, the Organization barely had the infrastructure to fully run a non-profit organization. The state legislature has been kind to provide funding to build the infrastructure within the organization. The learning curve has been steep but senior management staff and Board members in understanding the federal requirements. With adequate resources, the Organization is on track to accelerate the submission of future audit reports henceforth. Official Responsible for Ensuring the CAP: Chief Operating Officer Planned Completion Date for the CAP: July 15, 2025

View Audit 344524

Finding 525285 (2023-002)

Material Weakness 2023

African American Child Wellness Institute

MN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding 2023-002 Noncompliance-Allowable Costs/Costs Principles Material Weakness ALN 93.958 Block Grants for Community Mental Health Services Pass-through Entity Identification Number GRK 213195 U. S. Department of Health and Human Services Minnesota Department of Human Services Condition: Emplo...

Finding 2023-002 Noncompliance-Allowable Costs/Costs Principles Material Weakness ALN 93.958 Block Grants for Community Mental Health Services Pass-through Entity Identification Number GRK 213195 U. S. Department of Health and Human Services Minnesota Department of Human Services Condition: Employee time sheets do not identify the hours charged to each federal grant, and do not identify hours worked by employees on non-federal grants. Actions Planned in Response to the Finding: The timeline for hiring an in-house accountant is very compressed. The in-house accountant will undergo various training on Uniform Guidance and federal grant management. These training programs will help the organization to create a system of time and effort reporting that will meet the Standards for Documentation of Personnel Expenses included in OMB Uniform Guidance. Specifically, time sheets will be redesigned to ensure that employees record hours charged to each federal grant, any other projects, and administrative time. Official Responsible for Ensuring the CAP: Chief Operating Officer Planned Completion Date for the CAP: June 30, 2025

View Audit 344524 Questioned Costs: $1

Finding 525281 (2023-001)

Material Weakness 2023

African American Child Wellness Institute

MN

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

To: U.S. Department of Health and Human Services-Passed through Minnesota Department of Human Services RE: Single Audit Corrective Action Plan (CAP) for the fiscal year ended December 31, 2023 Name and address of independent accounting firm: BWK Rogers PC 431 South Seventh Street, Suite 2424 Minn...

To: U.S. Department of Health and Human Services-Passed through Minnesota Department of Human Services RE: Single Audit Corrective Action Plan (CAP) for the fiscal year ended December 31, 2023 Name and address of independent accounting firm: BWK Rogers PC 431 South Seventh Street, Suite 2424 Minneapolis, MN 55415 African American Child Wellness Institute submits the following corrective action plan for the year ended December 31, 2023. Please contact Akinyele Akinsanya at 763-522-0100. Finding 2023-001 Noncompliance-Allowable Costs/Costs Principles Material Weakness ALN 93.958 Block Grants for Community Mental Health Services Pass-through Entity Identification Number GRK 213195 U. S. Department of Health and Human Services Minnesota Department of Human Services Condition: Expenses charged to the federal grant cannot be traced into the Organization’s general ledger. Invoices submitted to the pass-through agency for reimbursement also cannot be traced into the general ledger. Actions Planned in Response to the Finding: It is clear to management that the Organization needs to boost its accounting team to fulfil effective reporting that could easily be traced into the organization’s general ledger. As a result, the organization will recruit and hire a full-time accountant to work with the current team. Further steps may be required including replacing the organization’s current accounting software that will identify and record expenditure specific to each cost centers for each federal grant. The in-house accountant will also be required to obtain additional training in Uniform Guidance and federal grant management and create a system of financial reporting to record expenditure directly to each federal grant award. Official Responsible for Ensuring the CAP: Chief Operating Officer Planned Completion Date for the CAP: March 15, 2025

View Audit 344524 Questioned Costs: $1

Finding 525092 (2023-005)

Material Weakness 2023

Confluence Health

WA

Questioned Costs Allowable Costs / Cost Principles Material Weakness § 200.303

Finding 2023-005 Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 5 TIN# 910171250 Activities Allowed or Unallowed, Allowable Cost...

Finding 2023-005 Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 5 TIN# 910171250 Activities Allowed or Unallowed, Allowable Cost/Cost Principles Material Weakness in Internal Control over Compliance and Noncompliance Finding Summary: Confluence Health claimed and reported expenditures that contained errors based upon the underlying documentation. Context: A nonstatistical sample of 60, supplies, services, and payroll transactions out of a population of approximately 5,215 totaling $5,006,903 were selected for testing. The sample contained errors in two transactions in which the amounts claimed on the Period 5 report were not supported by payroll records. The amounts claimed not supported by payroll records totaled $89,582 out of a total sample value of $2,615,445. Corrective Action Plan: Confluence Health will tract with separate payroll codes for employee working on federal grants that involve inpatient facing care for the next pandemic to allow for accurate tracking of costs. Responsible Individual: Eric Caldwell, VP of Finance is responsible for this corrective action plan that was put into place on January 15, 2025.

View Audit 344374 Questioned Costs: $1

Finding 525091 (2023-004)

Material Weakness 2023

Confluence Health

WA

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2023-004 Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 5 TIN# 910171250 Finding Summary: For certain quarters, the am...

Finding 2023-004 Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 5 TIN# 910171250 Finding Summary: For certain quarters, the amounts reported for net patient revenue were based on gross charges. Additionally, amounts did not agree to the supporting documentation provided. Corrective Action Plan: Confluence Health during the next pandemic will confirm reporting requirements before submitting reporting data. Confluence developed a Grant Committee to oversee the reporting guidelines before approving grants. This will make the information for reporting requirements clearer to the organization and Financial Reporting Department. The 2023 data was reported at net patient revenue as required by the grant. Responsible Individual: Eric Caldwell, VP of Finance is responsible for this corrective action plan that was put into place after the audit.

View Audit 344374

Finding 525090 (2023-003)

Material Weakness 2023

Confluence Health

WA

Material Weakness Reporting Internal Control / Segregation of Duties

Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 5 TIN# 910171250 Finding Summary: Confluence Health selected option ii to calculat...

Department of Health and Human Services Federal Financial Assistance Listing #93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Applicable Federal Award Number and Year – Period 5 TIN# 910171250 Finding Summary: Confluence Health selected option ii to calculate lost revenue which consists of a comparison of actual results during the period of availability to a budget approved before March 27, 2020, for the entire period of availability. The budget used in the calculation of lost revenue for quarters in 2021, 2022 and 2023 was not approved prior to March 27, 2020. Corrective Action Plan: Confluence Health during the next pandemic will issue a budget for the entire period required by the grant. Confluence developed a Grant Committee to oversee the reporting guidelines before approving grants. This will make the information for reporting requirements clearer to the organization and Financial Reporting Department. Responsible Individual: Eric Caldwell, VP of Finance is responsible for this corrective action plan that was put into place after the audit.

View Audit 344374

Finding 524401 (2023-002)

Material Weakness 2023

Sinai Health System and Affiliates

IL

Questioned Costs Period of Performance Subrecipient Monitoring § 200.308 § 200.309 § 200.403

Condition: Controls did not identify that expenses submitted to the State were outside of the period of performance. Planned Corrective Action: Background: Sinai began the process of risk assessment in the government grants area at the end of 2022. At that time, Sinai engaged outside counsel to as...

Condition: Controls did not identify that expenses submitted to the State were outside of the period of performance. Planned Corrective Action: Background: Sinai began the process of risk assessment in the government grants area at the end of 2022. At that time, Sinai engaged outside counsel to assist in this process. In December of 2023, Sinai created the Office of Government Grant Administration (OGGA) and developed a comprehensive grant compliance policy and procedure. The Audit and Compliance Committee of the Board was updated on this initiative. In 2024, the OGGA created a Grant Compliance Manual which sets forth processes and procedures in grant management to ensure compliance with government regulations. Unfortunately, these controls were not implemented until after the relevant time period at issue in this audit. In 2025, Sinai is continuing to improve its compliance procedures with respect to government grants, and has developed the following plan: 1. Working Group: Sinai will implement a process of convening a Working Group for each government grant, which will consist of a representative from Finance, the OGGA, and the stakeholder involved (i.e., nursing, medicine, etc.) The Working group will be responsible for, among other things, ensuring that that the reported qualifying expenditures are incurred during the period of performance of the grant. In other words, allowable costs will be discussed early in the process, so that there is fulsome understanding among the key individuals involved. 2. Record-Keeping: The OGGA will also establish shared folders to house all of the pertinent documentation relative to the grant. 3. Invoice/Supporting Documentation Review. The Grant Accounting Manager will review all invoices and other supportive documentation to ensure that allowable costs are submitted for reimbursement. This compliance check will be completed prior to submission of the documentation for reimbursement. Monthly reviews of these activities will be performed by the Grant Accountant, the Compliance Grant Manager, and other OGGA staff as needed. Proactive review to prevent or resolve issues in the upcoming month’s billings should be pursued. 4. Annual Assessment. The Chief Compliance Officer, with the assistance of the General Counsel, will meet with the OGGA team annually to assess procedures and risk controls; a report of this assessment will be made to the Audit and Compliance Committee of the Board of Directors Contact person responsible for corrective action: Dimas Ortega - Vice President of Finance, Deputy Chief Financial Officer Anticipated Completion Date: 06/30/2025

View Audit 343640 Questioned Costs: $1

Finding 524240 (2023-002)

Material Weakness 2023

Next Move Homeless Services

CA

Questioned Costs Special Tests & Provisions HUD Housing Programs

Program: Continuum of Care Federal Financial Assistance Listing No.:14.267 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward Award Year: 2023 Compliance Requirement: Special Tests and Provisions – Reasonable Rental Rates Grant Award Number: ...

Program: Continuum of Care Federal Financial Assistance Listing No.:14.267 Federal Agency: U.S. Department of Housing and Urban Development Pass-through: Sacramento Steps Forward Award Year: 2023 Compliance Requirement: Special Tests and Provisions – Reasonable Rental Rates Grant Award Number: CA0955L9T032108, CA0955L9T032209, CA0143L9T032114, CA0143L9T032215, CA1303L9T032107, CA1303L9T032208 Finding Summary: • As a result of our procedures performed, we noted for 8 out of 17 rental participants tested, the organization could not provide documentation to demonstrate the reasonableness of contract rents being paid for individual housing units in relation to rents being charged for comparable units. This should have included an analysis of rents in the immediate area of the participants housing. • For 3 out of 41 rental payments tested, we noted the rent paid exceed the HUD-determined fair market rents for the fiscal year. Repeat Finding from Prior Years: Yes, Finding 2022-002 Management’s Response: We concur. Views of Responsible Officials and Corrective Action: • Develop policies and procedures for staff working on grants to ensure that all contract rents being paid for individual housing units are reasonable in relation to rents being charged for comparable units. Additionally, the policies and procedures will ensure that grant funds being used to pay rent will not exceed HUD-determined fair market rents. • Train grant staff on new policies and procedures. Name of Responsible Person: Bryan Wagner, CFO Projected Implementation Date: December 31, 2024

View Audit 343437 Questioned Costs: $1

Finding 523996 (2023-006)

Material Weakness 2023

Magnolia School District

CA

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness

We agree with the recommendation and moving forward the Director of MOTF will ensure that all contractors and subcontractors submit required certified payrolls weekly and ensure that all construction contracts funded by the program include the prevailing wage rate requirement clause. These records w...

We agree with the recommendation and moving forward the Director of MOTF will ensure that all contractors and subcontractors submit required certified payrolls weekly and ensure that all construction contracts funded by the program include the prevailing wage rate requirement clause. These records will be maintained a minimum of three years.

View Audit 343203

Finding 523988 (2023-005)

Material Weakness 2023

Magnolia School District

CA

Material Weakness Reporting Internal Control / Segregation of Duties

We agree with the recommendation and moving forward all federal expenditures and full-time equivalent positions are reported accurately on the ESSER annual and quarterly reports, and that supporting documentation is maintained to support the amounts reported.

View Audit 343203

Finding 523980 (2023-004)

Material Weakness 2023

Magnolia School District

CA

Questioned Costs Allowable Costs / Cost Principles Material Weakness

We agree with the recommendation and moving forward all expenditure records and financial reports will be maintained for a minimum of three years.

View Audit 343203 Questioned Costs: $1

Finding 523548 (2023-003)

Material Weakness 2023

Pennsylvania Housing Finance Agency

PA

Material Weakness Internal Control / Segregation of Duties

U.S. Department of Treasury Housing Assistance Fund Program – Assistance Listing No. 21.026 Recommendation: CLA recommended that PHFA review their procedures around the debt verification during the HAF program application process. Explanation of disagreement with audit finding: There is no disagre...

U.S. Department of Treasury Housing Assistance Fund Program – Assistance Listing No. 21.026 Recommendation: CLA recommended that PHFA review their procedures around the debt verification during the HAF program application process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Based on this and other similar inadequacies with the vendor, the Agency terminated the contract of the non-compliant vendor (IEM) and moved the administration of the program in house. The new procedures and software being utilized provide the required documentation and verification to support disbursements as evidenced by the audit review. The Agency also anticipates making a mandatory discovery demand for all supporting program documentation to include the debt verification data and will seek judicial enforcement if IEM does not comply with the request. Name of the contact person responsible for corrective action: Kelly Wilson, PAHAF Program Manager. Planned completion date for corrective action plan: The migration to in house administration was completed in March of 2023. The discovery request is expected to be made by no later than Monday, March 25th, 2024.

View Audit 342838

Finding 523418 (2023-004)

Material Weakness 2023

Plainview Serenity Center, Inc.

TX

Material Weakness

See Finding 2023-001

View Audit 342711

Finding 523167 (2023-004)

Material Weakness 2023

Southern Maryland Tri-County Community Action Committee, Inc.

MD

Reporting Internal Control / Segregation of Duties Material Weakness § 200.501

Finding Reference: 2023-004 Views of Responsible Officials and Planned Corrective Actions The Agency agrees with this finding and recommendation as presented. In some contexts, the Agency experienced significant turnover in the Finance department during the third quarter, and a new Finance Directo...

Finding Reference: 2023-004 Views of Responsible Officials and Planned Corrective Actions The Agency agrees with this finding and recommendation as presented. In some contexts, the Agency experienced significant turnover in the Finance department during the third quarter, and a new Finance Director was hired during the fourth quarter of fiscal year 2023. The turnover in fiscal staff hindered the accounting processes and oversight that included journal entry review and postings and account reconciliations promptly. As a corrective measure to ensure adhering to a closing schedule and maintaining timely account reconciliations, the Agency reevaluated the fiscal department’s needs and hired new staff, including a finance director, accounts payable, part-time fiscal support specialist, and contracted with a CPA to assist with the following scope of work:  Review all trial fund balance processes.  Prepare a closing schedule that includes reporting and data processing deadlines.  Reconcile all balance sheet accounts in the general ledger chart of accounts.  Timely prepare and file all financial reports required by each award.  Work with the independent auditor to implement an interim audit fieldwork schedule to reduce required work subsequent to fiscal year-end. Name of the contact person responsible for corrective action: Michael Young, President, (301) 274-4474. Planned completion date for corrective action plan: December 31, 2025

View Audit 342468

Finding 523138 (2023-004)

Material Weakness 2023

Central Minnesota Jobs and Training Services

MN

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

MFIP and TANF Youth – Assistance Listing No. 93.558 Recommendation: The Organization should implement a comprehensive documentation retention policy that includes specific procedures for maintaining records supporting the calculation of indirect cost allocations. This policy should ensure that all r...

MFIP and TANF Youth – Assistance Listing No. 93.558 Recommendation: The Organization should implement a comprehensive documentation retention policy that includes specific procedures for maintaining records supporting the calculation of indirect cost allocations. This policy should ensure that all relevant documentation is retained for the required period and is easily accessible for audit purposes. Additionally, the Organization should ensure the formal review process for indirect cost allocations is completed to verify their accuracy and compliance with applicable regulations. Staff responsible for financial record-keeping and review should receive training on the importance of documentation retention, review procedures, and the specific requirements under the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To strengthen our financial recordkeeping, CMJTS will update our Document Retention Policy. This updated policy will introduce detailed guidelines for the management, maintenance, and secure storage of records that support indirect cost allocations, ensuring they are retained for the required period and easily accessible for audits. Additionally, we will establish a structured review process, including quarterly reviews by the accounting team and an annual reconciliation, to verify accuracy and compliance with applicable regulations. Any necessary adjustments will be documented and reviewed by the finance manager. The CMJTS Executive meets monthly to review and calculate indirect cost allocations for all active grants. The established process is to determine total indirect costs (like rent, utilities, administrative salaries) for the agency by location and department and then allocate them across different grants using a calculated "indirect cost rate," which is usually a percentage of the direct costs associated with each program, based on factors like staff time, caseload size, or other relevant allocation bases; this ensures that each program bears a proportional share of the shared overhead expenses. Name(s) of the contact person(s) responsible for corrective action: Jake Humphrey Planned completion date for corrective action plan: Policy updates – 12 months; Indirect Cost Rates process – implemented

View Audit 342459

Finding 522987 (2023-004)

Material Weakness 2023

Wright County Community Action, Inc.

MN

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

Head Start - ALN #93.600 Recommendation: We recommend that the Organization should review and approve the indirect costs that are allocated by the preparer and retain support of this review and approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding...

Head Start - ALN #93.600 Recommendation: We recommend that the Organization should review and approve the indirect costs that are allocated by the preparer and retain support of this review and approval. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WCCA will implement a policy to ensure a documented review and approval of indirect cost allocations. Name(s) of the contact person(s) responsible for corrective action: Carrie Tripp, Executive Director Planned completion date for corrective action plan: September 30, 2025

View Audit 342228

Corrective Action Plans

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