Corrective Action Plans

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Finding 2023-001 Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 24 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has ...
Finding 2023-001 Condition The College did not notify the National Student Loan Data System (NSLDS) in a timely manner for 24 students with status changes in our sample of 25 students. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The College has updated its policies and procedures to ensure notifications to the National Student Loan Data System are performed timely. In addition, all members of the responsible team will undergo formalized training to ensure their knowledge and proficiency regarding all applicable rules and regulations are kept up to date. Name(s) of Contact Person(s) Responsible for Corrective Action: Jeremy Sivillo, Institutional Registrar Kevin A. Thomas, D.O., Assistant Dean of Institutional Enrollment Management Anticipated Completion Date: Policies and procedure update implementation has been completed. Training for existing staff is to be completed by April 30, 2024. Training material development for new employees will be completed by May 31, 2024
Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Feder...
Planned Corrective Action: While we agree that the submission dates lagged the scheduled dates, we do not agree that this condition rises to the level of a material weakness in internal controls over reporting. BVCOG submitted their audited financial statements for fiscal year 2022 through the Federal Audit Clearinghouse (FAC) on June 30, 2023, which is prior to June 30, 2023. BVCOG awaits receipt of their audited financial fiscal year 2023 in order to submit them to the FAC. The audited fiscal year 2022 financial statements were submitted separately to HUD on November 22, 2023. HUD approved our submission without notice of delay. Unaudited financial statements for the fiscal year ending 2023 were submitted and accepted by HUD, with no point score deduction penalties or requests for corrective action. The timing of HUD’s Real Estate Assessment Center (REAC) report submission depends on acceptance of the previous unaudited or audited financial statements. The REAC submissions require that each year’s unaudited submission be approved by HUD before the audited submission can be submitted; further, both submissions for a year must be accepted by HUD before the next year’s submissions can be completed. Due to various factors including the COVID-19 pandemic and Winter Storm Uri in 2021, the Fiscal Year 2020 unaudited submission process completed April 2022. Subsequent staff turnover delayed the submission of the audited 2020 submission until August 2023. Once that submission was approved by HUD, the 2021 and 2022 submissions were completed by the end of November 2023. BVCOG realizes its REAC submission procedures rely on institutional knowledge and addressed this risk by engaging an outside CPA firm with personnel knowledgeable of the REAC system. This arrangement ensures additional cross-training opportunities in the future for current finance staff such that, if a key staff person leaves, there will be others in the department who know and understand the procedures necessary for compliance with HUD deadlines. Contact Person Responsible for Corrective Action: Janet Dudding, MBA, CPA, CGFO, Director of Finance Anticipated Completion Date: July 2024
Moving forward, a supervisory review of the move in files will be performed by a different staff member for the Authority than the staff member who initially determined eligibility. This will ensure that the Authority continues compliance with eligibility requirements.
Moving forward, a supervisory review of the move in files will be performed by a different staff member for the Authority than the staff member who initially determined eligibility. This will ensure that the Authority continues compliance with eligibility requirements.
It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to dete...
It was discovered that our financial institution was pledging securities based on book value and not on market value which led to the deposits not being fully collateralized according to HUD requirements and State Statutes. The Authority will review the collateral reports at least quarterly to determine that pledging requirements are adequate to ensure compliance in the future.
Finding 2023-001: Allowable costs – material weakness in internal controls over compliance and compliance finding. Management Response All submissions of 􀆟mesheets and payroll reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditu...
Finding 2023-001: Allowable costs – material weakness in internal controls over compliance and compliance finding. Management Response All submissions of 􀆟mesheets and payroll reimbursed by grants will require review by the Controller or the COO, in the Controller’s absence, to ensure that expenditures charged to the grants agree to the original 􀆟mesheets or payroll prior to submission or charging to a specific grant
Transitional Living for homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to monitor program income and ensure that the funds are being properly used before requesting additional federal funds. This could include regular reporti...
Transitional Living for homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to monitor program income and ensure that the funds are being properly used before requesting additional federal funds. This could include regular reporting on the use of program income and conducting periodic reviews to ensure compliance with program requirements. Additionally, the Organization should review its policies and procedures to ensure they are in compliance with program requirements and make any necessary updates. Finally, the Organization should ensure that all staff members responsible for monitoring program income are properly trained and have a clear understanding of program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During each Payment Management System Draw process, the Finance Director will verify the draw amounts and run a program income and expense report to verify that the amount of miscellaneous expenses for the Transitional Living Program are more than the program income received. A copy of the income and expense statement will be saved in each draw file with the other verification documents. A column for verification initials of this process was added to the ACF Grant Balances Spreadsheet used for recording the draw amounts and dates of the draws. Name(s) of the contact person(s) responsible for corrective action: Julia Montebello, Finance Director Planned completion date for corrective action plan: 4/26/2024
Transitional Living for Homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to ensure that proper documentation and support for eligibility is obtained and reviewed by a qualified individual. Explanation of disagreement with audit...
Transitional Living for Homeless Youth – Assistance Listing No. 93.550 Recommendation: It is recommended that the Organization implement controls to ensure that proper documentation and support for eligibility is obtained and reviewed by a qualified individual. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Program Director will conduct Weekly Document Reviews for new and ongoing clients and will also verify eligibility as staff submit weekly request forms for clients to receive services. Weekly Review Schedule: • The Program Director will conduct a review of all documentation once a week. Verification Process: • During the review, the Program Director will verify that all required documents for eligibility is being completed accurately, processed, and documented. Documentation of Review: • The results of this review will be documented on each client’s initial intake form and in Apricot. • The Program Director will sign the intake form to indicate verification and completion of the review and will also document this in Apricot. • By adhering to this procedure, we ensure that all documentation is thoroughly checked and validated on a consistent basis, maintaining the integrity and accuracy of our eligibility process. Name(s) of the contact person(s) responsible for corrective action: Elena Guerra, EYS Program Director. Planned completion date for corrective action plan: ongoing
Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the inte...
Finding 2023-003: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board had reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.
Catholic Social Services' management will improve its system of internal controls to correctly identify and present a complete and accurate schedule of expenditures of federal awards.
Catholic Social Services' management will improve its system of internal controls to correctly identify and present a complete and accurate schedule of expenditures of federal awards.
Community Development Block Grant and COVID-19 Community Development Block Grant – Material Weakness Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) reports, it was noted that no FFATA reporting had been completed during the year ended December 31, 2023. ...
Community Development Block Grant and COVID-19 Community Development Block Grant – Material Weakness Condition: During testing of the Federal Funding Accountability and Transparency Act (FFATA) reports, it was noted that no FFATA reporting had been completed during the year ended December 31, 2023. Recommendation: We recommend that the County continue with the process being implemented during the fiscal year 2024, which includes completing submission of the reports and tracking the timely submission of the FFATA reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With significant turnover of tenured leadership and employees within the Community Resources Department, Arapahoe County Community Resources took proactive measures in 2023 for review of the Community Development Housing and Homeless Services (CDHHS) programs (CDBG and HOME Investment) by recognized consultants within the field. Community Resources has contracted with two consultants, to assist in a full review and re-development of policies and procedures (Civitas) for the CDBG and HOME programs as well as a full review of all case files (Affordable Housing Consultants). Included with this response are the contracts with both Civitas and Affordable Housing Consultants for verification purposes. The County anticipates their work to be completed and an implementation of updated policies and procedures for these programs by fall of 2024. In response to the direct finding of no FFATA reporting during the year ending December 31st, 2023, Arapahoe County has ensured the entry of all sampled contracts. Demonstration of the report submissions have been submitted for verification purposes. It is important to note that all sub-agreements included the necessary FFATA information for the review period, but Community Resources failed to ensure that this information was entered into the FFATA Subaward Reporting System (FSRS). To ensure internal controls are in place for the FFATA’s timely and accurate submissions for all future subawards, Arapahoe County’s Community Resources Department has created the following internal controls and governance: 1. Creation of the FFATA Reporting Form which will be completed and submitted along with all future subaward agreements and includes all necessary information for complete and accurate submittal into FSRS. 2. Creation of the FFATA Subrecipient Reporting Work Instructions which detail the process, to include roles and responsibilities, for the completion and entry of the FFATA. 3. Update to our Grant Administration Policy which includes the requirement to complete and enter the FFATA in our grant administration oversight and track timely submission of the reports. Name of the contact persons responsible for corrective action: Katherine Smith Planned completion date for corrective action plan: September 30, 2024
DEPARTMENT OF PUBLIC HEALTH 2023-037 Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse - Assistance Listing No. 93.959 Action taken in response to the finding: All subrecipient FFATA information will be batch upload...
DEPARTMENT OF PUBLIC HEALTH 2023-037 Block Grants for Prevention and Treatment of Substance Abuse, COVID-19 - Block Grants for Prevention and Treatment of Substance Abuse - Assistance Listing No. 93.959 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of July 1. A batch upload of data will be completed each year in that period. All outlying contracts not executed on June 30 will have their FFATA data uploaded to FSRS within 30 days of contract execution throughout the year. These uploads will be conducted by the BSAS Grants coordinator. Once successfully uploaded the Grants coordinator will receive a FFATA submission receipt from FSRS for each FFATA submission. They will share this with their supervisor and the Fiscal Director for confirmation. These records will be kept on file in the BSAS Grant Teams file for future reference. Our internal Fiscal Compliance Auditor will review batches of these submission quarterly to ensure compliance. Name of the contact person responsible for corrective action: Shannon McEneaney-Farron, BSAS Fiscal Director Planned completion date for corrective action plan: July 31, 2024 If the Department of Health and Human Services has questions regarding this plan, please call David Godin at 617-721-6200.
DEPARTMENT OF PUBLIC HEALTH 2023-033 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of Ju...
DEPARTMENT OF PUBLIC HEALTH 2023-033 Opioid – STR - Assistance Listing No. 93.788 Action taken in response to the finding: All subrecipient FFATA information will be batch uploaded to FSRS within 30 days of execution of subcontracts. The majority of BSAS subrecipient contracts are executed as of July 1. A batch upload of data will be completed each month over the grant period so that all outlying contracts not executed on June 30 will have their FFATA data uploaded to FSRS within 30 days of contract execution throughout the year. These uploads will be conducted by the BSAS Grants coordinator. Once successfully uploaded the Grants coordinator will receive a FFATA submission receipt from FSRS for each FFATA submission. They will share this with their supervisor and the Fiscal Director for confirmation. These records will be kept on file in the BSAS Grant Teams file for future reference. Our internal Fiscal Compliance Auditor will review batches of these submission quarterly to ensure compliance. Name of the contact person responsible for corrective action: Shannon McEneaney-Farron, BSAS Fiscal Director Planned completion date for corrective action plan: Ongoing. This process will commence as of July 1, 2024.
EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-030 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: EOHHS is developing a standardized checklist, using CLA’s guidance as a template, to ensure that SOC reports ...
EXECUTIVE OFFICE OF HEALTH AND HUMAN SERVICES 2023-030 Medicaid Cluster, COVID-19 – Medicaid Cluster - Assistance Listing No. 93.775, 93.777, 93.778 Action taken in response to the finding: EOHHS is developing a standardized checklist, using CLA’s guidance as a template, to ensure that SOC reports are reviewed and that such reviews are documented. Name of the contact person responsible for corrective action: Conduent – Jacob Guggenheim, Director of Healthcare Information and Analysis DentaQuest - Tomaso Calicchio, Director of Specialty Provider Networks Maximus – Janice Wadsworth, Director of Provider Operations Planned completion date for corrective action plan: July 2024
EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-027 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly t...
EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-027 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly the Department of Housing and Community Development (DHCD or Department), has implemented the recommended measures and will continue them going forward. EOHLC has reviewed their policies and procedures for LIHEAP reporting requirements and is committed to making any enhancements that are necessary to ensure the reports are submitted timely and accurately, and that the information reported agrees to the supporting documentation. In addition, EOHLC Management or their designees will review deadlines and other requirements for LIHEAP reports on an ongoing basis. Name of the contact person responsible for corrective action: Edward Kiely Planned completion date for corrective action plan: October 1, 2024
EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-026 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly t...
EXECUTIVE OFFICE OF HOUSING AND LIVABLE COMMUNITIES 2023-026 Low-Income Home Energy Assistance, COVID-19 – Low-Income Home Energy Assistance - Assistance Listing No. 93.568 Action taken in response to the finding: The Executive Office of Housing and Livable Communities (EOHLC), which was formerly the Department of Housing and Community Development (DHCD or Department), has implemented the recommended measures and will continue them going forward. As a result of the original finding, 2022-018, EOHLC had previously put policies and procedures in place to ensure that all required subawards are reported timely and accurately to FSRS, and the Federal Funding Accountability and Transparency Act (FFATA) reports are reported timely and accurately. EOHLC’s FFATA report procedure was developed in September of 2023 and submitted on November 20, 2023. Although EOHLC acknowledges why this has resulted in this finding, EOHLC notes that policies and procedures have already been put in place to remedy this issue. Name of the contact person responsible for corrective action: Kristen Crowley Planned completion date for corrective action plan: FFATA report procedure developed September 12, 2023 and LIHEAP submitted November 20, 2023
DEPARTMENT OF PUBLIC HEALTH 2023-023 Immunization Cooperative Agreements, COVID-19 - Immunization Cooperative Agreements - Assistance Listing No. 93.268 Action taken in response to the finding: The Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting June 1, 2024 ...
DEPARTMENT OF PUBLIC HEALTH 2023-023 Immunization Cooperative Agreements, COVID-19 - Immunization Cooperative Agreements - Assistance Listing No. 93.268 Action taken in response to the finding: The Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting June 1, 2024 a process to review obligations for subawards under Immunization, Assistance Listing No. 93.268 to identify subawards that fall under the rules set forth by Federal Funding Accountability and Transparency Act (FFATA) and report the appropriate obligations to FSRS according to the above-mentioned recommendations. Name of the contact person responsible for corrective action: Cheryl Bernard-Dort, Director of Administration and Finance or her designee. Planned completion date for corrective action plan: The completion date for this correction action plan is September 30, 2024.
EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the mon...
EXECUTIVE OFFICE OF ELDER AFAIRS 2023-020 COVID-19 – Aging Cluster - Assistance Listing No. 93.044, 93.045, 93.053 Action taken in response to the finding: EOEA will establish a process to ensure that all required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Name of the contact person responsible for corrective action: Sheila Tunney, EOEA CFO Planned completion date for corrective action plan: EOEA will complete this corrective action plan following issuance of the final FFY24 federal award, which is expected in August 2024.
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federa...
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-013 WIOA Cluster– Assistance Listing No. 17.258, 17.259, 17.278 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to...
EXECUTIVE OFFICE OF LABOR AND WORKFORCE DEVELOPMENT 2023-007 Employment Service Cluster – Assistance Listing No. 17.207, 17.801 Action taken in response to the finding: EOLWD Finance is drafting a Standard Operating Procedure (SOP) that includes the necessary controls to ensure subawards subject to Federal Funding Accountability and Transparency Act (FFATA) reporting are reviewed, approved, and submitted timely to FSRS. EOLWD Finance will also conduct training for staff. Name of the contact person responsible for corrective action: Malachy Rice, Director of Federal Grants Management Planned completion date for corrective action plan: July 1, 2024
Corrective Action Plan: Review and approval of invoices, meal count sheets, and reimbursement requests will be more closely monitored, and leadership will continue to engage and teach agency staff to follow existing policies to assure compliance. No further policy revisions are necessary. Staff trai...
Corrective Action Plan: Review and approval of invoices, meal count sheets, and reimbursement requests will be more closely monitored, and leadership will continue to engage and teach agency staff to follow existing policies to assure compliance. No further policy revisions are necessary. Staff training will be strengthened. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024
Corrective Action Plan: Material adjustments were related to funds that were not clearly identified as Federal Funds that came to use from State agencies. States have a responsibility to indicate when they are providing pass-thru funding from federal sources. No further action deemed appropriate by ...
Corrective Action Plan: Material adjustments were related to funds that were not clearly identified as Federal Funds that came to use from State agencies. States have a responsibility to indicate when they are providing pass-thru funding from federal sources. No further action deemed appropriate by Nexus leadership. Responsible Individuals: Dr. Kenneth D. Varble – Vice President of Accounting Anticipated Completion Date: December 2024
Finding #2023-002 – Material Weakness and Material Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Passed through the Texas Workforce Commission, Child Care and Development Block Grant, Child Care Business Training, Assistance Listing #: 93.575, Contract N...
Finding #2023-002 – Material Weakness and Material Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Passed through the Texas Workforce Commission, Child Care and Development Block Grant, Child Care Business Training, Assistance Listing #: 93.575, Contract Number: 2920CCQ002, Contract Year: 12/01/19 – 06/30/24. Recommendation: CFC should implement policies and procedures to ensure that any applicable credits be credited to the Federal award either as a cost reduction or cash refund, as appropriate. Planned corrective action: CFC will develop a written policy outlining clear steps for: 1) Identifying and documenting credits associated with reversed invoices. 2)Applying credits within the accounting system to reduce grant costs. 3)Issuing refunds to funding agencies when required. Grant managers and finance personnel will be trained on these new policies and procedures, with an emphasis on the importance of proper credit application for grant compliance. We will also review existing internal controls over grant management to identify and address any additional weaknesses. Additionally, we will work with TWC to resolve the reimbursement of $137,893 and ensure the appropriate credit is applied. Responsible officer: Chief Financial Officer, Alisa Ealy. Estimated completion date: September 30, 2024
View Audit 315200 Questioned Costs: $1
Management’s Response: Management will implement procedures to ensure that timely and accurate financial information is prepared in accordance with generally accepted accounting principles.
Management’s Response: Management will implement procedures to ensure that timely and accurate financial information is prepared in accordance with generally accepted accounting principles.
Management’s Response: Management has revised MNM’s segregation of duties and compensating controls surrounding financial reporting and has implemented the appropriate safeguards to ensure they are adhered to. MNM has developed written procedures and incorporated the following controls surrounding...
Management’s Response: Management has revised MNM’s segregation of duties and compensating controls surrounding financial reporting and has implemented the appropriate safeguards to ensure they are adhered to. MNM has developed written procedures and incorporated the following controls surrounding cash receipts and disbursements. • Maintenance of a daily log of cash receipts and disbursements • Restrict access to cash and checks to authorized individuals • Maintain adequate supporting documentation for all cash receipts and disbursements • Recount of daily cash receipts by more than one individual for accuracy • Make deposits and post to accounts receivable on a regular basis at a minimum weekly • Safeguard cash and checks for deposits in a secure location (i.e. safe or lockbox) • Cash receipts are verified to daily log and supporting documentation as part of bank reconciliation process • Cash receipt and disbursement detail to be reviewed by Executive Director
The Township will establish controls to determine federal revenues and if an audit under the Uniform Guidance is required. The anticipated completion date is June 30, 2024.
The Township will establish controls to determine federal revenues and if an audit under the Uniform Guidance is required. The anticipated completion date is June 30, 2024.
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