Corrective Action Plans

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Views of responsible o􀆯icials and planned corrective actions: There is no disagreement with the audit finding. Action taken in response to finding: PCA America will add suspension and debarment policies and procedures to the organization’s grants compliance manual. It will ensure vendor verification...
Views of responsible o􀆯icials and planned corrective actions: There is no disagreement with the audit finding. Action taken in response to finding: PCA America will add suspension and debarment policies and procedures to the organization’s grants compliance manual. It will ensure vendor verification for suspension and debarment prior to entering into a transaction/contract. With annual review of suspension and debarment throughout the program lifecycle. Name(s) of the contact person(s) responsible for corrective action: Dr. Bart Klika, Chie_x001F_ Research O􀆯icer Planned completion date for corrective action plan: The corrective action plan detailed above is being implemented by August 31, 2026.
Significant Deficiency - Suspended or Debarred Covered Transactions Corrective Action Plan: The Village administration team will collaborate with the engineering team and funding source to establish required written and documented procedures to ensure that contractors and sub-contractors working on ...
Significant Deficiency - Suspended or Debarred Covered Transactions Corrective Action Plan: The Village administration team will collaborate with the engineering team and funding source to establish required written and documented procedures to ensure that contractors and sub-contractors working on projects within the Village are not suspended or debarred. Responsible Party: Thomas J. Ostrander, Village Manager Proposed Completion Date: February 28, 2027
Management is in the process of drafting an updated procurement policy to comply with the new requirements of the Uniform Guidance.
Management is in the process of drafting an updated procurement policy to comply with the new requirements of the Uniform Guidance.
2026-001 Suspension and Debarment Corrective action planned: To ensure full compliance with federal documentation standards moving forward: 1. Formalized Onboarding Control: In May 2026, the Organization updated its standard New Vendor Form to include a mandatory verification checkbox and documented...
2026-001 Suspension and Debarment Corrective action planned: To ensure full compliance with federal documentation standards moving forward: 1. Formalized Onboarding Control: In May 2026, the Organization updated its standard New Vendor Form to include a mandatory verification checkbox and documented sign-off confirming SAM.gov exclusion checks are completed prior to vendor setup or contract execution. 2. Existing Vendor Audit: Management is currently conducting a comprehensive review to document and retain SAM.gov exclusion verifications for all active vendors. Anticipated completion date: May 2026 Contact person responsible for corrective action: Scott Matlock
Audit Finding 2026-001: During our testing of tenant security deposits, it was discovered that the balance in the bank account maintained for tenant security deposits was insufficient to cover the liability for tenant security deposits payable. -Response: There was a temporary depletion of funds in ...
Audit Finding 2026-001: During our testing of tenant security deposits, it was discovered that the balance in the bank account maintained for tenant security deposits was insufficient to cover the liability for tenant security deposits payable. -Response: There was a temporary depletion of funds in the operating account, since they paid the amount of their insurance deductible to a vendor for urgent water damage remediation after an apartment fire on the property. This resulted in the operating account not having sufficient funds to cover the next payroll. Hence a temporary transfer of funds was made from the tenant security deposits account. Management is aware that the Regulatory Agreement stipulates maintaining sufficient funds in a separate tenant security deposit account to cover the liability for tenant security deposits payable and have since replenished the balance in the tenant security deposit account. The $1,900 was deposited back into the Security Deposit account on 08/17/2026. - Responsible Party: Linda G. Holder - Executive Director - Houston Housing Management Corporation - 1418 Preston St. - Houston, TX 77002
2026-001 Public Housing Capital Fund Recommendation: The Commission should implement policies and procedures to ensure all federal compliances are followed pertaining to Procurement, Suspension and Debarment. Action Taken: Management will implement policies and procedures to ensure the Commission is...
2026-001 Public Housing Capital Fund Recommendation: The Commission should implement policies and procedures to ensure all federal compliances are followed pertaining to Procurement, Suspension and Debarment. Action Taken: Management will implement policies and procedures to ensure the Commission is in compliance with all grant requirements pertaining to the Public Housing Capital Grant. Anticipated Completion Date of Action: October 31, 2026
This finding is due to the Village not having control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Subsequently, the Village’s engineer has searched the state procurement office webpage to check if any vendor for a federal project i...
This finding is due to the Village not having control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Subsequently, the Village’s engineer has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, the Village will have controls in place to ensure that vendors are not debarred or suspended from federal funding awards. The person responsible for the corrective action is the Village President. The anticipated completion date of the corrective action plan is before the end of the 2027 fiscal year. The plan for adherence is the Council will review implement controls to ensure that vendors are not suspended, debarred, or otherwise excluded.
This finding is due to the Village not having formal written policies in place required by Uniform Guidance. The Village is aware that these policies are required and will adopt all necessary policies. The Village does not believe that there were any actual nonallowable costs or transactions because...
This finding is due to the Village not having formal written policies in place required by Uniform Guidance. The Village is aware that these policies are required and will adopt all necessary policies. The Village does not believe that there were any actual nonallowable costs or transactions because of the lack of written policies as required by Uniform Guidance. The Village will adopt all necessary policies to be in compliance. The person responsible for the corrective action is the Village President. The anticipated completion date of the corrective action plan is before the end of the 2027 fiscal year. The plan for adherence is the Council will review all proposed policies and adopt them, the Council will also monitor any changes to policy requirements to ensure that they are in compliance in the future.
Federal Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No. 10.557 & Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization update its procurement policy to be in lin...
Federal Program: Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) Assistance Listing No. 10.557 & Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization update its procurement policy to be in line with the federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will update the Procurement and Purchasing Policy and Procedure to include a Small and Micro-Purchase Threshold and the BABA requirements. The Organization will have this policy and procedure update completed by July 13, 2026.
Statement of Condition 2026-001 (Assistance Listing 14.155): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended January 31, 2026. Recommendation: Management should notify the lender of the new reserve for replacement deposit amount and make an ad...
Statement of Condition 2026-001 (Assistance Listing 14.155): The Corporation did not make all of the HUD required reserve for replacement deposits for the year ended January 31, 2026. Recommendation: Management should notify the lender of the new reserve for replacement deposit amount and make an additional $565 deposit to the reserve for replacements fund on the next billing. Management Response: Agree. Management has notified the lender of the new required deposit and will make an additional $565 deposit to the reserve for replacements fund on the next billing.
Noncompliant Buy America Procurements - Transit - MDT - The Montana Department of Transportation is strengthening internal controls and ensuring full compliance with federal requirements for procuring public transit vehicles. The Transit Section and the Procurement Unit are jointly developing compre...
Noncompliant Buy America Procurements - Transit - MDT - The Montana Department of Transportation is strengthening internal controls and ensuring full compliance with federal requirements for procuring public transit vehicles. The Transit Section and the Procurement Unit are jointly developing comprehensive procedures that clearly define roles and responsibilities, update procurement checklists, and establish a centralized location for maintaining complete procurement files. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026
Noncompliant Timely Reimbursement Controls - O&M - DMA - The Montana Department of Military Affairs partially concurs with the finding. The department recognizes the need to submit reimbursement requests timely and has implemented improved tracking procedures and a regular reimbursement‑request proc...
Noncompliant Timely Reimbursement Controls - O&M - DMA - The Montana Department of Military Affairs partially concurs with the finding. The department recognizes the need to submit reimbursement requests timely and has implemented improved tracking procedures and a regular reimbursement‑request process, generally on a bi‑weekly or monthly basis, to support timely submission of SF‑270s. However, the department cannot submit reimbursement requests until the applicable federal funding modification has been approved and funding has been allocated by the National Guard; therefore, delays attributable to pending federal funding availability are outside the department’s control. The department will continue to track expenditures and reimbursement due dates by award, monitor the status of funding modifications, submit reimbursement requests promptly when funding becomes available, and document the reason for any reimbursement request submitted outside the required timeframe. The department will also consult with the United States Property and Fiscal Office to identify whether alternative processes are available to allow reimbursement requests to be submitted without waiting for completion of a funding modification. Management will review outstanding reimbursement requests and documented exceptions regularly to ensure timely follow‑up. Responsible Party - Janae Brower, Chief Financial Officer, Montana Department of Military Affairs Target Implementation Date - 11/30/2026
Inadequate Procurement Documentation - HPC - MDT - The Montana Department of Transportation has developed a tracking spreadsheet for independent cost estimates and will continue to provide reminders and training through 2026. The department will update its procedures to ensure documentation for susp...
Inadequate Procurement Documentation - HPC - MDT - The Montana Department of Transportation has developed a tracking spreadsheet for independent cost estimates and will continue to provide reminders and training through 2026. The department will update its procedures to ensure documentation for suspension and debarment checks and cost estimates is retained in consultant files. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Dustin Rouse, Chief Engineer, Montana Department of Transportation Target Implementation Date - 12/31/2026
Inadequate Suspension and Debarment Verifications - Transit - MDT - The Montana Department of Transportation concurs with the finding. A. The Transit Section and Procurement Unit are jointly developing comprehensive procedures that clearly define roles and responsibilities, update procurement checkl...
Inadequate Suspension and Debarment Verifications - Transit - MDT - The Montana Department of Transportation concurs with the finding. A. The Transit Section and Procurement Unit are jointly developing comprehensive procedures that clearly define roles and responsibilities, update procurement checklists, and establish a centralized location for maintaining complete procurement files. These updated procedures will be completed by the end of calendar year 2026. B. The Procurement Unit and the Legal Office began working together in July 2026 to review all templates, clauses, and federal requirements. This review will be ongoing to ensure compliance with all state and federal regulations. Responsible Party - Kimberly Doherty, Accounting Systems Supervisor, Montana Department of Transportation Target Implementation Date - 12/31/2026
Inadequate Subrecipient Monitoring Controls - ELC - DPHHS - The Montana Department of Public Health and Human Services has implemented a new risk-assessment template and created additional tools to document subrecipient monitoring activities in state fiscal year 2025. The department has also updated...
Inadequate Subrecipient Monitoring Controls - ELC - DPHHS - The Montana Department of Public Health and Human Services has implemented a new risk-assessment template and created additional tools to document subrecipient monitoring activities in state fiscal year 2025. The department has also updated its policies and procedures. The department will continue to review and enhance its subaward processes to ensure full compliance. Responsible Party - Brenda Crawford, Internal Control and Compliance Officer, Montana Department of Public Health and Human Services Target Implementation Date - 6/30/2025
Inadequate Suspension and Debarment Verifications - SLFRF, ELC - DOA - The Montana Department of Administration Architecture and Engineering Division will incorporate the requirements of Title 2 Code of Federal Regulations sections 180.300(b) and 180.300(c) into its control processes for architectur...
Inadequate Suspension and Debarment Verifications - SLFRF, ELC - DOA - The Montana Department of Administration Architecture and Engineering Division will incorporate the requirements of Title 2 Code of Federal Regulations sections 180.300(b) and 180.300(c) into its control processes for architecture and engineering firm procurements. This will align these controls with those used for construction contract procurements and will include verification of application submissions and verification of contractual obligations. The division considers the risk associated with this issue to be extremely low because no Montana architecture or engineering firm appears as debarred or suspended in the federal System for Award Management database. Responsible Party - Russell Katherman, Administrator of Architecture and Engineering , Montana Long Range Building, Montana Department of Administration Target Implementation Date - 8/26/2026
Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. This grant is closed. For all future reporting under the Federal Funding Accountability and Transparency Act, the Office will update internal guidance to align with federal regulations and ...
Noncompliant FFATA Reports - ESSER - OPI - The Montana Office of Public Instruction concurs with this finding. This grant is closed. For all future reporting under the Federal Funding Accountability and Transparency Act, the Office will update internal guidance to align with federal regulations and federal oversight requirements. The Office will ensure that required documentation is maintained and that reconciliations verify values in USAspending and SAM. Responsible Party - April Grady, Chief Financial Officer, Montana Office of Public Instruction Target Implementation Date - 12/31/2026
Inadequate Supporting Documentation - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division partially concurs. The Division validated the reviewed project costs through its internal review and through additional Federal Emergency Management Agen...
Inadequate Supporting Documentation - Disaster Grants - DMA - The Montana Department of Military Affairs, Disaster and Emergency Services Division partially concurs. The Division validated the reviewed project costs through its internal review and through additional Federal Emergency Management Agency (FEMA) processes, including the Validate As You Go procedure, and determined the costs to be allowable. The division acknowledges the cited federal compliance criteria and recognizes the opportunity to strengthen the consistency, accessibility, and retention of project documentation. To enhance existing processes, the division has implemented a standardized project file structure that clearly identifies the location of supporting documentation and ensures official grant files are complete rather than relying solely on documentation stored within federal systems. This process is being applied to the disasters that occurred in December 2025 and were federally declared in April 2026. The division will continue to evaluate and refine its documentation practices while maintaining appropriate controls, reviews, validations, payments, and closeout procedures for federally funded projects. Responsible Party - Janae Brower, Chief Financial Officer, Montana Department of Military Affairs Target Implementation Date - 10/31/2026
Noncompliant Procurement Delegation - R&D - DOA, MUS - The Montana Department of Administration State Procurement Services Division is centralizing procurement staff and processes across all agencies to improve consistency in laws, rules, procedures, and policies when agencies procure products and s...
Noncompliant Procurement Delegation - R&D - DOA, MUS - The Montana Department of Administration State Procurement Services Division is centralizing procurement staff and processes across all agencies to improve consistency in laws, rules, procedures, and policies when agencies procure products and services. To modernize and integrate procurement in the Statewide Accounting, Budgeting, and Human Resources System and to strengthen oversight and payment of contractual obligations, the department is soliciting a new procurement system. All agencies will be required to document contract management activities in the new system. Compliance reviews will be conducted by a Department of Administration internal auditor beginning in fiscal year 2027 and will be prioritized according to risk assessment scores, auditor workload, and agency capacity. The department has improved compliance for sole‑source grants by appointing new committee members, and annual training for policies and procedures will be revised as needed. The State Procurement Services Division will develop and distribute a standard form for declaring exigencies to ensure agencies document all information required by statute, rule, and policy. The division is also preparing changes to administrative rules to clarify definitions and help agencies distinguish between exigent purchases and other expedited purchasing methods. The University of Montana - Missoula will continue working with the Montana Office of the Commissioner of Higher Education, which serves as the university’s liaison with the Department of Administration, to ensure written delegation agreements are executed and maintained in a timely manner. Montana State University - Bozeman concurs with the finding and agrees there are no questioned costs associated with the condition. The university will continue to work with the Montana University System office to receive an executed delegation of authority. A draft delegation was received from the Department of Administration in May 2026, and the university system provided feedback. As of the date of the audit report, the university has not received an update from the department. Responsible Party - Molly McLoughlin, Administrator, Montana Department of Administration Bob Hlynosky, Director of Procurement, University of Montana - Missoula Brian O'Connor, Chief Procurement Officer, Montana Office of the Commissioner of Higher Education Target Implementation Date - 6/30/2027
Suspesion and Debarment Recommendation: The City should perform SAM checks for all vendors or contracors prior to entering into covered transactions and retain docuentation of these processes. Management Response: Management concurs with the finding. As part of the federal grant award process, City ...
Suspesion and Debarment Recommendation: The City should perform SAM checks for all vendors or contracors prior to entering into covered transactions and retain docuentation of these processes. Management Response: Management concurs with the finding. As part of the federal grant award process, City Management will ensure SAM checks are performed prior to contracting with vendors. Anticipated Completion Date: Septembe 30, 2026 Responsibnle Party: Gina Sherman, Management Analyst
Management concurs with the finding above and recognizes the importance of maintaining compliance with federal award requirements. To address the matter, management will implement the following corrective actions: Update procurement policies and procedures to properly document suspension and debarme...
Management concurs with the finding above and recognizes the importance of maintaining compliance with federal award requirements. To address the matter, management will implement the following corrective actions: Update procurement policies and procedures to properly document suspension and debarment verification through SAM.gov for all applicable vendors and contracts receiving federal funds. If vendors or contractors are not verifiable through SAM.gov, additional procedures will be performed to ensure vendors and contractors are not suspended or debarred. Implement a standardized checklist to ensure all compliance requirements are met Management will perform semi-annual monitoring of federal award transactions and compliance requirements throughout the year Management believes these actions will adequately address the condition noted and reduce the likelihood of recurrence. The Chief Financial Officer is responsible for implementing and monitoring these corrective actions, which are expected to be fully implemented by December 31, 2026
City Response and Corrective Action Plan: Management agrees with the recommendation. Moving forward the City will check vendors in SAM.gov before awarding contracts and will recheck them at least once a year for multi year agreements. Each check will be recorded in a central log, and supporting docu...
City Response and Corrective Action Plan: Management agrees with the recommendation. Moving forward the City will check vendors in SAM.gov before awarding contracts and will recheck them at least once a year for multi year agreements. Each check will be recorded in a central log, and supporting documentation will be kept in our contract and grant files. When needed, the City will collect a vendor certification at the time of award and review compliance annually. The City expects full implementation of these procedures within 60 days, with ongoing monitoring after that.
Management's Response: The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure tha...
Management's Response: The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure that they are in compliance with Uniform Guidance. Until it is written, procurement standards will be reviewed and followed. Completion Date: Discussion is ongoing regarding the plan.
Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h). Th...
Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h). The Organization concurs with the prior year (2024-003) and current year renumbered recommendation (2025-003),and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Financial Policies – May 2025. Completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Initiated use of MTPF, and process implementation of Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal. C. HRSA Policies – July 2025. Developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. Informed the Board about the progress of the Organization’s policy framework, including the above policies. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work by the Organization: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the application of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). E. Updated procurement processes for emergency disaster recovery and support of community needs, including MTF documentation. Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date Finding No. 2025-003: Procurement Policies Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.
Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted ...
Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted written standards of conduct governing actual, potential, and perceived conflicts of interest involving employees and governing body members who participate in the selection, award, or administration of contracts supported by federal funds. To address the finding, the Town will develop a written conflict of interest policy that complies with applicable federal requirements, including 2 CFR § 200.318(c)(1). At a minimum, the policy will: 1. Define actual, potential, and perceived conflicts of interest and prohibited conduct; 2. Identify the employees, officials, and governing body members subject to the policy; 3. Require prompt written disclosure of relevant financial interests and other potential conflicts; 4. Establish procedures for reviewing, documenting, and resolving disclosed conflicts; 5. Require affected individuals to refrain from participating in matters in which a conflict exists; 6. Establish appropriate disciplinary or corrective measures for violations; 7. Require periodic written conflict-of-interest acknowledgments and disclosures; and 8. Address the retention of acknowledgments, disclosures, determinations, and related compliance documentation. The proposed policy will be presented to the Town Council for formal consideration and adoption. Following adoption, the Town will distribute the policy to applicable employees and governing body members and provide appropriate training or written guidance regarding their responsibilities. The Town will retain completed acknowledgments, disclosures, and documentation of any conflict determinations in accordance with its applicable record-retention requirements. Management will periodically review the policy and related procedures to help ensure continued compliance with federal award requirements. Responsible Official Town Administrator Anticipated Completion Date December 31, 2026. Current Status The Town currently does not have a written conflict of interest policy.
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