Corrective Action Plans

Finding 499236 (2023-001)

Significant Deficiency 2023

Home Forward

OR

Questioned Costs Allowable Costs / Cost Principles

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that payroll transactions charged to the program are supported. Explanation of disagreement with audit finding: There is no disagreement with ...

Moving to Work Demonstration Program – Assistance Listing No. 14.881 Recommendation: We recommend that Home Forward reviews the controls in place to ensure that payroll transactions charged to the program are supported. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Updated settings in payroll system so timesheet codes are available for selection only by the employees who should be using them. Added additional review of timesheet totals for certain codes. Will provide reminders and additional resources to supervisors on reviewing timesheets. Name(s) of the contact person(s) responsible for corrective action: Casey Little, Assistant Controller Planned completion date for corrective action plan: 8/31/2024

View Audit 322033 Questioned Costs: $1

Finding 499197 (2023-005)

Material Weakness 2023

Shatterproof A Nonprofit Corporation

CT

Questioned Costs Allowable Costs / Cost Principles

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent. The timesheets are then reviewed and approved by the program director or a direct supervisor. Anticipated completion date: Implemented June 2024

View Audit 321990 Questioned Costs: $1

Finding 499190 (2023-004)

Material Weakness 2023

Shatterproof A Nonprofit Corporation

CT

Questioned Costs Allowable Costs / Cost Principles

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent...

Name of Auditee’s Contact Person Responsible for Corrective Action: Molly Gravholt Corrective Action Planned: Management has implemented additional time tracking on a weekly basis for all employees who work on federal contracts. Employees must track and allocate their time based on actual time spent. The timesheets are then reviewed and approved by the program director or a direct supervisor. Anticipated completion date: Implemented June 2024

View Audit 321990 Questioned Costs: $1

Finding 499188 (2023-003)

None 2023

New York City Housing Authority

NY

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Number 2023-003 PROCUREMENT AND SUSPENSION AND DEBARMENT – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Procurement And Suspension and Debarment - Non-federal en...

Finding Number 2023-003 PROCUREMENT AND SUSPENSION AND DEBARMENT – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Procurement And Suspension and Debarment - Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Non-federal entities receiving contracts from the federal government are required to comply with the contract clause at FAR 52.209-6 before entering into a subcontract that will exceed $30,000, other than a subcontract for a commercially available off-the-shelf item. Condition/Context The Authority received funding from the Public and Indian Housing Program. The Authority has procurement and suspension and Debarment policies. Of the sixty (60) vendor files selected for testing, we noted 3 vendor’s suspension and Debarment documentation were not provided by the Authority. The Authority did review suspension and Debarment status in SAM.GOV for the samples in question, which had no documentation of suspension and Debarment and all vendors were active and no suspensions noted. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program’s suspension and Debarment policies to ensure that all vendors are not suspended or debarred. Corrective Action Plan In June 2022, NYCHA implemented the Dun & Bradstreet (D&B) Supplier Risk Management tool for development/program units to check federal debarment status of micro vendors. In addition, in February 2023, NYCHA also implemented the self-certification debarment form for micro vendors. Currently, all micro vendors who wish to be placed on the Micro Prequalification List (Micro PQL) for Responsibility to be eligible for a micro award undergo an integrity/responsibility review by a centralized vendor responsibility department prior to being placed on the Micro PQL. This review includes debarment checks among many other integrity assessments. The Micro PQL will go in effect on September 30, 2024. Given that NYCHA’s micro spend comprises less than 4% of total spend in 2021 through 2023 (and approximately 1.1% as of Q3 of 2024), concomitant with the fact that NYCHA has already implemented corrective actions to ensure all vendors are checked for debarments, NYCHA believes the risk of this deficiency to be insignificant. Action Date Already implemented Final Implementation Already implemented Name And Phone Number Of Person Responsible For Implementation Sergio Paneque Chief Procurement Officer 212-306-3528 Sergio.paneque@nycha.nyc.gov

View Audit 321980 Questioned Costs: $1

Finding 499187 (2023-002)

None 2023

New York City Housing Authority

NY

Questioned Costs HUD Housing Programs Eligibility

Finding Number 2023-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms th...

Finding Number 2023-002 ELIGIBILITY – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Eligibility for Individuals - Most PHAs devise their own application forms that are filled out by the PHA staff during an interview with the tenant. The head of household signs (a) a certification that the information provided to the PHA is correct; (b) one or more release forms to allow the PHA to get information from third parties; (c) a federally prescribed general release form for employment information; and (d) a privacy notice. Under some circumstances, other members of the family may be required to sign these forms (24 CFR sections 5.212, 5.230, and 5.601 through 5.615). Condition/Context The Authority received funding from the HUD. The Public and Indian Housing program is to provide and operate cost effective, decent, safe, and affordable dwellings for lower income families through an authorized local PHA. Of the sixty (60) case files selected for testing in which 540 pieces of audit evidence (eligibility forms as noted in the Criteria section above) were requested to be provided: Eight eligibility forms were not provided (five missing application forms, one missing certifications information provided to the PHA forms and two missing Release form). These forms are required documentation to be maintained in the case files to support eligibility for Public and Indian Housing Program. Therefore, we were not able to determine if the eligible participants met all the eligibility criteria. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program case files to ensure that all eligibility forms are received, reviewed, and maintained in the case files to support the determination of eligibility. Corrective Action Plan In January 2011, NYCHA implemented the Siebel Customer Relationship Management (CRM) system, which included digital file storage and an online application process, which replaced our previous paper application process. Any applications in process from that date onward were subject to document scanning and documentation was stored digitally. Any applications processed prior to this date were kept in a paper format and stored at the development, where the applicant was certified or where the tenant resides. If a tenant family transferred to another development, the physical tenant folder and documents were sent to their new location. In June 2020, NYCHA sought to digitize all tenant folders; however, the cost of the project was determined to be prohibitive so the goal of digitizing the tenant folders was not realized. Any documents damaged or lost prior to 2011 cannot be recovered, including those impacted by Hurricane Sandy. Action Date September 6,2024 Final Implementation September 6,2024 Name And Phone Number Of Person Responsible for Implementation Sylvia Aude Senior Vice president Office of the Senior Vice President for Public Housing Operations Tenancy Administration +1-212-306-3921

View Audit 321980 Questioned Costs: $1

Finding 499165 (2023-001)

Significant Deficiency 2023

National Casa Association

WA

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.300 § 200.306 § 200.308 § 200.309 § 200.403

Responsible: Thomas Hoover, Chief Financial Officer Corrective Actions: Updated Finance policies: Specify that documentation of review and approval of costs charged to federal grants be maintained and that costs are recorded in the appropriate grant funding period. Completion Date: July 10, 2024...

Responsible: Thomas Hoover, Chief Financial Officer Corrective Actions: Updated Finance policies: Specify that documentation of review and approval of costs charged to federal grants be maintained and that costs are recorded in the appropriate grant funding period. Completion Date: July 10, 2024. Explanation: Policies have been in place over the coding of costs allocated to federal grants in compliance with CFR 200 and were enhanced in 2023 in response to an OJJDP/OCFO recommendation. Review and approval of costs after being approved by an authorized signer takes place in multiple steps and concludes with preparation of reimbursements and financial grant reports (FFR). In order to further demonstrate compliance as recommended, Management updated Finance policies to capture the documentation and approval of cost allocation methods and coding of costs to federal grants and maintenance of such documentation of Supervisory review and approval. Policies already in place specified that supporting and source documentation be maintained for at least 3 years, in compliance with federal grant requirements. In addition, the updated policy specifies that grant costs be recorded in the appropriate grant funding (fiscal) period. Four transactions sampled were partially or fully recorded in the incorrect funding (fiscal) period, though they were within the grant period.

View Audit 321944 Questioned Costs: $1

Finding 499112 (2023-002)

Material Weakness 2023

Morrison County

MN

Questioned Costs Reporting Material Weakness § 200.303

Finding Number: 2023-002 Finding Title: Reporting Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Shannon Coyle, County Auditor-Treasurer Corrective Action Planned: Morrison County management is aware that the ann...

Finding Number: 2023-002 Finding Title: Reporting Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Shannon Coyle, County Auditor-Treasurer Corrective Action Planned: Morrison County management is aware that the annual Project and Expenditure Report submitted for Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) to the U.S. Treasury was done so incorrectly. The County has reviewed the U.S. Department of the Treasury guidance and form instructions to ensure it is correctly reporting its CSLFRF activity going forward. Anticipated Completion Date: The correction will be made on the Annual Project and Expenditure Report due in April 2024, for the reporting period ending March 31, 2024.

View Audit 321900 Questioned Costs: $1

Finding 499092 (2023-002)

Material Weakness 2023

Chisago County

MN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.403

Finding Number: 2023-002 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Kristin Waddell Corrective Action Planned: Extensive rese...

Finding Number: 2023-002 Finding Title: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Kristin Waddell Corrective Action Planned: Extensive research was done on this topic and position of the County is that cities and townships are non-entitlement units (NEUs) who report to the Treasury directly. SLFRF Compliance and Reporting Guidance published by The Department of the Treasury states that NEUs are not subrecipients under the SLFRF program; they are SLFRF recipients that report directly to the Treasury. Recipients of the County’s ARPA Broadband grants: -provided the specific unserved or underserved areas located within the County where therequested ARPA funds would be used to deliver high-speed, reliable, and affordable internet(typically accompanied by the consultant report coordinating the construction) on their grantapplications to the County Board; and -have certified they are complying with “all federal, state, and local laws and all requirementsand published guidance set forth regarding the usage of any and all monies appropriated underthe ARPA” in their signed grant agreements with the County; However, beginning in 2024 the County will collect itemized support for the expenditures incurred related to the ARPA Broadband Grant Program. Anticipated Completion Date: Immediately

View Audit 321886 Questioned Costs: $1

Finding 499011 (2023-001)

Material Weakness 2023

County of Onondaga, New York

NY

Questioned Costs Student Financial Aid Eligibility

The County agrees that reinforcing existing policies and procedures to require caseworkers to cite source documents supporting a child’s disability when determining initial Title IV-E eligibility and continuation of eligibility is necessary and will continue to do so.

View Audit 321795 Questioned Costs: $1

Finding 499006 (2023-001)

Significant Deficiency 2023

Thurston County Economic Development Council

WA

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency § 200.430

Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Recommendation: JSP recommends that the program manager and a member of the finance committee knowledge about 2 CFR 200.430(i)(1) review the executive director costs char...

Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Treasury ALN: 21.027 Recommendation: JSP recommends that the program manager and a member of the finance committee knowledge about 2 CFR 200.430(i)(1) review the executive director costs charged to the Coronavirus State and Local Recovery Funds program. There is no disagreement with the audit finding. The corrective action was immediately implemented when it was identified in September of 2023, conducted over the period ending December 31, 2023. A review of the timesheets from October – December of 2023 reflects that this had been addressed. Action planned in response to finding: Treasurer of the Board of Directors and federal program manager shall review the executive director’s cost allocations within timesheets. Names of the contact person(s) responsible for corrective action: Michael Cade (EDC Executive Director), Michael McGauly (Board of Directors Treasurer), and Matt Stacey (EDC Finance Manager). Planned completion date for corrective action plan: September 2023

View Audit 321792 Questioned Costs: $1

Finding 498954 (2023-003)

Material Weakness 2023

City of Bluffton

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Bri Lau...

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Any transfers that happen, will be reviewed, and will have better documentation of what claims made the transfer happen and make sure supporting documentation is attached to the claim to prove the use of the transferred funds. Anticipated Completion Date: Immediately

View Audit 321762 Questioned Costs: $1

Finding 498826 (2023-005)

Material Weakness 2023

Winner Regional Healthcare Center

SD

Questioned Costs Allowable Costs / Cost Principles Material Weakness § 200.303

Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster FFAL #10.766 Finding Summary: During review of expenditure listings, three expenditures were claimed under the USDA Grant Program after the Center received an advancement of U...

Federal Agency Name: United States Department of Agriculture Program Name: Community Facilities Loans and Grants Cluster FFAL #10.766 Finding Summary: During review of expenditure listings, three expenditures were claimed under the USDA Grant Program after the Center received an advancement of USDA loan funds for those same three expenditures. We did not have a formal review process in place over the USDA Grant expenditure listing and the USDA loan advancement to ensure double dipping was not occurring. Responsible Individuals: Amanda Soesbe, Chief Finance Officer Corrective Action Plan: Due to staffing shortages there was no review of the grant applications to check for duplicate coverage. A Controller was hired November 20, 2023 to allow for reviews of documents and spreadsheets prior to submission. Anticipated Completion Date: 2025

View Audit 321577 Questioned Costs: $1

Finding 498782 (2023-101)

None 2023

Covenant Health, Inc.

MA

Questioned Costs Cash Management Allowable Costs / Cost Principles

Condition: During compliance testing, it was identified that an employee's wages were being charged to the grant after the employee was terminated. Corrective Action Taken or Planned: Management noted there was turnover in fiscal year 2023 which led to lack of some reviews. Controls have been pu...

Condition: During compliance testing, it was identified that an employee's wages were being charged to the grant after the employee was terminated. Corrective Action Taken or Planned: Management noted there was turnover in fiscal year 2023 which led to lack of some reviews. Controls have been put in place to ensure all worksheets are viewed for accuracy by the CFO prior to requesting drawdown amount. Name(s) of Contact Person(s) Responsible for Corrective Action Coleen Elias, Chief Executive Officer, Community Clinical Services. Anticipated Completion Date: Controls have been implemented as of the date of the audit report.

View Audit 321492 Questioned Costs: $1

Finding 498736 (2023-001)

Significant Deficiency 2023

Converge, Inc.

MS

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Management agrees with the finding and has already implemented approval processes prior to purchasing. We have also implemented itemized receipts required for all purchase in our expense management software.

View Audit 321411 Questioned Costs: $1

Finding 498678 (2023-002)

Material Weakness 2023

Topeka Housing Authority

KS

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs § 200.403 § 200.405

The Authority will limit advancing funds from the Section 8 Housing Choice Voucher and Emergency Housing Voucher Programs, to allowable Fees only. The Authority’s Executive Director, Trey George, has assumed the responsibility of executing this corrective action as of November 1, 2024.

View Audit 321393 Questioned Costs: $1

Finding 498669 (2023-001)

Significant Deficiency 2023

Pinellas County Housing Authority

FL

Questioned Costs HUD Housing Programs Significant Deficiency

Allowability — Landlord Overpayments Housing Voucher Cluster Significant Deficiency in Internal Controls Other Matter to Reported Under the Uniform Control Condition: The Authority made numerous overpayments in HAP to landlords starting in the month of October2023. A variance in HAP disbursements wa...

Allowability — Landlord Overpayments Housing Voucher Cluster Significant Deficiency in Internal Controls Other Matter to Reported Under the Uniform Control Condition: The Authority made numerous overpayments in HAP to landlords starting in the month of October2023. A variance in HAP disbursements was noted by the Department of Housing and Urban Development (HUD), and upon further investigation by management it was determined that the overpayment to landlords was not caught by staff when the original disbursements were made. Auditor Recommendations: The Authority should work on recapturing overpaid funds from landlords that have current tenant agreements. The Authority should also monitor internal controls in place with the new software to make sure the accounting software is functioning properly. Action Taken: Upon discovering the overpayments to the landlords, HCV department promptly issued letters informing them of the excess Housing Assistance Payment (HAP) received. The letter instructed the landlords to either repay the overpaid amounts or have them recouped from future HAP payments. To date $142,824, has been successfully collected. Cherly LaRock is responsible for overseeing the collection process, and a monthly report on the status of these overpayments is submitted to the Board. Additionally, the data transferred from HAB to Yardi was thoroughly reviewed and any issues that were identified during review were promptly corrected. Finally, a Yardi consultant was engaged to assist in the evaluating the PCI-IA HAP process within Yardi. With the consultant's assistance, new procedures and controls have been established to streamline HAP payments and prevent future overpayments to landlords.

View Audit 321386 Questioned Costs: $1

Finding 498668 (2023-002)

Material Weakness 2023

Mahnomen County

MN

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Contact Person – Bruce Starkey, County Administrator Corrective Action Plan – The County will review procedures to ensure expenditures charged to federal programs are supported with actual expenditures. Reports will undergo a review prior to submission. Completion Date – 9/30/2024

View Audit 321383 Questioned Costs: $1

Finding 498507 (2023-002)

Material Weakness 2023

Iswa Development Corporation

SC

Questioned Costs

The Corporation concurs with the findings and processes for approval and payment authorization have been reviewed and revised. New board members and a new Interim Director are now in place. Segregation of duties and responsibilities will ensure proper review and approval processes are in place goi...

The Corporation concurs with the findings and processes for approval and payment authorization have been reviewed and revised. New board members and a new Interim Director are now in place. Segregation of duties and responsibilities will ensure proper review and approval processes are in place going forward to ensure representation of board minutes, as well as to ensure substantiation of any modifications to original board direction.

View Audit 321235 Questioned Costs: $1

Finding 498506 (2023-001)

Significant Deficiency 2023

Iswa Development Corporation

SC

Questioned Costs

The Corporation concurs with the findings and has implemented internal controls supplorting application approvals and fund disbursment authorization. Payment processes have been reviewed and revised. New board members and a new Interim Director are now in place to ensure proper review of all appli...

The Corporation concurs with the findings and has implemented internal controls supplorting application approvals and fund disbursment authorization. Payment processes have been reviewed and revised. New board members and a new Interim Director are now in place to ensure proper review of all applications and disbursements. Enhancements to existing internal controls and processes representing best practices will be integrated to ensure compliance with NAHASDA policies and requirments.

View Audit 321235 Questioned Costs: $1

Finding 498486 (2023-001)

Significant Deficiency 2023

Enterprisekc

KS

Questioned Costs Allowable Costs / Cost Principles § 200.413 § 200.430

Corrective Action Plan 2023-001: Management will implement a comprehensive time tracking review process that also extends to reviewing time for employees that choose to work remotely and will ensure that time not allocated to the grant is not included in the costs allocated to the grant. Management ...

Corrective Action Plan 2023-001: Management will implement a comprehensive time tracking review process that also extends to reviewing time for employees that choose to work remotely and will ensure that time not allocated to the grant is not included in the costs allocated to the grant. Management will revise the fringe benefit rate that gets charged to the hourly rates to ensure that none of the costs included in the fringe benefits are also direct expenses billed to the grant. The unallowable costs will be redirected to other allowable grant costs in 2024. Anticipated Completion Date: September 2024 Contact Person: Jay Konomos, Pillar Leader

View Audit 321192 Questioned Costs: $1

Finding 498473 (2023-001)

Material Weakness 2023

Lapeer County

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.318 § 200.319 § 200.327

The Board acknowledges the finding related to procurement practices under Finding 2023-001. We recognize the importance of adhering to federal procurement requirements, specifically those outlined in 2 CFR 200.319(d), to ensure compliance and maintain the integrity of federal funds. Management will ...

The Board acknowledges the finding related to procurement practices under Finding 2023-001. We recognize the importance of adhering to federal procurement requirements, specifically those outlined in 2 CFR 200.319(d), to ensure compliance and maintain the integrity of federal funds. Management will review and update policies to ensure they align with federal regulations specified in 2 CFR 200.319(d) and will provide training to relevant personnel on federal procurement requirements.

View Audit 321176 Questioned Costs: $1

Finding 498466 (2023-001)

None 2023

Medical Debt Resolution, Inc.

NY

Questioned Costs Allowable Costs / Cost Principles

Finding Number: 2023-001 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Programs: United States Department of the Treasury ALN Number: 21.019 ALN Name: Coronavirus Relief Fund Contract Periods: August 9, 2022 – December 31, 2024 (County of Cook, Illinois); J...

Finding Number: 2023-001 Compliance Requirement: Activities Allowed or Unallowed; Allowable Costs/Cost Principles Programs: United States Department of the Treasury ALN Number: 21.019 ALN Name: Coronavirus Relief Fund Contract Periods: August 9, 2022 – December 31, 2024 (County of Cook, Illinois); June 16, 2023 – June 16, 2024 (City of New Orleans, Louisiana) Planned Corrective Action: In order to ensure that retroactive personnel costs are allocated to grants appropriately, the following measures are being implemented: 1. Effective October 1, 2024, Medical Debt Resolution, Inc. (the Organization) is transitioning to a common-date annual review including a common annual salary adjustment date for all personnel. This will ensure a timely administration of personnel compensation adjustments, thus eliminating the need for retroactive pay. 2. In the unlikely event of a retrospective pay need in the future, the Organization will develop and implement a new standard operating procedure for Allocation of Retrospective Pay which will provide guidelines for how to appropriately allocate the cost across funds if multiple periods are involved. 3. The Organization is thoroughly reviewing all retrospective payments made in 2023 and 2024 YTD and will be issuing an adjustment to all grants, as applicable, by October 31, 2024. Person Responsible: Vice President, Finance & Administration Expected Completion Date: October 31, 2024

View Audit 321164 Questioned Costs: $1

Finding 498458 (2023-007)

Material Weakness 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Questioned Costs Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Management’s response and corrective action is as follows: The Office of Community Development utilizes a loan service agency to manage, administer and oversee the funds for the loan program. Requests for loan forgiveness are submitted to the OCD by the loan service agency monthly for staff approv...

Management’s response and corrective action is as follows: The Office of Community Development utilizes a loan service agency to manage, administer and oversee the funds for the loan program. Requests for loan forgiveness are submitted to the OCD by the loan service agency monthly for staff approval. The OCD staff then reconciles this income monthly and submits the monthly report to the Finance Department for processing. Loan balances are not only altered by program income but also through loan forgiveness offered to low-to-moderate income residents. All loans are reviewed for forgiveness in compliance with the Code of Federal Regulations and are approved by the OCD before being executed by the Parish Attorney’s Office to provide multiple layers of review. Case files are maintained at the OCD and documentation of monthly reconciling has been provided along with an accounting ledger. The OCD is working to improve monthly reconciling templates to include incurred fees from the loan servicing agency as well as forgiveness events to provide an accurate gross revenue. Expected Implementation Date: June 2024 Contact person: Marlee Pittman Miller, Director, Mayor-President’s Office of Community Development

View Audit 321162 Questioned Costs: $1

Finding 498456 (2023-005)

Significant Deficiency 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.326

Management’s response and corrective action is as follows: Purchasing Department has implemented the following corrective actions to avoid this in the future: requisition checklist outlining guideline for compliance; creating standard operating procedure for purchase of vehicles for City-Parish Ag...

Management’s response and corrective action is as follows: Purchasing Department has implemented the following corrective actions to avoid this in the future: requisition checklist outlining guideline for compliance; creating standard operating procedure for purchase of vehicles for City-Parish Agencies; conduct routine departmental training; ensure that supervisor approvals prior to bid release. Expected Implementation Date: June 2024 Contact person: Paul Narcisse, Purchasing Director, Office of Purchasing

View Audit 321162 Questioned Costs: $1

Finding 498455 (2023-004)

Significant Deficiency 2023

City of Baton Rouge - Parish of East Baton Rouge

LA

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties § 200.522

Management’s response and corrective action is as follows: After reviewing the condition, cause, and effect of the presented Finding, the City-Parish finds it important to clarify that the duplicative charges were initially identified and documented as a self-reported finding. This discrepancy was...

Management’s response and corrective action is as follows: After reviewing the condition, cause, and effect of the presented Finding, the City-Parish finds it important to clarify that the duplicative charges were initially identified and documented as a self-reported finding. This discrepancy was discovered during the subrecipient monitoring component of this award and was promptly reported and reconciled prior to being presented as an audit finding. Upon identification of the duplicative charges, totaling approximately $22,000, immediate corrective action was taken to address the non-compliance. Dated January 5, 2024, a memorandum was filed disclosing the duplicative reimbursements, documenting the actions taken to rectify these charges, and recommending further steps to enhance the internal controls of the non-profit organization. The following information summarizes the East Baton Rouge City-Parish American Rescue Plan Act (ARPA): Duplication of Benefits - Findings and Corrective Action Memorandum: This memorandum documents the incidental reimbursement of multiple duplicative items associated with the subrecipient’s grant agreement and the corrective actions undertaken to resolve these findings, ensuring compliance with the terms of this award. During the routine subrecipient monitoring reviews, it was discovered that duplicate reimbursements occurred for 12 items between separate federal awards (American Rescue Plan Act SLFRF and CARES Act). In accordance with 2 CFR 200.522(c), a corrective action plan was provided to resolve the non-compliance. To address this, the following actions were taken: 1) Reconciliation of Duplicate Reimbursements: The non-profit entity has since reconciled the total value of $22,222.98 in duplicate reimbursements with an equivalent value of eligible expenses, including all necessary backup documentation to satisfy existing procurement and reimbursement requirements. 2) Development of a Duplication of Benefits Policy: It was recommended that the non-profit entity develop a comprehensive duplication of benefits policy to strengthen their internal controls further. These additional safeguards are considered best practices and are intended to minimize the risk of future non-compliance. Additionally, a comprehensive, grant specific, financial management policy template was provided to support the non-profits action to adopt and implement an appropriate standard of internal controls. The City-Parish is committed to maintaining robust internal controls and ensuring compliance with federal regulations. Immediate corrective measures were proactively taken to address these duplicative charges. Additionally, the City-Parish's third-party grants manager has established recurring weekly monitoring meetings with the non-profit entity to support the development and implementation of an adequate system of internal controls. Continuous efforts are being made to improve these processes to prevent such issues in the future. Expected Implementation Date: January 2024 Contact person: Courtney Scott, Assistant Chief Administrative Officer, Mayor-President’s Office

View Audit 321162 Questioned Costs: $1

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