Corrective Action Plans

Finding 1223317 (2024-028)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Questioned Costs Allowable Costs / Cost Principles § 200.303

OTAG recognizes the need to strengthen internal controls related to cash management reporting, matching requirement monitoring, and grant period-of-performance compliance. A comprehensive review of existing Master Cooperative Agreement Appendices management processes has been initiated to identify c...

OTAG recognizes the need to strengthen internal controls related to cash management reporting, matching requirement monitoring, and grant period-of-performance compliance. A comprehensive review of existing Master Cooperative Agreement Appendices management processes has been initiated to identify control weaknesses and implement corrective measures. OTAG will implement tracking tools to monitor award periods, liquidation deadlines, and expenditure charging. Personnel will verify Master Cooperative Agreement Appendices periods prior to processing transactions. Expenditures charged to awards will undergo review to confirm alignment with the applicable award and performance period with cross reconciliation of the Government of the Virgin Islands procurement methods, and the Government of the Virgin Islands fiscal enterprise system. Policy and Procedure Enhancements: OTAG will update SOPPs to address cash management, reporting requirements, matching calculations, expenditure monitoring, and period-of-performance reviews. Training will be provided to personnel upon implementation of the revised procedures. Preventive Measures: •Monthly grant reconciliation reviews. •Quarterly compliance monitoring. •Management review of reimbursement requests and matching calculations. •Annual internal compliance assessment. •Centralized documentation repository for grant records. Monitoring & Accountability: The Adjutant General and Executive Director will monitor implementation and effectiveness. Quarterly compliance reports will be provided to agency leadership, and corrective actions will be tracked through completion.

View Audit 406809

Finding 1223314 (2024-025)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Questioned Costs Period of Performance § 200.303 § 200.403

OTAG has reviewed the payroll transactions identified during the audit and has initiated corrective measures to strengthen controls over payroll documentation, appendix charging, and period-of-performance compliance. Payroll expenditures charged to Master Cooperative Agreement Appendices will be sub...

OTAG has reviewed the payroll transactions identified during the audit and has initiated corrective measures to strengthen controls over payroll documentation, appendix charging, and period-of-performance compliance. Payroll expenditures charged to Master Cooperative Agreement Appendices will be subject to quarterly review to verify that timesheets, payroll registers, and supporting documentation are complete, accurate, and retained in accordance with the SF-270 submission requirements. Payroll charges will also be reviewed against periods of performance before posting to ensure costs are assigned to the correct award. OTAG will revise its SOPPs to establish formal procedures for payroll certification, documentation retention, reconciliation of payroll records to timesheets, and review of Master Cooperative Agreement funded personnel costs. Training will be conducted for personnel on documentation standards and allowable cost requirements. To prevent recurrence, monthly reconciliations between payroll records and supporting timesheets will be performed and documented. Quarterly compliance reviews will evaluate payroll charges and supporting documentation for accuracy and completeness. Monitoring & Accountability: The Adjutant General and Executive Director will jointly oversee implementation. Results of monthly reconciliations and quarterly reviews will be reported to executive management.

View Audit 406809

Finding 1223313 (2024-023)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Questioned Costs Subrecipient Monitoring Reporting § 200.303

The Government concurs with the auditor’s findings and recommendations. DOH has implemented no corrective action, as grant is closed.

View Audit 406809

Finding 1223311 (2024-021)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Cash Management Internal Control / Segregation of Duties Questioned Costs § 200.303

The Government concurs with the auditor’s findings and recommendations. DOH has implemented no corrective action, as grant is closed.

View Audit 406809

Finding 1223310 (2024-017)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Cash Management Internal Control / Segregation of Duties Questioned Costs § 200.303

As of July 2024, DOH revised drawdown Standard Operating Procedures (SOPs) to mandate that all supporting documents include a signature or initial to certify that a proper review was conducted at certification level of certification. DOH have also incorporated this updated procedure into Federal Gra...

As of July 2024, DOH revised drawdown Standard Operating Procedures (SOPs) to mandate that all supporting documents include a signature or initial to certify that a proper review was conducted at certification level of certification. DOH have also incorporated this updated procedure into Federal Grants update trainings and made it accessible to all staff on Business Process Improvement SharePoint site.

View Audit 406809

Finding 1223309 (2024-020)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Internal Control / Segregation of Duties Questioned Costs Procurement, Suspension & Debarment § 200.303

As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Federal Grants ...

As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Federal Grants Financial Analyst is being integrated into the workflow to ensure compliance. Additionally, a Director of Federal Grants has been onboarded to add an additional level of oversight.

View Audit 406809

Finding 1223307 (2024-018)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Questioned Costs § 200.303 § 200.403 § 200.430

DHS adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and a workflow ensures accurate NOPA li...

DHS adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and a workflow ensures accurate NOPA listings for payroll purposes. Additionally, in order to ensure that Notices of Personnel Actions are updated on a timely basis, ensuring that salaries are charged to the respective account, DHS has implemented the following process: Provisional Payroll Codes are requested prior to the close of the Fiscal Year by the Department of Finance through the Office of Management and Budget through the established process. Once the codes are received, the Division of Human Resources will update the most current Personnel Distribution Sheets to reflect active employees. The sheets will be submitted to Fiscal for certification by the CFO.NOPA’s are updated with the provisional codes. Lastly, once payroll is processed by the Department of Finance (DOF), a Flex Earnings Report is generated by the Analyst on each payday. A reconciliation is then performed to ensure that all employees, along with their respective fringe benefits, are accurately captured and drawn. Following this process, DOF posts the payroll to the accounting system. The Federal Grants Financial Analyst, once onboarded, will also play a key role in ensuring that transactions are recorded in the appropriate accounting period and that costs are properly allocated. DHS has added an additional layer of monitoring with the onboarding of a Director of Federal Grants. The newly created unit of Audit and Compliance, once staffed will play a crucial role with periodic monitoring.

View Audit 406809

Finding 1223277 (2024-003)

Material Weakness 2024

TURNING POINTS FOR CHILDREN

PA

Questioned Costs Student Financial Aid Allowable Costs / Cost Principles

Management concurs with the finding. The Organization will implement procedures to ensure that only approved indirect cost rates are applied to federal awards and other grant-funded programs. Management will Provide training to accounting and grants management personnel on indirect cost requirements...

Management concurs with the finding. The Organization will implement procedures to ensure that only approved indirect cost rates are applied to federal awards and other grant-funded programs. Management will Provide training to accounting and grants management personnel on indirect cost requirements and grant compliance. Management will also review all current awards to identify any additional instances where an incorrect rate may have been applied and making any necessary adjustments or notifications to funding agencies.

View Audit 406769

Finding 1223225 (2024-001)

Material Weakness 2024

California Labor Federation

CA

Questioned Costs Reporting Significant Deficiency § 200.512

All outstanding audits have been completed. Audits will be conducted annually and completed within six months following the end of each calendar year to ensure ongoing compliance and timely submissions.

View Audit 406708

Finding 1223220 (2024-010)

Material Weakness 2024

Williston Basin Public School District #7

ND

Allowable Costs / Cost Principles Questioned Costs Material Weakness § 200.303 § 200.403

2024-010 – EDUCATION STABILIZATION FUND - LACK OF SUPPORT OVER ESSER FUNDS – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 was unable to provide supporting documentation for expenses charged to the Education Stabilization Fund. 13 of ...

2024-010 – EDUCATION STABILIZATION FUND - LACK OF SUPPORT OVER ESSER FUNDS – ALN 84.425 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 was unable to provide supporting documentation for expenses charged to the Education Stabilization Fund. 13 of the 60 we sampled did not have any support, leaving them with known questioned costs of $171,408. Management’s Response: We agree. WBSD#7 created a new Grants Coordinator position in July 2023 with one of the specific responsibilities for that position being oversight of all Federal programs. This oversight responsibility includes monitoring expenditures to ensure all expenditures are allowable within the parameters of each program and also that proper documentation for those expenditures has been maintained. It has taken the district some time to get this area cleaned up. Anticipated Completion Date: FY 2025

View Audit 406706

Finding 1223202 (2024-002)

Material Weakness 2024

State Education Resource Center

CT

Questioned Costs Reporting Significant Deficiency

To mitigate further delays in completing our 2025 audit, SERC has discussed amending the agreement with its current auditing firm to conduct the 2025 audit. SERC has also contracted with an external consultant to facilitate the fiscal department's operations while we find a permanent fiscal departme...

To mitigate further delays in completing our 2025 audit, SERC has discussed amending the agreement with its current auditing firm to conduct the 2025 audit. SERC has also contracted with an external consultant to facilitate the fiscal department's operations while we find a permanent fiscal department head.

View Audit 406698

Finding 1222870 (2024-005)

Material Weakness 2024

State of Kosrae

FM

Subrecipient Monitoring Equipment & Real Property Management Questioned Costs § 200.303

Finding Number 2024-005 Corrective Action Plan (CAP) CSG will draft and implement a policy on Equipment and Real Property Management, specifically regarding safe-guarding equipment and reporting. Policy will include: • A requirement for each department to assign a custodian to manage all capitalized...

Finding Number 2024-005 Corrective Action Plan (CAP) CSG will draft and implement a policy on Equipment and Real Property Management, specifically regarding safe-guarding equipment and reporting. Policy will include: • A requirement for each department to assign a custodian to manage all capitalized equipment. • A requirement for each department to report all incidents via an Equipment Incident Report form. • Each department will be required to update DAS on the status of all capitalized equipment on a quarterly basis. • A Physical Inventory Count will be done annually to ensure proper reporting of existing equipment. Anticipated Completion Date December 31, 2026 Responsible Person (Contact Details) Jonas Paul, Director (DAS) jpaulckdas@gmail.com Kayviann Hallers Umwech, Internal Control (DAS) kayviannhallers@gmail.com Roxalyn Kaminanga, Chief (DAS) roxalynkaminanga@gmail.com

View Audit 406415

Finding 1222861 (2024-004)

Material Weakness 2024

State of Kosrae

FM

Cash Management Questioned Costs Subrecipient Monitoring § 200.1

Finding Number 2024-004 Corrective Action Plan (CAP) CSG will draft and implement a policy on Cash Management specifically regarding cash disbursement to vendors for infrastructure projects. • CSG will assign a designated person to request drawdowns for Infrastructure projects. This same individual ...

Finding Number 2024-004 Corrective Action Plan (CAP) CSG will draft and implement a policy on Cash Management specifically regarding cash disbursement to vendors for infrastructure projects. • CSG will assign a designated person to request drawdowns for Infrastructure projects. This same individual will keep track of this request and will notify the appropriate individuals at Chuuk State Finance who will authorize the disbursement of the check/s to the vendor. • A specific timeframe in which CSG will minimize the time between cash drawdown received from FSM National Government and disbursement to vendors will be established upon consultation with grantor agency. Anticipated Completion Date December 31, 2026 Responsible Person (Contact Details) Jonas Paul, Director (DAS) jpaulckdas@gmail.com Kayviann Hallers Umwech, Internal Control (DAS) kayviannhallers@gmail.com Roxalyn Kaminanga, Chief (DAS) roxalynkaminanga@gmail.com

View Audit 406415

Finding 1222708 (2024-006)

Material Weakness 2024

Native Americans for Community Action, Inc.

AZ

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring

Finding 2024 -006: Overbilling of Indirect Costs – Material Weakness Condition: During the course of the audit, Baker Tilly determined that, for certain time periods, NACA applied an incorrect indirect cost rate, resulting in over billings to the funding source. Corrective Action: Along with the aud...

Finding 2024 -006: Overbilling of Indirect Costs – Material Weakness Condition: During the course of the audit, Baker Tilly determined that, for certain time periods, NACA applied an incorrect indirect cost rate, resulting in over billings to the funding source. Corrective Action: Along with the auditors and the process during the course, management disclosed and determined there was an overcharge of indirect costs. Currently, NACA is under a negotiated cost agreement. We have already disclosed the overbilling to I H S, who is our cognizant grantor, and plan is to disclose to other federal and local agencies. If needed, a payback plan will be established. Communication will be via email for documentation purposes. Name of Person Responsible: Walter McCullough, CFO Anticipated Date of Completion: April 30, 2026.

View Audit 406311

Finding 1222586 (2024-001)

Material Weakness 2024

Arctic Village Tribal Council

AK

Cash Management Questioned Costs Material Weakness § 200.305

Finding 2024-001 Lack of Internal Controls Over Cash Management Name of Contact Person: Galen Gilbert, First Chief Corrective Action Plan: In the prior fiscal year, Arctic Village Council (AVC) experienced delays in drawing down HUD funds due to staff transitions and turnover. While reimbursement wa...

Finding 2024-001 Lack of Internal Controls Over Cash Management Name of Contact Person: Galen Gilbert, First Chief Corrective Action Plan: In the prior fiscal year, Arctic Village Council (AVC) experienced delays in drawing down HUD funds due to staff transitions and turnover. While reimbursement was ultimately received, the funds were not deposited until after fiscal year-end, contributing to the reported cash management issue. To strengthen internal controls and avoid future delays, AVC will continue to follow its monthly reconciliation process to ensure that all grant expenditures are accurately aligned with drawdown activity and supported by eligible costs. In addition, AVC will explore establishing a line of credit (LOC) in FY2025 to help bridge timing gaps between expenditures and reimbursement cycles. This LOC would provide short-term liquidity support and help reduce reliance on general fund balances while awaiting federal reimbursements. Proposed Completion Date: September 30, 2025

View Audit 406180

Finding 1221748 (2024-003)

Material Weakness 2024

Young Womens Christian Association of Greater Lafayette

IN

Questioned Costs Reporting Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges noncompliance with federal reporting timelines.  Create a compliance calendar listing all federal reporting deadlines, including the Data Collection Form due date and interim milestones for audit completion.  Designat...

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges noncompliance with federal reporting timelines.  Create a compliance calendar listing all federal reporting deadlines, including the Data Collection Form due date and interim milestones for audit completion.  Designate outsourced finance team as the responsible official for preparing and submitting the Data Collection Form, with the CEO as backup, and require written confirmation of submission to management and the Finance Committee.  Incorporate a year-end compliance checklist into closing procedures to verify preparation and timely filing of the Data Collection Form.  Provide training to leadership and finance staff on federal reporting requirements and consequences of late submissions.

View Audit 406008

Finding 1221747 (2024-007)

Material Weakness 2024

Young Womens Christian Association of Greater Lafayette

IN

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges gaps in VOCA employee file documentation.  Implement a standardized checklist for VOCA and other grant-funded employees that includes required acknowledgements (nondiscrimination, drug-free workplace, confidentiality, ...

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges gaps in VOCA employee file documentation.  Implement a standardized checklist for VOCA and other grant-funded employees that includes required acknowledgements (nondiscrimination, drug-free workplace, confidentiality, and related forms).  Educate HR staff in auditing best practices, emphasizing complete and accurate employee files and the specific grant documentation required.  Schedule periodic reviews of VOCA-funded employee files (at least quarterly) to verify that all required documents are present and current, with results reported to management.

View Audit 406008

Finding 1221745 (2024-005)

Material Weakness 2024

Young Womens Christian Association of Greater Lafayette

IN

Allowable Costs / Cost Principles Cash Management Reporting

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges deficiencies in reconciliation of reimbursement claims. • Implement a standardized reimbursement reconciliation worksheet that ties each grant claim to the general ledger, payroll reports, and underlying invoices prior ...

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges deficiencies in reconciliation of reimbursement claims. • Implement a standardized reimbursement reconciliation worksheet that ties each grant claim to the general ledger, payroll reports, and underlying invoices prior to submission. • Require documented review and approval of each claim by the designated finance team member, confirming that claimed amounts are allowable, supported, and within the grant period. • Provide staff training on claim preparation, reconciliation, and documentation retention expectations.

View Audit 406008

Finding 1221744 (2024-004)

Material Weakness 2024

Young Womens Christian Association of Greater Lafayette

IN

Allowable Costs / Cost Principles Questioned Costs

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges weaknesses in payroll allowability and calculation accuracy. • Update written payroll procedures for grant-funded employees that define allowable and unallowable pay elements (including shift differentials) and specify ...

Views of Responsible Officials and Planned Corrective Actions: YWCA acknowledges weaknesses in payroll allowability and calculation accuracy. • Update written payroll procedures for grant-funded employees that define allowable and unallowable pay elements (including shift differentials) and specify documentation requirements. • Configure payroll and accounting systems to properly classify VOCAfunded positions and apply standard shift differential calculations, with automated checks where possible. • Require a secondary review of payroll registers and allocations for VOCAfunded staff before costs are included in reimbursement requests, with sign-off by designated finance team member. • Provide training to HR, payroll, and finance staff on VOCA grant requirements, federal cost principles, and internal review procedures.

View Audit 406008

Finding 1221701 (2024-002)

Material Weakness 2024

KANSAS CITY BOARD OF PUBLIC UTILITIES

KS

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Finding 2024-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part ...

Finding 2024-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities

View Audit 405972

Finding 1221700 (2024-001)

Material Weakness 2024

KANSAS CITY BOARD OF PUBLIC UTILITIES

KS

Reporting Questioned Costs Matching / Level of Effort / Earmarking § 200.303

Finding 2024-001 Congressionally Mandated Projects / Reporting Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the...

Finding 2024-001 Congressionally Mandated Projects / Reporting Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities

View Audit 405972

Finding 1221610 (2024-051)

Material Weakness 2024

Commonwealth of Puerto Rico - Department of the Family

PR

Subrecipient Monitoring Questioned Costs Special Tests & Provisions § 200.334 § 200.337

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous documentation and oversight framework. We are prioritizing the development of standardized file-handling protocols, the implementation of a uniform record-keeping system, and the execution of comprehensive staff training to...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a rigorous documentation and oversight framework. We are prioritizing the development of standardized file-handling protocols, the implementation of a uniform record-keeping system, and the execution of comprehensive staff training to ensure that all sanction-related evidence is preserved, organized, and readily accessible for audit and verification purposes. Action Steps: 1. Implement a new "Uniform Record Retention & Archiving SOP" that mandates a specific organization, labeling, and storage legend for all participant files, ensuring uniform accessibility across all regions. 2. Adopt a formal "Sanction & Work Verification Checklist" that [LP4.1]must be completed for every participant file. This checklist will specifically require the inclusion of sanction periods, justification forms for "just cause," and evidence of non-compliance. 3. Develop an internal tracking log to manage sanction periods. This log will ensure that participants who have failed to comply with the work verification plan are monitored, and payments are suspended or reinstated only upon documented evidence of compliance. 4. Conduct a mandatory regional training curriculum for all regional staff on the importance of file maintenance, the specific requirements for documenting sanctions, and compliance. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Yessenia Peña Díaz Assistance Secretary of Administration

View Audit 405849

Finding 1221609 (2024-050)

Material Weakness 2024

Commonwealth of Puerto Rico - Department of the Family

PR

Questioned Costs Special Tests & Provisions Eligibility

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing rigorous documentation and archiving framework. We are prioritizing the development of standardized file-handling protocols, the implementation of a uniform record-keeping system, and the execution of comprehensive staff training to e...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing rigorous documentation and archiving framework. We are prioritizing the development of standardized file-handling protocols, the implementation of a uniform record-keeping system, and the execution of comprehensive staff training to ensure that all eligibility and non-cooperation evidence is preserved, organized, and readily accessible for audit and verification purposes. Action Steps: 1. Implement a new "Uniform Record Retention & Archiving SOP" that mandates a specific organization, labeling, and storage legend for all participant files, ensuring uniform accessibility across all regions. 2. Revise the Eligibility Documentation Checklist that must be completed for every participant, specifically requiring proof of child support referrals and, where applicable, non-cooperation determinations. 3. Formalize the communication protocol between the IV-A (ADSEF) and IV-D (Child Support) agencies to ensure prompt notification and documentation of non-cooperation instances, as required by 45 CFR §264.30(b). 4. Conduct a mandatory regional training curriculum for all regional staff on the importance of file maintenance, the specific requirements for child support referrals, and the legal protocols for handling non-cooperation cases. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Gerhil Medina Baez Auxiliary Administrator Operational Services

View Audit 405849

Finding 1221608 (2024-049)

Material Weakness 2024

Commonwealth of Puerto Rico - Department of the Family

PR

Questioned Costs Special Tests & Provisions Eligibility

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a verification framework. We are prioritizing the formalization of inter-agency data sharing agreements, the implementation of standardized income validation protocols, and the execution of a comprehensive training program to ensure a...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a verification framework. We are prioritizing the formalization of inter-agency data sharing agreements, the implementation of standardized income validation protocols, and the execution of a comprehensive training program to ensure all regional staff adhere to federal IEVS requirements. Action Steps: 1. MOU Formalization – Execute and maintain active Memoranda of Understanding (MOUs) with all relevant agencies to secure legal access to real-time wage, unemployment, and benefit data. 2. Develop and mandate a new "Income Eligibility Validation SOP". This protocol will strictly forbid reliance on sworn statements alone and will require technicians to cross-reference application data against verified external agency sources. 3. Integrated Data Exchange Protocol – Implement a recurring, automated schedule for the ingestion of SWICA, UC, and BENDEX/SSA data into our internal eligibility systems, ensuring data is available to technicians at the point of application and during quarterly reviews. 4. Implement a Training Curriculum – Launch a recurring, mandatory training program for all regional eligibility technicians and supervisors, focusing on federal IEVS requirements, standardized data validation procedures, and the legal consequences of non-compliance. 5. Implement a monthly "Eligibility Quality Assurance" review, where central-level management audits a sample of case files to ensure that income has been verified against external sources as required by the State Plan. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget Gerhil Medina Baez Auxiliary Administrator Operational Services

View Audit 405849

Finding 1221604 (2024-047)

Material Weakness 2024

Commonwealth of Puerto Rico - Department of the Family

PR

Internal Control / Segregation of Duties Reporting Questioned Costs § 200.303

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive internal control framework for EBT operations. We are prioritizing the development of current, formal written procedures, the implementation of a rigorous supervisory review cycle, and the enforcement of mandatory trai...

VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive internal control framework for EBT operations. We are prioritizing the development of current, formal written procedures, the implementation of a rigorous supervisory review cycle, and the enforcement of mandatory training to ensure that all EBT transactions are fully reconciled, documented, and compliant with federal requirements. Action Steps: 1. ERP-Driven Reconciliation - Configure the ERP system to automatically ingest and reconcile EBT Daily Activity and Payment Summary files against federal drawdowns (PMS/SF-425) and General Ledger expenditure records. 2. Updated Procedures Manual - Develop and approve a new "EBT Reconciliation Procedures Manual" that integrates the ERP's automated workflows, superseding the 2012 document and establishing frequency, roles, and oversight. 3. ERP Variance Reporting - Utilize the ERP to generate "Exception Reports" for any unmatched transactions between EBT disbursements and federal drawdowns. 4. Staff Training & ERP Integration - Execute mandatory training for all staff on the ERP’s automated reconciliation capabilities and the new standardized SOPs for verifying EBT settlement accuracy. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Eddie J. Burgos Auxiliary Administrator for Finance and Budget Carlos Martinez Colón Finance Director Vanessa Ayala Gerena Director of Budget

View Audit 405849

Corrective Action Plans

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