Corrective Action Plans

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Management’s Response/Corrective Action Plan: Management has communicated directly with all staff responsible for student recordkeeping and cohort tracking at the high school level. The District procedural form for documenting student removals will be required in all cases. This form will serve as t...
Management’s Response/Corrective Action Plan: Management has communicated directly with all staff responsible for student recordkeeping and cohort tracking at the high school level. The District procedural form for documenting student removals will be required in all cases. This form will serve as the official record and must be completed, signed, and retained in accordance with district policy and audit requirements. No student will be removed from the cohort without completed and verifiable documentation.
Name of auditee: Hollywood West Tenant Action Committee HUD auditee identification number: 122-44641 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2024 CAP prepared by Name: Noel Sweitzer Position: President, HDSI Management, Inc. Telephone number...
Name of auditee: Hollywood West Tenant Action Committee HUD auditee identification number: 122-44641 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2024 CAP prepared by Name: Noel Sweitzer Position: President, HDSI Management, Inc. Telephone number: (323) 231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2024-003: The Corporation did not furnish HUD with a complete annual financial report within ninety (90) days following the year ended June 30, 2024. Recommendation: The Corporation should ensure the annual financial report is filed within 90 days of year end. Action(s) taken or planned on the finding: The audited financial statements have been submitted to HUD. No further action is required.
Name of auditee: Hollywood West Tenant Action Committee HUD auditee identification number: 122-44641 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2024 CAP prepared by Name: Noel Sweitzer Position: President, HDSI Management, Inc. Telephone number...
Name of auditee: Hollywood West Tenant Action Committee HUD auditee identification number: 122-44641 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2024 CAP prepared by Name: Noel Sweitzer Position: President, HDSI Management, Inc. Telephone number: (323) 231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2024-002: The Corporation has not submitted audited financial statements to the Federal Audit Clearinghouse after the receipt of the auditor's reports. Recommendation: The Corporation should submit audited financial statements to the Federal Audit Clearinghouse within the time frames required. Action(s) taken or planned on the finding: The audited financial statements will be submitted to the Federal Audit Clearinghouse on a go forward basis.
Name of auditee: Hollywood West Tenant Action Committee HUD auditee identification number: 122-44641 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2024 CAP prepared by Name: Noel Sweitzer Position: President, HDSI Management, Inc. Telephone number...
Name of auditee: Hollywood West Tenant Action Committee HUD auditee identification number: 122-44641 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2024 CAP prepared by Name: Noel Sweitzer Position: President, HDSI Management, Inc. Telephone number: (323) 231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2024-001: During the year ended June 30, 2024, the Corporation did not make the required deposits to the reserve for replacements in the amount of $12,747. Recommendation: Management should request approval from HUD for a transfer from the residual receipt account to the reserve for replacement account in the amount of $8,498 to correct the error. Management should also make the additional deposit of $4,249 or request a suspension of deposits from HUD. Action(s) taken or planned on the finding: Management has requested approval from HUD to transfer the funds to the reserve for replacement account and will make the additional deposit during the year ended June 30, 2025.
1. Implement and maintain a formal time and effort process for payroll charged to Federal and other restricted awards. 2. Require approved time records or other compliant personnel activity documentation that accurately reflects work performed and is incorporated into payroll allocations. 3. Train p...
1. Implement and maintain a formal time and effort process for payroll charged to Federal and other restricted awards. 2. Require approved time records or other compliant personnel activity documentation that accurately reflects work performed and is incorporated into payroll allocations. 3. Train program and finance staff on requirements for payroll allocation support under 2 CFR 200.430. 4. Retain supporting records in the grant file and review payroll allocation support as part of monthly close and grant reporting.
Management acknowledges that this finding was also reported in the prior fiscal year. Due to staffing changes within the finance department and competing operational priorities, the corrective actions previously planned were not fully implemented in time to ensure timely filing of the required repor...
Management acknowledges that this finding was also reported in the prior fiscal year. Due to staffing changes within the finance department and competing operational priorities, the corrective actions previously planned were not fully implemented in time to ensure timely filing of the required reports. Management recognized the importance of timely regulatory filings and has taken additional steps to strengthen internal processes and oversight. Significant staff turnover within the finance department during and after the audit period resulted in delays in preparing audit schedules and supporting documentation required for the completion of the related regulatory filings. In addition, formalized procedures and a compliance calendar for regulatory reporting deadlines were not fully implemented during the prior year. Finance Management will implement a financial compliance calendar to track all required regulatory reporting deadlines, including IRS Form 990, single audit and other financial reports. The calendar will include preparation, review, and submission deadlines to ensure reports are completed and filed in time. Finance management will coordinate with external auditors and tax preparers to support timely completion of filings. Responsible party: Finance Management Target Completion Date: June 30, 2026 Monitoring: The Finance Director will maintain and review the compliance calendar monthly to monitor upcoming deadlines and filing status. The CFDO will periodically review compliance with reporting requirements to ensure filings are completed within required timeframes.
Management acknowledges this finding and recognizes the importance of maintaining adequate internal control over the preparation and review of accounting records. This finding was also reported in the prior fiscal year, however due to turnover within key finance leadership roles and limited staff ca...
Management acknowledges this finding and recognizes the importance of maintaining adequate internal control over the preparation and review of accounting records. This finding was also reported in the prior fiscal year, however due to turnover within key finance leadership roles and limited staff capacity and expertise during the audit period, the previously planned corrective actions were not fully implemented. While improvement began toward the end of Fiscal Year 2025 (FY25), management acknowledges that the implementation of strengthened internal control procedures will continue into Fiscal Year 2026 (FY26), as the newly established finance team further develops and formalizes these processes. The Finance Department experienced turnover within key finance leadership roles, which limited the department's capacity and expertise necessary to implement the corrective actions and process improvements identified in the prior year audit. The organization has since strengthened the finance department by hiring additional staff to support the implementation of improved internal controls, formalized procedures, and regulatory reporting processes. Finance leadership has implemented additional review procedures over the preparation of the accounting records including supervisory review of journal entries, documented monthly account reconciliations and a standardized month-end checklist. These procedures will help ensure accounting records are accurate, complete and reviewed timely. While improvements begin during the end of FY25, full implementation of these process improvements will continue into FY26 to ensure sustainable internal control practices and timely regulator reporting. Responsible party: Finance Management Target Completion Date: June 30, 2026 Monitoring: Management reviews the month end close calendar monthly to ensure all reconciliation, journal entries, and reporting are completed and documented. Finance management also reviews monthly financials with the program leaders during soft close.
2024-005 – Reporting Contact Person Terry Hanson Corrective Action Plan Management recognizes the delayed submission of the 2024 audit to the Federal Audit Clearinghouse. To prevent recurrence, management is developing a compliance calendar and assigning responsibility for federal filing deadlines t...
2024-005 – Reporting Contact Person Terry Hanson Corrective Action Plan Management recognizes the delayed submission of the 2024 audit to the Federal Audit Clearinghouse. To prevent recurrence, management is developing a compliance calendar and assigning responsibility for federal filing deadlines to the Director of Finance. Regular progress reviews will ensure all audit deliverables are completed and submitted within the required ninemonth period. This corrective measure will improve accountability and ensure timely compliance with federal reporting standards. Planned Completion Date for CAP Immediately
2024-004 – Reserve for Replacement Contact Person Terry Hanson Corrective Action Plan Management will request a waiver from HUD to cease deposits to the RFR Account until such time that the account falls below the HUD recommended minimum required deposit, per 4350.1. If waiver is not forthcoming, ma...
2024-004 – Reserve for Replacement Contact Person Terry Hanson Corrective Action Plan Management will request a waiver from HUD to cease deposits to the RFR Account until such time that the account falls below the HUD recommended minimum required deposit, per 4350.1. If waiver is not forthcoming, management will request that owner provide funding to RFR, until such time that the operating account balance reflects a positive balance and the property is able to deposit to RFR. Planned Completion Date for CAP Immediately
Finding Number: 2024-004 Finding Title: Eligibility Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Janelle White – Controller Health and Wellness Service Team Melody Santana-Marty – Controller Community Services and Supports Corrective Action Pla...
Finding Number: 2024-004 Finding Title: Eligibility Program: 93.778 Medical Assistance Program Name of Contact Person Responsible for Corrective Action: Janelle White – Controller Health and Wellness Service Team Melody Santana-Marty – Controller Community Services and Supports Corrective Action Planned: Internal quality controls specific to the Medicaid program, will be reviewed and updated. Department-wide communication to staff regarding the importance of complete and adequate supporting documentation in the case file prior to case approval has been implemented and will continue on an ongoing basis. This communication will include guidance on how to determine whether documentation is sufficient, along with examples of acceptable support. At a minimum, required documentation will include: • Documentation verifying citizenship. • Examples of properly completed applications. • Reconciliation of the income verification in MAXIS and the documentation in the case file. • Reconciliation of the asset verification in MAXIS and the documentation in the case file. The Quality Assurance review process and Corrective Action Plan have been documented and communicated to provide guidance for new staff, serve as refresher training for existing staff, and ensure that appropriate actions are consistently followed. This documentation will be reviewed and revised as necessary to maintain compliance and consistency across the department. Supervisory review has been implemented for new hires. When issues are identified with current staff, enhanced review strategies and procedures will be applied to ensure required documentation is properly reviewed prior to case approval. Supervisors will conduct periodic reviews of case files to ensure that all required documentation is on file. If errors are identified and overpayments occur, the Department will follow established protocols of the Minnesota Department of Human Services regarding the identification, reporting, and recovery of overpayments. Anticipated Completion Date: 06/10/2026
Finding Number: 2024-003 Finding Title: Eligibility and Child Support Non-Cooperation Program: 93.558 Temporary Assistance for Needy Families Name of Contact Person Responsible for Corrective Action: Janelle White – Controller Health and Wellness Service Team Melody Santana-Marty – Controller Commun...
Finding Number: 2024-003 Finding Title: Eligibility and Child Support Non-Cooperation Program: 93.558 Temporary Assistance for Needy Families Name of Contact Person Responsible for Corrective Action: Janelle White – Controller Health and Wellness Service Team Melody Santana-Marty – Controller Community Services and Supports Corrective Action Planned: Internal quality control review checklists, specific to each program area, will be reviewed and updated, and additional controls will be developed to ensure that required documentation is obtained and maintained. Department-wide communication to staff regarding the importance of complete and adequate supporting documentation in the case file prior to case approval has been implemented and will continue on an ongoing basis. This communication will include guidance on how to determine whether supporting documentation is sufficient, along with examples of acceptable documentation. At a minimum, required documentation will include: • Documentation verifying client eligibility for the key eligibility-determining factors. • Evidence of the verification process recorded in MAXIS. • Documentation confirming that child support files have been reviewed and updated for non-cooperation, as applicable. Supervisors will conduct periodic reviews of case files to ensure that all required documentation is on file. Anticipated Completion Date: June 30, 2026
Finding Number: 2024-002 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: Daniel Rahkola, Division Director Finance Corrective Acti...
Finding Number: 2024-002 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: Daniel Rahkola, Division Director Finance Corrective Action Planned: The County will review program-related costs to ensure compliance with applicable grant requirements and to confirm that all costs are allowable, allocable, and properly supported. Supporting documentation must sufficiently demonstrate the allowability of each cost. This review will include the following: • Submitted payroll reports that detail individual hours worked, descriptions of work performed, and a clear link between the work performed and allowable grant program activities. • General ledger reports that support each cost and clearly document the relationship between the expenditure and allowable grant program expenses. Anticipated Completion Date: June 30, 2026
The City plans to have information ready for the auditors to get 2025 done in a reasonable time frame. This finding will likely carry to 2025 but between staffing and priorities, the City hopes to have clear this finding following its December 31, 2025 audit.
The City plans to have information ready for the auditors to get 2025 done in a reasonable time frame. This finding will likely carry to 2025 but between staffing and priorities, the City hopes to have clear this finding following its December 31, 2025 audit.
Finding 2024-003 Federal Agency Name: U.S. Department of Agriculture Assistance Listing Number: #10.766 Program Name: Community Facilities Loans and Grants, Community Facilities Loans and Grants Compliance Requirement: Special Tests and Provisions Finding Summary: The Hospital did not sufficiently f...
Finding 2024-003 Federal Agency Name: U.S. Department of Agriculture Assistance Listing Number: #10.766 Program Name: Community Facilities Loans and Grants, Community Facilities Loans and Grants Compliance Requirement: Special Tests and Provisions Finding Summary: The Hospital did not sufficiently fund their reserve account. As of December 31, 2024, the Hospital should have USDA debt reserves at least equal to $459,326. Responsible Individuals: Doug B. Lewis, Chief Financial Officer Corrective Action Plan: Management will review the reserve account requirements and ensure appropriate contributions are made during the fiscal year.
Finding 2024-003: Late Submission Corrective Action: The City of Menomonie is developing policies and procedures to ensure that financial records are maintained on a more current basis, reconciled timely and audited within nine months after year-end. Persons Responsible: Eric Atkinson Anticipated Co...
Finding 2024-003: Late Submission Corrective Action: The City of Menomonie is developing policies and procedures to ensure that financial records are maintained on a more current basis, reconciled timely and audited within nine months after year-end. Persons Responsible: Eric Atkinson Anticipated Completion Date: Ongoing
Corrective Action Plan • Policies and Procedures Reinforcement – Review and reinforce procurement policies to ensure all purchases are supported by approved requisitions and required quotations. • Documentation Retention Controls - Implement controls to ensure all procurement documentation is proper...
Corrective Action Plan • Policies and Procedures Reinforcement – Review and reinforce procurement policies to ensure all purchases are supported by approved requisitions and required quotations. • Documentation Retention Controls - Implement controls to ensure all procurement documentation is properly filed and retrievable. • Staff Training and Development – Provide training on procurement requirements under uniform guidance. This training will focus on compliance with policies and procedures and emphasize the importance of require documentation for each process and best practices. • Monitoring and Compliance Review - Establish periodic internal review procedures to ensure adherence to procurement policies. Name of the contact person responsible for corrective action plan Jesús A. Rodríguez Avilés – Financial Planning and Analysis Director Anticipated Completion date June 30, 2025
2024-003 – Significant Deficiency in Internal Control over Compliance and Other Matters – Special Tests and Provisions Name of Contact Person: Mariya Lovishchuk, Development Director Corrective Action: This was a clerical error issue. Davis Bacon Wages were paid throughout the entire project and cer...
2024-003 – Significant Deficiency in Internal Control over Compliance and Other Matters – Special Tests and Provisions Name of Contact Person: Mariya Lovishchuk, Development Director Corrective Action: This was a clerical error issue. Davis Bacon Wages were paid throughout the entire project and certified payroll was provided. However, the original construction contract did not include the correct prevailing wage language. Prevailing wages requirement was discussed and agreed upon prior to issuance of contract, but wrong language was inserted by mistake. Upon discovery of the wrong language, contract amendment was immediately issued to rectify. Proposed Completion Date: Already complete
MANAGEMENT WILL ENSURE THAT FUTURE AUDITS ARE COMPLETED TIMELY.
MANAGEMENT WILL ENSURE THAT FUTURE AUDITS ARE COMPLETED TIMELY.
The City will incorporate verification of grant-funded assets into year-end closing process; require asset reconciliation between Finance Department, Grants Department, and Funding Agency asset records (if provided); and maintain item-level tracking of grant-funded assets. Responsible Officials: Mic...
The City will incorporate verification of grant-funded assets into year-end closing process; require asset reconciliation between Finance Department, Grants Department, and Funding Agency asset records (if provided); and maintain item-level tracking of grant-funded assets. Responsible Officials: Michael Elizalde, Grants & Strategic Initiatives Director / Vidal Roman Finance Director Timeline to Complete: Estimated December 2026
Views of Responsive Officials of Auditee: Management recognizes that the City’s audits have not been completed within the required statutory deadlines in recent years, including the reporting delay noted in this finding. These delays were primarily the result of turnover and transition in key financ...
Views of Responsive Officials of Auditee: Management recognizes that the City’s audits have not been completed within the required statutory deadlines in recent years, including the reporting delay noted in this finding. These delays were primarily the result of turnover and transition in key financial staff positions, which impacted continuity and the timely completion of audit-related activities. At the same time, management would like to highlight the significant progress that has been made in addressing this issue. Over the past six months, the City has successfully completed two fiscal year audits, representing meaningful advancement toward eliminating the audit backlog. Management is committed to continuing this progress and has established a plan to return to full compliance with reporting deadlines. The City anticipates being fully current beginning with the FY-2027 audit cycle and will continue implementing process improvements and ensuring staffing stability to support timely audit completion. Management understands the importance of timely reporting, particularly as it relates to maintaining eligibility for federal funding and will prioritize adherence to all applicable deadlines moving forward.
The county will implement a formal reconciliation process between grant tracking spreadsheets and the General Ledger. This reconciliation will be performed at minimum quarterly (when most grants are submitted) and shall include: 1. Documented Comparison: A side-by-side verification of total expendit...
The county will implement a formal reconciliation process between grant tracking spreadsheets and the General Ledger. This reconciliation will be performed at minimum quarterly (when most grants are submitted) and shall include: 1. Documented Comparison: A side-by-side verification of total expenditures and revenues per grant on amounts reported within the general ledger and amounts included on subsidiary tracking spreadsheets. This verification (crosswalk) should include specific general ledger account numbers used for tracking revenues and expenditures. 2. Supervisory Review: Reconciliations should be reviewed and signed off by a person independent of the spreadsheet preparation 3. System Integration: In January 2025, the County implemented a new ERP software system, which offers a grant module and features to identify grant items to help eliminate reliance on manual “shadow” systems or spreadsheets.
A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury Recommendation: Manageme...
A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing 21.027 – COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Federal Agencies: Department of Treasury Recommendation: Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of expenditures submitted to the Department of Treasury for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue educating grant managers on capabilities within the system that can be utilized in the execution of review and approval of grant expenditures prior to timely submission to the relevant granting agencies for reimbursement. Centralized repositories have been set up for grant managers to extract specific monthly financial reports for use in the execution of their controls, as well as to retain their review and approval evidence. The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. ORSPA and Corporate Financial Reporting are developing standard operating procedures for the required review and reconciliation of grant expenditures per the accounting system to the financial submissions to the granting agency, including requirements for maintaining evidence of the review(s). Anticipated Completion Date – June 30, 2027 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu
H. Period of Performance Timely Payment of Financial Obligations Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: As the grant period has ended, we recommend that the Corpora...
H. Period of Performance Timely Payment of Financial Obligations Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: As the grant period has ended, we recommend that the Corporation works with the funding agency to remedy the period of performance noncompliance. In addition, we recommend that the Corporation reassess the design of its period of performance controls to identify where enhancement or additional controls are needed over liquidation of financial obligations subsequent to the end of a grant award. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue to educate all grant managers on (1) the reporting capabilities within the system that can be utilized in the execution of monitoring payment status on individual invoices that have been submitted to granting agencies for reimbursement, and (2) the requirement to use their grant specific general ledger coding when orders are placed with vendors that are set up under the Corporation’s group purchasing process. For the specific vendor noted in Finding 2024-003, a grant number input field has been added to the group purchasing orders to allow for enhanced tracking and review of expenditures associated with grants and the monitoring of payment of those expenditures. The use of the accurate grant general ledger coding by grant managers when orders are placed will reduce the time between placement of order and payment of the invoice. The grant manager responsible for oversight of BHSB grants will work with BHSB to remedy the period of performance noncompliance noted in Finding 2024-003. Anticipated Completion Date – June 30, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu
C. Cash Management; L. Reporting Evidence and Review and Approval of the Reported Expenditures and Timely Report Submission Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: M...
C. Cash Management; L. Reporting Evidence and Review and Approval of the Reported Expenditures and Timely Report Submission Assistance Listing 93.959: Block Grants for Substance Use Prevention, Treatment, and Recovery Services Federal Agency: Department of Health and Human Services Recommendation: Management should reassess the design of its controls to ensure submissions to BHSB are made timely within the required 15-day period and that documentation is retained that evidences the review and approval of expenditures submitted to BHSB for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation went live on its new ERP system in April 2024. Since go-live, management has continued to optimize the system and find ways to strengthen our internal controls, including automating certain processes. Management will continue educating grant managers on capabilities within the system that can be utilized in the execution of review and approval of grant expenditures prior to timely submission to the relevant granting agencies for reimbursement. Centralized repositories have been set up for grant managers to extract specific monthly financial reports for use in the execution of their controls, as well as to retain their review and approval evidence. Additionally, management is developing standard operating procedures and policies that include the requirements for compliance and internal controls for federal grants. The policies will acknowledge that for controls to be designed and operate effectively, there must always be a segregation of duties between the preparer of the control vs. reviewer and that clear documentation must be retained to evidence the execution of the controls. Anticipated Completion Date – June 30, 2027 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu
Finding: The Organization did not have adequate and effective controls over compliance in place as it relates to activities allowed or unallowed and allowable costs. We noted Instances where payroll and non-payroll related expenditures did not have documentation of review. Corrective Response: Manag...
Finding: The Organization did not have adequate and effective controls over compliance in place as it relates to activities allowed or unallowed and allowable costs. We noted Instances where payroll and non-payroll related expenditures did not have documentation of review. Corrective Response: Management is committed to strengthening how we track and allocate hours to grant-funded projects to ensure full compliance with 2 CFR 200.430. Going forward, the organization will implement a time study approach to support the allocation of personnel costs to federal grants. Employees working across multiple funding sources will participate in periodic time studies designed to reasonably estimate the distribution of their time based on actual activities performed. The results of these time studies will be used as the basis for allocating payroll costs to the appropriate grants, and will be supported by documentation and supervisory review. We will also implement consistent tools and processes to ensure allocations are applied systematically across all funding sources. On a monthly basis, the finance team will review and reconcile payroll allocations to ensure they align with the established methodology. In addition, we will provide training and ongoing oversight to reinforce compliance and prevent similar Issues In the future.
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