Corrective Action Plans

Finding 573489 (2024-001)

Significant Deficiency 2024

Evangeline Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs HUD Housing Programs Reporting

Project Legal Name: Evangeline Booth Friendship House Residence, Inc., a Texas Corporation HUD Project No.: 113-EE041 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023-9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvenshine Position: Territorial Legal Director-General Cou...

Project Legal Name: Evangeline Booth Friendship House Residence, Inc., a Texas Corporation HUD Project No.: 113-EE041 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023-9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvenshine Position: Territorial Legal Director-General Counsel Telephone Number: 404-728-6700 A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding Management will repay the property and update our procedures to correctly calculate management fees. The issue was due to a change in software.

View Audit 364210 Questioned Costs: $1

Finding 573474 (2024-004)

Material Weakness 2024

Catherine Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs HUD Housing Programs Reporting

4. Finding 2024-004 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding This is related to the deposit error in 2024-002. North TX A/C repaid one deposit on Septemb...

4. Finding 2024-004 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding This is related to the deposit error in 2024-002. North TX A/C repaid one deposit on September 30, 2024 and will repay the remaining one-month deposit to the property. These funds will be correctly deposited into the replacement reserve account going forward. B. Status of Corrective Actions on Findings Reported in the Schedule of the Status of Prior Audit Findings, Questioned Costs and Recommendations 1. Finding 2023-001 In process. See finding 2024-003.

View Audit 364206 Questioned Costs: $1

Finding 573473 (2024-003)

Material Weakness 2024

Catherine Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs HUD Housing Programs Reporting

3. Finding 2024-003 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding 2 HUD approved the $75,000 repaid as a response to a 2022 finding. HUD has not reached out t...

3. Finding 2024-003 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding 2 HUD approved the $75,000 repaid as a response to a 2022 finding. HUD has not reached out to management for repayment of the $23,000, however, management will seek evidence of HUD approval for the remaining $23,000 repaid.

View Audit 364206 Questioned Costs: $1

Finding 573472 (2024-002)

Material Weakness 2024

Catherine Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs Reporting

2. Finding 2024-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding North TX A/C refunded a one-month deposit of $2,732 to the property on September 30, 2024. T...

2. Finding 2024-002 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding North TX A/C refunded a one-month deposit of $2,732 to the property on September 30, 2024. They will repay the remaining one-month deposit of $2,732, and these funds will be correctly deposited into the replacement reserve account going forward.

View Audit 364206 Questioned Costs: $1

Finding 573471 (2024-001)

Significant Deficiency 2024

Catherine Booth Friendship House Residence Inc., A Texas Corporation

TX

Questioned Costs HUD Housing Programs Reporting

Project Legal Name: Catherine Booth Friendship House Residence, Inc., A Texas Corporation HUD Project No.: 113-EE021 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023-9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvinshine Position: Territorial Legal Director – General Co...

Project Legal Name: Catherine Booth Friendship House Residence, Inc., A Texas Corporation HUD Project No.: 113-EE021 Audit Firm: CohnReznick LLP Period covered by the audit: 10/1/2023-9/30/2024 Corrective Action Plan prepared by: Name: Lee Auvinshine Position: Territorial Legal Director – General Counsel Telephone Number: 404-728-6700 The following is a recommended format to be followed by the auditee for preparing a corrective action plan: A. Current Findings on the Schedule of Findings, Questioned Costs and Recommendations 1. Finding 2024-001 a. Comments on the Finding and Each Recommendation Management agrees with the finding and is taking steps to address the issue that caused it. b. Action(s) Taken or Planned on the Finding Management will repay the property and update our procedures to correctly calculate management fees. The issue was due to a change in software.

View Audit 364206 Questioned Costs: $1

Finding 573467 (2024-003)

Material Weakness 2024

Bibb County Board of Education

AL

Questioned Costs Matching / Level of Effort / Earmarking Special Tests & Provisions

We are award of the Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "David-Bacon Act") when using COVID-19 Education Stabilizaiton Funds to fund construction contracts in excess of $2,000. We will ensure the Davis-Bacon Act ...

We are award of the Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "David-Bacon Act") when using COVID-19 Education Stabilizaiton Funds to fund construction contracts in excess of $2,000. We will ensure the Davis-Bacon Act wage rate is included in all construction contracts over $2,000.

View Audit 364195 Questioned Costs: $1

Finding 573466 (2024-002)

Material Weakness 2024

Bibb County Board of Education

AL

Questioned Costs Procurement, Suspension & Debarment

We are aware of the U.S. Code of Federal Regulations Title 2, Part 2, Part 200.318, of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) concerning public works projects. We will work to develop and implement more effective proced...

We are aware of the U.S. Code of Federal Regulations Title 2, Part 2, Part 200.318, of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) concerning public works projects. We will work to develop and implement more effective procedures concerning all public works projects.

View Audit 364195 Questioned Costs: $1

Finding 573354 (2024-009)

Material Weakness 2024

Leech Lake Tribal College

AZ

Questioned Costs Student Financial Aid Material Weakness

The Department will enforce policies and procedures to ensure that compliance with the requirements. New internal controls are expected to be implemented to address these findings.

View Audit 364132 Questioned Costs: $1

Finding 573304 (2024-001)

Material Weakness 2024

Housing Authority of the City of Easton

PA

Questioned Costs HUD Housing Programs Eligibility

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, ...

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Tyler Martin, Executive Director, is responsible for implementing this corrective action by December 31, 2025.

View Audit 364098 Questioned Costs: $1

Finding 573227 (2024-001)

Material Weakness 2024

Vermont Youth Conservation Corp, Inc.

VT

Questioned Costs Matching / Level of Effort / Earmarking Reporting

Recommendation: Vermont Youth Conservation Corps, Inc. should put procedures In place to ensure that they are in compliance with grant agreements and that all required matching dollars are satisfied in the respective award period. ...

Recommendation: Vermont Youth Conservation Corps, Inc. should put procedures In place to ensure that they are in compliance with grant agreements and that all required matching dollars are satisfied in the respective award period. Action Taken: Vermont Youth Conservation Corps, Inc. has implemented procedures to ensure grant matching requirements are satisfied at the time of final report submission. If Corporation for National and Community Service (CNCS) has any questions regarding this plan, please call Hapy Mayer at (802) 434-3969 ext. 134.

View Audit 364046 Questioned Costs: $1

Finding 573207 (2024-007)

None 2024

League for the Blind & Disabled, Inc.

IN

Questioned Costs Cash Management Internal Control / Segregation of Duties § 200.302 § 200.333 § 200.334

2024-007 Missing Supporting Documentation for Federal Reimbursement Claims Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding. A process for retaining claims and supporting documentation has been implemented.

View Audit 364023 Questioned Costs: $1

Finding 573162 (2024-001)

None 2024

Kentucky Housing Corporation

TN

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.516

The Corporation identified a subrecipient’s misuse of grant funds during a regular audit of draws and a scheduled monitoring review/technical assistance consultation for the agency. Ethic complaints were received by the Corporation during the same timeframe regarding the subrecipient’s management wh...

The Corporation identified a subrecipient’s misuse of grant funds during a regular audit of draws and a scheduled monitoring review/technical assistance consultation for the agency. Ethic complaints were received by the Corporation during the same timeframe regarding the subrecipient’s management which expanded the scope of the financial review. As a result of these monitoring efforts, the Corporation identified ineligible and questioned costs, and efforts are underway to recapture ineligible and unsupported costs. The Corporation has put the following policies and procedures in place to mitigate future risk: 1. Biennial Risk Assessment with Annual Updates 2. Annual Project Compliance Report (APCR) required by subrecipient agencies (with the exception of subrecipients receiving only Department of Energy and LIHEAP grants for the Weatherization Assistance Program, which are governed by separate monitoring procedures). 3. Enhanced Draw Monitoring and draw documentation requirements 4. Expansion of the Corporation’s Compliance and Training Team Given the policies, procedures, and changes outlined above, the Corporation feels confident it will be able to comply with its Compliance Monitoring Plan going forward and identify any concerns with subrecipient compliance in a timely manner. Curtis Stauffer, Managing Director, Housing Contract Administration, and applicable compliance staff will implement by October 1, 2024.

View Audit 363980 Questioned Costs: $1

Finding 573121 (2024-001)

Material Weakness 2024

The Addiction Center of Broome County, Inc.

NY

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Corrective Action Plan for FYE December 31, 2024 Finding 2024-001 Corrective Action Plan: Management will implement periodic time studies throughout contract durations to support accurate allocation of personnel costs. Staff will be reminded of relevant compliance requirements, and internal proces...

Corrective Action Plan for FYE December 31, 2024 Finding 2024-001 Corrective Action Plan: Management will implement periodic time studies throughout contract durations to support accurate allocation of personnel costs. Staff will be reminded of relevant compliance requirements, and internal processes will be adjusted as needed. We will continue to monitor this area and document efforts to ensure ongoing alignment with applicable regulations. Contact Person Responsible for Corrective Action Plan: Lottie Albrecht, Director of Administration Phone Number: 607-940-0102 Email: lalbrecht@acbcservices.org Anticipated Completion Date of Corrective Action Plan: December 2025 (as part of preparation for fiscal year ending December 31, 2025)

View Audit 363928 Questioned Costs: $1

Finding 573115 (2024-002)

Material Weakness 2024

Genesee County Youth Corporation

MI

Questioned Costs Eligibility Internal Control / Segregation of Duties

2024 – 002 Lack of Segregation of Duties - Lack of Supervisory Review - Allow-ability of Expenses Charged to Grants The corrective action proposed for the above finding should be sufficient to account for any area of non-compliance in the evidence of supporting documentation for all disbursemen...

2024 – 002 Lack of Segregation of Duties - Lack of Supervisory Review - Allow-ability of Expenses Charged to Grants The corrective action proposed for the above finding should be sufficient to account for any area of non-compliance in the evidence of supporting documentation for all disbursements. Additionally, the Business Operations Manager and Executive Director will implement a systematic review of all grant awards, contracts, and develop an addendum document charting all allowable expenses within each funding stream that will be utilized by the team when to determine proper allocation of disbursements. This chart will provide a quick guide to monitor compliance and allow-ability of expenditures to each funder at the time a check request is submitted. Checks

View Audit 363925 Questioned Costs: $1

Finding 573025 (2024-004)

Material Weakness 2024

City of Johnstown

PA

Questioned Costs Procurement, Suspension & Debarment § 200.320

The City will work internally within the City Manager's office and Finance Department to adopt a centralized procurement process and policy that is in line with Uniform Guidance. Staff identified to participate in the process will be trained as necessary.

View Audit 363889 Questioned Costs: $1

Finding 573006 (2024-002)

Material Weakness 2024

Southwest Center for Hiv/aids, INC

AZ

Questioned Costs Allowable Costs / Cost Principles Material Weakness § 200.405

Item: 2024-002 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Arizona Department of Health Services Compliance Requirement: Allowable Activities and Costs Criteria or ...

Item: 2024-002 Assistance Listing Number: 93.940 Programs: HIV Prevention Activities Health Department Based Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Arizona Department of Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In accordance with 2 CFR 200.405 - Allocable Costs - (d) If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: Costs charged to the federal program were based on an allocation methodology that was not properly updated for the current period Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2025 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. The Organization will update allocations timely going forward.

View Audit 363873 Questioned Costs: $1

Finding 573005 (2024-001)

Material Weakness 2024

Southwest Center for Hiv/aids, INC

AZ

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.405

Item: 2024-001 Assistance Listing Number: 93.914 Programs: HIV Emergency Relief Project Grants Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Maricopa County Department of Public Health Services Compliance Requirement: Allowable Activities and Costs Criteria or...

Item: 2024-001 Assistance Listing Number: 93.914 Programs: HIV Emergency Relief Project Grants Federal Agency: U.S. Department of Health and Human Services Pass-through Agency: Maricopa County Department of Public Health Services Compliance Requirement: Allowable Activities and Costs Criteria or Specific Requirement: In accordance with 2 CFR 200.405 - Allocable Costs - (d) If a cost benefits two or more projects or activities in proportions that can be determined without undue effort or cost, the cost must be allocated to the projects based on the proportional benefit. Condition: Costs charged to the federal program were based on an allocation methodology that was not properly updated for the current period. Name of Contact Person: Rosalie Johnson, Chief Financial Officer Phone Number: (602) 595-8109 Anticipated Completion Date: January 1, 2025 Views of Responsible Officials and Corrective Actions: Management agrees with the finding. The Organization will update allocations timely going forward.

View Audit 363873 Questioned Costs: $1

Finding 572979 (2024-001)

Significant Deficiency 2024

King County Public Hospital District #2 Dba Evergreen Healthcare

WA

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.303 § 200.403

AUDIT FINDINGS 2024-001: In one of 25 selections for testwork over period of performance, expenditures related to contract labor were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) that were outside of the project period. Further, the review performed over expenditure...

AUDIT FINDINGS 2024-001: In one of 25 selections for testwork over period of performance, expenditures related to contract labor were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) that were outside of the project period. Further, the review performed over expenditures was not completed appropriately to identify this error, this is an instance of the District’s internal control not operating as designed. Name of Contact Person: Daria Heimerman, Director of Financial Reporting, dtheimerman@evergreenhealthcare.org Corrective Action Planned: Assess process and controls for improvements to identify expenditures incurred outside of the designated project period. Anticipated Completion Date: August 2025 Statement of Concurrence or Nonconcurrence: Management concurs with audit finding 2024-001.

View Audit 363843 Questioned Costs: $1

Finding 572630 (2024-002)

Significant Deficiency 2024

Housing Authority of the City of Tampa, Florida

FL

Questioned Costs HUD Housing Programs Cash Management § 200.302 § 200.305

Action Taken: Management agrees with the finding noted above. Management will also note that as a repeated finding we do not so much offer a corrective action plan as we do a summarization of steps already taken to close this finding for fiscal 2025. A new and highly qualified Chief Financial Office...

Action Taken: Management agrees with the finding noted above. Management will also note that as a repeated finding we do not so much offer a corrective action plan as we do a summarization of steps already taken to close this finding for fiscal 2025. A new and highly qualified Chief Financial Officer with over 30 years of public housing experience was hired by the agency in April of 2024. The CFO has fully staffed the department with competent and qualified individuals including a new and fully qualified Controller and Director of Finance. All individuals hired have received targeted training from both internal and external sources. In June 2024 the new financial management team implemented a policy/procedure for the records requirement and payment timeframes for all capital fund draw downs. This policy requires the hand signing of eLOCCS forms and reconciliation of individual draws at the time of drawdown. During fiscal 2025 the entire Finance staff was trained extensively on all matters related to HUD accounting. Specific training was directed to the Capital Fund program, its eligibility standards, accounting processes, and drawdown procedures. This training was conducted by a nationally recognized HUD-specific trainer. The Authority has hired a qualified, experienced internal auditor. The internal auditor has completed a 100% testing sample on capital fund draws made in fiscal 2025. His observations were rectified, and the policy revised where needed. The sampling assured that supporting documentation was sufficient for audit, that it matched the amounts drawn, and that invoices were paid within HUD dictate s timeframes. Management feels that with this policy and enhanced testing in place the finding will not be repeated in 2025. Management expects closure of this finding, under the direction of the Chief Financial Officer, for the Fiscal 2025 audit.

View Audit 363741 Questioned Costs: $1

Finding 572580 (2024-001)

Significant Deficiency 2024

Habibi Terrace, Inc.

CA

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Name of auditee: Habibi Terrace, Inc. HUD auditee identification number: 143-EE054-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on...

Name of auditee: Habibi Terrace, Inc. HUD auditee identification number: 143-EE054-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-001: During the year ended December 31, 2024, the Corporation withdrew $5,980 from the reserve for replacements without obtaining HUD approval. Comments on the Finding and Each Recommendation: Management should make a deposit to the reserve for replacements for $5,980. Action(s) taken or planned on the finding: Management will make a deposit of $5,980 during the year ended December 31, 2025.

View Audit 363712 Questioned Costs: $1

Finding 572504 (2024-001)

Significant Deficiency 2024

Housing Resources, Inc.

WI

Questioned Costs Procurement, Suspension & Debarment § 200.320

Corrective Action Plan: Housing Resources, Inc. will review and update the current procurement policy to clarify competitive bidding thresholds and approval process for single source purchases. Once approved by the organization’s Board of Directors, the policy will be reviewed with all staff. Additi...

Corrective Action Plan: Housing Resources, Inc. will review and update the current procurement policy to clarify competitive bidding thresholds and approval process for single source purchases. Once approved by the organization’s Board of Directors, the policy will be reviewed with all staff. Additionally, we will identify a specific staff person to manage vendor and contractor relationships including solicitation, bid process, selection, onboarding, etc. Documentation will be kept throughout the process should bids be required. Anticipated Corrective Action Plan Completion Date: October 31, 2025 Contact Information: For additional information regarding this finding please contact Trena Bond, Executive Director, at (414)461-6330.

View Audit 363651 Questioned Costs: $1

Finding 572460 (2024-001)

Significant Deficiency 2024

Housing Authority of the City of Greensboro

NC

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Finding 2024-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files - Noncompliance & Significant Deficiency – Housing Choice Voucher Program – ALN #14.871 The Greensboro Housing Authority (GHA) continues the implementation of systems and processes to correct i...

Finding 2024-001 – Housing Choice Voucher Tenant Files – Eligibility – Internal Control over Tenant Files - Noncompliance & Significant Deficiency – Housing Choice Voucher Program – ALN #14.871 The Greensboro Housing Authority (GHA) continues the implementation of systems and processes to correct internal control of participant files in the Housing Choice Voucher Program (HCVP) with the following actions: GHA will continue to have external and internal third-party reviews of select file samples ongoing throughout the year for the purpose of identifying each of the items stated in the above finding along with other potential areas for risk. GHA has implemented accountability measures through a two-pronged approach of quality control and quality assurance checks at both the division and department levels to verify the accuracy of calculations and the completeness of program participant files. GHA has also revised and updated its file readiness checklist to ensure consistent file quality and adherence to stated protocols. GHA will continue to provide internal and external training for HCV team members. Based on the results of independent and internal reviews, we have identified specific areas for ongoing training and development. We have also targeted specific individuals who need additional development and focused training. GHA has initiated and will continue implementing the latest module(s) within its corporate software platform (YARDI). This will result in streamlining and automation of the HCV process. These upgrades and enhancements will include eligibility, intake, inspection and recertification workflows which will minimize and even mitigate specific errors that have been identified above. As a result, we will have an effective increase in both quality control and quality assurance within the entire HCV process. Anticipated Completion Date: The above plans will be implemented immediately and will be continuously monitored. We anticipate a completion date of no later than December 31, 2025. Responsible Parties: Meredith J. Daye, Chief Operating Officer Donna Mills, Vice President of Voucher Administration

View Audit 363610 Questioned Costs: $1

Finding 572452 (2024-002)

Material Weakness 2024

Boys and Girls Club of Lawrence

KS

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.317 § 200.403

2024-002 Unnecessary spending of federal awards Federal Agency: U.S. Department of Treasury Pass Through Entity: Child Care Aware of Kansas Program Name: Coronavirus State and Local Recovery Funds (COVID-19) Assistance Listing Number: 21.027 Award Period: March 12, 2020 to June 30, 2023 Recommen...

2024-002 Unnecessary spending of federal awards Federal Agency: U.S. Department of Treasury Pass Through Entity: Child Care Aware of Kansas Program Name: Coronavirus State and Local Recovery Funds (COVID-19) Assistance Listing Number: 21.027 Award Period: March 12, 2020 to June 30, 2023 Recommendation: Policies and Procedures should be implemented for expenditures related to significant long-term commitments to undergo proper vetting to ensure the expense necessary prior to purchase. Action Taken (Unadutied): Management intends to enhance controls over the procurement process to require approval by Board of Directors for all purchase commitments exceeding a defined threshold. Contact Name – Ozel Soykan, Director of Finance Expected completion date – 12/31/2025 If the U.S. Department of Treasury has questions regarding this plan, please call Ozel Soykan at 785-423-2098.

View Audit 363590 Questioned Costs: $1

Finding 572431 (2024-001)

Significant Deficiency 2024

Wisconsin Coalition Against Sexual Assault Inc.

WI

Questioned Costs Allowable Costs / Cost Principles

2024-001 Inadequate Documentation Criteria: Under Uniform Guidance, costs charged to federal programs need to be supported with proper documentation and reviewed to make sure they’re accurate, necessary, and allowed. Condition: During our testing of reimbursement and cost allocations charged to fede...

2024-001 Inadequate Documentation Criteria: Under Uniform Guidance, costs charged to federal programs need to be supported with proper documentation and reviewed to make sure they’re accurate, necessary, and allowed. Condition: During our testing of reimbursement and cost allocations charged to federal awards, we noted multiple instances where documentation supporting the expenditures was incomplete or missing. Specifically: • Several allocations lacked invoices or receipts to support the claimed amounts. • Mileage reimbursements were not recalculated or independently reviewed before payment. • A charge of $410 was identified as fraudulent but was still charged to a federal grant. Cause: The organization’s internal review procedures over cost allocations and reimbursements were not consistently applied. Questioned Costs: We identified $1,101 in costs that may not be allowable. Effect: Without proper documentation and review, there’s a greater risk that unallowable costs could be charged to the grant, which may result in questioned costs or repayment. Auditor’s Recommendation: We recommend that the organization strengthen its internal control procedures related to cost allocation and reimbursement by: • Requiring complete supporting documentation (e.g., invoices, receipts) for all claimed costs. • Implementing formal review and approval processes. • Training staff responsible for reimbursement requests and approvals on federal requirements. Grantee Response: WCASA acknowledges the finding and has since transitioned to a new financial services provider with strong knowledge of our systems and Uniform Guidance requirements. As part of this transition, additional procedures have been established to ensure proper documentation and review, including: • Requiring documentation for all reimbursement requests • Training personnel on federal requirements for allowable costs • Strengthening the review and approval process

View Audit 363567 Questioned Costs: $1

Finding 572350 (2024-001)

Significant Deficiency 2024

Metropolitan Transportation Authority

NY

Questioned Costs Allowable Costs / Cost Principles Cash Management

FEDERAL AWARDS—CORRECTIVE ACTION PLAN REFERENCE # 2024-001 Federal Transit Cluster - ALN Number: 20.507; 20.525; and 20.526 Contract Number: C40261TECHINSP; C33941EFA-MTAB; C40265TECH-MTAB; U3NY-2023-101-02 and U9NY-2018-059-01 Significant Deficiency-Non-Compliance Agen...

FEDERAL AWARDS—CORRECTIVE ACTION PLAN REFERENCE # 2024-001 Federal Transit Cluster - ALN Number: 20.507; 20.525; and 20.526 Contract Number: C40261TECHINSP; C33941EFA-MTAB; C40265TECH-MTAB; U3NY-2023-101-02 and U9NY-2018-059-01 Significant Deficiency-Non-Compliance Agency: U.S. Department of Transportation Criteria: Activities Allowed/Allowable Costs/Cost Principles including Indirect Costs––Direct - As stated in Uniform Grant Guidance - §200 Requirements for Allowable Costs: a. Costs did not consist of improper payments, including (1) payments that should not have been made or that were made in incorrect amounts (including overpayments and underpayments) under statutory, contractual, administrative, or other legally applicable requirements; (2) payments that do not account for credit for applicable discounts; (3) duplicate payments; (4) payments that were made to an ineligible party or for an ineligible good or service; and (5) payments for goods or services not received (except for such payments where authorized by law). Condition/Context: The MTA has Activities Allowed/Allowable Costs/Cost Principles including Indirect Costs procedures in place. MTA has corporate policies and procedures regarding Activities Allowed/Allowable Costs. We tested the Federal Transit Cluster’s Allowable Costs compliance. Based on our review of sixty samples related to Personnel Services and Other than Personnel Services for this cluster, we noted that four samples related to an MTA Bus Company personnel’s hourly rate were charged at higher rate. We noted that the rate per personnel file and employee payroll register differs from the actual rate used by the agency to charge labor costs. The agency calculated labor cost using the annual earnings that is divided by 52 weeks because there are 52 weeks a year, but MTA payroll department used 52.1428 weeks based upon 365/7 days a week, which created variances in labor costs billed and actual recorded labor costs. For Contract # - U3NY-2023-101-02 and U9NY-2018-059-01 – We noted two instances of sixty samples reviewed where the agency used 2023 approved overhead rate of 98.18% instead of the 2024 approved overhead rate of 98.98%. Recommendation: We recommend that MTA ensure that all personnel are reviewed and should be charged at the correct hourly rates as required by §200 CFR Subpart E – Allowable Costs. We also recommend that approved indirect rate applied to direct costs. Corrective Action Plan: MTA Bus will work with the project team to implement the correct rate and calculate the variance. MTA Bus will return the credit to the FTA as needed. Going forward, MTA Bus will review the employee wage rates from the official data sources to ensure that the correct rates are applied. SIR Finance will ensure that the overhead rates on the labor sheets are reflecting the correct percentage by adding a "verification measure" to a checklist while performing internal audits and approvals of the invoices prior to submission. Additionally, SIR-Finance will adjust the formatting within the invoice spreadsheets for easier visibility to a potential error in the calculated overhead percentage. Action Date: MTABUS – 1ST QUARTER 2026 SIRTOA - Effective Immediately - on July 2025 Invoices Final Implementation Date: MTABUS – 2ND QUARTER 2026 SIRTOA – July 2025 Name And Phone Number of Person Responsible For Implementation: MTABUS Marixsa Rivera Assistant Budget Chief • Project Development 718-927-8056 SIRTOA Marissa Rand Assistant Director, Finance & Timekeeping - SIR 347-694-6448

View Audit 363411 Questioned Costs: $1

Corrective Action Plans

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