Corrective Action Plans

Finding 39683 (2022-003)

Significant Deficiency 2022

IL

Questioned Costs Eligibility

Findings 2022 ? 003 Emergency Rental Assistance (ERA) Program Federal Assistance Listing # (21.023) ? Allowable Costs/Eligibility Corrective Action Plan: ...

Findings 2022 ? 003 Emergency Rental Assistance (ERA) Program Federal Assistance Listing # (21.023) ? Allowable Costs/Eligibility Corrective Action Plan: Key considerations are: Treasury added flexibility between the ERA 1 and 2 programs relaxed the burden of proof necessary for applicants to qualify for funding. 1. The reduction of burden and qualifications allowed for self-attestation, third party income verification or certification, and internal policies to reduce burden as supported by the Treasury. 2. Rental payments calculations and assumptions on timing may not have taken into consideration the FAQ guidance covering overall ceilings on payments in ERA I funding once ERA II was in place, which allowed for an 18-month cap on both funding sources. DPD will continue to work towards recovering over-allocations to awardees and initiate collection efforts directed towards owners and landlords. As we finalize the ERA II program by September 2024, DPD will reconcile the payment status of the ERA II awardees and notify awardees of overpayment and repayment requirements. Please reference the following: ERA-FAQ and ERA Questions. https:www.google.com/url?sa=t&source=web&rct=j&url=https:home.treasury.gov/system/files/136/ERA-FAQ-8-25-2021.pdf&ved=2ahUKEwjZ05HLjOL_AhVEkmoFHaXiAMwQFnoECCIQAQ&usg=AOvVaw1SKQl-IN3zig70bkVCxj9C

View Audit 37825 Questioned Costs: $1

Finding 39672 (2022-004)

Material Weakness 2022

Westwood Community School District

MI

Questioned Costs Allowable Costs / Cost Principles Cash Management

The District concurs with the finding. The District will implement procedures to ensure compliance with the allowability requirements.

View Audit 37977 Questioned Costs: $1

Finding 39658 (2022-001)

Significant Deficiency 2022

Odd Fellows South Oak Building CORP

NE

Questioned Costs HUD Housing Programs Cash Management

Comments on the Finding and Each Recommendation: The required deposit of $66,982, per the December 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts, was not deposited into the Residual Receipts Fund within 90 days of fiscal year end. The Regulatory Agreement requires Surpl...

Comments on the Finding and Each Recommendation: The required deposit of $66,982, per the December 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts, was not deposited into the Residual Receipts Fund within 90 days of fiscal year end. The Regulatory Agreement requires Surplus Cash, as defined by HUD, to be deposited into a separate Residual Receipts Fund within 90 days of fiscal year end. As a result, the Corporation was not in compliance with the Regulatory Agreement. Management should monitor the Surplus Cash position and make required deposits to the Residual Receipts Fund within 90 days of fiscal year end. Action(s) taken or planned on the finding: Management deposited the $66,982 to the Residual Receipts Fund on May 13, 2022. No further action is required.

View Audit 37823 Questioned Costs: $1

Finding 39654 (2022-002)

Significant Deficiency 2022

Keystone Place Housing Corporation

MO

Questioned Costs HUD Housing Programs Reporting

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2022 Name of Audit: Keystone Place Housing Corporation HUD Project Number: 084-HD063 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ending December 31, 2022 Corrective Action Plan Prepared by: Name: Rodney Potter Posit...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2022 Name of Audit: Keystone Place Housing Corporation HUD Project Number: 084-HD063 Name of Audit Firm: Welch & Associates, LLC Period Covered by Audit: Year Ending December 31, 2022 Corrective Action Plan Prepared by: Name: Rodney Potter Position: Assistant Executive Director Telephone Number: (816) 364-3827 Findings-Financial Statement Audit None Findings-Federal Award Programs Audit Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Supportive Housing for Persons with Disabilities ? Section 811 Assistance Listing Number: 14.181 Finding 2022-002 Comments on Findings and Each Recommendation Keystone Place Housing Corporation agrees with the auditors? finding and recommendation. Action(s) Taken or Planned on the Finding We will ensure a current and approved HUD Form 9839-B is on file. The form has been submitted to HUD for approval on March 22, 2023.

View Audit 36917 Questioned Costs: $1

Finding 39649 (2022-001)

Material Weakness 2022

Little Rock School District

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.439

Finding 2022-001 Allowable Costs/Cost Principles Criteria or Specific requirement: Purchases of equipment and other capital expenditures require the written approval of the Federal awarding agency or pass-through entity, as specified in Office of Management and Budget (OMB) 2 CFR section 200.439. ...

Finding 2022-001 Allowable Costs/Cost Principles Criteria or Specific requirement: Purchases of equipment and other capital expenditures require the written approval of the Federal awarding agency or pass-through entity, as specified in Office of Management and Budget (OMB) 2 CFR section 200.439. Condition: In our test of equipment purchases from the COVID-19 Education Stabilization Fund, we identified the purchase of 447 pieces of equipment with the unit costs greater than the $5,000 threshold for which the District did not obtain prior written approval from the Arkansas Division of Elementary and Secondary Education (DESE). Retroactive approval was subsequently obtained from DESE during the audit fieldwork. LRSD Response: The District will continue to monitor internal controls in regards to use of ESSER funds and ensure all prior approvals are granted by DESE before purchasing of capital assets with a unit value equal to or greater than $5,000. Responsible LRSD Staff: Kelsey Bailey, CDFO, will be responsible for ensuring compliance. Completion Date: Kelsey Bailey has made contact with Jayne Greene at DESE for guidance and retroactive approval was granted from DESE on March 9, 2023. Please let me know if additional information is needed. Respectfully, Kelsey Bailey Chief Deputy Finance & Operations Officer

View Audit 37215 Questioned Costs: $1

Finding 39622 (2022-003)

None 2022

Central Dewitt Community School District

IA

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management § 200.313

The District will review current processes for purchasing equipment within Iowa Department of Education approval amounts or seek amendments when approval cost limits cannot be met. June 30, 2023 Cyndie Johnson

View Audit 46139 Questioned Costs: $1

Finding 39615 (2022-001)

Material Weakness 2022

Bickford Street Elderly Housing Corporation

MA

Questioned Costs HUD Housing Programs

Department of Housing and Urban Development Finding No. 2022-001 Unauthorized Distributions; Assistance Listing Number 14.157 Supportive Housing for the Elderly Recommendation: The Sponsor should immediately reimburse the amount due to the Project and establish procedures to ensure payments of this ...

Department of Housing and Urban Development Finding No. 2022-001 Unauthorized Distributions; Assistance Listing Number 14.157 Supportive Housing for the Elderly Recommendation: The Sponsor should immediately reimburse the amount due to the Project and establish procedures to ensure payments of this nature are not made in the future. Corrective Action: The Sponsor has repaid the fees to the Project as requested by HUD.

View Audit 44829 Questioned Costs: $1

Finding 39593 (2022-001)

None 2022

Rutgers, the State University of New Jersey

NJ

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.430

Management agrees with the finding. The noted PI circumvented existing internal controls, all of which performed as designed to ensure financial compliance and grants stewardship. Management recognizes the opportunity to ensure that PIs are aware of the University?s grant accounting policies and pra...

Management agrees with the finding. The noted PI circumvented existing internal controls, all of which performed as designed to ensure financial compliance and grants stewardship. Management recognizes the opportunity to ensure that PIs are aware of the University?s grant accounting policies and practices as well as federal policies through formal trainings. Research Financial Services, and the Office for Research will work closely with the Chancellor led units to create and enforce trainings for our university faculty and researchers. Management will also investigate opportunities to reduce opportunities to circumvent controls.

View Audit 37104 Questioned Costs: $1

Finding 39590 (2022-003)

Significant Deficiency 2022

Rutgers, the State University of New Jersey

NJ

Questioned Costs Reporting Significant Deficiency

Rutgers University-Newark made the decision to use some of their institutional HEERF funds as direct payments to student accounts in order to both reduce the burden on students and as a reimbursement to the University for outstanding student receivables. The University?s understanding was that fund...

Rutgers University-Newark made the decision to use some of their institutional HEERF funds as direct payments to student accounts in order to both reduce the burden on students and as a reimbursement to the University for outstanding student receivables. The University?s understanding was that funds used in this manner from the institutional portion of HEERF funds did not require student consent. The finding has pointed out that information did exist in an FAQ, which clarifies that when using institutional HEERF funds in this manner student consent is required. Going forward we will change our policy so when applying any HEERF funds to student receivables as a direct grant to the student, a consent process will be in place that allows students to authorize the University to reduce their outstanding charges. Moving forward, the consent and distribution process for any direct student grants, including institutional HEERF funds, will be moved under University Enrollment Services which will ensure that the proper distribution of funds occurs and that internal controls are in place so that the awarding criteria are adhered to across all student recipients.

View Audit 37104 Questioned Costs: $1

Finding 39587 (2022-002)

Significant Deficiency 2022

Lima Ecumenical Housing Corporation Dba Pilgrim Place Apts 043-11199

OH

Questioned Costs HUD Housing Programs Cash Management

Comments on the Finding and Each Recommendation: The required deposit of $15,276, per the July 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts, was not deposited into the residual receipts fund within 90 days of fiscal year end. The Regulatory Agreement requires Surplus C...

Comments on the Finding and Each Recommendation: The required deposit of $15,276, per the July 31, 2021 Computation of Surplus Cash, Distributions and Residual Receipts, was not deposited into the residual receipts fund within 90 days of fiscal year end. The Regulatory Agreement requires Surplus Cash, as defined by HUD, to be deposited into a separate residual receipts fund within 90 days of the fiscal year end. The Corporation was not in compliance with the Regulatory Agreement. Management should monitor the Surplus Cash position and make required deposits to the residual receipts fund within 90 days of fiscal year end. Action(s) Taken and Planned on the Finding: Management deposited the $15,276 to the residual receipts fund on May 31, 2022. No further action is required.

View Audit 37873 Questioned Costs: $1

Finding 39490 (2022-002)

Significant Deficiency 2022

Human Solutions, Inc.

OR

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency § 200.403

2022-002 Federal Awards and Questioned Costs Finding Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Recovery Funds AL Number: 21.027 Statement of Condition: Noncompliance and Significant Deficiency in Internal Control Over Compliance related to Allowabl...

2022-002 Federal Awards and Questioned Costs Finding Federal Agency: U.S. Department of Treasury Federal Program: Coronavirus State and Local Recovery Funds AL Number: 21.027 Statement of Condition: Noncompliance and Significant Deficiency in Internal Control Over Compliance related to Allowable Costs. Criteria: Two expenses charged to the program were not properly supported in accordance with regulations. According to section 2 CFR 200.403, charges to Federal awards must be adequately documented. The Organization should have internal controls in place to comply with requirements of the award and federal requirements to ensure amounts charged to Federal awards are allowable, accurate and properly allocated. Context and Cause: The Organization was unable to locate two receipts of 25 expenditures tested under AL #21.027. Recommendation: The Organization should follow the Uniform Grant Guidance for Allowable Costs and their internal policy for retaining documentation related to federal expenditures. View of responsible officials: We concur with the recommendation. We are planning to implement a new software which will track receipts and report the completeness of documentation. Tanja Lux, CFO and Andrew Mills, Accounting Manager, will be responsible for implementation of the new system.

View Audit 46555 Questioned Costs: $1

Finding 39483 (2022-004)

Significant Deficiency 2022

School District of Colby

WI

Questioned Costs Cash Management Matching / Level of Effort / Earmarking

2022-004 ? Education Stabilization Fund ? Prevailing wage rate requirements Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages ...

2022-004 ? Education Stabilization Fund ? Prevailing wage rate requirements Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts, subject to wage rate requirements, a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Condition: There was one Education Stabilization Fund construction project performed by a subcontractor. Grant expenditures for the project paid by the Education Stabilization Fund totaled $263,826. There was not a prevailing wage clause in the contract and certified payrolls were not received. Cause: The District was not aware that wage rate requirements applied to the construction project until after it was completed. The District did verify that prevailing wage rates were paid by the contractor during the project; however, they did not obtain certified payrolls. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $263,826 Auditor?s Recommendation: Establish controls to comply with wage rate requirements related to the Education Stabilization Fund. Grantee Response: The District will comply with the wage rate requirements for the Education Stabilization Fund going forward. Contact Person: Brian Zaleski Anticipated Completion: June 30, 2023

View Audit 45766 Questioned Costs: $1

Finding 39424 (2022-001)

None 2022

Ochsner Clinic Foundation

LA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.406 § 200.84

Finding 2022-001: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. During the cou...

Finding 2022-001: Disaster Grants ? Public Assistance (Presidentially Declared Disasters) (Assistance Listing #97.036) Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. During the course of the Ochsner Clinic Foundation Uniform Guidance (UG) Audit for the Year Ended December 31, 2022, EY identified the following finding, as reported in the Schedule of Findings and Questioned Costs: Finding 2022-001 - Noncompliance over activities allowed or unallowed, allowable costs/cost principles, and period of performance related to amounts reimbursed for project worksheets. This finding is associated with application numbers PA-06-LA-4611-PW-01437 and PA-06-LA-4611-PW-01457. Both of these Project Worksheets (PWs) are for external security services that Ochsner procured in the aftermath of Hurricane Ida. These PWs included a population of 130 expenditures (invoices) for a total value of $923,105 (total value factoring in the cost share was $888,900). FEMA obligated these PWs and payment was remitted to Ochsner (via GOHSEP) for the full cost share amount of $888,900. As part of their testing over activities allowed or unallowed, allowable costs/cost principles, and period of performance, EY selected a sample of 45 items from this population ? 21 for testing over activities allowed or unallowed and allowable costs/cost principals and 24 for testing over period of performance. Through their testing, EY identified certain expenditures in the sample that were not reduced for all applicable credits (i.e., the vendor provided a credit back to Ochsner for a previously paid invoice). As a result of these items identified in the sample, Management evaluated the entire population of expenditures, and identified $99,285 as the difference between the submitted expenditures value to FEMA and the expenditures value after reducing for all applicable vendor credits. Ochsner did not identify these discrepancies when the PWs were filed with FEMA because the vendor invoices were used as the basis for the estimate of the claims, which is consistent with FEMA?s requirements. These vendor invoices reflected the full amounts billed by the vendor and did not reflect any credits that ultimately resulted in lesser amounts being remitted to the vendor at time of payment. The discrepancies that EY identified during the UG audit would have been identified, as is usually done, by either Ochsner or by FEMA / GOHSEP during the normal closeout process for these PWs, as discussed within the Public Assistance Program and Policy Guide (Version 4, Effective June 1, 2020) - Chapter 12: Final Reconciliation and Closeout. As part of this standard process, Ochsner will be required to provide proof of payment to FEMA / GOHSEP as part of the closeout process, at which time these discrepancies would have been identified. In order to cure this finding, Ochsner will reach out to FEMA / GOHSEP to self-report the issue and ask that these PWs be moved to closeout (this can be done because both PWs have been paid in full). Ochsner will also work with FEMA / GOHSEP to refund the total overpayment of $99,285 ? either via direct payment or reduction of future reimbursement under Ochsner?s other outstanding PWs with FEMA for COVID-19 and Hurricane Ida. For future FEMA claims, Ochsner will continue to work to ensure that PWs are reduced for all applicable credits using the most accurate information available ? either at the time the PWs are submitted or during closeout. Responsible Official: Scott Whitfield, Ochsner Assistant Vice President - Treasury Anticipated Completion Date: December 31, 2023

View Audit 36845 Questioned Costs: $1

Finding 39339 (2022-001)

Significant Deficiency 2022

North Central Michigan College

MI

Questioned Costs Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN The compliance audit identified one finding, which is described in the Schedule of Findings and Questioned Costs. We evaluated this matter as described below and have described our corrective action as a result. 2022-001 ? Grant Funds Used for Executive Salaries and Benefit...

CORRECTIVE ACTION PLAN The compliance audit identified one finding, which is described in the Schedule of Findings and Questioned Costs. We evaluated this matter as described below and have described our corrective action as a result. 2022-001 ? Grant Funds Used for Executive Salaries and Benefits Planned Corrective Action. Finding 2022-001 was a result of College management not being aware that the HEERF grant funds could not be used for executives? salaries and benefits. As a result, the College will verify all future expenditures meeting applicable guidelines prior to using the grant funds. The College will additionally ensure that the questioned costs are repaid to the federal government or not draw down $34,007 of questioned costs when obtaining future funds. Responsible Party. Tom Zeidel, Vice President of Finance & Facilities Date of Planned Corrective Action. Effective immediately ? December 2, 2022 Management Assessment. We concur with the audit assessment regarding this matter.

View Audit 47973 Questioned Costs: $1

Finding 39050 (2022-002)

Material Weakness 2022

Converge, Inc.

MS

Questioned Costs Allowable Costs / Cost Principles Cash Management

Management agrees with the finding. The Organization has implemented a new reporting and approval process for submissions through the Payment Management System: ? A Detailed Statement of Activity is generated by the Director of Finance as soon as it is determined all revenues and expenditures have b...

Management agrees with the finding. The Organization has implemented a new reporting and approval process for submissions through the Payment Management System: ? A Detailed Statement of Activity is generated by the Director of Finance as soon as it is determined all revenues and expenditures have been recorded for the month. ? Report is reviewed and approved by Co-Executive Director. ? Director of Finance submits the reports in PMS and requests reimbursement. The Organization has hired a new Director of Finance with extensive experience in non-profit accounting.

View Audit 36881 Questioned Costs: $1

Finding 39049 (2022-001)

Material Weakness 2022

Converge, Inc.

MS

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Management agrees with the finding. The Organization is in the process of implementing a new compliance monitoring process: ? Subrecipients will receive their awards on a cost reimbursement basis. ? Subrecipient payments will be disbursed quarterly. ? Subrecipient payments will only be issued after...

Management agrees with the finding. The Organization is in the process of implementing a new compliance monitoring process: ? Subrecipients will receive their awards on a cost reimbursement basis. ? Subrecipient payments will be disbursed quarterly. ? Subrecipient payments will only be issued after submission, review, and approval of required financial and performance reports. Moving to a cost reimbursement model will reduce the risk of overstating the Organization?s revenue and expenditures and motivate subrecipients to record and submit detailed data on a quarterly basis. This new model will be effective for the grant year beginning April 1, 2023 and a memo of change is being distributed to subrecipients under contract. The Organization will work with the granting agency to determine whether the Organization will pay back the funds or will be allowed to carry them forward to the next period.

View Audit 36881 Questioned Costs: $1

Finding 38974 (2022-002)

Significant Deficiency 2022

Northeast Indiana Innovation Center, Inc. and Affiliates

IN

Questioned Costs Allowable Costs / Cost Principles § 200.302 § 200.403

Unallowable Costs Planned Corrective Action: This finding occurred due to the fact that hours entered on a form-stack form by several contractors on our Community Navigator Program with the SBA were charged to the SBA before invoices were received from the contractor for those hours. This led to pay...

Unallowable Costs Planned Corrective Action: This finding occurred due to the fact that hours entered on a form-stack form by several contractors on our Community Navigator Program with the SBA were charged to the SBA before invoices were received from the contractor for those hours. This led to payment being received prior to the contractor being paid. Although this was officially approved by the SBA prior to submitting the quarterly bill for our services under the contract, we recognize that this is not how it should be done according to government and accounting rules. Thus, we will undertake the following corrective action to ensure that this does not occur again. 1. We will ensure that invoices for these identified charges are received from the contractors and the contractors are paid the full amount owed. 2. We will ensure that reimbursable expenses are not charged on government contracts and grants until they are actually paid or spent. This does not include expenses that are allowed by contract to be billed in advance. 3. Both the lead accounting person and the Compliance Officer will review and authorize all charges for allowability on all programs prior to submission of a request for payment. 4. A periodic review of the process and process adherence will be conducted by the finance committee of the Board of Directors. Person Responsible for Corrective Action Plan: Jamie Thomas, Compliance Officer Anticipated Date of Completion: October 15, 2023

View Audit 37998 Questioned Costs: $1

Finding 38922 (2022-010)

Material Weakness 2022

Antelope Union High School District No. 50

AZ

Questioned Costs Equipment & Real Property Management Internal Control / Segregation of Duties

Type of Finding: Noncompliance, material weakness Condition/Context: The District did not ensure that monies spent on equipment were properly budgeted within the grant agreement and that ADE had prior approval of equipment purchases. Action planned in response to finding: The District will establish...

Type of Finding: Noncompliance, material weakness Condition/Context: The District did not ensure that monies spent on equipment were properly budgeted within the grant agreement and that ADE had prior approval of equipment purchases. Action planned in response to finding: The District will establish proper internal controls over property and equipment to ensure all equipment purchases are budgeted for within the grant agreement. Planned completion date for corrective action plan: For the period ending June 30, 2023. Name of the contact person responsible for corrective action: Aaron Whittle, Business Manager

View Audit 44342 Questioned Costs: $1

Finding 38921 (2022-009)

Material Weakness 2022

Antelope Union High School District No. 50

AZ

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Condition/Context: The District spent $12,772 of federal funding on video conferencing, COVID-19 testing, charging stations, fire and alarm testing, palm tree trimming, ADEQ monitoring, and a printer. These expenditures were not explicitly authorized within the budget approved by the passthrough age...

Condition/Context: The District spent $12,772 of federal funding on video conferencing, COVID-19 testing, charging stations, fire and alarm testing, palm tree trimming, ADEQ monitoring, and a printer. These expenditures were not explicitly authorized within the budget approved by the passthrough agency for the related grant. In addition, the District expended $31,500 in payroll for retention stipends that were not explicitly written into the budget approved by the passthrough agency. Lastly, for eleven of 25 general disbursements tested, an approved purchase order or requisition was not maintained to support the authorization of the purchase. Among those eleven purchases, five did not have invoices approved for payment. Action planned in response to finding: The District will establish proper internal controls over processing expenditures to ensure that only those expenditures that are allowed and approved within the budget be spent out of grant funds. Those expenditures should be approved within a purchase order and requisition and the related invoices should be approved for payment. Planned completion date for corrective action plan: For the period ending June 30, 2023.

View Audit 44342 Questioned Costs: $1

Finding 38908 (2022-001)

Significant Deficiency 2022

Gwinnett County Board of Commissioners

GA

Questioned Costs Subrecipient Monitoring § 200.516

U.S. Department of Treasury. Program Name: COVID 19: Emergency Rental Assistance Program. Assistance Listing Number: 21.023. Finding: 21.023. Criteria: In accordance with Uniform Guidance 2 CFR 200.516 - Audit Findings, known or likely fraud affecting a Federal Award, as well as known quest...

U.S. Department of Treasury. Program Name: COVID 19: Emergency Rental Assistance Program. Assistance Listing Number: 21.023. Finding: 21.023. Criteria: In accordance with Uniform Guidance 2 CFR 200.516 - Audit Findings, known or likely fraud affecting a Federal Award, as well as known questioned costs that are greater than $25,000 must be reported as audit findings in the schedule of findings and questioned costs. Condition: Although the County has controls in place to ensure compliance with their Emergency Rental Assistance Program's policies and procedures, which include fraud prevention procedures, fraud did occur. During 2022, the County discovered (and reported to the auditors) that eight (8) landlord applicants committed fraudulent activity that included the submission of documents that were modified electronically prior to their submission, stolen identity, misrepresentation and inability to repay funds within a timely manner. Funds were disbursed to these applicants prior to the County becoming aware of the fraud. Cause: Eight (8) landlord applicants committed fraudulent activity. Effects: Eight (8) applicants received funding, although the fraudulent activity was committed by the applicants. Questioned Costs: $144,692. Recommendation: We recommend the County strengthen procedures and/or implement additional procedures to reduce the potential of fraud occuring. Auditee's Reponse: In addition to continuing to follow the County's policies and procedures developed in accordance with Emergency Rental Assistance guidelines established by the U.S. Department of Treasury, the County implemented additional procedures in May 2022 to enhance fraud prevention activities. The updated procedures required HomeFirst Gwinnett, the subrecipient managing the Emergency Rental Assistance Program, to perform additional verification and approval procedures to detect fraudulent applications before they are presented for payment. HomeFirst Gwinnett would no longer accept documentation that had been completely generated electronically as sole proof of property ownership and added another level of file review of property deed records for landlord property owners utilizing the authorized property deed record website. All assistance above $10,000 will require final review/approval by the HomeFirst Gwinnet director or manager. As new applicants input their information into the County's vendor portal, the Treasury Division in the Department of Financial Services would verify the validity of those records and would not allow the registration to complete unless they met the required criteria. Any suspicious activity was reported to management promptly, and for suspected fraudulent applicants, those applicants accounts were locked as a preventative control so that no future transactions could be processed while the account was under investigation. For individual landlords, ACH payment was no longer an option and they were required to physically present present a valid picture ID to receive a check at the Program Office. Additional training on the revised procedures was provided to program staff. While the additional prevention measures noted above did deter fraudulent attempts made on the program, Gwinnett County tracked and reported eight landlord cases of suspected fraud in 2022. The suspected fraud was forwarded to the Gwinnett County Police Department's (GCPD) Financial Crimes Unit. Any funds recovered will be returned to the U.S. Department of the Treasury. Gwinnett County's emergency rental assistance program, Project RESET 2.0 (PR2.0), concluded on Thursday, December 29, 2022.

View Audit 38140 Questioned Costs: $1

Finding 38905 (2022-002)

Material Weakness 2022

Collaborative Solutions for Communities

DC

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.308 § 200.430

CSC?s management concurs with the finding. See Section IV- Current Year Corrective Action Plan.2022-002 Allowable Costs/ Cost Principles Name of Contact Person: Brenda Chandler and Johnny Mammen Corrective Actions: CSC has implemented a policy as of July 10, 2023, that ensures that personnel ar...

CSC?s management concurs with the finding. See Section IV- Current Year Corrective Action Plan.2022-002 Allowable Costs/ Cost Principles Name of Contact Person: Brenda Chandler and Johnny Mammen Corrective Actions: CSC has implemented a policy as of July 10, 2023, that ensures that personnel are hired after the positive background compliances confirmations are obtained along with the modification of internal controls to ensure CSC?s compliance with Federal statutes, regulations, and the terms and conditions of the federal award as stated in the grant requirements. The Human Resources Director will be responsible for implementing and monitoring this policy. Due to the new personnel in finance effective July 17, 2023, CSC will be able to ensure that all grants? receipts are supported by appropriate documentation for expenses incurred. The Senior Accountant will be supervised by the Director of Finance who will be responsible for the implementation of the corrective action. Proposed Completion Date: July 10, 2023 and July 17, 2023 Telephone Number: 202-517-6737

View Audit 38139 Questioned Costs: $1

Finding 38902 (2022-001)

Significant Deficiency 2022

Marion Senior Living, Inc.

NE

Questioned Costs HUD Housing Programs Cash Management

Finding #2022-001: Comments on the Finding and Each Recommendation: The required deposit of $16,084, per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts, was not deposited into the Residual Receipts Fund within 90 days of the fiscal year end. The Regulatory Agreeme...

Finding #2022-001: Comments on the Finding and Each Recommendation: The required deposit of $16,084, per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts, was not deposited into the Residual Receipts Fund within 90 days of the fiscal year end. The Regulatory Agreement requires Surplus Cash, as defined by HUD, to be deposited into a separate Residual Receipts Fund within 90 days of the fiscal year end. The Corporation was not in compliance with the Regulatory Agreement. Management should monitor the Surplus Cash position and make required deposits to the Residual Receipts Fund within 90 days of fiscal year end. Action(s) Taken or Planned on the Finding: Management deposited the $16,084 to the Residual Receipts Fund on March 31, 2022. The finding is considered cleared.

View Audit 38013 Questioned Costs: $1

Finding 38899 (2022-001)

Material Weakness 2022

Norwood Life Society

IL

Questioned Costs HUD Housing Programs Material Weakness

U.S. Department of Housing and Urban Development (?HUD?) Norwood Life Society respectfully submits the following corrective action plan for the year ended December 31, 2022. Audit period: January 1, 2022 to December 31, 2022 The findings from the schedule of findings and questioned costs are discuss...

U.S. Department of Housing and Urban Development (?HUD?) Norwood Life Society respectfully submits the following corrective action plan for the year ended December 31, 2022. Audit period: January 1, 2022 to December 31, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS Department of Housing and Urban Development 2022-001 Mortgage Insurance_Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities ? Assistance Listing No. 14.129 Recommendation: We recommend that the Project work with their Regional HUD representative to discuss the unauthorized loan to result in either approval or a plan for resolution. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Rick Steffens, the CFO, will oversee this plan, and the plan has been implemented and fully resolved. The unauthorized loan was due to an increasing intercompany balance due from an affiliated nursing home (?Bethesda?) who was losing money and unable to reimburse Norwood Crossing for shared bills for items including benefits and insurance. Due to the size of the losses, we realized this issue was unable to be resolved without disposing of Bethesda and began working on selling Bethesda in the second quarter of 2022. Bethesda was supposed to close on the sale on November 30, 2022, which would have solved the intercompany issue during the 2022 audit year, which was our plan. However, the sale was continuously delayed due to numerous serious issues pushing the actual sale date all the way back to July 1, 2023. The audit finding for the unauthorized intercompany loan was for $1,724,731.69. However, the intercompany balance continued to grow in 2023 and had an additional $574,583.86 of expenses that built up in 2023 before the sale occurred. This made a grand total of $2,299,315.55 that needed to be repaid from Bethesda to Norwood Crossing for the unauthorized intercompany loans through the sale date. Bethesda worked to repay the intercompany loans the best it could during 2023 before the sale occurred, and completely paid down the remaining balance on the unauthorized intercompany loans shortly after the sale of Bethesda occurred. The following payments were made from Bethesda to Norwood Crossing: Payment Dates Payment Amounts 5/8/2023 $675,000.00 5/23/2023 $350,000.00 7/17/2023 $1,274,315.55 Total $2,299,315.55 These repayments above fully resolved the unauthorized intercompany loans that were 1) in the 2022 Audit as a finding, and 2) increases that occurred in 2023 after the 2022 year end. Furthermore, Bethesda has officially been sold as of July 1, 2023 and is no longer causing this issue to continue to occur going forward. Name(s) of the contact person(s) responsible for corrective action: Rick Steffens Planned completion date for corrective action plan: July 17, 2023 If the Oversight Agency for Audit has questions regarding this plan, please call Rick Steffens at 773-577-5334.

View Audit 36683 Questioned Costs: $1

Finding 38843 (2022-001)

Material Weakness 2022

Labrae Local School District

OH

Questioned Costs Material Weakness

Finding Number 2022-001. Planned Corrective Action: District management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The District will implement a s...

Finding Number 2022-001. Planned Corrective Action: District management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant and loan requirements, including Schedule reporting requirements. The District will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. The treasurer did not use September 30th as the end date for the final expenditure reports (FER). The treasurer used September 9th as the end date and expenditures were incurred later in the month. When filing the FER in September, the Treasurer will make sure no more expenditures are incurred in September, after the FER is completed. Anticipated Completion Date: 6/30/2023. Responsible Contact Person: Bradley Panak

View Audit 34732 Questioned Costs: $1

Finding 38788 (2022-004)

Significant Deficiency 2022

Chilton County Board of Education

AL

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

Finding: Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "Davis-Bacon Act"), requires that any construction contract in excess of$2,000 that is funded wholly or in part by federal funds include prevailing wage rate clauses. ...

Finding: Title 29, U.S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "Davis-Bacon Act"), requires that any construction contract in excess of$2,000 that is funded wholly or in part by federal funds include prevailing wage rate clauses. The laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for locality of project (prevailing wage .. rates) by the Department of Labor (DOL) and the contractor or subcontractor must submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance ( certified payrolls). During fiscal year 2022, the Board entered into two construction project contracts that did not include prevailing wage rate clauses. As of September 30, 2022, the Board had expended $266,813.05 of COVID-19 Education Stabilization Funds (Elementary and Secondary School Emergency Relief) on these projects. The Board did not have controls in place to ensure the Davis-Bacon Act wage rate requirements were included in construction contracts, therefore, construction project contracts were awarded during the fiscal year that did not include prevailing wage rate clauses nor did the contractors submit weekly certified payrolls to the Board. As a result, the Board is not in compliance with the Davis-Bacon Act as it pertains to wage rate requirements. Recommendation: The Board should comply with Title 29, U. S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the "Davis--Bacon Act") when using COVID-19 Education Stabilization Funds (ESSER) to fund construction contracts in excess of $2,000. Response/Views: The board agrees with this finding. Contact Person(s): Cheri' Miley Wright, Interim CSFO/Freddy Smith, Maintenance Supervisor

View Audit 46229 Questioned Costs: $1

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