Corrective Action Plans

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to b...

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: nCASE has taken corrective measures in our accounting software by detailing the audit log and recording all changes with supporting documentation. There will be final weekly review and approval of the changes. nCASE also keeps a log of items that are backordered or have shipping delays. This log includes: item ordered, date ordered, and date shipped/charged. This corresponds to subsequent changes in the above- mentioned audit log. These measures are detailed in our policies and procedures. nCASE has obtained and put into practice, a log for detailing adjustments to journal entries that are included in our policies and procedures. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.

View Audit 365412 Questioned Costs: $1

Finding 575382 (2021-006)

Material Weakness 2021

National Center for the Advancement of Stem

PA

Questioned Costs Special Tests & Provisions Matching / Level of Effort / Earmarking § 200.303 § 200.308

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to b...

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: Management has established policies and procedures that define how personnel are to record involvement in project activities. These records are used to document time and labor for specific projects and in combination with time‐ keeping documentation will reflect this data in payroll documentation. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.

View Audit 365412 Questioned Costs: $1

Finding 575380 (2021-004)

Material Weakness 2021

National Center for the Advancement of Stem

PA

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

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to b...

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: nCASE will invoice for the indirect amount proportional only to the direct amount invoiced and only after the direct amount has been invoiced. Policy and procedure have been updated to reflect how this is invoiced. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.

View Audit 365412 Questioned Costs: $1

Finding 575379 (2021-003)

Material Weakness 2021

National Center for the Advancement of Stem

PA

Questioned Costs Allowable Costs / Cost Principles § 200.313 § 200.414

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to b...

Agency: National Center for the Advancement of STEM Education, Inc. (nCASE) Person Responsible for Corrective Action: Name: Nancy Priselac Title: Executive Director Anticipated Completion Date: December 8, 2023 Response to Finding: Management concurs with audit recommendation. Correction Action to be Taken: nCASE has written policies and procedures that detail how management is to review and approve documentation relating to payroll and how reports are created that confirm charges are accurate, allowable, and properly allocated as well as allow for clear comparisons to estimates. Management created timekeeping documents to track employee labor, time and effort. nCASE’s accounting system matches charges listed to documentation used to collect and record time and effort by employees and apply designations to its respective project/label. The system can track direct, indirect, and fringe benefit designations. Accounting data now allows management to create clear reports on payroll. nCASE has implemented documentation that allows employees to track time and labor in detail of project. Management has written policies and procedures that direct employees on how to record time and labor. DoD has reviewed the matters covered in the audit report thoroughly, and the grant was closed out without any repayment of funds to DoD. Upon subsequent review and reconciliation, amounts were not overcharged.

View Audit 365412 Questioned Costs: $1

Finding 574876 (2021-010)

Material Weakness 2021

City of East St. Louis, Illinois

IL

Questioned Costs Procurement, Suspension & Debarment § 200.317

The City acknowledges and agrees with the finding regarding procurement deficiencies during the administration of ARPA funds. Since the time covered by the audit, the City has taken significant steps to strengthen internal controls over procurement. A full-time Purchasing Manager has been appointed...

The City acknowledges and agrees with the finding regarding procurement deficiencies during the administration of ARPA funds. Since the time covered by the audit, the City has taken significant steps to strengthen internal controls over procurement. A full-time Purchasing Manager has been appointed to oversee and enforce compliance with both City and federal procurement standards. In addition, the City is currently updating its procurement policy to ensure clearer thresholds, detailed procedures for informal bidding, and approval workflows aligned with 2 CFR Part 200. All procurement staff are being trained on the revised procedures and control mechanisms. These updates are being documented, and we have introduced internal review checkpoints prior to purchase order execution. We are also developing a procurement checklist and digital authorization process to ensure documentation is complete before funds are obligated. This will prevent similar deficiencies from recurring.

View Audit 365135 Questioned Costs: $1

Finding 574737 (2021-010)

Material Weakness 2021

Claremont School District

NH

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303 § 200.334

The District did not provide a corrective action plan

View Audit 365056 Questioned Costs: $1

Finding 574736 (2021-009)

Material Weakness 2021

Claremont School District

NH

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303 § 200.334

The District did not provide a corrective action plan

View Audit 365056 Questioned Costs: $1

Finding 574654 (2021-007)

Significant Deficiency 2021

Virgin Islands Port Authority

VI

Questioned Costs Allowable Costs / Cost Principles § 200.303

The Authority will ensure that the management team will perform more stringent review of the allowable costs.

View Audit 364929 Questioned Costs: $1

Finding 571922 (2021-006)

None 2021

Choctaw County

OK

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.403

We will implement policies and procedures to ensure compliance with applicable grant requirements.

View Audit 362988 Questioned Costs: $1

Finding 565787 (2021-013)

Material Weakness 2021

Rogers County

OK

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.403

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with work with all elected officials and with the ...

The Board of County Commissioners, with the cooperation and participation of all elected officials, reviews, develops and implements policies and procedures to create a strong internal control environment. The Board of County Commissioners will work with work with all elected officials and with the state and local partners in each federal award to develop policies, procedures, and internal controls designed to accurately track grants, including the application process, verification, oversight, and reporting of grant requirements. These policies and procedures will be designed to identify requirements for recipients and sub-recipients of grants, ensure accurate equipment and real property management, procurement, recipient and subrecipient monitoring and reporting. Further, policies will ensure a proper understanding of all grant requirements and compliance of the same.

View Audit 359478 Questioned Costs: $1

Finding 558160 (2021-004)

Material Weakness 2021

Hill Country Community Clinic, Inc.

CA

Questioned Costs Allowable Costs / Cost Principles Reporting

Management acknowledges the finding. We will update and refine our grant policies and procedures to ensure that all grant expenses and revenue calculations comply with federal guidelines. A standardized review process will be implemented to validate expenditures, ensuring they are in alignment with ...

Management acknowledges the finding. We will update and refine our grant policies and procedures to ensure that all grant expenses and revenue calculations comply with federal guidelines. A standardized review process will be implemented to validate expenditures, ensuring they are in alignment with the grant’s budget and not reimbursed by other sources. Documentation standards will be reinforced to ensure proper support for all grant expenses and revenue calculations. The finance team will verify that all revenue calculations follow the accrual basis of accounting, as required by HHS guidance. We will implement internal review and approval processes before submitting future grant reports. Periodic internal audits will be conducted to confirm compliance with uniform guidance guidelines and identify any potential reporting discrepancies. A designated compliance officer or team will oversee federal grant reporting to ensure adherence to evolving federal requirements. Staff involved in federal grant reporting and financial management will receive targeted training on grant compliance requirements, including allowable costs, proper revenue calculations, and documentation best practices. Regular updates will be provided to finance and grants management personnel to ensure continued compliance with evolving federal regulations. Replacement COVID-19 related costs of $1,566,926 were identified to evidence the spend down of period one Provider Relief Funds. These funds are not subject to repayment as the Organization was able to attest and comply with the terms and conditions of the funding, including demonstrating that the distributions received were used for qualifying expenses or lost revenue attributable to COVID-19. The above corrective actions are currently being implemented.

View Audit 355035 Questioned Costs: $1

Finding 554383 (2021-003)

Significant Deficiency 2021

Vermont Seniors

CA

Questioned Costs

Management will transfer excess funds from the operating account to the reserve for replacements account and continue to work toward bringing the delinquent accounts current.

View Audit 353063 Questioned Costs: $1

Finding 544470 (2021-005)

Material Weakness 2021

City of Stonecrest, Georgia

GA

Questioned Costs Reporting Subrecipient Monitoring

Name of the Contact Person Responsible for the Corrective Action Plan: Gia Scruggs, City Manager Corrective Action Plan: The corrective action plan is more fully explained in the corrective actions specified in the corrective action plan for Finding 2021-004. City Finance Department staff, together ...

Name of the Contact Person Responsible for the Corrective Action Plan: Gia Scruggs, City Manager Corrective Action Plan: The corrective action plan is more fully explained in the corrective actions specified in the corrective action plan for Finding 2021-004. City Finance Department staff, together with the City Manager, are presently monitoring compliance and reporting relating to state and federal grants and program support. Third-party contractors will no longer be used for these tasks, and as more restricted funds are received by the City, the grants management team will be organized. Presently the City has only one federal grant program and one state program. Anticipated Completion Date: The corrective action plan has been implemented and a formal grants management plan is under consideration. The implementation is underway with staff positions authorized and was completed as of December 31, 2022.

View Audit 351144 Questioned Costs: $1

Finding 544469 (2021-004)

Material Weakness 2021

City of Stonecrest, Georgia

GA

Questioned Costs Allowable Costs / Cost Principles § 200.300 § 200.306 § 200.308 § 200.309 § 200.403

Name of the Contact Person Responsible for the Corrective Action Plan: Gia Scruggs, City Manager Corrective Action Plan: The private contractor engaged in 2017 to provide government management and operations services staffed the engagement with less than 40 staff including 5 consultants. The City, s...

Name of the Contact Person Responsible for the Corrective Action Plan: Gia Scruggs, City Manager Corrective Action Plan: The private contractor engaged in 2017 to provide government management and operations services staffed the engagement with less than 40 staff including 5 consultants. The City, since the termination of the services contract effective December 31, 2021, has 79 staff involved in City management and operations roles including 5 elected officials. The additional staff, including an additional 5 in accounting/finance, affords the City the capacity to effectively account for and report on restricted funds received in connection with state and federal grant programs. The City Manager staff has grown by an additional 3 staff persons from the contractor level that was assigned in 2021 to monitor grants providing sufficient City staff for current grant programs to be monitored and grant conditions complied with. As the City continues to be eligible for additional state and federal grants, a Grants Administrator position has been added to staff organization and the plan is to organize a grants management team devoted to reporting and compliance assurance as well as seeking to apply for state and federal grant and program funds. Anticipated Completion Date: City Finance Department staff, together with the City Manager, are presently monitoring compliance and reporting relating to state and federal grants and program support. Third-party contractors will no longer be used for these tasks, and as more restricted funds are received by the City, the grants management team will be organized. Presently, the City has only one federal grant program and one state program. The corrective actions have been implemented and are presently operative and in place

View Audit 351144 Questioned Costs: $1

Finding 530197 (2021-001)

Significant Deficiency 2021

Huntsville Memorial Hospital

TX

Questioned Costs Allowable Costs / Cost Principles Cash Management

U.S. Department of Health and Human Services 2021-001 Provider Relief Fund – Assistance Listing No. 93.498 Recommendation: We recommend that management implement a system that allows for easy identification of any copies of invoices paid. Explanation of disagreement with audit finding: There is no d...

U.S. Department of Health and Human Services 2021-001 Provider Relief Fund – Assistance Listing No. 93.498 Recommendation: We recommend that management implement a system that allows for easy identification of any copies of invoices paid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Huntsville Community Hospital, Inc. now operates under a full digitized accounting and payables system which allows them to pull any historical invoice copies as needed. Name(s) of the contact person(s) responsible for corrective action: Paul Hanson, CFO Planned completion date for corrective action plan: Huntsville Community Hospital, Inc. now operates under a full digitized accounting and payables system.

View Audit 348302 Questioned Costs: $1

Finding 526799 (2021-012)

Material Weakness 2021

Muskogee County

OK

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

Assistance Listing Number 21.019 Noncompliance Over Major Federal Program Coronavirus Relief Fund Activities Allowed or Unallowed and Allowable Costs/Cost Principles Chairman Board of County Commissioners: Muskogee County has hired an internal grant administrator to assist in keeping the county comp...

Assistance Listing Number 21.019 Noncompliance Over Major Federal Program Coronavirus Relief Fund Activities Allowed or Unallowed and Allowable Costs/Cost Principles Chairman Board of County Commissioners: Muskogee County has hired an internal grant administrator to assist in keeping the county compliant with all local, state, and federal requirements. Efforts will be made going forward to ensure that all grant funds are properly expended within the allowable period of performance. It should be noted that OMES did not review any of the submitted information to determine eligibility prior to sending reimbursements for items that have now been determined questionable. County Clerk: Documentation was scanned into the Purchase Order's images and once the Purchase Order was paid, the images were then deleted by the Board of County Commissioners secretary. Images were later recovered by the software system and since the incident, restrictions have been implemented to no longer allow deletions.

View Audit 345861 Questioned Costs: $1

Finding 526706 (2021-005)

Material Weakness 2021

City of McKeesport

PA

Questioned Costs Procurement, Suspension & Debarment § 200.318 § 200.320

CONDITION: The City of McKeesport contracted with Applied Concepts, Inc. for police trailers, and A&H Equipment for the purchase of a vactor truck. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold...

CONDITION: The City of McKeesport contracted with Applied Concepts, Inc. for police trailers, and A&H Equipment for the purchase of a vactor truck. These contracts individually exceeded the Uniform Guidance micro purchase threshold of $10,000, but did not exceed the Simplified Acquisition Threshold of $250,000. Both of these purchases were procured through a cooperative purchasing group (COSTARS). The City was unable to 1) provide records sufficient to detail the history of procurement for these two contracts and 2) provide documentation to verify that price or rate quotations were obtained from an adequate number of qualified sources.CRITERIA: Section 2 CFR 200.320(a)(2)(i) of the Uniform Guidance prescribes the bidding requirements for equipment, supplies, and work of any nature made by a non-federal entity whereby the cost exceeds certain dollar thresholds as adjusted periodically. In instances where the cost incurred exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, price or rate quotations must be obtained from an adequate number of qualified sources. In addition, as specified in 2 CFR 200. 318(i) of the Uniform Guidance, the City must maintain sufficient records to detail the history of procurement. • MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review and update as necessary its procurement policies to ensure In instances where the procurement cost incurred for goods and/or services exceeds the Uniform Guidance micro purchase threshold of $10,000 but does not exceed the Simplified Acquisition Threshold of $250,000, that 1) price or rate quotations are obtained from an adequate number of qualified sources, and 2) sufficient records are maintained to detail the history of procurement. The timeframe for completion of this review will occur during the first nine months of calendar year 2025 with the intention of having the City be in full compliance with Sections 2 CFR 200.320(a)(2)(i) and 2 CFR 200. 318(i) of the Uniform Guidance.

View Audit 345703 Questioned Costs: $1

Finding 526705 (2021-004)

Material Weakness 2021

City of McKeesport

PA

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.412

CONDITION: For the calendar year 2021, the City of McKeesport submitted a listing to the Department of Treasury, of eligible expenses for the Coronavirus State and Local Fiscal Recovery Federal Funding. This listing contained the ShotSpotter as referenced in Finding 2021-004 which was already reimb...

CONDITION: For the calendar year 2021, the City of McKeesport submitted a listing to the Department of Treasury, of eligible expenses for the Coronavirus State and Local Fiscal Recovery Federal Funding. This listing contained the ShotSpotter as referenced in Finding 2021-004 which was already reimbursed to the City as part of the Community Development Block Grant (CDBG) Program by the Department of Housing and Urban Development. CRITERIA: In accordance with Section 2 CFR 200.412 of the Uniform Guidance, federal expenses are prohibited from being charged to more than one federal program. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will review this eligible expense charged to the Coronavirus State and Local Fiscal Recovery Federal Funding Program, confirm that this is an expense that was already reimbursed by the Department of Housing and Urban Development for the benefit of the City’s CDBG Grant Program, and if so, consult with a representative from the Department of Treasury as to the procedure required to amend the quarterly report filings required to be filed with the Department of Treasury to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance. The timeframe for completion of this process is effective immediately.

View Audit 345703 Questioned Costs: $1

Finding 526701 (2021-003)

Material Weakness 2021

City of McKeesport

PA

Questioned Costs Procurement, Suspension & Debarment § 200.214

CONDITION: Per the on-site monitoring report of the City’s Community Development Block Grant (CDBG) Program performed by the Department of Housing and Urban Development dated May 15, 2024, the City purchased a device called ShotSpotter with CDBG contract B-20-MC-42-0106 funding in the amount of $99,...

CONDITION: Per the on-site monitoring report of the City’s Community Development Block Grant (CDBG) Program performed by the Department of Housing and Urban Development dated May 15, 2024, the City purchased a device called ShotSpotter with CDBG contract B-20-MC-42-0106 funding in the amount of $99,000. The City of McKeesport did not verify if the above vendor was on the excluded parties list in the System for Award Management through www.sam.gov. CRITERIA: In accordance with Section 2 CFR 200.214 of the Uniform Guidance, the City is subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict the awarding of contracts to certain parties that are debarred, suspended, or otherwise ineligible to participate in federal assistance programs. In addition, the City’s Community Development Block Grant Policies & Procedures Manual in Section VIII for procurement requires this step to be performed. MANAGEMENT’S CORRECTIVE ACTION PLAN: Management of the City will utilize the www.sam.gov website for determining whether contractors/vendors are debarred or suspended from participating in federal assistance programs on all future applicable contract awards to ensure compliance with Section 2 CFR 200.214 of the Uniform Guidance, and Section VIII of the City’s CDBG Policies & Procedures Manual for procurement. The City will save the results from the website search with each applicable vendor file to document compliance with these requirements. The timeframe for completion of this process is effective immediately.

View Audit 345703 Questioned Costs: $1

Finding 523531 (2021-001)

None 2021

National Council for Preservation Education

KY

Questioned Costs Eligibility Internal Control / Segregation of Duties

Recommendation: NCPE should have internal controls in place for the retention of federal program records. NCPE should also have procedures in place to allow for the review of an individual’s eligibility to receive a federal award. Response: NCPE’s Executive Committee hired a new manager in 2017 to ...

Recommendation: NCPE should have internal controls in place for the retention of federal program records. NCPE should also have procedures in place to allow for the review of an individual’s eligibility to receive a federal award. Response: NCPE’s Executive Committee hired a new manager in 2017 to create, track, and retain important records to comply with the terms and conditions of federal agreements. In addition to the application form completed by all interns, an award letter was introduced in 2019. The Award Letter is sent by the National Park Service (NPS) site supervisor to the successful candidate, with NCPE copied, to confirm their appointment and provide essential details about the internship like duration, rate of pay, location, paid time off, etc. This letter with the completed application form documents an intern's eligibility to participate in the program for a specific duration and rate of pay. For the current audit, applications or resumes were missing for 1 of the interns sampled and an award letter was missing for 1 intern. It was this lack of documentation that resulted in the questioned costs. Requiring a completed application has been a standard practice for several years but this wasn’t always the case when students applied directly to a site supervisor and not through the online application at PreserveNet (NCPE’s website for preservationists and preservation resources). Site supervisors are now regularly reminded about the program’s eligibility requirement, however, and management is confident that these interns, and all future interns, met the criteria for participation in the program. Nevertheless, in the future efforts will be intensified to improve record keeping. If NPS has any questions concerning these responses, please contact me or NCPE’s Treasurer, Doug Appler.

View Audit 342824 Questioned Costs: $1

Finding 522674 (2021-016)

Material Weakness 2021

Ottawa County

OK

Questioned Costs Allowable Costs / Cost Principles § 200.403

The county will work to design and implement a system of internal controls to ensure compliance with all applicable grant requirements.

View Audit 341985 Questioned Costs: $1

Finding 520957 (2021-003)

Significant Deficiency 2021

Hoover Seniors

CA

Questioned Costs HUD Housing Programs Reporting

a. Comments on the Finding and Each Recommendation Management concurs with the finding and agrees with the recommendation. b. Action(s) Taken or Planned on the Finding Management will transfer excess funds from the operating account to the reserve for replacements account and continue to work toward...

a. Comments on the Finding and Each Recommendation Management concurs with the finding and agrees with the recommendation. b. Action(s) Taken or Planned on the Finding Management will transfer excess funds from the operating account to the reserve for replacements account and continue to work toward bringing the delinquent accounts current.

View Audit 340847 Questioned Costs: $1

Corrective Action Plans

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