Corrective Action Plans

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Repeat finding 2024-005 The City will establish policies, procedures and internal controls to ensure that all subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of year end.
Repeat finding 2024-005 The City will establish policies, procedures and internal controls to ensure that all subrecipient CAPER reports are reconciled to the IDIS system and submitted to HUD within 90 days of year end.
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. E...
Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional staff member will review COD reports before they are submitted via EdConnect. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: April 2026
Period of Performance – Assistance Listing No. 93.958 Recommendation: Management should review and revise its process for allocating costs to federal grants to include additional layers of review and so that costs for which some or all are from outside of the period of performance, may be appropriat...
Period of Performance – Assistance Listing No. 93.958 Recommendation: Management should review and revise its process for allocating costs to federal grants to include additional layers of review and so that costs for which some or all are from outside of the period of performance, may be appropriately excluded from the federal grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will revise cost allocation procedures to add program and finance review steps to ensure that only costs incurred within the applicable period of performance are charged to federal grants. Costs identified as outside the allowable period will be excluded or reclassified. Updated procedures will be communicated to relevant staff and monitored for compliance. Name(s) of the contact person(s) responsible for corrective action: George Pepe Planned completion date for corrective action plan: 6/30/2026
Special Tests and Provisions – Assistance Listing No. 14.267 Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. ...
Special Tests and Provisions – Assistance Listing No. 14.267 Recommendation: We recommend program managers verify that rent reasonableness checklists and certifications are fully completed by HUD staff. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement a supervisory review process requiring program managers to review and formally sign off on rent reasonableness checklists and certifications. Staff will receive refresher training on completion requirements, and management will periodically review files to ensure documentation is complete and properly approved. Name(s) of the contact person(s) responsible for corrective action: Jamie Rotter Planned completion date for corrective action plan: 6/30/2026
The Organization agrees with the finding. The Project has begun and will continue to make monthly deposits back to the security deposit bank account to meet the outstanding security deposit obligations so that by year end, the security deposit bank account is equal to or greater than the aggregate o...
The Organization agrees with the finding. The Project has begun and will continue to make monthly deposits back to the security deposit bank account to meet the outstanding security deposit obligations so that by year end, the security deposit bank account is equal to or greater than the aggregate of all outstanding security deposit obligations owed to tenants. The Project will also begin a monthly check that the security deposit bank account is adequately funded to cover all outstanding security deposit obligations owed to tenants. Contact: Angela Pough, Site Property Manager Completion Date: December 31, 2026
United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 2025 The findings from the schedule of findings and questioned costs are d...
United States Department of Housing and Urban Development Good Shepherd Homes, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: January 01, 2025 - December 31, 2025 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 United States Department of Housing and Urban Development SIGNIFICANT DEFICIENCY 2025-001 Section 223(f) Mortgage Insurance for the Refinance of Existing Multifamily Housing Projects Federal Assistance Listing #14.155 Recommendation: We recommend that management deposit the remaining $770 to the residual receipts account as soon as possible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management deposited the $770 into the residual receipts account on March 12, 2026. Management will ensure moving forward that if the Project has surplus cash, the correct amount will be deposited into the residual receipts account. Name(s) of the contact person(s) responsible for corrective action: Krista Martini, Chief Financial Officer Planned completion date for corrective action plan: March 12, 2026 If the United States Department of Housing and Urban Development has questions regarding this plan, please call Krista Martini at 320-259-3490.
As a resolution plan to ensure proper compliance with eligibility criteria required for student admission to the TRIO Program, specifically regarding disability, we will implement the following measures: Review and modify the program admission application to include a checklist format for the docume...
As a resolution plan to ensure proper compliance with eligibility criteria required for student admission to the TRIO Program, specifically regarding disability, we will implement the following measures: Review and modify the program admission application to include a checklist format for the documents submitted by the student to validate compliance with eligibility criteria during the program admission process. Create a form that a qualified professional or specialist can use to validate and document relevant information about the disability to determine eligibility and reasonable accommodations or modifications, as established and defined by the Americans with Disabilities Act (ADA). This form will be required when the medical certification provided by the qualified professional/specialist does not detail relevant information to determine the student’s eligibility based on disability or is more than one year old. Access and participate in training sessions, workshop, seminars, and webinars that focus on the ADA and its amendments, and on Title 42, Chapter 126, Section 1210, to gain greater knowledge and experience in meeting disability eligibility criteria in the Program.
The Financial Aid Office, to ensure compliance with federal requirements, has implemented since the end of the 2024-2025 academic cycle a revised reconciliation procedure within the new system and established controls to ensure that Direct Loan reconciliations are completed monthly and that appropri...
The Financial Aid Office, to ensure compliance with federal requirements, has implemented since the end of the 2024-2025 academic cycle a revised reconciliation procedure within the new system and established controls to ensure that Direct Loan reconciliations are completed monthly and that appropriate documentation is retained.
Staffing Enhancement - Approval was granted for the hiring of an additional staff member dedicated to the refund process. This action increases operational capacity and strengthens segregation of duties, a key regulatory control to prevent delays in processing Title IV credit balance refunds. Staff ...
Staffing Enhancement - Approval was granted for the hiring of an additional staff member dedicated to the refund process. This action increases operational capacity and strengthens segregation of duties, a key regulatory control to prevent delays in processing Title IV credit balance refunds. Staff Training - Formal training was provided to personnel involved in the refund process to ensure compliance with updated procedures and strengthen internal controls. Technical consultations with Ellucian Banner were conducted to ensure that processes align with system best practices and institutional requirements. Completion of Procedures Manual - The procedures manual was finalized and includes standardized steps that streamline workflow, reduce operational risks, and ensure full traceability of each stage of the refund process. The manual is a mandatory reference for the personnel involved in refund process. Interdepartmental Work Schedule - A coordinated work schedule was established among Financial Aid, Bursar, and Accounting. The schedule outlines specific dates for financial aid disbursements, refund processing in student accounts, and issuance of payments to students. This measure strengthens interdepartmental coordination and supports compliance with required timelines. With the implementation of these corrective and preventive measures, the University reinforces its commitment to meeting all required timelines, improving administrative efficiency, and maintaining strong internal controls to ensure timely and compliant processing of Title IV credit balance refunds.
Upon identification of the issue, the Financial Aid Office conducted a comprehensive review of its internal procedures and implemented corrective measures to ensure full compliance with Title IV regulations. These measures included reinforcing staff training through targeted sessions, strengthening ...
Upon identification of the issue, the Financial Aid Office conducted a comprehensive review of its internal procedures and implemented corrective measures to ensure full compliance with Title IV regulations. These measures included reinforcing staff training through targeted sessions, strengthening internal monitoring controls, and confirming that the new system is properly configured to generate and track disbursement notifications. Additionally, the University is in the process of implementing the ISE system, with an expected full deployment date of April 2026, which will further enhance automation and tracking capabilities related to disbursement notifications. As part of the enhanced monitoring controls, the office has established periodic reviews of disbursement records, monthly reconciliation processes, and the routine generation and review of system reports to verify that notifications are sent timely and accurately. These steps are designed to prevent similar occurrences in the future and ensure that all students receiving Direct Loans are consistently provided with the required disbursement notifications in accordance with regulatory requirements.
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. The hazard insurance policy for the project property was in force; however, due to an administrative oversight during policy renewal, the required standard mortgagee clause identi...
Views of Responsible Officials and Planned Corrective Actions: Management Response: Management concurs with the finding. The hazard insurance policy for the project property was in force; however, due to an administrative oversight during policy renewal, the required standard mortgagee clause identifying the U.S. Department of Housing and Urban Development (HUD) as mortgagee/loss payee was not reflected in the insurance documentation maintained on file. Corrective Action Plan: Management will work with the insurance broker to obtain the required endorsement naming the U.S. Department of Housing and Urban Development (HUD) as mortgagee/loss payee and will implement a review process to ensure required endorsements are verified upon future policy renewals. Responsible Official: Stacey Ninness, President/CEO Anticipated Completion Date: Management anticipates the policy endorsement will be completed within 60 days of the audit report date.
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: The Organization should ensure proper review and approval over expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: The Organization should ensure proper review and approval over expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: YSS engaged a project manager in September 2023 to provide oversight on the two major construction projects taking place, Rooftop Gardens and Ember Campus. The project manager reviews the work being performed to ensure alignment with the progress billing on the monthly AIA pay applications. The project manager submits the invoice for approval to the CFO who, with the CEO, approves payment and the invoice is sent YSS accounts payable to processes payment. Name of the contact person responsible for corrective action: Danielle Fineran Planned completion date for corrective action plan: June 30, 2026
Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
Corrective Action Plan: Management will request a rent increase when the property is eligible and budget for monthly tax and escrow deposits to prevent future shortfalls in escrow cash.
March 23, 2026 CORRECTIVE ACTION PLAN Cognizant or Oversight Agency for Audit Trinity Academy for the Performing Arts respectfully submits the following corrective action plan for the year ended June 30, 2025 Name and address of independent public accounting firm: AAFCPAs 160 Federal Street, 16th Fl...
March 23, 2026 CORRECTIVE ACTION PLAN Cognizant or Oversight Agency for Audit Trinity Academy for the Performing Arts respectfully submits the following corrective action plan for the year ended June 30, 2025 Name and address of independent public accounting firm: AAFCPAs 160 Federal Street, 16th Floor Boston, MA 02110 Audit period: July 1, 2024, thru June 30, 2025 The findings from June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT FINDINGS SIGNIFICANT DEFICIENCY 2025-001 Payroll Recommendation: The School implements a standardized checklist and conducts periodic internal reviews of onboarding documentation to ensure all required forms are properly completed and retained in accordance with Federal Regulations. Action Taken: The School is implementing a standardized onboarding checklist; all personnel folders will now include a printed version to ensure required forms, including Form 1-9 and Form W-4, are completed in full at the time of hire. In addition, periodic internal review of personnel files are completed in full at the time of hire. In addition, periodic internal reviews of personnel files will be conducted to verify ongoing compliance. HR staff will also receive additional training to reinforce proper documentation procedures and retention requirements. We are committed to strengthening internal controls and ensuring full compliance moving forward. If there are any questions regarding this plan, please call Harold Sands at 401-432-7881. Sincerely yours, Harold Sands
March 23, 2026 CORRECTIVE ACTION PLAN Cognizant or Oversight Agency for Audit Trinity Academy for the Performing Arts respectfully submits the following corrective action plan for the year ended June 30, 2025 Name and address of independent public accounting firm: AAFCPAs 160 Federal Street, 16th Fl...
March 23, 2026 CORRECTIVE ACTION PLAN Cognizant or Oversight Agency for Audit Trinity Academy for the Performing Arts respectfully submits the following corrective action plan for the year ended June 30, 2025 Name and address of independent public accounting firm: AAFCPAs 160 Federal Street, 16th Floor Boston, MA 02110 Audit period: July 1, 2024, thru June 30, 2025 The findings from June 30, 2025, 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 SIGNIFICANT DEFICIENCY Revenue Recognition 2025-002 Elementary and Secondary School Emergency Relief Funds Recommendation: The School develop policies and procedures surrounding revenue recognition. These procedures should also include a reconciliation of expenses incurred versus revenue recognized, ensuring revenue is recognized when services are rendered and the provisions of the grants have been met. Action Taken: Revenue recognition issues that occurred in the fiscal year 2024 audit flowed through to fiscal year 2025 and were not caught in time for the fiscal year 2025 audit. The School continues to adhere to the matching policy. If there are any questions regarding this plan, please call Harold Sands at 401-432-7881. Sincerely yours, Harold Sands
United Way will ensure all timesheets are appropriately retained and approved.
United Way will ensure all timesheets are appropriately retained and approved.
2025-004 REPORTING Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: None Type of Finding: Material Weakness in Internal Controls and Material Noncompliance Compliance Requirement: L. Reporting Condition/Context: Documentatio...
2025-004 REPORTING Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: None Type of Finding: Material Weakness in Internal Controls and Material Noncompliance Compliance Requirement: L. Reporting Condition/Context: Documentation was not provided to support the number of federally connected students reported on the Impact Aid application. Criteria: The District’s policies and procedures should ensure that internal controls over compliance of federal programs are in place and operating effectively. Cause: Management oversight and turnover in the federal grant department. Effect: Internal control weakness and material noncompliance. Recommendation: We recommend the District review its internal control procedures over federal programs to ensure that proper documentation is maintained to support the number of federallyconnected students on the Impact Aid application. Repeat Finding: Yes, similar to prior year finding 2024-005. Views of Responsible Officials: There is no disagreement with this finding. See the corrective action plan. Contact person: Laticia John, Business Coordinator
The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. Dur...
The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 4 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis prior to March 31, 2025. In April 2025, the University remediated this policy and procedure. No exceptions were identified during the remediation period, and the finding is considered remediated. In April 2025, to address this finding and strengthen compliance, the University initiated the following corrective actions. First, the University worked with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change ensures that the University’s procurement processes are more consistent with federal standards. Second, a new requirement was implemented, mandating that a price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form documents the University’s independent price analysis. Third, the University provided targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new price analysis requirement. The training emphasized the importance of maintaining contemporaneous documentation in procurement files. Finally, the University implemented enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of a price analysis retained in the procurement files. Primary responsibility for implementing and monitoring this corrective action plan rests with Beth Connelly, Senior Director of Procurement Operations, 216-368-6332.
The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properl...
The University acknowledges the audit finding and remains committed to maintaining compliance with the cash management requirements outlined in 2 CFR 200.302 (b)(3), which stipulates that recipients must maintain records that sufficiently identify Federal awards and ensure that drawdowns are properly supported and authorized prior to submission. During the audit period, at least one drawdown was approved, one day retroactively, after submission but prior to receipt of funds. This occurred prior to the remediation period. No exceptions were identified in the remediation period, and the finding is considered remediated. The instance arose during a leadership transition with the Office of Research Administration. Since that time, the entire drawdown process, review and approval has been clarified under new leadership, and additional oversight has been implemented to ensure approvals are documented prior to submission. As part of the drawdown process review, the University developed a standardized drawdown template, which streamlines how the Federal award expense information is gathered, compared to approve budgeted amounts and reviewed for approval. The template documents the preparer, the approver and the dates of both for the respective drawdown. The Office of Research Administration received training on the use of the template in January and February 2026 and implementation is planned for February 2026. Primary responsibility for implementing the correction action plan for this finding rests with Angela Tagliaferri, Assistant Vice President of Post-Award Services and Financial Compliance, 216-368-6269.
Condition: On May 15, 2025, ISBE communicated to the District that ARP ESSER recipients had until May 24, 2025 to liquidate obligations and that the District needed to submit its expenditure report to ISBE by May 21, 2025 for ISBE to process and submit to the U.S. Department of Education by the new ...
Condition: On May 15, 2025, ISBE communicated to the District that ARP ESSER recipients had until May 24, 2025 to liquidate obligations and that the District needed to submit its expenditure report to ISBE by May 21, 2025 for ISBE to process and submit to the U.S. Department of Education by the new deadline. On May 21, 2025, the District submitted a claim for reimbursement of expenditures totaling $4,343,814. The expenditures comprising this claim by date incurred and liquidated were as follows: $1,668,710 incurred through May 21, 2025 and liquidated as of that date $31,692 incurred through May 21, 2025 but not liquidated as of that date $325,805 incurred from May 21, 2025 through June 30, 2025 and liquidated as of June 30, 2025 $531,321 incurred from May 21, 2025 through June 30, 2025 but not liquidated as of June 30, 2025 $1,786,286 incurred after June 30, 2025 At May 21, 2025 and June 30, 2025, expenditures totaling $2,675,104 and 2,349,299, respectively, out of the $4,343,814 claimed for reimbursement were not incurred, not liquidated or both and, therefore, did not qualify for reimbursement based on the Federal statutes, regulations and the terms and conditions of the Federal award in effect at those dates. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Responsible Person: Dr. Maureen M. White, Superintendent Anticipated Completion Date: June 30, 2026
Finding #2025-001: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, the Corporation did not make the HUD required total amount of deposits to the reserve for replacements. Management should transfer $19,826 from the operating account to the reserve for replac...
Finding #2025-001: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, the Corporation did not make the HUD required total amount of deposits to the reserve for replacements. Management should transfer $19,826 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. On February 3, 2026, management transferred $20,258 from the operating account to the reserve for replacements. 35
2025-005 – Noncompliance and Deficiency in Internal Control over Cash Management Corrective Action: The District will implement a documented review and approval process for each Federal reimbursement request prior to submission, including verification of calculations, agreement to supporting documen...
2025-005 – Noncompliance and Deficiency in Internal Control over Cash Management Corrective Action: The District will implement a documented review and approval process for each Federal reimbursement request prior to submission, including verification of calculations, agreement to supporting documentation, and allowability within the reimbursement period. The reimbursement package, review documentation, and approval will be retained in accordance with the District’s records retention policy for each applicable grant award. Management will not submit reimbursement requests until the documented review is complete and any identified discrepancies are resolved. Responsible Officials: Fire Chief Gerard Tarleton Anticipated Completion Date: September 2026
Recommendation: We recommend that management and those charge with governance to improve internal controls to ensure that all required lease agreements are included in tenant files. Response: As of March 2026, to prevent recurrence, management has implemented the following procedural changes: 1. The...
Recommendation: We recommend that management and those charge with governance to improve internal controls to ensure that all required lease agreements are included in tenant files. Response: As of March 2026, to prevent recurrence, management has implemented the following procedural changes: 1. The move in checklist will add a line requiring staff sign-off confirming that all executed lease documents are placed in the tenant file prior to move-in or lease renewal. 2. Property management staff will conduct monthly file reviews to verify that all move in’s required documentation, including signed lease agreements, is present and current in each tenant file. 3. The Regional Manager will conduct quarterly file audits to ensure ongoing compliance and will report findings to management.
Management acknowledges the finding related to cash management requirements and the timing of federal fund draws and disbursements. While the University maintains a robust, multi-layered review process, enhancements are necessary to ensure full alignment with federal requirements regarding the minim...
Management acknowledges the finding related to cash management requirements and the timing of federal fund draws and disbursements. While the University maintains a robust, multi-layered review process, enhancements are necessary to ensure full alignment with federal requirements regarding the minimization of time between the receipt and disbursement of funds. The University currently utilizes several internal controls, including: • A two-person pre-draw validation process to ensure draws align with liquidated expenses • Programmatic oversight through detailed fiscal year draw reports and reconciliation to G5 activity • Periodic fiscal year and program year reviews to identify and correct discrepancies These controls enabled the University to identify and correct the instances noted in the audit. However, management recognizes that refinements are needed to further align the timing of draws with actual cash disbursement activity. To address this, the University will implement the following corrective actions: 1. Refinement of Draw Timing – Draw requests will be more closely aligned with immediate cash needs and anticipated disbursement activity. 2. Enhanced Pre-Draw Reconciliation – In addition to existing controls, a real-time reconciliation of outstanding obligations and pending disbursements will be required prior to each draw to ensure alignment with cash needs. 3. Standardized Draw Calendar Adjustments – The University will evaluate and adjust its draw schedule, where necessary, to better align with actual disbursement cycles, including payroll and purchase card activity. 4. Formalized Monitoring and Documentation – Documentation will be maintained to support the relationship between drawdowns and disbursements, and periodic internal reviews will be conducted to ensure ongoing compliance. 5. Training and Communication – Additional guidance will be provided to program and fiscal staff regarding federal cash management requirements and expectations for timing of draws. Management believes these enhancements, in combination with existing internal controls, will ensure compliance with federal cash management requirements and prevent recurrence of this issue. Implementation Date: July 1, 2025 Responsible Party: James Altman (Director of Finance) in coordination with Darla Ellett (Trio Director) and Teriki Barnes (Trio Director)
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