Corrective Action Plans

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Management acknowledges the finding related to Return of Title IV (R2T4) calculations and the timeliness of returns. The University recognizes the importance of accurate calculations and timely processing in compliance with federal regulations. The errors identified were primarily related to inaccur...
Management acknowledges the finding related to Return of Title IV (R2T4) calculations and the timeliness of returns. The University recognizes the importance of accurate calculations and timely processing in compliance with federal regulations. The errors identified were primarily related to inaccuracies in determining the total number of days in the payment period and ensuring the correct data elements were consistently applied within the student information system. While corrective actions were implemented following the prior audit, management has determined that additional controls and validation procedures are necessary to ensure consistent accuracy. To address this issue, the University has implemented and will continue to implement the following corrective actions: 1. System Configuration Review and Validation – The student information system configuration for R2T4 calculations has been reviewed and updated to ensure that academic calendars, including term dates and scheduled breaks, are accurately reflected. These configurations will be validated prior to the start of each term. 2. Enhanced Calculation Review Process – A secondary review of a sample of R2T4 calculations will be performed to verify the accuracy of key inputs, including days attended, total days in the term, and applicable aid types. 3. Standardized Procedures and Checklists – The University has developed standardized procedures to ensure consistent application of federal requirements, including proper ordering of funds and treatment of post-withdrawal disbursements. 4. Timeliness Monitoring – Processes have been enhanced to track and monitor the timing of R2T4 calculations and returns to ensure compliance with required deadlines. 5. Training and Staff Development – Financial aid staff have received additional training on R2T4 requirements, with a focus on calculation components, system inputs, and regulatory updates. 6. Ongoing Quality Assurance Reviews – Periodic internal reviews will be conducted to assess compliance and identify any discrepancies for prompt correction. Management believes these enhanced controls and monitoring procedures will address the root causes of the finding and prevent recurrence. Implementation Date: July 1, 2025 Responsible Party: Chrissie Isenberg (Director of Financial Aid)
Management concurs with the findings and auditors’ recommendations to enhance internal controls to ensure compliance with the RD requirements. Furthermore, we would like to note that the questioned costs was paid from project cash for the ultimate benefit of improving the property for the tenants. T...
Management concurs with the findings and auditors’ recommendations to enhance internal controls to ensure compliance with the RD requirements. Furthermore, we would like to note that the questioned costs was paid from project cash for the ultimate benefit of improving the property for the tenants. The substantial rehabilitation tax credit transaction planned by the owner is anticipated to start within the next fiscal year will significantly enhance the living standards and experience for the tenants. The funds used for purposes directly related to the operations of the project will be repaid with the planned closing of the Low-Income Housing tax credit transaction during fiscal year 2026 unless an approval is granted by RD for payment of the questioned costs that will ultimately benefit the tenants of Rotary Commons. Furthermore, internal controls over funds used for purposes unrelated to the Corporation are being strengthened to prevent future noncompliance.
CORRECTIVE ACTION PLAN The County respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Warren Averett, LLC 45 Eglin Parkway, N.E., Suite 301, Fort Walton Beach, FL 32548. The finding from the schedule...
CORRECTIVE ACTION PLAN The County respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Warren Averett, LLC 45 Eglin Parkway, N.E., Suite 301, Fort Walton Beach, FL 32548. The finding from the schedule of findings and questioned costs for the year ended September 30, 2025, is discussed below. The finding is numbered consistently with the number assigned in the schedule of findings and questioned costs. Name of Contact Person for Completing Corrective Action Plan: Jane Evans, Grants and RESTORE Manager (850) 651-7521 jevans@myokaloosa.com Expected date of completion is October 1, 2026. FINDING 2025-001 – EQUIPMENT AND REAL PROPERTY MANAGEMENT Managements Response: 1. System Cleanup & Review: The Accounting Director will provide the fixed asset records to the OMB Director. The OMB Director will coordinate with relevant departments (e.g., Public Works, Facilities), to review all equipment, infrastructure, and building assets funded by federal or state awards. Missing data fields, required by 2 CFR 200.313(d) and 2 CFR 200.311 will be populated in the fixed asset records. The County is implementing a new Workday ERP system, which has an integrated fixed asset module. This module will accommodate the tracking of grant-specific information required and provide a better workflow for consistency and compliance. 2. Infrastructure Project Closeout Procedure: The County will revise the policies and closing procedures for CIP (Construction in Progress) projects. Before an asset is moved from CIP to fixed assets, the fixed asset coordinator must provide a completed "Grant-Funded Property Identification Form" detailing the funding source, FAIN (Federal Award Identification Number) or State award number, and percentage of contribution to the Finance Department. 3. Policy Re-training: The OMB Director in collaborative efforts with Finance Department will hold training sessions for all department heads and project managers to reinforce the established fixed asset tracking policy, emphasizing the compliance requirements of the Florida Single Audit Act and Uniform Guidance. 4. Ongoing Monitoring: Internal reviews of the fixed asset listing will be conducted quarterly by the Accounting Director or designee to verify that new assets are properly categorized with necessary grant details.
Community Services Block Grant– Assistance Listing No. 93.569 Recommendation: We recommend Alliance for Community Empowerment, Inc. fill positions within the 180-day period. Action taken in response to finding: Alliance for Community Empowerment, Inc. is actively searching for individuals to fill va...
Community Services Block Grant– Assistance Listing No. 93.569 Recommendation: We recommend Alliance for Community Empowerment, Inc. fill positions within the 180-day period. Action taken in response to finding: Alliance for Community Empowerment, Inc. is actively searching for individuals to fill vacant positions and plans to have a board vote at the March meeting to fill the vacancies. Name of the contact person responsible for corrective action: Dr. Monette Ferguson, Executive Director. Planned completion date for corrective action plan: March 31, 2026
Corrective Action Planned: Management reviewed this instance and performed a detailed analysis of our internal controls, procedures and other like transactions. Management concluded that it was an isolated incident that occurred due to the timing and processing of the voided transaction and the tran...
Corrective Action Planned: Management reviewed this instance and performed a detailed analysis of our internal controls, procedures and other like transactions. Management concluded that it was an isolated incident that occurred due to the timing and processing of the voided transaction and the transition to a new grant year. Vivent Health has implemented additional controls including dual review of grant year-to-date expenditures and system and reporting enhancements that will identify and prevent changes related to prior periods. Specific steps taken are: 1) retrained accounts payable team on void check procedure, 2) implemented a system enhancement that does not permit a user to enter any transaction type to a prior month that has been closed (also planned for new financial system to be implemented by September 2026), 3) examined all void check transactions for any grant-related expenditures that crossed the last two fiscal years with no instance of duplicate invoicing identified, and 4) implemented dual review of running a YTD general ledger report for all grants and comparing total expenditures for the grant period versus total expenditures claimed in the prior month. Name(s) of Contact Person(s) Responsible for Corrective Action: Erin Crandall, VP Finance Anticipated Completion Date: These actions were implemented February 2026 and will be documented throughout the current fiscal year, with completion at fiscal year-end (August 31, 2026). Vivent Health is implementing a new ERP system in September 2026 and will ensure these controls are in place.
Corrective Action Plan Finding No. 2025-003 Condition – The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Departmen...
Corrective Action Plan Finding No. 2025-003 Condition – The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Department of Labor as required. Plan – The District’s Director of Maintenance, Operations & Risk Management will ensure certified payrolls are submitted with invoices and a copy of the submissions to the US Department of Labor are attached to final pay invoice. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official
Views of Responsible Officials: Management concurs with the finding. During FY2025, the organization experienced significant disruption related to Federal stop-work orders and associated cost-reduction measures, including staff terminations and the discontinuation of certain legacy systems during th...
Views of Responsible Officials: Management concurs with the finding. During FY2025, the organization experienced significant disruption related to Federal stop-work orders and associated cost-reduction measures, including staff terminations and the discontinuation of certain legacy systems during the transition and integration of operations with Global Communities. As a result, for some employees in the audit sample—particularly those who separated from the organization prior to the FY2025 attestation cycle—management was unable to retrieve employee-signed conflict of interest attestations for the immediately preceding period because the systems and files used to capture and retain those acknowledgments were no longer accessible, and responsible personnel were no longer employed. Management notes that, for a portion of the employee population, the FY2025 ethics training included a conflicts of interest section requiring employee acknowledgment; however, system limitations affected the ability to produce individual, employee-named attestations for all sampled employees in a format suitable for audit evidence. Planned Corrective Actions: Following the operational integration with Global Communities, management is strengthening controls over conflict of interest compliance by: (1) requiring conflict of interest acknowledgment at onboarding and on a periodic basis thereafter through a standardized process; (2) maintaining a centralized tracking mechanism to monitor completion status; (3) retaining documentation in a centralized repository/personnel record to ensure retrievability; and (4) performing periodic monitoring to confirm completion and retention across headquarters and field locations. These actions are intended to improve documentation, transparency, and ongoing compliance with conflict of interest requirements and standards of conduct.
Corrective Actions Implemented: 1. Monthly Reconciliation Process: A reconciliation procedure has been implemented requiring cafeteria site managers to compare meal production records, point-of-sale (POS) reports, and student attendance records (including Saturday School attendance, when applicable)...
Corrective Actions Implemented: 1. Monthly Reconciliation Process: A reconciliation procedure has been implemented requiring cafeteria site managers to compare meal production records, point-of-sale (POS) reports, and student attendance records (including Saturday School attendance, when applicable) prior to submission of CNIPS claims. Any discrepancies are investigated and corrected. 2. Verification of Meal Counts: Site managers are now required to review production records and POS data to ensure that only meals actually served to eligible students are included in reimbursement claims. 3. Staff Training: Training has been provided to cafeteria staff and site managers on proper meal counting and claiming procedures to ensure compliance with federal requirements. 4. Supervisory Review: All monthly CNIPS claims are now subject to review and approval by the Child Nutrition Director prior to submission to ensure accuracy and completeness. 5. Ongoing Monitoring: The Director will conduct periodic internal reviews of meal counting and claiming procedures to ensure continued compliance and prevent recurrence of this issue. The District believes these corrective actions address the cause of the finding and will ensure accurate reporting of meals served going forward.
Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency implement an internal control to have a documented review of the reports by a person independent of the preparer of the report Explanation of disagreement with audit finding: There is no di...
Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency implement an internal control to have a documented review of the reports by a person independent of the preparer of the report Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Agency will review its processes to ensure an internal control is implemented. Name of the contact person responsible for corrective action: Tony Vermazen, Fiscal Manager Planned completion date for corrective action plan: Fiscal Year 2026
ECA agrees with this finding and has created calendar reminders for all federal contracts to comply with all financial and programmatic requirements. ECA also hired a Director of Development in March 2026, who will also be partially responsible for maintaining contract compliance.
ECA agrees with this finding and has created calendar reminders for all federal contracts to comply with all financial and programmatic requirements. ECA also hired a Director of Development in March 2026, who will also be partially responsible for maintaining contract compliance.
Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Corrective Action Plan The City will submit pay...
Finding 2025-002 Information on Federal Program: Federal Program: CDBG Entitlement Grants Cluster Federal Agency: U.S. Department of Housing and Urban Development (HUD) Assistance Listing: 14.218 Compliance Requirements: Allowable Costs/Cost Principles Corrective Action Plan The City will submit payment to HUD for the $249,565 of questioned costs. Additionally, the City will update its written program and financial policies and procedures per 24 CFR 570.200(g) which should outline how the City of Corpus Christi will monitor compliance with both of the Administrative and Planning expenditure tests and will provide HUD with a certification stating Planning and Community Development staff received training regarding the limitation on planning and administration costs for origin year grants. Person(s) Responsible Jennifer Buxton, Interim Director of Planning and Economic Development Anticipated Completion Date The City has completed all corrective actions.
2025-001 REPORTING ALN 20.106 Airport Improvement Program U.S. Department of Transportation Federal Aviation Administration Federal Award No. 3-12-0046-064-2024 2024/2025 Funding Recommendation: The Airport, a component unit of the City, should develop a process to ensure reports are submitted timel...
2025-001 REPORTING ALN 20.106 Airport Improvement Program U.S. Department of Transportation Federal Aviation Administration Federal Award No. 3-12-0046-064-2024 2024/2025 Funding Recommendation: The Airport, a component unit of the City, should develop a process to ensure reports are submitted timely for all awards including re-assigning tasks when personnel are on leave. Corrective Action: Airport management has set up a process whereby the quarterly reports are reviewed by another team member to ensure the reports are completed and submitted in the time frame required by the Federal Aviation Administration. This review will be completed by the Accounting Manager who understands the importance of submitting the information and, if they are not completed, will complete and submit the reports. Any issues or omissions observed by the Accounting Manager with submitting the required reports will be reported to the Director of Finance and Administration for further follow-up with the staff member who is primarily responsible for this task Responsible party: Mike O’Dell, Director of Finance & Administration Date Expected to be Corrected: March 17, 2026
2025-002 DISALLOWED COSTS ALN 97.083 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Federal Award No. EMW-2022-FF-00868 2024/2025 Funding Recommendation: Independent review of program reimburseme...
2025-002 DISALLOWED COSTS ALN 97.083 Staffing for Adequate Fire and Emergency Response (SAFER) Grant Program U.S. Department of Homeland Security Federal Emergency Management Agency (FEMA) Federal Award No. EMW-2022-FF-00868 2024/2025 Funding Recommendation: Independent review of program reimbursement requests and reports should be consistently performed and documented prior to submission the grantor. Corrective Action: The City agrees with this finding and will establish internal procedures for review of program reimbursement requests before submission to the grantor. The Grant Compliance Manager will prepare the reimbursement requests and semi-annual reports and provide to the Director of Finance for review and approval prior to submission. This corrective action will take effect immediately. Responsible party: Rebecca Thibert, Grant Compliance Monitor Date Expected to be Corrected: March 17, 2026
Management agrees with the findings. The situation was due to gaps in documentation controls during staffing transitions. The Organization has implemented standardized personnel file procedures, including required documentation checklists and periodic reviews to ensure compliance with health, backgr...
Management agrees with the findings. The situation was due to gaps in documentation controls during staffing transitions. The Organization has implemented standardized personnel file procedures, including required documentation checklists and periodic reviews to ensure compliance with health, background check, and performance evaluation requirements.
Management agrees with the findings. The condition resulted from limited access to prior electronic records and staffing disruptions during the program transition. The Organization has strengthened documentation procedures to ensure required home visit and parent-teacher conference records are prope...
Management agrees with the findings. The condition resulted from limited access to prior electronic records and staffing disruptions during the program transition. The Organization has strengthened documentation procedures to ensure required home visit and parent-teacher conference records are properly maintained and accessible, including retaining key compliance documents in centralized formats and implementing periodic file reviews.
Management has agreed to closely monitor the receipt of federal funds and disburse those funds timely in order to ensure compliance with this regulation. The Cash Balance Report that is updated daily of all incoming receipts will be used as a tool to ensure expenses incurred are paid timely in the w...
Management has agreed to closely monitor the receipt of federal funds and disburse those funds timely in order to ensure compliance with this regulation. The Cash Balance Report that is updated daily of all incoming receipts will be used as a tool to ensure expenses incurred are paid timely in the weekly disbursements.
Compliance over Negotiation Process Recommendation: The City should review the documentation sent to the seller during the procurement process to ensure the City is providing all necessary documentation to the seller according to 2 CFR 200 and 49 CFR 24. Management Response: Management agrees with t...
Compliance over Negotiation Process Recommendation: The City should review the documentation sent to the seller during the procurement process to ensure the City is providing all necessary documentation to the seller according to 2 CFR 200 and 49 CFR 24. Management Response: Management agrees with the finding. The issue resulted from procedures not fully aligning with federal requirements for real property acquisition documentation and communication. Management will implement procedures to ensure all required communications and documentation are provided and retained in accordance with 2 CFR 200 and 49 CFR 24, including clear communication to sellers and proper recordkeeping to demonstrate compliance. Anticipated Completion Date: Immediately Responsible Contact Person: Yannick Ngendahayo, Finance Director and Mona Feigenbaum, Lake Worth Beach CRA Accounting Manager
Reviews of Grant Reports Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal and the review is documented. Management Response: Management agrees with the finding. Management will implement procedures to document independent review of all repo...
Reviews of Grant Reports Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal and the review is documented. Management Response: Management agrees with the finding. Management will implement procedures to document independent review of all reports submitted to the U.S. Treasury to ensure completeness, accuracy, and timeliness. Anticipated Completion Date: Immediately Responsible Contact Person: Yannick Ngendahayo, Finance Director
U.S. Department of Housing and Urban Development Pioneer Housing Development, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: Year ended December 31, 2025 The findings from the schedule of findings and questioned costs are discussed ...
U.S. Department of Housing and Urban Development Pioneer Housing Development, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2025. Audit period: Year ended 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 U.S. Department of Housing and Urban Development 2025-001 Section 207 Insured Loan Balance – Assistance Listing No. 14.134 Recommendation: We recommend management ensure security deposits are accurately recorded upon receipt and review the security deposit asset against the related liability monthly to ensure the account is adequately funded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On January 20, 2026, a $2,000 deposit was made to the security deposit account to adequately fund it. Management will review the asset against the related liability monthly to ensure the account is adequately funded going forward. Name(s) of the contact person(s) responsible for corrective action: Jill Kouba, Director, Financial Services Planned completion date for corrective action plan: January 20, 2026
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally, we recommend the district designate an individual to review eligibility and ve...
Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Additionally, we recommend the district designate an individual to review eligibility and verification determinations for accuracy and proper input into software. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Food Service Director will review eligibility and verification determinations for accuracy and proper input into the software. The District will continue to improve on reviewing and approval of claims. Name of the contact person responsible for correction action: Jessica Holtz Planned completion date for corrective action: June 30, 2026
2025-007 – Late Audit Report Corrective action plan: Management reviewed existing accounting staffing structure, revised position descriptions, and have advertised to fill two of three open positions. Management feels with these revised position descriptions, more focus on accounting operations and ...
2025-007 – Late Audit Report Corrective action plan: Management reviewed existing accounting staffing structure, revised position descriptions, and have advertised to fill two of three open positions. Management feels with these revised position descriptions, more focus on accounting operations and procedures. Personnel responsible for corrective action: Heather King, Interim Chief Executive Officer Estimated corrective action completion date: June 2026
The Organization will develop and implement formal written policies and procedures to ensure that payroll charges to federal awards are based solely on actual costs incurred, in compliance with federal requirements. As part of this effort, the Organization will require all employees whose salaries a...
The Organization will develop and implement formal written policies and procedures to ensure that payroll charges to federal awards are based solely on actual costs incurred, in compliance with federal requirements. As part of this effort, the Organization will require all employees whose salaries are charged in whole or in part to federal awards to complete time and effort documentation for each payroll period. This documentation will accurately reflect the actual hours worked on federal program activities as well as other activities, as applicable. Supervisors or designated management personnel will review and approve all time and effort reports on a timely basis. Evidence of this review, including signatures or electronic approvals, will be maintained in accordance with record retention policies. The approved time and effort documentation will serve as the basis for allocating personnel costs to federal awards. The Organization will ensure that payroll charges are adjusted, if necessary, to align with actual time worked. Documentation supporting these allocations will be retained and made available for audit or review. Training will be provided to all relevant staff to ensure understanding and consistent application of the new procedures. Implementation of these policies and procedures will occur June 15 2026, and ongoing monitoring will be conducted to ensure compliance.
Condition: The District incurred program expenditures that were not charged in accordance with the approved grant budget. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. The District will strengthen internal controls to e...
Condition: The District incurred program expenditures that were not charged in accordance with the approved grant budget. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. The District will strengthen internal controls to ensure expenditures are reviewed for compliance with the approved grant budget prior to being claimed for reimbursement. Going forward, the District will compare expenditures to the approved budget detail and ensure costs are charged to the appropriate budget category.Responsible Person: Dr. Mable Alfred, Interim Superintendent. Anticipated Completion Date: June 30, 2026
Condition: The District claimed expenditures that did not have adequate supporting documentation, such as invoices, receipts, purchase orders and proof of payment. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Grant exp...
Condition: The District claimed expenditures that did not have adequate supporting documentation, such as invoices, receipts, purchase orders and proof of payment. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Grant expenditures will be reviewed and approved by appropriate personnel prior to reimbursement requests being submitted. Responsible Person: Dr. Mable Alfred, Interim Superintendent. Anticipated Completion Date: June 30, 2026
Condition: The District claimed expenditures that were incurred outside of the applicable periods of performance.Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Grant expenditures will be reviewed and approved by appropri...
Condition: The District claimed expenditures that were incurred outside of the applicable periods of performance.Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Grant expenditures will be reviewed and approved by appropriate personnel prior to reimbursement requests being submitted. Responsible Person: Dr. Mable Alfred, Interim Superintendent. Anticipated Completion Date: June 30, 2026
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