Corrective Action Plans

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LSNYC's Compliance Officer spoke at length with the attorney who mistakenly failed to exclude the value of the client's primary residence from the asset total and an erroneous asset override. She now understands that the "exclude" radio button should entered have been selected for this asset, which ...
LSNYC's Compliance Officer spoke at length with the attorney who mistakenly failed to exclude the value of the client's primary residence from the asset total and an erroneous asset override. She now understands that the "exclude" radio button should entered have been selected for this asset, which would have put the client's assets under the asset ceiling. now understands that an asset override must be approved in writing by her supervisor and She also that the asset override must be uploaded into the case file. Ongoing compliance trainings and financial eligibility trainings have been modified to emphasize the importance of selecting the "exclude" button for assets that do not count toward the total under LSC regulations, and that asset waivers must be approved in writing by a supervisor.
The attorney responsible for failing to obtain a retainer in this case was advised that retainers must always be obtained for full representation cases, and required to review a compliance training video. Ongoing compliance trainings have been modified to emphasize the importance of completing retai...
The attorney responsible for failing to obtain a retainer in this case was advised that retainers must always be obtained for full representation cases, and required to review a compliance training video. Ongoing compliance trainings have been modified to emphasize the importance of completing retainers with clients, for LSC compliance purposes, professional liability protection purposes, and to ensure that clients are made aware of the scope of services that LSNYC has agreed to provide and their own responsibilities in their representation.
Finding No. 2023-001: Fraudulent Payroll Activities Resulting in Theft (Material Weakness) Person Responsible: Reginal Barner Date of Completion: 12/31/2024 Corrective Action Plan: Our fee accountant and payroll consultant will access the payroll process and implement corrective actions, including a...
Finding No. 2023-001: Fraudulent Payroll Activities Resulting in Theft (Material Weakness) Person Responsible: Reginal Barner Date of Completion: 12/31/2024 Corrective Action Plan: Our fee accountant and payroll consultant will access the payroll process and implement corrective actions, including adding internal controls and training.
View Audit 323042 Questioned Costs: $1
View of Responsible Official: We agree with the auditors' comments, and the following action has been taken to improve the situation. We have adjusted the agency’s Accounting Policies & Procedure Manual to include a detailed review of the General Ledger detail supporting each draw request. Accountin...
View of Responsible Official: We agree with the auditors' comments, and the following action has been taken to improve the situation. We have adjusted the agency’s Accounting Policies & Procedure Manual to include a detailed review of the General Ledger detail supporting each draw request. Accounting personnel will ensure the agency’s General Ledger specifically details the month of rent and utility allowance being provided so eligible costs are clearly delineated. Someone other than the preparer will perform a review of each drawdown request to ensure that costs are not being drawn down prior to the operating start date of each individual grant. This issue was discussed with HUD in March 2024 at which time procedural changes were implemented. Additionally, as noted above, our agency was able to repay and redraw the funds drawn outside of the aforementioned period of performance without further penalty. Corrective Action: Effective March 2024 the preparer is required to include the month of rent and utility allowance being provided in the General Ledger detail. A review of the General Ledger detail supporting each draw request will be performed by someone other than the preparer to ensure that costs are not being drawn down prior to the operating start date of each individual grant.
AUDIT FINDINGS 2023-001: There were not adequate controls related to the reporting of expenditures on the schedule of expenditures of federal awards (Schedule) for the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program (FEMA). Specifically, there was a system pr...
AUDIT FINDINGS 2023-001: There were not adequate controls related to the reporting of expenditures on the schedule of expenditures of federal awards (Schedule) for the COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) program (FEMA). Specifically, there was a system pricing issue that resulted in an incorrect amount of expenses related to inventory that were submitted to FEMA for reimbursement. Name of Contact Person: Daria Heimerman, Director of Financial Reporting, dtheimerman@evergreenhealthcare.org Corrective Action Planned: FEMA has been notified and the amount has been updated as part of the project closeout. Anticipated Completion Date: September 2024 Statement of Concurrence or Nonconcurrence: Management concurs with audit finding 2023-001.
View Audit 323033 Questioned Costs: $1
Finding 2023-002 Grantor: Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Title: Fringe Rate Analysis – Formula Error Award Year: Fiscal year 2023 1/1/2023 – 12/31/2023 Award Number: Various Management agrees with the recommendation. Ho...
Finding 2023-002 Grantor: Department of Health and Human Services Federal Program: Various Assistance Listing #: Various Title: Fringe Rate Analysis – Formula Error Award Year: Fiscal year 2023 1/1/2023 – 12/31/2023 Award Number: Various Management agrees with the recommendation. However, while there was an error in the underlying data used to evaluate the annual fringe rate, the federal government was not overcharged for fringe benefits. Corrective Action Plan and Anticipate Completion Date Management’s corrective action plan includes: • Management will ensure a more robust review of the underlying formulas. Responsible Person: Natasha Collins, Director of Research Accounting Completion Date: December 31, 2024
Finding 500183 (2023-003)
Material Weakness 2023
Mhub
IL
Finding Number: 2023-003 Condition: The Organization does not have written procedures to implement the requirements of CFR 200.305. The advance payment of the Federal award was not maintained in an interest-bearing account and no interest was remitted back to the Federal government. Planned Cor...
Finding Number: 2023-003 Condition: The Organization does not have written procedures to implement the requirements of CFR 200.305. The advance payment of the Federal award was not maintained in an interest-bearing account and no interest was remitted back to the Federal government. Planned Corrective Action: Management is in the process of updating written procedures for Federal award compliance. Management will calculate and remit interest for 2023 to the Department of Health and Human Services Payment Management System (PMS). Contact person responsible for corrective action: Manas Mehandru, COO Anticipated Completion Date: October 15, 2024
Finding Reference Number: 2023-2 Recommendation The Company must deposit $13,918 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Comple...
Finding Reference Number: 2023-2 Recommendation The Company must deposit $13,918 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Completion date or proposed completion date: December 31, 2024 Action(s) taken or planned on the finding Management will make the required deposit to the residual receipts reserve.
View Audit 323019 Questioned Costs: $1
Corrective Action Plan September 23, 2024 U.S. Department of Housing & Urban Development 20 Church Street, 10 th floor Hartford, CT 06103 Northwest Senior Housing Corporation respectfully submits the following corrective action plan for Susan M. B. Perry Senior Housing's (Project #Ol 7-EE088) year e...
Corrective Action Plan September 23, 2024 U.S. Department of Housing & Urban Development 20 Church Street, 10 th floor Hartford, CT 06103 Northwest Senior Housing Corporation respectfully submits the following corrective action plan for Susan M. B. Perry Senior Housing's (Project #Ol 7-EE088) year ended December 31, 2023, which was audited by: Bailey, Moore, Glazer, Shaefer & Proto LLP 16 Lunar Drive Woodbridge, CT 06525 The sole finding from the 12/31/2023 schedule of findings and questions costs is discussed below and numbered consistently with the numbers assigned in the schedule. FINDINGS - FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL A WARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Finding number 2023-001: 14.157 Supportive Housing for the Elderly Condition: Withdrawals from the replacement reserves totaling $3,065.08 were not supported by invoices or cash disbursements. As a result, the replacement reserve is underfunded by this amount. Recommendation: Care to be taken to track reserve requests to the actual cash disbursements. Action Taken: Upon receipt of an approved replacement reserve draw, the payment status of all listed invoices are reviewed and within three business day of the money being transferred, checks are cut towards any invoices that have not yet been paid. Furthermore, the unsubstantiated $3,065.08 that was drawn from the replacement reserve account was returned to the account on September 25, 2024. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Matthew Fontaine at (860) 951-9411 extension 249. Matthew Fontaine, CPA Managing Agent
Finding Reference Number: 2023-2 Recommendation Management should establish internal controls and procedures to ensure that surplus cash is properly monitored and disbursed. Reporting views of responsible officials Auditee concurs with this finding. Auditee agrees with auditor recommendations. ...
Finding Reference Number: 2023-2 Recommendation Management should establish internal controls and procedures to ensure that surplus cash is properly monitored and disbursed. Reporting views of responsible officials Auditee concurs with this finding. Auditee agrees with auditor recommendations. Completion date or proposed completion date: December 31, 2024 Action(s) taken or planned on the finding Management agrees with the recommendation of the auditor and internal controls are being put in place to ensure that surplus cash is deposited into the residual receipts reserve prior to paying down intercompany balances.
View Audit 323017 Questioned Costs: $1
Finding Reference Number: 2023-1 Recommendation The Company must deposit $586,006 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Com...
Finding Reference Number: 2023-1 Recommendation The Company must deposit $586,006 into the residual receipts reserve. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for depositing surplus cash into the residual receipts reserve. Completion date or proposed completion date: December 31, 2024 Action(s) taken or planned on the finding Management will make the required deposit to the residual receipts reserve.
View Audit 323017 Questioned Costs: $1
Management is dedicated to enhancing the competencies of our federal grant personnel. The College will offer focused and comprehensive re-training on both our internal procurement policies and the procurement requirements outlined in the Uniform Guidance to workforce members responsible for procurem...
Management is dedicated to enhancing the competencies of our federal grant personnel. The College will offer focused and comprehensive re-training on both our internal procurement policies and the procurement requirements outlined in the Uniform Guidance to workforce members responsible for procurement under federal awards. This re-training will ensure that all staff members understand protocols and regulations, thereby promoting compliance and efficiency in our procurement processes. The Privacy and Research Compliance Officer will monitor Program Management staff to ensure that price and rate quotations are obtained from a sufficient number of qualified sources. The Legal Department will not move forward in contract drafting until evidence of compliance with the College’s federal procurement policies is confirmed. This collaborative effort ensures informed purchasing decisions based on competitive pricing. Additionally, the Privacy and Research Compliance Officer will maintain evidence of price and rate quotation consistent with procurement policies. Through these initiatives, management aims to ensure procurement that aligns with both internal standards and federal regulations, ultimately supporting the effective and responsible use of federal funds.
View Audit 323015 Questioned Costs: $1
Management is committed to enhancing staff knowledge of Uniform Guidance requirements, particularly concerning allowable costs and cost principles. To achieve this, we will implement additional training sessions for all relevant personnel. These sessions will cover key aspects of compliance, ensurin...
Management is committed to enhancing staff knowledge of Uniform Guidance requirements, particularly concerning allowable costs and cost principles. To achieve this, we will implement additional training sessions for all relevant personnel. These sessions will cover key aspects of compliance, ensuring that staff are well-informed about federal regulations and their implications for our grant management processes. The Controller will ensure the calculation of payroll costs are based solely on the actual hours worked and certified by grant personnel. This practice will help maintain accuracy and accountability in our financial reporting. In addition, the Technical and Internal Controls Accountant will conduct quarterly internal reviews to monitor and verify that payroll costs reported on cost reimbursement invoices are consistent with the actual hours certified by grant personnel. These regular reviews will serve as a critical check to uphold the integrity of our financial processes and ensure compliance with federal guidelines. Through these initiatives, management aims to foster a culture of compliance and accountability, equipping our team with the knowledge and tools necessary to effectively manage grant funds.
View Audit 323015 Questioned Costs: $1
Management is committed to enhancing our federal grant policy by incorporating a requirement for an annual review and recalculation of the indirect cost recovery rate. The Controller will take responsibility for recalculating the indirect rate each year, making necessary adjustments—whether upward o...
Management is committed to enhancing our federal grant policy by incorporating a requirement for an annual review and recalculation of the indirect cost recovery rate. The Controller will take responsibility for recalculating the indirect rate each year, making necessary adjustments—whether upward or downward—to ensure it accurately reflects our current cost structure. To maintain compliance and integrity in our financial processes, the Technical and Internal Controls Accountant will oversee the review of costs included in the indirect cost pool to ensure they meet the criteria for allowability. Additionally, this role will involve verifying that invoices utilize the most current indirect cost recovery rate. Furthermore, management will prepare and submit the required indirect cost proposal to the appropriate cognizant agency to finalize our provisional billing rates used in fiscal year 2023, that aligns with our operational needs and complies with federal guidelines. This proactive approach will strengthen our financial management practices and support our ongoing commitment to transparency and accountability in the administration of federal grants.
View Audit 323015 Questioned Costs: $1
2023-002 1. Correcting Plan The Housing Authority has reviewed the re-inspection requirements and notified applicable staff of the deficiency. Processes will be changed to ensure correct population size is used to determine the required number of HQS re-inspections in the future. 2. Explanation of D...
2023-002 1. Correcting Plan The Housing Authority has reviewed the re-inspection requirements and notified applicable staff of the deficiency. Processes will be changed to ensure correct population size is used to determine the required number of HQS re-inspections in the future. 2. Explanation of Disagreement with the Audit Finding There is essentially no disagreement with the finding. 3. Official Responsible for Insuring CAP Jessica Kirwin – Executive Director 4. Planned Completion Date for CAP Will implement for the December 31, 2024 audit. 5. Plan to Monitor Completion of CAP The Executive Director will monitor completion of the CAP.
Finding 500167 (2023-003)
Significant Deficiency 2023
Recommendation: We recommend that the County review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. We also recommend the County develop a procedure to ensure any...
Recommendation: We recommend that the County review its internal controls and implement a procedure to ensure all reports required under the grant have a designated reviewer that is distinct from the individual responsible for preparing. We also recommend the County develop a procedure to ensure any new grants awarded to the County have an internal control assessment performed to document the responsibilities of individuals involved in the grant’s management. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Finance Director is developing a procedure to ensure an internal control assessment is performed to document the grant management responsibilities of all grants. Name of the contact person responsible for corrective action: Darcy Smith, Finance Director Planned completion date for corrective action plan: October 31, 2024
US Department of Health and Human Services Federal Financial Assistance Listing #93.600 Head Start Cluster Applicable Federal Award Number and Year – 07CH011832-04-00 11/1/2023 – 10/31/2024, 07CH011832-03-00 11/1/2022 – 10/31/2023, 07CH011832-02-00 11/1/2021 – 10/31/2022 Activities Allowed or Unallo...
US Department of Health and Human Services Federal Financial Assistance Listing #93.600 Head Start Cluster Applicable Federal Award Number and Year – 07CH011832-04-00 11/1/2023 – 10/31/2024, 07CH011832-03-00 11/1/2022 – 10/31/2023, 07CH011832-02-00 11/1/2021 – 10/31/2022 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control Over Compliance Material Noncompliance Criteria: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Condition: The Organization requested drawdowns of grant funds in excess of amounts awarded for the grant years ended 10/31/2023 and 10/31/2022 that were denied by the passthrough agency, Omaha Public Schools, resulting in an overstatement in grant revenue and receivables, and federal awards expended included in the schedule of expenditures of federal awards. Corrective Action Plan: Management is in the process of reviewing its accounting policies and procedures over grant monitoring to ensure amounts are tracked appropriately. Management has hired a new fiscal services director to oversee this process. Individual Responsible For Corrective Action: Veronica Jones, Fiscal Services Director Anticipated Completion Date: December 31, 2024
View Audit 322999 Questioned Costs: $1
Corrective Action: Name of Contact Person Wayne Moyer Data Collection Reporting Package Effective August 31, 2024, CSC will close the books within the stipulated time and the audit will be completed in a timely manner to comply with federal guidelines for submission to the FAC. Proposed Completio...
Corrective Action: Name of Contact Person Wayne Moyer Data Collection Reporting Package Effective August 31, 2024, CSC will close the books within the stipulated time and the audit will be completed in a timely manner to comply with federal guidelines for submission to the FAC. Proposed Completion Date: August 31, 2024.
Corrective Action: Name of Contact Person Wayne Moyer and Brenda Chandler To further prevent the issues regarding employee clearances, CSC HR department will have an in-depth discussion with the grantor at time of grant renewal to ensure that the contract language states that the clearances for hir...
Corrective Action: Name of Contact Person Wayne Moyer and Brenda Chandler To further prevent the issues regarding employee clearances, CSC HR department will have an in-depth discussion with the grantor at time of grant renewal to ensure that the contract language states that the clearances for hiring will be the responsibility of the grantor. While the grantor placed the instructions for clearances in the scope of work for Safe Passage, it was not clearly outlined in the grant under personnel requirements. Proposed Completion Date August 31, 2024
View Audit 322995 Questioned Costs: $1
Department of Housing and Urban Development Homeless No More, Inc., HUD Project No. 122-HD085-WDD-NP, respectfully submits the following Corrective Action Plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Suchan & Associates, An Accountancy Corporat...
Department of Housing and Urban Development Homeless No More, Inc., HUD Project No. 122-HD085-WDD-NP, respectfully submits the following Corrective Action Plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Suchan & Associates, An Accountancy Corporation, 8588 Utica Ave. Suite 100, Rancho Cucamonga, California 91730. Audit Period: January 1, 2023 through December 31, 2023 The finding from the 2023 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. Section A of the Schedule, Summary of Audit Results does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENTS AUDIT None FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING NO. 2023-001 Section 811 (Capital Advance Loan), AL No. 14.181 Recommendation: The Project should fund the replacement reserves shortage as soon as possible and make the required monthly deposits in accordance with the regulatory agreement. Action Taken: As of the current date the delinquent deposits have not been brought up to date due to ongoing cash flows issues. The Project has not received tenant rental subsidies in year 2024, even though timely filed. The replacement reserve account will be funded as soon as the HUD assistance payments are received. If you have any questions regarding the plan, please call Dan O’Brien, Chief Financial Officer (213) 251-3410. Sincerely, Dan O’Brien Chief Financial Officer
Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Corrective Action Plan for Significant Deficiency and Noncompliance over Reporting Foundation employees’ time and effort reports are submitted monthly to t...
Program: AL No. 10.523 Centers of Excellence at 1890 Institutions Significant Deficiency and Noncompliance over Allowable Costs/Costs Principles Corrective Action Plan for Significant Deficiency and Noncompliance over Reporting Foundation employees’ time and effort reports are submitted monthly to the Director of Finance. The Director of Finance reviews time and effort reports and compiles the data to allocate personnel expenditures, however, the time stamp of approvals was not effectively documented during 2023. The Foundation has implemented procedures to effectively time stamp the review and approval process, each month. Contact Person: Calece Hilliard, CFAO 1890 Universities Foundation Completion Date: September 30, 2024
Turnover and vacancies in positions resulting in applications and petitions not being completed within 20 days of receipt. The Domestic Relations Department filled vacant positions through 2023. In response to the prior year finding, the Domestic Relations Department provided semi-annual training t...
Turnover and vacancies in positions resulting in applications and petitions not being completed within 20 days of receipt. The Domestic Relations Department filled vacant positions through 2023. In response to the prior year finding, the Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/petitions to case files and file documentation beginning in November 2023.
The County Human Services department noted that the service providers were paid at their negotiated rates agreed upon by contract terms, however no reconciliation was completed for the remainder eligible cost adjustments to the service providers for the fiscal year ended June 30, 2023. The County Hu...
The County Human Services department noted that the service providers were paid at their negotiated rates agreed upon by contract terms, however no reconciliation was completed for the remainder eligible cost adjustments to the service providers for the fiscal year ended June 30, 2023. The County Human Services department will complete the reconciliation of the service providers costs reports for the fiscal year ended June 30, 2024 before March 2025.
The County Human Services department will complete the Roster of Personnel (PW 1171) be submitted for the fiscal year ended June 30, 2023 by December 2024 and review the processes and controls to ensure the rosters is completed annually.
The County Human Services department will complete the Roster of Personnel (PW 1171) be submitted for the fiscal year ended June 30, 2023 by December 2024 and review the processes and controls to ensure the rosters is completed annually.
The County Human Services department has requested approval from PA DHS of its 2021-2022 fiscal year re-submission in September 2024. Following approval of the 2021-2022 submission and re-investment the County Human Services department will complete the submission of the 2022-2023 fiscal year report...
The County Human Services department has requested approval from PA DHS of its 2021-2022 fiscal year re-submission in September 2024. Following approval of the 2021-2022 submission and re-investment the County Human Services department will complete the submission of the 2022-2023 fiscal year report. The County Human Services department will reconcile the underlying expenditure detail in the accounting system to the expenditures reported. Internal approvals prior to submission and underlying records for reports will be maintained by the County Human Services department.
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