Corrective Action Plans

Finding 499659 (2023-004)

Significant Deficiency 2023

CA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.430

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is...

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: December 2025

View Audit 322528

Finding 499644 (2023-003)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

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

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, ma...

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, management plans to collaborate with its Payroll Service Provider to capitalize on software upgrades, aiming to enhance the accuracy of Time & Allocation to grants and reduce errors by designing straight-through-process improvements. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: October 2024 – immediate term and December 2025 - software implementation.

View Audit 322528 Questioned Costs: $1

Finding 499640 (2023-001)

None 2023

Housing Opportunities, Inc.

NC

Questioned Costs Reporting

HOUSING OPPORTUNITIES, INC. P.O. Box 10248 Greensboro, North Carolina 27404 CORRECTIVE ACTION PLAN Single Audit Clearinghouse 1201 East 10th Street Jeff...

HOUSING OPPORTUNITIES, INC. P.O. Box 10248 Greensboro, North Carolina 27404 CORRECTIVE ACTION PLAN Single Audit Clearinghouse 1201 East 10th Street Jeffersonville, Indiana 47132 Housing Opportunities, Inc. (the"Organization"), respectfully submits the following Corrective Action Plan for the year ended December 31, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Greensboro, North Carolina 27410 Audit period: Year ended December 31, 2023 The finding from the December 31, 2023 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings and Questioned Costs: Finding 2023-001: Section III-Findings and questioned costs relating to the major programs which are required to be reported as defined by the Uniform Guidance [2 CFR 200.516(a)] Recommendation: The Organization should continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Management's Response: Management reviews the financial stability of the banking institutions which hold the Organizations' funds on an ongoing basis and will continue to do so. Management does not feel at this time that the funds are truly at risk based on current market conditions and the reviews they continually do on the financial stability of the banking institutions holding these funds. Management will transfer the funds at any point they believe the funds are truly at risk. If you have questions regarding this plan, please call Hona Moore at 336-544-2300. Sincerely yours, Hona Moore Partnership Property Management

View Audit 322521

Finding 499638 (2023-002)

Material Weakness 2023

Urban Redevelopment Authority of Pittsburgh

PA

Questioned Costs Procurement, Suspension & Debarment

Finding 2023-002: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Requirements U.S. Department of Treasury, Passes through the City of Pittsburgh and the Commonwealth of Pennsylvania, Department of Community and Economic Development-Assistance Listing Number 21.027 Condi...

Finding 2023-002: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Requirements U.S. Department of Treasury, Passes through the City of Pittsburgh and the Commonwealth of Pennsylvania, Department of Community and Economic Development-Assistance Listing Number 21.027 Condition: During 2023, the URA did not follow the internal control procedures to ensure all covered contracts and subawards were not conducted with entities that are suspended and debarred. The URA's current process is supposed to ensure that all contracts, agreements and grants include a clause or condition that the entity is not suspended or debarred. We reviewed samples of covered transactions and noted that 17 out of 20 transactions did not have the suspension and debarment clause within the agreement. In conjunction with the audit, we reviewed the System for Award management (SAM) Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. Action: The URA will add suspension and debarment back to all agreements. For the agreements that have been administered, the URA will review SAM.gov to ensure the client is not in the system.

View Audit 322520 Questioned Costs: $1

Finding 499629 (2023-002)

Material Weakness 2023

Hamilton County Economic Development Corporation

IN

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

Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement. Response: The Organizations’ Board and Chief Executive Officer (CEO) and key HCEDC Staff recognize the need to further refine internal controls. Management recognized one ins...

Condition: During our testing of federal expenditures, we noted that certain expenses were submitted twice for reimbursement. Response: The Organizations’ Board and Chief Executive Officer (CEO) and key HCEDC Staff recognize the need to further refine internal controls. Management recognized one instance in which duplicate reimbursement occurred. The duplication was reported to the funding agency (Indiana Department of Education) upon discovery and reconciled in order to place grant expenditures in good standing. Corrective Actions Taken: HCEDC staff has been working with CliftonLarsonAllen since March 2024 to design and implement new controls to prevent these types of errors occurring in the future. HCEDC is also onboarding a Grants Management Software to provide additional tracking and reporting transparency for funders and audit purposes. Timeline for Implementation: • Grant Management Software – October 2024 • CliftonLarsonAllen LLP engaged – March 2024

View Audit 322512 Questioned Costs: $1

Finding 499617 (2023-001)

Material Weakness 2023

County of Jefferson

PA

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

Subrecipient Monitoring AL 93.778 Medical Assistance Program and DHS Medical Assistance Criteria: PA DHS compliance require the County to perform subrecipient monitoring procedures over MATP funding disbursed to the Program’s vendor. Condition: During the audit, it was noted that the County was no...

Subrecipient Monitoring AL 93.778 Medical Assistance Program and DHS Medical Assistance Criteria: PA DHS compliance require the County to perform subrecipient monitoring procedures over MATP funding disbursed to the Program’s vendor. Condition: During the audit, it was noted that the County was not performing subrecipient monitoring over the Program’s vendor. Cause: The County does not have adequate controls in place or the expertise to ensure proper subrecipient monitoring procedures. Effect: The Program’s vendor may be using grant funding inappropriately. This is a repeat finding from the prior year – Finding 2022-001. Questioned Costs: The amount of questioned costs, if any, is undeterminable Recommendation: The County should implement internal control procedures that ensure the vendor is being properly monitored. Management Response: Management maintains that they do not have adequate controls or proper expertise to monitor the vendor. Management will contract a firm to provide oversight over the vendor. Anticipate Completion Date: Immediate

View Audit 322490

Finding 499616 (2023-002)

Material Weakness 2023

County of Jefferson

PA

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

Subrecipient Monitoring AL 21.023 Emergency Rental Assistance Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program’s vendor. Condition: During the audit, it was noted that the County was not perfor...

Subrecipient Monitoring AL 21.023 Emergency Rental Assistance Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program’s vendor. Condition: During the audit, it was noted that the County was not performing subrecipient monitoring over the Program’s vendor. Cause: The County does not have adequate controls in place or the expertise to ensure proper subrecipient monitoring procedures. Effect: The Program’s vendor may be using grant funding inappropriately. This is a repeat finding from the prior year – Finding 2022-002. Questioned Costs: The amount of questioned costs, if any, is undeterminable Recommendation: The County should implement internal control procedures that ensure the vendor is being properly monitored. Management Response: Management maintains that they do not have adequate controls or proper expertise to monitor the vendor. Management will contract a firm to provide oversight over the vendor. Anticipate Completion Date: Immediate

View Audit 322490

Finding 499610 (2023-001)

Significant Deficiency 2023

Hazel Dell Non Profit Housing

WA

Questioned Costs Eligibility HUD Housing Programs

Name of Auditee: Hazel Dell Non-Profit Housing FHA Auditee Identification Number: 126-EE027 Period Covered by the Audit: Year ended December 31, 2023 CAP provided by: Name: Andrea Bean Position: Director of Property Management Telephone Number: 360-694-2501 Finding 2023-001: 1. Statement of...

Name of Auditee: Hazel Dell Non-Profit Housing FHA Auditee Identification Number: 126-EE027 Period Covered by the Audit: Year ended December 31, 2023 CAP provided by: Name: Andrea Bean Position: Director of Property Management Telephone Number: 360-694-2501 Finding 2023-001: 1. Statement of Condition: Four of the tenant file selected for review were charged with rental rates higher than the HAP contract. 2. Cause: Property manager error on contract rate input. 3. Actions Taken on the Finding: Property manager will be bringing the rent roll and voucher submission process to the centralized Compliance team. This team member will run the rent rolls, comparing them to the current rent schedules on file. Once this first approval is completed, the rent rolls will be sent to onsite property managers for approval.

View Audit 322465 Questioned Costs: $1

Finding 499571 (2023-004)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

Questioned Costs Special Tests & Provisions Significant Deficiency

Response to Finding 2023-004 The Authority generally concurs with the auditor’s findings and recommendations regarding the handling of HQS deficiencies. To address this, the Authority will implement a more rigorous process to ensure timely correction of deficiencies and adherence to abatement proced...

Response to Finding 2023-004 The Authority generally concurs with the auditor’s findings and recommendations regarding the handling of HQS deficiencies. To address this, the Authority will implement a more rigorous process to ensure timely correction of deficiencies and adherence to abatement procedures. 1. Enhanced Correction Process: • Effective October 2024, the Authority will introduce stricter timelines and automated reminders for staff to manage I IQS deficiencies. • Tf a deficiency is not corrected within the timeframe specified in the HAKC HCV Admin Plan, it will automatically escalate to the HCV Inspection Manager and Supervisor for immediate action. • Immediate actions include placing the unit on hold in the Elite system, issuing a notice to the landlord and participant, and sending an email to the Specialist to issue a voucher for the participant to move, if necessary. • A formal letter will be sent to both the landlord and tenant notifying them of the identified deficiencies, along with a set timeframe of 30 days for the repairs to be completed. A re-inspection date will be scheduled to verify that repairs have been made. 2. Abatement Process: • If repairs are not made by the set re-inspection date, an abatement letter will be sent to both the landlord and tenant, notifying them that HAP payments will cease on the first day of the following month, providing a minimum of 30 days' notice. • At this time, a letter will also be sent to the tenant notifying them that a voucher will be issued to allow them to move to a more suitable unit. 3. Termination of HAP Contract: • If repairs are still not completed by the end of the 30-day abatement period, the HAP contract will be terminated along with the HAP payment. A termination of HAP letter will be sent to the landlord and tenant for the current unit. 4. Documentation and Review Process: • The Inspection Department will maintain a weekly abatement spreadsheet documenting the reason for abatement, the start and end dates of the abatement, and any associated inspection reports. • This spreadsheet, along with the abated inspection documentation, will be reviewed at the beginning and end of each month before closeout to ensure that the abatement process is properly initiated and managed. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024 If the Department of Housing and Urban Development has questions regarding this plan, please call LaMonyka French, Deputy, Executive Director at (816) 968-4100.

View Audit 322424 Questioned Costs: $1

Finding 499570 (2023-003)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Questioned Costs Special Tests & Provisions

Response to Finding 2023-003 The Authority generally concurs with the auditor’s findings and recommendations. To address the finding related to inadequate documentation for rent reasonableness determinations, the Authority will implement the following corrective actions: 1. Immediate and Ongoing Tra...

Response to Finding 2023-003 The Authority generally concurs with the auditor’s findings and recommendations. To address the finding related to inadequate documentation for rent reasonableness determinations, the Authority will implement the following corrective actions: 1. Immediate and Ongoing Training: • To ensure consistency, increase staff knowledge, and reduce errors, the Authority will conduct immediate training sessions for all relevant staff, followed by annual refresher training. These sessions will focus on the correct procedures for documenting rent reasonableness and the importance of maintaining accurate and complete records. 2. Enhanced Quality Control and Error Monitoring: • The Authority will increase the frequency of quality control file reviews to identify errors promptly and address their root causes to prevent systemic issues. • Errors will be tracked by type and by the staff member responsible, allowing for the identification of patterns. Additional training will be provided for common error types and to individuals who are frequently responsible for errors. 3. Comprehensive File Reviews: • Quality reviews will be conducted on all files to ensure the presence of all required documents. It is anticipated that the initial comprehensive file review will take approximately one year to complete. • After the initial review, files will be selected randomly for review according to an established quality control schedule. This ongoing review process will ensure continuous compliance and address any issues as they arise. 4. Responsibility for Document Collection: • Each team member will be responsible for collecting any missing documents identified during the annual recertification, interim recertification, or change of unit processes. This accountability measure ensures that all necessary documentation is gathered and maintained consistently. 5. Adoption of a Digital Platform: • As part of the corrective action, the Authority has adopted a digital platform that requires the completion of all necessary fields before a rent determination can be finalized. This platform will also retain all documentation used to determine rent reasonableness for at least two years, ensuring thorough and accessible records. 6. Increased Random Audits: • Effective October 2024, random audits will be increased to monthly reviews to identify any discrepancies early and to ensure ongoing compliance with documentation requirements. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024

View Audit 322424

Finding 499569 (2023-002)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

Questioned Costs HUD Housing Programs Reporting

Response to Finding 2023-002 The Authority generally concurs with the auditor’s findings and recommendations. The Authority has implemented procedures to ensure recertifications are promptly uploaded to the PIC system. Effective August 2024, we have adopted a system that flags any recertification no...

Response to Finding 2023-002 The Authority generally concurs with the auditor’s findings and recommendations. The Authority has implemented procedures to ensure recertifications are promptly uploaded to the PIC system. Effective August 2024, we have adopted a system that flags any recertification not uploaded to PIC. A HAKC Quality Control employee is responsible for daily uploads from Monday through Friday. With each upload, any fatal errors encountered are documented in an Excel spreadsheet. Once the error has been corrected in the PIC system, the correction is recorded on the spreadsheet, and the corresponding green status from PIC is printed for documentation, confirming that the issue has been resolved. To maintain ongoing compliance, bi-weekly audits will be conducted to verify that no files are missing from the PIC system. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024

View Audit 322424

Finding 499568 (2023-001)

Significant Deficiency 2023

Housing Authority of Kansas City, Missouri

MO

Questioned Costs Eligibility Significant Deficiency

Response to Finding 2023-001 The Authority generally concurs with the auditor’s findings and recommendations. To address these issues, the Authority has implemented the following corrective actions: 1. Mandatory Refresher Training: • Effective May 2024, the Authority has rolled out mandatory refresh...

Response to Finding 2023-001 The Authority generally concurs with the auditor’s findings and recommendations. To address these issues, the Authority has implemented the following corrective actions: 1. Mandatory Refresher Training: • Effective May 2024, the Authority has rolled out mandatory refresher training for all relevant staff on eligibility documentation and recertification processes. This training ensures that all staff are fully aware of the correct procedures and policies, and that they understand the importance of maintaining complete and accurate tenant files and performing recertifications in a timely manner. 2. Implementation of a New Tracking System: • A new tracking system has been implemented to ensure that all documentation is completed timely and verified by a supervisor. This system allows for real-time monitoring of the documentation process, ensuring that all required documents are included in the tenant files. 3. Utilization of Checklists: • The Authority has introduced a mandatory checklist that staff are required to use every time a file is accessed or updated. This checklist serves as a tool to ensure that all necessary steps are taken, and all required documentation is included in the tenant file. 4. Enhanced Monitoring by HCV Director and Supervisors: • The HCV Director and Supervisors will closely monitor the recertification process to ensure that all recertifications are completed in a timely manner and in accordance with policy. This includes ensuring that all participants receive and return their recertification paperwork as required. 5. Increased Frequency of Quality Control Reviews: • The Authority will continue to conduct quality control file reviews and will increase the frequency of these reviews to identify errors sooner. This proactive approach will help address the root causes of errors quickly and prevent systemic issues from developing. 6. Ongoing Quality Reviews: • Continuous quality reviews will be conducted for all files to ensure that all required documents are present and that all recertifications are performed on time. This ongoing process is designed to maintain high standards of accuracy and compliance in tenant file management. Name of the contact person responsible for corrective action: Deputy Executive Director LaMonyka French Completion Date: December 2024

View Audit 322424

Finding 499559 (2023-001)

Significant Deficiency 2023

Nonprofit Finance Fund and Affiliate

NY

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

Planned Corrective Action: NFF revised current year SEFA for expenses which did not meet the compliance requirement. In addition, management implemented review control whereby the expenditures will be reviewed to ensure compliance with federal agency requirements. Beginning in August 2024, NFF wil...

Planned Corrective Action: NFF revised current year SEFA for expenses which did not meet the compliance requirement. In addition, management implemented review control whereby the expenditures will be reviewed to ensure compliance with federal agency requirements. Beginning in August 2024, NFF will update its time and effort management and review of employees who perform work related to federal grants. This includes circulating a tracking spreadsheet monthly to relevant staff to certify their time and effort spent on eligible activities allowable for grant expenditure relative to their overall work performed, which will be used for salary and benefit allocations. The Finance team will circulate the spreadsheet first to relevant staff members for certification, and then department heads for management review and approval. For department head time and effort review and approval, the executive suite will review and approve. The spreadsheet and approvals will be saved as back up for the allocations each month.

View Audit 322416 Questioned Costs: $1

Finding 499557 (2023-001)

Significant Deficiency 2023

America's Poison Centers

VA

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

Views of Responsible Officials: In 2024, the recommendation was implemented. Allocations will be reviewed by the outsourced accounting team to ensure that this has been executed upon. The CEO is responsible for overseeing both the new HR service provider and the outsourced accounting team and will e...

Views of Responsible Officials: In 2024, the recommendation was implemented. Allocations will be reviewed by the outsourced accounting team to ensure that this has been executed upon. The CEO is responsible for overseeing both the new HR service provider and the outsourced accounting team and will ensure that this does not recur.

View Audit 322412

Finding 499549 (2023-002)

Significant Deficiency 2023

Lakewood Resource & Referral Center-D/b/a/ Center for Health Education

NJ

Questioned Costs Special Tests & Provisions Eligibility

CORRECTIVE ACTION PLAN September 27, 2024 Health Resources and Services Administration Lakewood Resource and Referral Center, Inc. D/B/A Center for Health Education, Medicine and Dentistry respectfully submits the following corrective action plan for the year ended December 31, 2023. _____________...

CORRECTIVE ACTION PLAN September 27, 2024 Health Resources and Services Administration Lakewood Resource and Referral Center, Inc. D/B/A Center for Health Education, Medicine and Dentistry respectfully submits the following corrective action plan for the year ended December 31, 2023. ____________________________________________________________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2023 The findings from the December 31, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT FINDINGS Finding 2023-001 – Account Analyses MATERIAL WEAKNESS Recommendation We recommend that the Center ensure that all accounting records are analyzed and reconciled on a monthly basis. We also recommend that necessary procedures be enhanced whereby an employee of the Center consistently reviews and follows up on receivables and adjusts the reserves for those receivables appropriately. This will help accurately reflect the cash realizable value of receivables. This will provide the Center with a stronger accounting of patient services receivable with which to better manage cash collections. We also recommend that the Center perform the patient services revenue reconciliation by payor source on a monthly basis. This would help the Center determine whether patient services revenue is being properly recorded by payor source. Action Taken Management of the Center agrees with the finding and has started to work with a new general ledger software package at the start of 2024, to better accommodate monthly reconciliations. We will also ensure that these analyses and reconciliations will be reviewed on a consistent and timely basis. There has been steady improvement throughout 2024, and it is expected to be complete by the end of 2024. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, COVID-19 Health Centers Program Cluster (Assistance Listing Number 93.224/93.527) Finding 2023-002 – Special Tests and Provisions SIGNIFICANT DEFICIENCY Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts are being properly calculated. Supervisors should monitor and review the sliding fee calculations on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Action Taken Management of the Center is providing additional training to the relevant staff that deal with the Sliding Fee Discount (SFD). These staff members include front desk staff, financial counselors, and the general finance and billing departments, as applicable. The SFD Policy and SFD Scale are being reviewed by management to ensure that the guidelines and procedures are clear. Revisions to the SFD Policy and SFD Scale will be made, and Board approved, if necessary to improve clarity. To ensure that the SFD is being properly calculated in accordance with the SFD Scale, a monitoring process will be included, which may include internal periodic audits by supervisors. All changes will be finalized and implemented by the end of 2024. If the Health Resources and Services Administration has questions regarding this plan, please call Scott Jackson, Chief Financial Officer at (732) 364-2144 x6138. Sincerely yours, Scott Jackson, CFO

View Audit 322404

Finding 499543 (2023-004)

Material Weakness 2023

Perry County

IN

Allowable Costs / Cost Principles Material Weakness Reporting § 200.1 § 200.303

FINDING 2023-004 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Summary of Finding: Perry County did not properly report period expenditures. The County submitted one P&E report during the audit period. Although the Deputy Auditor compiled the information fo...

FINDING 2023-004 Subject: COVID 19 - Coronavirus State and Local Fiscal Recovery Fund - Reporting Federal Summary of Finding: Perry County did not properly report period expenditures. The County submitted one P&E report during the audit period. Although the Deputy Auditor compiled the information for the report and the County Auditor reviewed and submitted the report, the internal controls were not effective in preventing, or detecting and correcting, errors. As a result, the P&E report contained errors. Contact Person Responsible for Corrective Action: Kristinia L. Hammack, Perry County Auditor Contact Phone Number: (812) 547-6427 Views of Responsible Officials: We concur with the audit finding. Description of Corrective Action Plan: The Auditor is now aware that the P&E Reporting Period is not calendar. All internal control will stay in place and this information will be noted for further SLFRF Reporting. The Auditor will review the reports prior to submission to ensure that the reporting period is not on a calendar year when reporting. Completion Date: March 1, 2025 INDIANA STATE

View Audit 322397

Finding 499540 (2023-003)

Significant Deficiency 2023

Tongue River Valley Joint Powers Board

WY

Procurement, Suspension & Debarment Questioned Costs Significant Deficiency § 200.326

2023-003 Uniform Guidance Written Policies and Procedures Significant Deficiency in Internal Control and Compliance According to the USDA-RD, the Tongue River Valley Joint Powers Board/The Tongue River Gas distribution project is exempt from being compliant with the Davis Bacon Labor Laws. Therefore...

2023-003 Uniform Guidance Written Policies and Procedures Significant Deficiency in Internal Control and Compliance According to the USDA-RD, the Tongue River Valley Joint Powers Board/The Tongue River Gas distribution project is exempt from being compliant with the Davis Bacon Labor Laws. Therefore, the Board believes this finding is not applicable. The bidding and bonding process for the construction of the Natural Gas Distribution system complied with all Federal Regulations. The current activities are funded by user fee which are in part used to make loan payments.

View Audit 322395 Questioned Costs: $1

Finding 499531 (2023-012)

Material Weakness 2023

Hennepin County Minnesota

MN

Questioned Costs Procurement, Suspension & Debarment

Subject: Hennepin County’s 2023 Corrective Action Plan Finding# 2023-012 Procurement Program: Congressional Directives (ALN 93.493) Type of Finding: Material Weakness in Internal Control over Compliance; Material Noncompliance Finding Condition: The county hospital does not have effective int...

Subject: Hennepin County’s 2023 Corrective Action Plan Finding# 2023-012 Procurement Program: Congressional Directives (ALN 93.493) Type of Finding: Material Weakness in Internal Control over Compliance; Material Noncompliance Finding Condition: The county hospital does not have effective internal controls over the procurement requirement of the Congressional Directives program, which resulted in two instances of noncompliance. During our testing we noted: Small Purchases: In our sample of six small purchases we found the following exceptions for five of the selections: • The county hospital purchased lab equipment with a total cost of $118,000 but did not seek more than a single quote when two distributors were available, which resulted in noncompliance with the procurement requirements. The price of the equipment is set by the manufacturer. The county hospital cited sole source as the procurement method but the circumstances cited by the county hospital , an established relationship with the vendor, did not meet one of the allowable criteria under the regulations. The county hospital was unable to provide support that it maintained records documenting the history of the procurement. • The county hospital obtained architectural services with a total cost of $31,259 using noncompetitive negotiation but none of the criteria allowing for noncompetitive procurements were met, which resulted in noncompliance with the procurement requirements. The county hospital was unable to provide support that it maintained records documenting the history of the procurement, including the selection of the architect for this procurement or the initial selection. • The county hospital obtained fluid management equipment with a total cost of $39,756 but did not maintain documentation of the history of the procurement decision, including the decision to use the pricing available through a Group Purchasing Organization. • The county hospital purchased infant care equipment with a total cost of $83,676 but did not maintain documentation of the history of the procurement decision, including the decision to use the pricing available through a Group Purchasing Organization. • The county hospital purchased imaging equipment with a total cost of $170,370 but did not maintain documentation of the history of the procurement decision, including the decision to use the pricing available through a Group Purchasing Organization. Formal Methods: In our sample of two procurements requiring formal methods we found the following exceptions: • The county hospital purchased infant care equipment with a total cost of $345,923 by seeking quotes from two different vendors, but based on the size of the procurement the county hospital should have utilized one of the formal procurement methods such as sealed bids or competitive proposals. The county hospital later decided to use the pricing available through a Group Purchasing Organization but was unable to provide support that it maintained records documenting the history of the procurement. • The county hospital selected ultrasound equipment with a total cost of $600,000 by seeking product demonstrations from three different vendors. The county hospital did not maintain records to demonstrate that the responses were the result of public solicitation. The county hospital was unable to provide documentation to support that it maintained records documenting the history of the procurement, including a cost/price analysis and decision to use a contract through a Group Purchasing Organization. During 2023 the county hospital did not have written procurement policies that conformed to the requirements of the Uniform Guidance, including the requirement to maintain records of the history of the procurement. State law specifically exempts the county hospital from the State's own laws related to local government procurement, but this has not been replaced by local laws or policies and procedures specific to procurement. Hennepin County’s Corrective Action Planned in Response to Finding: Hennepin Healthcare System, Inc. (HHS) implemented procedures in its Peoplesoft system to document sole source or competitive pricing prior to vendor approval. The process will be reviewed with all new grants with the individuals involved in the grants. Additionally, Hennepin Healthcare System, Inc. implemented policies around federal procurement procedures, which was posted online to the policy communication and storage site for employees. Hennepin County Employee Responsible for the CAP: Mark Willmert Planned Completion Date for CAP: December 31, 2024

View Audit 322389 Questioned Costs: $1

Finding 499515 (2023-003)

Significant Deficiency 2023

Hispanic-American Institute Inc.

NM

Special Tests & Provisions Questioned Costs Procurement, Suspension & Debarment

View of Responsible Official: On September 25, 2024, we notified AmeriCorps of this finding and are seeking concurrence from the AmeriCorps SCP Advisory Council for our programs. Finding resolved timeline: October 15, 2024. Designated of employee position responsible for meeting this deadline: Bruce...

View of Responsible Official: On September 25, 2024, we notified AmeriCorps of this finding and are seeking concurrence from the AmeriCorps SCP Advisory Council for our programs. Finding resolved timeline: October 15, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, president and Authorized Representative.

View Audit 322381

Finding 499514 (2023-002)

Significant Deficiency 2023

Hispanic-American Institute Inc.

NM

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles

View of Responsible Official: We have undertaken additional training and review of regulations in this area to assure compliance. Finding resolved timeline: December 1, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President and program Authoriz...

View of Responsible Official: We have undertaken additional training and review of regulations in this area to assure compliance. Finding resolved timeline: December 1, 2024. Designated of employee position responsible for meeting this deadline: Bruce Young-Candelaria, President and program Authorized Representative

View Audit 322381 Questioned Costs: $1

Finding 499511 (2023-001)

None 2023

Gates Plaza Housing Development Fund Company, Inc.

NY

Questioned Costs Cash Management HUD Housing Programs

Criteria The Entity is required to maintain residual receipts in an interest-bearing account. Condition The Entity’s residual receipts were not maintained in an interest-bearing account. Cause The interest rate on the account was changed by the bank, which was not noticed by management personnel b...

Criteria The Entity is required to maintain residual receipts in an interest-bearing account. Condition The Entity’s residual receipts were not maintained in an interest-bearing account. Cause The interest rate on the account was changed by the bank, which was not noticed by management personnel before the year end. Context When performing out audit, we noted that the Entity's residual receipts did not earn interest in 2023. Questioned Costs none noted. Effect The Entity was not in compliance with the requirement to maintain its residual receipts in an account that bears interest. Recommendation We recommend the Entity contact the bank to correct the interest rate on the account or move the balance to an interest-bearing account. Views of the Responsible Official See Corrective Action Plan

View Audit 322373

Finding 499499 (2023-002)

Material Weakness 2023

Wicomico County Housing Authority

MD

Special Tests & Provisions Questioned Costs HUD Housing Programs

Recommendation: The Authority should review and enhance its internal controls to ensure: · the utility allowance schedules are reviewed and updated as necessary at least annually; and units are inspected annually under HQS. Explanation of disagreement with audit finding: There is no disagreement wit...

Recommendation: The Authority should review and enhance its internal controls to ensure: · the utility allowance schedules are reviewed and updated as necessary at least annually; and units are inspected annually under HQS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority specialist responsible for file maintenance and recertifications during fiscal year 2022 and early 2023 is no longer with the Agency. The Authority has experienced staff now in place to perform these services. The Authority will revisit our policy and procedures over recertification, HQS, and file maintenance to ensure documentation is maintained and is in compliance with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2024

View Audit 322360

Finding 499498 (2023-001)

Material Weakness 2023

Wicomico County Housing Authority

MD

HUD Housing Programs Questioned Costs Eligibility

Recommendation: The Authority should review and enhance its internal controls to ensure: . management obtains and reviews documentation supporting United States of America citizenship; . tenants provide release forms prior to obtaining necessary documentation; . management verifies income listed on ...

Recommendation: The Authority should review and enhance its internal controls to ensure: . management obtains and reviews documentation supporting United States of America citizenship; . tenants provide release forms prior to obtaining necessary documentation; . management verifies income listed on the HUD Form 50058; and recertifications are consistently reviewed and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority specialist responsible for file maintenance and recertifications during fiscal year 2022 and early 2023 is no longer with the Agency. The Authority has experienced staff now in place to perform these services. The Authority will revisit our policy and procedures over recertification and file maintenance to ensure documentation is maintained and is in compliance with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Don Bibb, Executive Director Planned completion date for corrective action plan: December 31, 2024

View Audit 322360

Finding 499493 (2023-004)

Significant Deficiency 2023

The Young Men's Christian Association of Metropolitan Denver

CO

Questioned Costs Allowable Costs / Cost Principles

Controls over Payroll charged to Federal Awards Condition: The YMCA is responsible for ensuring that support for all federal expenditures including payroll charged to federal grants is properly maintained. Criteria: Internal controls need to be sufficient to ensure that support for federal expend...

Controls over Payroll charged to Federal Awards Condition: The YMCA is responsible for ensuring that support for all federal expenditures including payroll charged to federal grants is properly maintained. Criteria: Internal controls need to be sufficient to ensure that support for federal expenditures is available, including payroll records that agree to amounts charged to federal grants. Cause: The YMCA experienced turnover in the accounting department and the CFO position. Records were not maintained to support payroll costs charged to federal grants. Effect: When adequate support is not obtained and used to support the amount charged to the federal program or support by an after-the-fact review, there is a risk that unsupported or inaccurate costs are being charged to the federal program. Recommendation: We recommend proper control activities should be implemented to allow for a consistent, accurate, and allowable method to support distribution of personnel charges to federal programs. If management elects to continue to allocate personnel charged based on a budget estimate, the after-the-fact review should be properly documented. Views of Responsible Officials and Planned Corrective Action: The CFO, along with the financial team will implement a process to perform timely review of salary expense charged to federal awards, and retain records by pay period as support for expenditures charged to federal awards.

View Audit 322351 Questioned Costs: $1

Finding 499491 (2023-003)

Significant Deficiency 2023

The Young Men's Christian Association of Metropolitan Denver

CO

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Controls over Allowable Costs Condition: The YMCA is responsible for ensuring that support for all federal expenditures is properly maintained. Criteria: Internal controls need to be sufficient to ensure that support for federal expenditures is available, including receipts that agree to amounts ...

Controls over Allowable Costs Condition: The YMCA is responsible for ensuring that support for all federal expenditures is properly maintained. Criteria: Internal controls need to be sufficient to ensure that support for federal expenditures is available, including receipts that agree to amounts charged to federal grants. Cause: The YMCA experienced turnover in the accounting department and the CFO position. Receipts including purpose were not available for all expenditures charged to the federal grant. Effect: Proper documentation was not available for the audit. Recommendation: We recommend the YMCA institute an internal policy that requires expenditures related to federal awards be retained, including purpose, receipts/invoices, coding, and review of approval. Views of Responsible Officials and Planned Corrective Action: The CFO, along with the financial team will review federal awards and expenses charged to federal programs to ensure amounts are coded in the appropriate manner. The CFO and financial team will ensure that support is retained and available for all expenses charged to federal programs.

View Audit 322351 Questioned Costs: $1

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