Corrective Action Plans

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Finding 375557 (2023-006)
Significant Deficiency 2023
Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact per...
Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-007 Inadequate Request for Information Name of contact person: Corrective Action: Proposed Completion Date: Section III - Federal Award Findings and Questioned Costs Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. December 12, 2023 and ongoing. Linda Taylor, DSS Manager December 12, 2023 and ongoing. Electronic verifications discussed with all Medicaid Staff. Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. Linda Taylor, DSS Manager Section III - Federal Award Findings and Questioned Costs (continued) Linda Taylor, DSS Manager A training will be conducted at the end of the Continuous Coverage Unwinding per DHB-Admin. Letter 13-23. This policy is not required to be enforced at this time. We would like to reserve the rights to conduct this training at the is time to prevent confusing employees. Proposed training date to be held at the end of the Continous Coverage Undwinding period. Linda Taylor, DSS Manager Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training date December 12, 2023. December 12, 2023 and on going.
Finding 375556 (2023-005)
Significant Deficiency 2023
Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact per...
Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-007 Inadequate Request for Information Name of contact person: Corrective Action: Proposed Completion Date: Section III - Federal Award Findings and Questioned Costs Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. December 12, 2023 and ongoing. Linda Taylor, DSS Manager December 12, 2023 and ongoing. Electronic verifications discussed with all Medicaid Staff. Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. Linda Taylor, DSS Manager Section III - Federal Award Findings and Questioned Costs (continued) Linda Taylor, DSS Manager A training will be conducted at the end of the Continuous Coverage Unwinding per DHB-Admin. Letter 13-23. This policy is not required to be enforced at this time. We would like to reserve the rights to conduct this training at the is time to prevent confusing employees. Proposed training date to be held at the end of the Continous Coverage Undwinding period. Linda Taylor, DSS Manager Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training date December 12, 2023. December 12, 2023 and on going.
Finding 375555 (2023-004)
Significant Deficiency 2023
Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact per...
Finding 2023-004 IV-D Cooperation with Child Support Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-005 Inaccurate Information Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-006 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding 2023-007 Inadequate Request for Information Name of contact person: Corrective Action: Proposed Completion Date: Section III - Federal Award Findings and Questioned Costs Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. December 12, 2023 and ongoing. Linda Taylor, DSS Manager December 12, 2023 and ongoing. Electronic verifications discussed with all Medicaid Staff. Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training will be held December 12, 2023. Linda Taylor, DSS Manager Section III - Federal Award Findings and Questioned Costs (continued) Linda Taylor, DSS Manager A training will be conducted at the end of the Continuous Coverage Unwinding per DHB-Admin. Letter 13-23. This policy is not required to be enforced at this time. We would like to reserve the rights to conduct this training at the is time to prevent confusing employees. Proposed training date to be held at the end of the Continous Coverage Undwinding period. Linda Taylor, DSS Manager Agency will continue to complete second party reviews to monitor compliance with Medicaid policy. Agency will conduct quarterly trainings to address accuracy. Training date December 12, 2023. December 12, 2023 and on going.
Finding 2023-004: Capital Fund Grant Admin NHA Corrective Action: The Authority has all documentation on paper for all payment vouchers, statements that monies were drawn down correctly, invoices, and records of payments. The updated annual online budget forms were not completed in the required ...
Finding 2023-004: Capital Fund Grant Admin NHA Corrective Action: The Authority has all documentation on paper for all payment vouchers, statements that monies were drawn down correctly, invoices, and records of payments. The updated annual online budget forms were not completed in the required Capital Funds timeline regulations. Plans are underway to update the 2023 online budgets within the next month. Ongoing Capital Funds Education continues to be prioritized. Improvements in internal processes will be implemented as knowledge is accumulated. When these online budgets are updated with the information from the paper tracking documentation and submitted for approval to the regional office, it will be clear that the $206,189.50 in Questioned Costs in this finding were accurately distributed. In order to prevent this situation from occurring in the future, the Authority will follow the finding recommendation to provide the following reports at monthly board meetings beginning with the April 2024 board meeting.: • status of grants including grant award • obligation and expenditure deadlines • funds obligated • funds advance, and • funds expended
View Audit 294573 Questioned Costs: $1
Condition During the year ended June 30, 2023, the Center submitted a report for the funds used during the year ended June 30, 2022. The report submitted by the Center contained expenditure amounts that did not agree to the amounts reported on the schedule of expenditures of federal awards for the y...
Condition During the year ended June 30, 2023, the Center submitted a report for the funds used during the year ended June 30, 2022. The report submitted by the Center contained expenditure amounts that did not agree to the amounts reported on the schedule of expenditures of federal awards for the year ended June 30, 2022. Recommendation We recommend the Center update its report filing procedures to include comparing the expenditures entered on the annual performance report to the audited schedule of expenditures of federal awards. In addition, the report should also be reviewed by an individual separate from the person compiling the information. Management Response The report referenced was for FY 2021-22, and the data available at the time of reporting was minimal and incorrect. There were items that were purchased that were incorrectly coded to other grants or items purchased and charged to this grant that should have been charged to another. I have now instituted a procedure where each year’s spending per grant is maintained in a separate folder with the proper financial reports included as well as copies of invoices.
2023-004 Child Nutrition Cluster – 10.555 – National School Lunch Program, 10.559 – Summer Food Service Program for Children, 10.553 – School Breakfast Program – Procurement, Suspension, and Debarment Condition One procurement was tested for the Food Service Program, and it was found to not have fol...
2023-004 Child Nutrition Cluster – 10.555 – National School Lunch Program, 10.559 – Summer Food Service Program for Children, 10.553 – School Breakfast Program – Procurement, Suspension, and Debarment Condition One procurement was tested for the Food Service Program, and it was found to not have followed the District’s procurement plan. Recommendation The District should ensure that it follows its procurement policy for all applicable transactions. Comments on the Finding The District is aware of the oversight and has implemented procedures to prevent this, in the future. Actions Taken As of the date of this notice, staff involved with this procedure have undergone training through KASB and KSDE and have added the procedure of verifying quotes to ensure the procurement plan is followed to a monthly checklist to ensure that it occurs timely.
View Audit 294521 Questioned Costs: $1
Management is working with a consultant to revise the policies and develop financial procedures, which will be followed to assure that all reimbursement requests consistently include only applicable invoices as support. Once developed, these procedures will be approved by the Board and implemented ...
Management is working with a consultant to revise the policies and develop financial procedures, which will be followed to assure that all reimbursement requests consistently include only applicable invoices as support. Once developed, these procedures will be approved by the Board and implemented immediately.
View Audit 294512 Questioned Costs: $1
We were under the false notion that purchases made through the Commonwealth of Pennsylvania’s cooperative purchasing program (COSTAR) satisfied compliance of quote/bid requirements of federal purchases. We will follow our policy for federal purchases. When federal money is utilized, we will docume...
We were under the false notion that purchases made through the Commonwealth of Pennsylvania’s cooperative purchasing program (COSTAR) satisfied compliance of quote/bid requirements of federal purchases. We will follow our policy for federal purchases. When federal money is utilized, we will document three vendor quote/bid, rationale of procurement, selection of contractor, and basis of price. The district will continue to document sole source noncompetitive procurement exceptions. The District will implement the above procedure immediately.
View Audit 294465 Questioned Costs: $1
Finding 374738 (2023-003)
Significant Deficiency 2023
The County Attorney is writing up a policy.
The County Attorney is writing up a policy.
CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 ...
CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2023 The finding from the June 30, 2023 consolidated and combined schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None reported. FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Material Weakness FINDING 2023-001 Eligibility U.S. Department of Housing and Urban Development 14.157 Supportive Housing for the Elderly Section 202 Loan Condition: In connection with the audit, it was noted that of the eight lease files tested four files did not have timely recertification of tenants and Enterprise Income Verification system documentation was performed later than the required recertification date. Additionally, one file did not contain the signed application or the background check. Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: Management agrees with recommendation and has begun to implement the following: - A checklist form will be completed for every certification and signed off once file is approved. - An AR form will be created for the move in, transfer and move out process which is to be attached with proof of payment. Once completed it is to be sent to senior staff for review. Under this new management, we already have set in place policies and procedures under the governance of HUD and the tenant selection plan to ensure compliance and due diligence is taking place. Any new staff will be HUD trained. - The file setup format and recertification updates will be monitored on a monthly basis. - EIV are being run according to the frequency provisions related to the type of reports we are annually required to complete as per HUD. Annual inspections are being schedule as per Annual Recertifications are being processed. - Bi-weekly meetings will be in place to discuss the results collected with a tracking log on the progress of the project. - Trainings will be scheduled to keep on top of HUD updates/compliance procedures; Yardi software trainings; and in-house trainings covering compliance with the files and Yardi 50059 module. Expected completion date: January 2024 If any cognizant or oversight agency has questions regarding this plan, please call Lola Maroulis, Chief Financial Officer at 212-840-8005, extension 111. Sincerely yours, Lola Maroulis, Chief Financial Officer
Eagle Academy PCS agrees with the findings and has made the necessary corrections to address the payroll allocation. The school has hired a new Human Resources Manager, and the school also contracted with a third-party vendor that will be responsible for managing all grant reporting, applications, a...
Eagle Academy PCS agrees with the findings and has made the necessary corrections to address the payroll allocation. The school has hired a new Human Resources Manager, and the school also contracted with a third-party vendor that will be responsible for managing all grant reporting, applications, amendments, and reconciliations. This will strengthen the school year-end closing process and tighten internal controls in the human resources department. Management has also added an additional layer to the time & effort verification which will ensure that all reimbursement requests submitted will be based on actual expenses incurred and not estimates. This will eliminate the unpaid leave of the findings identified in the audit. This will strengthen internal controls and enhance Eagle Academy PCS reporting and grant tracking system.
View Audit 294423 Questioned Costs: $1
Prior to the year-end of June 30, 2023, Eagle Academy PCS had several federal grants that were approved and open for drawdown in May 2023. These were all related to grants budget to be reimbursed to the school during the 2022-2023 school year. Due to the late approval of the grants, the school and m...
Prior to the year-end of June 30, 2023, Eagle Academy PCS had several federal grants that were approved and open for drawdown in May 2023. These were all related to grants budget to be reimbursed to the school during the 2022-2023 school year. Due to the late approval of the grants, the school and management didn’t have enough time to submit reimbursement requests and submit amendments. The amendments were submitted during the SB&Company’s audit preparation period. As a result, these amendments were all pending approval even though the expenditures already incurred in FY2023. Management has contracted with a third-party vendor that will be responsible for managing all grant reporting, applications, amendments, and reconciliations. This will strengthen the school year end closing process.
SIGNIFICANT DEFICIANCY 2023-001 Condition: During our eligibility testing, one of 40 participant files reviewed showed that one ineligible participant received child care services for a period of time. Recommendation: We recommend the Organization enhance their training process with respect to doc...
SIGNIFICANT DEFICIANCY 2023-001 Condition: During our eligibility testing, one of 40 participant files reviewed showed that one ineligible participant received child care services for a period of time. Recommendation: We recommend the Organization enhance their training process with respect to documentation review to ensure an adequate review process is in place to prevent errors with respect to participant eligibilty. Views of responsible officals: CCCS has already alerted the DFD of the exception and requested a recoupment of funds. We will re-train our staff to ensure the existing procedures and documentation reviews are correctly followed. Name of the contact person for corrective action: Mary Jane DiPaolo, Executive Director Planned completion date for corrective action plan: September 30, 2024
View Audit 294370 Questioned Costs: $1
Condition: The District did not select and verify the required sample of approved free and reduced price applications by the required deadline. Plan: The district will have a calendar reminder to begin auditing applications on Oct. 1 and complete the process with submission to ISBE by December 15. A...
Condition: The District did not select and verify the required sample of approved free and reduced price applications by the required deadline. Plan: The district will have a calendar reminder to begin auditing applications on Oct. 1 and complete the process with submission to ISBE by December 15. Anticipated Date of Completion: 12/31/2024 Name of Contact Person Yasmine Dada, Business Manager ________________________________________________
It was determined at the end of the 2022-2023 school year that $26,667 of indirect costs were 2022-2023 school year, we were informed that the guidelines changed for some funding sources regarding indirect costs. We will be correcting the action as instructed in our books and will implement an annua...
It was determined at the end of the 2022-2023 school year that $26,667 of indirect costs were 2022-2023 school year, we were informed that the guidelines changed for some funding sources regarding indirect costs. We will be correcting the action as instructed in our books and will implement an annual review process for funding sources to ensure that we are able to implement all guidelines.
View Audit 294314 Questioned Costs: $1
Finding 374632 (2023-001)
Significant Deficiency 2023
Finding 2023-001 Eligibility – Noncompliance and Significant Deficiency in Internal Control Over Compliance Planned Corrective Actions: Registration staff is requesting beneficiary identification at the time of registration for all patients that do not have it in their EHR. Project is ongoing. Month...
Finding 2023-001 Eligibility – Noncompliance and Significant Deficiency in Internal Control Over Compliance Planned Corrective Actions: Registration staff is requesting beneficiary identification at the time of registration for all patients that do not have it in their EHR. Project is ongoing. Monthly audits of the elements of registration, including documentation of beneficiary status will be conducted to ensure continual compliance. Additionally, Maniilaq will work with our local tribes to get enrollment information to assist in verifying beneficiary status. Individual(s) Responsible for Corrective Action Plan Kandy Barlow VP of Health Services 907-442-7385 Anticipated Completion Date: March 31,2024
Finding #2023-002: ESSER II #84.425D COVID-19 – Education Stabilization Fund and ESSER III #84.425U COVID-19 – Education Stabilization Fund Federal Grantor: U.S. Department of Education Pass-through Award Numbers: 2022-252646-DPI-ESSERFII-163 and 2022-252646-DPI-ESSERFIII-165 Pass-throug...
Finding #2023-002: ESSER II #84.425D COVID-19 – Education Stabilization Fund and ESSER III #84.425U COVID-19 – Education Stabilization Fund Federal Grantor: U.S. Department of Education Pass-through Award Numbers: 2022-252646-DPI-ESSERFII-163 and 2022-252646-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Condition: There were five Education Stabilization Fund construction projects performed by contractors/subcontractors. None of the contracts included prevailing wage language clauses and certified payrolls were not obtained by the District during the fiscal year expended. Not all contractors/subcontractors were able to provide certified payrolls when requested as part of the compliance testing. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: There was turnover in the business office and the contracts were secured and approved prior to the current business manager. The District was not aware of the applicable requirements related to these projects. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $78,300 (Amount for which certified payrolls were not subsequently provided) Recommendation: Establish procedures and controls to comply with wage rate requirements related to the Education Stabilization Fund. Obtain verification from contractors that prevailing wage rates were paid on the projects submitted for costs reimbursed by the grant. Response: The District became aware of the prevailing wage rate requirements after finishing the projects. Before bidding future construction projects more than $2,000, that may be funded with federal grant dollars, the request for bid and contract will include a prevailing wage rate clause. Certified payrolls will be received from contractors or subcontractors. Additionally, the district has obtained payroll data from all each contractor to provide support for wage rates paid if necessary. Contact Person: Erik Farrar Anticipated Completion: March 15, 2024
View Audit 294304 Questioned Costs: $1
Finding 374619 (2023-002)
Significant Deficiency 2023
Perquimans County Department of Social Services unit will continue to 2nd party cases monthly, randomly review workers calculations and procedures of the countable resources. IMS will implement a training with question and answer session to demonstrate the proper calculations to be used.
Perquimans County Department of Social Services unit will continue to 2nd party cases monthly, randomly review workers calculations and procedures of the countable resources. IMS will implement a training with question and answer session to demonstrate the proper calculations to be used.
Finding 374618 (2023-001)
Significant Deficiency 2023
Perquimans County Department of Social Services unit will continue to 2nd party cases monthly, randomly review workers online data and continue to train on the important of pulling current and accurate information from the online data system. IMS will implement a Power point presentation to illustra...
Perquimans County Department of Social Services unit will continue to 2nd party cases monthly, randomly review workers online data and continue to train on the important of pulling current and accurate information from the online data system. IMS will implement a Power point presentation to illustrate the importance of the information the County utilizes from the online and work number systems.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There ...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University evaluate its procedures and a policy around how level of education is determined and verified when packaging and awarding students. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Student Financial Aid Office will add an additional step to the policy for verifying and reviewing student loan levels. In addition to reviewing loan level reports before the beginning of the academic year, we will also review loan levels after the census date of the first semester of the academic year. This added step will catch any changes that were made to student packaging up to the census date. Name(s) of the contact person(s) responsible for corrective action: David L Kumm, Executive VP CFO/COO Planned completion date for corrective action plan: 7/1/2023
View Audit 294279 Questioned Costs: $1
Finding 374608 (2023-001)
Significant Deficiency 2023
Finding 2023-001: Cash Management: Management agrees with the finding and recommendation. The University continues to evaluate monthly expenses to match actual expenses with cash draws. The University will also evaluate if an increase in the frequency of draws at smaller amounts is necessary in orde...
Finding 2023-001: Cash Management: Management agrees with the finding and recommendation. The University continues to evaluate monthly expenses to match actual expenses with cash draws. The University will also evaluate if an increase in the frequency of draws at smaller amounts is necessary in order to ensure funding drawn is expended within the thirty-day window. Chao Wang, Senior Director, Sponsored Projects Financial Operations, will perform on‐going monitoring of draws under this program to ensure funds are expended timely in accordance with the grant requirements throughout the year, and to identify the areas where additional training is required. The estimated completion date is June 30, 2024.
View Audit 294278 Questioned Costs: $1
Corrective Action Plan Finding No.: 2023- 003 Condition: Audit procedures identified that during fiscal year 2023, the District claimed four construction related invoices that amounted to $1,257,867 of ESSER III award expenditures that were previously claimed under fiscal year 2022 ESSER award reimb...
Corrective Action Plan Finding No.: 2023- 003 Condition: Audit procedures identified that during fiscal year 2023, the District claimed four construction related invoices that amounted to $1,257,867 of ESSER III award expenditures that were previously claimed under fiscal year 2022 ESSER award reimbursement claims and were reported on the fiscal year 2022 Schedule of Expenditures of Federal Awards. The District was able to identify alternate invoices that where for allowable costs within the existing grant agreement and were not previously claimed. The District's internal controls did not initially identify that the same expenditure was claimed twice under the federal award for reimbursement. Plan: The District will implement additional procedures and review processes to ensure that expenditures claimed for reimbursement are for allowable costs that have not been previously claimed for reimbursement. Anticipated Date of Completion: June 30, 2024 Name of Contact Person: James Vreeland, Business Manager Management Response: See above
The District's procedure for purchases utilizing federal funds for goods in excess of $5,000 are submitted to the California Department of Education prior to purchase for approval. The District utilized COVID relief funds to upgrade classrooms with equipment consistent in the SVI classroom project. ...
The District's procedure for purchases utilizing federal funds for goods in excess of $5,000 are submitted to the California Department of Education prior to purchase for approval. The District utilized COVID relief funds to upgrade classrooms with equipment consistent in the SVI classroom project. While the components of the SVI project are under the $5,000 threshold for prior approval collectively they are over this threshold. The components being under the $5,000 threshold resulted in an oversight of the needed preapproval for these purchases. Fiscal Services is developing a checklist of required steps in the procurement process when federal funds are being considered to ensure prior approval, if needed, is sought prior to purchase. The checklist will include an area where each component is listed to include delivery cost and installation and will include acknowledgement of whether these components collectively create one asset. This will allow other staff reviewing the checklist to determine if preapproval based on cost may be needed. The checklist will require approval of the department head of the requesting department acknowledging understanding of the federal purchasing requirements for capital expenditure as well as, approval of the Director, Fiscal Services and the District's Assistant Superintendent of Business Services.
View Audit 294238 Questioned Costs: $1
NED management has been aware of the FFATA reporting requirements and takes a serious approach to FFATA regulations. NED's concerns regarding FFATA compliance are rooted in concern for personal and physical safety of our grantees working in the sphere of human rights and democracy, particularly thos...
NED management has been aware of the FFATA reporting requirements and takes a serious approach to FFATA regulations. NED's concerns regarding FFATA compliance are rooted in concern for personal and physical safety of our grantees working in the sphere of human rights and democracy, particularly those NED partners working in the world's most hostile authoritarian countries. As stated in our response to the FY2022 Audit, NED staff analysis of the potential reporting requirements recognized two significant risks to NED's partners and the success of its programs: 1) reporting all first-tier sub awardees would mean posting the identity of recipients and details of sensitive awards on a publicly accessible website, and 2) reporting NED partners as first-tier sub awardees of the Department of State (DOS) on a public website of federal funding accountability undermines the Congress' intentional decision to protect the independence of NED's programmatic decision-making when it crafted the NED Act. With the intention of balancing the legitimate concerns for our NED grantees with our desire to comply with the spirit of transparency and accountability rooted in FFATA, NED renewed discussions with Department of State officials to find a resolution to this issue. The leadership at NED and at State’s Bureau of Democracy, Human Rights, and Labor jointly assessed the issue to determine a long-term solution. Following the development of a Duty of Care policy outlining NED’s institutional obligations to “do no harm” with respect to the safety and security of our stakeholders, including NED grantees, NED management has since reached an agreement with our DOS Grants Officer to designate NED’s annual appropriation award as “sensitive” and therefore not subject to the annual FFATA reporting requirements. We have since received NED’s annual award for2024 with language matching several of our special funds DOS awards: “This award has been deemed sensitive and is not subject to the Federal Funding Accountability and Transparency Act (FFATA).” We expect the same terms to apply to our awards going forward which, ensuring a permanent resolution to this issue. Name of Responsible Official: Nancy Herzog, Title: VP, Grant Operations & Evaluation Date correction action executed: 11/29/2023.
Views of responsible officials and Corrective Action Plan: Controls will be implemented for future reporting and the School will correct the reporting errors in the following period.
Views of responsible officials and Corrective Action Plan: Controls will be implemented for future reporting and the School will correct the reporting errors in the following period.
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