Corrective Action Plans

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Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer ...
Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer will implement a new Vendor Contract Packet. The Vendor Contract Packet will consist of an EDGAR Certification Form that will address the assurances under the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR 200 (EDGAR). Within the vendor packet, will be the vendor’s agreement and ability to comply with EDGAR regulations. Further, it will require the vendor to agree to the wage rate determinations and a copy of the certified payrolls and a statement of compliance with requirement. Contact person: Sylvia S. Garza, CFO Completion: January 31, 2024
Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer ...
Corrective Action: The District will establish internal controls that will be designed to ensure the compliance with the Wage Rate Requirements (Davis-Bacon Act) provision applicable to contracts that are governed by federally financed and assisted construction projects. The Chief Financial Officer will implement a new Vendor Contract Packet. The Vendor Contract Packet will consist of an EDGAR Certification Form that will address the assurances under the Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards, 2 CFR 200 (EDGAR). Within the vendor packet, will be the vendor’s agreement and ability to comply with EDGAR regulations. Further, it will require the vendor to agree to the wage rate determinations and a copy of the certified payrolls and a statement of compliance with requirement. Contact person: Sylvia S. Garza, CFO Completion: January 31, 2024
The District is to determine the most appropriate approach to ensure payroll charges related to the ESY Program related to Special Education only includes individuals approved by the Department to be included in the I.D.E.A. budget line.
The District is to determine the most appropriate approach to ensure payroll charges related to the ESY Program related to Special Education only includes individuals approved by the Department to be included in the I.D.E.A. budget line.
View Audit 14330 Questioned Costs: $1
Finding: 2023-002 – Special Tests and Provisions – Wage Rate Requirements U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Three o...
Finding: 2023-002 – Special Tests and Provisions – Wage Rate Requirements U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Three of the contracts selected for testing that were subject to the Wage Rate Requirements did not include the required provision, and the District did not obtain the required certified payrolls. The District did not follow federal requirements to include the prevailing wage rate provision in its contract. Auditor Recommendation: We recommend that the District reviews its policies to ensure that applicable prevailing wage requirements are included in construction contracts whenever federal funds are used and certified payrolls are obtained. Corrective Action: District officials will ensure that construction contracts contain these requirements during the bidding and/or proposal process. Responsible Person: Rebecca Jones, Superintendent and Tara Newman, Business Manager Anticipated Completion Date: June 30, 2024
View Audit 14327 Questioned Costs: $1
Finding: 2023-001 – Allowable Costs/Cost Principles – Timesheets U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Two out of forty...
Finding: 2023-001 – Allowable Costs/Cost Principles – Timesheets U.S. Department of Education – COVID-19 - Education Stabilization Fund (ALN 84.425D and 84.425U); Passed through the Michigan Department of Education; All project numbers. Auditor Description of Condition and Effect: Two out of forty disbursements selected for testing did not include the required documentation by the employee and approvals by their supervisor. As a result of this condition, the District was exposed to increased risk that payroll charges of federal awards could be made for unallowable costs. Auditor Recommendation: We recommend that the District review its written policies and procedures over federal awards to ensure that all timesheets have the appropriate documentation and evidence of review and approval prior to payment. Corrective Action: The business office will be reviewing that all timesheets are signed by employees and approved by their supervisor prior to payment. Responsible Person: Rebecca Jones, Superintendent and Tara Newman, Business Manager Anticipated Completion Date: June 30, 2024
BOULDER VALLEY SCHOOL DISTRICT CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Boulder Valley School District respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The finding from the schedule of findings and ques...
BOULDER VALLEY SCHOOL DISTRICT CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2023 Boulder Valley School District respectfully submits the following corrective action plan for the year ended June 30, 2023. Audit period: July 1, 2022 – June 30, 2023 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS Department of Education 2023-001 COVID-19 – Education Stabilization Fund – Assistance Listing No. 84.425U Recommendation: We recommend the District add a review process into their controls to ensure all employees’ time being charged to the grant is accurately captured. Additionally, we recommend the District review and adjust all final time and effort certifications in a timely manner, based on the final adjusted and allowable personnel expenditures charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will take the following actions in response to the finding:  Missing time and effort certifications have been obtained from the 3 employees.  Adjustments will be made to ensure the grant is charged the correct amount of eligible personnel costs.  To align with the timing of semi-annual time and effort certifications in December and June each year, the District will implement the following procedures in February and September, related to each preceding 6-month period: o Review personnel costs charged to each grant on an employee-by-employee basis to ensure the amount charged to the grant is accurate. o Review time and effort certifications for all employees, compared to the final actual personnel costs charged to each grant.  Assess and implement functionality in the Infor ERP system to: o Maintain time and effort records and have employees certify their time within the Infor ERP system. This process is currently manual and outside of the ERP system. o Develop, test and implement grant reporting capabilities in the Infor ERP system, to assist in monitoring all District grants. Efforts to date with Infor consultants to develop grant reports have not achieved the desired results. Current reports must be manually generated. Name of the contact person responsible for corrective action: Bill Sutter, CFO Planned completion date for corrective action plan: September 2024 If the Colorado Department of Education has questions regarding this plan, please call Bill Sutter, CFO at 720-561-5019.
View Audit 14270 Questioned Costs: $1
Comments on the Finding and Each Recommendation: Management agrees with both the finding and the recommendations. Action(s) Taken or Planned on the Finding Under the direction of the Assistant Executive Director, the Housing Administrator has already established an inspection oversight process with ...
Comments on the Finding and Each Recommendation: Management agrees with both the finding and the recommendations. Action(s) Taken or Planned on the Finding Under the direction of the Assistant Executive Director, the Housing Administrator has already established an inspection oversight process with HQS staff addressing the deficiencies noted in the finding, including the timeliness of reinspection. The process also includes implementing an updated voucher abatement and loss procedure before 12/31/2023. The operations memorandum detailing the oversight process will be distributed to staff before 01/01/2024.
The district will adjust its operations to include a financial review and reconciliation of the reimbursement requests prepared on its behalf by the private consultant administering the program.
The district will adjust its operations to include a financial review and reconciliation of the reimbursement requests prepared on its behalf by the private consultant administering the program.
Contact Person – Drew Kjono, Superintendent; Corrective Action Plan – The District will establish policy to review the supporting documentation for reimbursement reports.; Completion Date – January 31, 2024
Contact Person – Drew Kjono, Superintendent; Corrective Action Plan – The District will establish policy to review the supporting documentation for reimbursement reports.; Completion Date – January 31, 2024
The Board of Directors is and will remain involved in the financial affairs of the Cooperative. The Cooperative hired a new management agent with proper segregation of duties.
The Board of Directors is and will remain involved in the financial affairs of the Cooperative. The Cooperative hired a new management agent with proper segregation of duties.
Finding 2023.004 - Reporting Recommendation The Organization should establish a system of internal controls to ensure that all UDS related calculations are properly documented and maintained. Action Taken Health contracted with an interim Chief Financial Officer in January 2023. The interim CFO de...
Finding 2023.004 - Reporting Recommendation The Organization should establish a system of internal controls to ensure that all UDS related calculations are properly documented and maintained. Action Taken Health contracted with an interim Chief Financial Officer in January 2023. The interim CFO departed in February 2023 and was unable to provide the organization with work source documents for the 2022 UDS submission. Effective January 2024, the current Chief Financial Officer and the electronic medical records specialist (IT) will ensure all source documentation for the UDS submission is saved on the organization’s shared file drive to support the annual UDS submission.
Finding 2023.003 - Activities Allowed or Unallowed Recommendation The Organization should establish a system of internal controls to ensure that all employees are being paid the correct amounts. Action Taken United Methodist Western Kansas Mexican-American Ministries Inc. d/b/a Genesis Family Heal...
Finding 2023.003 - Activities Allowed or Unallowed Recommendation The Organization should establish a system of internal controls to ensure that all employees are being paid the correct amounts. Action Taken United Methodist Western Kansas Mexican-American Ministries Inc. d/b/a Genesis Family Health implemented PayCom in January 2023. With this system update, the organization has implemented an automated process to ensure changes to employee pay rates are approved and adjusted timely. This process requires all changes to employee’s compensation being entered into the PayCom (payroll system) by the departmental managers/supervisors. Changes in pay are automatically flagged for review and approval by the human resources department. These changes improved internal controls to ensure all employee rate changes are implemented timely and employees are being paid the correct amount.
Finding 2023.002 - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken The proficiency of all billing staff respon...
Finding 2023.002 - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken The proficiency of all billing staff responsible for applying sliding fee discounts and ensuring proper calculations based on family size and income will be evaluated. The organization implemented an Onboarding and Enrollment department in June 2023 to review clinic schedules prior to the patient’s appointment. The onboarding and enrollment staff meet with each new patient to review and verify insurance information, check Medicaid eligibility, ensure fully completed registrations and complete application for any slide fee discounts applicable based on income and family size. Billing staff reviews this information and applies the appropriate discount to the patient charges. This crosschecking process will improve internal controls related to the sliding fee discount process.
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in r...
Student Financial Aid Cluster – CFDA No. 84.268 Recommendation: We recommend that the Seminary review the updated GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The seminary will update our current WISP to comply with additional requirements and newer standards. Name(s) of the contact person(s) responsible for corrective action: Raymond Ingram, Director of Finance Planned completion date for corrective action plan: February 1,2024
Condition: In a monitoring visit performed by the U.S. Department of Labor, the grantor found that service coordinators are verifying that the veterans meet the “Homelessness” requirement to be enrolled in the program, but in some instances, were missing the verification (case notes or form entries)...
Condition: In a monitoring visit performed by the U.S. Department of Labor, the grantor found that service coordinators are verifying that the veterans meet the “Homelessness” requirement to be enrolled in the program, but in some instances, were missing the verification (case notes or form entries) and relying on self-attestation, which should be a last resort. Planned Corrective Action: The Organization responded to the monitoring visit recommendation referenced by providing additional staff training and implementing a verification function to ensure all applicable case notes, form entries, and documentation are acquired and made part of the case file. Contact person responsible for corrective action: Craig Fisgus, Vice President of Veteran Services Anticipated Completion Date: Revised processes were implemented immediately following the receipt of the monitoring visit recommendation.
Rogers Behavioral Health System, Inc. and Subsidiaries CORRECTIVE ACTION PLAN YEAR ENDED July 31, 2023 Identifying Number: 2023-001 Finding: In the internal tracking of eligible COVID-19 related expenses applied to the Period 4 PRF receipts for Rogers Behavioral Health System, Inc. and Subsidiari...
Rogers Behavioral Health System, Inc. and Subsidiaries CORRECTIVE ACTION PLAN YEAR ENDED July 31, 2023 Identifying Number: 2023-001 Finding: In the internal tracking of eligible COVID-19 related expenses applied to the Period 4 PRF receipts for Rogers Behavioral Health System, Inc. and Subsidiaries (the Health System), the Health System calculated invoice amounts related to legal services incurred as part of the Health System’s response to COVID-19 in a manner that increased legal expenses applied to PRF funds by the percent discount given by legal counsel rather than decreasing legal expenses applies to PRF funds. Calculating the identified eligible legal expenses in this manner occurred for legal expenses incurred and applied to PRF funds from August 2021 to February 2022. Additionally, for one month, the Health System included the eligible expenses twice in the internal tracking of eligible COVID-19 related expenses. Corrective Actions Taken or Planned: Rogers ensured there were enough valid qualifying expense to support the funds received. Future assignments of costs will be reviewed for reasonableness and appropriateness to ensure only proper allowable costs are submitted to support funds received. This will be achieved by the utilization of work tag assignments on allowable costs. Due to a recent financial system implementation, Rogers will be able to use enhanced tools to track costs more accurately. Person Responsible: Emily Russart, Controller Anticipated Completion Date: March 31, 2024
View Audit 14135 Questioned Costs: $1
Recommendation: YWCA of Western Massachusetts Inc.’s internal control procedures should be revised to ensure an adequate review process is in place to ensure expenditures incurred are allowable under the terms of the grant. ...
Recommendation: YWCA of Western Massachusetts Inc.’s internal control procedures should be revised to ensure an adequate review process is in place to ensure expenditures incurred are allowable under the terms of the grant. Views of Responsible Officials: Despite DPH's mandate to remove all personally identifiable information from these funding requests, the YWCA reconstructed every ERAP request using identifying vendor numbers. The YWCA ultimately identified how and where the three former employees illegally used ERAP funds to pay their bills as well as some of their family members or friends. They stole ERAP funds to illegally pay such bills as electricity, water and sewer bills, rent, car insurance payments, and credit card payments. As soon as the YWCA discovered these thefts, the YWCA immediately notified the appropriate authorities (such as the YWCA's Board of Directors, the police, and DPH) and kept them updated. Additionally, the employment ended for the three YWCA employees responsible for this fraud and theft. As of this audit issue date, all three former employees have been indicted for multiple felonies such as credit card fraud over $1300, larceny over $1200, and false entry in corporate books. Their criminal cases are pending in Hampden County Superior Court. The YWCA maintains an expectation that justice will be served. Finally, to prevent future theft and misuse of any grant funding, the YWCA has implemented some new policies and procedures. One, the YWCA will not hire close relatives. Two, a thorough review of all financial policies and procedures is in process to ensure that the appropriate checks and balances are in place. Three, any supervisor, who has access to YWCA funds, will be required to participate in a background check to ensure that do not have any personal or financial problems.
View Audit 14119 Questioned Costs: $1
McSherrystown Interfaith Housing Corporation 40 E. High Street, Gettysburg, PA 17325 Phone (717) 334-1518 • Fax (717) 334-8326 TDD/TTY Relay Service: 1-800-654-5984 www.adamscha.org CORRECTIVE ACTION PLAN December 28, 2023 McSherrystown Interfaith Housing Corporation respectfully submits the follow...
McSherrystown Interfaith Housing Corporation 40 E. High Street, Gettysburg, PA 17325 Phone (717) 334-1518 • Fax (717) 334-8326 TDD/TTY Relay Service: 1-800-654-5984 www.adamscha.org CORRECTIVE ACTION PLAN December 28, 2023 McSherrystown Interfaith Housing Corporation respectfully submits the following corrective action plan for the year ended September 30, 2023. Cognizant or Oversight Agency for Audit: Mortgage Insurance Rental Housing, ALN #14.134 Name and address of independent public accounting firm: Hamilton & Musser, PC 176 Cumberland Parkway Mechanicsburg, PA 17055 Audit Period: October 1, 2022 - September 30, 2023 The finding from the September 30, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings - Financial Statement Audit: None Findings and Questioned Costs - Major Federal Award Programs Audit: #2023-001 - Significant Deficiency-Reconciliation of Escrow Accounts Mortgage Insurance Rental Housing, ALN #14.134 Recommendation We recommend that McSherrystown Interfaith Housing Corporation make an entry to record escrow activity during the year and implement similar monthly adjustments going forward. View of responsible officials and planned corrective action We agree that this compliance requirement is listed in the compliance supplement. We will implement additional procedures to capture escrow activity during the year. Additional training has been provided to the Accounting staff. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call McSherrystown Interfaith Housing Corporation Executive Director, Stephanie McIIwee at (717) 334-1518.
2023-006: Unallowable Costs Recommendation: Implement procedures to ensure all grant expenditures are reviewed by fiscal management for additional review. Action taken in response to finding: Incorrectly charged amounts will be journalled to the correct account in 2023-24. All future grant related p...
2023-006: Unallowable Costs Recommendation: Implement procedures to ensure all grant expenditures are reviewed by fiscal management for additional review. Action taken in response to finding: Incorrectly charged amounts will be journalled to the correct account in 2023-24. All future grant related payroll expenses will be reviewed by the finance/fiscal team and management. Name of the contact person responsible for corrective action: Susan Wheat, Vice President of Finance and Administration Planned completion date for corrective action plan: January 2024
2023-005: Gramm-Leach-Bliley Act Compliance Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Action taken in response to finding: Fill the newly created Interim Dir...
2023-005: Gramm-Leach-Bliley Act Compliance Recommendation: We recommend the District review and finalize its information security policy and ensure it contains all seven elements required for compliance with Gramm-Leach-Bliley. Action taken in response to finding: Fill the newly created Interim Director of Information Security and Special Projects position with an Interim placement effective February 1, 2024, to provide leadership in developing, implementing, and maintaining the District’s Information Security Policy including the seven elements required by the Gramm-Leach-Bliley Act. Names of the contact person responsible for corrective action: James “Kimo” Calilan, Director – Information Systems Planned completion date for corrective action plan: April 30, 2024
2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures use...
2023-004: 240 Days Outstanding Check Recommendation: We recommend the District re-evaluate their procedures for processing and documenting outstanding Title IV funds to the Department of Education. Action taken in response to finding: This issue is the result of a conflict between the procedures used by the awarding team (Financial Aid) and the disbursement team (Fiscal Services). The Financial Aid team was operating with a set of pre-pandemic instructions that had them contact students to fix their address information (the typical reason that disbursements timeout) and send a list of students with verified addresses to Fiscal Services for reissuing. Nothing in their procedures mentioned the need to rescind aid—only the need to verify addresses to allow funds to reach students. The Fiscal Services team’s procedures, on the other hand, assumed the Financial Aid team was rescinding aid as necessary and thus would reissue repeatedly as long as the funds remained awarded in the school’s information system, even in cases where the initial disbursement had been made more than 240 days prior. The combination of these two procedures led to the findings in this year’s audit and last year’s audit, as well. The Financial Aid team’s procedures were updated and presented to the team on October 4, 2023. These new procedures included:  Directions on how to rescind funds  A policy statement requiring recission when the time since first disbursement has exceeded 90 days (an institutional policy that is stricter than the 240 days allowable under federal regulations)  A clear set of instructions on how to make the determination to rescind funds. Name of the contact person responsible for corrective action: Patrick Scott, Dean – Financial Aid Planned completion date for corrective action plan: October 2023 for procedure correction. February 2024 for completed review of affected students in audit list.
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of...
Recommendation: We recommend that the District improve the existing procedures and controls to ensure compliance with the aforementioned criteria. Action taken in response to finding: This issue was discovered during the audit process and the staff member associated with this error was made aware of it in July 2023. Refresher training occurred during August 2023 and we have added members to the R2T4 calculation team in December 2023 in hopes of spreading workload and allowing more time to complete calculations and returns before the relevant deadlines. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: January 2024
2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather th...
2023-001: Student Eligibility and Awarding Recommendation: We recommend the District to evaluate its procedures related to the manual input of information from the student loan request. Action taken in response to finding: This issue was the result of using the Solano completed unit level, rather than the cumulative number that includes transfer units, when awarding a student in our small BS Biotechnology program. Student had completed 43.5 credits at Solano by the beginning of the aid year. As a result, the student was awarded a second-year subsidized amount when they were eligible for the third year and beyond amount. This resulted in the student receiving $1,000 less subsidized loans than they were eligible for. In July 2023, we trained the team to watch for this issue and evaluated the procedure log that we use for processing Direct Loans. This log now includes two checks that are relevant to ensuring subsidized loan amounts are correct: 1. Confirm the level of the student. If the student is in our BS Biotechnology program, they may have additional eligibility than the standard first-year and second-year loans that we normally process as a community college. 2. If the loan is a single-term loan, is the full subsidized eligibility exhausted before awarding any unsubsidized loan amounts? The student’s file was corrected on COD on 8/3/2023 to reflect a $5,500 subsidized award. Names of the contact persons responsible for corrective action: Patrick Scott, Dean – Financial Aid, and Kate Larot, Financial Aid Specialist Planned completion date for corrective action plan: August 2023
View Audit 14106 Questioned Costs: $1
Finding 10418 (2023-003)
Significant Deficiency 2023
Contact Person – Kristine Wehrkamp Herman, Superintendent; Corrective Action Plan – The District will follow their cash disbursement procedures.; Completion Date – January 31, 2024
Contact Person – Kristine Wehrkamp Herman, Superintendent; Corrective Action Plan – The District will follow their cash disbursement procedures.; Completion Date – January 31, 2024
Contact Person – Kristine Wehrkamp Herman, Superintendent; Corrective Action Plan – The District will implement policies and procedures to ensure all construction contracts in excess of $2,000 that are paid with federal funds follows the federal wage rate requirements.; Completion Date – January 31,...
Contact Person – Kristine Wehrkamp Herman, Superintendent; Corrective Action Plan – The District will implement policies and procedures to ensure all construction contracts in excess of $2,000 that are paid with federal funds follows the federal wage rate requirements.; Completion Date – January 31, 2024
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