Corrective Action Plans

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Management agrees with the findings and recommendations, will ensure payroll is allocated correctly going forward. Funds have been transferred.
Management agrees with the findings and recommendations, will ensure payroll is allocated correctly going forward. Funds have been transferred.
Management has reviewed the current nonessential costs that have resulted in the community not being able to fund the replacement reserve in accordance with the regulatory agreement. We have suspended services that will be maintained by the site staff. These services includes the common area cleanin...
Management has reviewed the current nonessential costs that have resulted in the community not being able to fund the replacement reserve in accordance with the regulatory agreement. We have suspended services that will be maintained by the site staff. These services includes the common area cleaning and unit turn overs.
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance wi...
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance with the requirements of the HUD Handbook4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. FG Companies has also implemented a bi-weekly file audit system that will continue to be completed by the Regional Manager. This system is to ensure all files are current with certifications and all required state and local forms are completed and filed accordingly.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have ...
Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90-day reminders for all move in. 2. Existing Tenant EIV – It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The Regional Manager is required during monthly visits to spot check at least 5 existing tenants.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will gain prior approval for replacement reserve withdraw in accordance with HUD going forward.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will gain prior approval for replacement reserve withdraw in accordance with HUD going forward.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations and has implemented reviews of the financial statements by senior management prior to approving transfers to ensure accuracy of information.
Management agrees with the findings and recommendations and has implemented reviews of the financial statements by senior management prior to approving transfers to ensure accuracy of information.
Management agrees with the finding and is working with ownership on reimbursement to the property. Management will collect in accordance with HUD going forward.
Management agrees with the finding and is working with ownership on reimbursement to the property. Management will collect in accordance with HUD going forward.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will collect in accordance with HUD going forward.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will collect in accordance with HUD going forward.
Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.
Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management concurs with Audit Finding 2025-004 and will strengthen controls over USDA commodity receiving documentation and related reporting to ensure compliance with Food Distribution Cluster special tests and provisions and reporting requirements. Management will implement the following correctiv...
Management concurs with Audit Finding 2025-004 and will strengthen controls over USDA commodity receiving documentation and related reporting to ensure compliance with Food Distribution Cluster special tests and provisions and reporting requirements. Management will implement the following corrective actions: 1. Required Receiving Worksheets for USDA Commodity Receipts Management will reinforce the requirement that a completed receiving worksheet be prepared for all TDA USDA commodity receipts. Each receiving worksheet will be signed or initialed by the receiving employee at the time of receipt to evidence verification of quantities received. 2. Reconciliation of Receiving Documentation to CERES Management will implement a formal reconciliation process to ensure all USDA receiving documentation is reconciled to CERES inventory entries prior to submission of monthly TEFAP reports. Any discrepancies will be promptly investigated, resolved, and documented. 3. Supervisory Review and Approval Supervisory personnel will perform periodic documented reviews to verify that: o All USDA commodity receipts are supported by completed and signed receiving worksheets; and o Receiving activity is accurately and completely recorded in CERES. Evidence of supervisory review will be retained. 4. Documentation Retention and Standardization All receiving worksheets and supporting documentation will be retained in accordance with Food Distribution Cluster record retention requirements. Management will standardize receiving forms and procedures to promote consistency and completeness. 5. Training and Ongoing Monitoring Management will provide refresher training to warehouse and inventory staff on USDA receiving requirements and the importance of timely, accurate documentation. Management will periodically monitor compliance with these procedures to ensure controls are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)
Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following co...
Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)
Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will i...
Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will implement the following corrective actions: 1. Formal Approval and Authorization of Inventory Adjustments Management will establish a formal policy requiring documented supervisory review and approval for all manual positive and negative inventory adjustments recorded in the general ledger and the CERES inventory system. Approval will be obtained prior to posting adjustments, and access to record adjustments will be restricted to authorized personnel. 2. Standardized Documentation for Adjustments Each inventory adjustment will be supported by standardized documentation clearly explaining the nature, reason, and calculation of the adjustment, along with applicable supporting records (e.g., receiving documents, distribution records, shortage documentation). All documentation will be retained in accordance with USDA record retention requirements. 3. Reconciliation of Inventory Activity Management will implement a periodic (at least monthly) reconciliation of inventory receipts, distributions, and adjustments to CERES and the general ledger. Reconciling items will be investigated, resolved, and documented timely. 4. Monitoring of USDA Program Inventory Management will perform periodic reviews of inventory activity related to donated inventory and Tennessee and Mississippi USDA programs to ensure that adjustments are appropriate, approved, and accurately recorded. 5. Training and Ongoing Oversight Management will provide targeted training to staff involved in inventory and accounting processes regarding USDA Special Tests and Provisions requirements and the new approval and documentation procedures. Management will monitor compliance with these controls to ensure they are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)
2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these control...
2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these controls. Proposed Completion Date: The governing board will implement the above procedure immediately.
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.
Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Man...
Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Management response: The District will review the general ledger to the expenditure reports before submitting.
Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Man...
Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Management Response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.
Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Actio...
Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Action: Management will incorporate written procedures for determining the allowability of costs into the City's Financial Plan document, which already includes a section for City-wide policies related to grant administration. The Finance Director and City Manager are responsible for updating the Financial Plan, and the policy updates will be incorporated along with the adoption of the City's fiscal year 2026-2027 budget prior to June 30, 2026.
The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.
The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.
Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Instituti...
Finding 2025-004 Finding Summary: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that Institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statuses, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. During testing of compliance for Enrollment Reporting, there were 3 instances out of 60 where the College did not report a student’s change in enrollment status accurately or within the required time limit of 60 days from the effective date of the student’s change in enrollment status. Corrective Action Plan: Enrollment reporting has been centralized under a single point of contact, thereby mitigating risk, ensuring consistency, accountability, and regulatory compliance. This structure was formally implemented last summer with the hiring of an Academic Records Compliance Specialist, significantly strengthening oversight and operational controls. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Noah Briscoe – Assistant Registrar Anticipated Completion Date: 12/31/2025
Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurate...
Finding 2025-003 Finding Summary: 34 CFR 690.83 and the FSA Handbook states that an Institution must report accurate and timely data. During testing of compliance for COD Reporting, there were 6 instances out of 60 where the College did not report a student’s disbursement information to COD accurately. Corrective Action Plan: The institution has taken and has fixed this issue by: • The system is now functioning correctly after addressing the issue with the vendor. • To prevent future issues, a more robust tool has been developed to identify discrepancies promptly should they arise. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Jennifer Service – Director of Financial Aid Anticipated Completion Date: 12/31/2025
Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a...
Finding 2025-002 Finding Summary: 34 CFR 668.164(h)(2)(i,ii) states that A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible, but no later than—Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. During our testing of compliance for HEA Credit balances, there were 5 instances out of 60 where the College did not refund a student’s within the required time frame of 14 days from the first day of class or 14 days after the credit balance was created. Corrective Action Plan: The institution has taken and has fixed this issue by: • Dedicated Staffing: A full-time position has been approved and filled to manage stipend processing, ensuring consistent oversight and timely disbursement. • Process Documentation: Stipend processing procedures have been documented to ensure continuity, accountability, and clarity of responsibilities. • System Review and Planning: The system is up and running as it should have been. • Ongoing Monitoring: Leadership will continue to monitor stipend processing timelines and staffing capacity to ensure compliance and timely student support. Responsible Individual(s): Monze Stark – Dean of Enrollment Services, Bethany Parmer – Assistant Dean of Enrollment Services Anticipated Completion Date: 12/31/2025
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