Corrective Action Plans

Finding 555251 (2023-004)

Material Weakness 2023

MN

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

1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax fi...

1. Enhance Document Retention Procedures: *We will update our document retention policy to clearly define retention periods for payroll-related records, ensuring compliance with legal and regulatory requirements. This will include retaining all necessary documentation such as payroll reports, tax filings, and third-party payroll contracts. *A secure, organized system will be implemented for storing payroll-related documents, whether physical or digital. This will include utilizing secure cloud storage or an enterprise document management system with restricted access controls. *We will conduct a quarterly review to ensure that documents are being retained for the appropriate time frame and securely disposed of when no longer required. 2. Implement Stronger Controls During Payroll Provider Transitions: *We will formalize and document the process for changing third-party payroll providers. This process will include detailed steps for due diligence, transition planning, data transfer procedures, and ensuring continuous payroll processing during the transition period. *A project team will be assigned for every payroll provider change to ensure proper planning, including backup and contingency plans, data verification, and communication with both internal and external stakeholders. *A comprehensive review of the transition will be conducted after each change, including a reconciliation of payroll records to ensure that all data is accurately transferred, and all systems are functioning properly. 3. Vendor Oversight and Service Level Agreements (SLAs): *We will ensure that future contracts with third-party payroll providers include clear Service Level Agreements (SLAs) outlining the provider's responsibilities in terms of document retention, data security, and transition procedures. This will ensure that providers maintain the necessary standards and practices for managing payroll-related documents.

View Audit 353876 Questioned Costs: $1

Finding 555231 (2023-001)

Material Weakness 2023

Boys and Girls Club of Lake County

IL

Questioned Costs Allowable Costs / Cost Principles Cash Management

Condition: During the audit it was noted that instances of wages submitted for reimbursement for two Club employees were more than gross wages that should have been assigned to the grant based on the amount of the paycheck and the percentage allocation. Plan: The Club plans to review the issue with ...

Condition: During the audit it was noted that instances of wages submitted for reimbursement for two Club employees were more than gross wages that should have been assigned to the grant based on the amount of the paycheck and the percentage allocation. Plan: The Club plans to review the issue with its current procedures and revise them as necessary to provide better controls over grant expenditures. Anticipated Date of Completion: As soon as possible – before FY25 year end Name of Contact Person: Germain Castellanos, CEO Management Response: Since the audit, we have evaluated our procedures related to grant reimbursement requests review and we are working on improving our current procedures.

View Audit 353845 Questioned Costs: $1

Finding 555206 (2023-004)

Significant Deficiency 2023

California State University

CA

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

The University will review and enhance its procedures and internal controls to monitor or ensure the completeness and accuracy of all federal grants, to ensure they are separately recorded within the general ledger and all expenditures and activities are processed in accordance with applicable feder...

The University will review and enhance its procedures and internal controls to monitor or ensure the completeness and accuracy of all federal grants, to ensure they are separately recorded within the general ledger and all expenditures and activities are processed in accordance with applicable federal guidelines. The campus will implement effort reporting procedures for the SNAP Cluster program that include accounting for all employee activities for the program and the University implement appropriate controls to ensure costs charges to the SNAP program are based on actual costs incurred and are properly determined and calculated based upon the Uniform Guidance allowable cost criteria.

View Audit 353823 Questioned Costs: $1

Finding 555150 (2023-007)

Material Weakness 2023

Samu Foundation

DC

Questioned Costs Procurement, Suspension & Debarment § 200.213

Views of Responsible Officials: SAMU will develop a comprehensive corrective action plan that addresses: 1. Creation and implementation of a formal suspension and debarment screening policy 2. Establishment of a documented screening process with clear timelines 3. Training program for staff on feder...

Views of Responsible Officials: SAMU will develop a comprehensive corrective action plan that addresses: 1. Creation and implementation of a formal suspension and debarment screening policy 2. Establishment of a documented screening process with clear timelines 3. Training program for staff on federal requirements and internal procedures 4. Regular monitoring and internal audit procedures By implementing these measures, SAMU can strengthen its compliance with federal regulations, mitigate the risk of providing funds to suspended or debarred parties, and protect its federal funding sources.

View Audit 353757 Questioned Costs: $1

Finding 555149 (2023-006)

Material Weakness 2023

Samu Foundation

DC

Questioned Costs Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.319 § 200.320

Views of Responsible Officials: The procurement policy will be expanded for all re-procuring of longterm contracts procedures. All contracts with service providers or contractors will be reviewed and a renewal or re-procurement process will be taken care accordingly.

View Audit 353757 Questioned Costs: $1

Finding 555145 (2023-002)

Significant Deficiency 2023

Housing Authority of the Township of Neptune

NJ

Questioned Costs Allowable Costs / Cost Principles § 200.423 § 200.438

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook,...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook, Executive Director, is responsible for implementing this corrective action by September 30, 2024.

View Audit 353750 Questioned Costs: $1

Finding 555110 (2023-001)

Material Weakness 2023

Crosspurpose

CO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.4

Effective October 1, 2023, management implemented extensive accounting and documentation controls to ensure full accounting and reporting compliance on direct costs incurred for all federal grants and expenditures. These controls are reviewed and monitored for compliance by management on a periodic ...

Effective October 1, 2023, management implemented extensive accounting and documentation controls to ensure full accounting and reporting compliance on direct costs incurred for all federal grants and expenditures. These controls are reviewed and monitored for compliance by management on a periodic basis during the year.

View Audit 353705 Questioned Costs: $1

Finding 554889 (2023-001)

Material Weakness 2023

Arctic Village Tribal Council

AK

Questioned Costs Cash Management Material Weakness § 200.305

Federal Award Findings Finding 2023-001 Lack of Internal Controls Over Cash Management Name of Contact Person: Galen Gilbert, First Chief Corrective Action Plan: AVC staff were unable to complete a drawdown for the HUD grants due to a change in staff. AVC is working with HUD to resolve the matt...

Federal Award Findings Finding 2023-001 Lack of Internal Controls Over Cash Management Name of Contact Person: Galen Gilbert, First Chief Corrective Action Plan: AVC staff were unable to complete a drawdown for the HUD grants due to a change in staff. AVC is working with HUD to resolve the matter. AVC staff is currently drawing down all other funds in a timely matter. AVC has limited unrestricted cash. AVC is currently looking for opportunities to increase unrestricted cash, such as increasing prices for gas and electric. Proposed Completion Date: July 31, 2024

View Audit 353454 Questioned Costs: $1

Finding 554450 (2023-008)

Significant Deficiency 2023

Leech Lake Tribal College

AZ

Questioned Costs Allowable Costs / Cost Principles § 200.405

The Department will enforce policies and procedures to ensure that the calculated rates are in agreement with the approved indirect cost rate.

View Audit 353088 Questioned Costs: $1

Finding 554398 (2023-002)

Material Weakness 2023

Island County Economic Development Council

WA

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

Material Weakness in Compliance and Internal Control over Compliance Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding ...

Material Weakness in Compliance and Internal Control over Compliance Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence is retained by ICEDC as proof of oversight of expenditure of federal funds. Additionally, we recommend adding a review and approval process for the ED’s timesheets. There is no disagreement with the audit finding. Action taken in response to finding: ICEDC appreciates CLA’s recommendation to enhance processes concerning the retention of documentary evidence of approvals and importance of maintaining strong oversight of expenditures, especially when handling federal funds. ICEDC will place greater emphasis on obtaining and retaining documentation of approvals related to the expenditure of funds. This documentation will serve as proof of oversight, ensuring compliance with federal regulations and enhancing transparency in fund management. A formal review and approval process will be established for the Executive Director's (ED’s) timesheets. This process will involve periodic reviews by a designated authority and documentation will be retained to maintain a clear audit trail. Name(s) of the contact person(s) responsible for corrective action: Kristina Hines Planned completion date for corrective action plan: 8/31/2025

View Audit 353072 Questioned Costs: $1

Finding 554151 (2023-019)

Significant Deficiency 2023

State of California

CA

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.300 § 200.303 § 200.309 § 200.403

The CDSS’ Disability Determination Services Division (DDSD) has implemented corrective measures to address inaccuracies in the Modernized Integrated Disability Adjudicative System (MIDAS) and Disability Case Processing System (DCPS) invoice review processes. This includes an internal quality control...

The CDSS’ Disability Determination Services Division (DDSD) has implemented corrective measures to address inaccuracies in the Modernized Integrated Disability Adjudicative System (MIDAS) and Disability Case Processing System (DCPS) invoice review processes. This includes an internal quality control process to monitor and review additional invoice samples from Branches after they have been processed and reviewed by Branch Program Technicians and Branch Auditors. Additionally, the DDSD Central Support Services Branch implemented a secondary audit process and created a new Auditor role to routinely sample additional Medical Evidence of Record (MER) and Consultative Examination (CE) contracts. Findings are provided to branches to reinforce accuracy and assure compliance. The DDSD, also transitioned from MIDAS to DCPS, which provides more sophisticated fiscal controls. To remediate any inaccuracies, DDSD’s centralized auditor will assess findings and develop an action plan to prevent erroneous invoices. The CDSS ensures that all necessary controls are in place to verify the accuracy and proper documentation of invoices. The CDSS concludes that the sample size of 15 MER cases does not provide sufficient audit evidence that controls are not operating effectively resulting in a calculated $54,398 in potential costs. However, CDSS agrees with the finding and is committed to the control and mitigation of risk related to the audit recommendation. Estimated Implementation Date: Implemented Contact: Bernice Stanfield, Fiscal and Procurement Section Chief Central Support Services Branch Disability Determination Service Division California Department of Social Services

View Audit 352774 Questioned Costs: $1

Finding 554140 (2023-013)

Material Weakness 2023

State of California

CA

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

The CDSS disagrees with the finding. California’s subsidized child care system is locally operated. The CDSS relies on hundreds of local county offices and nonprofit agencies to administer child care and development programs at the local level, rather than having the State pay subsidized providers d...

The CDSS disagrees with the finding. California’s subsidized child care system is locally operated. The CDSS relies on hundreds of local county offices and nonprofit agencies to administer child care and development programs at the local level, rather than having the State pay subsidized providers directly. As a result, CDSS required Alternative Payment Programs, direct-service contractors that administer Family Child Care Home Education Networks, and fiscal partners to track survey completion as a prerequisite for awarding American Rescue Plan Act (ARPA) subgrants. This local infrastructure and the size of California’s subsidized child care and development system separates California from other states. As a result, CDSS worked very closely with the federal grantor, the Administration for Children and Families, to ensure that the ARPA survey methodology met federal monitoring requirements and tracked data elements required by the federal government. For this reason, CDSS believes it has fulfilled its responsibility and does not need to further establish a monitoring program. Estimated Implementation Date: Will not implement Contact: Jeff Fowler, Staff Services Manager III Child Care and Development Program California Department of Social Services

View Audit 352774 Questioned Costs: $1

Finding 554139 (2023-012)

Material Weakness 2023

State of California

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332 § 200.513 § 200.521

The CDSS agrees with the finding. The Child Care and Development Division's Program Quality Improvement Branch (PQIB) recognized the need for tracking monitoring procedures starting from risk assessment identification to closing out of Continuous Improvement Plans (CIP) to ensure that contractors wi...

The CDSS agrees with the finding. The Child Care and Development Division's Program Quality Improvement Branch (PQIB) recognized the need for tracking monitoring procedures starting from risk assessment identification to closing out of Continuous Improvement Plans (CIP) to ensure that contractors with the highest risk factors are prioritized and agencies requiring follow up received a CIP. • Tracking Use of the Risk Assessment: Annually, the PQIB identifies risk criteria for the upcoming Fiscal Year (FY) monitoring through the Contract Monitoring Protocols Agreement document. Using the Consultant Caseload Cohorts spreadsheet staff identify the agencies they will monitor using the FY Monitoring Priorities criteria (risk assessment criteria). The PQIB Travel Team and Administrators review the monitoring schedules for each consultant to ensure the risk assessment criteria has been followed. The risk assessment criteria are reviewed and updated annually based on trends and support needs of the field. In FY 2023-2024 PQIB implemented a cohort review cycle to apply the risk assessment criteria to all contracted programs subject to monitoring reviews. • Maintaining Monitoring Reports: Each Contract Monitoring Report includes a “Monitoring Summary Page” containing all items reviewed during a Contract Monitoring Review (CMR). Any item from the Program Integrity Monitoring Tool identified during a review as unmet and/or identified for a CIP is automatically tracked by the analysts for follow-up and resolution. A spreadsheet with all the reviews scheduled for any contract monitoring visit are maintained by FY and the findings are recorded for each item on the tool. The PQIB analysts track the review dates, reports, findings, and CIPs. The analysts meet with the administrators monthly to track missing reports. All reports are filed by individual agency. • Continuous Improvement Plan (CIP): The PQIB analysts use the Contract Monitoring Report to determine if a CIP is required. A standard CIP template was developed, and all staff are required to use the same document. Every CIP has a 45-day corrective action period; however, programs may be granted extensions if requested in writing. Programs can request up to an additional 180 days to complete corrective actions. To receive an extension, a plan must be submitted in writing detailing how the program will address the actions by the end of the extension period. The PQIB analyst conducts follow-up with the consultant until the CIP is received. The CIP is not closed until all items identified for corrective action are resolved. A completed CIP and Resolution Letter are sent to the contractor and filed in the Common Folder in the agency’s folder. All spreadsheets, agreements, forms, and records of completed monitoring reports referenced above are maintained in the Common Folder and on the PQIB SharePoint page. Furthermore, CDSS is actively working to fully adopt audit report monitoring responsibilities of Local Education Agencies (LEA) and certain non-LEAs receiving Child Care and Development Fund (CCDF) Cluster program funds by July 1, 2025. Estimated Implementation Date: July 1, 2025 Contact: Jeff Fowler, Staff Services Manager III Child Care and Development Program California Department of Social Services

View Audit 352774 Questioned Costs: $1

Finding 554122 (2023-005)

Significant Deficiency 2023

State of California

CA

Questioned Costs Eligibility Reporting § 200.303

As reported in the prior year’s response, since fiscal year 2020-21, the Employment Development Department (EDD) has implemented dozens of strict anti-fraud measures and has continued to evaluate and enhance its fraud detection. EDD has also developed internal fraud working groups and a multiagency ...

As reported in the prior year’s response, since fiscal year 2020-21, the Employment Development Department (EDD) has implemented dozens of strict anti-fraud measures and has continued to evaluate and enhance its fraud detection. EDD has also developed internal fraud working groups and a multiagency fraud task force that reviews fraud data and fraud reports on a continual basis and recommends adjustments to filters and tools as necessary. EDD has successfully halted two large fraud scheme attempts over the previous two years and continues to work towards immediate detection and prevention of fraud attempts. EDD will continue to analyze and assess our processes to stay ahead of the ever-evolving fraud landscape. As previously described, EDD implemented the following measures to address the nationwide fraud attempts perpetrated against the new emergency federal benefit programs in 2020-21: • Implemented additional cross-matches in September 2020 to detect multiple claims per address. • Ceased automatically backdating PUA claims under federal rules in September 2020. • Strengthened identity verification procedures in October 2020 by implementing ID.me. • Implemented additional cross-matches in November 2020 against state inmate information. • Vetted applications against law enforcement databases and other tools provided by Thomson Reuters in December 2020 to further curb identity and non-identity fraud. • Established a 1099-G call center to help victims of identity theft deal with any tax-related questions. • Ceased printing Social Security numbers on mailed documents to reduce identity theft risk. • Enhanced benefit card security with Bank of America. • Partnered with state, local and federal law enforcement agencies to support thousands of criminal investigations, arrests, prosecutions and convictions. Estimated Implementation Date: Completed September 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch California Employment Development Department

View Audit 352774 Questioned Costs: $1

Finding 554121 (2023-004)

Material Weakness 2023

State of California

CA

Questioned Costs Eligibility Internal Control / Segregation of Duties § 200.303

As reported in the prior year’s response, given the unprecedented volume of unemployment insurance claims during the federal disaster—approximately 20 million claims compared to 3.8 million during the Great Recession—EDD took action to speed payments to eligible claimants whenever possible. For exam...

As reported in the prior year’s response, given the unprecedented volume of unemployment insurance claims during the federal disaster—approximately 20 million claims compared to 3.8 million during the Great Recession—EDD took action to speed payments to eligible claimants whenever possible. For example, EDD launched in July 2021 a Conditional Payment Program to speed payments to claimants who certified for benefits and already received at least one week of benefits in the past but whose payments were later pending for more than two weeks. EDD also boosted its capacity to process workloads, prioritized timely payments, and employed automation among other measures. EDD began automatically cross-matching EDD wage records and Franchise Tax Board records in November 2020 to assist in verifying the income of PUA claimants who could not be automatically verified through these procedures. Such claimants were required to submit additional documentation to EDD for a manual review. Regarding the manual processing of the income documents to substantiate the PUA weekly benefit amounts that have been increased above the minimum California WBA of $167, and the verification of employment or self-employment substantiation (known in California as “Self-employment/Employment Substantiation” or “SEES”), based on the U.S. Department of Labor’s (DOL) guidance in Unemployment Insurance Program Letter 05 24, EDD notified DOL on February 6, 2024, that California Unemployment Insurance Code (CUIC) section 1376 bars EDD from resolving the wage verification and self-employment verification items. Section 1376 provides that EDD cannot establish overpayments more than one year after the close of the benefit year in which the overpayment was made unless the overpayment is found to be a result of fraud, misrepresentation, or willful nondisclosure. Given that there is no fraud in creating these overpayments on the part of the individuals identified in these populations, EDD is no longer able to establish overpayments for these populations. On May 31, 2024, DOL notified EDD that the February 6, 2024, submission regarding how California’s finality laws affect the actions required to correct the wage verification and self-employment findings is sufficient to close these findings. Estimated Implementation Date: Completed May 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch California Employment Development Department

View Audit 352774 Questioned Costs: $1

Finding 554120 (2023-003)

Significant Deficiency 2023

State of California

CA

Questioned Costs Eligibility Reporting § 200.303

Reference No. 2023-003: The EDD resumed adjudicating all potential eligibility issues as of January 2021 and completed the retroactive determination workload on April 30, 2023. Estimated Implementation Date: Completed April 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch ...

Reference No. 2023-003: The EDD resumed adjudicating all potential eligibility issues as of January 2021 and completed the retroactive determination workload on April 30, 2023. Estimated Implementation Date: Completed April 2024 Contact: Diane Underwood, Division Chief Unemployment Insurance Branch California Employment Development Department

View Audit 352774 Questioned Costs: $1

Finding 553937 (2023-009)

Material Weakness 2023

Trimble Local School District

OH

Questioned Costs Allowable Costs / Cost Principles Equipment & Real Property Management § 200.439

Finding Number: 2023-009 Planned Corrective Action: The Treasurer will monitor future grants for this requirement. At the writing of this response ARP ESSER grants for the district have been completely expended. Anticipated Completion Date: March 1, 2025 Responsible Contact Person: Ashley Miller

View Audit 352599 Questioned Costs: $1

Finding 547552 (2023-005)

Material Weakness 2023

Housing Authority of the County of Monterey

CA

Questioned Costs HUD Housing Programs Material Weakness

Finding 2023-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program and Mainstream Vouchers Program Federal Assistance Listing Numbers: 14.871 and 14.879 Material Noncompliance – N. Special Tests and Provisions – HQS In...

Finding 2023-005 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program and Mainstream Vouchers Program Federal Assistance Listing Numbers: 14.871 and 14.879 Material Noncompliance – N. Special Tests and Provisions – HQS Inspections Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family at least biennially to determine if the unit meets the HQS and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of fifty-four (54) units, twenty-seven (27) units did not have a biennial HQS inspection performed. Our sample size is statistically valid. Known Questioned Costs: $239,802. Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs are in material noncompliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Mainstream Vouchers Programs and will implement internal control procedures that will ensure compliance with federal regulations. Jonathan Campbell, Director of Housing Programs, will be responsible to implement this corrective action by June 30, 2024.

View Audit 351739 Questioned Costs: $1

Finding 547551 (2023-004)

Material Weakness 2023

Housing Authority of the County of Monterey

CA

Questioned Costs HUD Housing Programs Material Weakness

Finding 2023-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Non Compliance...

Finding 2023-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Enforcement. For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct all life threatening HQS deficiencies within 24 hours after the inspections and all other deficiencies within 30 days or within a specified PHA-approved extension. Condition: Based upon inspection of the Authority’s files and on discussion with management, the Authority did not properly abate four (4) out of eleven (11) annual failed inspections selected for testing. Context: The Authority did not properly abate four (4) out of eleven (11) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Known Questioned Costs: $7,011. Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS enforcement. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in material non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers Program and will implement internal control procedures that will ensure compliance with federal regulations. Jonathan Campbell, Director of Housing Programs, will be responsible to implement this corrective action by June 30, 2024.

View Audit 351739 Questioned Costs: $1

Finding 547550 (2023-003)

Material Weakness 2023

Housing Authority of the County of Monterey

CA

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements:...

Finding 2023-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 and 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Significant Deficiency in Internal Control over Compliance for Eligibility: Emergency Housing Vouchers Material Weakness in Internal Control over Compliance for Eligibility: Section 8 Housing Choice Vouchers Program Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 3,328 units. Of a sample size of fifty-four (54) tenant files, the following was noted: • One tenant file was missing entirely • Original application was missing in 6 files • Lead based paint form was missing in 3 files • Signed lease was missing in 3 files Our sample size is statistically valid. Known Questioned Costs: $88,087 Cause: There is significant deficiency in the Emergency Housing Vouchers Program and a material weakness in the Section 8 Housing Choice Vouchers Program in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Emergency Housing Vouchers Program is in non-compliance and the Section 8 Housing Choice Vouchers Program is in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The affected files relate to clients that have been on the program for decades and as files get large, archiving takes place. To correct this finding, a directive will be issued to staff that will ensure that when files are archived the original application must be placed in the current working file going forward. Jonathan Campbell, Director of Housing Programs, will be responsible to implement this corrective action by June 30, 2024.

View Audit 351739 Questioned Costs: $1

Finding 544093 (2023-002)

Material Weakness 2023

Quinnipiac University

CT

Questioned Costs Allowable Costs / Cost Principles

Uniform Guidance Corrective Action Plan Year ended June, 30, 2023 Federal Finding #2023-002 The Federal Emergency Management Agency (FEMA) cannot duplicate funding for any costs for which there is another funding source. Quinnipiac University agrees with the finding. For one invoice submitted to FEM...

Uniform Guidance Corrective Action Plan Year ended June, 30, 2023 Federal Finding #2023-002 The Federal Emergency Management Agency (FEMA) cannot duplicate funding for any costs for which there is another funding source. Quinnipiac University agrees with the finding. For one invoice submitted to FEMA for reimbursement, the University also collected patient care revenue, resulting in a duplication of benefits. The finding is attributed to the additional review of financial records in response to inquiries from FEMA during the close out of the COVID-19 Public Assistance grant program. In March 2025, the University formally amended the project application number and adjusted its claimed amount for Emergency Protective Measures costs. Once the amendment was approved by the granting agency, the University returned the excess funds to the state of Connecticut. If the Office of Management and Budget have questions regarding this corrective action, please reach out to Stephen Allegretto, the Associate Vice President for Finance and Controller, who is responsible for ensuring this corrective action plan is implemented, at 203-582-7962.

View Audit 350900 Questioned Costs: $1

Finding 541798 (2023-002)

Material Weakness 2023

Housing Authority of Covington

KY

Questioned Costs Internal Control / Segregation of Duties Eligibility

Authority Response: The Authority agrees with the finding and is in process of assessing and modifying controls over compliance to avoid similar issues. The Authority will increase oversight of the compliance of program. Steve Arlinghaus, Executive Director, is responsible for implementing this cor...

Authority Response: The Authority agrees with the finding and is in process of assessing and modifying controls over compliance to avoid similar issues. The Authority will increase oversight of the compliance of program. Steve Arlinghaus, Executive Director, is responsible for implementing this corrective action by June 30, 2024.

View Audit 350707 Questioned Costs: $1

Finding 529877 (2023-004)

Significant Deficiency 2023

Manor College

PA

Questioned Costs Cash Management Significant Deficiency

The enhanced reconciliation process noted above for the Correction Action for Finding 2023-003 will determine the amount of financial aid awarded during the month. Based on the amount awarded, the College will then draw down the amount awarded. Manor believes the monthly reconcilation and drawdown p...

The enhanced reconciliation process noted above for the Correction Action for Finding 2023-003 will determine the amount of financial aid awarded during the month. Based on the amount awarded, the College will then draw down the amount awarded. Manor believes the monthly reconcilation and drawdown process being implemented by Manor personnel will minimize the risk that student financial aid funds are overdrawn.

View Audit 347913 Questioned Costs: $1

Finding 529651 (2023-006)

Material Weakness 2023

Town of Lake Lure

NC

Questioned Costs Procurement, Suspension & Debarment HUD Housing Programs

Finding: 2023-006 Name of Contact Person: Stephen Ford, Finance Director Corrective Action: The Town seeks to make the procurement process fair, open, and guided by a legal procurement process and related procedures. In May 2023, a new procurement policy and procedures was developed and adopted by...

Finding: 2023-006 Name of Contact Person: Stephen Ford, Finance Director Corrective Action: The Town seeks to make the procurement process fair, open, and guided by a legal procurement process and related procedures. In May 2023, a new procurement policy and procedures was developed and adopted by Town Council. Prior to the new policy, the prior guiding document was flawed, unclear, and sometimes vague. The new policy addressed those deficiencies and the new policy will be used in subsequent years. Also, in regards to the some major purchases, the Town had to address some purchases that availability, accessibility to services (sole source), extension of services (labor and need), and Council oversight. However management and Town Council confirms the need for safeguarding and adhering to the procurement policy, and has implemented training among staff as well as requiring general contractor oversight. Proposed Completion Date: The Town will implement the above procedure immediately.

View Audit 347541 Questioned Costs: $1

Finding 528847 (2023-006)

Material Weakness 2023

Iliff School of Theology

CO

Questioned Costs Student Financial Aid Material Weakness

Condition: Our audit procedures identified an instance where the School could not locate evidence that the required R2T4 calculation under federal regulation was completed and another instance whereas the calculation was inaccurate. Planned Corrective Action: The Iliff School of Theology has contr...

Condition: Our audit procedures identified an instance where the School could not locate evidence that the required R2T4 calculation under federal regulation was completed and another instance whereas the calculation was inaccurate. Planned Corrective Action: The Iliff School of Theology has contracted with a professional, third-party processing company to administer its student aid programs. This third-party processor is adequately skilled to complete Return of Title IV calculations and includes an established review process for quality control. All documentation will be maintained. Contact person responsible for corrective action: Jason Warr, VP for Business, Controller Anticipated Completion Date: May 2024

View Audit 346899 Questioned Costs: $1

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