Corrective Action Plans

Finding 554580 (2024-034)

Significant Deficiency 2024

State of Oregon

OR

HUD Housing Programs Reporting Significant Deficiency § 200.328

2024-034 Oregon Housing and Community Services Department Quarterly Performance Report should include all expenditures incurred to date Management Response: The agency agrees with this finding. Quarterly performance report requirements will be reviewed with staff and additional oversight will be add...

2024-034 Oregon Housing and Community Services Department Quarterly Performance Report should include all expenditures incurred to date Management Response: The agency agrees with this finding. Quarterly performance report requirements will be reviewed with staff and additional oversight will be added to ensure accurate reporting occurs. Corrective reports will be filed to the extent allowed by HUD. Anticipated Completion Date: June 30, 2025 Contact person: Beth Brown, Controller

View Audit 353285

Finding 554579 (2024-036)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting Significant Deficiency

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff t...

2024-036 Oregon Business Development Department Implement controls and submit delinquent FFATA reports Management Response: We partially agree with this recommendation. Business Oregon has prepared and submitted FFATA reports in SAM.gov through 2023, and had done so yearly since 2011. Due to staff turnover, Business Oregon has not completed loading the data for FFATA reporting for 2024. Business Oregon is currently in the process of compiling the data pertaining to CDBG grant awards and other federal grant awards that met the criteria for FFATA reporting. Business Oregon will formally assign this reporting task and create written procedures regarding preparation of the FFATA reports to ensure a complete list of recipients or subawards is reported in SAM.gov in a timely manner. The estimated completion date of this corrective action is 6/30/2025. Anticipated Completion Date: June 30, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

View Audit 353285

Finding 554578 (2024-035)

Significant Deficiency 2024

State of Oregon

OR

HUD Housing Programs Period of Performance Reporting § 200.302

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program...

2024-035 Oregon Business Development Department Ensure CDBG expenditures are recorded in SFMA under the appropriate grant year Management Response: We agree with this recommendation. In February of 2025, the agency’s accountant assigned to this program began a full reconciliation of the CDBG program from FY 2020 to FY 2024. We have identified the differences between our accounting records in SFMA and what has been recorded through IDIS, our portal to request funds from the federal government. As of March 2025, we are beginning to finalize our reconciliation of administrative funds and our own agency’s matching contributions. Once incorporating this first step, our accounting staff will continue with a full project reconciliation for the current fiscal year, 2025. Any errors or adjustments identified will be corrected in this current fiscal year. This reconciliation between accounting records in SFMA and IDIS is expected to be complete in May of 2025. Anticipated Completion Date: May 31, 2025 Contact person: Imee Anderson, Chief Financial Officer, Mia Seo, Deputy-Chief Financial Officer, Rory Spencer, Accounting Manager, Jon Unger, CDBG Program Manager

View Audit 353285

Finding 554577 (2024-042)

Significant Deficiency 2024

State of Oregon

OR

Questioned Costs Period of Performance Cash Management

2024-042 Oregon Military Department Ensure payroll expenditures are coded to the correct period and errors are corrected timely Management Response: We agree with this recommendation. OMD acknowledges the finding regarding payroll expenditures coded outside the period of performance. We are committe...

2024-042 Oregon Military Department Ensure payroll expenditures are coded to the correct period and errors are corrected timely Management Response: We agree with this recommendation. OMD acknowledges the finding regarding payroll expenditures coded outside the period of performance. We are committed to strengthening controls to ensure payroll expenses are properly recorded and errors are promptly corrected. OMD will implement following corrective actions to address the recommendation made in the Audit Report. • All Payroll Coding Review Procedures: Establish a mandatory review process before finalizing payroll reimbursement requests to verify the correct coding of federal fiscal year allocations. • Timely Error Correction Process: Develop a formal procedure to ensure errors are identified and corrected within 60-90 days of discovery. • Training and Oversight: Conduct mandatory training for finance and payroll personnel on proper coding procedures and compliance with federal performance periods. • Review and Correction of Prior Year Coding Errors (FFY 2019, 2022, and 2023): Conduct a comprehensive review of payroll expenditures from FFY 2019, 2022, and 2023 to identify and correct any remaining errors. This process will involve reconciling payroll records with federal grant periods, adjusting accounting records, and ensuring proper documentation for any necessary retroactive corrections. Anticipated completion date: January 31, 2026. Contact person: Adam Giblin, Chief Financial Officer.

View Audit 353285 Questioned Costs: $1

Finding 554575 (2024-031)

Significant Deficiency 2024

State of Oregon

OR

Subrecipient Monitoring Reporting School Nutrition Programs § 200.303

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following pro...

2024-031 Department of Education Implement controls to ensure FFATA reporting is completed for all required subawards Management Response: ODE agrees with this finding. To strengthen controls and ensure FFATA reporting is completed for all required subawards, ODE plans to implement the following process improvements: • Collaborate with the Child Nutrition program management and Fiscal Grants team to provide full documentation of grant awards including terms, conditions and attachments. • Update ODE’s grant profile request Smartsheet tool to: o Identify FFATA eligibility prior to setting up a new grant award in the accounting system. o Automatically notify the FFATA team of new grant awards that require reporting. Anticipated Completion Date: June 30, 2025 Contact person: Kristie Miller, Accounting Director

View Audit 353285

Finding 554571 (2024-002)

Significant Deficiency 2024

Trinity Services, Inc.

IL

Questioned Costs Allowable Costs / Cost Principles Reporting

The Organization will enhance its procedures and internal controls with respect to preparation and requests of funds. Grant agreements will be reviewed to confirm if expenditures being requested are allowed. The Organization will add a secondary level of review to ensure reimbursement requests are a...

The Organization will enhance its procedures and internal controls with respect to preparation and requests of funds. Grant agreements will be reviewed to confirm if expenditures being requested are allowed. The Organization will add a secondary level of review to ensure reimbursement requests are accurately stated.

View Audit 353273 Questioned Costs: $1

Finding 554570 (2024-001)

Significant Deficiency 2024

Trinity Services, Inc.

IL

Questioned Costs Allowable Costs / Cost Principles Reporting

The Organization will enhance its procedures and internal controls with respect to preparation and requests of funds. Grant agreements will be reviewed to confirm if expenditures being requested are allowed. The Organization will add a secondary level of review to ensure reimbursement requests are a...

The Organization will enhance its procedures and internal controls with respect to preparation and requests of funds. Grant agreements will be reviewed to confirm if expenditures being requested are allowed. The Organization will add a secondary level of review to ensure reimbursement requests are accurately stated.

View Audit 353273 Questioned Costs: $1

Finding 554551 (2024-001)

Significant Deficiency 2024

North Central Florida Health Planning Council, Inc.

FL

Cash Management Reporting

Regarding 2024-1, we recognize that our current finance department is not adequately staffed with the caliber of accountants needed to support an organization of our size and complexity. Management and the Board are currently assessing our needs and weighing options regarding restructuring our finan...

Regarding 2024-1, we recognize that our current finance department is not adequately staffed with the caliber of accountants needed to support an organization of our size and complexity. Management and the Board are currently assessing our needs and weighing options regarding restructuring our finance department. Regardless of structure and staffing, moving forward, Management will develop and implement more efficient and effective processes for proper posting and regular reconciliation of grant-related balances to the accounting software and ongoing scrutiny of those processes.

View Audit 353267

Finding 554549 (2024-005)

Significant Deficiency 2024

Falmouth Housing Authority

MA

HUD Housing Programs Reporting Significant Deficiency

2024-005 - REPORTING Significant Deficiency Auditee’s Response and Planned Corrective Action FHA is implementing a Capital Fund close out checklist quarterly review process. The Executive Director and accounting team will participate in additional capital funding courses to improve its knowledge and...

2024-005 - REPORTING Significant Deficiency Auditee’s Response and Planned Corrective Action FHA is implementing a Capital Fund close out checklist quarterly review process. The Executive Director and accounting team will participate in additional capital funding courses to improve its knowledge and practices of required submission deadlines and government policy changes, if any. The new Fiscal Officer is tasked with monitoring submission deadlines via HUD’s EPIC and eLOCCS platforms. Planned Implementation Date of Corrective Action: Immediate Person Responsible for Corrective Action: Bobbi Richards, Executive Director

View Audit 353264

Finding 554541 (2024-004)

Significant Deficiency 2024

Falmouth Housing Authority

MA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

2024-004 - REPORTING Significant Deficiency Auditee’s Response and Planned Corrective Action As with 2024-001, this finding was based on a HUD system error that prevented submission on the due date. FHA experienced transition in the fiscal department and is cross-training backup personnel. A 10-day ...

2024-004 - REPORTING Significant Deficiency Auditee’s Response and Planned Corrective Action As with 2024-001, this finding was based on a HUD system error that prevented submission on the due date. FHA experienced transition in the fiscal department and is cross-training backup personnel. A 10-day buffer will be applied internally to submission deadlines to ensure on-time filing regardless of staff changes and absences. Planned Implementation Date of Corrective Action: Immediate Person Responsible for Corrective Action: Bobbi Richards, Executive Director

View Audit 353264

Finding 554514 (2024-002)

Significant Deficiency 2024

City of Minco, Oklahoma

OK

Reporting

Procedures will be added to ensure proper reporting in future periods.

View Audit 353177

Finding 554501 (2024-003)

Material Weakness 2024

Rocky Boy Public Schools

MT

Subrecipient Monitoring Cash Management Reporting

FINDING 2024-003: Head Start Program Control Weakness of Filing the Required Semi-Annual and Annual Reports ...

FINDING 2024-003: Head Start Program Control Weakness of Filing the Required Semi-Annual and Annual Reports Response: The District Clerk will contact the Head Start Grant Specialist to ensure the SF424 semi and annual reports are reviewed and approved when submitted. The District should implement a policies and procedures requiring that all Head Start reports be submitted within 30 days of the reporting period end date.

View Audit 353162

Finding 554500 (2024-001)

Significant Deficiency 2024

City of Simi Valley

CA

Reporting Internal Control / Segregation of Duties § 200.328 § 200.502 § 200.510

The City internally identify improvement opportunities in managing grants. As a part of the City’s grant oversight improvement efforts, the City began implementing various processes and internal controls surrounding grant monitoring, which improves the SEFA drafting process and mitigates risks of f...

The City internally identify improvement opportunities in managing grants. As a part of the City’s grant oversight improvement efforts, the City began implementing various processes and internal controls surrounding grant monitoring, which improves the SEFA drafting process and mitigates risks of future inaccuracies. These efforts began in early 2024 and include the following: • Creation of a grant policy that provides City staff with guidance, information, and expectations surrounding grants. • Creation of a master grants database that lists the general ledger fund, applicable project ledger references, status, grant type, start/end dates, granting agency, pass-through agency, grant name, assistance listing numbers, grant amounts, and the grant manager for each grant. This database is now used to verify the completeness and accuracy of the SEFA (beginning FY24). • Formal quarterly monitoring. Each quarter, the City will formally review the grants database with department contacts and grant managers to verify the completeness and accuracy of the database. The City is formalizing this process and plans to include department signoffs evidencing the review process. If any items are missing, the missing component will be identified and added to the database on a timely basis. The City will also utilize this quarterly process to review the grants policy to ensure grant managers are aware of the requirements related to their grants. • The City is in the process of formalizing the SEFA drafting process utilized during the FY24 SEFA preparation, which includes additional mitigating procedures such as reviewing all next FY federal receipts to ensure none of them relate to the SEFA year federal expenditures. Personnel Responsible for Implementation: Marvin Lopez Position of Responsible Personnel: Deputy Administrative Services Director (Fiscal Services) Expected Date of Implementation: June 30, 2025

View Audit 353160

Finding 554487 (2024-001)

Significant Deficiency 2024

Latin American Youth Center

DC

Subrecipient Monitoring Reporting

Views of Responsible Officials: To ensure compliance moving forward, the Center, as a direct recipient, will identify all Federal grants where they have a subaward reporting recipient, along with their reporting timelines and deadlines. The Center has likewise identified the staff owner of FFATA rep...

Views of Responsible Officials: To ensure compliance moving forward, the Center, as a direct recipient, will identify all Federal grants where they have a subaward reporting recipient, along with their reporting timelines and deadlines. The Center has likewise identified the staff owner of FFATA reporting within the Center. Immediately after the finding during the audit, the Center has prepared the subsequent year’s FFATA report to ensure compliance in subsequent fiscal year, 2025.

View Audit 353129

Finding 554419 (2024-007)

Significant Deficiency 2024

Northeastern Illinois University

IL

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Condition: Northeastern Illinois University (University) did not have adequate procedures in place to ensure the Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) reports were accurate and timely submitted to the U.S. Department of Education and posted to NEIU’s website. ...

Condition: Northeastern Illinois University (University) did not have adequate procedures in place to ensure the Education Stabilization Fund – Higher Education Emergency Relief Fund (HEERF) reports were accurate and timely submitted to the U.S. Department of Education and posted to NEIU’s website. Planned Corrective Action: The grants and Contracts Office will frequently review funding agency websites to ensure reports are up to date with changes in reporting requirements. The published reports will be revised to meet the requirements of the funding agency. The Grants and Contracts Office will also ensure that reports will be submitted and published as required by the funding agency in a timely manner. Contact person responsible for corrective action: Jannica Rae Quintana, Director of Controller’s office and Ruthann Griffith, Grants and Contracts Manager Anticipated Completion Date: 1/30/2025

View Audit 353078

Finding 554417 (2024-006)

Material Weakness 2024

Northeastern Illinois University

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS) for the effective date of the enrollment change P...

Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS) for the effective date of the enrollment change Planned Corrective Action: Registrar’s office will utilize the financial aid’s last date of attendance report to back date the effective enrollment reported date for unofficially withdrawn students. Contact person responsible for corrective action: Rahshida Walker, Registrar Anticipated Completion Date: 6/30/2025

View Audit 353078

Finding 554416 (2024-003)

Significant Deficiency 2024

City of Edinburg

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties

Recommendation: We recommend that the City adhere to the Compliance and Reporting Guidance for the SLFRF program and establish internal controls to ensure the City submits required reports when they are due. Views of Responsible Officials: The City has changed the process to submit their Quarterly r...

Recommendation: We recommend that the City adhere to the Compliance and Reporting Guidance for the SLFRF program and establish internal controls to ensure the City submits required reports when they are due. Views of Responsible Officials: The City has changed the process to submit their Quarterly reports. Reports are reviewed by the Grants Administration Department and Finance Department before they are submitted. The Finance Department has implemented procedures to ensure that all reports are processed and submitted timely. Proposed Completion Date: Fiscal Year 2024-2025 Contact Person: Ascencion Alonzo, Director of Finance, City of Edinburg

View Audit 353076

Finding 554301 (2024-001)

Material Weakness 2024

Western Illinois Area Agency on Aging

IL

Internal Control / Segregation of Duties Material Weakness Reporting

Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency implement an internal control to have a documented review of the reports by a person independent of the preparer of the report Explanation of disagreement with audit finding: There is no di...

Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency implement an internal control to have a documented review of the reports by a person independent of the preparer of the report Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Agency will review its processes to ensure an internal control is implemented. Name of the contact person responsible for corrective action: Tony Vermazen, Fiscal Manager Planned completion date for corrective action plan: Fiscal Year 2025

View Audit 352904

Finding 554300 (2024-002)

Significant Deficiency 2024

City of San Bruno

CA

Questioned Costs Allowable Costs / Cost Principles Reporting

The City will develop, document, and implement formal grant summary requirements review process and audit preparedness policy and procedures. The responsibilities, deliverables, and deadlines will be clearly outlined and communicated to all staff members. The City will remedy the customer account cr...

The City will develop, document, and implement formal grant summary requirements review process and audit preparedness policy and procedures. The responsibilities, deliverables, and deadlines will be clearly outlined and communicated to all staff members. The City will remedy the customer account credit balances by October 2025. Management intends to review and adjust the customer account balances.

View Audit 352902 Questioned Costs: $1

Finding 554299 (2024-001)

Significant Deficiency 2024

City of San Bruno

CA

Reporting Significant Deficiency Internal Control / Segregation of Duties

The City will develop, document, and implement a formal year-end closing process and audit preparedness policy and procedures. The responsibilities, deliverables, and deadlines will be clearly outlined and communicated to all staff members. The City remedied the delinquent ARPA SLFRF quarterly P&E R...

The City will develop, document, and implement a formal year-end closing process and audit preparedness policy and procedures. The responsibilities, deliverables, and deadlines will be clearly outlined and communicated to all staff members. The City remedied the delinquent ARPA SLFRF quarterly P&E Report to the Treasury in January 2024, covering July 1, 2022, through December 31, 2023. Management intends to fully expend the remaining ARPA SLFRF award in FY24 and file the required quarterly P&E Reports in April 2024 and the final report in July 2024.

View Audit 352902

Finding 554287 (2024-003)

Significant Deficiency 2024

City of West Melbourne, Florida

FL

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking § 200.303

Recommendation: The City should create a process to alert/remind management and City officials to meet the reporting requirements and deadlines. Corrective Action: The City recognizes the need for timely grant reporting and has recently added a Grants Administrator position to the Finance Department...

Recommendation: The City should create a process to alert/remind management and City officials to meet the reporting requirements and deadlines. Corrective Action: The City recognizes the need for timely grant reporting and has recently added a Grants Administrator position to the Finance Department who has created a grant report tracking process. Responsible Parties: Candice Blake, Finance Director Anticipated Completion Date: September 30, 2025

View Audit 352892

Finding 554282 (2024-001)

None 2024

Luther Crest, INC

KS

Questioned Costs Procurement, Suspension & Debarment HUD Housing Programs

Finding 2024-001: During the year ended December 31 2024 reserve deposits totaling $45256 were not made as required by the regulatory agreement (1) Comments on the Finding and Each Recommendation: The Organization did not have sufficient cash flow to make the required deposits. The management agent ...

Finding 2024-001: During the year ended December 31 2024 reserve deposits totaling $45256 were not made as required by the regulatory agreement (1) Comments on the Finding and Each Recommendation: The Organization did not have sufficient cash flow to make the required deposits. The management agent has reflected the delinquent reserve payments as payable at December 31 2024 and is making deposits as cash flow allows; (2) Actions Taken on the Finding: The Organization obtained a 6 month suspension of deposits and is making the delinquent deposits as cash flow allows

View Audit 352857 Questioned Costs: $1

Finding 554281 (2024-001)

None 2024

Luther Knoll INC

KS

Questioned Costs HUD Housing Programs Reporting

Finding 2024-001: During the year ended December 31 2024 reserve deposits totaling $9000 were not made as required by the regulatory agreement. (1) Comments on the Finding and Each Recommendation: The Organization did not have sufficient cash flow to make the required deposits. The management agent ...

Finding 2024-001: During the year ended December 31 2024 reserve deposits totaling $9000 were not made as required by the regulatory agreement. (1) Comments on the Finding and Each Recommendation: The Organization did not have sufficient cash flow to make the required deposits. The management agent has reflected the delinquent reserve payments as a payable at December 31 2024 and is making deposits as cash flow allows. (2) Actions Taken on the Finding: The Organization is making the delinquent depoist as cash flow allows

View Audit 352855 Questioned Costs: $1

Finding 554280 (2024-002)

Significant Deficiency 2024

City of Amarillo, Texas

TX

Reporting

Condition: Retainage payable of $47,878 was incorrectly reported in the program expenditures as of September 30, 2024. Corrective Action Plan: See the City’s response starting on page 19.

View Audit 352851

Finding 554250 (2024-003)

Significant Deficiency 2024

Sunrise County Economic Council

ME

Reporting Allowable Costs / Cost Principles Significant Deficiency § 200.508 § 200.510

Management attempted to contract with multiple accounting consultants for creating the SEFA but they were already at full capacity and were not available to assist with the creation of the report. When the relevant contract or grant award did not include the necessary information, SCEC management an...

Management attempted to contract with multiple accounting consultants for creating the SEFA but they were already at full capacity and were not available to assist with the creation of the report. When the relevant contract or grant award did not include the necessary information, SCEC management and program staff reached out to our contracting agencies to confirm whether federal funds were part of each award and to find out CFDA numbers and other contract information necessary to complete the form. Nevertheless, there were several errors that in the SEFA submitted to our auditors for review. For the two IRP and RMAP lending programs, the prior year balances were carried over into the FY 24 SEFA through a clerical error. The errors in item 11.037 and 11.419 are related to information we received from the contracting agency. In particular, 11.037 was listed under US Economic Development Administration according to the contracting agency and we were given the description of Economic Adjustment Assistance. The description for 11.419 was given to SCEC by the contracting agency as CDS – Congressionally Directed Spending. Finally, we provided two CFDA’s for the STEM Education award with the submission of the SEFA as we were waiting for confirmation from Program Managers about the correct CDFA numbers. The auditors were informed that we were waiting for these numbers when the SEFA was submitted. In FY24, SCEC had 29 different federal funding sources, from 14 different agencies. We are working to improve our capacity to report these awards without error before the review of our auditors.

View Audit 352825

Corrective Action Plans

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