Corrective Action Plans

Finding 560310 (2023-003)

Material Weakness 2023

CT

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accou...

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accountant and Auditors to make sure deadlines are realistic, coordinated and attainable. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 560309 (2023-002)

Material Weakness 2023

Windsor Housing Authority

CT

HUD Housing Programs Subrecipient Monitoring Eligibility

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for ten...

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for tenants begins 90 days prior to the recert date, but if tenants do not provide all the requested information, the recertification will be delayed until the information is provided, tenant is converted to a market rate rent, or we begin the termination process for termination of the voucher. We will continue to follow the HUD process for the management of the Housing Choice Voucher Programs/Mainstream voucher programs. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 560261 (2023-001)

Material Weakness 2023

Appalachian Community Capital Corporation

VA

Reporting

Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: Decem...

Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: December 31, 2023 The findings from the December 31, 2023 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2023-001: Community Development Financial Institutions Fund – Assistance Listing No. 21.024, Rapid Response Program, Restatement of Schedule of Expenditures of Federal Awards, Material Weakness Criteria and Condition: Recipients of federal funds are required to prepare a complete and accurate Schedule of Expenditures of Federal Awards. Additionally, recipients must establish and maintain effective internal controls over federal awards to provide reasonable assurance of accurate financial reporting Context: The Company restated the 2023 Schedule of Expenditures of Federal Awards by a material amount a result of misinterpretation of reporting requirements for loan loss reserves and allocations of other allowable purposes. Cause: The omission occurred due to a misinterpretation of reporting requirements involving the treatment of grant expenditures for the purpose of loan loss reserve funds, which differs in nature from general program expenditures. Management identified the issue and determined a change in reporting was needed to simplify tracking and reporting of federal grants, and to ensure compliance with the technical definition of expenditures in the guidance. Effect: Loan loss reserves allocated in the wrong period resulted in an understatement of total federal expenditures on the Schedule of Expenditures of Federal Awards. Recommendation: We recommend that the Company implement a formalized review process to ensure all applicable expenditures, including loan loss reserves, are properly recorded in the period in which assigned. Views of Responsible Officials and Planned Corrective Actions: We agree with the finding and have established a process to ensure all expenditures are properly included in the SEFA. Name of Contact Person: Donna Gambrell, President and Chief Executive Officer Signature of Contact Person:

View Audit 356165

Finding 560097 (2023-002)

Significant Deficiency 2023

Central Area Rural Transit System, Inc.

AK

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expendit...

Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expenditures to determine single audit status, and file corresponding reports in a timely manner. Expected Completion Date June 30, 2025

View Audit 356074

Finding 560057 (2023-005)

Material Weakness 2023

Commonwealth Ports Authority

MP

Subrecipient Monitoring Reporting

Finding No 2023-005 “ALN #21.027 Reporting” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Corrective Action: CPA agrees with the finding. CPA has subsequently made corrections to the reports. Pro...

Finding No 2023-005 “ALN #21.027 Reporting” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Corrective Action: CPA agrees with the finding. CPA has subsequently made corrections to the reports. Proposed Completion Date: April 30, 2025

View Audit 355992

Finding 560049 (2023-001)

Significant Deficiency 2023

New Narrative

OR

Reporting Significant Deficiency

Significant Deficiency over Preparation of Schedule of Federal Expenditures (SEFA) The Organization did not identify all federal awards and significant adjustments were required to the SEFA prepared by management. Corrective Action: The Organization agrees with the auditor’s recommendation. At the...

Significant Deficiency over Preparation of Schedule of Federal Expenditures (SEFA) The Organization did not identify all federal awards and significant adjustments were required to the SEFA prepared by management. Corrective Action: The Organization agrees with the auditor’s recommendation. At the time of this audit’s publishing, the Organization has implemented additional procedures and controls to identify and report all federal award activity. Anticipated Completion Date: May 2025

View Audit 355986

Finding 560044 (2023-001)

Significant Deficiency 2023

Wisconsin Cheese Makers Association

WI

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting

Comments on findings and recommendations Management should implement a process to evaluate and allocate expenses on a regular basis. Actions taken or planned Management implemented a process to evaluate and allocate expenses based on employee estimates of time spent by function and proportion of th...

Comments on findings and recommendations Management should implement a process to evaluate and allocate expenses on a regular basis. Actions taken or planned Management implemented a process to evaluate and allocate expenses based on employee estimates of time spent by function and proportion of the association’s floor space utilized by each employee during the year. Anticipated completion date July 1, 2023

View Audit 355972

Finding 560017 (2023-005)

Material Weakness 2023

City of Shepherdsville

KY

Reporting

Recommendation: The City should implement controls for filing federal financial reports in a timely manner. Action Taken: In the past few years, the city has experienced turnover in management from the City Clerk, Finance Director, and the HR Director along with being significantly understaffed. Wit...

Recommendation: The City should implement controls for filing federal financial reports in a timely manner. Action Taken: In the past few years, the city has experienced turnover in management from the City Clerk, Finance Director, and the HR Director along with being significantly understaffed. With the stabilization of appropriate staffing levels along with appropriate procedures, and clear job duties this should no longer be an issue. The Mayor and City clerk have sent out instructions to all department heads that the documentation for all grants must be sent to the Admin Department. With the completion of the FY 2024 audit and the continued support of leadership this should no longer be an issue.

View Audit 355934

Finding 560005 (2023-003)

Significant Deficiency 2023

Ida B Wells, INC

CT

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding; Reference Number: 2023-003 Description of Finding: The audit and reporting package were not submitted by the due date April 30, 2024. Finding is a significant deficiency. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will ensu...

Finding; Reference Number: 2023-003 Description of Finding: The audit and reporting package were not submitted by the due date April 30, 2024. Finding is a significant deficiency. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will ensure that there is an adequate level of appropriately trained and experienced personnel and that internal controls over financial reporting will function properly to submit the audit and reporting package timely. Name of Contact Person: Kimalee Williams, CEO - Faith Asset Management, LLC, (860) 528-5000, kimalee@faithassetmgt.com Projected Completion Date: July 31, 2026

View Audit 355922

Finding 560003 (2023-002)

Significant Deficiency 2023

Ida B Wells, INC

CT

HUD Housing Programs Special Tests & Provisions Cash Management

Finding Reference Number: 2023-002 Description of Finding: The security deposits, residual receipts, and replacement reserve were not properly established in separate bank accounts, and the required monthly deposits to the replacement reserve were not made. Statement of Concurrence or Nonconcurrence...

Finding Reference Number: 2023-002 Description of Finding: The security deposits, residual receipts, and replacement reserve were not properly established in separate bank accounts, and the required monthly deposits to the replacement reserve were not made. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management has set up separate bank accounts and continues to make the required deposits. Name of Contact Person: Kimalee Williams, CEO - Faith Asset Management, LLC, (860) 528-5000, kimalee@faithassetmgt.com Projected Completion Date: December 15, 2024

View Audit 355922

Finding 559992 (2023-002)

Significant Deficiency 2023

Central Arizona Irrigation & Drainage District

AZ

Allowable Costs / Cost Principles Reporting Procurement, Suspension & Debarment § 200.508 § 200.510

COVID-1 9 Coronavirus State and Local Fiscal Recovery Funds — Assistance Listing No. 21 .027 Recommendation: We recommend the District design controls to ensure an adequate review process over the invoices recorded and presented on the schedule of expenditures of federal awards to determine complian...

COVID-1 9 Coronavirus State and Local Fiscal Recovery Funds — Assistance Listing No. 21 .027 Recommendation: We recommend the District design controls to ensure an adequate review process over the invoices recorded and presented on the schedule of expenditures of federal awards to determine compliance with the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District’s policies will be updated and approved if needed to conform to federal guidance. Name(s) of the contact person(s) responsible for corrective action: Ron McEachern, General Manager or Delia Stoor, Accounting Manger Planned completion date for corrective action plan: September 30, 2024

View Audit 355902

Finding 559952 (2023-005)

Material Weakness 2023

City of Delta Junction, Alaska

AK

Reporting Material Weakness § 200.512

Finding 2023-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Kaylee Reierson, Finance Officer Corrective Action: Neither current City Administrator or Finance Officer was employed with the City during this time period. Moving forward, all reporting will be...

Finding 2023-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Kaylee Reierson, Finance Officer Corrective Action: Neither current City Administrator or Finance Officer was employed with the City during this time period. Moving forward, all reporting will be done in a timely manner. Proposed Completion Date: Already implemented when the new administration was hired.

View Audit 355888

Finding 559947 (2023-002)

Significant Deficiency 2023

New York Battery and Energy Storage Technology Consortium, Inc.

NY

Reporting § 200.512

Management agrees with the finding and will ensure that the required deadline is met in the future.

View Audit 355881

Finding 559943 (2023-005)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Cash Management HUD Housing Programs Procurement, Suspension & Debarment

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This in...

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This includes the oversight of processing payments of CFP expenditures, which includes the following procedures for: 1) payment of invoices; 2) requisition of funds; 3) monitoring; and 4) reporting of CFP funds.payment of InvoicesAll CFP invoices will be reviewed and clearly marked as approved and documented to show that the source of funds for payment are CFP grant funds by the Executive Director prior to payment. The Executive Director will specify the general ledger code, including the BLI account to be used for payment processing on the invoice before providing the invoice to the accounts payable clerk.Under no circumstances will a payment be made if KMHA has not drawdown and received the respective CFP funds.With the exception of funds associated with BLI 1406 “Operations”, PHAs have three (3) business days to issue and mail the check once the CFP funds are received.The Executive Director/accounts payable clerk will specify the BLI account and CFP grant year on the check voucher prior to sending the check voucher to the fee accountant for financial statement processing.Requisition of FundsFor each drawdown, the Executive Director will print the associated eLOCCS Voucher Payment form from the eLOCCS system.The Executive Director will document the check number(s) and vendor(s) associated with each CFP draw (i.e., the eLOCCS Voucher Payment form). In addition, each individual draw shall be numbered for reference purposes.A copy of each draw shall be submitted to the fee accountant to ensure proper reporting of the grant drawdown.With the exception of funds associated with BLI 1406 “Operations”, in no case shall a draw be made without the proper approved invoices.MonitoringThe fee accountant's monthly financial statements will include a CFP report for each grant which will be reviewed by the Executive Director for proper coding and accuracy.Folder has been created to track all required information in the management of a CFP grant to include correspondence to and from HUD, expenses, grant reimbursements, budgets, closeout documentation and EPIC management.Proposed Completion Date: Immediately

View Audit 355868

Finding 559920 (2023-001)

Material Weakness 2023

People's Emergency Center and Subsidiaries

PA

Material Weakness Reporting § 200.512

Finding 2023-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2023, management was unable to provide timely year end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately refle...

Finding 2023-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2023, management was unable to provide timely year end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately reflect the underlying accounting transactions. Recommendation We recommend that individuals overseeing the accounting and finance department continue to review the Organization's current accounting policies and update existing policies or implement new policies, as needed, to ensure that the trial balances are accurately maintained throughout the year, reconciliations are completed and reviewed monthly or quarterly, as appropriate, and the trial balances and related supporting schedules are prepared and reviewed timely after year-end. Management’s Corrective Action Plan Management has implemented a structured monthly closing process to ensure timely and accurate recording of transactions. All balance sheet accounts will be reconciled by the 15th day of the following month. We will develop and implement a month-end and year-end closing checklist based on U.S. GAAP and, as necessary, any city, state, or federal reporting requirements. We are also evaluating current staffing levels to determine if there is a need to hire additional personnel or retain external accounting support during the year-end closing process. We will conduct a pre-closing review in the 4th quarter to identify and resolve discrepancies prior to year-end. We will also prepare a preliminary trial balance and draft financial statements by July 31 to allow sufficient time for audit fieldwork. The Finance Committee of the HopePHL Board of Directors will receive quarterly updates on the status of the monthly financial closing process. Contact Person: Kathy Desmond, President and CEO Anticipated Completion Date: June 30, 2025

View Audit 355861

Finding 559858 (2023-002)

Material Weakness 2023

Washington County

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.208 § 200.328

Finding Number: 2023-002 Planned Corrective Action: The Chief Financial Administrator will ensure all ARPA expenditures are included on the Project and Expenditure Reports. Anticipated Completion Date: March 31, 2025 Responsible Contact Person: Ben Cowdery, Chief Financial Administrator

View Audit 355799

Finding 559810 (2023-001)

Significant Deficiency 2023

Opportunities Credit Union

VT

Reporting Significant Deficiency

Identifying Number: Finding 2023-001 Finding: Late Issuance of 2023 Single Audit Package Condition: The submission of the 2023 Single Audit reporting package was not submitted by the September 30, 2024 deadline. Corrective Actions Taken or Planned: Management agrees with the finding that the Single ...

Identifying Number: Finding 2023-001 Finding: Late Issuance of 2023 Single Audit Package Condition: The submission of the 2023 Single Audit reporting package was not submitted by the September 30, 2024 deadline. Corrective Actions Taken or Planned: Management agrees with the finding that the Single Audit report was not filed timely. This report will be filed once the Single Audit is issued. The delay in filing was due to personnel constraints. Management will take steps to hire the necessary personnel to ensure all audit work can be performed in a timely manner going forward. Completion Date: April 30, 2025 Responsible for the Corrective Action Plan: Erin Metivier, Chief Financial Officer

View Audit 355770

Finding 559783 (2023-003)

Significant Deficiency 2023

Portland Community Reinvestment Initiatives, Inc.

OR

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.502 § 200.510

While PCRI does have systems in place to adequately track federal expenditures, the preparation of the schedule of federal expenditures was delayed in large part due to the deficiencies outlined in Finding 2023-001, which led to delays in accurately compiling the information required for the schedul...

While PCRI does have systems in place to adequately track federal expenditures, the preparation of the schedule of federal expenditures was delayed in large part due to the deficiencies outlined in Finding 2023-001, which led to delays in accurately compiling the information required for the schedule of federal expenditures, and that the transition of relevant accounting processes to the outsourced accounting firm will resolve this deficiency going forward. The timeline for full transition of relevant accounting processes to the outsourced accounting firm which started in January of 2025 is approximately seven months due to the complexities of PCRI’s operations. PCRI anticipates this transition being complete in July of 2025.

View Audit 355753

Finding 559782 (2023-002)

Significant Deficiency 2023

Portland Community Reinvestment Initiatives, Inc.

OR

Reporting § 200.512

The delay in submission of the December 31, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the due date is a direct result of the delays in completion of the December 31, 2023 audit which were caused by the deficiencies outlined in Finding 2023-001. Management believes tha...

The delay in submission of the December 31, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the due date is a direct result of the delays in completion of the December 31, 2023 audit which were caused by the deficiencies outlined in Finding 2023-001. Management believes that the outsourcing of critical accounting functions will help ensure that PCRI’s records are reconciled in a timely manner which will allow for the Single Audit to be submitted by the due date going forward. The timeline for full transition of relevant accounting processes to the outsourced accounting firm which started in January of 2025 is approximately seven months due to the complexities of PCRI’s operations. PCRI anticipates this transition being complete in July of 2025.

View Audit 355753

Finding 559682 (2023-002)

Significant Deficiency 2023

Muslim Youth for Positive Impact

CO

Reporting

The Organization agrees with this finding and will implement a corrective action plan based on this recommendation.

View Audit 355577

Finding 559681 (2023-001)

Material Weakness 2023

Muslim Youth for Positive Impact

CO

Reporting Internal Control / Segregation of Duties

Management acknowledges that adjustments to deferred revenue, receivables, and revenue were required.

View Audit 355577

Finding 559271 (2023-002)

Significant Deficiency 2023

Foundation for Democratic Development

DC

Reporting

2022-003 Reporting Federal Program – All federal programs Criteria – The data collection form must be completed and submitted within nine months of the Organization’s fiscal year end. Condition and Context – As a result of a conversion to a new accounting system, the impact of COVID-19, and reco...

2022-003 Reporting Federal Program – All federal programs Criteria – The data collection form must be completed and submitted within nine months of the Organization’s fiscal year end. Condition and Context – As a result of a conversion to a new accounting system, the impact of COVID-19, and reconciliation differences, the data collection form was not timely submitted for the year ended December 31, 2023. Questioned Costs – None. Effect – The Organization was not in compliance with the Uniform Guidance reporting requirements. Cause – With the conversion to a new accounting system, combined with the COVID-19, new accounting staff and reconciliation differences, the data collection form could not be timely completed and submitted. Recommendation – The financial records of the Organization should be reconciled and closed shortly after year-end, which will permit the timely submission of the data collection form. Views of Responsible Officials and Planned Corrective Actions Management agrees with this finding. We will anticipate being able to comply with this requirement effective with the FY2024 audit. Anticipated Completion Date: The financial records for the year ended December 31, 2024, will be reconciled and closed, permitting the audited financial statements, financial reporting package and data collection form to be filed timely by September 30, 2025. Contact Person: Natalia Arno, President, 916-849-3057

View Audit 355515

Finding 559265 (2023-002)

Significant Deficiency 2023

Oklahoma City Innovation District, Inc.

OK

Eligibility Reporting Matching / Level of Effort / Earmarking § 200.512

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays e...

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays earlier in the audit process. Action Taken: Management agrees with the finding and will take steps to improve the timeliness of the audit process. Anticipated completion date: June 30, 2025 Name of contact person and title: Jeffrey Seymour, President / CEO

View Audit 355490

Finding 559174 (2023-002)

Significant Deficiency 2023

Ocab Community Action Agency, INC

SC

Reporting Matching / Level of Effort / Earmarking Special Tests & Provisions

Management is actively working on retaining and recruiting knowledgeable personnel in the finance and account department to enhance the department's effectiveness and efficiency. OCAB has established agreements with account professionals to improve the training and efficiency of staff in the fiscal...

Management is actively working on retaining and recruiting knowledgeable personnel in the finance and account department to enhance the department's effectiveness and efficiency. OCAB has established agreements with account professionals to improve the training and efficiency of staff in the fiscal office, focusing on areas such as financial compliance, daily fiscal responsibilities month end closing and budget analysis. OCAB as slso hired 2 fiscal personnel in this department. We believe significant progress has been made since the last reorting period. A wage and benefits was completed and utilized in the process. OCAB believes that the measures taken will ensure compliance with all department of Health & Human Services regulations.

View Audit 355410

Finding 559162 (2023-002)

Material Weakness 2023

Hamilton County Hospital District

TX

Reporting Internal Control / Segregation of Duties

orrective Action Plan for Finding 2023-002 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to e...

orrective Action Plan for Finding 2023-002 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to ensure reports are prepared using complete and accurate information. We will increase compensating controls for introducing additional oversight and review for future COVID-19 Provider Relief Fund reporting. Tammy Schreiber, CFO, will be responsible to ensure this is accomplished. The District had enough lost revenues during Period 4 that the error determined in Finding 2023-002 will not result in a conflict with funding received. The Corrective Action Plan will be implemented by September 30, 2025.

View Audit 355389

Corrective Action Plans

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