Corrective Action Plans

Finding 504257 (2023-001)

Material Weakness 2023

Deerbrook, Inc.

MO

Allowable Costs / Cost Principles Special Tests & Provisions Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to pr...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended June 30, 2023. Finding 2023-001 Responsible Party Name: Myra Cerna Position: Project Accountant Telephone Number: (816) 608-1799 x 259 Federal Agency Department of Housing and Urban Development Federal Program Supportive Housing for Persons with Disabilities (Sec 811) Compliance Requirements A/B - Activities Allowed or Unallowed and Allowable Costs/Cost Principles, C – Cash Management, E – Eligibility, and N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action Management reported that the failure(s) involved records related to the period managed by the predecessor management company. We will request and keep all required documentation from HUD and establish processes and procedures to ensure compliance with the Regulatory Agreement or Capital Advance Use Agreement. Anticipated Completion Date June 30, 2024

View Audit 326753

Finding 504216 (2023-002)

Significant Deficiency 2023

Koinonia, Inc. 053-11202

NC

HUD Housing Programs Procurement, Suspension & Debarment Reporting § 200.302 § 200.303

Koinonia, Inc. Lenoir, North Carolina CORRECTIVE ACTION PLAN August 27, 2024 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 ...

Koinonia, Inc. Lenoir, North Carolina CORRECTIVE ACTION PLAN August 27, 2024 U.S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Koinonia, Inc. respectfully submits the following Corrective Action Plan for the year ended December 31, 2023. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Post Office Box 19608 Greensboro, North Carolina 27419-9608 The findings from the year ended December 31, 2023 Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - Financial Statement Audit and Federal Award Program Audit Finding 2023-001: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects (Section 223(f)/207) Recommendation: We recommend that the Project funds are only used for expenses of the Project. Additionally, we recommend the related entity reimburse the operating cash of the Project $15,985 for the payroll fees paid. Action Taken: Management acknowledges the Project funds were used for expenses of another entity. Management will ensure the related entity reimburses the operating cash of the Project $15,985 for the payroll fees paid and ensure that the Project funds are only used for expenses of the Project. Finding 2023-002: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend management review/enhance its accounting and internal control procedures to ensure that all key accounts are reconciled and reviewed with supporting evidence of such review. Action Taken: We agree with Finding 2023-002 and the recommendation described in the accompanying schedule of findings and questioned costs. Management will review the accounting ial procedures, system of internal controls and policies. FINDING - Federal Award Program Audit Finding 2023-003: U.S. Department of Housing and Urban Development, Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects (Section 223(f)/207) Recommendation: We recommend that management review its policies and procedures in place to ensure that the residual receipts deposit is made per regulatory guidelines. Action Taken: We agree with Finding 2023-003 described in the accompanying schedule of findings and questioned costs. Management will deposit $4,285 into the Project's residual receipts account. Management will review its policies and procedures in place to ensure that the residual receipts deposit is made per regulatory guidelines. If HUD has questions regarding this corrective action plan, please call 828-758-2617. Sincerely yours, Chassidy Triplett Project Administrator Koinonia, Inc.

View Audit 326713

Finding 504207 (2023-003)

Material Weakness 2023

Agwsr Community School District

IA

Internal Control / Segregation of Duties Reporting

We continue reviewing our procedures and will implement additional controls where possible.

View Audit 326704

Finding 504204 (2023-002)

Material Weakness 2023

Holland Home

MI

Material Weakness Reporting Internal Control / Segregation of Duties

Condition: The Organization is required to submit a quarterly narrative report within 30 days following the end of the calendar quarter to the granting agency The Organization was awarded the grant funds in September 2023 and did not complete the one required narrative reporting requirement due in J...

Condition: The Organization is required to submit a quarterly narrative report within 30 days following the end of the calendar quarter to the granting agency The Organization was awarded the grant funds in September 2023 and did not complete the one required narrative reporting requirement due in January 2024. Planned Corrective Action: Management will update its review process to ensure all required reporting is completed timely, and correspond with the granting agency to complete any missed reporting requirements they request. Management has noted that the nature through which the grant was issued resulted in some confusion regarding time periods and critical reporting requirements related to the grant program. Contact person responsible for corrective action: Adam Kinder, CFO Anticipated Completion Date: October 15, 2024

View Audit 326681

Finding 504203 (2023-001)

Material Weakness 2023

Holland Home

MI

Subrecipient Monitoring Material Weakness Reporting

Condition: The Organization has engaged a subrecipient as part of this grant program, which was subsequently determined, but did not have an executed agreement with the subrecipient and as a result did not meet the requirements of having performed formal risk assessment procedures. Planned Correctiv...

Condition: The Organization has engaged a subrecipient as part of this grant program, which was subsequently determined, but did not have an executed agreement with the subrecipient and as a result did not meet the requirements of having performed formal risk assessment procedures. Planned Corrective Action: Management has drafted and is finalizing an agreement with the identified subrecipient, and implement formalized policies and procedures to ensure no risk factors for non-compliance exist and to properly monitor the subrecipient activity. The identified subrecipient has met all documentation and submission requirements to support reporting and appropriate usage of grant funds related to the grant program. Contact person responsible for corrective action: Adam Kinder, CFO Anticipated Completion Date: October 11, 2024

View Audit 326681

Finding 504187 (2023-005)

Significant Deficiency 2023

West Oakland Health Council

CA

Reporting

The Council experienced turnover and changes within the finance department, which resulted in delays in the completion of the annual financial statement audit and SF-SAC filing. The Council will implement additional internal controls to prevent future late submissions of the SF-SAC.

View Audit 326649

Finding 504182 (2023-002)

Significant Deficiency 2023

Life Source International Charter School

CA

Questioned Costs Eligibility Subrecipient Monitoring § 200.308 § 200.309 § 200.403

1. Implementation of Sage Accounting Software: We have since implemented a comprehensive financial accounting software system, Sage, which allows us to track expenditures more accurately and ensure compliance with federal grant requirements. The system includes built-in safeguards to flag non-compli...

1. Implementation of Sage Accounting Software: We have since implemented a comprehensive financial accounting software system, Sage, which allows us to track expenditures more accurately and ensure compliance with federal grant requirements. The system includes built-in safeguards to flag non-compliant expenditures.

View Audit 326634 Questioned Costs: $1

Finding 504182 (2023-002)

Significant Deficiency 2023

Life Source International Charter School

CA

Questioned Costs Eligibility Subrecipient Monitoring § 200.308 § 200.309 § 200.403

2. Review and Strengthening of Internal Controls: Life Source International Charter School will be implementing additional internal control systems & processes that include an additional review of back up documents before monthly reports are filed. A copy of all backup documents in support of all m...

2. Review and Strengthening of Internal Controls: Life Source International Charter School will be implementing additional internal control systems & processes that include an additional review of back up documents before monthly reports are filed. A copy of all backup documents in support of all monthly reports will be kept at both Life Source International Charter School and the outside entities providing services and making reports on behalf of Life Source International Charter School.

View Audit 326634 Questioned Costs: $1

Finding 504182 (2023-002)

Significant Deficiency 2023

Life Source International Charter School

CA

Questioned Costs Eligibility Subrecipient Monitoring § 200.308 § 200.309 § 200.403

3. Staff Training and Capacity Building: Our staff has received training on federal grant compliance, including the specific criteria governing the period of performance and allowable costs under federal awards. Additionally, with the Sage system in place, staff are now better equipped to manage com...

3. Staff Training and Capacity Building: Our staff has received training on federal grant compliance, including the specific criteria governing the period of performance and allowable costs under federal awards. Additionally, with the Sage system in place, staff are now better equipped to manage compliance and reporting accurately.

View Audit 326634 Questioned Costs: $1

Finding 504182 (2023-002)

Significant Deficiency 2023

Life Source International Charter School

CA

Questioned Costs Eligibility Subrecipient Monitoring § 200.308 § 200.309 § 200.403

4. Commitment to Ongoing Compliance: We are committed to continually improving our internal control processes to ensure compliance with all federal regulations.

View Audit 326634 Questioned Costs: $1

Finding 504181 (2023-010)

Material Weakness 2023

City of Belgrade

MT

Reporting

FINDING 2023-010: Annual Financial Report and Audit (Repeated 2021-02, 2022-06) Response: Staffing issues, including vacancies, extended leave required for multiple employees, and limited skill sets, continued to impact the timing of the Fiscal Year 2023 audit. The addition of a Controller position...

FINDING 2023-010: Annual Financial Report and Audit (Repeated 2021-02, 2022-06) Response: Staffing issues, including vacancies, extended leave required for multiple employees, and limited skill sets, continued to impact the timing of the Fiscal Year 2023 audit. The addition of a Controller position addresses the skills issue, and all positions are now currently filled. There is a continued extended leave issue but it is not expected to impact the department. The Fiscal Year 2024 audit is on track to be completed on time.

View Audit 326632

Finding 504104 (2023-002)

Material Weakness 2023

Myrtle Point School District

OR

Subrecipient Monitoring Reporting Material Weakness § 200.508 § 200.510

Finding 2023-002 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 10.555 National School Lunch Program cluster Name of Federal Agency: U.S. Dep...

Finding 2023-002 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 10.555 National School Lunch Program cluster Name of Federal Agency: U.S. Department of Agriculture Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger. Cause: The District relied on individuals with insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Expenditures of federal awards and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly, and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: • SEFA was originally presented for auditors with incorrect information. • No reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: October 1, 2024 Responsible Person: Director of Business Services, Yamhill County School District No. 8

View Audit 326505

Finding 504091 (2023-001)

Significant Deficiency 2023

Rccc Villa

IA

Internal Control / Segregation of Duties Reporting

A review of current procedures will be done to ensure there is proper oversight.

View Audit 326496

Finding 504083 (2023-005)

None 2023

Cottey College

MO

Questioned Costs Student Financial Aid Special Tests & Provisions

2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The Coll...

2023-005 Student Financial Aid Cluster (a) Federal Supplemental Educational Opportunity Grant (b) Federal Work Study Grant (c) Federal Pell Grant Program (d) Federal Direct Loan Program, Assistance Listing No. (a) 84.007 (b) 84.033 (c) 84.063 (d) 84.268 - Year Ended June 30, 2023 Condition: The College did not timely and accurately complete refund calculations due to excluding one extra day in error for Thanksgiving break, which caused the total days to be off by one day. In review of the calculations the number of days in the break was not calculated correctly, resulting in the incorrect days in 1 out of 4 return of Title IV funds calculations. As a result of the incorrect number of days, the amounts of Title IV returned was incorrectly calculated for 1 out of the population of 4 (25%) withdrawal calculations which resulted in only $32 being under refunded for one student in the sample. We consider this finding to be an instance of non-compliance in relation to Special Tests and Provisions and is not a repeat finding. Statistical sampling was not used in making sample selections. Corrective Action Plan: The Registrar's Office will review the school calendar in Common Origination and Disbursement Web Site before the financial aid office begins processing R2T4's for the school year. Responsible Person for Correction Action Plan: Hannah Masters (Executive Director of Financial Aid and Student Accounts) and Chayna Penney (Registrar) Implementation Date for Corrective Action Plan: 09/10/2024

View Audit 326482 Questioned Costs: $1

Finding 504051 (2023-006)

Material Weakness 2023

MacOnaquah School Corporation

IN

Internal Control / Segregation of Duties Cash Management Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-006 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting a...

FINDING 2023-006 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: The School Corporation had not properly designed or implemented a system of internal controls, which would include proper segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education (IDOE) via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the audit period the School Corporation submitted two ESSER I reports, two ESSER II reports and two ESSER III reports, for a total of six reports. The annual data reports were complied, prepared and submitted by one employee without documentation to support an oversight or review process in place to prevent, or detect and correct, errors. In addition, because the unit was unable to provide supporting documentation for the information contained in the six reports submitted during the audit period, three of these reports contained errors. Contact Person Responsible for Corrective Action: Kelly McPike Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: An effective internal control will be developed to ensure supporting documentation is used and retained for all required reports submitted on behalf of the Education Stabilization Program Funds. The reports will be compiled, prepared, and submitted by more than one employee to support any possible oversight or errors. Anticipated Completion Date: April 2024

View Audit 326469

Finding 504047 (2023-005)

Material Weakness 2023

MacOnaquah School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Cash Management § 200.303

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting, Special Tests and Provisions – Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: The School Corporation had not designed or implemented effective internal controls to ensure that reimbursement request...

FINDING 2023-005 Finding Subject: Child Nutrition Cluster – Reporting, Special Tests and Provisions – Verification of Free and Reduced Price Applications (NSLP) Summary of Finding: The School Corporation had not designed or implemented effective internal controls to ensure that reimbursement requests were accurately submitted. The reimbursement requests were prepared by one employee based on meals served without evidence of an oversight or review process. The School Corporation had not designed or implemented effective internal controls to ensure the Verification of Free and Reduced Price Applications were accurately completed. One employee selected and verified the required sample of approved free and reduced-price applications without an oversight or review process. Contact Person Responsible for Corrective Action: Juli Windsor Contact Phone Number:765-689-9131 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The management of the School Corporation will establish a system of internal controls related to the grant agreement for the reporting and provisions to verify the free and reduced-price applications meet the compliance requirements. There will be responsible officials in place to comply with the report. Anticipated Completion Date: April 2024

View Audit 326469

Finding 504012 (2023-001)

Material Weakness 2023

Penn Manor Apartments (div. of Southeast Kansas Lutherans, Inc.)

KS

Cash Management HUD Housing Programs Reporting

The action taken was to immediately cease the payments, and wait until there are residual funds available to repay the loan or HUD approval is granted.

View Audit 326375

Finding 503980 (2023-005)

Material Weakness 2023

9/11 Day

CA

Internal Control / Segregation of Duties Reporting § 200.303 § 200.328 § 200.329

The audit testing in question related to transactions that occurred from October 1, 2020, to December 31, 2021. At this time, due to COVID and the use of Charity CFO, an outside accounting organization, to record and manage our transactions, 9/11 Day chose to track federal expenditures independently...

The audit testing in question related to transactions that occurred from October 1, 2020, to December 31, 2021. At this time, due to COVID and the use of Charity CFO, an outside accounting organization, to record and manage our transactions, 9/11 Day chose to track federal expenditures independently and internally through accounting spreadsheets. Although these transactions were included in 9/11 Day Quickbooks software as well, Charity CFO did not separate them under categories that identified them as federal grant expenses. At the request of the Auditor, 9/11 Day reviewed and reconciled these federal transactions in Quickbooks, without discrepancies. Beginning in 2023, we began tracking federal grant expenses and revenue in Quickbooks. In response to Auditor recommendations, we are reviewing and will update our written procedures for tracking, reviewing, approving and retaining documentation of federal expenses consistent with Federal Financial Reports submitted to the Agency.

View Audit 326306

Finding 503801 (2023-002)

None 2023

Warsaw Cusd 316

IL

Reporting

SEE SEFA REPORT FOR CAP ON FINDING 2023-002

View Audit 326080

Finding 503800 (2023-003)

None 2023

Warsaw Cusd 316

IL

Questioned Costs Reporting

SEE SEFA REPORT FOR CAP ON FINDING 2023-003

View Audit 326080 Questioned Costs: $1

Finding 503792 (2023-001)

Material Weakness 2023

Greenheart International

IL

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.328

2023-001 Name of Contact Person: Matthew Roy Corrective Action: After the September 2023 staffing changes, the Finance Director and the Accounting Manager reviewed the FFR reports prior to filing. The Finance Director provided verbal approval to file. For all reports going forward, Greenheart will d...

2023-001 Name of Contact Person: Matthew Roy Corrective Action: After the September 2023 staffing changes, the Finance Director and the Accounting Manager reviewed the FFR reports prior to filing. The Finance Director provided verbal approval to file. For all reports going forward, Greenheart will document approval of filing via email exchanges from the Accounting Manager to the Director of Finance. Proposed Completion Date: Management considers this finding resolved as of August 2024.

View Audit 326064

Finding 503750 (2023-001)

Material Weakness 2023

Rio Grande Headwaters Land Trust

CO

Allowable Costs / Cost Principles Material Weakness Reporting § 200.512

Finding 2023-001: Internal Control over Compliance Type of finding: Internal Control (material weakness) and Compliance (noncompliance) Recommendation: The Organization should strengthen its internal controls over year-end financial close and reporting with adopted policies and procedures to ensure ...

Finding 2023-001: Internal Control over Compliance Type of finding: Internal Control (material weakness) and Compliance (noncompliance) Recommendation: The Organization should strengthen its internal controls over year-end financial close and reporting with adopted policies and procedures to ensure compliance with the Report submission portion of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements section. Action Taken: The Organization plans to strengthen internal controls by adopting methods that allow for better tracking of restricted versus unrestricted funding, in addition to creating internal methods of tracking income, expense, and reporting of restricted funds throughout the year. The Organization took action with a change in management and a new external bookkeeper, which will allow the above processes to be completed with oversight from both internal and external sources. If there are questions regarding this plan, please call the responsible party listed below. Thank you, Laura Cusick Executive Director Rio Grande Headwaters Land Trust Laura@Rightslv.org (719)657-0800

View Audit 325993

Finding 503705 (2023-002)

Material Weakness 2023

It's Time Texas, Inc.

TX

Questioned Costs Reporting

Management Response: Name of Contact Person: Lonnicia Maxwell, Vice President Operations Corrective Action: ITT will design and implement a control process to ensure they are in compliance with Federal award time and effort reporting requirements. These actions were implemented in September 2024.

View Audit 325913 Questioned Costs: $1

Finding 503704 (2023-006)

Material Weakness 2023

City of Auburn, Maine

ME

Subrecipient Monitoring Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Management Response/Corrective Action Plan: Additional reports will be run to verify totals before filings of quarterly reports, paying particular attention to end of year and the needed reversal of the prior year payroll accrual. Errors found in reports will be corrected in subsequent records as al...

Management Response/Corrective Action Plan: Additional reports will be run to verify totals before filings of quarterly reports, paying particular attention to end of year and the needed reversal of the prior year payroll accrual. Errors found in reports will be corrected in subsequent records as allowable under Department of Treasury grant reporting guidelines.

View Audit 325909

Finding 503674 (2023-001)

Significant Deficiency 2023

California Mobility Center

CA

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

Management agrees with the finding and will implement controls and processes to improve the financial reporting of the Organization.

View Audit 325884

Corrective Action Plans

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