Corrective Action Plans

Finding 501226 (2023-004)

Material Weakness 2023

KS

Reporting Subrecipient Monitoring Material Weakness § 200.502

2023-004 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Award Period: June 30, 2023 Recommendation: The Board...

2023-004 Preparation of and Internal controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: U.S Department of Education Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Award Period: June 30, 2023 Recommendation: The Board of Education and management should review the financial reporting process. Once this review is complete, the District should then perform a risk assessment to determine the best way to implement appropriate internal controls over financial reporting to ensure that the District prepares the schedule conformity with Uniform Guidance. Action Taken (Unaudited): Management plans to work with a third-party consulting firm to address issues and improve protocols. Contact Name – Dr. Jessica Dain Expected Completion Date - 12/31/2024

View Audit 323488

Finding 501221 (2023-003)

Significant Deficiency 2023

State of Alabama

AL

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding: 45 CFR Section 261 .63 requires the Alabama Department of Human Resources to submit a Work Verification Plan to the U.S. Department of Health and Human Services (HHS) for approval. The Alabama Department of Human Resources must comply with its approved Work Verification Plan to ensure accur...

Finding: 45 CFR Section 261 .63 requires the Alabama Department of Human Resources to submit a Work Verification Plan to the U.S. Department of Health and Human Services (HHS) for approval. The Alabama Department of Human Resources must comply with its approved Work Verification Plan to ensure accuracy in reporting work activities by work eligible individuals on the Temporary Assistance for Needy Families (TANF) Data Report. Data for work participation activities are used in calculating work participation rates. During our testing of 25 TANF cases, we found two cases in which the hours reported for an individual participating in a work activity were inaccurate. The Department of Human Resources failed to ensure accuracy of data for work participation activities which may result in an inaccurate work participation rate. This is a significant deficiency in internal controls. The Department of Human Resources did not have adequate procedures in place to ensure that the information included on the TANF Data Report is accurate. Recommendation: The Department of Human Resources should establish and maintain effective internal controls to ensure accuracy in reporting work activities by work-eligible individuals on the TANF Data Report. Response/Views: We disagree. The finding statement declares that the Department of Human Resources failed to ensure accuracy of data for work participation activities which may result in an inaccurate work participation rate. This is a significant deficiency in internal controls. The Department of Human Resources did not have adequate procedures in place to ensure that the information included on the TANF Data Report is accurate. We do agree with the findings of two cases "in which the hours reported for an individual participating in a work activity were inaccurate." We agree that the 2 of the 25 cases selected had the incorrect frequency for the number of employment hours entered which could potentially affect the work participation rate for Alabama. Corrective Action Planned: The two cases which involved an error in the frequency of the hours reported appear to be isolated and inadvertent in nature. Our policy requires verification and calculation of employment hours at the beginning of employment and reverification and calculation of employment hours in the fifth month of employment. Based on our JOBS policy, your review of 25 cases, potentially represents up to 200 calculations and your findings indicate only 2 calculation errors. Furthermore, our research indicates that the errors in the two cases addressed in your findings did not have an affect on the State's overall Work Participation Rate. Additionally, we believe our supervisory reviews as well as a percentage of record rereviews remain the best way to monitor accuracy of information entered in our system while basic and refresher training remains the course of prevention for information prior to entry into the system. Basic training for each new employee involves two weeks of intense, in person, interactive training. Refresher training or one to one support is provided as needed or requested by county staff. The official policy and automation helpdesk are staffed by specialists, who responds to questions daily. County consultants also perform re-reviews of the county's reviews and provide guidance as observed or requested. The stated purpose of these processes is to ensure systematic review of the work done in the family assistance program; to identify worker problems; to identify error trends and concentrations; and to monitor program performance. At the county level information from that process can be used for worker performance assessment, local corrective action, to train new workers, to identify areas of strengths and weaknesses of staff. At the State level the process provides information to monitor program performance to include identifying problems and error trends by county, region and statewide. Analysis of this data provides a way to determine training needs and to evaluate performance standards and the impact of program changes. The Division case record re-review process of the work of the supervisor provides yet another level of oversight to address the issues. Resulting corrective action from these reviews both at the County and State Office level can include additional individual worker or general staff training, program clarifications, as well as attention to the specific cases identified. Longstanding practice of such activity and experience tells us the process does prevent, detect, and correct errors. These errors have been discussed with the county worker and supervisor for case corrective action. Finally, DHR is in the final stages of development of a new TANF and JOBS system and we have requested that the hours of participation field require a question regarding the frequency of hours listed. Anticipated Completion Date: December 31, 2024. Contact Person(s): Fannie Ashley or Tessa Mitchell

View Audit 323486

Finding 501220 (2023-002)

Significant Deficiency 2023

State of Alabama

AL

Subrecipient Monitoring Reporting

Finding: The Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that is codified in 2 CFR Part 170, requires recipients (i.e., direct recipients) of grants or cooperativ...

Finding: The Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that is codified in 2 CFR Part 170, requires recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The Uniform Guidance, 2 CFR Part 200, Appendix XI Compliance Supplement, May 2023, requires the ALSDE to report applicable first-tier subawards and contract information as required in the “Transparency Act.” The ALSDE did not report applicable first-tier subawards and contractors subject to FFATA data for the monitored grants in the FSRS pursuant to Federal Regulations. The ALSDE did not have procedures in place to ensure that applicable first-tier subaward information was reported to the FSRS, resulting in a failure to provide a full disclosure to the public of all entities or organizations receiving federal funds during the fiscal year 2023. Recommendation: The ALSDE should develop, maintain, and implement effective procedures to ensure compliance with the FFATA. Response/Views: The finding reads as if the ALSDE did not report FFATA for the monitored grants. It was explained to us that this was just for 84.425. FFATA was reported for monitored grants with the exception of part of 84.425. There was a discrepancy in whether it should have been reported. Guidance with the United States Department of Education (USDE) indicated that if the Governor awarded GEER funds to a state agency with an agreement, then the state agency is responsible for reporting. If there is no agreement in place, then the responsibility falls to the Governor’s office. The ALSDE takes full responsibility for this finding. Corrective Action Planned: Steps are being taken to ensure all are aware of the ALSDE’s responsibility to treat 84.425 just as all other Federal awards required for FFATA reporting. These awards will be reported as we are currently doing per FSRS and Federal Regulations. Anticipated Completion Date: The ALSDE will have this corrected no later than 10/31/24. Contact Person(s): Lynn Shows, Accounting Director, lshows@alsde.edu, 334-699-4472

View Audit 323486

Finding 501207 (2023-004)

Significant Deficiency 2023

Shasta Regional Transportation Agency

CA

Cash Management Reporting Significant Deficiency

Federal Agency: U.S. Department of Transportation Program/Cluster: Metropolitan Planning and Research Federal Assistance Listing Number: 20.505 Pass‐through: California Department of Transportation Award No. and Year: 74A0821, 2022/2023 Compliance Requirement: Reporting Type of Finding: Significant ...

Federal Agency: U.S. Department of Transportation Program/Cluster: Metropolitan Planning and Research Federal Assistance Listing Number: 20.505 Pass‐through: California Department of Transportation Award No. and Year: 74A0821, 2022/2023 Compliance Requirement: Reporting Type of Finding: Significant Deficiency over Compliance, Instance of Noncompliance Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Delay in Caltrans approving the first quarter request for reimbursement and progress reports until January 24, 2023, as well as additional staff time needed to prepare the narrative information, resulted in the submittal of the second quarter reports nine days after the due date of January 30, 2023. Caltrans District 2 staff were notified early that there would be a delay in the reporting and indicated this was acceptable. This is an extraordinary occurrence, as it is SRTA’s common practice to submit all required reports before the deadline. Corrective Action Plan: The Agency will send a memorandum to all staff to ensure timely reporting of required quarterly reports in accordance with the agency’s established policies and procedures and compliance with the Master Fund Transfer Agreement that is active at the time of submittal. The Agency will also create reminders on the shared agency calendar that will be set to automatically alert the executive director, CFO, OWP manager, and relevant staff, of the deadline to submit the quarterly narratives to further eliminate the risk of late reporting. Responsible Individual(s): Sean Tiedgen, Executive Director and Jessica Carlson, Chief Fiscal Officer Anticipated Completion Date: June 30, 2024

View Audit 323480

Finding 501206 (2023-002)

Significant Deficiency 2023

Ufcw Charity Foundation, Inc.

DC

Reporting Subrecipient Monitoring Significant Deficiency § 200.328 § 200.329

Finding 2023-002: Reportable Finding Considered a Significant Deficiency – Reporting Assistance Listing Number: 10.181 Agency: U.S. Department of Agriculture Program: Pandemic Relief Activities: Farm and Food Worker Relief Program (FFWR) Award Number: AM22FFWDC0002-02 Grant Years: 2023 Views of Resp...

Finding 2023-002: Reportable Finding Considered a Significant Deficiency – Reporting Assistance Listing Number: 10.181 Agency: U.S. Department of Agriculture Program: Pandemic Relief Activities: Farm and Food Worker Relief Program (FFWR) Award Number: AM22FFWDC0002-02 Grant Years: 2023 Views of Responsible Officials – We acknowledge the finding regarding the reconciliation of Form SF-425 for the period November 4, 2022, through April 3, 2023. The issue arose because the preparer did not properly reconcile financial records or obtain a secondary review prior to submission. We are committed to maintaining compliance with 2 CFR sections 200.328 and 200.329 and have already taken corrective steps. Corrective Actions – Root Cause Analysis: The deficiency was caused by the preparer’s failure to review and reconcile Form SF-425 with the financial records prior to submission. The preparer submitted the form without verifying the accuracy of the data. Revised Reporting and Review Process: • Action: We have implemented a formal review process where all Forms SF-425 are reconciled with the financial records before submission. This process includes: o The preparer reconciles the financial data with the underlying financial records. o A mandatory review by the Finance Director or another senior finance officer before submission. o Final approval is given by the Program Director and then the President. • Results: This process was successfully implemented for the April 4, 2023, through October 3, 2023, filing, significantly improving accuracy and compliance. • Responsible Person: The Finance Director is responsible for overseeing the reconciliation and review process. • Timeline: The new process is already in place and was followed for the second filing in 2023. Documentation of Review and Approval: • Action: All review and approval process steps are documented through email communications, ensuring that each step—from reconciliation to final approval—is tracked and recorded. • Responsible Person: The Finance Director ensures that email approvals are completed and stored as part of the official documentation. • Timeline: This documentation process is currently in place and was followed for the April 4, 2023, through October 3, 2023, submission. Conclusion: The corrective actions outlined above have been implemented and are already showing positive results, as demonstrated by the successful filing of the April 4, 2023, through October 3, 2023, From SF-425. By ensuring that every Form SF-425 is reconciled and reviewed before submission, we are confident that these measures will prevent future discrepancies. Completion Timeline: The revised review and approval process is fully implemented and has been successfully applied to the April 4, 2023, through October 3, 2023, filing.

View Audit 323477

Finding 501192 (2023-003)

None 2023

Restart Housing Services, Inc.

MO

HUD Housing Programs Reporting

Management concurs with the findings and is working to ensure all employees adhere to control procedures and compliance requirements set by HUD. For finding 2023-003, the Organization is working to deposit surplus cash into a residual receipts account.

View Audit 323454

Finding 501167 (2023-001)

Significant Deficiency 2023

John H. Boner Community Center, INC

IN

Reporting Subrecipient Monitoring

SIGNIFICANT DEFICIENCY 2023-001 US DEPARTMENT OF EDUCATION. Promise Neighborhoods. 84.215N for the year ended December 31, 2023. The Center received an independent contractor invoice in 2023 for services performed in 2022. This resulted in the reporting of $220,695 of the Center's 2022 federal award...

SIGNIFICANT DEFICIENCY 2023-001 US DEPARTMENT OF EDUCATION. Promise Neighborhoods. 84.215N for the year ended December 31, 2023. The Center received an independent contractor invoice in 2023 for services performed in 2022. This resulted in the reporting of $220,695 of the Center's 2022 federal award expenditures in the 2023 Schedule. Recommendation: We recommend that management establish a reconciliation process for all substantial grants to be completed within the first couple of months of the following year to identify potential differences and issues. This should include the inquiry of independent contractors and subrecipients as to unbilled services. Action Taken: We concur with the recommendation. Effective fiscal year 2024, management has established a reconciliation process to track contractor and vendor billings. This will include the inquiry of independent contractors and subrecipients as to unbilled services at fiscal year-end. If the U.S. Department of Education has questions regarding this plan, please call James Taylor 317 808-2300.

View Audit 323425

Finding 501157 (2023-001)

Material Weakness 2023

Rappahannock Goodwill Industries, Inc.

VA

Internal Control / Segregation of Duties Reporting

Management was able to see deficiencies in the finance and accounting department in 2023. There was turnover of several staff, and in December 2023 the VP of Finance was removed from the position and a new qualified CFO was hired in mid-January 2024. An accounting and consulting firm, Cherry Bekae...

Management was able to see deficiencies in the finance and accounting department in 2023. There was turnover of several staff, and in December 2023 the VP of Finance was removed from the position and a new qualified CFO was hired in mid-January 2024. An accounting and consulting firm, Cherry Bekaert was hired in early January 2024 to assist with bringing the accounting and financial systems up to GAAP standards. In addition, the GL accountant position has been upgraded in 2024 to a Senior Accountant position and new qualified staff have been hired to continue to allow for internal controls. The AR and AP positions continue so that there is separation of duties as well. Additionally, management decided in 2023, to move away from the accounting system ‘Traverse’ that was very difficult to navigate and was antiquated in its functioning. The new Sage Intacct accounting software was implemented in 2024. Cherry Bekaert was hired and under the direction of the new CFO the implementation was completed on May 1, 2024. SAGE Intacct has made the accounting process much more efficient to enable proper functioning of the accounting department. Moving forward, the intention is to continue the assistance of the consulting firm, as a long-term consulting partner, to complete reconciliations and to ensure stability if there is staff turnover. This also ensures oversight and corrections of processes monthly.

View Audit 323413

Finding 501142 (2023-001)

Material Weakness 2023

Houston Housing Authority

TX

Internal Control / Segregation of Duties HUD Housing Programs Material Weakness

2023-001 Financial Reporting – Disclaimer of Opinion Material Weakness in Internal Control Material Noncompliance Condition: During our audit of the Authority’s financial statements, numerous adjustments were needed to properly report the financial statements in accordance with generally accep...

2023-001 Financial Reporting – Disclaimer of Opinion Material Weakness in Internal Control Material Noncompliance Condition: During our audit of the Authority’s financial statements, numerous adjustments were needed to properly report the financial statements in accordance with generally accepted accounting principles. Certain accounts had not been properly reconciled and corrective entries were not readily available. Significant audit adjustments were necessary for several audit areas and the audit was significantly delayed due to these adjustments. Given the amount of adjustments needed the auditor did not have enough time to complete the necessary audit procedures and as such have issued a disclaimer of opinion on the financial statements. Auditor’s Recommendations: The Authority should continue to develop and implement internal controls over both internal and external reporting, and the year-end close process to ensure reporting remains accurate and timely, with any unexpected financial data being investigated and corrected before it is reported. The Authority should consider additional staff training on development activities. Action Taken: The Houston Housing Authority agrees with this finding and related recommendations. During this audit, as these issues arose, notes were taken, evaluation of what had happened was made so that we could make the necessary adjustments to our procedures to prevent the continuation of these issues. In addition, we hired a firm to come in and undertake a review of the finance department. The purpose of this review was to review our existing staffing levels, workloads, experience, etc., for purposes of proposing a reorganization of the finance department to address any deficiencies. We have reviewed the recommendations from this consultant and are in the process of implementing many of the recommended changes. We are in the process of bringing in additional staff to expand the capacity of the Finance department. As we had fallen behind on our audits we anticipated the weaknesses noted in prior audits would continue to be present in future audits including the 2023 audit. We have been working very diligently to address the issues within the finance department that gave rise to this finding. We fully expected this finding or a similar finding to be present for the 2023 audit as many of the departmental improvements and changes were not in place during the 2023 calendar year. We have also been somewhat limited in the time available to implement changes as we have been working on clearing up the prior audit delinquencies since hiring out new outside auditors. This will be the first time in years where we will have a prior year audit available to us prior to the end of the current year. We will be able to have any 2023 audit adjustments posted to the general ledger prior to yearend 2024 so many of the reconciliation issues that have been encountered on the prior audits are not expected to be present when we move into the 2024 audit. The VP Fiscal and Business Operations as well as the Director of Finance are responsible for implementing the necessary process and procedural changes to eliminate the need for this type of finding for the 2024 audit.

View Audit 323395

Finding 501137 (2023-002)

Material Weakness 2023

West Community Economic Development Corporation

CO

Cash Management Reporting

West Community Development Corporation (dba BuCu West Development Center) is revising its financial procedures to ensure all federal grant transactions are recorded on an accrual basis. We are working closely with our financial team and external consultants to realign our reporting practices by the ...

West Community Development Corporation (dba BuCu West Development Center) is revising its financial procedures to ensure all federal grant transactions are recorded on an accrual basis. We are working closely with our financial team and external consultants to realign our reporting practices by the next fiscal year. This includes enhanced staff training and system upgrades to support accrual-based tracking and reporting.

View Audit 323394

Finding 501136 (2023-001)

Material Weakness 2023

West Community Economic Development Corporation

CO

Reporting

West Community Development Corporation (dba BuCu West Development Center) agrees with the finding and recommendation. A finance director position was hired in March 2024 to support and improve accounting procedures and reporting including SEFA preparation to ensure full compliance with Uniform Guida...

West Community Development Corporation (dba BuCu West Development Center) agrees with the finding and recommendation. A finance director position was hired in March 2024 to support and improve accounting procedures and reporting including SEFA preparation to ensure full compliance with Uniform Guidance. Additionally, we implemented an upgraded invoicing platform and financial tracking system to better segregate and report federal award expenditures accurately and in a timely manner.

View Audit 323394

Finding 501134 (2023-001)

Significant Deficiency 2023

Georgia Alliance of Boys & Girls Clubs, Inc.

GA

Internal Control / Segregation of Duties Reporting § 200.328 § 200.329

Individuals Responsible for Corrective Action Plan: Kristine Steinmann, Alliance Director Corrective Action: The Alliance will enhance its procedures and internal controls to ensure that records of report submission are appropriately retained. Anticipated Completion Date: December 31, 2024

View Audit 323392

Finding 501133 (2023-001)

None 2023

Texas Alliance of Boys & Girls Clubs, Inc.

TX

Reporting Subrecipient Monitoring § 200.414 § 200.502

Individuals Responsible for Corrective Action Plan: BGCA Fiscal Team-Shelby Mahoney; Alliance Director Corrective Action: Review all federal grant contracts to determine if any separate funding sources should be listed for total funds received. Anticipated Completion Date: December 31, 2024

View Audit 323391

Finding 501127 (2023-004)

Material Weakness 2023

The Carle Foundation

IL

Student Financial Aid Reporting Eligibility § 200.303

Corrective Action Plan: The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending acc...

Corrective Action Plan: The Methodist College Registrar has been working with NSC to get the college relinked to the correct college in their system, which was fixed 11/2023. The registrar redeveloped database query to pull the old data that had been deleted by NSC due to FERPA and began sending accurate file submissions to NSC in June 2024. Files generated and submitted under the College’s new processes are taking roughly one week to process from initial submission, through error correction, and finalization. Contact Person(s): Justina Kirchgessner Anticipated Completion Date: End of 2024

View Audit 323383

Finding 501115 (2023-001)

Material Weakness 2023

The Carle Foundation

IL

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.430

Corrective Action Plan: SOR II grant leadership evaluated its process for preparing and reviewing time tracking for this award and implemented procedures to ensure appropriate documentation of personnel costs is complete and accurate. The prior year's finding was corrected with the pay period ending...

Corrective Action Plan: SOR II grant leadership evaluated its process for preparing and reviewing time tracking for this award and implemented procedures to ensure appropriate documentation of personnel costs is complete and accurate. The prior year's finding was corrected with the pay period ending 9/23/2023, which resulted in this repeat finding for the year ended 12/31/2023. Hourly staff are clocking into the appropriate cost center and salaried staff are submitting hours to payroll to ensure the proper tracking of time. Contact Person(s): Heather Hintz/Kathy Dams Anticipated Completion Date: 10/1/2023

View Audit 323383

Finding 501096 (2023-001)

Material Weakness 2023

Triple Bottom Line Foundation

CO

Subrecipient Monitoring Reporting

The 2023 SEFA was based on the 2022 audited SEFA schedule, updating it for the new 2023 federal programs. Since most of ICAST contracts are with state government agencies, in some instances it is not clear or apparent to ICAST staff, whether the source of funds are Federal for those state contracts...

The 2023 SEFA was based on the 2022 audited SEFA schedule, updating it for the new 2023 federal programs. Since most of ICAST contracts are with state government agencies, in some instances it is not clear or apparent to ICAST staff, whether the source of funds are Federal for those state contracts. The initial SEFA submission was identified as preliminary and was subsequently updated as ICAST learned more about the source of the state funds. The accrual figures were subject to ongoing deliberations with the state and federal agencies that led to delays in addressing the final reconciliation. ICAST is experiencing delays as long as six months for approval and payment of its invoices by both the state and the federal agencies monitoring its program funds. ICAST has addressed this finding in the following manner: 1. Management and staff will be taking refresher training on the Uniform Guidance requirements. New staff will be trained on it. 2. ICAST has begun to clarify upfront the source of funds for all contracts with its funders. Also ICAST is consolidating all contracts into a central location, with clear indication of the source of funds, to ensure complete and accurate records are available to management and staff when assessing programs for inclusion/exclusion on the SEFA. 3. ICAST continues to hire and train additional financial/accounting staff and management to ensure financial records are reviewed every month and items are followed up and resolved in a timely manner. 4. ICAST is reorganizing its accounting recordkeeping process, to ensure program information is more transparent and readily available.

View Audit 323382

Finding 501070 (2023-001)

Material Weakness 2023

Young Women's Christian Association of Metropoliatan St. Louis

MO

Reporting Subrecipient Monitoring Material Weakness

Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with...

Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with the Department of Health and Human Services and other regulatory bodies to ensure the proper completion of subaward reports in FSRS, the SF429 and other required reporting. The above noted issue was discovered during the course of the 2022 audit, but after the reporting deadlines for the 2023 year. Upon discovery of the requirement, Management took the above noted steps to become compliant with both 2022 and 2023. The finding repeated in 2023 solely due to the timing of the discover of the issue. Effective to date, all FSRS and applicable SF429 reports have been filed correctly and timely.

View Audit 323329

Finding 501065 (2023-001)

None 2023

Foundation for Puerto Rico, Inc.

PR

Reporting Internal Control / Segregation of Duties § 200.512

Management Response: This finding was identified for the submission of the 2021 Data Collection Form, and by the time the Organization established procedures to ensure that the Data Collection Form and Single Audit report are submitted within the established due date, the due date of the 2022 audit ...

Management Response: This finding was identified for the submission of the 2021 Data Collection Form, and by the time the Organization established procedures to ensure that the Data Collection Form and Single Audit report are submitted within the established due date, the due date of the 2022 audit already passed. However, the procedures will be in place for the next year’s audit to avoid the recurrence of this finding.

View Audit 323328

Finding 501062 (2023-001)

None 2023

Virginia University of Integrative Medicine

VA

Reporting

The University has already addressed the Corrective Action Plan for this issue: • The 3rd Party Processor was contacted and they confirmed VUIM will need to provide information about 100% of the VUIM student body to Campus Ivy. • VUIM met with Campus IVY, Populi, as well as a 3rd party software dev...

The University has already addressed the Corrective Action Plan for this issue: • The 3rd Party Processor was contacted and they confirmed VUIM will need to provide information about 100% of the VUIM student body to Campus Ivy. • VUIM met with Campus IVY, Populi, as well as a 3rd party software developer to build a technology solution for aggregating the student data Campus Ivy requires but Populi could not produce, out of the box. Now, all information about all students are reported accurately and timely, by running the newly built report process and uploading it to Campus IVY every 45 days - well within the 60 day timeline required.

View Audit 323327

Finding 501051 (2023-005)

Significant Deficiency 2023

Forum for Cultural Engagement, Inc.

NY

Cash Management Reporting Significant Deficiency § 200.303

Views of Responsible Officials and Action Taken: FCE implemented new internal controls in the fourth quarter of 2023 and has continued to document all draw down requests, review thereof, and approvals.

View Audit 323314

Finding 501049 (2023-003)

Significant Deficiency 2023

Forum for Cultural Engagement, Inc.

NY

Reporting Material Weakness Significant Deficiency § 200.508

Views of Responsible Officials and Action Taken: FCE agrees with the finding and has implemented a corrective action plan that requires the accounting and reporting to be performed by an outside CPA firm with expertise in accrual basis accounting, cost allocation and grant accounting concepts. Durin...

Views of Responsible Officials and Action Taken: FCE agrees with the finding and has implemented a corrective action plan that requires the accounting and reporting to be performed by an outside CPA firm with expertise in accrual basis accounting, cost allocation and grant accounting concepts. During FCE’s monthly financial review, we examine each grant/class level in QB, ensuring that expenses are properly charged to the correct grant in the correct period of performance.

View Audit 323314

Finding 501029 (2023-003)

Significant Deficiency 2023

Suffolk County, New York

NY

Questioned Costs Reporting Cash Management

REFERENCE # 2023-002 OTHER - BASIS OF ACCOUNTING – SIGNIFICANT DEFICIENCY Program WIOA CLUSTER: WIOA ADULT PROGRAM (Assistance Listing Number 17.258) WIOA YOUTH ACTIVITIES – (Assistance Listing Number 17.259) WIOA DISLOCATED WORKER FORMULA GRANTS – (Assistance Listing Number 17.278) Identific...

REFERENCE # 2023-002 OTHER - BASIS OF ACCOUNTING – SIGNIFICANT DEFICIENCY Program WIOA CLUSTER: WIOA ADULT PROGRAM (Assistance Listing Number 17.258) WIOA YOUTH ACTIVITIES – (Assistance Listing Number 17.259) WIOA DISLOCATED WORKER FORMULA GRANTS – (Assistance Listing Number 17.278) Identification Number(s) VARIOUS AND AA-36336-21-55-A-36 Finding The Suffolk County Department of Labor (the “Department”) receives WIOA Adult; Youth and Dislocated Worker Formula Grants from New York State Department of Labor (the “Agency”). The Department reports to the Agency on an accrual basis, as required by the Agency. The County’s Schedule of Expenditures of Federal Awards (the “SEFA”) is presented on the accrual basis of accounting. The Department provides all supporting documents to the Agency for reimbursement. We noted that the Department included expenditures in the amount of $373,855, which were incurred and dated in the prior year. The Department recorded the expenditures and revenue in the 2023 financial statements. These expenditures were also added to the SEFA in calendar year ended December 31, 2023. Questioned Costs Cannot be determined. Recommendation We recommend the Department report expenditures on the SEFA on the accrual basis of accounting, which is the basis the County utilizes for other federal programs. Corrective Action Plan Throughout the year, the Department will regularly reconcile vouchers to ensure that expenditures and associated revenue are reported in the correct year on the SEFA. Two staff members in the department (one as the primary, the other as the alternate) will be assigned the responsibility of tracking the SEFA reconciliation process. When preparing the annual SEFA, the department will reconcile expenditure reports with the expenditures reported on the annual SEFA. During year-end processing, the Department, when entering vouchers into the financial system, will ensure items to be accrued will contain the letter “A” as a prefix to the voucher number. The Department will also check to ensure all items that should be accrued, are in fact accrued prior to year-end closing. In addition, the Department will confirm the date entered in the financial system, reflects the proper year in which the expenditure and associated revenue should be recorded. Action Date This process will commence on September 16, 2024. Final Implementation Date Implementation of this plan will be completed by 2/28/25. We recognize that since this is a continuous improvement process, we will review the success of our implemented procedures on an annual basis. Name And Phone No. Of Person Responsible For Implementation Paul Goerke (primary) 631.853.6606 Yvonne Spreckels (alternate) 631.853.6628

View Audit 323277 Questioned Costs: $1

Finding 501012 (2023-003)

Material Weakness 2023

Umpqua Public Transportation District

OR

Subrecipient Monitoring Cash Management Material Weakness § 200.302

Finding 2023-003 – Fiscal Management System (Material Weakness) Criteria: CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following: Identification, in its accounts, of all Federal awards received and e...

Finding 2023-003 – Fiscal Management System (Material Weakness) Criteria: CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation. The reimbursement reports were to be reviewed by the District Manager prior to submission. Approval of the reimbursement requests and supporting reports by the District Manager were often delayed. Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring timely review of reports and filing of the reimbursement requests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper financial reporting. Lack of timely filing of reimbursement requests could result in overstating accounts receivable balances and critical revenues lost due to cutoff terms of the grant award. Questioned Cost: No Context: Delays in filing reimbursement claims and internal disputes regarding grant reimbursement request procedures were evident. The weak or nonexistent controls over the reimbursement request procedures resulted in lost revenues and delayed recognition of revenue, which required adjustments to correct the financial statements. Repeat of a Prior-Year Finding: Yes, Financial Statement Findings 2022-001 Recommendation: The District should establish a more simplified and effective process for the review and approval of GAAP basis reporting and grant reimbursement requests and grant reporting. As part of this process, supporting general ledger reports and supporting data should be subject to a qualified individual to review and approval on a timely basis. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that process that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledger recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data reports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District

View Audit 323248

Finding 501005 (2023-002)

Significant Deficiency 2023

Umpqua Public Transportation District

OR

Cash Management Subrecipient Monitoring Reporting § 200.302 § 200.328 § 200.329

Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20...

Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation. Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement requests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonexistent controls over the reimbursement request procedures created a potential for inaccurate, incomplete reporting. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that process that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledger recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data reports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District

View Audit 323248

Finding 500955 (2023-010)

Significant Deficiency 2023

Wabanaki Health and Wellness

ME

Reporting Significant Deficiency

2023-010- Significant Deficiency in Internal Control and Non-material Noncompliance – Inaccurate Reporting WPHW understands this finding and has already taken steps to ensure this issue does not happen again. The following process has been put into place to ensure all expenses are appropriately acc...

2023-010- Significant Deficiency in Internal Control and Non-material Noncompliance – Inaccurate Reporting WPHW understands this finding and has already taken steps to ensure this issue does not happen again. The following process has been put into place to ensure all expenses are appropriately accrued into the correct period and ensure that reporting is correct. 1) The Accounting and AR/AP Specialist will review all incoming expenses for a period of 90 days after grant end to determine appropriate grant year for the expense 2) Accounting Manager and Director of Accounting will conduct monthly grant review to ensure all expenses are in the appropriate period 3) Director of Accounting and Director of Grants Management will meet on a monthly basis to review all grants due to close a. Director of Grants Management will review all financial reports to ensure programmatic dates match and expenses are correctly allocated

View Audit 323235

Corrective Action Plans

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