Corrective Action Plans

Finding 404132 (2023-001)

Significant Deficiency 2023

Hias & Council Migration Service of Philadelphia

PA

Reporting Significant Deficiency Internal Control / Segregation of Duties

Management agrees with the finding and has taken corrective action by purchasing and implementing software which will track the employee’s actual time spent. This software was placed in service on October 1, 2023.

View Audit 310920

Finding 404129 (2023-001)

Significant Deficiency 2023

Amskills, Inc.

FL

Reporting Internal Control / Segregation of Duties

Management intends to implement an accounting period closing checklist that addresses the following: Revenue Transactions: Verify that all revenue transactions for the month have been recorded accurately and in accordance with AmSkills revenue recognition policies. Confirm that revenue is recognized...

Management intends to implement an accounting period closing checklist that addresses the following: Revenue Transactions: Verify that all revenue transactions for the month have been recorded accurately and in accordance with AmSkills revenue recognition policies. Confirm that revenue is recognized when it is earned and the criteria for revenue recognition are met. Billing and Invoicing Processes: Ensure that all billings and invoices for services rendered during the month are processed and issued promptly. Review billing records to confirm accuracy and completeness of invoices issued. Expense Recognition: Review expense transactions to ensure they are recorded in the correct period. Verify that expenses incurred during the month are properly recognized and classified according to AmSkills’ accounting policies.Perform Reconciliations and Adjustments: - Conduct reconciliations between financial records and supporting documentation. Identify any discrepancies or variances and make necessary adjustments to ensure financial accuracy.

View Audit 310912

Finding 404123 (2023-002)

Significant Deficiency 2023

Hampton Roads Community Action Program, Inc.

VA

Questioned Costs Allowable Costs / Cost Principles Reporting

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-002 Head Start Cluster- Federal Assistance Listing Number 93.600 - Significant Deficiency in Internal Control over Allowable Costs Recommendation: Internal Controls should be implemented around expense cutoff to ensure all expenses relate to the appropria...

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-002 Head Start Cluster- Federal Assistance Listing Number 93.600 - Significant Deficiency in Internal Control over Allowable Costs Recommendation: Internal Controls should be implemented around expense cutoff to ensure all expenses relate to the appropriate period, or in this case, school year. Action taken: We concur with the recommendation. On May 30, 2024, HRCAP drafted Accounting Policy 3.10 to be reviewed for addition to the Finance Policy Manual. This policy would serve to provide internal control procedures for grant-related transactions in accordance with Generally Accepted Accounting Principles (GAAP). Specifically, it outlines precise year end and cut-off procedures tailored to grant revenue and expenses, emphasizing the critical importance of recording these transactions within the appropriate grant period. Sincerely yours, Audrea Lambert, Chief Financial Officer

View Audit 310907 Questioned Costs: $1

Finding 404118 (2023-003)

Significant Deficiency 2023

Veterans, Inc. and Affiliate

MA

Cash Management Reporting Significant Deficiency

Audit Finding Reference: 2023-003 Internal Controls Over Cash Management and Reporting Planned Corrective Action: Our systems have required review and approvals procedures as described below but the notation of review and approval were not evident. Going forward either through email or sign-off, i...

Audit Finding Reference: 2023-003 Internal Controls Over Cash Management and Reporting Planned Corrective Action: Our systems have required review and approvals procedures as described below but the notation of review and approval were not evident. Going forward either through email or sign-off, it will show approval. a. Cash Drawdowns: i. Currently, all cash drawdowns are prepared by our grant accountant; and reviewed and approved verbally by our grant manager. In addition, all cash drawdowns are reviewed and approved by the national office of the grantor. Going forward, prior to the submission to the national office for approval, the cash drawdowns will be reviewed and approved via email or signature by upper management. b. Financial Reporting: i. Currently, all financial reports (FFR; SF-425; etc.) are prepared by our grant manager, with the assistance of information obtained from our grant accountant from the general ledger. These reports are reviewed and approved verbally by our Vice President of Finance, Development and Administration. In addition, all financial reports are reviewed and approved by the national office of the grantor. Going forward, prior to submitting the reports to the national office for approval, the reports will be reviewed and approved via email or signature by upper management. c. Performance Reporting: i. Performance reports are prepared by the grant lead, and verbally approved by their manager. Managers are copied on the emails to the Federal Office, verifying their approval of the report. Going forward, prior to submitting to the national office for approval, the reports will be reviewed and approved via email or signature by upper management. Planned Implementation Date of Corrective Action: 06/01/2024 Person Responsible for Corrective Action: Vice President – Finance, Development & Administration

View Audit 310900

Finding 404112 (2023-004)

Significant Deficiency 2023

Catholic Charities West Michigan

MI

Reporting Significant Deficiency

Action Taken: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance...

Action Taken: Timely reporting as well as documented approvals are very important to Catholic Charities West Michigan and we agree that we must demonstrate that proper reviews or reports have occurred. We have implemented a process including monthly meetings with the Program Manager and the Finance Accountant to review activity and close the month. All reporting is now filed timely with proper documented review.

View Audit 310898

Finding 404106 (2023-002)

Significant Deficiency 2023

Catholic Charities West Michigan

MI

Reporting Cash Management Significant Deficiency

Action Taken: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will rec...

Action Taken: Modifications of the Administrative Financial Management and Cash Management policies will be made to further address concerns identified in the Single Audit. In addition, the reconciliation process will be reviewed and improved to assure timely preparation of the SEFA. CCWM will reconcile federal programs to the passthrough agencies 9 months into the fiscal year at a minimum as part of the preparation of the SEFA report.

View Audit 310898

Finding 404103 (2023-001)

None 2023

Tufts Medical Center Inc. and Affiliates

MA

Reporting Internal Control / Segregation of Duties

Re: Finding 2023-001 – Lost Revenue Reporting, Corrective Action Plan To whom it may concern: We agree with the auditor’s finding that the Home Health Visiting Nurse Association (VNA) erroneously filed Reporting Period 5 separately from the Tufts Medicine filing, with data inconsistent with the pre...

Re: Finding 2023-001 – Lost Revenue Reporting, Corrective Action Plan To whom it may concern: We agree with the auditor’s finding that the Home Health Visiting Nurse Association (VNA) erroneously filed Reporting Period 5 separately from the Tufts Medicine filing, with data inconsistent with the previous filings and methodologies. Management has implemented controls to ensure access is limited and that the reporting will be communicated and submitted by the Tufts Medicine Corporate Finance team. Management has communicated the matter with HHS and is currently in communications to resolve. Tufts Medicine Finance

View Audit 310888

Finding 404102 (2023-001)

Material Weakness 2023

City of Groveland, Florida

FL

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

The City agrees with the recommendation to strengthen internal controls over grant reporting processes. To enhance accountability and accuracy, grant reports authored by the designated grant recipient, who is the City employee tasked with managing the grant activity, will now undergo a review by som...

The City agrees with the recommendation to strengthen internal controls over grant reporting processes. To enhance accountability and accuracy, grant reports authored by the designated grant recipient, who is the City employee tasked with managing the grant activity, will now undergo a review by someone else in the City independent of the report preparation. This review will focus on ensuring the reports are complete, accurate, and fully compliant with all stipulated grant requirements.

View Audit 310883

Finding 404098 (2023-001)

None 2023

Appalachian School of Law

VA

Reporting

WE CONCUR WITH THE RECOMMENDATION AND IT WAS IMPLEMENTED IMMEDIATELY. THE CONDITION THAT LED TO THE FINDING WAS AN ANOMALY AND NOT EXPECTED TO OCCUR AGAIN.

View Audit 310874

Finding 404097 (2023-001)

Material Weakness 2023

Midland County Hospital District

TX

Questioned Costs Allowable Costs / Cost Principles Reporting

Management agrees with the finding that the Period 4 Provider Relief Fund report included expenses for utility and insurance expenditures that were not directly related to the District's prevention, preparation and/or response to the COVID-19 pandemic. Management reviewed HRSA guidance and examples...

Management agrees with the finding that the Period 4 Provider Relief Fund report included expenses for utility and insurance expenditures that were not directly related to the District's prevention, preparation and/or response to the COVID-19 pandemic. Management reviewed HRSA guidance and examples of allowable expenses prior to completing Period 4 Provider Relief Fund reporting and concluded these expenses were considered allowable as general and administrative expenses incurred during our response to the COVID-19 pandemic. Management notes that expenses and lost revenue reported exceed the amount of PRF funding received even if these expenses were excluded. We have taken corrective action for the review of completeness and accuracy for inclusion of allowable expenditures. PRF reporting, subsequent to this audit, will be reviewed prior to submission to ensure accuracy of reporting. Chief Financial Officer, Marie Castro, is responsible for ensuring the corrective action plan is followed. The corrective action plan will be implemented on June 30, 2024.

View Audit 310873 Questioned Costs: $1

Finding 404072 (2023-012)

Significant Deficiency 2023

Lutheran Social Services of New York, Inc.

NY

Reporting School Nutrition Programs

This has been resolved.

View Audit 310870

Finding 404071 (2023-011)

Significant Deficiency 2023

Lutheran Social Services of New York, Inc.

NY

Reporting

We will review all reporting requirements and ensure that these are recorded, reconciled and analyzed in a timely manner.

View Audit 310870

Finding 404041 (2023-002)

Material Weakness 2023

Sunrise County Economic Council

ME

Reporting Material Weakness § 200.508 § 200.510

We provided the NOAA Award label and CFDA# as soon as we were able to obtain it from the program manager. We corrected the CFDA# for the Highway Planning and Construction as soon as we were able to obtain them from the MEDOT. The contract documents did not include that information. We reported the ...

We provided the NOAA Award label and CFDA# as soon as we were able to obtain it from the program manager. We corrected the CFDA# for the Highway Planning and Construction as soon as we were able to obtain them from the MEDOT. The contract documents did not include that information. We reported the revenue for the State and Local Recovery Funds in the award column. We now know to put the unspent revenue in deferred. We did not know the $310,000 was Federal Funds, we will know for the future. We will be sure to include Covid-19 labels and all the award dates in the future. We will look for training to prepare a SEFA document, it will be on our professional development list in this year.

View Audit 310862

Finding 404007 (2023-003)

Significant Deficiency 2023

Great Lakes Inter-Tribal Council Inc.

WI

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Corrective Actions Taken or Planned: Create procedures by type of required reporting by grantor, as necessary. The procedure will include what and how the required report will be completed, who will and/or should review the required report, including signature for proof, and when the required report...

Corrective Actions Taken or Planned: Create procedures by type of required reporting by grantor, as necessary. The procedure will include what and how the required report will be completed, who will and/or should review the required report, including signature for proof, and when the required report should be completed. Procedures will be added to the accounting department procedures and shared with staff as necessary. Contact person(s) responsible for corrective action: Gina Brown, CFO Anticipated Completion Date: September 2024

View Audit 310846

Finding 403965 (2023-003)

Significant Deficiency 2023

Disability Rights Washington

WA

Reporting Allowable Costs / Cost Principles Significant Deficiency § 200.328

Corrective Action: As part of DRW’s internal control revision, we will enhance policies and practices associated with reporting including the semi-annual SF-425. Steps: 1. DRW will review current systems and tools in use for reporting and complying with Federal award reporting requirements and modif...

Corrective Action: As part of DRW’s internal control revision, we will enhance policies and practices associated with reporting including the semi-annual SF-425. Steps: 1. DRW will review current systems and tools in use for reporting and complying with Federal award reporting requirements and modify or implement systems or tools that are more reliably accurate than current systems and tools. 2. DRW will implement internal controls that require the preparation and review of federal reporting requirements by two distinct people at DRW. 3. DRW will implement a reporting calendar and review regularly to ensure activities including preparation and review are being performed regularly and consistently. Anticipated completion September 30, 2024.

View Audit 310821

Finding 403910 (2023-001)

Significant Deficiency 2023

Maverick County, Texas

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties

Date: June 21, 2024 Finding 2023-001: Performance Reporting Federal Program: CLFR American Rescue Plan ALN 21.027 Federal Agency: U.S. Department of Treasury Federal Award Year: 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Raul Trevino: The Count...

Date: June 21, 2024 Finding 2023-001: Performance Reporting Federal Program: CLFR American Rescue Plan ALN 21.027 Federal Agency: U.S. Department of Treasury Federal Award Year: 2021 Type of Finding: Significant Deficiency in Internal Control over Compliance and Noncompliance Raul Trevino: The County has experienced a rotation of County Auditor position for the past 6 years, within 2-year term each. Unfortunately, the American Rescue Plan Act (ARPA) was 100% handled by former County Auditor Sonia Junfin. The reporting submission was affected due to her resignation, but only for the quarter ending 12/31/2022. Corrective Actions: • Designate Access: During the 2nd Quarter of Fiscal Year 2023, the County ensured that not only the Auditor has access, at least one Assistant County auditor has access to the required information and system for report submission. • Cross-Training Program: During the 2nd Quarter of Fiscal Year 2023, the County implemented a comprehensive cross-training program to ensure all designated employees had a thorough understanding of reporting guidelines and procedures. • Designated Responsibility: During the 2nd Quarter of Fiscal Year 2023, the County designated specific individuals to be responsible of overseeing report submission deadlines to ensure compliance. Additionally, the County established clear communication channels for reporting deadlines and responsibilities to designated staff members. By following this plan, the County has addressed the issue of delayed report submissions and ensured smoother operations despite turnover in staff. Date corrective action plan was implemented: February 02, 2023.

View Audit 310796

Finding 403872 (2023-004)

None 2023

Palm Beach County Board of County Commissioners

FL

Reporting Special Tests & Provisions

The department has an internal process in place requiring the timely review and submittal of grant reports. This policy has been reviewed with staff and Management has counseled staff regarding the submission time frames and will take necessary measures to ensure review, signoff and timely submissi...

The department has an internal process in place requiring the timely review and submittal of grant reports. This policy has been reviewed with staff and Management has counseled staff regarding the submission time frames and will take necessary measures to ensure review, signoff and timely submission of quarterly Cash on Hand Reporting.

View Audit 310753

Finding 403862 (2023-002)

Significant Deficiency 2023

Palm Beach County Board of County Commissioners

FL

Reporting Internal Control / Segregation of Duties

The department has an internal process in place requiring the review and signature by Finance Director prior to the submission of quarterly report. This policy has been reviewed with staff and Management has counseled staff regarding the submission time frames and will take necessary measures to ens...

The department has an internal process in place requiring the review and signature by Finance Director prior to the submission of quarterly report. This policy has been reviewed with staff and Management has counseled staff regarding the submission time frames and will take necessary measures to ensure review, signoff and timely submission of quarterly Cash on Hand Reporting.

View Audit 310753

Finding 403856 (2023-005)

Significant Deficiency 2023

Palm Beach County Housing Authority

FL

HUD Housing Programs Reporting Significant Deficiency

Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority implement processes to ensure HUD-50058 submissions are completed in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Acti...

Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority implement processes to ensure HUD-50058 submissions are completed in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Beginning in March 2023, the PBCHA implemented the completion of all reexaminations within its Yardi resident portal. Reexaminations within Yardi provide online workflows that maximize efficiency, streamline compliance, reduce errors and increase reporting accuracy. The PBCHA will implement processes to ensure that HUD 50058 submissions are uploaded in accordance with HUD regulations. The PBCHA will utilize available dashboards and reports to improve monitoring and oversight to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Cheryl Lewis Planned completion date for corrective action plan: 12/31/2024

View Audit 310743

Finding 403844 (2023-001)

Material Weakness 2023

Palm Beach County Housing Authority

FL

HUD Housing Programs Subrecipient Monitoring Eligibility

Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit ...

Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and unit the compliance deficiencies have been corrected. We recommend the Authority to hire outside consultants to assist with eligibility determination and verification or increase staffing in this area. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Beginning in March 2023, the PBCHA implemented the completion of all reexaminations within its Yardi resident portal. Reexaminations within Yardi provide online workflows that maximize efficiency, streamline compliance, reduce errors and increase reporting accuracy. The PBCHA will utilize available dashboards and reports to improve monitoring and oversight to ensure compliance. Name(s) of the contact person(s) responsible for corrective action: Cheryl Lewis Planned completion date for corrective action plan: 12/31/2024

View Audit 310743

Finding 403814 (2023-005)

Significant Deficiency 2023

Institute for Sustainable Communities, Affiliate and Subsidiary

VT

Reporting Cash Management Significant Deficiency

Management agrees with the recommendations. We are revising the Financial Management policies and procedures to ensure that the separation of duties is clear, and the report preparation and review process complies with this recommendation.

View Audit 310730

Finding 403701 (2023-001)

Significant Deficiency 2023

Washington City Orphan Asylum Dba Hillcrest Children's Center

DC

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.430

We acknowledge the findings from the audit of our federal grants award, specifically the insufficient documentation of time and effort for one of our employees. We understand the importance of adhering to 2 CFR part 200.430 of the Uniform Guidance and regret any discrepancies that occurred. The sing...

We acknowledge the findings from the audit of our federal grants award, specifically the insufficient documentation of time and effort for one of our employees. We understand the importance of adhering to 2 CFR part 200.430 of the Uniform Guidance and regret any discrepancies that occurred. The single discrepancy noted related to a new employee that was hired for the federal grant a month and half before the end of the grant year. The variance resulted from an inadvertent payroll coding error in the payroll system, where the employee’s time and effort for the grant was miscoded. We appreciate the opportunity to address this finding and are committed to preventing its recurrence. Below, please find the detailed corrective action plan with timelines and responsible parties. Corrective Action Plan 1 Review and Correction: - We wish to assure you that this was an isolated incident resulting from a clerical oversight. As soon as the discrepancy was brought to our attention, corrective measures were promptly taken. The incorrect coding has been rectified in the payroll system. - Further, we have reviewed the documentation for the employee in question to established that the employee subsequent records accurately reflected the time and effort spent on the federal program. 2 Policy Review and Update: - We have reviewed our time and effort documentation procedures to ensure they align with federal requirements and would consistently lead to a fair and accurate time and effort allocation. - We noted that our current policy and procedures are adequate but can be strengthened further by a more effective supervisory review of time sheets for each employee assigned to a federal grant. - Nevertheless, all changes in policies and procedures that result in our continuous review will be documented and communicated to relevant personnel. - Updated procedures will be incorporated into our organizational handbook and made accessible to all staff members. - Further, we will ensure federal program managers are aware of any changes in regulations or requirements. This proactive approach will help us stay updated and adjust our procedures accordingly. 3 Staff Training: - We will, additionally, require all staff involved in federal grants to undergo quarterly training to reinforce the importance of accurate time and effort reporting. This training will cover the proper use of our time reporting system and the necessity of aligning it with accounting records. Our training sessions will cover the requirements of 2 CFR part 200.430 and the specific procedures that must be followed to maintain compliance. 4 Enhanced Oversight and Monitoring: - A system of regular internal audits will be established to monitor the compliance of time and effort documentation. - These audits will be conducted quarterly, and any discrepancies will be promptly addressed to ensure continuous compliance. 5 Continuous Improvement: - We commit to continuously improving our processes and controls related to federal grant management. This will include seeking feedback from our staff and auditors to identify areas for further enhancement. We believe that these corrective actions address the identified deficiency and goes beyond with additional effort to enhance our compliance environment. As a company, we are committed to maintaining the highest standards of accuracy and accountability to manage our federal funds.

View Audit 310722

Finding 403693 (2023-001)

Significant Deficiency 2023

Town of Preston

CT

Cash Management Reporting School Nutrition Programs

FINDING 2023-001 – Significant Deficiency in Internal Control over Compliance – Reporting Description of Finding: Controls should be in place to ensure the accuracy of reporting submitted for federal awards programs with proper supporting documentation to agree to the reports being submitted to the ...

FINDING 2023-001 – Significant Deficiency in Internal Control over Compliance – Reporting Description of Finding: Controls should be in place to ensure the accuracy of reporting submitted for federal awards programs with proper supporting documentation to agree to the reports being submitted to the Department of Education. As part of the recordkeeping process, each month’s claim for reimbursement and all data used in the claims review process must be maintained on file. Of the eleven monthly claims reports reviewed during the audit, the supporting documentation for one of the claims (April 2023) could not be located. Statement of Concurrence or Nonconcurrence: The Town agrees with this finding. Corrective Action: The Town agrees with the finding and has implemented internal controls to ensure the supporting documentation for each monthly claim are filed and maintained. Each month the monthly claims reports and supporting documentation will be filed away in a designated secure location with a checklist by month to confirm processing. Name of Contact Person: Cynthia Varricchio, MBA, Director of Finance and School Business Operations. Projected Completion Date: June 30, 2024

View Audit 310692

Finding 403650 (2023-002)

Significant Deficiency 2023

Bscs Science Learning

CO

Reporting

BSCS Science Learning agrees with the finding and recommendation. Staff training occurred before the time of issuance of this report. BSCS Science Learning will train new hires on procedures for preparing supporting detail to support the total expenditures that are reported on the SEFA to ensure the...

BSCS Science Learning agrees with the finding and recommendation. Staff training occurred before the time of issuance of this report. BSCS Science Learning will train new hires on procedures for preparing supporting detail to support the total expenditures that are reported on the SEFA to ensure the support generated is complete and accurate for submission with the SEFA for audit.

View Audit 310688

Finding 403649 (2023-001)

Significant Deficiency 2023

Bscs Science Learning

CO

Subrecipient Monitoring Reporting

BSCS Science Learning agrees with the finding and recommendation. Staff training occurred before the time of issuance of this report. BSCS Science Learning will segregate subaward and subcontract accounts in the accounting system to allow the SEFA to be generated accurately from the accounting syste...

BSCS Science Learning agrees with the finding and recommendation. Staff training occurred before the time of issuance of this report. BSCS Science Learning will segregate subaward and subcontract accounts in the accounting system to allow the SEFA to be generated accurately from the accounting system.

View Audit 310688

Corrective Action Plans

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