Corrective Action Plans

Finding 370814 (2021-002)

Significant Deficiency 2021

AL

Allowable Costs / Cost Principles Reporting

Description of Finding Significant weakness in allocation of administrative costs for financial reporting. In the past, DCSOS has elected to use the 10% de minimis allocation for indirect administrative costs for all Federal grants. For State funded grants, administrative costs were a part of the ...

Description of Finding Significant weakness in allocation of administrative costs for financial reporting. In the past, DCSOS has elected to use the 10% de minimis allocation for indirect administrative costs for all Federal grants. For State funded grants, administrative costs were a part of the budget where possible. As the organization has grown quickly in the past 3 years, a systematic process to allocate costs has not been developed and consequently, during the audit process, there was not an ‘explainable allocation’ method to review. DCSOS agrees with this audit finding. Statement of Concurrence or Nonconcurrence: Due to the rapid growth of the organization and limited staffing, a method of calculating and allocating indirect (administrative) costs has not been developed. It is noted through the audit that the absence of following the Uniform Guidance (2 CFR200) could distort the cost to run each program. Therefore, DCSOS agrees with the audit finding. Corrective Action: For the future grant application process, DCSOS will develop a formal method of allocating indirect costs to each program using an explainable method. This process will be implemented in the future grant year 2025. Proposed Completion Date: September 30, 2024 Person Responsible for Corrective Action: Financial Officer

View Audit 292503

Finding 370813 (2021-001)

Significant Deficiency 2021

Dallas County System of Services, Inc.

AL

Reporting Internal Control / Segregation of Duties § 200.512

Description of Finding: Significant weakness in internal control over financials reporting, other matters. A single audit was not filed within 9 months after the year end. In addition, an annual audited financial statement was not filed within the required timeframe, including extensions, 2 CFR 20...

Description of Finding: Significant weakness in internal control over financials reporting, other matters. A single audit was not filed within 9 months after the year end. In addition, an annual audited financial statement was not filed within the required timeframe, including extensions, 2 CFR 200.512. Statement of Concurrence or Nonconcurrence: As a part of the recovery from the pandemic, new programs were added to the DCSOS menu of services. In 2021 it included a new federally funded program which brought the collective total of federal funds to over the $750,000 threshold. Due to covid setbacks in preparing the annual audit, management was unaware of the requirements of a single audit. Therefore, DCSOS agrees with the audit finding. Corrective Action: The DCSOS has hired additional staff in the finance office and prepared a plan to ensure the filing of the 2022- and 2023-year end statements will be prepared and filed prior to the September 30th, 2024 deadline. With a new work plan in place, subsequent year filings for single audits will comply with the single audit filing deadlines. Proposed Completion Date: Immediately Person Responsible for Corrective Action: Financial Officer

View Audit 292503

Finding 370794 (2021-003)

Significant Deficiency 2021

353-365 Housing Development Fund Company, Inc.

NY

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

a. Recommendation: The Company should design their internal controls to ensure that the calculation of surplus cash is reviewed and performed timely, to ensure they will comply with HUD guidelines. b. Action(s) Taken/Planned: Management has acknowledged a breach in protocol and deposited the current...

a. Recommendation: The Company should design their internal controls to ensure that the calculation of surplus cash is reviewed and performed timely, to ensure they will comply with HUD guidelines. b. Action(s) Taken/Planned: Management has acknowledged a breach in protocol and deposited the current year's surplus cash on October 1, 2021.

View Audit 292473

Finding 370586 (2021-009)

Material Weakness 2021

Kickapoo Tribe in Kansas

KS

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2021-009 Reporting Individual(s) Responsible: Grace Ross, Tribal Treasurer, Tribal Administrator Action: Reviewing reporting requirements with department heads and reviewing reports submitted. Anticipated Completion Date: April 2024

View Audit 292271

Finding 370583 (2021-010)

Material Weakness 2021

Kickapoo Tribe in Kansas

KS

Procurement, Suspension & Debarment Cash Management Material Weakness

Finding 2021-010 Special Tests and Provisions Individual(s) Responsible: Grace Ross, Tribal Treasurer, Program Directors Action: Be able to provide documentation to show that federal funds were fully protected and insured. Review annual and quarterly reporting to ensure timely filing. Antici...

Finding 2021-010 Special Tests and Provisions Individual(s) Responsible: Grace Ross, Tribal Treasurer, Program Directors Action: Be able to provide documentation to show that federal funds were fully protected and insured. Review annual and quarterly reporting to ensure timely filing. Anticipated Completion Date: April 2024

View Audit 292271

Finding 370197 (2021-001)

Significant Deficiency 2021

Envision Community Services INC

IL

Reporting Internal Control / Segregation of Duties

We will have our current accountant set a schedule for performing monthly closes of the financial statements so they can be presented in summary format to management and the board of directors. We will require that the President/CEO and other key members of the management team and the board of direc...

We will have our current accountant set a schedule for performing monthly closes of the financial statements so they can be presented in summary format to management and the board of directors. We will require that the President/CEO and other key members of the management team and the board of directors review the monthly financial reports provided by the accountant so that all board members understand the financial position and results of activities of ECS on a regular and consistent basis. Finally, we will develop a transition plan with procedures requiring that whomever is responsible for the accounting and financial reporting function for ECS reconcile all financial accounts and close the financial records for the month prior to departure to ensure a smooth transition ECS’s accounting and financial reporting function to the next person responsible for its maintenance

View Audit 291773

Finding 370162 (2021-002)

Material Weakness 2021

Jewish Federation of Metropolitan Detroit

MI

Reporting Material Weakness § 200.502 § 200.510

Finding Number: 2021-002 Condition: Controls in place were not sufficient to ensure the accuracy and completeness of the SEFA. Planned Corrective Action: In order to assure the accurate classification of federal grant expenditures, the Federation staff implemented the following controls as part of t...

Finding Number: 2021-002 Condition: Controls in place were not sufficient to ensure the accuracy and completeness of the SEFA. Planned Corrective Action: In order to assure the accurate classification of federal grant expenditures, the Federation staff implemented the following controls as part of their accounting review process: 1) The Senior Accountant responsible for grant accounting and the Senior Director of Finance will perform a complete review of all grant agreements, to determine whether the grants are funded with federal or state funds. 2) The quarterly workpapers will include a copy of the signed grant agreement, a current SEFA schedule, and a general ledger that correctly corresponds to the totals included on the included SEFA. 3) The staff will perform a quarterly review of the State of Michigan website (Michigan.gov/MDHHS) to confirm the funding sources of all existing grants. Contact person responsible for corrective action: Rebecca Stasch, Senior Director of Finance Anticipated Completion Date: 05/31/2023

View Audit 291682

Finding 370138 (2021-001)

Significant Deficiency 2021

Thru Guidance Ministries, Inc.

CA

Reporting

Adequate policies and procedures are to be put in place to ensure timeliness of data requested and will be implemented to ensure future audits are in compliance with the Uniform Guidance timeline beginning after December 31, 2022.

View Audit 291673

Finding 370124 (2021-004)

Material Weakness 2021

Calhoun Liberty Hospital Association INC

FL

Questioned Costs Cash Management Reporting

Material Weakness 2021-004 Actions by Management: Management agrees with the finding as stated and the additional actions that will be taken by the Hospital will endeavor to utilize all grant funds prudently, comply with federal statues, and regulations. The Hospital will implement internal controls...

Material Weakness 2021-004 Actions by Management: Management agrees with the finding as stated and the additional actions that will be taken by the Hospital will endeavor to utilize all grant funds prudently, comply with federal statues, and regulations. The Hospital will implement internal controls and account management requirements.

View Audit 291645 Questioned Costs: $1

Finding 370055 (2021-010)

Material Weakness 2021

Delaware County

OK

Reporting Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.502 § 200.510 § 200.514

The BOCC will work to design and implement internal controls to ensure accurate reporting of federal expenditures on the Schedule of Federal Awards (SEFA) and ensure compliance with federal requirements.

View Audit 291562

Finding 369837 (2021-002)

Material Weakness 2021

Trinity Community Housing CORP

IL

HUD Housing Programs Reporting

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that full accrual-based accounting is performed. Responsible party: Ken Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291369

Finding 369815 (2021-002)

Material Weakness 2021

Trinity Acres Housing Corporation

IL

HUD Housing Programs Reporting

Corrective Action Plan: The Corporation plans has hired a management agent company that will ensure that full accrual-based accounting is performed. Responsible party: Ken Dickerson, Chairman Planned completion date for corrective action plan: Already remediated.

View Audit 291368

Finding 369635 (2021-001)

Significant Deficiency 2021

Mobile Housing Authority

AL

Internal Control / Segregation of Duties HUD Housing Programs Reporting

Management has reviewed its staffing needs and end of year complexities and requirements necessary to report U.S. GAAP basis financial statements. Management has hired additional staff that possess the necessary accounting and reporting skills and experience to assist with interim reporting, end of ...

Management has reviewed its staffing needs and end of year complexities and requirements necessary to report U.S. GAAP basis financial statements. Management has hired additional staff that possess the necessary accounting and reporting skills and experience to assist with interim reporting, end of year close, reconciliations of all significant account balances, and strengthening the internal controls over financial reporting including amounts reported in the financial data schedule. In addition to these action steps, we will get started earlier in conducting our end of year reconciliations and enhance our over-sight so we can better monitor and evaluate our readiness to report our financial statements in compliance with 24 CFR Section 5.801. Responsible Person: Jeffery J. Bennett, Chief Financial Officer Projected Completion Date: June 30, 2023

View Audit 291023

Finding 369487 (2021-004)

Significant Deficiency 2021

Ka Mana O Na Helu

HI

Procurement, Suspension & Debarment Reporting Matching / Level of Effort / Earmarking § 200.512 § 200.514

View of Responsible Officials and Planned Corretive Action Responsible Party: Executive Director The single audit requirement was new to KMNH as a result of ESG CV funding. KMNH completed the procurement process as required by HUD, but did not receive any response from qualified service providers de...

View of Responsible Officials and Planned Corretive Action Responsible Party: Executive Director The single audit requirement was new to KMNH as a result of ESG CV funding. KMNH completed the procurement process as required by HUD, but did not receive any response from qualified service providers despite proactive outreach on our part. We were informed that many of the audit firms were overwhelmed by the need to complete audits due to the increased level of federal funding due to COVID. KMNH has since been able to secure an audit firm to complete the audit after the stipulated due date. The same audit firm has been engaged to complete our audit for year ended December 31, 2022. The benefit to using the same audit firm is that their understanding of KMNH’s financial reporting and grant compliance processes learned during the 2021 audit should contribute to an expeditious 2022 audit. KMNH will work diligently with the audit firm with the goal of completing the audit as soon as possible.

View Audit 290718

Finding 369391 (2021-003)

Material Weakness 2021

So Consortium

OH

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.414 § 200.502 § 200.510

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track ...

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

View Audit 290596

Finding 369353 (2021-003)

Material Weakness 2021

Legacy Senior Services

MN

Material Weakness Reporting Internal Control / Segregation of Duties § 200.303

Finding Summary: The Organization selected option ii to calculate lost revenue which consists of a comparison of actual results during the period of availability to the approved budget. The Organization did not have a budget for the entire reporting period that was approved prior to March 27, 2020. ...

Finding Summary: The Organization selected option ii to calculate lost revenue which consists of a comparison of actual results during the period of availability to the approved budget. The Organization did not have a budget for the entire reporting period that was approved prior to March 27, 2020. Responsible Individuals: Stephanie Schmidt, Director, Financial Planning & Analysis Corrective Action Plan: The organization thought it was calculating lost revenue appropriately and later realized the budget needed to be approved prior March 27, 2020. The lost revenue calculation was revised to Option i in Period 4 reporting. Anticipated Completion Date: March 2023

View Audit 290581

Finding 369352 (2021-002)

Significant Deficiency 2021

Legacy Senior Services

MN

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Finding Summary: The Organization’s final expenditure listing and lost revenue identified as eligible and claimed under the Provider Relief Fund program did not have documented review and approval by a separate individual outside of the preparer. In addition, the Organization’s special reports submi...

Finding Summary: The Organization’s final expenditure listing and lost revenue identified as eligible and claimed under the Provider Relief Fund program did not have documented review and approval by a separate individual outside of the preparer. In addition, the Organization’s special reports submitted to the Department of Health and Human Services (HHS) for Period 1 and Period 2 were not reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Stephanie Schmidt, Director, Financial Planning & Analysis Corrective Action Plan: When summarizing eligible costs and lost revenue for submission, a secondary review of the summary spreadsheet prepared from the underlying supporting expense records will be documented. Before reports are submitted to the federal agency, documented approval of this submission will be acquired. Anticipated Completion Date: 2/1/2024

View Audit 290581

Finding 369290 (2021-025)

None 2021

Saint Augustine's University

NC

Student Financial Aid Eligibility Internal Control / Segregation of Duties

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an auto...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The University contracted with Inceptia on 2/5/2020, and Inceptia started completing verification for SAU on 2/18/2020. Inceptia' s Verification Gateway platform provides an automated solution to gather information and documentation required for Financial Aid Verification. Inceptia uses innovative technology to apply progressive rules for automatically or manually approving verification. Furthermore, it provides efficient and effective processes to help institutions remain compliant by organizing documents, streamlining award packaging, and allowing staff to manage the verification process. It provides the institution with the internal controls it needs over its Title IV funding. The Financial Aid Staff also can manually verify students if needed. With Colleague and Inceptia, SAU now has a more unified operating system for systematic processes. If a student has been flagged for verification, Colleague will not allow staff to award the student financial aid. One of the award eligibility rules is "Verification Complete." If students fail to pass this rule, they will not be awarded financial aid. Colleague gives the Financial Aid Staff greater control over the disbursal of Title IV funds and prevents the FAO from disbursing aid to students who are ineligible to receive it. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369287 (2021-022)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved. The financial aid and ...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships; Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved. The financial aid and business offices are directly involved with the COD processes weekly. This process sends originations and disbursement information for PELL and Federal loans to COD. Funds are transmitted to a student’s account through a two-part process called FATR between the two offices. With the implementation of Colleague, we have resolved those issues. Colleague's Financial Aid module provides the tools necessary to maintain, track, process, and report information associated with financial aid applicants and recipients to Colleague. The Financial Aid module helps manage the processing of financial aid, data, and reporting and will give SAU internal controls over their Title IV Student Financial Aid programs. Using this system, SAU can create and modify Grant records for submission to COD and import and reconcile Grant data. The financial aid office did not have these options in CAMS. The financial aid office no longer builds and or disburses aid manually in COD. Colleague and COD work together. The reconciliation process for Pell and Direct Loans to self-audit, ensuring the accuracy and validity of financial data sent and submitted to COD. The reconciliation process in completed monthly and any discrepancies are resolved prior to the next month. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369285 (2021-020)

None 2021

Saint Augustine's University

NC

Student Financial Aid Eligibility Reporting

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolve...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: The financial aid department has developed a Direct Loan workflow process in accordance with federal guidelines. With the implementation of Colleague, this issue has been resolved. Utilizing Colleague's software, the financial aid office can now accurately assess our students' aid eligibility to ensure they are appropriately awarded. Colleague has Award Eligibility Criteria (AEC) rules invoked at transmittal to determine if the student is eligible to receive loan funds. Items this rule checks for include half-time enrollment, completion of Entrance Interview, Satisfactory Academic Progress, etc. AEC is primarily used as a criterion a student must pass before aid can be transmitted to Accounts Receivable. There are two sets of rules on the AEC form: Eligibility Criteria for Awarding and Eligibility Criteria for Transmitting. These rules monitor students' aggregate loan limits, SAP, as defined by Uniform Guidance rules and requirements for federal awards, and provide SAU with the internal controls needed for their Title IV program. The Financial Aid Director follows Ellucian Colleague’s best practice recommendations. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369278 (2021-024)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Subrecipient Monitoring Cash Management

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run throug...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run through Colleague's CODE (Common Originators Disbursement Ellucian) system, which is used to send origination requests and disbursement information for Pell and Federal loans to COD. Funds are transmitted to a student's account through a two-part process run between the Financial Aid Office (FAO) and the Business Office. The Finanical Aid Office is responsible for sending loan originations and disbursments to COD within 15 days. The data extraction process will be more consistent using the workflows provided by the new ERP system. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369276 (2021-019)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Special Tests & Provisions Reporting

Name of Responsible Individual: Rita Archer, University Registrar, Office of the Registrar Corrective Action: Enrollment reporting is required for all schools participating in Title IV aid programs. Schools are required to certify enrollment for all students included on their roster files. SAU was ...

Name of Responsible Individual: Rita Archer, University Registrar, Office of the Registrar Corrective Action: Enrollment reporting is required for all schools participating in Title IV aid programs. Schools are required to certify enrollment for all students included on their roster files. SAU was without a Registrar during the 2019-2020 award year however, in August 2020 this position was filled. In addition more staff was hired to assist in these reporting functions. The Registrar had to submit the missing reports before submitting new ones. This backlog led to late status changes being reported. Primarily, the University implemented a comprehensive ERP software tool, Ellucian Colleague in FY2021 and FY2022 and hired more staff. The built-in internal control structure which includes access to enrollment reports and data coupled with a complete reconciliation process with the Office of Financial Aid, Office of the Registrar and Student Accounts will prevent this from recurring. Professional development is encouraged for the University’s staff to stay current on compliance, regulatory and legal guidelines and adopt industry best practices. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369246 (2021-017)

Material Weakness 2021

Saint Augustine's University

NC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: Given the challenges that current management faced in regard to the lack of proper accounting, document retention and internal controls over financial reporting that took...

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: Given the challenges that current management faced in regard to the lack of proper accounting, document retention and internal controls over financial reporting that took place during fiscal year 2021, there were significant delays in the audit. With the implementation of the new ERP system and new internal policies being put in place this should keep future delays at a minimum. New policies and procedures are being developed to ensure the timeliness of documentation to meet required deadlines. Anticipated Completion Date: June 30, 2024

View Audit 290538

Finding 369245 (2021-016)

Material Weakness 2021

Saint Augustine's University

NC

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: The enhanced internal controls and policies and procedures now in place over the financial reporting process will aid current management in the accurate and timely compl...

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: The enhanced internal controls and policies and procedures now in place over the financial reporting process will aid current management in the accurate and timely completion of the Schedule of Expenditures of Federal Awards (SEFA). Additionally, current management has reviewed the reporting requirements for the SEFA and going forward, grant setup procedures will include a checklist that will identify the correct federal grant name (and cluster, if applicable), assistance listing number and total expenditure amount per program to ensure accuracy in reporting on the SEFA. Additionally, further review will be conducted by the Controller and Vice President of Finance to ensure accuracy. Anticipated Completion Date: June 30, 2024

View Audit 290538

Finding 369028 (2021-001)

Material Weakness 2021

St. Clair County Head Start Program, Inc.

AL

Reporting

Finding: During the course of the audit, we noted the Federal Financial Report, SF 425, we noted that cash receipts reported on lines 10.a and cash disbursements reported on lines 10.b, did not agree to the actual cash received and cash disbursed per the financial records. Cash receipts were underst...

Finding: During the course of the audit, we noted the Federal Financial Report, SF 425, we noted that cash receipts reported on lines 10.a and cash disbursements reported on lines 10.b, did not agree to the actual cash received and cash disbursed per the financial records. Cash receipts were understated by $99,286 and cash disbursements were understated by $99,286. Management was not able to correct the report after the report was submitted electronically in the Department of Health and Human Services Payment Management System (PMS). Corrective Actions Taken or Planned: The Organization strives to engage employees who possess industry knowledge and expertise and is in the process of hiring a new and qualified Executive Director and Chief Financial Officer. Under new leadership, improvement in the financial reporting process will be a priority. Currently, the Board of Directors is actively involved in managing the Organization and provides guidance and oversight of the financial reporting process. Contact person responsible for the corrective action: Thelma Jones, President of the Board Anticipated completion date: The Board of Directors is actively involved in managing the Organization and searching for a new Executive Director. Once the Executive Director is in place, the search will begin for a new Chief Financial Officer.

View Audit 290449

Corrective Action Plans

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