Corrective Action Plans

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Finding No.: 2021-014 AL Program: 93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Area: Reporting Questioned Costs: $0 Contact Person(s): Program Manager and Director of DGFI Corrective Action Plan: CHCC agrees with the Findings an...
Finding No.: 2021-014 AL Program: 93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response Area: Reporting Questioned Costs: $0 Contact Person(s): Program Manager and Director of DGFI Corrective Action Plan: CHCC agrees with the Findings and will establish a stringent records retention policy, even for reports that were electronically completed and submitted using Grantor portals. These fiscal reports were done on the RedCap before 2023 and were readily accessible, hence ELC Program Staff did not maintain separate offline copies of the reports. When ELC transitioned to ELC CAMP, we lost access to the submitted and saved reports. Hence, we cannot provide supporting documents to our assertion that all reports have been submitted. Responsible Official: Program Administrator, Director of DGFI and Chief Financial Officer Proposed Completion Date: On-going
Finding No.: 2021-009 AL Program: 93.268 Immunization Cooperative Agreement Area: Special Tests and Provision – Record of Immunization Questioned Costs: -0- Contact Person(s): Program Administrator, Program Manager Corrective Action Plan: Since 2020, the CHCC has conducted the following steps to ens...
Finding No.: 2021-009 AL Program: 93.268 Immunization Cooperative Agreement Area: Special Tests and Provision – Record of Immunization Questioned Costs: -0- Contact Person(s): Program Administrator, Program Manager Corrective Action Plan: Since 2020, the CHCC has conducted the following steps to ensure that annual site visits for VFC providers are completed and documented appropriately to evaluate adherence to the VFC program requirements: - Worked with CDC Subject Matter Experts to ensure that data systems for site visit findings/reporting were accessible to the VFC Coordinator. Training on the system was also provided to the VFC Coordinator. This system is cloud based and accessible to anyone provided access. Therefore, should staff turnover occur, access to prior reports and the system for submitting new site visit reports will continue to be accessible to the organization and to team members who will take on the responsibility. - Ensure that Position Descriptions for the VFC Coordinator clearly specify responsibilities for implementing the VFC Program in accordance with the VFC Operations Guide, which outlines the requirements for annual provider compliance site visits, including the sampling of patient records to verify eligibility screening and administration of VFC vaccine only to eligible children. - Provided training/refresher to the staff member assigned/responsible (VFC Coordinator) for conducting site visits - Timeliness and completeness of site visit entries have been incorporated as part of the program’s activity workplan. Site visits were suspended per the CDC Project Officer during that time period due to the COVID-19 response. E-mail communication from the CDC Project Officer is attached. The Program continued to continuously monitor VFC Providers were maintaining proper storage of vaccines and verify that information on vaccination records was maintained by each VFC Provider despite not conducting a formal site visit. Responsible Official: Program Manager, Program Administrator, and Director of Public Health Services Proposed Completion Date: On-going
Finding No.: 2021-008 AL Program: 93.268 Immunization Cooperative Agreement Area: Special Tests and Provision Control, Accountability and Safeguarding of Vaccine Questioned Costs: -0- Contact Person(s): Program Manager Corrective Action Plan: CHCC concurs with the finding. To address this finding, t...
Finding No.: 2021-008 AL Program: 93.268 Immunization Cooperative Agreement Area: Special Tests and Provision Control, Accountability and Safeguarding of Vaccine Questioned Costs: -0- Contact Person(s): Program Manager Corrective Action Plan: CHCC concurs with the finding. To address this finding, the Immunization Program conducts the following reconciliation of vaccination records as follows: Vaccination records: daily entries of vaccination records are captured through the patient encounter form for all providers administering vaccinations. Data Entry Assistants and Program Assistants are responsible for entering the vaccinations based on the form. The Immunization Information Systems (IIS) team are responsible for ensuring data quality elements are complete on the form and reflected on the WebIZ system. Patient screening forms: also known as the patient encounter form is the paper-based document in which patient demographics and vaccination data elements are recorded upon visit for all providers. Data Entry Assistant and Program Assistant capture demographic and input vaccines an individual is to receive for the visit. The vaccinator then inputs vaccination data elements (lot number, manufacturer, site, route, etc.) to be inputted into the registry, WebIZ. Temperature log: utilized to document the vaccine storage unit temperature based on the thermometer reading and logged at the start and end of each workday, as well as after hours and weekends/holidays. The VFC Coordinator and Security team logs the temperatures on a daily, routine basis. Vaccine inventory: monitored weekly by the Logistics Technician via spreadsheet and tracked using the registry WebIZ for overall vaccine inventory management. Inventory is reported to CDC by the Program Manager every 14 days. Vaccine wastage from all providers is submitted to the program at the first week of each month for the previous month reporting period. Overall wastage reporting is done monthly to CDC. A summary report of FY2021 vaccine transactions on the CNMI Immunization Registry, WebIZ was submitted via spreadsheet format under, “Vaccine Inventory Reports” Additionally, the CHCC has conducted the following steps to strengthen that annual site visits for VFC providers are completed and documented appropriately to evaluate adherence to the VFC program requirements: - Provided training to the staff member assigned/responsible (VFC Coordinator) for conducting site visits - Worked with CDC Subject Matter Experts to ensure that data systems for site visit findings/reporting were accessible to the VFC Coordinator. Training on the system was also provided to the VFC Coordinator. This system is cloud based and accessible to anyone provided access. Therefore, should staff turnover occur, access to prior reports and the system for submitting new site visit reports will continue to be accessible to the organization and to team members who will take on the responsibility. - Ensure that Position Description for the VFC Coordinator clearly specify responsibilities for implementing the VFC Program in accordance with VFC Operations Guide, which outlines the requirements for annual provider compliance site visits, including the sampling of patient records to verify eligibility screening and administration of VFC vaccine only to eligible children. - Entries of vaccine reconciliation documentation such as vaccine inventory (orders, transfers, and wastages) are accessible on the registry, CNMI WebIZ, as well as routine reporting to CDC VtrckS Site visits were suspended per the CDC Project Officer during that time period due to the COVID-19 response. E-mail communication from the CDC Project Officer is attached. The Program continued to continuously monitor VFC Providers were maintaining proper storage of vaccines and reviewing medical records for eligibility screening despite not conducting a formal site visit. Responsible Official: Program Manager, Program Administrator, and Director of Public Health Services Proposed Completion Date: On-going
Audit performed by Pettit & Company, LLC 6249 South East Street, Suite E Indianapolis, IN 46227 Period covered by the audit Year ended December 31, 2021 Finding 2021-001 Late Issuance of 2020 Single Audit Reporting Package Type of Finding:Noncompliance Condition: The Organization is required to subm...
Audit performed by Pettit & Company, LLC 6249 South East Street, Suite E Indianapolis, IN 46227 Period covered by the audit Year ended December 31, 2021 Finding 2021-001 Late Issuance of 2020 Single Audit Reporting Package Type of Finding:Noncompliance Condition: The Organization is required to submit the reporting package by the deadline required by Uniform Guidance, which was September 30, 2022 for the year ended December 31, 2021. The Organization failed to file their report by this deadline. Views of Responsible Officials: The Organization has retained a new Contract CFO.
The condition occurred due to the absence of a formalized reconciliation procedure to identify third-party reimbursements (e.g., insurance recoveries) prior to the compilation of federal expenditures reported in the SEFA. Corrective Measures, internal Control Enhancement, the Authority has revised i...
The condition occurred due to the absence of a formalized reconciliation procedure to identify third-party reimbursements (e.g., insurance recoveries) prior to the compilation of federal expenditures reported in the SEFA. Corrective Measures, internal Control Enhancement, the Authority has revised its SEFA preparation procedures to incorporate a formal reconciliation process between General Ledger federal expenditures, Third-party reimbursement records (including insurance recoveries), and Federal award financial reports. This reconciliation will be documented, reviewed by supervisory personnel within the Comptroller’s Office, and retained as part of the SEFA supporting documentation in accordance with record retention requirements under Uniform Guidance. Training and Capacity Development: Personnel responsible for grants accounting and SEFA preparation will complete additional training on 2 CFR Part 200 (Uniform Guidance), FEMA cost eligibility and documentation requirements, Identification and treatment of non-federal offsets to federal expenditures
A specialized funds firm was hired that is working on internal controls to improve the method of accounting of federal funds that meet accounting and FEMA requirements.
A specialized funds firm was hired that is working on internal controls to improve the method of accounting of federal funds that meet accounting and FEMA requirements.
Due to government closures that occurred during the pandemic it was impossible to obtain external and internal information to comply with established requirements.
Due to government closures that occurred during the pandemic it was impossible to obtain external and internal information to comply with established requirements.
Planned Corrective Action: Management agrees with the finding and has implemented controls to match revenue received from Emergency Federal Funds with expenditures submitted on drawdown requests. This will properly capture all expenditures of Federal Funds in the correct fiscal year. Furthermore, ma...
Planned Corrective Action: Management agrees with the finding and has implemented controls to match revenue received from Emergency Federal Funds with expenditures submitted on drawdown requests. This will properly capture all expenditures of Federal Funds in the correct fiscal year. Furthermore, management will meet on a quarterly basis to review all Federal Funds and perform reconciliations on a monthly basis. In addition to quarterly financial reviews and monthly financial reconciliations, management will immediately adapt to changing guidelines on Emergencv Federal Funds in future fiscal vears. Planned Implementation Date of Corrective Action: Currently Implemented.
Finding 2021-010 Lack of Internal Controls Over Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Files will be developed to contain relevant documentation of reports submitted for federal grants. Proposed Comp...
Finding 2021-010 Lack of Internal Controls Over Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Files will be developed to contain relevant documentation of reports submitted for federal grants. Proposed Completion Date: October 31, 2026
Finding 2021-008 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Management will strengthen internal controls over payroll and review personnel files for adequate p...
Finding 2021-008 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Costs Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Management will strengthen internal controls over payroll and review personnel files for adequate pay rate documentation. Proposed Completion Date: October 31, 2026
Finding 2021-007 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Improvements will be made to documentation procedures for payables and cash disbursements to accommo...
Finding 2021-007 Lack of Internal Controls Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Improvements will be made to documentation procedures for payables and cash disbursements to accommodate the minimum requirements for grant regulations and audit purposes. Proposed Completion Date: October 31, 2026.
Finding 2021-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Reconciliation and closing procedures will be started earlier to accommodate for the nine-month reporting requirement. A certified public ...
Finding 2021-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Reconciliation and closing procedures will be started earlier to accommodate for the nine-month reporting requirement. A certified public accountant has been contracted to assist with the year-end closing and audit preparation process. Since required audits are backlogged by three years, the future date of compliance with this requirement is expected to be in 2027. Proposed Completion Date: March 31, 2027.
Finding 2021-009 Lack of Internal Controls Over Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Files will be developed to contain relevant documentation of reports submitted for federal grants. Proposed Comp...
Finding 2021-009 Lack of Internal Controls Over Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Files will be developed to contain relevant documentation of reports submitted for federal grants. Proposed Completion Date: October 31, 2026.
Recommendation: We recommend the organization implement and enforce internal controls, including a compliance calendar and assignment of responsibility, to ensure all required audits and submissions to the FAC are completed accurately and within required timeframes. Organization’s response: The Orga...
Recommendation: We recommend the organization implement and enforce internal controls, including a compliance calendar and assignment of responsibility, to ensure all required audits and submissions to the FAC are completed accurately and within required timeframes. Organization’s response: The Organization concurs with the finding and will implement our recommendation immediately. Contact: BreNita Jackson, Executive Director
2021-004 – Reporting - Significant Deficiency in Internal Control over Compliance and Other Matter Name and Contact Person: Desiree Rock, Tribal Administrator Corrective Action Plan: Management will ensure that federal grant reporting is filed timely by the reporting deadlines. Proposed Completion D...
2021-004 – Reporting - Significant Deficiency in Internal Control over Compliance and Other Matter Name and Contact Person: Desiree Rock, Tribal Administrator Corrective Action Plan: Management will ensure that federal grant reporting is filed timely by the reporting deadlines. Proposed Completion Date: July 30, 2026
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
We were not able to submit the financials on time because we lost our previous auditors in 2021. It took some time to find a new company that handles HUD related audits. Going forward, we will work on getting back to our normal audit schedule to get back in compliance at the soonest possible time.
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