Corrective Action Plans

Finding 498493 (2023-002)

Significant Deficiency 2023

OK

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties § 200.303

Name(s) of the contact person(s) responsible for corrective action: Richard Marshall Planned completion date for corrective action plan: 12/31/2025 2023-002 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879 – Rent Reasonableness Recommendation: We recommend management to implement contr...

Name(s) of the contact person(s) responsible for corrective action: Richard Marshall Planned completion date for corrective action plan: 12/31/2025 2023-002 Housing Voucher Cluster – Assistance Listing No. 14.871/14.879 – Rent Reasonableness Recommendation: We recommend management to implement controls over the recertification and rent change process to ensure determination of reasonable rent is performed prior to processing of the move in. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue to perform quality control on files and note any pattern that develops for the same type of errors and take corrective action if a pattern develops. Name(s) of the contact person(s) responsible for corrective action: Richard Marshall Planned completion date for corrective action plan: 12/31/2025

View Audit 321203

Finding 498490 (2023-001)

Significant Deficiency 2023

Oklahoma City Housing Authority

OK

HUD Housing Programs Eligibility Significant Deficiency § 200.303

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 – Eligibility Recommendation: We recommend management to implement controls and policies to ensure compliance with eligibility requirements. Additional training for housing specialists would also improve accuracy. Explanation of disagr...

Housing Voucher Cluster – Assistance Listing No. 14.871 / 14.879 – Eligibility Recommendation: We recommend management to implement controls and policies to ensure compliance with eligibility requirements. Additional training for housing specialists would also improve accuracy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Monitor and quality control documents as required by HUD. If quality control determines there is a pattern of the same type of discrepancy, then corrective actions will be taken. The finding is based on 2 late reexaminations and failure to automatically identify a client as disabled. This is marked as a repeat finding in the same category, but is not the same type of finding as last year.

View Audit 321203

Finding 498472 (2023-002)

Significant Deficiency 2023

City of Union City

IN

Internal Control / Segregation of Duties Special Tests & Provisions Reporting § 200.303

The City will review the wage-rate testing prepared by the consultant and formally document their review

View Audit 321171

Finding 498471 (2023-001)

Significant Deficiency 2023

City of Union City

IN

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

The City will review the reports prepared by the consultant and formally document their review

View Audit 321171

Finding 498428 (2023-005)

Significant Deficiency 2023

State of Missouri

MO

Allowable Costs / Cost Principles Eligibility Significant Deficiency

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Social Services (DSS) – MO HealthNet Division (MHD) and Family Support Division (FSD) Audit Finding Number: 2023-005 Medicaid and CHIP MAGI-Based Participant Eligibility Redeterminations...

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2023 State Agency: Department of Social Services (DSS) – MO HealthNet Division (MHD) and Family Support Division (FSD) Audit Finding Number: 2023-005 Medicaid and CHIP MAGI-Based Participant Eligibility Redeterminations Name of the contact person responsible for corrective action: Heather Atkins Anticipated completion date for corrective action: N/A Recommendations: The DSS through the MHD and the FSD review and correct cases for participants with manual overrides in the MEDES, ensure redeterminations are completed for these participants as required, and close the cases of any ineligible participants. In addition, the DSS should ensure system controls are functioning as designed for these participants. DSS Response: The DSS disagrees with this finding. The DSS disagrees there is a significant deficiency in internal controls. As noted in the finding, from the 60 participants selected, the SAO did not identify any participants with previously-established overrides; therefore, no incorrect payments were cited. Section 6008 of the Families First Coronavirus Response Act (FFCRA) required states to provide continuous coverage, through the end of the month in which the PHE period ends, to all Medicaid beneficiaries who were enrolled in Medicaid on or after March 18, 2020, regardless of any changes in eligibility unless the individual voluntarily terminated eligibility, is deceased, or moved out of state. As required by the Centers for Medicaid and Medicare Services (CMS) during the PHE, the DSS had processes in place to terminate eligibility for individuals who were deceased, voluntarily requested closure, or reported they have moved out of state when a current change was reported. The Consolidated Appropriations Act, 2023, signed on December 29, 2022, amended section 6008 of the FFCRA such that the continuous enrollment condition ended on March 31, 2023. During the PHE, the DSS did not conduct reviews of cases that did not report current changes. The DSS developed a report identifying all individuals with manual overrides and their certification dates to complete annual reviews on them. The DSS is actively working the report and have initiated annual reviews on all individuals that have had MO HealthNet eligibility for at least twelve consecutive months. The DSS anticipates completing the review of all individuals by August 31, 2024, to account for the required 90 day reconsideration period as required in 42 CFR 435.916.

View Audit 321142

Finding 498387 (2023-004)

Significant Deficiency 2023

Ottawa County District Board of Health

OH

Allowable Costs / Cost Principles Significant Deficiency

Finding Number: 2023-004 Planned Corrective Action: No further funds will be released from the Coronavirus State and Local Fiscal Recovery Funds without written verification that funds are allocated for and spent in accordance with allowable expenditures. Anticipated Completion Date: December 31, ...

Finding Number: 2023-004 Planned Corrective Action: No further funds will be released from the Coronavirus State and Local Fiscal Recovery Funds without written verification that funds are allocated for and spent in accordance with allowable expenditures. Anticipated Completion Date: December 31, 2024 Responsible Contact Person: Jennifer Widmer, County Auditor

View Audit 321127

Finding 498377 (2023-003)

Significant Deficiency 2023

Housing Authority of the City of Omaha

NJ

Questioned Costs HUD Housing Programs Significant Deficiency

Finding 2023-003: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Non Complianc...

Finding 2023-003: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program Federal Assistance Listing Numbers: 14.871 Noncompliance – N. Special Tests and Provisions – Housing Quality Standards (HQS) Enforcement Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance for Special Tests and Provisions Criteria: HQS Enforcement. For units under HAP contract that fail to meet HQS, the PHA must require the owner to correct all life threatening HQS deficiencies within 24 hours after the inspections and all other deficiencies within 30 days or within a specified PHA-approved extension. Condition: Based upon inspection of the Authority’s files and on discussion with management, the Authority did not properly abate one (1) out of twenty-five (25) annual failed inspections selected for testing. Context: The Authority did not properly abate one (1) out of twenty-five (25) failed inspections selected for testing. As a result, the Authority was not in compliance with the HQS as required by 24 CFR sections 982.158(d) and 982.405(b). Known Questioned Costs: $1,532 Cause: There is a significant deficiency in internal controls over the compliance for the special tests and provisions type of compliance related to HQS enforcement. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Section 8 Housing Choice Vouchers Program is in non-compliance with the special tests and provisions type of compliance related to HQS enforcement. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Philisa Smith, HCV Director, is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring by December 31, 2024.

View Audit 321110 Questioned Costs: $1

Finding 498376 (2023-002)

Significant Deficiency 2023

Housing Authority of the City of Omaha

NJ

Questioned Costs HUD Housing Programs Eligibility

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program, Federal Catalog Numbers: 14.871 Noncompliance - E - Eligibility Non Compliance Material to the Financial Statements: No Significant Deficiency in Inte...

Finding 2023-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Section 8 Housing Choice Vouchers Program, Federal Catalog Numbers: 14.871 Noncompliance - E - Eligibility Non Compliance Material to the Financial Statements: No Significant Deficiency in Internal Control over Compliance Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: Of a sample size of forty-three (43) tenant files, the following information was unavailable for examination at the time of audit: (3) Verification of Income (2) Verification of Assets HUD Form 50058 Our sample size is statistically valid. Known Questioned Costs: 7,162 Cause: There is a significant deficiency in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Section 8 Housing Choice Voucher Program is in non-compliance with the eligibility type of compliance requirements of the program. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Philisa Smith, HCV Director, is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring by December 31, 2024.

View Audit 321110 Questioned Costs: $1

Finding 498333 (2023-002)

Significant Deficiency 2023

Farmworker Justice

DC

Reporting Allowable Costs / Cost Principles Significant Deficiency § 200.508

Views of Responsible Officials: Management concurs with the recommendation. See the corrective action plan.

View Audit 321069

Finding 498318 (2023-001)

Significant Deficiency 2023

Independent Living Place, Inc.

TX

Questioned Costs HUD Housing Programs Significant Deficiency

CORRECTIVE ACTION PLAN Name and Number of the Project: INDEPENDENT LIVING PLACE, INC. No. 115-EH115 Audit Firm: M Group, LLP Audit Period: The year ended September 30, 2023 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our audit...

CORRECTIVE ACTION PLAN Name and Number of the Project: INDEPENDENT LIVING PLACE, INC. No. 115-EH115 Audit Firm: M Group, LLP Audit Period: The year ended September 30, 2023 Compliance Review A. COMMENTS ON FINDINGS AND RECOMMENDATIONS We concur with the findings and recommendations of our auditors regarding our noncompliance as cited in the accompanying Schedule of Findings and Questioned Costs. ACTIONS TAKEN FINDING 1: Section 202 Supportive Housing for the Disabled, Assistance Listing 14.157 and Section 8 Housing Assistance Payments Program, Assistance Listing 14.195 CORRECTIVE ACTION COMPLETED: On August 7, 2024, the Project deposited $2,450 into the replacement reserve account. We have prepared the corrective action plan as required by the standards applicable to financial statements contained in Government Auditing Standards and by the audit requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principals, and Audit Requirements for Federal Awards. Any questions regarding the above corrective action plan should be directed to Mr. Stewart Grounds, Chief Financial Officer of Arnold-Grounds Apartment Management & Affordable Housing Specialists, LLC.

View Audit 321062 Questioned Costs: $1

Finding 498310 (2023-001)

Significant Deficiency 2023

East Central Energy

MN

Procurement, Suspension & Debarment Significant Deficiency § 200.317 § 200.318 § 200.327

Contact Person – Lisa Prachar, VP/CFO Corrective Action Plan – East Central Energy and Subsidiaries is currently developing a written procurement plan that adheres to minimum standards. Completion Date – December 31, 2024

View Audit 321061

Finding 498294 (2023-006)

Significant Deficiency 2023

City of Seattle

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles

City staff will contact all Community Based Organizations (CBOs) that received Emergency Rental Assistance 2 funding to determine if they were required to complete a Single Audit per the Single Audit Act. This communication will include, if applicable, a request that they submit the organizations mo...

City staff will contact all Community Based Organizations (CBOs) that received Emergency Rental Assistance 2 funding to determine if they were required to complete a Single Audit per the Single Audit Act. This communication will include, if applicable, a request that they submit the organizations most recent audit for review by staff. Should a Single Audit identify any findings or other deficiencies, staff will ask the CBO to provide an update as to the status of the deficiency and if it has been appropriately addressed. Staff will document this communication in the electronic file of the CBO who was required to complete a Single Audit.

View Audit 321037

Finding 498271 (2023-003)

Significant Deficiency 2023

City of Seattle

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

HSD acknowledges the identified weakness and implemented an updated Accounts Payable control procedure in 2024, that includes an additional standard monthly report and review process to ensure that reimbursements are processed with the required 30-day period.

View Audit 321037

Finding 498252 (2023-001)

Significant Deficiency 2023

West Hennepin Affordable Housing Land Trust Dba Homes Within Reach

MN

Reporting Significant Deficiency § 200.512

Name of contact person: Brenda Lano, Executive Director Corrective Action: The Organization continues to work with the various cities and counties to obtain grant agreements and document if there is not an agreement. The Organization is also actively working with their auditor to improve communicat...

Name of contact person: Brenda Lano, Executive Director Corrective Action: The Organization continues to work with the various cities and counties to obtain grant agreements and document if there is not an agreement. The Organization is also actively working with their auditor to improve communication during the audit so a late filing does not occur again. We expect the issue will be mitigated for the 2023 audit. Completion Date: The Organization has already adopted this corrective action.

View Audit 321018

Finding 498187 (2023-002)

Significant Deficiency 2023

Westward Heights

WY

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.327

Effective immediately, our management company changed the process that office managers get invoices submitted and paid, which will guarantee the Chief Financial Analyst gets financial statements out before the 15th of each month. This will allow time to get the quarterly reports completed and sent t...

Effective immediately, our management company changed the process that office managers get invoices submitted and paid, which will guarantee the Chief Financial Analyst gets financial statements out before the 15th of each month. This will allow time to get the quarterly reports completed and sent to the USDA.

View Audit 320940

Finding 498157 (2023-001)

Significant Deficiency 2023

Rock Valley Community Programs

WI

Significant Deficiency Internal Control / Segregation of Duties

Immediate- (Instantaneous) • The Human Resources Manager at RVCP completed a record review and file audit of all payroll functions twice within 30 days (before the signature date of this document), once by the HRM. • A check and balance with updated Policy and Procedure for onboarding was completed,...

Immediate- (Instantaneous) • The Human Resources Manager at RVCP completed a record review and file audit of all payroll functions twice within 30 days (before the signature date of this document), once by the HRM. • A check and balance with updated Policy and Procedure for onboarding was completed, socialized, and disseminated • The Executive Director must review a sampling of 4 employees at the end of every 2"' pay period cycle and test for accuracy. Short Term- (30 days or less) • The payroll servicer will be changed, and the new system will be identified in 30 days. long Term- (30 plus days) • Final HRIS replacement system contracted to replace • Roll out new HRIS system to include payroll and checklist software • Create and test controls to gauge the accuracy of policy and procedures and new HRIS

View Audit 320888

Finding 498136 (2023-003)

Significant Deficiency 2023

Florence County

WI

Cash Management Reporting Significant Deficiency

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-003 Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program – Assistance Listing No. 93.778 / 93.324 / 93.071 Recommendation: We recommend that there is an appropriate reviewer of each grant claim. E...

DEPARTMENT OF HEALTH AND HUMAN SERVICES 2023-003 Medical Assistance Program / State Health Insurance Assistance Program / Medicare Enrollment Assistance Program – Assistance Listing No. 93.778 / 93.324 / 93.071 Recommendation: We recommend that there is an appropriate reviewer of each grant claim. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The amounts reported were accurate and in compliance. The department will continue to train employees in respective positions to ensure responsibilities align with program requirements. Immediately upon discovery of the omission of the review step, management reiterated to department financial staff the importance of the review process. Name(s) of the contact person(s) responsible for corrective action: Kim Merrill, Finance Manager Planned completion date for corrective action plan: December 31, 2024

View Audit 320852

Finding 498127 (2023-003)

Significant Deficiency 2023

Little Earth of United Tribes Housing Corporation

MN

HUD Housing Programs Subrecipient Monitoring Eligibility

Management will implement a system to monitor and review tenant file gross rent changes occurring during the year.

View Audit 320806

Finding 498126 (2023-002)

Significant Deficiency 2023

Little Earth of United Tribes Housing Corporation

MN

HUD Housing Programs Reporting Significant Deficiency § 200.512

Management filed the 2022 Single Audit Reporting Package in July 2024.

View Audit 320806

Finding 498125 (2023-001)

Significant Deficiency 2023

Little Earth of United Tribes Housing Corporation

MN

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Management made an additional deposit to the replacement reserve of $17,617 in June 2024.

View Audit 320806

Finding 498115 (2023-002)

Significant Deficiency 2023

Wilson Elementary School District No. 7

AZ

Allowable Costs / Cost Principles Significant Deficiency

Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Talise Berry Anticipated Completion Date: April 30, 2025 Planned Corrective Action: The Wilson School District has begun implementing interna...

Finding Number: 2023‐002 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Talise Berry Anticipated Completion Date: April 30, 2025 Planned Corrective Action: The Wilson School District has begun implementing internal procedures that require supporting documentation to be uploaded into the financial system for all transactions. Ongoing staff turnover will facilitate the enforcement of this process among all personnel handling transactions within the financial system. The district has also developed resources to ensure that staff understand the importance of maintaining accurate supporting documentation.

View Audit 320767

Finding 498114 (2023-001)

Significant Deficiency 2023

Wilson Elementary School District No. 7

AZ

Special Tests & Provisions Significant Deficiency

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Talise Berry Anticipated Completion Date: April 30, 2025 Planned Corrective Action: The Wilson School District understood that Davis‐Bacon req...

Finding Number: 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Numbers: 84.425U Contact Person: Talise Berry Anticipated Completion Date: April 30, 2025 Planned Corrective Action: The Wilson School District understood that Davis‐Bacon requirements applied to the construction contracts. However, this is the first time in over a decade of working with our auditors that we have been asked to provide certification of compliance with federal regulations requiring us to obtain payroll journal details from vendors for payments made to their staff working on our projects. Moving forward, we will ensure full compliance by consistently requesting and maintaining these records for all future projects.

View Audit 320767

Finding 498097 (2023-005)

Significant Deficiency 2023

Baboquivari Unified School District No. 40

AZ

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.334

2023-005 Allowable Costs/Cost Principles – Indirect Costs U.S. Department of Education Education Stabilization Fund – Assistance Listing No. 84.425 Pass-Through Agency: Arizona Department of Education Pass-Through Number(s): All Pass-Through Numbers Present in the SEFA Recommendation: We recommend m...

2023-005 Allowable Costs/Cost Principles – Indirect Costs U.S. Department of Education Education Stabilization Fund – Assistance Listing No. 84.425 Pass-Through Agency: Arizona Department of Education Pass-Through Number(s): All Pass-Through Numbers Present in the SEFA Recommendation: We recommend management to incorporate a management review control to ensure the calculation is complete and accurate and all supporting documents including the general ledger used for the calculation is retained in accordance with UG. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district will have a process in place to update all documentation related to indirect costs and the calculations from the general ledger. Name(s) of the contact person(s) responsible for corrective action: Clementina Carlyle, Chief Financial Officer.

View Audit 320760 Questioned Costs: $1

Finding 498095 (2023-003)

Significant Deficiency 2023

Baboquivari Unified School District No. 40

AZ

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

2023-003 Level of Effort U.S. Department of Education Impact Aid – Assistance Listing No. 84.041 Pass-Through Agency: N/A Pass-Through Number(s): N/A Recommendation: The District should refine its current process and associated controls to monitor supplanting of grant funds Explanation of disagreeme...

2023-003 Level of Effort U.S. Department of Education Impact Aid – Assistance Listing No. 84.041 Pass-Through Agency: N/A Pass-Through Number(s): N/A Recommendation: The District should refine its current process and associated controls to monitor supplanting of grant funds Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district will update the supplanting methodology utilized to ensure all federal funds are supplementing and not supplanting state funds. Name(s) of the contact person(s) responsible for corrective action: Clementina Carlyle, Chief Financial Officer.

View Audit 320760

Finding 498094 (2023-002)

Significant Deficiency 2023

Baboquivari Unified School District No. 40

AZ

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.326

2023-002 Special Provisions U.S. Department of Education Impact Aid – Assistance Listing No. 84.041 Pass-Through Agency: N/A Pass-Through Number(s): N/A Recommendation: The District should refine its current process and associated controls surrounding the requirements in 29 CFR Part 5, Labor Standar...

2023-002 Special Provisions U.S. Department of Education Impact Aid – Assistance Listing No. 84.041 Pass-Through Agency: N/A Pass-Through Number(s): N/A Recommendation: The District should refine its current process and associated controls surrounding the requirements in 29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: To address the finding, the district procurement process will be updated to include steps to contact vendors/contractors about their prevailing wage rate requirements on all contracts paid from federal funds. In addition, the district will request vendors to submit Form WH-347 at the conclusion of all federally funded projects. Name(s) of the contact person(s) responsible for corrective action: Clementina Carlyle, Chief Financial Officer. Planned completion date for corrective action plan: December 31, 2024

View Audit 320760

Corrective Action Plans

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