Corrective Action Plans

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Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being perfor...
Recommendation: We recommend the college review its process and procedures for R2T4 calculations to ensure they are in line with Dept. of Education requirements. We also recommend the college maintain evidence of the formal review process that ensures Return of Title IV calculations are being performed timely and correctly to minimize the likelihood that errors may go undetected and not corrected in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College will ensure that all Financial Aid policies and procedures are up-to-date; reviewed annually; and revised, as needed. Documentation will also be made for any procedures that are currently being performed by their third-party-servicer, Global including Return to Title IV (R2T4) calculations. As an internal control, the Financial Aid Office will retain records of the Return to Title IV calculations performed by Global; sign-off on the appropriate reports with the date reviewed; include the initials of the Coordinator of Financial Aid and co-signed by the Director of Financial Aid. The Coordinator of Financial Aid will notify Global of funds to be returned by the institution and/or student by completing the established process (GARP) to ensure that the funds are returned to the Department of Education within 45 days of the Date of Determination. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.
Finding 2025-002: National Student Loan Database System (NSLDS) Reporting Significant Deficiency in Internal Control over Compliance / Other Matters Views of Responsible Officials and Planned Corrective Actions: Management concurs with the audit findings and acknowledges that controls over accurate ...
Finding 2025-002: National Student Loan Database System (NSLDS) Reporting Significant Deficiency in Internal Control over Compliance / Other Matters Views of Responsible Officials and Planned Corrective Actions: Management concurs with the audit findings and acknowledges that controls over accurate and timely reporting of student enrollment information to the NSLDS were not operating effectively, including procedures related to oversight of reporting performed by a third-party servicer. To address this finding, management is implementing the following corrective actions:  Management is evaluating and formalizing its oversight procedures related to NSLDS submissions performed by the third-party servicer, including defined responsibilities, review procedures, and escalation protocols.  Periodic internal reviews of NSLDS submissions are being implemented to verify the accuracy and timeliness of campus-level and program-level enrollment reporting.  Management is updating policies and procedures to ensure that all enrollment status changes and effective dates are captured and reported in accordance with U.S. Department of Education regulations. Management expects these corrective actions to be substantially implemented and will continue to monitor compliance to prevent recurrence.
Finding Number: 2025-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2026 Responsible Contact Person: Pamela Keener, Finance Director
Finding Number: 2025-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2026 Responsible Contact Person: Pamela Keener, Finance Director
Classification Significant Deficiency Responsible Official Chief Financial Officer Anticipated Completion Date June 30, 2027 Management Response Management concurs with the finding. OIC experienced turnover in key finance positions, delayed year-end close activities, and documentation challenges dur...
Classification Significant Deficiency Responsible Official Chief Financial Officer Anticipated Completion Date June 30, 2027 Management Response Management concurs with the finding. OIC experienced turnover in key finance positions, delayed year-end close activities, and documentation challenges during the auditor transition; management will strengthen close, documentation, and audit readiness controls. Corrective Action Plan 1. Implement a documented monthly and year-end close process with defined deadlines, assigned responsibilities, balance sheet reconciliations, and documented supervisory review. 2. Maintain audit-ready support for material balances, including fixed assets, leases, beginning balances, federal awards, and other significant accounts in a centralized electronic repository. 3. Develop personnel and auditor transition procedures, including desk procedures, PBC checklists, training, and quarterly status reporting to the Finance Committee and Audit Committee.
Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the a...
Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2026
Department of Housing and Urban Development Columbia Park Manor, HUD Project No. CA39S931006, respectively submits the following corrective action plan for the audit year ended 12/31/2025. Auditor: Apria LLP 2185 N. California Blvd, STE 350 Walnut Creek, CA 94596 SECTION I - CURRENT YEAR FINDING Fin...
Department of Housing and Urban Development Columbia Park Manor, HUD Project No. CA39S931006, respectively submits the following corrective action plan for the audit year ended 12/31/2025. Auditor: Apria LLP 2185 N. California Blvd, STE 350 Walnut Creek, CA 94596 SECTION I - CURRENT YEAR FINDING Finding No.: 2025-001 Comments on Findings and Recommendations: Unable to locate EIV report ran within 120 days of Ml eff. 5/612025. This practice does not comply with HUD requirements. Action Taken or Planned: Clarification record added to the file. Moving Forward PS will ensure that PM runs and files away the EIV report within the HUD required timeline after Ml. Anticipated Completion Date: 11/25/2025
Condition: The Authority was unable to send failed HQS inspection notices timely to participants who needed to correct deficiencies. Planned Corrective Action: Throughout 2025, BHP implemented several process improvement measures for inspections for the Housing Choice Voucher Program, including deta...
Condition: The Authority was unable to send failed HQS inspection notices timely to participants who needed to correct deficiencies. Planned Corrective Action: Throughout 2025, BHP implemented several process improvement measures for inspections for the Housing Choice Voucher Program, including detailed preparations for the implementation of NSPIRE standards. As noted in the audit, BHP needed to improve our timely notification to landlords of failed inspection items. To address the noted deficiency, BHP implemented a daily email notification to the HCV team summarizing all failed inspections that have occurred in the prior 48 hours. These improvements were implemented in the second half of 2025 and have successfully addressed the noted concern. In addition, BHP implemented additional inspection improvements during the year, including hiring additional qualified personnel to assist with scheduling inspections, as well as timely distribution of any notices of failed inspections. BHP is working to improve our processes to better serve clients and create efficiencies within their workflows as we prepare for full NSPIRE implementation. Contact person responsible for corrective action: Karen Brunnemer, MTW and Federal Policy Director and Omar Llamas, HCV Program Manager Anticipated Completion Date: 12/31/2026
Corrective Action Plan Program Managers responsible for submitting Performance Reports must copy the appropriate Contract Administrator, Director of Contracts, Accountability & Risk Management and the Director of Transition Services on all correspondence related to report submissions. When an extens...
Corrective Action Plan Program Managers responsible for submitting Performance Reports must copy the appropriate Contract Administrator, Director of Contracts, Accountability & Risk Management and the Director of Transition Services on all correspondence related to report submissions. When an extension is needed, the Program Manager will request written approval from TWC. If an unexpected delay occurs, the Program Manager will notify TWC in writing and confirm the anticipated submission date to support compliance with reporting deadlines. Program Managers will also create tasks and calendar reminders for all applicable reporting and billing due dates. Person(s) Responsible: Bekah Coggins, Director of Transition Services Anticipated Completion Date: Effective May 4, 2026, and onward
Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these r...
Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these reports reflect actual amounts posted to internal accounts rather than estimated expenditures, they are used to cross-reference program expenses and support billing submissions. Buckner also implemented additional levels of review to ensure the Program Manager completes billing documentation accurately, the Program Director reviews followed by final review by the Finance Administrator. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective August 20, 2025, and onward
Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calcula...
Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calculate allocations and reduce errors. Each month, the Finance Administrator calculates allocations based on time worked, provides them to the Program Director for billing, and reviews state billing submissions to confirm accuracy. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective June 20, 2025, and onward
At the start of each fiscal year, the Finance Director will prepare a submission timeline working backward from the March 31 FAC deadline, establishing interim milestones for year-end close, draft financial statement preparation, management review, and auditor fieldwork. Progress against the submiss...
At the start of each fiscal year, the Finance Director will prepare a submission timeline working backward from the March 31 FAC deadline, establishing interim milestones for year-end close, draft financial statement preparation, management review, and auditor fieldwork. Progress against the submission timeline will be monitored by the CEO and reported to the Board of Directors on a quarterly basis. Management will engage its external auditors earlier in the process and ensure adequate finance staffing is maintained prior to the fiscal yearend close.
Internal Control Over Reporting Department of Human Services – Grants to States for Medicaid – Assistance Listing No. 93.778 Recommendation: We recommend that the County enact controls to assure employees included in grant are included in reporting submitted. Explanation of disagreement with audit f...
Internal Control Over Reporting Department of Human Services – Grants to States for Medicaid – Assistance Listing No. 93.778 Recommendation: We recommend that the County enact controls to assure employees included in grant are included in reporting submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement procedures to ensure that all reports are reviewed prior to submission. Names of the contact person responsible for corrective action: Pat Paquin, Finance Manager Planned completion date for corrective action plan: December 31, 2026
Findings #2025-004 and #2025-006 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 –...
Findings #2025-004 and #2025-006 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 – 09/30/25, FFY2025-27946V-ASA RSS, 10/01/24 – 09/30/25, FFY2025-27946V-AUSAA-RSS, 10/01/24 – 09/30/25, FFY2025-27946V-CMA, 10/01/24 – 09/30/25, FFY2025-27946V-RSS, Passed through United States Conference of Catholic Bishops: 10/01/24 – 09/30/25, 25RSI13A, Passed through U. S. Committee for Refugees: 10/01/24 – 09/30/25, RHP-2025-YMCA-Houston TX-03, 93.567, Refugee and Entrant Assistance Voluntary Agency Programs, Passed through U. S. Committee for Refugees and Immigrants: 10/01/24 – 09/30/25, 2502VARVMG, 10/01/23 – 09/30/24, 2402VARVMG, 93.676, Unaccompanied Alien Children Program, Passed through U. S. Committee for Refugees and Immigrants: 01/01/25 – 12/31/25, 90ZU0630-02. Condition and context: During our testing of the accuracy of accounts payable cutoff and the testing of allowable costs charged to major programs, the following exceptions were identified for expenses recorded in the incorrect period: 3 of 19 subsequent disbursement transactions tested were recorded in the incorrect accounting period. Refugee and Entrant Assistance State/Replacement Designee Administered Programs (ALN 93.566) – 3 out of 40 transactions tested were recorded to the incorrect accounting period. Unaccompanied Alien Children Program (ALN 93.676) – 1 out 40 transactions tested was recorded in the incorrect accounting period. Refugee and Entrant Assistance Voluntary Agency Programs (ALN 93.567) – 1 out of 40 transactions tested was recorded in the incorrect accounting period. Recommendation: Policies and procedures should be enhanced for proper identification of the period that expenses relate to so that expenses will be recorded in the correct accounting period for financial statement reporting and for billing allowable costs to federal programs. Planned corrective action: Management acknowledges the deficiency identified related to the precision of procedures to ensure expenses are recorded in the appropriate accounting period. Processes were in place and operated to identify and record expenses in the correct period, and management’s review procedures are designed to capture all material items for financial reporting and program compliance purposes. The exceptions identified through audit testing represent a limited number of timing differences in a high-volume environment, primarily related to the timing of invoice receipt and processing, and were not material individually or in the aggregate. These items were recorded in the subsequent period in the normal course of operations and do not reflect a systemic breakdown in controls. In response, management has reinforced month-end cutoff procedures, including enhanced review of subsequent disbursements and clearer expectations around accrual identification and invoice timing. Management will continue to monitor cutoff procedures to ensure expenses are recorded in the appropriate period with an appropriate level of precision while maintaining timely vendor payment practices. Responsible officer: Lauren Rome, VP of Financial Operations/Interim CFO. Estimated completion date: June 15, 2026
Implement cross training of staff member, maintain updated procedures for tasks, and establish backup coverage for critical reporting functions to mitigate the impact of future staffing changes in the reporting compliance process. Anticipated completion date: December 31, 2026. Responsible contact: ...
Implement cross training of staff member, maintain updated procedures for tasks, and establish backup coverage for critical reporting functions to mitigate the impact of future staffing changes in the reporting compliance process. Anticipated completion date: December 31, 2026. Responsible contact: Mike Gagliardi, Administrator.
Statement of Condition: During our testing of participant eligibility for the WIOA Cluster, we identified an instance in which a male participant subject to Selective Service requirements was not registered with the Selective Service System, and no evidence of registration verification or documented...
Statement of Condition: During our testing of participant eligibility for the WIOA Cluster, we identified an instance in which a male participant subject to Selective Service requirements was not registered with the Selective Service System, and no evidence of registration verification or documented exemption was maintained in the participant file. Management Response and Corrective Action Plan: Management agrees with the recommendation and has developed a guideline in which a participant is not to be co-enrolled in WIOA Youth while being enrolled in another youth program. Responsibility of: Chief Finance and Admin Officer, Sherri Emitte Planned Implementation Date of Corrective Action Plan: 2026 Audit
Statement of Condition: During our testing of compliance with requirements applicable to major federal programs, we noted that the entity did not have formal, consistently applied review and approval controls over key compliance areas. Specifically, evidence of supervisory review and approval was no...
Statement of Condition: During our testing of compliance with requirements applicable to major federal programs, we noted that the entity did not have formal, consistently applied review and approval controls over key compliance areas. Specifically, evidence of supervisory review and approval was not consistently documented for compliance-related transactions. As a result, review procedures appear to be informal, inconsistent, or reliant on individual practices rather than standardized, documented controls. Management Response and Corrective Action Plan: Management agrees with the recommendation and has developed a much more stringent review and approval process. Responsibility of: Chief Finance and Admin Officer, Sherri Emitte Planned Implementation Date of Corrective Action Plan: 2026 Audit
2025-002: Reporting Submissions Not Performed Timely Federal Department: Department of Housing and Urban Development Assistance Listing #: 14.251 Internal Controls Significant Deficiency & Noncompliance Category of Finding – Reporting Name of contact person: Leah Cameron, Director of Supportive Serv...
2025-002: Reporting Submissions Not Performed Timely Federal Department: Department of Housing and Urban Development Assistance Listing #: 14.251 Internal Controls Significant Deficiency & Noncompliance Category of Finding – Reporting Name of contact person: Leah Cameron, Director of Supportive Services Corrective Action: Clare Housing will complete the following corrective action steps: • Clare Housing will establish a centralized reporting calendar for all grants that includes all required reports, due dates, and responsible staff. • Clare Housing will clearly assign ownership for each report, including primary and backup staff. • Clare Housing will utilize automated reminders (e.g., calendar alerts or task management tools) at key intervals prior to due dates. • Clare Housing will track report status (in progress, under review, submitted) to ensure visibility. • The Director of Supportive Services will monitor overall reporting compliance and conduct periodic file reviews. Clare Housing will ensure reporting requirements are met by establishing calendar reminders for all reporting requirements. Calendar reminders will include relevant staff, including but not limited to, the Director of Finance and the Director of Supportive Services. The Director of Supportive Services and Director of Finance will ensure submission of any prepared reports in the DRGR (or other relevant reporting) system by the appropriate due date. Completion Date: Creation of the centralized reporting calendar and tracking system and periodic file reviews will be by August 1, 2026.
Recommendation: We recommend that Eastern Lancaster County School District implement procedures to ensure that SNP Claim for Reimbursement Summary reports are independently reviewed and approved prior to submission to Program Electronic Application and Reimbursement System (PEARS). This review shoul...
Recommendation: We recommend that Eastern Lancaster County School District implement procedures to ensure that SNP Claim for Reimbursement Summary reports are independently reviewed and approved prior to submission to Program Electronic Application and Reimbursement System (PEARS). This review should be performed by an individual who is not involved in the preparation of the reports and evidence of the review should be documented. School District Response: (Corrective Action) Eastern Lancaster County School District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: o Review the claim for mathematical accuracy. o Verify meal counts against supporting documentation. o Confirm claims are submitted within required timelines. 3. Evidence of the review and approval will be documented through: o Signature or electronic approval on the reimbursement summary report. o Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. 5. The Chief of Finance and Operation will periodically monitor compliance with the procedure to ensure controls remain effective. Anticipated Completion Date: The corrective action procedures will be fully implemented by June 1, 2026. Responsible Person for the Corrective Action: Keith D. Ramsey, Chief of Finance and Operations
2025-003 Eligibility Finding Type: Significant deficiency in Internal Controls over Compliance and Compliance Federal Program Title and AL Number: The Food Distribution Cluster (10.565, 10.568, 10.569). Criteria: Per Title 7 CFR § 247.8, to apply for or to be recertified for CSFP benefits, the appli...
2025-003 Eligibility Finding Type: Significant deficiency in Internal Controls over Compliance and Compliance Federal Program Title and AL Number: The Food Distribution Cluster (10.565, 10.568, 10.569). Criteria: Per Title 7 CFR § 247.8, to apply for or to be recertified for CSFP benefits, the applicant or caretaker of the applicant must be informed of his or her rights and responsibilities, in accordance with § 247.12, the local agency must ensure that the applicant or caretaker signs the application form. Condition and context: As part of our eligibility testing, and in order to determine compliance with the requirements, we verified that the CSFP participants had completed and signed applications or recertifications prior to receiving food distributions. For four out of 32 non-statistical samples, the application was completed but did not have the participants' signature. Cause: The Food Bank did not have controls in place to ensure the participant signatures were received prior to providing food assistance to the individual. Effect: The Food Bank was not able to demonstrate compliance with Title 7 CFR § 247.8. Questioned Costs: None Repeat finding: No Recommendation: We recommend the Food Bank implement controls to ensure CSFP applications and recertifications are signed by the applicant prior to the individual receiving food. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan. Management Response and Planned Corrective Action: Criteria: Per Title 7 CFR § 247.8, to apply for or to be recertified for Commodity Supplemental Food Program (“CSFP”) benefits, the applicant or caretaker of the applicant must be informed of his or her rights and responsibilities, in accordance with § 247.12, the local agency must ensure that the applicant or caretaker signs the application form. The Los Angeles Regional Food Bank (“Food Bank”) has submitted a request to “Oasis Insights”, the Food Bank’s software vendor utilized for CSFP, to reinstate mandatory field validation, or a “hard stop”, on CSFP applications to prevent case progression or assistance issuance when required signatures have not been captured. The Food Bank will verify that the mandatory field validation feature has been reinstated. Additionally, the Food Bank’s CSFP Program Manager will ensure that all Food Bank employees responsible for overseeing CSFP will be provided with retraining in the area of CSFP eligibility requirements. The Director of Compliance and Administration will verify that CSFP applications through Oasis are unable to progress forward without a required signature and that the aforementioned CSFP eligibility training has been completed. The Food Bank will complete these corrective actions on or before June 30, 2026. Individuals responsible for corrective action: Elizabeth Cervantes – Sr. Director of Product Acquisition and Agency Relations 323.974.0073 Hilda Ayala – Sr. Director of Programs and Policy 323.353.0114 Steven Meisberger – Chief Financial Officer 323.318.0319
Finding 2025-005 Lack of Internal Control over Special Tests and Provisions- Character Investigations Name of Contact Person: Alexis Russell, Human Resource Director Corrective Action: Background check verification will be added into the employee onboarding process for all Annette Island Service Uni...
Finding 2025-005 Lack of Internal Control over Special Tests and Provisions- Character Investigations Name of Contact Person: Alexis Russell, Human Resource Director Corrective Action: Background check verification will be added into the employee onboarding process for all Annette Island Service Unit employees to ensure required character investigations are completed and documented for all positions subject to Indian Child Protection and Family Violence Prevention Act requirements. In addition, Human Resources will conduct periodic internal reviews of personnel files to indentify and address any missing background check documentation for current employees Proposed Completion Date: Implemented in FY2026, ongoing monitoring in place.
Finding 1217346 (2025-004)
Material Weakness 2025
Internal Control Over Reporting Department of Human Services – Grants to States for Medicaid – Assistance Listing No. 93.778 Recommendation: We recommend the county implement processes and procedures to ensure all reports have a timely review documented by someone other than the preparer. Explanatio...
Internal Control Over Reporting Department of Human Services – Grants to States for Medicaid – Assistance Listing No. 93.778 Recommendation: We recommend the county implement processes and procedures to ensure all reports have a timely review documented by someone other than the preparer. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: County will continue to train staff to ensure they are aware of the requirements. Names of the contact person responsible for corrective action: Denise Gaida, Auditor- Treasurer Planned completion date for corrective action plan: December 31, 2026
Finding 2025-002- Eligibility- Significant Deficiency in Internal Controls over Compliance and Non-Compliance Federal Program: Home Investment Partnerships Program (HOME) Assistance Listing Number: 14.239 Year(s): 2025 Federal Agency: Department of Housing and Urban Development (HUD) Pass-Through Ag...
Finding 2025-002- Eligibility- Significant Deficiency in Internal Controls over Compliance and Non-Compliance Federal Program: Home Investment Partnerships Program (HOME) Assistance Listing Number: 14.239 Year(s): 2025 Federal Agency: Department of Housing and Urban Development (HUD) Pass-Through Agencies: Idaho Housing and Finance Association Responsible Party: Jeanne Stromberg, Major - Divisional Finance Secretary-Cascade Division 916-501-6374 RESPONSE: Management will implement a review and approval process to ensure all documentation for applications is maintained in the file and that all applications that are eligible tor participation are properly approved. Effective Date: November 2026
2025-005: WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Pass-Through Agency: Direct award Grantor Number: Not applicable Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in...
2025-005: WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Pass-Through Agency: Direct award Grantor Number: Not applicable Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions – Wage Rate Requirements Repeat Finding: Yes. Same as finding 2024-001 and 2023-002. Criteria or Specific Requirement: Federal regulations require that contractors and subcontractors performing work on federally funded construction projects pay laborers and mechanics wages at rates not less than those prevailing on similar projects in the locality. These requirements are established under the Davis-Bacon Act and incorporated into federal grant compliance requirements under 2 CFR Part 200. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly per 29 CFR 5.5 compliance provisions. Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for one of 2 contractors that were tested and funded under the Impact Aid program, we noted that the District did not obtain or review certified payroll reports from contractors to verify compliance with federal prevailing wage requirements. As a result, the District could not demonstrate that contractors complied with required wage provisions for the sampled projects. Corrective Action: The District will ensure wage rate requirements are maintained for all vendors as appropriate under Uniform Guidance and the provision of the Davis Bacon Act. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Kay Morris, Superintendent
By expanding our internal and/or contracted accounting capacity and updating internal controls and accounting processes to include these new roles in the monthly and annual workflow, the Organization will be in better position to perform timely reconciliations and adjustments to federal grant activi...
By expanding our internal and/or contracted accounting capacity and updating internal controls and accounting processes to include these new roles in the monthly and annual workflow, the Organization will be in better position to perform timely reconciliations and adjustments to federal grant activity, ensuring timely filling of the data collection form and single audit package.
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over HQS enforcement by implementing procedures to track and monitor HQS deficiencies and required correction timelines. Explanation of disagreement with audit f...
Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over HQS enforcement by implementing procedures to track and monitor HQS deficiencies and required correction timelines. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PBCHA has made significant improvements in inspection compliance and will continue to monitor its third-party inspection vendor to ensure timely submission of inspection reports. The agency will utilize Yardi and other centralized tracking systems to monitor inspection due dates and follow-up activities, ensuring inspections are completed in accordance with HUD requirements. PBCHA will also provide ongoing staff training to reinforce NSPIRE requirements and compliance expectations. Name(s) of the contact person(s) responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2026
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