Corrective Action Plans

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Finding 2025-001: Allowable Cost – Significant Deficiency in Internal Controls Over Compliance Program: Block Grants for Prevention and Treatment of Substance Abuse (ALN 93.959) Management Response: Management concurs with the finding. The exceptions identified resulted from a lapse in execution of ...
Finding 2025-001: Allowable Cost – Significant Deficiency in Internal Controls Over Compliance Program: Block Grants for Prevention and Treatment of Substance Abuse (ALN 93.959) Management Response: Management concurs with the finding. The exceptions identified resulted from a lapse in execution of established approval procedures, as 2 of the 25 sampled credit card transactions charged to the grant did not include documented supervisory approval prior to payment. However, compensating controls existed, including Finance Department review of all expenditures prior to payment of the Brex account and additional review of expenses charged to the grant during preparation of monthly grant invoices and reporting. No unallowable costs or, questioned costs, were identified. To remediate the finding, all supervisors have received additional training and reminders regarding requirements for timely review and approval of expenditures prior to payment processing. In addition, the accounting team has implemented procedures prohibiting payment processing until all required approvals have been completed and documented. Management believes these enhanced controls strengthen adherence to existing policies and reduce the likelihood of recurrence. Management notes that the supervisor associated with the exceptions is no longer employed by the Organization; however, corrective actions focus on strengthening processes and controls rather than reliance on personnel changes. Corrective Action Planned/Implemented: • Refresher training provided to supervisors regarding expenditure review and approval requirements. • Accounting procedures updated to prevent payment processing prior to completion and documentation of all required approvals. • Existing accounting department monitoring procedures will continue, including review of expenditures before payment and grant expenditure review during monthly reporting. Responsible Party: Controller / Accounting Department Implementation Date: Implemented as of April 2026
Delivering Evidence-Led inTerventions in Arkansas to Advance Healthy Equity and Access in Diabetes Care (DELTA AHEAD) Recommendation: We recommend the Organization review its policies and procedures during the check signing process to ensure all approvals are obtained as required by the Organization...
Delivering Evidence-Led inTerventions in Arkansas to Advance Healthy Equity and Access in Diabetes Care (DELTA AHEAD) Recommendation: We recommend the Organization review its policies and procedures during the check signing process to ensure all approvals are obtained as required by the Organization's internal control policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Accounting staff will review the policies, procedures, and workflow with ADCES and grant-focused staff to ensure there is a common understanding across the organization. Name of the contact person responsible for corrective action: Matthew Biecker, Chief Financial Officer Planned completion date for corrective action plan: Immediately
2025-005 - Reporting Corrective Action Plan: Management agrees with the finding and has committed the resources giving rise to the finding. Person(s) Responsible: M. Michael Garza Timing for Implementation: June 30, 2026.
2025-005 - Reporting Corrective Action Plan: Management agrees with the finding and has committed the resources giving rise to the finding. Person(s) Responsible: M. Michael Garza Timing for Implementation: June 30, 2026.
Recommendation: We recommend that First Rising Mount Zion Baptist Church Housing Corporation, Inc. design and implement controls to prevent non-compliance with HUD requirements surrounding surplus cash deposits such as recalculating surplus cash at the end of the year after all transactions have bee...
Recommendation: We recommend that First Rising Mount Zion Baptist Church Housing Corporation, Inc. design and implement controls to prevent non-compliance with HUD requirements surrounding surplus cash deposits such as recalculating surplus cash at the end of the year after all transactions have been posted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: First Rising Mount Zion Baptist Church Housing Corporation, Inc. T/A Gibson Plaza Apartments will implement enhanced internal controls to ensure compliance with HUD requirements related to surplus cash calculations and deposits. Specifically: - Management will perform a final recalculation of surplus cash at year-end after all accounting transactions have been recorded and reviewed. - A standardized checklist will be developed and utilized to ensure that all required steps in the surplus cash calculation process are completed accurately. - The surplus cash calculation will be reviewed and approved by a secondary individual independent of the preparer to ensure accuracy and compliance. Name(s) of the contact person(s) responsible for corrective action: Asa Ewings Planned completion date for corrective action plan: 5/31/2026
Significant Deficiency, Nonmaterial Non-Compliance Finding 2025-005: Name of Contact Person: Bill Bradley The Town did not have a system of internal controls in place to ensure cash management compliance requirements were met. Auditor’s review indicated that a reimbursement request #4 was drawn and ...
Significant Deficiency, Nonmaterial Non-Compliance Finding 2025-005: Name of Contact Person: Bill Bradley The Town did not have a system of internal controls in place to ensure cash management compliance requirements were met. Auditor’s review indicated that a reimbursement request #4 was drawn and received in August yet the Town did not disburse the funds, until September. Therefore, the monies were not paid to the vendor within the three (3) day required compliance period. Corrective Action: With the new Town Manager and Finance Director the Town fully expects to comply with the three (3) day compliance requirement Proposed Completion Date: Immediately.
Views of Responsible Officials: The Foundation will retroactively receive the FFATA reports for their sub-recipients, and going forward will ensure that the FFATA reports are received and submitted for all sub-recipients.
Views of Responsible Officials: The Foundation will retroactively receive the FFATA reports for their sub-recipients, and going forward will ensure that the FFATA reports are received and submitted for all sub-recipients.
Diabetes, Digestive, and Kidney Diseases Extramural Research (ALN 93.847) Recommendation: We recommend that the Organization reviews the dates of costs incurred before charging costs to their Federal award and that evidence of this review is retained. Explanation of disagreement with audit finding: ...
Diabetes, Digestive, and Kidney Diseases Extramural Research (ALN 93.847) Recommendation: We recommend that the Organization reviews the dates of costs incurred before charging costs to their Federal award and that evidence of this review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented procedure enhancements to its review and processing of grant-related costs to better detect and prevent costs being charged outside of the period of performance. Including: the period charged for costs is based on expected receipt date of the goods or services being charged; a threestep/tiered review process of costs to be charged prior to the processing of such costs; a periodic review of the periods in which costs were charged for proper period alignment. Name of the contact person responsible for corrective action: Mahtab Khan Planned completion date for corrective action plan: May 2026
Blood Diseases and Resources Research (ALN 93.839) Recommendation: We recommend that the Organization reviews their calculations around payroll costs before drawdowns and that evidence of this review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit...
Blood Diseases and Resources Research (ALN 93.839) Recommendation: We recommend that the Organization reviews their calculations around payroll costs before drawdowns and that evidence of this review is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is in the process of implementing an upgraded grants payroll allocation costs software (Paas 2.0) that contains system controls that will detect payroll changes and automatically update, thus preventing such errors in the future. In addition to these automated software controls, management will implement review procedures in parallel as a secondary measure of control to detect and prevent such errors. Management anticipates the implementation and completion of the software project and related procedures in July 2026. Name of the contact person responsible for corrective action: Mahtab Khan Planned completion date for corrective action plan: July 2026
Audit Finding Reference: 2025 - 001 Planned Corrective Action: BRHP continues weekly reporting of all 50058 actions to identify any files where the 60-day deadline is approaching. PIC uploads continue to occur weekly. Starting this year and going forward, if any files approach or exceed the 60-day s...
Audit Finding Reference: 2025 - 001 Planned Corrective Action: BRHP continues weekly reporting of all 50058 actions to identify any files where the 60-day deadline is approaching. PIC uploads continue to occur weekly. Starting this year and going forward, if any files approach or exceed the 60-day submission threshold, the effective date will be revised as necessary, and any associated costs will be absorbed by BRHP to ensure that clients are held harmless. Name of Contact Person: FaShaunDa Walton, Housing Mobility Director, fwalton@brhp.org Anticipated completion date: December 31, 2026
Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.
Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.
Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee...
Federal Program: Consolidated Health Centers Grant Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that all documentation supporting the sliding discount provided is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization identified challenges and errors in the prior eligibility workflow after the 2024 audit. Over the course of 2025, the Organization experienced turnover in management and front desk personnel in the dental department. The workflows were modified when the new eligibility manager joined the Organization. Upon hiring a new dental manager and patient access (front desk) manager, workflows and procedures were also modified to ensure the front desk reviews insurance coverage upon check in. The system is set up so the Organization does not need manually adjust all claims, so the claim was auto-posted for the visit identified above. Our corrective action plan is already established, although it was put into place after the date of service of the visit identified above. If the U.S. Department of Health and Human Services has questions regarding this plan, please call Amanda Craig, CFO, at 970-710-5062.
Finding 2025-003 Duplicate expenditures charged to same grant Recommendation: We recommend the District establish and maintain proper review procedures for expenditures charged to grants prior to submission for reimbursement. Management’s View: The District will strengthen internal controls over pay...
Finding 2025-003 Duplicate expenditures charged to same grant Recommendation: We recommend the District establish and maintain proper review procedures for expenditures charged to grants prior to submission for reimbursement. Management’s View: The District will strengthen internal controls over payroll expenditures charged to federal grants by implementing a standard operating procedure that will be conducted by the Payroll Specialist of verifying payroll distribution reports, funding codes, and supporting documentation prior to submission for payment. Before each payroll is finalized, the payroll specialist will run a payroll report that will be generated and sorted by employee to verify that no duplicate charges have been applied to the same grant within the same payroll period. This review will ensure that all costs charged to federal grants during the pay period are accurate, allowable, properly coded, and not duplicated. No payroll adjustments will be keyed until timesheets have been verified against previously submitted timesheets and that they are reviewed to confirm that prior entries have not already been charged to the same grant. Additionally, a secondary review by the accountant will be conducted prior to finalizing grant-related payrolls. Effective March 1, 2026, the Payroll Accountant and Chief Financial Officer will review grant-related payroll transactions to ensure accuracy, proper funding allocation, and compliance with applicable federal requirements. Effective Date: March 1, 2026 Contact Person: Sylvia Garza, Chief Financial Officer, Edcouch-Elsa Independent School District
Late Single Audit Submission Description of Finding Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months af...
Late Single Audit Submission Description of Finding Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The Single Audit packages for the City’s fiscal years 2022-2025, were not submitted timely to the Federal Audit Clearinghouse. Statement of Concurrence or Nonconcurrence Management agrees with the finding. Corrective Action Management will review existing processes and controls related to audit readiness and financial reporting to ensure that all required financial reports are submitted timely. The City will implement a formal audit and Single Audit submission calendar with defined internal deadlines, assign clear staff responsibilities for preparing and submitting required documents, and use a centralized tracker to monitor audit milestones and ensure timely submission to the Federal Audit Clearinghouse. Staff involved in federal reporting will also receive annual training on Single Audit requirements to ensure compliance with federal timelines going forward. Name of Contact Person Shannon McCue, City Budget Director Projected Completion Date June 30, 2026
Condition: The Organization was reimbursed $22,968 under the grant award for amounts incurred subsequent to the performance year of the grant. The control in place to review expenditures was not effective in identifying expenditures that were outside the grant period. Planned Corrective Action: The ...
Condition: The Organization was reimbursed $22,968 under the grant award for amounts incurred subsequent to the performance year of the grant. The control in place to review expenditures was not effective in identifying expenditures that were outside the grant period. Planned Corrective Action: The Organization will implement enhanced review procedures of federal expenditures sought for reimbursement to better align with the underlying accounting treatment. Contact person responsible for corrective action: David Anderson Anticipated Completion Date: September 30, 2026
Community Development Block Grants Cluster Entitlements/Special Purpose – Assistance Listing No. 14.218 Recommendation: It is recommended the County modify its procedure to include: • Improve reconciliation procedures to verify hours per pay period recorded in quarterly spreadsheet agrees to hours r...
Community Development Block Grants Cluster Entitlements/Special Purpose – Assistance Listing No. 14.218 Recommendation: It is recommended the County modify its procedure to include: • Improve reconciliation procedures to verify hours per pay period recorded in quarterly spreadsheet agrees to hours recorded in the KRONOS system. • Record grant wages using the pay rate at the beginning of the quarter if recorded on a quarterly basis or use pay rates for each pay period if recorded on a pay period basis. Explanation of disagreement with audit finding: Management concurs with the auditor’s recommendations. Action taken in response to finding: • Document the audit process in a formalized SOP and cross train all reviewers from SRGA Admin, Budget, and Fiscal. • Create a checklist to accompany each personnel draw to ensure that after rates are verified that SRGA Admin certify that no RPAs or pay adjustments were approved during the pay periods reported and if there were, a second pay rate is entered for that draw and hours are split according to accurate rates/dates. • Document the cure process in the SOP to ensure that any errors found after the fact will be corrected with HUD to remain compliant and to ensure that no funds drawn in error are retained. • Include a date verification process prior to submission of the draw to ensure that staff did not duplicate any dates. This verification will be an audit of the Time Tracking Review completed by Admin staff. Ongoing training and coaching will be administered should duplicate entries be found on final draw reports. • Audit of all personnel draws for both allocations of CDBG-DR grants will be completed using the new SOP and verification tools before the end of FY2026. Name of the contact person responsible for corrective action: Nicole Turner, Director Planned completion date for corrective action plan: The above action plan will be implemented immediately; an audit of all personnel draws will be conducted using new process and checklists by the end of FY2026.
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Central Valley School District No. 356 September 1, 2024 through August 31, 2025 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Central Valley School District No. 356 September 1, 2024 through August 31, 2025 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility requirements. Name, address, and telephone of District contact person: Mathew Knott, Director of Business Services 2218 N. Molter Road Liberty Lake, WA 99019 509-558-5437 Corrective action the auditee plans to take in response to the finding: The District does agree that one school with a poverty rate above 75% was not served. However, OSPI reviewed and approved the District’s Title I application, including our proposed ranking and allocation methodology, and no concerns or comments were raised during that review process. Additionally, the District was able to provide alternative snapshot dates demonstrating that no individual school was truly above the 75% threshold. Once the District became aware of the issue, we proactively contacted OSPI to determine whether any corrective action was necessary for the current year. OSPI’s guidance was that no changes or corrections were required for the current year and that adjustments should instead be implemented in the following year if a school exceeded the 75% threshold. Based on that direction from OSPI, the District did not make current-year corrections. Given these circumstances, including OSPI’s prior approval of the application and subsequent guidance that no corrective action was required, the District respectfully disagrees with the State Auditor’s Office conclusion that this matter rises to the level of a Finding rather than being addressed through a Management Letter. We consider this matter to be resolved as no school going into the 2025-2026 fiscal year was above the 75% threshold. Anticipated date to complete the corrective action: 8/31/2025
Continuum of Care Assistance Listing No. 14.267 Payroll Disbursements Recommendation: We recommend that LAHSA implement procedures to ensure that timesheet approval is documented timely. Explanation of disagreement with audit finding: There is no disagreement withthe audit finding. Action taken in r...
Continuum of Care Assistance Listing No. 14.267 Payroll Disbursements Recommendation: We recommend that LAHSA implement procedures to ensure that timesheet approval is documented timely. Explanation of disagreement with audit finding: There is no disagreement withthe audit finding. Action taken in response to finding: LAHSA has enhanced its internal controls over timesheet approvals to ensure timely documentation. Timesheet approval status reports are reviewed on a weekly basis during Chief level meetings to monitor compliance. Timesheets not approved within two days of the established deadline are escalated to the respective Chief and Deputy Chief for immediate follow-up. If timesheets remain unapproved after an additional two days, the matter is further escalated to the CEO, for prompt resolution. These procedures establish clear accountability and escalation protocols to ensure timely approval of timesheets Names of the contact persons responsible for corrective action: Gita O'Neill, Keshia Douglas, Christopher Williams, and Paul Rubenstein. Planned completion date for corrective action plan: Implemented
Corrective Action: Preschool Promise, Inc. recognizes the importance of maintatining written procurement procedures in compliance with Uniform Guidance. In response to this finding, management has taken the following corrective actions. Developed and adopted a written procurement policy compliant wi...
Corrective Action: Preschool Promise, Inc. recognizes the importance of maintatining written procurement procedures in compliance with Uniform Guidance. In response to this finding, management has taken the following corrective actions. Developed and adopted a written procurement policy compliant with 2 CFR Part 200, 200.317-200-327. The policy defines procurement methods and applicable thresholds, documentation standards, competitive bidding requirements, conflict-of-interest provisions, contract oversight expectations, and record retention requirements. Implemented the policy orgainzation-wide for procurements funded by federal awards to promote consistent applicaiton and compliance. Provided training to management and staff responsible for purchasing and vendor selection. Established procedures to review and update the procurement policy periodically to ensure ongoing compliance with federal regulations. These actions are intended to strengthen internal controls over procurement and prevent recurrence of this finding in future periods. Responsible party Robyn Lightcap Executive Director and Marie Giffen Senior Director of Finance. Anticipated Completion Date: Completed during fiscal year 2026
Audit Finding Reference: 2025-001 Timely Filing of Single Audit Report Planned Corrective Action: The Organization understands it is the responsibility of the Organization to ensure the Single Audit Report is filed timely, At the beginning of the audit process, the Organization will establish an agr...
Audit Finding Reference: 2025-001 Timely Filing of Single Audit Report Planned Corrective Action: The Organization understands it is the responsibility of the Organization to ensure the Single Audit Report is filed timely, At the beginning of the audit process, the Organization will establish an agreed timeline with its auditors and the Organization will produce documentation consistent with that timeline. Planned Implementation Date of Corrective Action: April 21, 2026 Person Responsible for Corrective Action: Mike Stuard, Director of Finance
CORRECTIVE ACTION PLAN 2025-001- REPORTING Significant Deficiency/Noncompliance Auditee’s Response and Planned Corrective Action The Newburyport Housing Authority submitted audit documentation late due to the Executive Director, Tracy Watson, being on medical leave since August 2025. During this tim...
CORRECTIVE ACTION PLAN 2025-001- REPORTING Significant Deficiency/Noncompliance Auditee’s Response and Planned Corrective Action The Newburyport Housing Authority submitted audit documentation late due to the Executive Director, Tracy Watson, being on medical leave since August 2025. During this time, staff experienced difficulties obtaining the required documentation needed to complete the audit in a timely manner. The NHA Board of Commissioners named Kim Kane as Interim Executive Director during Tracy Watson’s absence. Kim Kane will ensure all documentation is submitted in full and in a timely manner. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Kim Kane, Interim Executive Director
Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding Lincoln Public Schools procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or ...
Significant Deficiency in Internal Control over Compliance, Other Matters Description of Finding Lincoln Public Schools procurement standards do not include the essential elements as outlined in 2 CFR sections 200.303, and 200.318 through 200.326 within Uniform Guidance. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management will update Lincoln Public Schools’ procurement policies to include all essential elements to be in compliance with Uniform Guidance.
We agree with Finding 2025-004 and the recommendations described above. We will work to implement additional controls over financial reporting to ensure the financials are submitted in a timely manner.
We agree with Finding 2025-004 and the recommendations described above. We will work to implement additional controls over financial reporting to ensure the financials are submitted in a timely manner.
Foster Grandparent Program – Assistance Listing No. 94.011 Recommendation: The organization should ensure proper eligibility verifications are performed for all current and potential program participants to ensure all program participants are eligible. Explanation of disagreement with audit finding:...
Foster Grandparent Program – Assistance Listing No. 94.011 Recommendation: The organization should ensure proper eligibility verifications are performed for all current and potential program participants to ensure all program participants are eligible. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will ensure moving forward that eligibility verifications are performed for all participants in a timely manner as specified by the grant requirements. Name(s) of the contact person(s) responsible for corrective action: Andrew Johannes, CFO Planned completion date for corrective action plan: 12/31/2026
2025-002: Inadequate Controls Related to Wage Rate Requirements Condition: Of the five contracts included within major program 20.205 in the current year, two were subject to the wage rate requirement. These two contracts accounted for $1.9M of the $4M total program expenditures. In total there were...
2025-002: Inadequate Controls Related to Wage Rate Requirements Condition: Of the five contracts included within major program 20.205 in the current year, two were subject to the wage rate requirement. These two contracts accounted for $1.9M of the $4M total program expenditures. In total there were 13 weeks of payroll included within the two contracts, of which three were selected for testing. The internal control failure occurred due to the timing of the invoices in relation to year end close procedures. Payment was accelerated to capture both the expense and cash outlay within the same fiscal year overlooking the need to confirm the receipt of the certified payrolls. Corrective Action Taken or Planned: Prior to submitting any invoices that are reimbursable with federal funds, the accounting staff will verify in writing that the vendor’s certified payrolls have been received and reviewed. Additionally, a newly created Federally Funded Invoice and Payment Compliance Checklist form has been created. This form will be completed and submitted with the approved invoice for payment. Person Responsible for Corrective Action: Mark Rozum, Treasurer/Comptroller Anticipated Completion Date for Corrective Action: The corrective action has already started and will be fully implemented within 30 days in response to the auditor’s recommendations.
April 23, 2026 Cognizant or Oversight Agency for Audit South Coastal Counties Legal Services, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street ...
April 23, 2026 Cognizant or Oversight Agency for Audit South Coastal Counties Legal Services, Inc. and Affiliate respectfully submits the following corrective action plan for the year ended December 31, 2024. Name and address of independent public accounting firm: AAFCPAs, Inc. 50 Washington Street Westborough, MA 01581 Audit Period: January 1, 2025 - December 31, 2025 The findings from April 22,2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDING - FINANCIAL STATEMENT AUDIT FINDING SIGNIFICANT DEFICIENCY 2024-001 Seperation of Justice Center Recommendation: We recommend management examine their internal processes and policies on how activities for both entities are seperately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a correction action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2026. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and developed a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to ensure that compliance with the corective action plan will result in adequate separation between entities under Title 45 of the Code of Federal Regulations. Mulitple aspects of the plan has been implemented, with full compliance expected in 2026. FINDING - FEDERAL AWARD PROGRAM AUDIT SIGNIFICANT DEFICIENCY LEGAL SERVICES CORPORATION 2024-001 Seperation of the Justice Center The significant deficiency relates to the Federal Funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under assistance listing number 09.112087. Recommendation: We recommend management examine their interal processes and policies on how activies for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a corrective action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and develiped a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to enure that compliance with the correction action plan with result in adequate separation between entities under Title 45 of the Code of Fedearl Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2026. If Legal Services Corporation has questions regarding this plan, please call Christopher Oldi, Executive Director at (774) 488-5950 2023-001 Seperation of the Justice Center The significant deficiency relates to the Federal Funds received from Legal Services Corporation (LSC), Basic Field Grant, grant recipient #122087, under assistance listing number 09.112087. Recommendation: We recommend management examine their interal processes and policies on how activies for both entities are separately accounted for to ensure proper separation consistent with LSC requirements. We understand management has submitted a corrective action plan and has been working with LSC and has already implemented several recommendations from the review and is expected to finalize and implement any remaining required recommendations in 2025. We further understand that LSC has not demanded a formal deadline for completion of the Program Integrity Review and the the Organization is not unreasonably delayed in its implementation of any corrective actions. Action Taken: SCCLS prepared and develiped a corrective action plan with LSC and has met with LSC on a bi-weekly basis working with LSC to enure that compliance with the correction action plan with result in adequate separation between entities under Title 45 of the Code of Fedearl Regulations. Multiple aspects of the plan have been implemented, with full compliance expected in 2026. If Legal Services Corporation has questions regarding this plan, please call Christopher Oldi, Executive Director at (774) 488-5950 Sincerely yours, Christopher Oldi Executive Director
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