Corrective Action Plans

Finding 518290 (2022-001)

Significant Deficiency 2022

Central Alabama Regional Planning and Development Commission

AL

Significant Deficiency Internal Control / Segregation of Duties § 200.302

Finding 2022-001: The Central Alabama Regional Planning & Development Commission (the Commission) will develop a grants manual or additional written policies to incorporate all the requirements of 2 CFR 200 and ensure compliance with grant requirements.

View Audit 336628

Finding 518137 (2022-001)

Material Weakness 2022

Nebraska Children's Home Society

NE

Subrecipient Monitoring Questioned Costs Reporting

For Fiscal Year 2023 there was limited time available for any changes to be made or procedures to be put in place as there was a significant staff change over within Finance. The new Finance Director has since implemented a new financial software with proper coding available to track all funding. Th...

For Fiscal Year 2023 there was limited time available for any changes to be made or procedures to be put in place as there was a significant staff change over within Finance. The new Finance Director has since implemented a new financial software with proper coding available to track all funding. There is a new contract and grants management procedure to be managed by the Finance Director and the Contracts and Grants Manager, for proper initial review with quarterly review at a minimum for tracking. All billing and revenue are reviewed monthly with appropriate parties as well. This was fully implemented as of July 1, 2023, the start of FY24.

View Audit 336455

Finding 516996 (2022-005)

Significant Deficiency 2022

MacOmb County

MI

Questioned Costs Reporting Significant Deficiency

All staff members in the department that administers the grant in question that can file the report in question have now been provided proper acccess to the reporting portal.

View Audit 334902

Finding 516657 (2022-004)

Significant Deficiency 2022

California Asian Pacific Chamber of Commerce

CA

Allowable Costs / Cost Principles Significant Deficiency § 200.400

Description of Finding: The allocation of payroll costs to programs are done manually instead of done based on entity-wide timesheets Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian ackno...

Description of Finding: The allocation of payroll costs to programs are done manually instead of done based on entity-wide timesheets Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian acknowledges the serious nature of this finding and the potential for damage to relationships with the grantors and Federal entities. The Interim Controller and Director of Finance are currently implementing an ERP system which will allow for better cost collection, reporting and reviews of the grant-related expenses for accuracy, reliability, and reconciliation. We also understand these findings are repetitive from the 2021 audit; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2022 audit. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. A subcontractor has been retained to assist with providing information for the 2023 audit to bring the audits current. The ERP system includes electronic timesheets for daily charging to specific grants, as well as more visibility into the proper separation of direct, indirect, and unallowable costs per the CFR. Timesheet training has been performed and timesheet completion is required for all employees each day. This will begin on 1/1/2025 and will provide support for hours worked/billed, as well as document the certification and approvals that all time entered is accurate and in compliance with contract requirements. and provide proper support for all grant labor costs and indirect costs. An indirect cost pool allocation structure is being designed and implemented to properly allocate the allowable indirect costs to each work effort, including Fringe, Overhead and G&A. This proposed structure and rates will be submitted for approval in 2025 for use in billing the contracts properly. Monthly reviews by the Project Directors/Managers plus Accounting will be performed to identify any potential cost charging issues and corrective action(s) required. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Susan Wright, Controller, 256-689-7055, swright@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: January 2025

View Audit 334631

Finding 514552 (2022-008)

Significant Deficiency 2022

Housing Authority of the City of Pueblo

CO

HUD Housing Programs Questioned Costs Special Tests & Provisions

U.S. Department of Housing and Urban Development – CFDA #14.872 Capital Fund Program – 2022 Special Tests and Provisions – Environmental Reviews Significant Deficiency in Internal Control over Compliance Finding Summary: Testing indicated that there has not been an environmental review performed on ...

U.S. Department of Housing and Urban Development – CFDA #14.872 Capital Fund Program – 2022 Special Tests and Provisions – Environmental Reviews Significant Deficiency in Internal Control over Compliance Finding Summary: Testing indicated that there has not been an environmental review performed on 3 of 4 projects within the last 5-year period as required by HUD. Responsible Individual: Steven Trujillo, Executive Director Corrective Action Plan: The major project we are working on complied, but our smaller projects were not in compliance. We will make a point of getting this review completed as soon as possible and create a reminder to ensure it will be completed in a timely manner in the future. Anticipated Completion Date: January 2024

View Audit 332864

Finding 514551 (2022-007)

Significant Deficiency 2022

Housing Authority of the City of Pueblo

CO

Internal Control / Segregation of Duties Questioned Costs Special Tests & Provisions

U.S. Department of Housing and Urban Development – CFDA #14.872 Capital Fund Program – 2022 Special Tests and Provisions – Capital Funds for Operating Costs Significant Deficiency in Internal Control over Compliance Finding Summary: Testing indicated that there was not a consistent, documented proce...

U.S. Department of Housing and Urban Development – CFDA #14.872 Capital Fund Program – 2022 Special Tests and Provisions – Capital Funds for Operating Costs Significant Deficiency in Internal Control over Compliance Finding Summary: Testing indicated that there was not a consistent, documented process to ensure the timely obligation and expenditure of program funds to remain in compliance. Responsible Individual: Steven Trujillo, Executive Director Corrective Action Plan: Even though we had meetings, the process in 2022 was not documented very well. We now document our regular meetings indicating that we are monitoring the use/obligation of funds that will ensure the funding is spent or obligated in a timely manner. Anticipated Completion Date: January 2023

View Audit 332864

Finding 514547 (2022-003)

Significant Deficiency 2022

Housing Authority of the City of Pueblo

CO

HUD Housing Programs Internal Control / Segregation of Duties Questioned Costs

U.S. Department of Housing and Urban Development – CFDA #14.871 Section 8 Housing Choice Vouchers Special Test and Provisions – Reasonable Rent Significant Deficiency in Internal Control over Compliance Finding Summary: During our testing for reasonable rent, we identified 10 instances when the Auth...

U.S. Department of Housing and Urban Development – CFDA #14.871 Section 8 Housing Choice Vouchers Special Test and Provisions – Reasonable Rent Significant Deficiency in Internal Control over Compliance Finding Summary: During our testing for reasonable rent, we identified 10 instances when the Authority did not maintain records to document the basis for the determination that rent to owner is reasonable rent. Responsible Individual: Steven Trujillo, Executive Director Corrective Action Plan: During 2022 the Authority experienced significant staff turnover and the appropriate steps, to maintain documentation of the reasonable rent calculation were not followed, therefore we did not ensure compliance with the program. The Housing Authority has implemented a process that requires proper documentation to be maintained when the reasonable rent calculation is completed. Anticipate Completion Date: January 2023

View Audit 332864

Finding 514396 (2022-006)

Significant Deficiency 2022

Kingston Housing Authority

NY

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Finding 2022-006 - Recording of Declaration of Trust Against Public Housing Property - PH Auditee's Response and Planned Corrective Action The Authority will work to complete and/or locate the required Declaration of Trust documents for all PHA properties and seek direction from HUD, as needed. All...

Finding 2022-006 - Recording of Declaration of Trust Against Public Housing Property - PH Auditee's Response and Planned Corrective Action The Authority will work to complete and/or locate the required Declaration of Trust documents for all PHA properties and seek direction from HUD, as needed. All Declaration of Trust documentation will be maintained in an accessible location once complete. The Authority agrees with the findings, however, the Authority no longer administers the Public Housing Program due to the Section 22 conversion, so no further corrective action is applicable. Planned Implementation Date of Corrective Action: December 31, 2024 Person Responsible for Corrective Action: Harolda A. Wilcox, Executive Director

View Audit 332669

Finding 514395 (2022-005)

Significant Deficiency 2022

Kingston Housing Authority

NY

HUD Housing Programs Eligibility Significant Deficiency

Finding 2022-005 -Tenant Files - PH Auditee's Response and Planned Corrective Action The Authority will establish a checklist covering all Public Housing compliance requirements for tenants for the Tenant Housing Representatives to use during the move-in and recertification process which will be sig...

Finding 2022-005 -Tenant Files - PH Auditee's Response and Planned Corrective Action The Authority will establish a checklist covering all Public Housing compliance requirements for tenants for the Tenant Housing Representatives to use during the move-in and recertification process which will be signed by the Tenant Housing Representative and a supervisor or member of management. The checklist will be maintained in each tenant's file. The Authority agrees with the findings, however, the Authority no longer administers the Public Housing Program due to the Section 22 conversion, so no further corrective action is applicable. Planned Implementation Date of Corrective Action: December 31, 2024 Person Responsible for Corrective Action: Harolda A. Wilcox, Executive Director

View Audit 332669

Finding 514394 (2022-004)

Significant Deficiency 2022

Kingston Housing Authority

NY

HUD Housing Programs Eligibility Significant Deficiency

Finding 2022-004 -Tenant Files - HCV Auditee's Response and Planned Corrective Action The Authority will establish a checklist covering all Section 8 compliance requirements for tenants for the Tenant Housing Representatives to use during the move-in and recertification process which will be signed ...

Finding 2022-004 -Tenant Files - HCV Auditee's Response and Planned Corrective Action The Authority will establish a checklist covering all Section 8 compliance requirements for tenants for the Tenant Housing Representatives to use during the move-in and recertification process which will be signed by the Tenant Housing Representative and a supervisor or member of management. The checklist will be maintained in each tenant's file. Planned Implementation Date of Corrective Action: January 31, 2025 Person Responsible for Corrective Action: Harolda A. Wilcox, Executive Director

View Audit 332669

Finding 514393 (2022-003)

Significant Deficiency 2022

Kingston Housing Authority

NY

HUD Housing Programs Significant Deficiency Special Tests & Provisions

Finding 2022-003 - HQS Enforcement - HCV Auditee's Response and Planned Corrective Action The Authority established a checklist to be used by the Tenant Housing Representatives during the HQS inspection process to ensure all failed inspections are followed up on and corrected timely. The list will b...

Finding 2022-003 - HQS Enforcement - HCV Auditee's Response and Planned Corrective Action The Authority established a checklist to be used by the Tenant Housing Representatives during the HQS inspection process to ensure all failed inspections are followed up on and corrected timely. The list will be signed and reviewed regularly. A listing of all failed inspections will be maintained. Planned Implementation Date of Corrective Action: January 31, 2025 Person Responsible for Corrective Action: Harolda A. Wilcox, Executive Director

View Audit 332669

Finding 514392 (2022-002)

Significant Deficiency 2022

Kingston Housing Authority

NY

HUD Housing Programs Reporting Significant Deficiency

Finding 2022-002 - Reporting - HCV Auditee's Response and Planned Corrective Action The Authority will implement procedures and controls sufficient to ensure all accounts are reconciled timely and the unaudited and audited financial information can be submitted to HUD timely. Planned Implementation ...

Finding 2022-002 - Reporting - HCV Auditee's Response and Planned Corrective Action The Authority will implement procedures and controls sufficient to ensure all accounts are reconciled timely and the unaudited and audited financial information can be submitted to HUD timely. Planned Implementation Date of Corrective Action: December 31, 2024 Person Responsible for Corrective Action: Harolda A. Wilcox, Executive Director

View Audit 332669

Finding 514065 (2022-005)

Significant Deficiency 2022

Leech Lake Tribal College

AZ

Questioned Costs Reporting Significant Deficiency § 200.328

The Department has ramped up recruiting efforts by advertising positions on external websites such as indeed. The accounting department has recently increased the wages of existing staff and the starting wages of all positions in an effort to attract and retain qualified staff.

View Audit 332259

Finding 514011 (2022-003)

Significant Deficiency 2022

Respond INC

NJ

Questioned Costs Allowable Costs / Cost Principles Reporting

The Agency will improve its financial reporting process so that it can submit its audit to New Jersey Funding Agencies and potentially its Single Audit Reporting Package to the federal clearinghouse, if required, no later than nine months after fiscal year-end

View Audit 332205

Finding 514008 (2022-002)

Significant Deficiency 2022

Respond INC

NJ

Subrecipient Monitoring Cash Management Reporting

The Agency has reviewed these findings and will strive to adhere to the suggested corrective plan in this audit report. Additionally, management plans to continue to aggressively implement structural cost-saving measures throughout the Agency.

View Audit 332205

Finding 513957 (2022-006)

Significant Deficiency 2022

Menard County, Illinois

IL

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

Approved methodologies for all types of grants and proper documentation shall be copied and maintained with all reports submitted to the grantor for the appropriate record retention requirement.

View Audit 332158

Finding 513953 (2022-004)

Significant Deficiency 2022

Menard County, Illinois

IL

Reporting Significant Deficiency

The Menard County Board of Commissioners will review and approve financial and performance reports prior to submission.

View Audit 332158

Finding 513036 (2022-002)

Significant Deficiency 2022

Anchorage Concert Association

AK

Internal Control / Segregation of Duties Questioned Costs Reporting § 200.512

Finding 2022-002 Significant Deficiency over Internal Control over Compliance, Noncompliance - Reporting Name of Contact Person: Willow Zamos, Business Manager; 907-272-1471 Planned Corrective Action: Anchorage Concert Association will establish additional controls when receiving future federal fund...

Finding 2022-002 Significant Deficiency over Internal Control over Compliance, Noncompliance - Reporting Name of Contact Person: Willow Zamos, Business Manager; 907-272-1471 Planned Corrective Action: Anchorage Concert Association will establish additional controls when receiving future federal funding to ensure a timely audit of the program(s) is performed. Anticipated Completion Date: Already implemented.

View Audit 330917

Finding 513035 (2022-001)

Significant Deficiency 2022

Anchorage Concert Association

AK

Allowable Costs / Cost Principles Questioned Costs Significant Deficiency

Finding 2022-001 Documentation of Approval - Allowable Costs – Significant Deficiency in Internal Control over Compliance Name of Contact Person: Willow Zamos, Business Manager; 907-272-1471 Planned Corrective Action: Anchorage Concert Association will improve procedures to ensure documentation of i...

Finding 2022-001 Documentation of Approval - Allowable Costs – Significant Deficiency in Internal Control over Compliance Name of Contact Person: Willow Zamos, Business Manager; 907-272-1471 Planned Corrective Action: Anchorage Concert Association will improve procedures to ensure documentation of invoice approval is retained in vendor files. Anticipated Completion Date: Already implemented.

View Audit 330917

Finding 512543 (2022-005)

Significant Deficiency 2022

Southwest Regional Development Commission

MN

Reporting Internal Control / Segregation of Duties Significant Deficiency

Management has reviewed the findings and taken steps in developing an internal control review process. The Commission implemented procedures to ensure all reports have proof of review and submission, as well as working towards submitting all reports timely.

View Audit 330368

Finding 511956 (2022-003)

Significant Deficiency 2022

Claiborne County School District

MS

Cash Management School Nutrition Programs Significant Deficiency

Deficiencies in controls surrounding the cash management and program income. A. Name of contact person responsible for corrective action: Name: Courtney Bershell Title: Business Manager B. Corrective action planned: The district will implement changes to ensure child nutrition management software be...

Deficiencies in controls surrounding the cash management and program income. A. Name of contact person responsible for corrective action: Name: Courtney Bershell Title: Business Manager B. Corrective action planned: The district will implement changes to ensure child nutrition management software be used to document and support the daily meal counts that will be used for claim reimbursements. C. Anticipated completion date: June 30, 2024.

View Audit 329673

Finding 509651 (2022-001)

Significant Deficiency 2022

St. Ambrose Housing Aid Center, Inc.

MD

Questioned Costs Reporting Significant Deficiency

On March 3rd, 2022, three months prior to the end of the St. Ambrose Housing Aid Center's fiscal year, management was notified by the previous auditors that their firm was discontinuing its audit practice and is discontinuing this line of business for all its clients. This news was totally unexpecte...

On March 3rd, 2022, three months prior to the end of the St. Ambrose Housing Aid Center's fiscal year, management was notified by the previous auditors that their firm was discontinuing its audit practice and is discontinuing this line of business for all its clients. This news was totally unexpected. Following this surprise announcement, management initiated a search for a new audit firm with the skills and experience to accurately review the books and records of a large nonprofit organization with diverse real property assets. Management ultimately identified and engaged SB & Company, LLC in August of 2022 to perform all audits of St. Ambrose Housing Aid Center, Inc., and subsidiaries. An additional challenge occurred when our CFO, who worked for the organization for eight years, submitted her resignation in July 2023. While we were pleased for the growth opportunity for our colleague, her departure left the organization in a tenuous position. Finding a replacement has been difficult, we have engaged a search firm, but it has been difficult to find someone with the required skillset who would accept our compensation package. The late notification of the previous auditor and the time-intensive process for identifying and engaging a new firm meant that St. Ambrose Housing Aid Center, Inc. would not be able to deliver a timely audit. Management acknowledges that it is the responsibility of the Company to maintain an adequate system of internal controls over the financial reporting to initiate, authorize, record, process and report financial data reliably in accordance with generally accepted accounting principles in the United States of America. Management maintains its books and records using an adequate system of internal controls currently. While our circumstances have been difficult, we have discussed a schedule with our auditor that we believe will allow the audit to be performed to improve our delivery for the year ending June 30, 2024. Contact Person: Gerard Joab Anticipated Implementation Date: December 1, 2024

View Audit 329287

Finding 509394 (2022-001)

None 2022

Clarkson University

NY

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Management acknowledges deficiencies in internal controls that resulted in a number of entries posted to correct previous improper postings. Management is implementing an action plan with measurable objectives to correct this deficiency. This action plan includes a review of current processes to ide...

Management acknowledges deficiencies in internal controls that resulted in a number of entries posted to correct previous improper postings. Management is implementing an action plan with measurable objectives to correct this deficiency. This action plan includes a review of current processes to identify opportunities to further limit manual data entry to limit key punch errors. Further, processes will be revised to include secondary review prior to posting. Quarterly data reviews will be utilized to identify developing variances for investigation and further action as necessary. A more robust system of account reconciliation will be developed, with particular attention to high activity and / or high value accounts. Finally, year end processes will continue to be enhanced to ensure proper and timely completion of consolidated financial statements.

View Audit 329168

Finding 505556 (2022-001)

Significant Deficiency 2022

Michigan Falun Dafa Association

MI

Reporting Subrecipient Monitoring Significant Deficiency § 200.501 § 200.512

Finding Number: 2022-001 Finding Type: Material noncompliance with laws and regulations and significant deficiency in internal controls over Federal awards. Criteria and Condition: Michigan Falun Dafa Association was required to have an audit in compliance with the requirements of 2 CFR Section 2...

Finding Number: 2022-001 Finding Type: Material noncompliance with laws and regulations and significant deficiency in internal controls over Federal awards. Criteria and Condition: Michigan Falun Dafa Association was required to have an audit in compliance with the requirements of 2 CFR Section 200.501 and submit its audit to the Federal Audit Clearinghouse as required by 2 CFR Section 200.512, which was due by September 30, 2023. Auditors’ Recommendation: The auditors recommended Michigan Falun Dafa Association’s strengthening of internal controls procedures over the award process to ensure that all existing and any new compliance requirements are communicated to all involved in the process to ensure timely adherence to all or any requirements. Michigan Falun Dafa Association’s Response to the Finding and Corrective Action Plan: This is the first year the Michigan Falun Dafa Association expended $750,000 or more of federal award received, and as a result, was not aware of the requirement for a compliance audit. Michigan Falun Dafa Association will strengthen its internal control processes and procedures to ensure that compliance requirements will be communicated to all involved in grant administration to ensure timely adherence to all or any requirements for any new grants received. Responsible Individuals: Zhiwei, Xu, President Xinhua Yu, Treasurer Planned Completion Date: Immediate.

View Audit 328259

Finding 504821 (2022-006)

Significant Deficiency 2022

Lake County

IN

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

FINDING 2022-006 Finding Subject: Emergency Rental Assistance Program -- Reporting Summary of Finding: Condition and Context: Recipients are required to submit FFATA (Federal Funding Accountability and Transparency Act) reporting through the FSRS (FFATA Subaward Reporting System) website to the U.S....

FINDING 2022-006 Finding Subject: Emergency Rental Assistance Program -- Reporting Summary of Finding: Condition and Context: Recipients are required to submit FFATA (Federal Funding Accountability and Transparency Act) reporting through the FSRS (FFATA Subaward Reporting System) website to the U.S. General Services Administration. This reporting is required to be completed for each action based on subawards of $30,000 or more that are made from the federal program. Information to be reported included the information contained within the subaward. The County did not have any policies or procedures in place related to the FFATA reporting requirements. During the audit period, the County was required to submit the FFATA reporting for one subaward that was over $30,000. The County, however, did not submit the required report on the FSRS website. Recommendation: We recommended that management of the County design and implement a proper system of internal controls, to ensure that all subrecipients awarded $30,000 or more are properly reported in accordance with FFATA reporting requirements. Contact Person Responsible for Corrective Action: Timothy A. Brown Contact Phone Number and Email Address: 219-755-3225 and brownta@lakecountyin.org Views of Responsible Officials: LCCEDD concurs with the audit finding. Description of Corrective Action Plan: LCCEDD staff will be preparing an amendment to the policy and procedures manual to follow the FFATA regulations for all of the department sub-recipients (social service agencies) including the CDBG partner communities. The process will include review of all sub-recipient agreements by the Deputy Director who will provide to the Fiscal Officer a copy of the approved and signed agreement. The Fiscal Officer will work with the Bookkeeper to record the agreements into the FFATA Subaward Reporting System (FSRS). LAKE COUNTY COMMUNITY ECONOMIC DEVELOPMENT DEPARTMENT 2293 N. Main Street - Crown Point, In 46307 Tel. (219) 755-3225 www.lakecountyin.org INDIANA STATE BOARD OF ACCOUNTS 43 Anticipated Completion Date: A policy and procedure amendment will be written by the end of this year and presented to the Lake County Redevelopment Commission for their January 2025 meeting for adoption. LCCEDD staff will start reporting into FSRS all sub-recipient for FY2023 and FY2024 once the policy and procedure amendments are approved.

View Audit 327510

Corrective Action Plans

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