Corrective Action Plans

Finding 45831 (2022-002)

Significant Deficiency 2022

OH

HUD Housing Programs Internal Control / Segregation of Duties Reporting

Network Housing ?91, Inc. 12/31/2022 Corrective Action Plan Finding Number: 2022-002 Condition: The Organization failed to make the required reserve for replacements deposits in the current fiscal year. Planned Corrective Action: Management agrees with the finding as reported. Management has instit...

Network Housing ?91, Inc. 12/31/2022 Corrective Action Plan Finding Number: 2022-002 Condition: The Organization failed to make the required reserve for replacements deposits in the current fiscal year. Planned Corrective Action: Management agrees with the finding as reported. Management has instituted procedural changes to ensure that all required deposits are made monthly. Additionally, management has taken steps to deposit all delinquent deposits. Contact person responsible for corrective action: Paul Anderson, CFO Anticipated Completion Date: 12/31/2023

View Audit 41634

Finding 45826 (2022-002)

Significant Deficiency 2022

Network Housing '94 Sixth Street, Inc.

OH

HUD Housing Programs Internal Control / Segregation of Duties Reporting

Finding Number: 2022-002 Condition: The Organization failed to make the required reserve for replacements deposits in the current fiscal year. Planned Corrective Action: Management agrees with the finding as reported. Management has instituted procedural changes to ensure that all required deposits ...

Finding Number: 2022-002 Condition: The Organization failed to make the required reserve for replacements deposits in the current fiscal year. Planned Corrective Action: Management agrees with the finding as reported. Management has instituted procedural changes to ensure that all required deposits are made monthly. Additionally, management has taken steps to deposit all delinquent deposits. Contact person responsible for corrective action: Paul Anderson, CFO Anticipated Completion Date: 12/31/2023

View Audit 41633

Finding 45823 (2022-003)

Significant Deficiency 2022

Project Safeguard

CO

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles

Planned Corrective Action: Once Project Safeguard realized that the organization didn?t have a copy of the file from the Board of Directors from the Executive Director having been hired in 2013, Project Safeguard has rectified the situation by replacing the missing i-9 with an updated i-9 with attes...

Planned Corrective Action: Once Project Safeguard realized that the organization didn?t have a copy of the file from the Board of Directors from the Executive Director having been hired in 2013, Project Safeguard has rectified the situation by replacing the missing i-9 with an updated i-9 with attestation in accordance to guidance from UCIS . All I-9s are completed and maintained in a separate file as soon as employment begins and E-verify is completed within three days of employment as stated in the Project Safeguard policies. Name of Contact Person: BethAnne O?keefe, Finance Director Anticipated completion date: This was completed and the updated I-9 with attestation as soon as the I-9 documents were requested on 03/08/2023.

View Audit 41506

Finding 45822 (2022-004)

Significant Deficiency 2022

Project Safeguard

CO

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management

Planned Corrective Action: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed and will d...

Planned Corrective Action: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed and will document any variances from the allowed wages in the grant agreement, and what is being submitted for reimbursement. The organization will review policies and implement an action plan based on the availability of limited staff. Name of Contact Person: BethAnne O?keefe, Finance Director Anticipated completion date: 06/01/2023

View Audit 41506

Finding 45821 (2022-005)

Significant Deficiency 2022

Project Safeguard

CO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Planned Corrective Action: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed The organi...

Planned Corrective Action: The Organization has hired a full-time Finance Director who will monitor these matters more closely than under the previous structure. The Organization will also review the current controls to ensure a more robust review of quarterly reimbursements are performed The organization will review policies and implement an action plan based on the availability of limited staff. Name of Contact Person: BethAnne O?keefe, Finance Director Anticipated completion date: 06/01/2023

View Audit 41506 Questioned Costs: $1

Finding 45771 (2022-005)

Significant Deficiency 2022

Fargo Housing and Redevelopment Authority

ND

HUD Housing Programs Significant Deficiency

Contact Person Tom Keller, Executive Director, Jill Liebelt, CFO, & Chris Brungardt, CEO Corrective Action Plan The Authority will have a checklist on annual certifications to ensure all appropriate documents are included in the file. Planned Completion Date for CAP December 31, 2023

View Audit 40655

Finding 45770 (2022-004)

Significant Deficiency 2022

Fargo Housing and Redevelopment Authority

ND

HUD Housing Programs Significant Deficiency

Contact Person Tom Keller, Executive Director, Jill Liebelt, CFO, & Chris Brungardt, CEO Corrective Action Plan The Authority has reviewed and implemented quality control re-inspections to ensure compliance moving forward. Planned Completion Date for CAP December 31, 2023

View Audit 40655

Finding 45749 (2022-002)

Significant Deficiency 2022

Doane University

NE

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2022-002 Federal Awards Findings and Questioned Costs Condition The change in status for three of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The change in status infor...

Finding 2022-002 Federal Awards Findings and Questioned Costs Condition The change in status for three of twenty-five students tested was not reported to the National Student Loan Data System (NSLDS) within 30 days or included in a response to a roster file within 60 days. The change in status information for five of twenty-five students tested did not agree between the campus level and program level enrollment detail. The date for the change in status for eleven of twenty-five students tested did not agree to the University?s records. The total number of students impacted is thirteen due to students being included in multiple categories as noted above. Corrective Action Plan Doane University staff is changing our process for enrollment reporting. Auditors have provided a copy of the NSLDS Enrollment Reporting Guide which staff will refer to for specific guidance in case questions arise. Errors noted in the Single Audit for the period 7/1/2021-6/30/2022 will be adjusted to reflect data noted in the schedule relative to this finding. Name(s) of Contact Person(s) Responsible for Corrective Action: Denise Ellis, Registrar, Doane University. Anticipated Completion Date: April 30, 2023 CFO February 27, 2023

View Audit 39674

Finding 45740 (2022-004)

Significant Deficiency 2022

Doane University

NE

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Finding 2022-004 Condition The University?s 2021 single audit reporting package was not submitted within the required timeframe. Corrective Action Plan Corrective Action Planned: Doane University is aware of the timeline required for single audit reporting package submission and will work closely wi...

Finding 2022-004 Condition The University?s 2021 single audit reporting package was not submitted within the required timeframe. Corrective Action Plan Corrective Action Planned: Doane University is aware of the timeline required for single audit reporting package submission and will work closely with the auditor to ensure that all documentation is submitted within the required timeframe. Doane University transitioned to a new audit firm for fiscal year ended June 30, 2022 to help ensure a smoother process. Name(s) of Contact Person(s) Responsible for Corrective Action: Julie Heyen, Controller Anticipated Completion Date: March 31, 2023 CFO February 27, 2023

View Audit 39674

Finding 45739 (2022-003)

Significant Deficiency 2022

Doane University

NE

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2022-003 Condition Various key student financial assistance processes, such as monthly Direct loan reconciliations and drawdowns of federal funds, have been performed, but there is no evidence of documented reviews. In addition, it was noted that the servicer?s internal control report for th...

Finding 2022-003 Condition Various key student financial assistance processes, such as monthly Direct loan reconciliations and drawdowns of federal funds, have been performed, but there is no evidence of documented reviews. In addition, it was noted that the servicer?s internal control report for the Perkins Loan Program was not reviewed. Corrective Action Plan Corrective Action Planned: In the fiscal year starting July 1, Doane University has implemented or changed processes to ensure management review and documentation of the review is saved. Name(s) of Contact Person(s) Responsible for Corrective Action: Julie Heyen, Controller Anticipated Completion Date: September 30, 2022 CFO February 27, 2023

View Audit 39674

Finding 45717 (2022-003)

Significant Deficiency 2022

Blue Rivers Area Agency on Aging

NE

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency

Finding 2022-003 Significant Deficiency in Internal Controls over Compliance for Allowable Costs Corrective Action Planned: The Agency has completed time studies for personnel who are allocated across multiple programs and will review documentation to ensure the time study data is applied consistent...

Finding 2022-003 Significant Deficiency in Internal Controls over Compliance for Allowable Costs Corrective Action Planned: The Agency has completed time studies for personnel who are allocated across multiple programs and will review documentation to ensure the time study data is applied consistently or updated when necessary to support the allocation. Documentation will be maintained to support the allocation methods. Anticipated Completion Date: June 30, 2023 Responsible Parties: The Agency?s Management and staff.

View Audit 40668

Finding 45687 (2022-003)

Significant Deficiency 2022

Blackburn University Dba Blackburn College

IL

Questioned Costs Student Financial Aid Cash Management

Condition: Two of the 40 student files (5%) we examined, we noted the students were not properly awarded Direct loans. Further, we noted two of the 40 students (5%) were not properly awarded Pell. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3...

Condition: Two of the 40 student files (5%) we examined, we noted the students were not properly awarded Direct loans. Further, we noted two of the 40 students (5%) were not properly awarded Pell. Corrective Action Plan: It is important to note that the entire 2021/2022 award year was processed by 3rd party servicer, Fully Disbursed. The current Financial Aid staff at Blackburn College started in October of 2021 but the processing was conducted by Fully Disbursed as they were under contract with Blackburn College for all 2021-2022 processing and packaging until August 2022 at the completion of the summer semester. The Financial Aid Office at Blackburn has evaluated and revised policies and procedures to ensure students receive the proper amount of Title IV Aid. Reconciling each month is necessary to ensure we catch any and all discrepancies that may occur. We will continue to utilize all available software to assist with packaging and that will allow all financial aid, including Title IV funds, to be reviewed frequently by both the Director of Financial Aid and the Assistant Director of Financial Aid. Responsible Person for Correction Action Plan: Alexis Brown, Director of Financial Aid Implementation Date for Corrective Action Plan: April 2023

View Audit 40629 Questioned Costs: $1

Finding 45683 (2022-009)

Significant Deficiency 2022

Community College of Beaver County

PA

Student Financial Aid Eligibility Significant Deficiency

Finding 2022-009: Eligibility-Significant Deficiency and Noncompliance Condition: For three of the twenty-five students selected for testing, the Pell Award calculation was not correctly performed, and the students did not receive an adequate amount of Pell Award for the period under audit. Responsi...

Finding 2022-009: Eligibility-Significant Deficiency and Noncompliance Condition: For three of the twenty-five students selected for testing, the Pell Award calculation was not correctly performed, and the students did not receive an adequate amount of Pell Award for the period under audit. Responsible for the Plan: Janet Davidson, Director of Financial Aid Planned completion date: June 30, 2023 Corrective Action Plan: To ensure compliance with eligibility requirements the college will adopt the following procedure: ? The Financial Aid Assistant/Loan Officer will review the daily registration changes report to determine the students enrollment status for each term and then set the appropriate class load in Powerfaids in the POE screen. ? Powerfaids uses that class load screen and the Pell payment schedules to determine the students pell grant award. ? The Director of Financial Aid will work with IT/IR to create a report that details the pell load in Powerfaids to match it against current credit load in Jenzabar to ensure that the student has the appropriate credit load in Powerfaids and the appropriate Pell awards are disbursed.

View Audit 52943

Finding 45666 (2022-001)

Significant Deficiency 2022

Fort Healthcare, Inc.

WI

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting

Finding # 2022-01 Response: Management will file subawards reports timely based on the requirements of the Federal Funding Accountability and Transparency Act. Responsible Party: Roberta Farnham, Controller Estimated Completion: September 30, 2023

View Audit 52242

Finding 45646 (2022-002)

Significant Deficiency 2022

Leino Park Water District

MA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Finding 2022-002 Significant Deficiency in Internal Controls Over Compliance Condition: The District has not formalized written policies and procedures related to federal awards. Corrective Action Planned: The District has historically not received federal grant funds and had no previous requirement...

Finding 2022-002 Significant Deficiency in Internal Controls Over Compliance Condition: The District has not formalized written policies and procedures related to federal awards. Corrective Action Planned: The District has historically not received federal grant funds and had no previous requirements to implement this compliance item. Additionally, at this time, the District does not anticipate receiving any federal grant funds in the foreseeable future. In the future, if the District were to pursue requesting more federal grant funds, it will look to establish formalized, written policies relative to grant management. Anticipated Completion Date: November 1, 2028 Contact: Derek Knerr, Treasurer, Leino Park Water District

View Audit 51314

Finding 45626 (2022-001)

Significant Deficiency 2022

Northwest Regional Development Commission

MN

Allowable Costs / Cost Principles Significant Deficiency

2022-001 FINDING Contact Person ? Kalen Wiseth, Finance Director Corrective Action Plan ? The Organization will implement procedures to ensure that all expenses are approved and this approval documentation is maintained. Completion Date - Immediately

View Audit 40985

Finding 45566 (2022-005)

Significant Deficiency 2022

Suring Public School District

WI

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Allowable Costs The District understands the need to properly document internal control procedures for allowable costs in accordance with Uniform Guidance and State Single Audit Guidelines. In the future, the District will retain their documentation to support their allowable cost approval for fed...

Allowable Costs The District understands the need to properly document internal control procedures for allowable costs in accordance with Uniform Guidance and State Single Audit Guidelines. In the future, the District will retain their documentation to support their allowable cost approval for federal and state grants.

View Audit 48008

Finding 45515 (2022-002)

Significant Deficiency 2022

Vilas County

WI

Internal Control / Segregation of Duties Cash Management HUD Housing Programs

Segregation of Duties ? State Grant Reporting Recommendation: We recommend that the County review its internal controls and designate an individual other than the preparer to review and approve any grant claims. Explanation of disagreement with audit finding: There is no disagreement with the audit ...

Segregation of Duties ? State Grant Reporting Recommendation: We recommend that the County review its internal controls and designate an individual other than the preparer to review and approve any grant claims. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Department head will review all staff prepared grant payment requests for accuracy prior to submission. If the grant payment request is prepared by the department head, the Finance Director will review prior to submission. Name of the contact person responsible for corrective action: Darcy Smith, Finance Director. Planned completion date for corrective action plan: The secondary review of grant payment requests will be completed by December 31, 2022.

View Audit 51160

Finding 45514 (2022-001)

Significant Deficiency 2022

Vilas County

WI

Reporting Significant Deficiency Internal Control / Segregation of Duties

Preparation of Annual Financial Report Recommendation: We recommend the County continue reviewing the annual financial report. Such review procedures should be performed by an individual possessing a thorough understanding of accounting principles generally accepted in the United States of America a...

Preparation of Annual Financial Report Recommendation: We recommend the County continue reviewing the annual financial report. Such review procedures should be performed by an individual possessing a thorough understanding of accounting principles generally accepted in the United States of America and knowledge of the County?s activities and operations. While it may not be cost beneficial to train additional staff to completely prepare the report, a thorough review of this information by the finance director is necessary to ensure the basic financial statements and all accompanying information is accurate and complete. Action planned/taken in response to finding: The County?s finance director will assist the County?s auditors in their preparation of the annual finance report and required disclosures. The finance director will thoroughly review this report and disclosures when issued. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Name of the contact person responsible for corrective action: Darcy Smith, Finance Director. Planned completion date for corrective action plan: The assistance with the preparation and review of the financial statements will be completed by December 31, 2021.

View Audit 51160

Finding 45502 (2022-004)

Significant Deficiency 2022

Detroit Housing Commission

MI

Questioned Costs HUD Housing Programs Cash Management

Finding Number: 2022-004 Condition: Participant files selected for testing did not include complete information to support participant eligibility Planned Corrective Action: While the Detroit Housing Commission works towards implementing Rent Cafe, an electronic platform to allow applicants, residen...

Finding Number: 2022-004 Condition: Participant files selected for testing did not include complete information to support participant eligibility Planned Corrective Action: While the Detroit Housing Commission works towards implementing Rent Cafe, an electronic platform to allow applicants, residents, and Management the ability to streamline the continued occupancy and eligibility process, DHC will continue to utilize the manual application process with the following controls in place: 1. There will be ongoing training to support staff in Public Housing Rent Calculation. Within the designated training, Housing Specialists, Property Managers, Assistant Property Managers and Compliance Specialists will focus on correctly calculating subsidy for applicants and residents. Trainings will include but are not limited to properly identifying and verifying income, expenses, allowances, adjusted income, total tenant payment (TTP), utility standards, PHA payment and subsidy standards. 2. Regional Managers will conduct the first line of quality control file reviews. Upon Housing Specialist, Property Manager and Assistant Property Manager's completing Initial Eligibility, Annual and Interim recertifications, Regional Managers will review the proposed certification against the certification's checklist for approval. 3. The Compliance Department will conduct ongoing Quality Control File Reviews on a 10% sample selection of households to ensure timely completion and accuracy of ongoing participant rent determination. a. When deficiencies are identified during a Quality Control review, site staff will have 7 days to cure and upload the corrective file to SharePoint. b. The final quality control review will also include reconciliation for acceptance of the electronic file to PIC. 4 . To address the incorrect utility allowance amounts being utilized to calculate tenant rent, the following will occur: a. DHC's REM Department will work with DHC's IT Department of update the Utility Allowance tables in the housing's Yardi Software. Current utility allowances will be entered in the software's utility allowance table and will prepopulate based on the action type and effective date of the recertification. b. Site staff will include the printed utility allowance chart within the certification with the allowance amount provided clearly identified for review by the Regional Manager when conducting the first line of quality control file review. Contact person responsible for corrective action: Scharre Leslie, Operations Analyst & Compliance Manager Anticipated Completion Date: 6/30/2023

View Audit 45566 Questioned Costs: $1

Finding 45494 (2022-001)

Significant Deficiency 2022

Lutheran Social Services of Central Ohio Hamilton Housing, Inc.

OH

HUD Housing Programs Reporting Significant Deficiency

RE: Lutheran Social Services of Central Ohio Hamilton Housing, Inc. Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding Number: 2022-001 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD....

RE: Lutheran Social Services of Central Ohio Hamilton Housing, Inc. Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding Number: 2022-001 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $478 into residual receipts on September 23, 2022.

View Audit 41516

Finding 45493 (2022-001)

Significant Deficiency 2022

Lutheran Social Services of Central Ohio Groveport Housing, Inc.

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

RE: Lutheran Social Services of Central Ohio Groveport Housing, Inc. Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding Number: 2022-001 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD...

RE: Lutheran Social Services of Central Ohio Groveport Housing, Inc. Corrective Action Plan Fiscal Year Ended June 30, 2022 Finding Number: 2022-001 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $10,953 into residual receipts on September 23, 2022.

View Audit 41515

Finding 45492 (2022-002)

Significant Deficiency 2022

Lutheran Social Services of Central Ohio Delaware Housing, Inc.

OH

HUD Housing Programs Internal Control / Segregation of Duties Cash Management

Finding Number: 2022-002 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to impr...

Finding Number: 2022-002 Condition: The Corporation used surplus cash calculated at June 30, 2021, to make a payment on a residual receipts note without prior approval from HUD. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management deposited the surplus cash amount of $28,666 into residual receipts on September 23, 2022.

View Audit 41514

Finding 45488 (2022-002)

Significant Deficiency 2022

City of Downey

CA

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2022-002: Loan Continuing Compliance Requirements Noncompliance/Significant Deficiency Responsible: Jessica Flores, Economic Development and Housing Manager Management Response and Corrective Action The City began a implementation of a monitoring process for existing first-time homebuyer ...

Finding 2022-002: Loan Continuing Compliance Requirements Noncompliance/Significant Deficiency Responsible: Jessica Flores, Economic Development and Housing Manager Management Response and Corrective Action The City began a implementation of a monitoring process for existing first-time homebuyer outstanding loans, and is continues working on a process to review all loans. The City will complete implementation of a monitoring process in the following fiscal year. Proposed Completion Date: June 30, 2023

View Audit 46535

Finding 45483 (2022-003)

Significant Deficiency 2022

Union College

NE

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2022-003 Higher Education Emergency Relief Funds -Assistance Listing No. 84.425 Recommendation: We recommend the College review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be revie...

2022-003 Higher Education Emergency Relief Funds -Assistance Listing No. 84.425 Recommendation: We recommend the College review their reporting procedures to ensure all required steps are included as well as the supporting documentation to prepare the report is retained. The reports should be reviewed by someone other than the preparer of the report and this review should be documented. Views of responsible officials: There is no disagreement with the audit finding. Action taken in response to finding: Union College will ensure that all HEERF reports are reviewed by the VP for Financial Administration prior to submission. We will also ensure proper supporting documentation is retained and the necessary steps are followed as required. Name(s) of the contact person(s) responsible for corrective action: Brandie Kolff van Oosterwyk, Controller. Planned completion date for corrective action plan: The goal date for this project to be completed is prior to the FY23 audit.

View Audit 46373

Corrective Action Plans

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