Corrective Action Plans

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The District hired a new Chief Financial Officer in 2023 and was able to catch the District up on three years of financials statements and all missing audits. The new CFO made the following changes to ensure compliance: 1. Update internal controls and monitoring. The new CFO created a Federal Fundin...
The District hired a new Chief Financial Officer in 2023 and was able to catch the District up on three years of financials statements and all missing audits. The new CFO made the following changes to ensure compliance: 1. Update internal controls and monitoring. The new CFO created a Federal Funding Monitoring and Reporting Policy that specifies that responsibilities over compliance, expenditures, and reporting. 2. Implement Process Improvements. The new CFO and Accounts Payable were able to identify grant fund expenditures and work closely to make sure all future grant expenditures are identified and tracked. 3. Communicate with External Audit Team. The new CFO communicates regularly with the external audit team to ensure they are aware of the grant funds received and the type of audit that is required and coordinate audits with plenty of time to complete the audit before deadlines.
The District hired a new Chief Financial Officer in 2023 and was able to catch the District up on three years of financials statements and all missing audits. The new CFO made the following changes to ensure compliance: 1. Update internal controls and monitoring. The new CFO created a Federal Fundin...
The District hired a new Chief Financial Officer in 2023 and was able to catch the District up on three years of financials statements and all missing audits. The new CFO made the following changes to ensure compliance: 1. Update internal controls and monitoring. The new CFO created a Federal Funding Monitoring and Reporting Policy that specifies that responsibilities over compliance, expenditures, and reporting. 2. Implement Process Improvements. The new CFO and Accounts Payable were able to identify grant fund expenditures and work closely to make sure all future grant expenditures are identified and tracked. 3. Communicate with External Audit Team. The new CFO communicates regularly with the external audit team to ensure they are aware of the grant funds received and the type of audit that is required and coordinate audits with plenty of time to complete the audit before deadlines.
2021-010 Inventory Significant Deficiency Recommendation: Management should use a quarterly physical count as a starting point, track purchases and uses of inventory throughout the quarter in order to calculate the inventory balance that should be on hand at the end of the quarter. Management should...
2021-010 Inventory Significant Deficiency Recommendation: Management should use a quarterly physical count as a starting point, track purchases and uses of inventory throughout the quarter in order to calculate the inventory balance that should be on hand at the end of the quarter. Management should then compare the calculated ending inventory against the related quarterly physical count and determine if there are any large variances that require further investigation. Written policies and procedures should be adopted accordingly. Action Taken: The Housing Authority agrees with this finding and will implement this recommendation within 120 days of this audit report.
2021-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at leas...
2021-001 Segregation of Duties – Loan Program Significant Deficiency Recommendation: The Housing Authority’s fiscal policies should be revised to ensure that preventive controls are in place over check disbursements for loan disbursements, such that checks must be signed with live signatures at least the signature of one Tribal Council member. Further, individuals who benefit from the loan program should not have complete discretion over recording and processing of advances and repayment. We recommend a complete list of outstanding balances be presented to the Tribal Council, or its designee, for continued monitoring. Action Taken: The SCCHA discontinued the Loan Program as of November 2019. A complete list of balances owed has been submitted to the Tribal Council with the outstanding balances of those whom had signatory authority forwarded to the St. Croix Tribal Court for further repayment actions.
Section 8 Project Based Cluster – ALN #14.195 & 14.856 Recommendation: We recommend that management review their procedures for reviewing and monitoring the required deposit amounts to ensure that each Project deposits the correct amount each month. Explanation of disagreement with audit finding: Th...
Section 8 Project Based Cluster – ALN #14.195 & 14.856 Recommendation: We recommend that management review their procedures for reviewing and monitoring the required deposit amounts to ensure that each Project deposits the correct amount each month. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority completed a reconciliation of required monthly replacement reserve deposit amounts for all affected properties and updated automated accounting system entries to reflect correct deposit levels. A monitoring checklist and monthly financial review process have been established to verify ongoing compliance. Finance staff received targeted training regarding reserve funding requirements and contract documentation. Name(s) of the contact person(s) responsible for corrective action: Julie Ward, Chief Financial Officer Planned completion date for corrective action plan: December 31, 2025
Section 8 Project Based Cluster – ALN #14.195 & 14.856 Recommendation: We recommend that management review their procedures for retrieving tenant information and establish a method that ensures compliance. We recommend that the Authority should review their examination policies to ensure that all ex...
Section 8 Project Based Cluster – ALN #14.195 & 14.856 Recommendation: We recommend that management review their procedures for retrieving tenant information and establish a method that ensures compliance. We recommend that the Authority should review their examination policies to ensure that all examinations are performed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A comprehensive audit of tenant files was completed to confirm accuracy of medical deductions, recertification timeliness, and documentation requirements. The Management Analyst now performs ongoing file audits and coordinates with property managers to correct discrepancies promptly. Recertification scheduling is now supported by workflow reminders and supervisory tracking to prevent future delays. Name(s) of the contact person(s) responsible for corrective action: Jason Epperson, Assistant Vice President Planned completion date for corrective action plan: December 31, 2025
Section 8 Project Based Cluster – ALN #14.195 & 14.856 Recommendation: We recommend that management review their procedures for ensuring that contract rent changes are implemented and evidenced timely and accurately, and establish a method that ensures compliance. Explanation of disagreement with au...
Section 8 Project Based Cluster – ALN #14.195 & 14.856 Recommendation: We recommend that management review their procedures for ensuring that contract rent changes are implemented and evidenced timely and accurately, and establish a method that ensures compliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority reviewed and updated procedures for implementing contract rent increases and configured automated financial system flags to ensure that rent adjustments are applied on their effective dates. The Management Analyst now verifies contract rent changes during monthly internal reviews, and staff were retrained on rent adjustment documentation and approval workflows. Name(s) of the contact person(s) responsible for corrective action: Jason Epperson, Assistant Vice President Planned completion date for corrective action plan: December 31, 2025
Contact Person Jackie Cordie, Business Manager Corrective Action Plan The District plans to implement the auditor's recommendation. Planned Completion Date for CAP Fiscal year beginning July 1, 2024
Contact Person Jackie Cordie, Business Manager Corrective Action Plan The District plans to implement the auditor's recommendation. Planned Completion Date for CAP Fiscal year beginning July 1, 2024
Management concurs that there were staffing and turnover challenges for the Organization. Adequate policies and procedures are in place to ensure timeliness of data requested. Additionally, we will establish milestones to ensure future audits progress within the Uniform Guidance timeline.
Management concurs that there were staffing and turnover challenges for the Organization. Adequate policies and procedures are in place to ensure timeliness of data requested. Additionally, we will establish milestones to ensure future audits progress within the Uniform Guidance timeline.
Finding Number 2021-007: No Review of Reimbursement Requests Before Submission (Allowable Costs/Cost Principles), July 1, 2020 through June 30,2021. Statement of Condition: PCOA did not review reimbursement requests before submission PCOA personnel responsible for enacting corrective action plan: Ja...
Finding Number 2021-007: No Review of Reimbursement Requests Before Submission (Allowable Costs/Cost Principles), July 1, 2020 through June 30,2021. Statement of Condition: PCOA did not review reimbursement requests before submission PCOA personnel responsible for enacting corrective action plan: Jay Huffstutler, Finance Director, jhuffstutler@pcoa.org The corrective action plan:  Reimbursement requests now undergo formal internal review prior to submission.  A checklist-based review process was developed with assistance from the Director of Contracts, and compliance is enforced by the Finance Director.  Additional accounting staff are being hired to support the month-end closing process and ensure reimbursement requests are reconciled and supported appropriately. Completion Date: July 31, 2025
Finding Number 2021-006: Missing or Inaccurate Personnel Action Notices (Allowable Costs/Cost Principles), July 1, 2020 through June 30,2021. Statement of Condition: PCOA had missing or inaccurate personnel action notices PCOA personnel responsible for enacting corrective action plan: Jay Huffstutle...
Finding Number 2021-006: Missing or Inaccurate Personnel Action Notices (Allowable Costs/Cost Principles), July 1, 2020 through June 30,2021. Statement of Condition: PCOA had missing or inaccurate personnel action notices PCOA personnel responsible for enacting corrective action plan: Jay Huffstutler, Finance Director, jhuffstutler@pcoa.org; Jennifer Billa, Human Resources Director, Jbilla@pcoa.org The corrective action plan:  PCOA has standardized its personnel documentation process, including personnel action notices (PAN) and approval workflows.  HR and finance implemented policy and procedures to align pay rate documentation with payroll data.  All personnel changes are now signed off by the Finance and HR Director  Additional skilled personnel are being recruited to ensure accuracy and control around personnel changes. Completion Date: July 31, 2025
Finding Number 2021-005: Payroll Registers Not Approved by CFO (Allowable Costs/Cost Principles), July 1, 2020 through June 30,2021. Statement of Condition: PCOA did not have payroll registers reviewed by the CFO PCOA personnel responsible for enacting corrective action plan: Jay Huffstutler, Financ...
Finding Number 2021-005: Payroll Registers Not Approved by CFO (Allowable Costs/Cost Principles), July 1, 2020 through June 30,2021. Statement of Condition: PCOA did not have payroll registers reviewed by the CFO PCOA personnel responsible for enacting corrective action plan: Jay Huffstutler, Finance Director, jhuffstutler@pcoa.org The corrective action plan: Background: Previous CFO established this control in collaboration with PCOA leadership.  Approval controls over payroll have been reinstated. All payroll registers are now reviewed and approved prior to submission.  Oversight of payroll controls will be led by the new Finance Director  New staff are being hired to support payroll processing and ensure adherence to internal protocols. Completion Date: July 31, 2025
Finding Number 2021-003: Lack of Review of Meal Sign-In Sheets (Allowable Costs/Cost Principles) , July 1, 2020 through June 30,2021. Statement of Condition: The Meal Sign-in Sheets were not regularly and consistently attached to proper documentation. PCOA personnel responsible for enacting correcti...
Finding Number 2021-003: Lack of Review of Meal Sign-In Sheets (Allowable Costs/Cost Principles) , July 1, 2020 through June 30,2021. Statement of Condition: The Meal Sign-in Sheets were not regularly and consistently attached to proper documentation. PCOA personnel responsible for enacting corrective action plan: Francine McGetrick, Contracts Director, Fmcgetrick@pcoa.org The corrective action plan: 1. PCOA has implemented procedures requiring internal review of all client sign-in sheets related to meals billed for reimbursement. 2. While the required sign-in documentation was completed and retained, it was stored in the contracts area and not submitted with the DES files. A new process has been established to ensure that sign-in sheets are filed along with the corresponding summary information at the time of submission. 3. PCOA has designed the updated process and trained staff to ensure proper documentation is verified prior to billing. 4. Ongoing compliance is now overseen by the Director of Contracts, and operational staff have been re-trained to ensure consistent execution. Completion Date: June 30th, 2025
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its controls over reasonable rent determinations to ensure that they are performed timely, files are maintained, and the approved rent is properly carried forward to the HUD-50058. Explan...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its controls over reasonable rent determinations to ensure that they are performed timely, files are maintained, and the approved rent is properly carried forward to the HUD-50058. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has reinforced internal controls and accountability procedures to ensure that reasonable rent determinations are consistently performed and properly documented in compliance with HUD regulations. The HCV Director has assumed responsibility for reviewing and approving all reasonable rent determinations and will continue to monitor compliance until the Compliance Manager is hired in January 2026. Name(s) of the contact person(s) responsible for corrective action Keva Newsome, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/1/25
View Audit 373527 Questioned Costs: $1
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority to designate an individual to ensure accurate HUD-50058 information is inputted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audi...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority to designate an individual to ensure accurate HUD-50058 information is inputted into the PIC system timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will hire a Compliance staff person for the HCV Program in January 2026 to provide dedicated oversight of eligibility determinations, quality control, and ongoing staff training. Name(s) of the contact person(s) responsible for corrective action: Keva Newsome, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 1/31/26
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its internal controls over allowable costs to ensure all documentation is maintained at the time expenses are paid. Explanation of disagreement with audit finding: There is no disagreemen...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its internal controls over allowable costs to ensure all documentation is maintained at the time expenses are paid. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority is prioritizing completion of outstanding audits to ensure records can be located promptly when requested. All invoices will continue to require proper approval signatures prior to payment, and payment authorization will serve as an additional layer of verification to confirm compliance with internal control procedures. This instance involved only one of forty (40) accounts payable items that was not available in the document imaging system at the time of review so it needed to be recreated by printing off the invoice and it was paid online. The payment would have had to be pre-approved by CFO prior to payment. Name(s) of the contact person(s) responsible for corrective action: Shannon Sterling, CFO Planned completion date for corrective action plan: 12/1/25
View Audit 373527 Questioned Costs: $1
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its internal controls over the waiting list process to ensure all documentation is maintained at the time each applicant enters and is pulled from the waiting list. Explanation of disagre...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its internal controls over the waiting list process to ensure all documentation is maintained at the time each applicant enters and is pulled from the waiting list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Files will not be placed in storage until after the agency audit is completed. Name(s) of the contact person(s) responsible for corrective action: Keva Newsome, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/1/2025
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its controls over HQS inspections and abatements to ensure the controls are properly implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit f...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871 Recommendation: We recommend the Authority review its controls over HQS inspections and abatements to ensure the controls are properly implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A new HCV Director has been appointed and will perform monthly compliance reviews of failed inspections to ensure timely abatement enforcement and documentation accuracy. Name(s) of the contact person(s) responsible for corrective action: Keva Newsome, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/1/2025
View Audit 373527 Questioned Costs: $1
JCFHD experienced substantial leadership and staff turnover in key financial roles over multiple years, including the CEO, CFO, and finance team. As a result, the individuals who originally prepared the lost revenues calculation were no longer employed at the facility when the Uniform Guidance audit...
JCFHD experienced substantial leadership and staff turnover in key financial roles over multiple years, including the CEO, CFO, and finance team. As a result, the individuals who originally prepared the lost revenues calculation were no longer employed at the facility when the Uniform Guidance audit was conducted. This led to challenges in locating complete supporting documentation for the original calculation, resulting in additional calculations being necessary. Under new leadership, JCFHD has prioritized the development and implementation of robust policies and procedures to ensure that all relevant financial documentation is readily accessible for future Uniform Guidance audits. These measures are intended to strengthen internal controls and improve audit readiness. Corrective Action: 1. Provide additional training to finance staff on GAAP financial reporting and disclosure requirements to strengthen internal review and oversight. 2. Implement a documented review process for financial statements and footnotes prepared by external auditors, including CFO and Board-level approval prior to issuance. Completion Date: Within 120 days.
JCFHD experienced significant turnover in CEO, CFO, and finance positions over multiple years resulting in delays in completing the Uniform Guidance audit. JCFHD is under new leadership and has prioritized implementing policies and procedures to ensure future uniform guidance audits are completed an...
JCFHD experienced significant turnover in CEO, CFO, and finance positions over multiple years resulting in delays in completing the Uniform Guidance audit. JCFHD is under new leadership and has prioritized implementing policies and procedures to ensure future uniform guidance audits are completed and filed timely. Corrective Action: 1. Develop and implement written accounting policies and procedures aligned with GAAP and COSO principles. 2. Establish a monthly reconciliation calendar for all significant balance sheet accounts, with supervisory review and sign-off. 3. Provide training to accounting staff on new policies, reconciliation standards, and documentation requirements. 4. Assign the Accountant to monitor compliance and report quarterly to the CFO on reconciliation status and control improvements. Completion Date: Target completion within 90 days.
Finding No.: 2021-003 Segregation of Duties Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Name of Contact Persons: Faaeteete Sio and Ruth Matagi Corrective Action: Due to ...
Finding No.: 2021-003 Segregation of Duties Federal Agency: U.S. Department of Housing and Urban Development Federal Program Title: HOME Investment Partnerships Program Assistance Listing Number: 14.239 Name of Contact Persons: Faaeteete Sio and Ruth Matagi Corrective Action: Due to the COVID-19 pandemic, DBAS had to work a staggered schedule for the staff to include vulnerable employees who are 60+ year olds (management) to work remotely from home. Two of the signors fall under this category. DBAS will ensure and enforce proper segregation of duties will be followed. Loan approval and check signer controls will be reviewed and revised to ensure segregation of duties concerns are mitigated moving forward. This situation has since been addressed and corrected with the return of staff to the office.
Assistance Listing Number: #93.498 Program Name: Provider Relief Fund and American Rescue Plan {ARP} Rural Distribution Compliance Requirement: Other Finding Summary: The District does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of f...
Assistance Listing Number: #93.498 Program Name: Provider Relief Fund and American Rescue Plan {ARP} Rural Distribution Compliance Requirement: Other Finding Summary: The District does not have an internal control system designed to provide for a complete and accurate schedule of expenditures of federal awards being audited. We were requested to draft the schedule of expenditures of federal awards Responsible Individuals: Brian Murray, Chief Financial Officer Corrective Action Plan: GVH will review its' internal controls related to grant tracking. It also assign a project or grant account number to each grant and code all expenditures to that account code. The items in this account will be logged and the appropriate back identified and maintained.
Federal Agency Name: Department of Health and Human Services Assistance Listing Number: #93.498 Program Name: Provider Relief Fund and American Rescue Plan {ARP} Rural Distribution Compliance Requirement: Activities Allowed or Unallowed, Allowable Cost/Cost Principles Finding Summary: The District ...
Federal Agency Name: Department of Health and Human Services Assistance Listing Number: #93.498 Program Name: Provider Relief Fund and American Rescue Plan {ARP} Rural Distribution Compliance Requirement: Activities Allowed or Unallowed, Allowable Cost/Cost Principles Finding Summary: The District did not have adequate internal controls policy in place to ensure expenditures claimed were accurate and based upon underlying records and to ensure the records were retained to support the amounts. Responsible Individuals: Brian Murray, Chief Financial Officer Corrective Action Plan: GVH will review its internal controls related to grant tracking. It also assign a project or grant account number to each grant and code all expenditures to that account code. The items in this account will be logged and the appropriate back identified and maintained.
Planned Corrective Action: A Uniform Guidance policy and Procedure document has been adopted. Planned Implementation Date of Corrective Action: The policy was effective 03/21/2025. Person Responsible for Corrective Action: Finance Director
Planned Corrective Action: A Uniform Guidance policy and Procedure document has been adopted. Planned Implementation Date of Corrective Action: The policy was effective 03/21/2025. Person Responsible for Corrective Action: Finance Director
2021-002 Reserve Account Category: Significant Deficiency in Internal Control and Noncompliance Condition: The Authority has a deposit deficiency of $40,416 in the Reserve Account. The balance of the debt service reserve as of June 30, 2021, shall be $90,936. Management’s Response: Starting in FY 20...
2021-002 Reserve Account Category: Significant Deficiency in Internal Control and Noncompliance Condition: The Authority has a deposit deficiency of $40,416 in the Reserve Account. The balance of the debt service reserve as of June 30, 2021, shall be $90,936. Management’s Response: Starting in FY 2024-2025, the Finance Department will initiate the necessary transfers to the Reserve Account to rectify the deposit deficiency. Additionally, we will establish a plan for regular monitoring of the account to prevent future deficiencies. To ensure ongoing compliance and to identify any potential issues early, we will schedule more frequent internal audits. Person in charge: Juan C. Rodriguez Rivera Accounting Official 787-705-7188 Juan.rodriguez@lra.pr.gov Implementation Date: FY 2024-2025
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