Corrective Action Plans

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Finding # 2025-001: Type: Significant deficiency in internal controls over financial reporting Finding: Audit procedures identified a land acquisition financed through a promissory note that was not recorded when the transaction occurred. The matter related to a significant noncash real estate devel...
Finding # 2025-001: Type: Significant deficiency in internal controls over financial reporting Finding: Audit procedures identified a land acquisition financed through a promissory note that was not recorded when the transaction occurred. The matter related to a significant noncash real estate development transaction that was nonroutine and did not involve a typical cash disbursement through the normal accounts payable process. Corrective Action: Management implemented procedures to identify and evaluate significant nonroutine transactions. These include early communication with finance through regular meetings and pipeline and work-in-process updates, implemented in November 2025, and a monthly close procedure for nonrecurring transactions, implemented in August 2026. Anticipated Completion Date: November 2025 and August 2026
Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Assistance Listing Number: #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: The Cooperative was unable to provide documentation to support review and approval of the Cooper...
Federal Agency Name: Department of Treasury Pass-Through Entity: State of Iowa Department of Management Assistance Listing Number: #21.029 Program Name: Coronavirus Capital Projects Fund Finding Summary: The Cooperative was unable to provide documentation to support review and approval of the Cooperative’s request for reimbursement. Corrective Action Plan: Grant 24-GRAD-005 requires grantees to sign a General Accounting Expenditure form when submitting a reimbursement claim. The form lists the amount of invoices submitted, the MVEC match and the reimbursement requested. The CEO will sign off on these forms. For other grant reimbursements, the CFO will create a General Accounting Expenditure form for the CEO to sign off on. That form will be retained with the other supporting documentation. Responsible Individuals: Jeremy Richert, Chief Executive Officer and Kelly Gibbs, Chief Financial Officer Anticipated Completion Date: June 2026
Audit Finding Reference: 2025-002 Improve Controls Over Reporting Planned Corrective Action: Director of Operations & Impact created an 18-month reporting deliverables schedule and is reviewed quarterly on 9/22/25. The schedule of reporting deliverables has been added to a dedicated calendar in Shar...
Audit Finding Reference: 2025-002 Improve Controls Over Reporting Planned Corrective Action: Director of Operations & Impact created an 18-month reporting deliverables schedule and is reviewed quarterly on 9/22/25. The schedule of reporting deliverables has been added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications are integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact
Finding 2025-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Amber Jusefowytsch / Kim Newman / Anna Simmons Corrective Action Plan: A calendar of required reporting dates will be created with a one-month reminder to all involved parties to mitigate last minut...
Finding 2025-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Amber Jusefowytsch / Kim Newman / Anna Simmons Corrective Action Plan: A calendar of required reporting dates will be created with a one-month reminder to all involved parties to mitigate last minute issues with reporting compliance. Proposed Completion Date: This finding and corrective action plan have been reached near the end of FY26, the calendar will be implemented by December 31st, 2026 but we anticipate a similar finding for FY26.
Finding No. Corrective Action Plan 2025-002 Uniform Grant Guidance Implementation Recommendation: We recommend the County finalize the assessment of its financial management system and related internal controls over federal awards during the 2021 fiscal year. This assessment should include an evalua...
Finding No. Corrective Action Plan 2025-002 Uniform Grant Guidance Implementation Recommendation: We recommend the County finalize the assessment of its financial management system and related internal controls over federal awards during the 2021 fiscal year. This assessment should include an evaluation of existing policies and procedures to determine where additional enhancements should be made or new policies created, a plan to communicate these policies to County employees, and procedures to periodically review and update, as considered necessary. Action Planned/taken in response to the finding: Kewaunee County agrees with the finding. An assessment of all grants, requirements, and related policy and procedures is in progress and will continue to: • Evaluate existing policy and procedures for needed revisions • Document revisions to policy and procedures as necessary • Communicate any new policies to employees responsible for awards • Identify awards covered by the Uniform Guidance • Set and document a schedule for periodic review and revision Policy and procedures, as well as related documentation, are being revised as necessary to ensure compliance with the Uniform Guidance. Progress continues into 2025. The Finance Director will continue to coordinate and provide assistance and guidance to departments receiving grants subject to the Uniform Guidance. Names(s) of the contact person(s) responsible for corrective action: Paul Kunesh Planned completion date for corrective action: December 31, 2026
Finding No. Corrective Action Plan 2025-003 Review of Claim Forms and Expenditure Reconciliation Recommendation: We recommend that there is an appropriate reviewer of each grant claim and monthly reconciliation. Action planned/taken in response to the finding: Management will evaluate their current ...
Finding No. Corrective Action Plan 2025-003 Review of Claim Forms and Expenditure Reconciliation Recommendation: We recommend that there is an appropriate reviewer of each grant claim and monthly reconciliation. Action planned/taken in response to the finding: Management will evaluate their current processes and procedures during staffing transitions in fiscal year 2026 to ensure that proper review of claim forms and expenditure reconciliation. Names(s) of the contact person(s) responsible for corrective action: Paul Kunesh and Brian Johnson Planned completion date for corrective action: December 31, 2026
Views of Responsible Officials: The Finance and Executive teams are aware of the delay of the reporting package to the Federal Audit Clearinghouse within the required timeframe. As noted above, abrupt award termination and the resulting unpredictability and losses of federal funding resulted in sign...
Views of Responsible Officials: The Finance and Executive teams are aware of the delay of the reporting package to the Federal Audit Clearinghouse within the required timeframe. As noted above, abrupt award termination and the resulting unpredictability and losses of federal funding resulted in significant staff turnover, multiple revisions to—and reviews of—restricted net asset balances and significant delays. The Finance and Executive teams have corrected processes leading to these delays during FY2026 to ensure timely submission of all future Data Collection Forms to the Federal Audit Clearinghouse within the required timeframe. Anticipated Completion Date: December 31, 2025
Finding Reference: 2025-004 Description of Finding: The Authority was unable to provide documentation to show income had been verified during reexamination for 3 tenants out of a sample of 40 tenants. Statement of Concurrence or Nonconcurrence: The Authority agrees with the finding. Corrective Actio...
Finding Reference: 2025-004 Description of Finding: The Authority was unable to provide documentation to show income had been verified during reexamination for 3 tenants out of a sample of 40 tenants. Statement of Concurrence or Nonconcurrence: The Authority agrees with the finding. Corrective Action: Staff will attend annual file compliance training and upcoming rent calculation training to reinforce documentation requirements and ensure accurate income determinations going forward. We have also updated our file checklists, staff are reviewing all tenant files and we have an internal file review process, as noted in Finding 2025-002, to help ensure staff obtain and maintain all required third-party documentation for income reexaminations Name of Contact Person: Curtis Lokey, Director of Finance, 423-752-4893, clokey@chahousing.org
Finding Reference: 2025-003 Description of Finding: Contract rent adjustments were not applied to the calculation of rent for 4 tenants out of a sample of 40. Statement of Concurrence or Nonconcurrence: The Authority agrees with the finding. Corrective Action: Due to staffing challenges, some contra...
Finding Reference: 2025-003 Description of Finding: Contract rent adjustments were not applied to the calculation of rent for 4 tenants out of a sample of 40. Statement of Concurrence or Nonconcurrence: The Authority agrees with the finding. Corrective Action: Due to staffing challenges, some contract rent adjustments were implemented later than they should have been. We have since implemented a process to ensure contract rent adjustments are reviewed and applied timely. This process includes internal review procedures, and staff will receive annual training to reinforce contract rent requirements and help ensure adjustments are processed accurately and on time going forward.
Finding Reference: 2025-002 Description of Finding: The Authority was unable to provide all documents required to be maintained to determine eligibility. Statement of Concurrence or Nonconcurrence: The Authority agrees with the finding. Corrective Action: We have updated our file checklists to bette...
Finding Reference: 2025-002 Description of Finding: The Authority was unable to provide all documents required to be maintained to determine eligibility. Statement of Concurrence or Nonconcurrence: The Authority agrees with the finding. Corrective Action: We have updated our file checklists to better ensure that staff collect all required supporting documentation needed to determine eligibility during each reexamination. Staff received training on the new checklist format in late 2025 and have begun using the updated checklists. We are also reviewing all participant files to verify they are complete and compliant. In addition, we have an internal file review process that includes quality control reviews of a percentage of files at each site to help ensure required documentation is present and program requirements are being met. Staff will also attend annual file compliance training to reinforce documentation requirements and support continued compliance going forward.
Significant Deficiency in Internal Control Over Compliance and Noncompliance Related to Reporting for the Federal Funding Accountability and Transparency Act. Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs with the finding and acknowledges that internal pro...
Significant Deficiency in Internal Control Over Compliance and Noncompliance Related to Reporting for the Federal Funding Accountability and Transparency Act. Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs with the finding and acknowledges that internal procedures and oversight were insufficient to ensure timely FFATA subaward reporting. Corrective Action: To address this deficiency, AOOS will update its subaward monitoring controls to ensure full compliance with 2 CFR Part 170. Specifically, AOOS will: • Assign dedicated responsibility to designated staff to file subaward reports in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the end of the month following subaward execution. • Implement a monthly supervisory review to verify FSRS filing submissions and archive confirmation records in the subaward files. • Retroactively submit the missing FY25 FFATA reports into FSRS. 1007 W. Third Avenue, Suite 100 Anchorage, AK 99501 907.644.6753 www.aoos.org Anticipated Completion Date: September 30, 2026
1007 W. Third Avenue, Suite 100 Anchorage, AK 99501 907.644.6753 www.aoos.org August 17, 2026 CORRECTIVE ACTION PLAN Finding Number 2025-001 Significant Deficiency in Cash Management Compliance Documentation Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs wi...
1007 W. Third Avenue, Suite 100 Anchorage, AK 99501 907.644.6753 www.aoos.org August 17, 2026 CORRECTIVE ACTION PLAN Finding Number 2025-001 Significant Deficiency in Cash Management Compliance Documentation Contact Person: Sheyna Wisdom, Executive Director, AOOS Management Response: AOOS concurs with the finding and acknowledges the necessity of maintaining clear, accessible documentation linking individual federal cash draws directly to specific allowable expenditures incurred. Corrective action: To address this deficiency, AOOS, in coordination with its fiscal sponsor (Alaska SeaLife Center), will establish and formalize a standardized procedure for cash draw requests. Specifically, AOOS will: • Implement documentation for every ASAP drawdown request, which will include detailed general ledger expenditure reports, invoice registers, or transaction listings matching the exact draw amount. • Establish a dual-review process requiring formal written sign-off by both AOOS and Alaska SeaLife Center prior to executing funds transfers in ASAP. • Maintain permanent digital archives of all draw support packets and perform quarterly reconciliations between ASAP drawdowns, general ledger accounts, and SEFA reporting. Anticipated completion date: September 30, 2026
Finding 2025-005 - Untimely Release of Title IV Credit Balances (Significant Deficiency): Condition - During testing of student account activity, we identified that fourteen (14) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 ...
Finding 2025-005 - Untimely Release of Title IV Credit Balances (Significant Deficiency): Condition - During testing of student account activity, we identified that fourteen (14) out of sixty (60) sampled students had Title IV created credit balances that remained on their accounts for more than 14 days without being released to the student or parent. All refunds were eventually released to the students. Corrertive Action Plan The College experienced significant staff turnover within the business office. In addition, the College is undergoing conversion to a new Enterprise Resource Planning (ERP) system which affected its ability to complete some functions within a timely manner. A new bursar was hired in May 2026. Timely processing of student refunds was emphasized during her training. Going forward, student refunds will be released within 14 days after credit balances are reflected on student accounts." Completion Date - September 30, 2026 Responsible Party - Chief Financial Officer
Recommendation We recommend the District strengthen internal controls over the Child Nutrition Program reporting process by ensuring that all required documentation, including federal edit checks, Site Claim Reports by school, and evidence of supervisory review and approval of Meal Count Listings, i...
Recommendation We recommend the District strengthen internal controls over the Child Nutrition Program reporting process by ensuring that all required documentation, including federal edit checks, Site Claim Reports by school, and evidence of supervisory review and approval of Meal Count Listings, is prepared, reviewed, approved, and retained prior to submission of reimbursement claims. Management should also implement periodic monitoring procedures to ensure consistent compliance across all school sites. Management Response Corrective Action Beginning with the 2025–2026 school year, we have implemented a requirement that all kitchen managers complete a daily meal count form provided by the New Mexico Public Education Department (NMPED) in collaboration with the Student Success and Wellness Bureau (SSWB). This documentation ensures accountability and verifies that reimbursable meals are being served for both breakfast and lunch. Additionally, we are currently exploring the implementation of a software program to further strengthen meal count accountability. The Food Service Supervisor will be working closely with the District finance department to identify funding opportunities for the 2026–2027 school year. Due Date of Completion: June 30, 2026 Responsible Party(ies): Director of Federal Programs
Recommendation The District should re-evaluate the control systems in place to ensure that all transactions have sufficient supporting documentation such that an independent third party could adequately review supporting documents and be able to conclude that the transaction was correctly recorded a...
Recommendation The District should re-evaluate the control systems in place to ensure that all transactions have sufficient supporting documentation such that an independent third party could adequately review supporting documents and be able to conclude that the transaction was correctly recorded and reviewed. Management Response Corrective Action The New Director of Exceptional Programs (EXPRO), working along with the New Human Resources Department and New Director of Finance, has reviewed all contract amounts to ensure accurate disbursement including updated recommendation forms. Review of account strings specific to positions has also been reviewed and appropriately adjusted for accurate IDEA-B payroll disbursements. Implementation of new time sheet process with proper documentation and transparency. Files will be pulled to correct the condition. Due Date of Completion: June 30, 2027 Responsible Party(ies): Director of Human Resources, Director of Exceptional Programs, Director of Finance
Management Response/Corrective Action Plan: The District was awarded funding with the Congressional funds with all parties aware the project would be substantially completed before funding would be finalized. Much of the wait was due to the review and approval of the Build America, Buy America (BABA...
Management Response/Corrective Action Plan: The District was awarded funding with the Congressional funds with all parties aware the project would be substantially completed before funding would be finalized. Much of the wait was due to the review and approval of the Build America, Buy America (BABA) waiver. Unfortunately, the agency that trained MSAD54 staff on the process recommended for the request of funds to be made. Subsequent all funding requests were approved by HUD representatives prior to receiving the BABA waiver. The Superintendent recognized the potential error and contacted HUD who worked with the District to correct their mistake and return funds. The waiver has since been approved, and all funds have been drawn down.
Management Response/Corrective Action Plan: The District is aware of the requirement and has a plan to ensure all performance reports are submitted timely in the future.
Management Response/Corrective Action Plan: The District is aware of the requirement and has a plan to ensure all performance reports are submitted timely in the future.
Management Response/Corrective Action Plan: The District discussed and reviewed during the prior audit cycle and has implemented a process to ensure all invoices are approved individually prior to payment.
Management Response/Corrective Action Plan: The District discussed and reviewed during the prior audit cycle and has implemented a process to ensure all invoices are approved individually prior to payment.
Management Response/Corrective Action Plan: The School Nutrition Department has implemented strengthened procedures by adding a separate count of meals served in the accounting department. These measures are intended to improve the accuracy claims submitted.
Management Response/Corrective Action Plan: The School Nutrition Department has implemented strengthened procedures by adding a separate count of meals served in the accounting department. These measures are intended to improve the accuracy claims submitted.
Management’s Response/Corrective Action Plan: Management has communicated directly with all staff responsible for student recordkeeping and cohort tracking at the high school level. The District procedural form for documenting student removals will be required in all cases. This form will serve as t...
Management’s Response/Corrective Action Plan: Management has communicated directly with all staff responsible for student recordkeeping and cohort tracking at the high school level. The District procedural form for documenting student removals will be required in all cases. This form will serve as the official record and must be completed, signed, and retained in accordance with district policy and audit requirements. No student will be removed from the cohort without completed and verifiable documentation.
The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Orga...
The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. Additionally, the Organization should implement a system that will file documents in an organized manner and make them easily accessible to the Organization and auditors. Furthermore, the Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight.
Condition: During testing of Student Financial Assistance (SFA) disbursements, the Institution did not maintain documentation demonstrating that required Title IV disbursement notifications were provided to students. For the students selected for testing, the Institution could not provide evidence t...
Condition: During testing of Student Financial Assistance (SFA) disbursements, the Institution did not maintain documentation demonstrating that required Title IV disbursement notifications were provided to students. For the students selected for testing, the Institution could not provide evidence that students were notified of the amount and type of Title IV funds they were scheduled to receive, nor the timing and method of the disbursements, as required by federal regulations and the Federal Student Aid (FSA) Handbook. As a result, we were unable to verify that the required notifications were issued. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that the Institution did not maintain sufficient documentation to demonstrate that required Title IV disbursement notifications were provided to students. Although it was the AAC's practice to communicate financial aid awards and disbursement information to students, management recognizes that documentation supporting compliance with the federal notification requirements was not consistently retained. Corrective Action Plan: The AAC has reviewed its Title IV disbursement notification process and is implementing procedures to ensure that all required notifications are generated, issued to students prior to disbursement, and retained in accordance with federal regulations and institutional record retention requirements. The AAC will also establish a standardized process for documenting the date, method, and content of each notification. Additionally, financial aid staff will receive refresher training on Title IV disbursement notification requirements, and supervisory reviews will be incorporated into the disbursement process to verify that required notifications have been issued and properly documented before funds are disbursed. Management believes these enhanced controls will strengthen compliance with federal requirements and ensure adequate documentation is maintained for future audits. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.
Condition: During testing of eligibility, 1 out of 40 students were not awarded their maximum subsidized loan amounts they should have been awarded. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that one student did not receive the maximum subsidized loa...
Condition: During testing of eligibility, 1 out of 40 students were not awarded their maximum subsidized loan amounts they should have been awarded. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that one student did not receive the maximum subsidized loan amount for which the student was eligible. The error resulted from an oversight during the financial aid packaging process and was not identified through the Academy's review procedures. Upon notification of the finding, the AAC reviewed the student's eligibility, recalculated the award, and initiated the appropriate corrective action to ensure the student received the correct subsidized loan amount, if still permissible under federal regulations. Management also reviewed its loan awarding procedures to identify opportunities to strengthen internal controls. Corrective Action Plan: To prevent similar occurrences, the AAC will implement an additional supervisory review of loan awards before disbursement, utilize system-generated eligibility reports to verify that students are awarded the maximum subsidized loan amount for which they qualify, and provide refresher training to financial aid staff on federal Direct Loan awarding requirements. Management believes these enhancements will improve the accuracy of loan packaging and reduce the likelihood of similar errors in future award years. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.
Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of t...
Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of the federally allowable COA. • One student’s COA was overstated, which resulted in the student being potentially overawarded. • Six student’s were awarded the incorrect COA based on the grade level reported on the Institutional Student Information Record (ISIR). However, there is no code for year 4 on the ISIR, which resulted in the students receiving year 3 COA. • Two students received aid in excess of their calculated financial need, and the Institution did not maintain documentation supporting the adjustments or exceptions. • One student was enrolled at three quarter time during the fall semester and full time during the spring semester; however, the student received three quarter time Pell Grant disbursements for both semesters, resulting in an underpayment for the spring term and inaccurate Pell reporting. These errors demonstrate inconsistent application of federal awarding rules and insufficient review of eligibility and enrollment status changes. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that the identified errors resulted from inconsistencies in the application of federal Student Financial Assistance awarding requirements and insufficient review of student eligibility, Cost of Attendance calculations, financial need determinations, and enrollment status changes. Management has reviewed each of the identified student files and is taking appropriate corrective action, including recalculating awards, making any required adjustments or corrections, and updating reporting where necessary. The AAC has also evaluated the circumstances surrounding the use of Cost of Attendance budgets, including the limitation of the Institutional Student Information Record (ISIR), which does not include a separate code for fourth-year undergraduate students. Procedures are being revised to ensure that staff apply the appropriate institutional Cost of Attendance budget regardless of the ISIR grade level code and that any manual adjustments are adequately documented. Corrective Action Plan: To strengthen internal controls, the AAC will implement enhanced review procedures for financial aid packaging, Cost of Attendance determinations, financial need calculations, enrollment status changes, and Pell Grant disbursements prior to disbursement. In addition, financial aid personnel will receive refresher training on federal awarding requirements, documentation standards, and exception processing. Management believes these corrective actions will improve compliance with federal regulations and reduce the likelihood of similar errors in future award years. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.
Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will...
Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.
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