Corrective Action Plans

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2024-003 – Grant Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, Small Business Support Hubs Program passed through the Michig...
2024-003 – Grant Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, Small Business Support Hubs Program passed through the Michigan Strategic Fund. Auditor Description of Condition and Effect. Although we were able to review the quarterly reporting due during the fiscal year, we initially noted that the reports quarterly totals did not add up to the year-to-date totals, and total cost for the year reported, as well as quarterly totals, did not agree to the general ledger or the Schedule of Expenditures of Federal Awards. Management was able to subsequently correct these errors. Additionally, it was noted that there was no formal review and approval process over the completion and submission of the grant reports. As a result of this condition, the Organization reported inaccurate amounts to the grant pass-through agency. Auditor Recommendation. We recommend that the Organization base all grant financial reporting on general ledger detail of costs and that the reporting be reconciled to the Schedule of Expenditures of Federal Awards at year-end. In addition, all reports should be reviewed and approved by appropriate personnel prior to submission. Corrective Action. LEAP will be following the recommendation of basing all grant financial reporting on general ledger detail of costs and being more diligent in reconciling that ledger to the Schedule of Expenditures of Federal Awards at year-end. Further all reports moving forward will be reviewed and approved by CFO and COO in addition to the department head who is compiling with their team. LEAP’s modifications to its Grants Management SOP in 2025 are designed to also cover grant reporting process per Uniform Guidance requirements. This grant reporting issue too will be covered in the content of LEAP’s training for all management team members set to occur in August. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025
Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement po...
Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG 2 CFR 200.318 through 200.327 and will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. This will be in tandem with establishing effective internal controls as per Uniform Guidance 2 CFR 200.303. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by December 31, 2025.
Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely ...
Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely with project partners of federal grants to establish reporting deadlines and monitor individual reporting requirements throughout the year. This will be in tandem with establishing effective internal controls as per UGG 2 CFR 200.303. The Foundation will take steps to ensure that all required reports are submitted in a timely manner and all relevant documentation and evidence of reports’ submissions are retained in an effective manner. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and the process for internal monitoring documentation to be established by December 31, 2025.
As of today, September 29, 2025, the organization has fully implemented procedures in Populi to update enrollments to actual final status within the required 30 days. This data will be reported to our third-party servicer RGM in real-time. The academic and administrative teams review these reports.
As of today, September 29, 2025, the organization has fully implemented procedures in Populi to update enrollments to actual final status within the required 30 days. This data will be reported to our third-party servicer RGM in real-time. The academic and administrative teams review these reports.
Management will implement a formal tracking system and internal calendar reminders to ensure timely submission of audited financial statements in accordance with HUD requirements.
Management will implement a formal tracking system and internal calendar reminders to ensure timely submission of audited financial statements in accordance with HUD requirements.
Program Name - STOP Violence Grant- Victim Services CFDA Number - 16.588 Pass-through Entity - Michigan Department of Health and Human Service Condition and Description - For 4 out of 20 samples tested, during our testing of participant eligibility under the STOP Violence against Women Formula Grant...
Program Name - STOP Violence Grant- Victim Services CFDA Number - 16.588 Pass-through Entity - Michigan Department of Health and Human Service Condition and Description - For 4 out of 20 samples tested, during our testing of participant eligibility under the STOP Violence against Women Formula Grants, the Organization was unable to provide enrollment forms or supporting documentation. These forms are necessary to verify that participants met the program's eligibility criteria. YWCA Response- The YWCA Victim Services acknowledges this finding and has implemented the following corrective action plan to ensure compliance. Corrective Action Plan - Procedures exist to ensure all clients are enrolled and eligible for services under the STOP grant. In addition to documentation in the Apricot system, an additional legal screening process and intake forms are used to determine eligibility and complete client enrollment within a Victim Services application called MyCase. During the audit, documentation for the four identified cases from MyCase was erroneously excluded, causing the finding. As a subsequent event, the documentation for intake and eligibility for the four identified cases was provided to the external auditors. This process will continue, and future audits will include client documentation for both systems. Additionally, Enforcement of enrollment procedures within Apricot, and oversight from department Directors, has been made a priority. Time Frame for Correction -Appropriate procedures were in place during the full audit year of 2024 and will continue into future years. Corrective action related to documentation within the Apricot system was implemented in August 2025. Individuals Responsible - Jessica Glynn, Vice President of Victim Services and Kellie Swikoski, Grant Manager.
View Audit 369986 Questioned Costs: $1
Program Name - Temporary Assistance for Needy Families (TANF); Services for Trafficking Victims; Violence Against Women Formula Grants CFDA Number- 93.558 16.320, 16.588 Finding Type - Significant Deficiency and Noncompliance Condition and Description - During our procedures, we noted, the Agency di...
Program Name - Temporary Assistance for Needy Families (TANF); Services for Trafficking Victims; Violence Against Women Formula Grants CFDA Number- 93.558 16.320, 16.588 Finding Type - Significant Deficiency and Noncompliance Condition and Description - During our procedures, we noted, the Agency did not properly allocate its employees' leave hours for employees working on multiple activities. For 13 out of 20 samples selected for testing, Controls were not in place to ensure that leave time was proportionately distributed based on actual time worked on each activity. YWCA Response - The YWCA Victim Services acknowledges this finding and has implemented the following corrective action plan to ensure compliance. Corrective Action Plan - No employee leave hours are to be billed to the TANF grant. The cost of employee leave will be borne by non-governmental grants for all Victim Service staff. Time Frame for Correction - Corrective action was implemented in April 2025. Individuals Responsible- Marcy Dix, Director of Grant management with oversight from Jodi Breithart, CMA, MAcc, Vice President of Finance.
View Audit 369986 Questioned Costs: $1
2024-003 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Condition and Effect: The Organization did not register or submit any subaward information through the FFATA Subaward Reporting System (“FSRS”) reporting system as required by the Uniform Guidance...
2024-003 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Condition and Effect: The Organization did not register or submit any subaward information through the FFATA Subaward Reporting System (“FSRS”) reporting system as required by the Uniform Guidance. The Organization did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate subaward reporting that is required for prime recipients. Auditor Recommendation: We recommend that the Organization establish and implement procedures for FFATA reporting through FSRS and ensure that all key data are reported timely moving forward. Corrective Action: When granting funds as a subaward to a pass-through entity, the Organization will update its records for subawards to include the required information and therefore comply with FFATA reporting requirements for direct awards. Responsible Person: Dora Gonzales Anticipated Completion Date: December 2025
2024-002 - Lack of Independent Review and Approval Auditor Description of Condition and Effect: During our testing of Allowable Costs/Cost Principles, of the 12 items tested, we noted all 12 instances where time sheets were missing evidence of review and approval. In addition, there was no evidence ...
2024-002 - Lack of Independent Review and Approval Auditor Description of Condition and Effect: During our testing of Allowable Costs/Cost Principles, of the 12 items tested, we noted all 12 instances where time sheets were missing evidence of review and approval. In addition, there was no evidence of review and approval of the hourly rate or salary for all the employees tested. During Cash Management testing, of the three items tested, all three drawdown requests were missing evidence of review and approval. Finally, during our testing of Reporting, all four of the reports selected for testing lacked evidence of review and approval. The Organization did not comply with the federal requirements as noted per 2 CFR 200.303. Auditor Recommendation: We recommend the Organization adheres to their internal control process of an independent review and approval of transactions, cash management and reporting related to federal grant programs. Corrective Action: While the Organization has controls in place to ensure proper review and approval, Management will ensure to have this process documented going forward. Responsible Person: Dora Gonzales Anticipated Completion Date: December 2025
WWBIC plans to develop and adopt a written Cost Allocation Plan that complies with 2 CFR 200. Ml P's Cost Allocation Module will be implemented for efficiency and automation. WWBIC plans to use a direct method of recording staff time, by requiring staff to allocate time on time sheets by funding sou...
WWBIC plans to develop and adopt a written Cost Allocation Plan that complies with 2 CFR 200. Ml P's Cost Allocation Module will be implemented for efficiency and automation. WWBIC plans to use a direct method of recording staff time, by requiring staff to allocate time on time sheets by funding source. Once payroll postings align with funding sources, direct wages will be used as the allocation base. The 3rd party payroll integration with Paylocity will be implemented to use this method. This project is currently under development with our payroll system, Paylocity and the accounting team.
A comprehensive Fiscal Policies and Procedures Manual will be developed that incorporates all required written procedures under 2 CFR 200 and defines internal controls and implementation processes. Accounting staff, and members of WWBIC's Compliance and Advancement teams, will receive training on th...
A comprehensive Fiscal Policies and Procedures Manual will be developed that incorporates all required written procedures under 2 CFR 200 and defines internal controls and implementation processes. Accounting staff, and members of WWBIC's Compliance and Advancement teams, will receive training on the guidelines and requirements of the Schedule of Expenditures of Federal Awards (SEFA). As Federal and State funding is approved, WWBIC will flag the related accounts during set up to ensure that they are marked to be included in the SEFA. WWBIC will contact our auditors with possible questions before compiling and finalizing the SEFA.
Management is committed to ensuring that we are in compliance with all Head Start regulations required by the Department of Health and Human Services and other regulatory bodies. Management will ensure that the indirect cost calculations complies with all regulations prospectively.
Management is committed to ensuring that we are in compliance with all Head Start regulations required by the Department of Health and Human Services and other regulatory bodies. Management will ensure that the indirect cost calculations complies with all regulations prospectively.
View Audit 369964 Questioned Costs: $1
Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with...
Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with the Department of Health and Human Services and other regulatory bodies to ensure proper completion of subaward reports in FSRS, the SF429 and other required reporting. The above noted issue was discovered during the course of the 2024 audit. Upon discovery of the requirement, Management took the above noted steps to become compliant. The finding repeated in 2024 is solely due to the lack of clarity as to the timing of the reporting. Effective to date, all FSRS and applicable SF429 reports have been filed correctly and timely.
Federal Single Audit Finding: 2024-001 - Significant Deficiency in Internal Control and Noncompliance with Special Tests and Provisions in Application of Organization's Sliding Fee Discounts Policy Name of Contact Person: Jennifer Youngberg, Chief Financial Officer Corrective Action: We have reviewe...
Federal Single Audit Finding: 2024-001 - Significant Deficiency in Internal Control and Noncompliance with Special Tests and Provisions in Application of Organization's Sliding Fee Discounts Policy Name of Contact Person: Jennifer Youngberg, Chief Financial Officer Corrective Action: We have reviewed our Sliding Fee Discount Policy to ensure alignment with HRSA requirements. Staff responsible for eligibility and billing will receive refresher training. Supervisory reviews of a sample of applications will occur quarterly, with results tracked and reported to the Leadership Team. Each individual involved in the process will be made aware of their role, with clear separation of duties between operational and accounting functions. These actions will strengthen internal controls and ensure consistent application of the Sliding Fee Discount Policy going forward. Proposed Completion Date : December 31, 2025
Immediate Reimbursement: The Housing Authority will initiate the reimbursement of the Public Housing Program for the identified rental assistance funds. Policy and Procedure Updates: Internal cash management policies are being revised to establish clear timelines and responsibilities for fund reimbu...
Immediate Reimbursement: The Housing Authority will initiate the reimbursement of the Public Housing Program for the identified rental assistance funds. Policy and Procedure Updates: Internal cash management policies are being revised to establish clear timelines and responsibilities for fund reimbursements. Staff Training: All relevant personnel will receive training on HUD’s cash management requirements and the updated internal procedures to ensure consistent and timely compliance. Monthly Monitoring: A monthly reconciliation and review process will be implemented to monitor fund transfers and reimbursements. This will be overseen by the Finance Director and reported to the Executive Director quarterly. Fee Accountant Oversight: To strengthen financial oversight, the Housing Authority will engage a fee accountant to serve as an additional layer of review. This professional will provide independent verification of financial transactions and ensure compliance with HUD cash management standards.
2024-007 - Significant Deficiency in Internal Control and Non-material Noncompliance - Schedule of Expenditures of Federal Award Awareness and Preparation WPHW understands this finding and will be implementing further steps to ensure full compliance with this finding. The follow process has been put...
2024-007 - Significant Deficiency in Internal Control and Non-material Noncompliance - Schedule of Expenditures of Federal Award Awareness and Preparation WPHW understands this finding and will be implementing further steps to ensure full compliance with this finding. The follow process has been put in place to ensure compliance: 1) Director of Accounting and Grants Director will ensure they have appropriate training and work collaboratively to develop documentation process a. The Grant Director will update all grants as they are received, to ensure an accurate list of grants b. The Director of Accounting will update all the financial data for each grant 2) The Director of Accounting will be responsible for the review and submitting document to the auditing firm For FY25, the Director of Accounting and Grant Director will jointly build the document and review to ensure completeness and accuracy. Person(s) Responsible: Beth McLean, Director of Accounting Timing for Implementation: FY25-FY26
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the financial and performance reports prior to submitting to the federal agency. This re...
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer documents their review of the financial and performance reports prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization is finalizing the Federal Grant Report Review and Submission Protocol whose purpose is to ensure that all federal funding programmatic reports and FFRs are accurate, complete, and compliant with grant requirements and federal regulations before they are submitted to the funding agency. This form will be filed in the project folder.
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer document their review of the claim prior to submitting to the federal agency. This review would include comparing ...
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a formal control where someone other than the preparer document their review of the claim prior to submitting to the federal agency. This review would include comparing the amounts in the report to the general ledger or other supporting documents. This review should be supported by documenting the signature and date prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has created a process to ensure that claims are reviewed and approved prior to submission to the funder. This starts with the Claim/Billing Approval Form that is prepared by the Grants Manager/Designee and is routed to the Project Manager along with the supporting documentation. Once the form has been approved and electronically signed by both staff, it will be saved in the Organization’s internal files, and the claim will be initiated in the funder portal. Name(s) of the contact person(s) responsible for corrective action: Jill Matchett, Grants Manager Planned completion date for corrective action plan: October 10, 2025
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over payrates, payroll registers and time & effort studies. This review would include comparing the...
Partnerships for Climate-Smart Commodities – Assistance Listing No. 10.937 Recommendation: We recommend the Organization implement a compensating control to formally document their review and approval over payrates, payroll registers and time & effort studies. This review would include comparing the payroll processed and allocated to the grant to the approved time and effort documentation by funding source to ensure payroll costs are not being overcharged. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization’s practice is to require management approval before employee payrates are changed and before each payroll is initiated in the system. This practice was in place in 2024, but documentation of management approval had not been consistently maintained. The Organization will implement a process where any changes to an employee payrate is approved by a member of management via email prior to the change taking effect. Similarly, the Organization will implement a process where before payroll is processed each pay period, a member of management will review and document their approval of the payroll register via email or via the payroll system itself. In late 2024, the Organization began conducting quarterly time studies by position and adjusting allocations as time spent deviates from the most recent time study. These time studies are approved by the Organization’s management via email correspondence. Name(s) of the contact person(s) responsible for corrective action: Angie Sullivan, Director of Operations Planned completion date for corrective action plan: October 31, 2025
Housing Voucher Cluster-Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is...
Housing Voucher Cluster-Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their process and internal controls for new tenants to ensure compliance with HUD requirements and their administrative plan. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will review our process and internal controls for new tenants to ensure compliance with HUD requirements and our administrative plan. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: December 31 , 2025
Housing Voucher Cluster-Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their failed inspection process to ensure that any abatement/contract modifications are performed timely and in accordance with the compliance requirements. We recommend that the Aut...
Housing Voucher Cluster-Assistance Listing No. 14.871/14.879/14.EHV Recommendation: We recommend the Authority review their failed inspection process to ensure that any abatement/contract modifications are performed timely and in accordance with the compliance requirements. We recommend that the Authority utilize Yardi software to its full potential in terms of inspection documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Director of Housing will ensure the failed inspection process is performed timely and the documentation is maintained within the Yardi software program. Processes will be reviewed and updated to ensure timely correction and enforcement. Name(s) of the contact person(s) responsible for corrective action: Director of Housing Planned completion date for corrective action plan: December 31, 2025
View Audit 369839 Questioned Costs: $1
Federal agency: U.S. Department of Health and Human Services Federal Award Project Title: Better Family Life’s Relationship, Education, Advancement, and Development for Youth for Life Project Assistance Listing Number: 93.086 Assistance Listing Program Title: Healthy Marriage Promotion and Responsib...
Federal agency: U.S. Department of Health and Human Services Federal Award Project Title: Better Family Life’s Relationship, Education, Advancement, and Development for Youth for Life Project Assistance Listing Number: 93.086 Assistance Listing Program Title: Healthy Marriage Promotion and Responsible Fatherhood Grants Award Period: September 30, 2023 – September 29, 2024 Award Period: September 30, 2024 – September 29, 2025 Federal agency: U.S. Department of Health and Human Services Federal Award Project Title: Better Family Life’s Teen Pregnancy Prevention Education Assistance Listing Number: 93.297 Assistance Listing Program Title: Adolescent Health Programs Award Period: July 1, 2023 – June 30, 2024 Award Period: July 1, 2024 – June 30, 2025 Management response to 2024-002: In response to the auditors’ recommendation, management has addressed this deficiency by assigning appropriate personnel to review and approve all Federal reporting before submission. Additionally, management has implemented specific procedures for review and approval of drawdown requests, which include reviewing the indirect cost rate applied in all drawdown requests.
Views of Responsible Officials and Planned Corrective Action: The Authority has recognized the deficiencies in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Rossaine Ricketts, Comptroller, is responsible for implement...
Views of Responsible Officials and Planned Corrective Action: The Authority has recognized the deficiencies in the Housing Voucher Cluster and will implement internal control procedures that will ensure compliance with federal regulations. Rossaine Ricketts, Comptroller, is responsible for implementing this corrective action by December 31, 2025.
Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files during management transitions to ensu...
Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files during management transitions to ensure compliance with HUD requirements. Action Taken: The Company will start randomly testing a small sample of tenant files, as part of our quarterly site inspection. Additionally, Kay-Kay Realty, a third-party vendor is already engaged to review tenant move-in and recertification files, but the prior resident manager was selecting the files to review. We will now ask Kay-Kay Realty to randomly select tenant files for their review process. Contact person: Patrick Delaney; (808) 523-5681, ext. 693 Anticipated Completion Date: October 1, 2025
Ref. No. 2024-001: Missing Signatures Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files...
Ref. No. 2024-001: Missing Signatures Recommendation: The Company should consider reevaluating their established procedures and controls currently in place to ensure full compliance with regard to eligibility and proper maintenance of tenant information, including policies for handling missing files during management transitions to ensure compliance with HUD requirements. Action Taken: The Company will start randomly testing a small sample of tenant files, as part of our quarterly site inspection. Additionally, Kay-Kay Realty, a third-party vendor is already engaged to review tenant move-in and recertification files, but the prior resident manager was selecting the files to review. We will now ask Kay-Kay Realty to randomly select tenant files for their review process. Contact person: Patrick Delaney; (808) 523-5681, ext. 693 Anticipated Completion Date: October 1, 2025
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