Corrective Action Plans

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Finding 2025-001. The management company is required to use the Enterprise Income Verification for eligibility determination per the compliance supplement. There are numerous reports required to be created and reviewed by management on a periodic basis. (1) Recommendation: The management company sho...
Finding 2025-001. The management company is required to use the Enterprise Income Verification for eligibility determination per the compliance supplement. There are numerous reports required to be created and reviewed by management on a periodic basis. (1) Recommendation: The management company should acquire access to the HUD EIV, and begin producing and reviewing the required reports within required timeframes. The organization should further establish procedures that will ensure ongoing compliance. These procedures should include training and monitoring of responsible staff. (2) Actions Taken: Management has worked with HUD to obtain access and will begin performing this responsibility. The appropriate reports will be produced and reviewed once management has access to the HUD EIV system. Procedures are being implemented to assure that this process is taking place.
Finding 2025.002 - Sliding Fee Scale Discount Recommendation The Organization should strengthen internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Action Taken • Monthly Audits o The Front Office Coordinators at each location will routinely audit...
Finding 2025.002 - Sliding Fee Scale Discount Recommendation The Organization should strengthen internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Action Taken • Monthly Audits o The Front Office Coordinators at each location will routinely audit sliding fee verification on a monthly basis to verify that information has been captured and recorded correctly and all proof of income documentation is received. These monthly audits will be adopted as standard protocol and procedure for front office operations, effective January 2025. Any findings through the audit process will be reported to the COO. At least five patient charts will be audited monthly. o In addition, the Revenue Cycle Manager will also review audit findings or summaries to ensure adequate adjustment to patient accounts to correlate with the patient's eligibility status. • Staff Training o Although Heartland has offered periodic sliding fee scale procedure training, administration will be scheduling additional training with a focus on required documentation and proper analysis and implementation of sliding fee discounts. o COO and Revenue Cycle Manager will review, implement and update standard operating procedure for sliding fee scale verification. o Employees will receive a copy of the sliding fee scale policy and sign that they have read the material. o Front office employees at all locations will complete a sliding fee schedule competency check-off sheet that will be reviewed by the Front Office Coordinators and Revenue Cycle Manager.
Corrective Action Plan: Management agrees with the finding and will take steps to adjust the budget and ensure the R&R account is adequately funded moving forward. Anticipated Completion date: 07/14/2025
Corrective Action Plan: Management agrees with the finding and will take steps to adjust the budget and ensure the R&R account is adequately funded moving forward. Anticipated Completion date: 07/14/2025
RESPONSE: The practice of checking the debarment list had occurred in the past; the keeping of a "proof of practice" was not done. Going forward, this practice will be documented. TIMEFRAME FOR CORRECTIVE ACTION: Immediate. RESPONSIBLE CONTACT PERSON: Katy Posey, Financial Director/Treasurer
RESPONSE: The practice of checking the debarment list had occurred in the past; the keeping of a "proof of practice" was not done. Going forward, this practice will be documented. TIMEFRAME FOR CORRECTIVE ACTION: Immediate. RESPONSIBLE CONTACT PERSON: Katy Posey, Financial Director/Treasurer
Description: Significant deficiency in internal control over compliance related to reporting. Cause: Though the Organization has established internal controls for submitting covered subawards as required by the Transparency Act, the Organization made an incorrect determination that the covered subaw...
Description: Significant deficiency in internal control over compliance related to reporting. Cause: Though the Organization has established internal controls for submitting covered subawards as required by the Transparency Act, the Organization made an incorrect determination that the covered subaward was under the required reporting limit. Effect: The Organization did not comply with the subaward reporting requirements as specified in 2 CFR 170. Corrective Action: • The Organization’s management and Board of Directors understand the requirement and importance of complying with the Federal Funding Accountability and Transparency Act. Our Accounting & Finance Policy and Subrecipient Monitoring Policy have both been updated to clearly assign the responsibility for timely reporting of subawards. The covered subaward that was not reported in FY25 was reported promptly as soon as this issue was raised as part of the audit. Contact Person: Daniel Pulse, CFO Anticipated completion date: November 2025, Corrective action has been completed.
The following actions will be taken to ensure compliance with the Uniform Guidance requirements over internal controls: Management concurs with the finding. Effective immediately, The Greater Washington Community Foundation has implemented the following corrective actions: (1) Prior to entering into...
The following actions will be taken to ensure compliance with the Uniform Guidance requirements over internal controls: Management concurs with the finding. Effective immediately, The Greater Washington Community Foundation has implemented the following corrective actions: (1) Prior to entering into any subaward agreement involving federal funds as well as at the time of each payment, designated staff will verify that potential subrecipients are not suspended or debarred by conducting searches in the System for Award Management (SAM) at www.sam.gov, with documentation maintained in the grant file. This verification will also be performed when subaward agreements are amended or extended. (2) The standard subaward agreement template will be updated to include all required information specified in 2 CFR §200.332(b)(1), including the federal assistance listing number, subrecipient's unique entity identifier, federal award project description, amount of federal funds obligated, total federal award amount, applicable compliance requirements, and reporting and monitoring requirements. To strengthen ongoing compliance, the Foundation's procurement and cash management policies have been updated to incorporate these federal compliance requirements and will be reviewed annually. Given that federal funding is not received on a recurring basis, upon receipt of future federal funding, the Controller will serve as the Compliance Coordinator with full oversight of compliance activities. The Controller will review applicable federal regulations, update internal procedures as necessary, and provide comprehensive training to appropriate staff managing the contract to ensure adherence to all grant requirements. The finance team will complete a quarterly review process to verify that all active federal subawards contain required compliance elements, with the Controller maintaining oversight of this review and reporting any deficiencies to the Chief Financial Officer for immediate remediation. Individual Responsible for Corrective Action Plan: Contact: Rachel Crawford Title: Controller Phone Number: 202-303-2437 Estimated Completion Date: December 31, 2025
The Authority will consider implementing the recommendation. The Authority is actively working on rectifying the finding.
The Authority will consider implementing the recommendation. The Authority is actively working on rectifying the finding.
Recommendation: Management should consider increasing the frequency of its self-reviews of sliding fee encounters, increasing the frequency of when patient portal updates are being reviewed and approved, and/or provide additional training for front desk staff regarding the collection and verificatio...
Recommendation: Management should consider increasing the frequency of its self-reviews of sliding fee encounters, increasing the frequency of when patient portal updates are being reviewed and approved, and/or provide additional training for front desk staff regarding the collection and verification of patient information for each patient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: See matrix below Name(s) of the contact person(s) responsible for corrective action: Hiren Patel, CFO Planned completion date for corrective action plan: See matrix below Finding 2025-002 / ACTION STEP 1 / ACTION STEP 2 / ACTION STEP 3 / ACTION STEP 4 Assigned / RCM Leaders / Executive Leaders / Patient Care Reps (PCRs) / Practice Managers / Enrollment Specialist/RCM Leaders Resources needed / Annual Federal Poverty Level (FPL) update issued no later than February of each year, given by federal government / Supporting financial documentation for all patients/applications / Athena (EHR system) / Audit tracking tools, EHR reports Actions to be taken / Audit EHR system to ensure timely update by EHR each year; updated internal QRG and distribute to Operations front-staff leaders and Compliance Update patient level amounts based on approval by Executive Leaders- as needed / Complete review of supporting financial documentation for each patient/application Upload documentation in EHR to support approval/disapproval-update EHR accordingly 85% collections of patient levels at time of service / Practice Manager Audits 25 SFS claims to ensure all documentation has been received, uploaded and reviewed accurately / Enrollment Specialist reviews patient account during self-pay collection efforts for all that have outstanding balances; ensures all have supporting documents aligning with approval, notifies RCM leaders monthly of inaccurate findings RCM Leaders audit 50-60 accounts quarterly to cover all sites Progress indicated at benchmark / Implement workflow / Implement workflow / Implement **NEW**Workflow / Implement workflow Completion date / February of each year / February 2026 / February 2026 / February 2026 Evidences of improvement / Reporting to ensure alignment / Monthly audit / Monthly audit / Monthly/Quarterly audit
Views of Responsible Officials and Planned Corrective Action
Views of Responsible Officials and Planned Corrective Action
The Hawaii Criminal Justice Data Center (the HCJDC) will perform a desk review for its two
The Hawaii Criminal Justice Data Center (the HCJDC) will perform a desk review for its two
subrecipients for grant number 202-NS-BX-K004 by June 30, 2026. The desk reviews will be performed
subrecipients for grant number 202-NS-BX-K004 by June 30, 2026. The desk reviews will be performed
virtually and will include a risk assessment and review of project performances and outcomes.
virtually and will include a risk assessment and review of project performances and outcomes.
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services s...
Immediate Corrective Action Taken: • Fiscal Services reviewed the Title I allocations to confirm that no improper fiscal impact occurred as a result of the reporting discrepancy. • The district documented the finding and communicated the error internally to Fiscal Services and Educational Services staff. • Roles and responsibilities for ConApp enrollment data review have been clarified to prevent future manual errors. Preventive Measures to Avoid Recurrence: 1. Dual Verification of ConApp Enrollment Data • The Accountant in Fiscal Services will now compare and confirm the ConApp enrollment counts to certified CALPADS Fall 1 data before submission and certification. • A second-level review by the Coordinator of Teaching and Learning Department certifying the ConApp. 2. Documentation & Recordkeeping • Any adjustments to pre-populated enrollment numbers will require written justification and supporting documentation (e.g., CALPADS reports, email confirmations). Responsible Parties: • Fiscal Services Accountant – Responsible for matching the ConApp enrollment counts to CALPADS Fall 1 and maintaining backup documentation. • Coordinator, Teaching and Learning Department – Support in verifying site-level data. Completion Date: • Immediate clarification and assignment of review responsibilities were completed in October 2025.
Immediate Corrective Action Taken: • Upon discovery, the Ocean View School District Fiscal Services Department reclassified the payroll cost from Title I to the employees regular special education funding account. • This journal entry was completed prior to closing the books for FY 2024-25, ensuring...
Immediate Corrective Action Taken: • Upon discovery, the Ocean View School District Fiscal Services Department reclassified the payroll cost from Title I to the employees regular special education funding account. • This journal entry was completed prior to closing the books for FY 2024-25, ensuring that Title I funding was fully restored and not negatively impacted. Preventive Measure to Avoid Recurrence: Budget Code Verification Process • Fiscal Services has implemented an additional review step for all extra duty or abnormal pay requests. Before processing, HR and Payroll staff must verify the program code against the employee’s funding source in the financial system. Responsible Parties: • Director of Fiscal Services – Oversight of corrective action and monitoring. • Payroll Supervisor & HR Coordinator – Verification of funding sources before processing extra pay. • Site Administrators – Correct budget coding on memoranda. Completion Date: • Immediate correction was made prior to FY 2024-25 year-end close (August 19, 2025).
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant ...
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant is received, the School District will print the grant documents and review them with the necessary employees to ensure they are aware of the allowable and unallowable costs. Additionally, all invoices will be reviewed by the Food Service Director prior to being submitted to the business office for payment. Responsible Party(ies): • Food Service Head Cook Anticipated Completion Date: December 31, 2025
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Scanning Applications: o CSFP staff scan applications daily. These applications are t...
Audit Finding: ALN: 10.565 Grant No.: 204642 Grant Period: Year ended September 30, 2025 Type of finding – Significant deficiency in internal control over compliance Response: Agree Explanation/Corrective Action:  Scanning Applications: o CSFP staff scan applications daily. These applications are then stored in SharePoint. We have 2-3 volunteers weekly who rename applications based on Client ID, Name, and Expiration Date, then file them electronically based on their expiration date. This ensures that we are always up to date on having an electronic version of our CSFP applications. o Before shredding any applications that have been scanned, we confirm that the application exists in the system (done by CSFP staff).  If an application is missing: o Confirm that application information is in ClientTrack and document through a generated printed application. o Send application to distribution site for next distribution, to ensure participant signs new application before they receive another CSFP box. Anticipated Completion Date: This process was fully implemented at the end of May 2024. It should be noted that the applications have a 3-year certification period, so the full effect of the new process won’t be realized until spring of 2027.
The Food Service Director will coordinate a check procedure to review monthly meal counts before submitting reimbursement from Michigan Department of Education. Contact person responsible for corrective action: Jenny Patton, Food Service Director, Anticipated Completion Date: 12/31/2025
The Food Service Director will coordinate a check procedure to review monthly meal counts before submitting reimbursement from Michigan Department of Education. Contact person responsible for corrective action: Jenny Patton, Food Service Director, Anticipated Completion Date: 12/31/2025
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not al...
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not all dining locations had their final meal counts completed before the meal claim was submitted. The persons responsible for the corrective action are Aaron Burnett, the Food Service Director and Emily Kearney, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that all meal counts are final on the Z-Report before the claim requests are made.
Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Pr...
Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Program 84.038 - Federal Perkins Loan Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loans Criteria: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their informationsharing practices to their customers and to safeguard sensitive data (16 CFR 314). institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with few that 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution's written information security program must address the implementation ofthe minimum safeguards identified in 16 CFR 314.4(c)(l) through (8) including: assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16CFR 314.4(d)). Condition/Context: Under a college's Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned Costs: Not applicable. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The Corporation's students' personal information could be vulnerable. Recommendation: We recommend the Corporation review each element of GLBA to ensure compliance with all necessary requirements. Corrective Action Plan: Corrective Action Planned: To ensure continued GLBA compliance the Corporation contracted with FRSecure to develop a risk assessment and roadmap which did a system scan for issues, an assessor interviewed staff including IT, HR, Finance Leaders and others to learn more about the current state of overall security program. Compliance with GLBA was part of their review. FRSecure issued an assessment 'Roadmap Plan' for the department to review and the Corporation will implement the results as feasible. Name of the contact person responsible for corrective action: John Sehloff, Director of Information Technology Anticipated Completion Date: June 30, 2026
Finding 2025-001: Education Stabilization Fund Special Reporting Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.425U and 84.425V Award numbers: COVID-19 213713 2122 and COVID-19 221037 2324 Award y...
Finding 2025-001: Education Stabilization Fund Special Reporting Procedures U.S. Department of Education Type of Finding: Control Pass-through agency: Michigan Department of Education Assistance Listing Numbers: 84.425U and 84.425V Award numbers: COVID-19 213713 2122 and COVID-19 221037 2324 Award year end: September 30, 2024 Recommendation: The School District should create a process for gathering all requirements for special reporting under Uniform Guidance and the School District should prepare and submit the necessary special reports. Action taken: The Finance Director has created a process for gathering all requirements for special reporting under Uniform Guidance and for preparing and submitting the necessary special reports. Responsible Person and Anticipated Completion Date: Finance Director, January 2026. If the Michigan Department of Education has questions regarding this plan, please call Todd Hronek at (231) 788-7109.
Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse b...
Identifying Number: 2025-002 Audit Finding: Per the U.S. Department of Agriculture at 7 CFR 226.16(d)(4) and the Missouri Department of Health and Human Services, sponsoring organizations must conduct three monitoring review visits for each of their facilities and no more than six months may lapse between monitoring visits for CACFP compliance. At least two of the three reviews must be unannounced. If a violation occurs during the visit, the sponsor must follow up with the facilities noted as having problems, and the follow-up visit must be conducted no less than one week after the initial finding, and the visit must be documented. Kansas City Public Schools did not perform the required three site visits per year within a six-month timeframe for five of the samples, and the supporting documentation provided for all six samples did not contain the total of participants in attendance during the meal service and the total number of meals claimed during the five consecutive days. Corrective Actions Taken or Planned: The District agrees with the finding. The District will implement and strengthen the following internal controls to ensure that all three required visits are accurately documented using the DHSS Site Visit Report by June 30, 2026: a. Training: Child Nutrition Services (CNS) will review and provide training to all supervisors and department leaders on DHSS Sponsor Review requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance b. SOP: CNS will utilize a central repository [CNSReporting@kcpublicschools.org] to streamline and time-stamp audit submissions. The original copy will be stored in a designated binder, and a digital copy will be retained in the CNS shared drive. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance c. Monitoring: C CNS leaders, as designated by the Officer of Nutrition & Compliance, will conduct Supper audits during SY 2025–2026 in September, December, and March. Snack audits will be conducted in November, February, and April. Additional audits will be scheduled as necessary to ensure compliance with program requirements. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance d. Reporting: As part of progress monitoring, at the end of each monitoring month, each applicable site will be reviewed to confirm completion & accuracy of a Sponsor Review. Person responsible for implementation: Katlyn Lanoue, Officer of Nutrition & Compliance
Finding 2025-002 - Significant deficiency in internal control over compliance Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented proce...
Finding 2025-002 - Significant deficiency in internal control over compliance Recommendation: The Academy should consistently utilize a point-of-sale system to track and claim the number of meals served. Action to be Taken: The Academy concurs with the facts of this finding and has implemented procedures to prevent this in the future.
Finding Summary - There were no formal agreements between the District and its subrecipients as required in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Responsible Individual - Terry Baesler, Superintendent Corrective Action Plan - The District will maintain ...
Finding Summary - There were no formal agreements between the District and its subrecipients as required in 2 CFR 200.331 and no formal subrecipient monitoring procedures were being performed. Responsible Individual - Terry Baesler, Superintendent Corrective Action Plan - The District will maintain formal agreements with the subrecipient entities that include the Uniform Guidance language and implement formal monitoring procedures were being performed. Anticipated Completion Date - 6/30/2026
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim had an incorrect subtotal of meals disbursed which resulted in the meal claim being submitted for less than it shoul...
This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim had an incorrect subtotal of meals disbursed which resulted in the meal claim being submitted for less than it should have been. There is a chance that the claim was done for the correct amount, but the supporting documentation shows that the District claimed less than they were allowed to. The District is going to ensure that all totals are subtotaled correctly in the future and double checked before the claim request is made. The persons responsible for the corrective action are Jack Ledford, the Food Service Director and Katrina Bontekoe, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that funds requested for meal reimbursements agree to total meals served.
2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Co...
2025-005 – Medicaid – Allowable Activities and Costs The District is aware of the student’s receiving benefits need to have their billed services included in their IEPs. Responsible Officials – Beth Munson, Director of Business Services and Lisa Blochwitz, Director of Student Services Anticipated Completion Date – The District intends to work towards resolving this finding for the following year.
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