Corrective Action Plans

Finding 540536 (2024-006)

Significant Deficiency 2024

New Mexico Department of Homeland Security & Emergency Management

NM

Reporting Subrecipient Monitoring Cash Management § 200.302 § 200.303

Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effecti...

Recommendation We recommend the Department review the instructions for completion of the federal financial reports with training provided to the program staff preparing and reviewing the federal financial reports to ensure submitted reports are complete. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Management Response Corrective Action: The Department understands the issues and is continuing to take corrective action to improve reporting. In the past the Department has shifted its priority to onboarding across the Department, and we have onboarded a Grants Unit Manager to oversee the reporting requirements of all federal grants. The Grants Unit will focus on procedures to ensure the reporting requirements are met. A procedural checklist will be implemented to ensure that: 1. the recipient share section is completed, 2. that financial reports are submitted to the Department timely, and 3. all Performance Progress Reports as submitted. Due Date of Completion: June 30, 2025 Responsible Person(s): Deputy Cabinet Secretary, Grants Unit Manager

View Audit 350283

Finding 540533 (2024-005)

Significant Deficiency 2024

New Mexico Department of Homeland Security & Emergency Management

NM

Subrecipient Monitoring § 200.332 § 200.521

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements ...

Recommendation We recommend updating internal policy over subrecipient monitoring and recommend implementation of effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable federal laws, regulations, and compliance requirements of various federal grants. It seems likely that additional monitoring activities are being performed that are not currently being documented in a central location, and therefore we recommend standardizing the documentation of such activities. Management Response Corrective Action: We concur with this finding and the auditor's recommendation. As stated in the past the Department is in the process of implementing policies and procedures to ensure proper monitoring of subrecipients. The Department has had two significant staff resignations that has hindered the progress on these corrections. The Department has found replacements and will continue with training for both the financial and the grants departments. Subrecipient monitoring tools, such as excel worksheets and checklists are being reviewed and modified to fit the Department's needs. The complete implementation of the subrecipient policies and processes is expected to be completed June 2025. Due Date of Completion: June 30, 2025 Responsible Person(s): Deputy Cabinet Secretary, Grants Unit Manager

View Audit 350283

Finding 540513 (2024-008)

Significant Deficiency 2024

State of Hawaii, Department of Accounting and General Services

HI

Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Finding No: 2024-008 ALN No.: 17.258 Program Title: WIOA Adult Program 17.259 Program Title: WIOA Youth Activities 17.278 Program Title: WIOA Dislocated Worker Formula Grant (WIOA Cluster) Grant Award No.: AA347643L0 2022 AA347645P0 2022 Condition During the audit, it was noted that an excess 0.63% ...

Finding No: 2024-008 ALN No.: 17.258 Program Title: WIOA Adult Program 17.259 Program Title: WIOA Youth Activities 17.278 Program Title: WIOA Dislocated Worker Formula Grant (WIOA Cluster) Grant Award No.: AA347643L0 2022 AA347645P0 2022 Condition During the audit, it was noted that an excess 0.63% of funds were allocated for employment and training activities for adults and dislocated workers. The lead WIOA accountant who completed the close-out report at issue is no longer employed by DLIR. Corrective Action Plan Following the departure of the lead WIOA accountant who completed the subject closeout report, the Administrative Services Office (ASO) has heightened fiscal training and internal controls among its two new WIOA accountants to ensure that the federal award is managed in compliance with all terms and conditions of the award, including requirements pertaining to subrecipient earmarking, so no more than 15% of funds are expended towards the administrative costs category for the WIOA Title I Adult, Dislocated Worker, and Youth Programs. The Workforce Development Council (WDC) is also in the process of contracting with a selected vendor to develop in-depth, in-person fiscal training to be held in June 2025 that will support fiscal staff, including local areas’ fiscal staff, to better understand and navigate the financial management and budgeting for Workforce Innovation and Opportunity Act (WIOA) services. Person Responsible Lynn Araki-Regan Anticipated Date of Completion June 30, 2025

View Audit 350263

Finding 540509 (2024-005)

Material Weakness 2024

State of Hawaii, Department of Accounting and General Services

HI

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No: 2024 005 ALN No.: 10.179 Program Title: Micro Grants for Food Security Program Grant Award No.: AM200100XXXXG132 2020 21MGFSPHI1003-00 2021 AM22MGFSPHI1007-04 2022 23MGFSPHI1011-00 2023 Condition The audit identified 25 instances totaling $55,000 where grantee disbursements were not mad...

Finding No: 2024 005 ALN No.: 10.179 Program Title: Micro Grants for Food Security Program Grant Award No.: AM200100XXXXG132 2020 21MGFSPHI1003-00 2021 AM22MGFSPHI1007-04 2022 23MGFSPHI1011-00 2023 Condition The audit identified 25 instances totaling $55,000 where grantee disbursements were not made as soon as administratively possible after the drawdown of Federal Funds. Audit staff determined 25 days to be a reasonable period to disburse cash after drawdown from the Federal Government. Corrective Action Plan Concur. The Hawaii Department of Agriculture (HDOA) will change administrative procedures for disbursement of Federal funds under the Micro Grants for Food Security Program. Going forward, HDOA will process the grant contracts and payments in batches of roughly 100 micro grants per month. Federal Drawdown will not occur until the full batch of 100 contracts have been executed. HDOA fiscal staff will then expedite the payment process to ensure conformity with the 25 day disbursement timeline. Person Responsible Brendan Akamu, Market Development Branch Manager Anticipated Date of Completion The updated work process will be implemented in April 2025. The first batch of grant contracts and payments for the 2023 Fiscal year awards are scheduled for April 2025.

View Audit 350263

Finding 540466 (2024-003)

Material Weakness 2024

Hawaii Pacific University

HI

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

This issue was initially identified by the University through HPU’s internal monitoring processes. The cause was significant staff turnover within a 6-month period (including the resignation of the Director of Financial Aid). The difficulties of temporarily reduced staffing and loss of institutional...

This issue was initially identified by the University through HPU’s internal monitoring processes. The cause was significant staff turnover within a 6-month period (including the resignation of the Director of Financial Aid). The difficulties of temporarily reduced staffing and loss of institutional knowledge were compounded by the challenges brought by the FAFSA Simplification Act, which required many changes, placing an additional burden on a strained team. Although the University attempted to adhere to its policies and procedures to ensure that R2T4 is processed within the allotted time, the team did not succeed in completing this function. The University replaced key staff, recruited a new Director, and shifted responsibilities so that a specific staff member is responsible for R2T4 processing. These changes have enabled the University to resume processing R2T4 timely, as was accomplished in previous years. Person(s) Responsible: Director of Financial Aid. Targeted Correction Date: January 31, 2025. This issue is resolved.

View Audit 350256

Finding 540465 (2024-002)

Material Weakness 2024

Hawaii Pacific University

HI

Subrecipient Monitoring Student Financial Aid

The Information Security Officer has developed a comprehensive project plan to implement the core 9 elements as listed under FTC Safeguards. The plan is backed by HPU’s 3rd party risk assessment conducted in November of 2024. The addition of a new hire and a part-time resource has facilitated signif...

The Information Security Officer has developed a comprehensive project plan to implement the core 9 elements as listed under FTC Safeguards. The plan is backed by HPU’s 3rd party risk assessment conducted in November of 2024. The addition of a new hire and a part-time resource has facilitated significant progress. Budget for necessary tools, software, and services such as penetration testing are being actively quoted for review by the Budget Office and CFO for both current and future fiscal years. Checkpoints have been established every two weeks to review and confirm substantial progress towards meeting all requirements and address any barriers or setbacks that may occur. The Vice President of Operations and CIO will review the progress support efforts to meet the requirements and targeted delivery date. The HPU Cybersecurity Committee will be provided with the 2024 Risk Assessment and the Information Security Program documentation and policies for both initial and ongoing review of the programs with the objective to further strengthen the program beyond minimum requirement. Person(s) Responsible: Information Security Officer; Vice President of Operations and Chief Information Officer. Targeted Correction Date: June 30, 2025.

View Audit 350256

Finding 540443 (2024-003)

Material Weakness 2024

City and County of Honolulu

HI

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No. 2024-003: Special Test and Provisions (Material Noncompliance and Material Weakness – Federal Awards) Federal Award: 14.231 – Emergency Solutions Grant Program Audit Recommendation: We recommend that the City be diligent in completing timely reviews to ensure that it complies with th...

Finding No. 2024-003: Special Test and Provisions (Material Noncompliance and Material Weakness – Federal Awards) Federal Award: 14.231 – Emergency Solutions Grant Program Audit Recommendation: We recommend that the City be diligent in completing timely reviews to ensure that it complies with the requirements. Administration’s Comment: The City will follow review procedures diligently to ensure timely payments of subrecipients. Anticipated Completion Date: January 2024 Contact Person(s): Steven Hayama, Department of Budget and Fiscal Services, Fiscal Officer II

View Audit 350255

Finding 540431 (2024-002)

Material Weakness 2024

City of Atlanta

GA

Subrecipient Monitoring Allowable Costs / Cost Principles

Name of Contact Person Responsible for Corrective Action Plan: Betty Smoot-Madison, Deputy Commissioner, Strategy and Planning, Atlanta Department of Transportation Corrective Action Plan: Management will implement a process to ensure entities receiving grant funds from the City are properly evaluat...

Name of Contact Person Responsible for Corrective Action Plan: Betty Smoot-Madison, Deputy Commissioner, Strategy and Planning, Atlanta Department of Transportation Corrective Action Plan: Management will implement a process to ensure entities receiving grant funds from the City are properly evaluated to determine whether they are classified as contractors or subrecipients. Subrecipients will be assessed for risk and ongoing monitoring will be conducted for all subrecipients based on the results of the City’s risk assessment. Anticipated Completion Date: Fiscal year 2025

View Audit 350251

Finding 540428 (2024-002)

Significant Deficiency 2024

City of Pasadena

CA

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Reference Number: 2024-002 Name of Contact Person: Armine Trashian, Controller Corrective Action: The City will implement recommendations and maintain all compliance-related documentation to ensure all necessary documents are maintained in accordance with ongoing compliance requirements. Proposed...

Reference Number: 2024-002 Name of Contact Person: Armine Trashian, Controller Corrective Action: The City will implement recommendations and maintain all compliance-related documentation to ensure all necessary documents are maintained in accordance with ongoing compliance requirements. Proposed Completion Date: June 30, 2025

View Audit 350245

Finding 540426 (2024-002)

Material Weakness 2024

County of Los Angeles

CA

Subrecipient Monitoring § 200.332 § 200.513 § 200.521

1. Person responsible: Assistant Auditor-Controller, Department of Auditor-Controller 2. Corrective action plan: The County agrees with the finding and recommendation. The County hired independent Certified Public Accounting (CPA) firms to monitor CSLFRF subrecipients. The CSLFRF subrecipient mon...

1. Person responsible: Assistant Auditor-Controller, Department of Auditor-Controller 2. Corrective action plan: The County agrees with the finding and recommendation. The County hired independent Certified Public Accounting (CPA) firms to monitor CSLFRF subrecipients. The CSLFRF subrecipient monitoring reviews are currently in progress, with the objective of evaluating each subrecipient’s fiscal/administrative procedures, internal controls, records, and compliance with contractual service requirements. Based on an agreed-upon schedule with the Department of the Auditor-Controller, the CPA firms will document their reviews by issuing reports detailing the procedures performed and any findings. The County will be responsible for obtaining corrective action plans from subrecipients, monitoring findings, and ensuring that corrective actions are implemented. 3. Anticipated implementation date: June 30, 2026

View Audit 350242

Finding 540425 (2024-001)

Material Weakness 2024

County of Los Angeles

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Department of Public Health (DPH), Emergency Preparedness Response Division (EPRD) agrees with the finding and recommendation. From the programmatic standpoint, beginning fiscal year 2024-2025, EPRD requires all on-line requisition (OLR) requestors to attach a SAM.gov verification for the reference...

Department of Public Health (DPH), Emergency Preparedness Response Division (EPRD) agrees with the finding and recommendation. From the programmatic standpoint, beginning fiscal year 2024-2025, EPRD requires all on-line requisition (OLR) requestors to attach a SAM.gov verification for the reference vendor to every OLR submitted. Anticipated implementation date: Implemented July 1, 2024 Department of Public Health (DPH), Administrative Services Division (ASD) – Procurement agrees with the finding and recommendation. The ASD Manager will email Procurement staff to remind them to ensure SAM.gov verification documents are included in all federally funded purchase documentation before finalizing or approving those transactions. DPH ASD will also maintain procurement related documentation justifying the method and rationale for vendor selection along with the purchase orders. Procurement related documentation will be retained in eCAPS for each transaction. Procurement Supervisors and Managers will be required to review and approve purchases to ensure all necessary documents are included in eCAPS. Anticipated implementation date: Implemented March 31, 2025.

View Audit 350242

Finding 540423 (2024-002)

Material Weakness 2024

County of Fresno

CA

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies a...

Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies and procedures, as necessary, to address all current regulatory requirements. The Department’s multifamily monitoring for all projects in the HOME period of affordability will be completed prior to June 30, 2025. As part of the monitoring process, the Department will document all records requiring annual or semi-annual oversight and review for compliance with HOME requirements. Should the monitoring result in any findings requiring corrective action, the Department will ensure all findings are addressed by September 30, 2025. Anticipated Completion Date May 2025 Contact Information of Responsible Official Name: Augustine Ramirez Title: Division Manager, DPWP Community Development Division Phone: 559-600-4266

View Audit 350241

Finding 540415 (2024-005)

Significant Deficiency 2024

County of Maui

HI

Subrecipient Monitoring § 200.332

Ref. No. Federal Award Findings 2024-005 Subrecipient Monitoring - Significant Deficiency Recommendation We recommend thee County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 View of Responsible Offici...

Ref. No. Federal Award Findings 2024-005 Subrecipient Monitoring - Significant Deficiency Recommendation We recommend thee County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 View of Responsible Officials and Planned Corrective Action Management concurs with this finding. As mentioned in Corrective Action 2024-001, due to the increase in federal grants, multiple departments are responsible for the oversight of these grants. The Department of Finance continues to face staffing challenges and did not have adequate personnel and resources for the continuous monitoring of these funds. A Countywide Grant Compliance Specialist position is in the process of being created by the Department of Personnel Services. This position will be primarily responsible for the monitoring of grants in according with the Uniform Guidance. End Date: Ongoing Responding Person(s): Marci Sato Accounting System Administrator Department of Finance Phone No. 808-270-7503

View Audit 350238

Finding 540343 (2024-001)

Significant Deficiency 2024

City of San Diego

CA

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact t...

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact that the FSRS.gov system has since been retired and integrated into the SAM.gov system acknowledges the need for reducing duplicate recording in favor of an integrated system. Staff’s understanding of the process was in line with available guidance currently still posted on HUD’s website (https://www.hud.gov/sites/dfiles/CPD/documents/CPD_FSRS_Learning_Session_Final_8.26.21.pdf). The City of San Diego did not receive notification of the FSRS deadline from HUD for Fiscal Year (FY) 2024. With regard to the dates entered in the FSRS.gov system, the agreements’ effective dates cover the entire fiscal year, and the awards were approved by our City Council to be in effect for the full fiscal year. Hence, staff entered the date July 1, 2023. Management accepts that going forward, dates should be entered based on the date the agreements are fully executed. Management agrees to include specific FFATA training and procedures in all CDBG manuals and checklists including procedures for compliance, if and when federal agency communication is late or lacking. Implementation Date: The conditions described above have already been corrected. FFATA training and procedures will be implemented within 30 days. Contact: Michele Marano Assistant Deputy Director, Community Development Economic Development Department City of San Diego Email: mmarano@sandiego.gov Phone: 619.236.6381

View Audit 350217

Finding 540342 (2024-004)

Significant Deficiency 2024

Yolo County Transportation District

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.318 § 200.326 § 200.327

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant d...

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant documentation. Management is actively working with consultants to update policies and procedures. Staff is scheduled to complete a structured three-session training through GFOA to enhance their understanding of federal procurement regulations and best practices. The District will continue training and development efforts in public procurement, with a particular focus on federal compliance, strengthening internal controls, improving documentation, and ensuring adherence to regulatory requirements Responsible Party: Director of Finance & Administration and Department Managers Implementation Date: Ongoing; full implementation expected by June 30, 2025

View Audit 350214

Finding 539677 (2024-006)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver ...

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver credit balance to students. The contract with the servicer should have been uploaded to the Dept of Ed database. Since the audit finding, the contract has been uploaded. ASU will upload the contract timely going forward. Estimated Completion Date: Effective Immediately Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (MVSU) Responsible Official: Mrs. Brittney Manuel-Carpenter, Account Receivable Supervisor Corrective Action Planned: MVSU acknowledged the findings of reference 2024-06 SFA-Special Test- Using a Servicer to Deliver Title IV Credit Balances. MVSU acknowledges that the servicer contract is uploaded to the Department of Education database and is available for viewing. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: University will contact the Department of Education Cash Management to correct the URL link. While the link was broken on the Cash Management site it was active on the USM Business Services website: https://www.usm.edu/business-services/refunds.php and is continually maintained on their site. Estimated Completion Date: April 1, 2025

View Audit 350191

Finding 539676 (2024-004)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that...

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that addresses all 7 required elements of the GLBA regulations: • Review GLBA Requirements: Conduct a thorough review of the Gramm-Leach-Bliley Act (GLBA) regulations to understand the 7 required elements. - Completed • Gap Analysis: A gap analysis has been performed to identify missing elements in the current information security program. - Completed • Program Development: Develop and implement policies and procedures to address the identified gaps. This includes administrative, technical, and physical safeguards. - In Progress • Training: Provide training to staff on the new policies and procedures to ensure compliance and proper implementation. - Planning • vCISO Support: Leverage the expertise of the newly hired virtual Chief Information Security Officer (vCISO) to guide the development and implementation of the information security program. - In Progress 2. Conduct a Comprehensive Risk Assessment to identify and address significant gaps in the risk assessment process: • Risk Assessment Framework: Establish a risk assessment framework that aligns with GLBA requirements. - In Progress • Identify Risks: Identify potential risks to the confidentiality, integrity, and availability of customer information. – In Progress • Evaluate Controls: Assess the effectiveness of existing controls and identify areas for improvement. – In Progress • Mitigation Plan: Develop a risk mitigation plan to address identified vulnerabilities and implement appropriate controls. - Planning • vCISO Support: Utilize the vCISO's expertise to ensure a thorough and effective risk assessment process. – In Progress 3. Monitoring and Continuous Improvement to ensure ongoing compliance and continuous improvement of the information security program: • Regular Audits: Conduct regular audits to ensure compliance with GLBA regulations and the effectiveness of the information security program. – Planning • Feedback Mechanism: Establish a feedback mechanism to gather input from staff and stakeholders on the effectiveness of the program. - Planning • Update Policies: Periodically review and update policies and procedures to address emerging threats and changes in regulations. – In Progress • vCISO Support: Engage the vCISO in monitoring and continuous improvement efforts to maintain high standards of information security. – In Progress 4. Reporting and Accountability to ensure accountability and transparency in the implementation of the corrective action plan: • Assign Responsibility: Assign responsibility for the implementation of the corrective action plan to a dedicated team or individual. - Planning • Progress Reports: Provide regular progress reports to senior management and stakeholders on the implementation of the corrective action plan. - Planning • Documentation: Maintain thorough documentation of all actions taken to address the identified issues. - Planning • vCISO Support: Include the vCISO in reporting and accountability processes to ensure expert oversight and guidance. – In Progress By following this corrective action plan and leveraging the expertise of the vCISO, MVSU can address the deficiencies in its information security program and risk assessment process, ensuring compliance with GLBA regulations and protecting customer information effectively. Estimated Completion Date: November 30, 2025

View Audit 350191

Finding 539669 (2024-009)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Subrecipient Monitoring § 200.332 § 200.501

Finding Reference: 2024-009 - Subrecipient Monitoring (UM) Responsible Official: Dr. John Higginbotham, Vice Chancellor of Research and Economic Development Corrective Action Planned: On March 13, 2025, the University of Mississippi issued amendments to notify the two subrecipients that the subawar...

Finding Reference: 2024-009 - Subrecipient Monitoring (UM) Responsible Official: Dr. John Higginbotham, Vice Chancellor of Research and Economic Development Corrective Action Planned: On March 13, 2025, the University of Mississippi issued amendments to notify the two subrecipients that the subawards issued under ALN 95.010 during the fiscal year ended June 30, 2024, were not classified as research and development. The University of Mississippi will ensure that subaward agreements, including all attachments, are reviewed for accuracy by a second party before issuance. Estimated Completion Date: March 13, 2025 Finding Reference: 2024-009 - Subrecipient Monitoring (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Similar to UMMC’s response on Finding Reference 2024-001, UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. The firm also provided Workday training sessions to help us understand how the different fields are supposed to be utilized, especially in cases where UMMC is either a subrecipient or has a subaward with a different institution. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539652 (2024-001)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Subrecipient Monitoring Reporting Student Financial Aid § 200.502

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department...

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, Alcorn State University has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: May 31, 2025 Finding Reference: 2024-001 - SEFA Reporting (DSU) Responsible Official: Jacnita Robinson, Grant Accountant Corrective Action Planned: Delta State University acknowledges the audit finding related to errors in the Schedule of Expenditures of Federal Awards (SEFA) reporting. The federal award in question was not intentionally omitted from the SEFA. At the time of SEFA preparation, Delta State University believed the award would be reported on the Mississippi Department of Finance and Administration’s SEFA, as they were identified as the recipient of the award. The University’s intention was to prevent the duplication of expenditures and avoid double-booking the same federal funds on both SEFAs. To prevent this type of error in the future, Delta State University will review and revise its internal controls and procedures for identifying and classifying federal awards. Additional training will be provided to the staff responsible for award set-up and SEFA reporting to ensure proper classification and communication with state agencies regarding the reporting responsibilities for pass-through and beneficiary awards. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (JSU) Responsible Official: Dr. Almesha Campbell, Vice President for Research and Economic Development Corrective Action Planned: Jackson State University will follow the procedures outlined for preparing the Schedule of Expenditures of Federal Awards. Such procedures include, but are not limited to the following: • Verify the ALN provided on the award documents and cover page and then enter it in Banner during the award set-up process. In addition, review the ALNs for continuation awards. If errors are identified during this process, they will be corrected. • Review previous year’s SEFA report and data support to ensure the report is in the format requested by IHL • Correspond with the Division of Business and Finance to include additional expenditures. Currently, the expenditures to include are 1) Direct Loans, 2) Expenditures with ALN 21.027, and 3) Perkins Loans Expenditures • The Director for Fiscal Reporting and Compliance will complete a subsequent review after the Director for Grants and Contracts prepares the report for submission. Furthermore, the newly created Oversight Committee will review the SEFA before submission to ensure that the Federal Perkins Loan program expenditures are included on the SEFA. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (MUW) Responsible Official: Rachel Sudduth, Assistant Director of University Accounting Corrective Action Planned: University Accounting will review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified, this would also include federal expenditures made through Mississippi Bureau of Buildings. Estimated Completion Date: March 21, 2025 Finding Reference: 2024-001 - SEFA Reporting (MVSU) Responsible Official: Mr. Samuel Melton, Director of Sponsored Programs/Title III Corrective Action Planned: Mississippi Valley State University will ensure that federal awards are correctly coded when preparing the Schedule of Expenditures of Federal Awards using the following procedures: • The Office of Business and Finance and Office of Sponsored Programs will verify the ALN provided on the award documents provided by the sponsor (i.e., federal agency and/or pass-through entity). If errors are identified during this process, they will be corrected. • The Director of Accounting will complete a subsequent review after the designated Staff Accountant prepares the report for submission. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (UM) Responsible Official: Dr. Steven G. Holley, Vice Chancellor for Administration and Finance Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024, was revised to include $131,454 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN 21.027. Additionally, the University of Mississippi has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 30, 2024 Finding Reference: 2024-001 - SEFA Reporting (USM) Responsible Official: Andrea Phillips, Controller Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $597,135 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, USM has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 23, 2024 Finding Reference: 2024-001 - SEFA Reporting (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539649 (2024-004)

Significant Deficiency 2024

Municipality of Florida

PR

Subrecipient Monitoring Reporting

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

Finding 539647 (2024-003)

Significant Deficiency 2024

Municipality of Florida

PR

Subrecipient Monitoring Reporting § 200.328

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

Finding 539640 (2024-005)

Significant Deficiency 2024

Nbcc

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to d...

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to demonstrate this. However, the case manager neglected to exit the individual from HMIS during the previous audit period. This has been corrected. No services or funds were provided to this individual following their exit from the program. Our program has a good track record of data compliance and we expect this was an exception and not the rule. Program management will review and train staff again on data compliance during a weekly staff meeting, and will also counsel the involved staff member on the error to ensure there is no similar future error. xiv. Contact Person (s) Responsible for Corrective Action: Cassie Roach, Safe Parking Program Director, croach@sbnbcc.org Joel Goforth, Homeless Services Director, jgoforth@sbnbcc.org xv. Anticipated Completion Date: The anticipated completion date is April 30, 2025.

View Audit 350179

Finding 539638 (2024-003)

Significant Deficiency 2024

Nbcc

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of ...

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of CoC and ESG grant funds. We perceived the historical general approval to be in alignment with the contract requirement of obtaining written approval for the reimbursement of costs incurred for travel outside the county. All costs submitted for reimbursement were eligible and reasonable expenses. We now understand this historical approval by HUD was not transferrable to this grant and therefore, moving forward, we will secure email approval of travel eligibility for specific grant reimbursement prior to travel. To that end, we have already been in contact with Housing and Community Development (HCD) fiscal staff at Santa Barbara County about a reliable method to secure said approvals in advance moving forward. If travel is not approved for a specific grant, or not obtained prior to travel, other unrestricted income will be utilized for that portion of the travel expenses. viii. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Victoria Garfield, Grants Administrator, vgarfield@sbnbcc.org ix. Anticipated Completion Date: Staff anticipate attending the annual NAEH conference this year, therefore we will request approval once registration is confirmed and expect to receive approval or rejection from County CD staff by no later than the date of travel, or approximately July 15, 2025.

View Audit 350179 Questioned Costs: $1

Finding 539635 (2024-001)

Significant Deficiency 2024

City of Concord

CA

Subrecipient Monitoring Reporting

Finding Reference Number: SA2024-001 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV ...

Finding Reference Number: SA2024-001 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-23-MC-06-0009 COVID-19 – B-20-MW-06-0009 • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Suzanne McDonald, Finance Operations Manager and Brenda Kain, Interim Community Services Manager • Corrective Action Plan: Management concurs with this recommendation. As of October 2024, the city has new staff managing the CDBG program. This staff will be trained on the FFATA reporting requirements and on how to meet those reporting requirements using the new SAM.gov/fsfr reporting platform. • Anticipated Completion Date: Calendar Year 2025

View Audit 350178

Finding 539632 (2024-002)

None 2024

Argus Manor Association

WA

HUD Housing Programs Subrecipient Monitoring Reporting

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in...

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in these months, resulting in a deficiency in the account. Although the funding deficit amounts were not always significant, it is important that the security deposit cash account be fully funded at all times. S3800-080: Auditor Recommendation: We recommend that property management implement a more robust process for monitoring and reconciling the security deposit cash account on a monthly basis. This process should ensure that the account balance is consistently maintained at the required level. Furthermore, management should conduct periodic reviews of the security deposit balances to identify and address any discrepancies promptly. Training for staff involved in managing security deposits should be considered to ensure compliance with HUD regulations and internal policies. FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT (Continued) S3800-010: Finding Reference Number 2024-002 (Continued) S3800-045: Actions Taken or to be Taken: It is management’s policy to fully fund the security deposit account so the balance in cash meets or exceeds the total liability of deposits collected from tenants. Management discussed the importance of reviewing funding monthly with the Project Accountant, and new procedures have been implemented to include a monthly process to compare the security deposit liability to the bank account and fund any shortages to ensure the security deposit bank account is consistently maintained at the required level.

View Audit 350177

Corrective Action Plans

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