Corrective Action Plans

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Auditor Description of Condition and Effect: Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. As a result of this condition, the District did not fully comply with the Uniform Guidance ...
Auditor Description of Condition and Effect: Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation: We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year. Corrective Action: As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance. Responsible Person: Maria Gistinger, Interim Chief Financial Officer Anticipated Completion Date: June 30, 2026
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Findin...
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2025-002 (a) Comments on the Finding and Recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action Taken - The Authority will establish internal tracking and reminder systems to ensure all required reports, including the final P&E and AMCC, are completed and submitted to HUD by the required due dates. Grant reporting responsibilities will be clearly assigned, and submission deadlines will be monitored by the Director of Finance to prevent future delays. These procedures will be implemented immediately. (c) Planned Implementation Date - The Authority plans to implement procedures during the year ending March 31, 2026 to resolve the reported finding.
View of the Responsible Official: We agree with the significant deficiency identified. Responsible Persons: School-based food service coordinators and Management director of food service Management Response: Training is conducted annually with school-based food service coordinators to ensure proper ...
View of the Responsible Official: We agree with the significant deficiency identified. Responsible Persons: School-based food service coordinators and Management director of food service Management Response: Training is conducted annually with school-based food service coordinators to ensure proper understanding of reporting requirements. During the 2025-2026 year standardized forms have been distributed to all school food service locations to ensure accurate counting and calculations, which will align with the monthly claim reimbursement reports submitted for reimbursement. It is the expectation that all school-based food service coordinators will properly utilize the updated forms and will receive training as necessary to ensure a thorough understanding of the importance of accurate reporting. Management’s food service director will increase oversight of the meal counts and claims reports to verify the accuracy of the reporting, and to ensure that the count records agree to the claims submitted. Anticipated Completion Date: June 30, 2026
Statement of condition 2025-001: For the year ended June 30, 2025, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839-...
Statement of condition 2025-001: For the year ended June 30, 2025, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD. Management should not pay any management fees until the executed Project Owner's/Management Agent's Certification (HUD-9839- B) is received. Action(s) taken or planned on the finding: Agree. Management received email correspondence from HUD on August 12, 2021 that stated the Agent is approved to take over management immediately and the Project Owner's/Management Agent's Certification (HUD-9839-B) would be retroactively effective. Management has continued to seek the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD.
Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a...
Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will continue to utilize CBIZ to provide ongoing fee accounting services to incorporate the recommendations listed above on a monthly basis. A comprehensive year-end checklist will continue to be utilized to ensure all financial reports are reconciled to the underlying support. (c) Planned implementation date of corrective action - Completed by March 31, 2026.
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: We have implemented a new policy that requires the Superintendent to review and sign-off on all outgoing EFT and ACH payments. We have implemented a new policy that requires the Superintendent to review and sign-off on all bank statements. Respons...
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: We have implemented a new policy that requires the Superintendent to review and sign-off on all outgoing EFT and ACH payments. We have implemented a new policy that requires the Superintendent to review and sign-off on all bank statements. Responsible Party(ies): • Superintendent and Board of Education Anticipated Completion Date: June 30, 2026
New depository agreements have been executed between the Housing Agency and the banks. Signature from HUD is pending.
New depository agreements have been executed between the Housing Agency and the banks. Signature from HUD is pending.
Views of Responsible Officials: In instances where Federal financial and programmatic reports were submitted after the due dates, delays were primarily driven by the time required to obtain and reconcile financial and programmatic data from subrecipients and to complete BRAC USA’s internal reviews a...
Views of Responsible Officials: In instances where Federal financial and programmatic reports were submitted after the due dates, delays were primarily driven by the time required to obtain and reconcile financial and programmatic data from subrecipients and to complete BRAC USA’s internal reviews and sampling procedures. While this resulted in late submissions, our priority was to ensure the completeness, accuracy, and integrity of reported information rather than compromising quality for timeliness. To strengthen compliance going forward, in any instance where BRAC USA anticipates a delay in submitting required Federal financial or programmatic reports, we will proactively communicate with donor or the pass-through entity in advance of the due date, explain the reasons for the delay (including any timing issues related to subrecipient data), and request written approval of a revised reporting deadline. This approach will help ensure transparency, maintain the donor’s ability to effectively monitor grant performance, and document mutual agreement on adjusted submission dates, while still allowing BRAC USA to complete the necessary review and reconciliation procedures to ensure accurate and reliable reporting. Planned Completion Date: December 31, 2025
Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that ...
Views of Responsible Officials: In practice, BRAC USA has consistently evaluated subrecipient risk prior to issuing subawards by considering factors such as prior experience with similar awards, historical audit results, organizational capacity, and financial stability. However, we acknowledge that these assessments were not formalized or consistently documented in a standardized format, as required by 2 CFR § 200.332(c). To address this gap, BRAC USA will develop and implement written procedures and a standardized subrecipient risk assessment tool to be completed and filed prior to issuing Federal subawards. The tool will capture required criteria, including prior audit results, prior performance under similar awards, financial stability indicators, internal control considerations, and any recent staffing or systems changes. These procedures will be incorporated into BRAC USA’s Fiscal Policies and Procedures Manual. The results of each risk assessment will be used to tailor the level and nature of ongoing subrecipient monitoring, and records will be maintained in the grant file to evidence compliance with 2 CFR § 200.332(c). Planned Completion Date: April 30, 2026
Condition For one of the four reports tested for the Higher Education Institutional Aid Program, City Colleges did not timely submit a quarterly report to the Pass-Through Entity (PTE). A quarterly performance report was due on May 1, 2025 and submitted 14 days late on May 15, 2025. Cause Submission...
Condition For one of the four reports tested for the Higher Education Institutional Aid Program, City Colleges did not timely submit a quarterly report to the Pass-Through Entity (PTE). A quarterly performance report was due on May 1, 2025 and submitted 14 days late on May 15, 2025. Cause Submission delay was the result of miscommunication between PIs and the grantor. Corrective Action Taken or Planned The Institutional Resource Development (IRD) team will review all subaward grant contracts and work with the colleges to ensure that Tasks are entered into the Salesforce system to provide automatic two-week reminders to the PIs when performance reports are due to the pass-through entity (PTE). Contact Person: Lizz Gardner, Associate Vice Chancellor, Institutional Resource Development Anticipated Completion Date: January 31, 2026
Condition For one out of forty students tested, City Colleges properly recalculated a return of Title IV funds for a student but did not subsequently adjust the student's account to perform the return or notify the student of the adjusted award amount. Cause The lack of return of Title IV funds was ...
Condition For one out of forty students tested, City Colleges properly recalculated a return of Title IV funds for a student but did not subsequently adjust the student's account to perform the return or notify the student of the adjusted award amount. Cause The lack of return of Title IV funds was an oversight due to human error. Corrective Action Taken or Planned To strengthen internal controls, the District Office assigned an analyst to conduct a review of a random selection of files across all seven colleges scheduled for audit to help identify any discrepancies early and ensure compliance. All R2T4 specialists will receive yearly refresher trainings on R2T4 procedures and controls. Contact Person: Leticia Garcia, District Director of Student Financial Aid Anticipated Completion Date: December 13, 2025
Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action For future projects of this nature that are funded with federal dollars the District will implement a written procedure to ensure weekly certified payrolls are obtained, reviewed, and documented prior to payment approval. ...
Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action For future projects of this nature that are funded with federal dollars the District will implement a written procedure to ensure weekly certified payrolls are obtained, reviewed, and documented prior to payment approval. The District will communicate these requirements to contractors and maintain a monitoring log going forward. Proposed Completion Date Fiscal year ended June 30, 2026
Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action In the future all supporting documentation will be retained by Business Office personnel and kept in the audit file. Proposed Completion Date Fiscal year ended June 30, 2026
Name of Contact Person Travis Sweeney, SFO Business Manager Corrective Action In the future all supporting documentation will be retained by Business Office personnel and kept in the audit file. Proposed Completion Date Fiscal year ended June 30, 2026
Responsible party: Bethany Johnson, Interim Executive Director and Commercial Lending Manager and Tyler Ward, Interim Finance Director and Commercial Lender Implementation date: December 31, 2025 Corrective Action Plan Both Bethany Johnson, Interim Executive Director and Commercial Lending Manager, ...
Responsible party: Bethany Johnson, Interim Executive Director and Commercial Lending Manager and Tyler Ward, Interim Finance Director and Commercial Lender Implementation date: December 31, 2025 Corrective Action Plan Both Bethany Johnson, Interim Executive Director and Commercial Lending Manager, and Tyler Ward, Interim Finance Director and Commercial Lender, will continue to monitor the budget vs actuals both on a monthly and quarterly basis. Tyler Ward will provide an initial review and Bethany Johnson will provide a secondary review of the financial statements. If any variances are more than 5% over within a category, this category and the overall variances of each line item will be monitored closely to determine if any cumulative changes would cause a 10% or more increase or decrease overall in addition to a particular category. If a budget revision is determined to be required, Tyler Ward will prepare this document and Bethany Johnson will review and sign before submitting it to SBA. A reminder will be added to both Bethany Johnson and Tyler Ward’s SCKEDD calendars along with the existing reporting reminders. This will serve as a secondary reminder to monitor the budget at 90, 60 and 30 days before the end of the grant year. This will ensure that any changes in the 4th quarter can be addressed before the budget revision cutoff date to SBA. Calendar reminders will be added on 12/15/2025, and financials statement variances towards the Microloan grant will be reviewed with more scrutiny moving forward beginning with December 31, 2025 financial statements.
Corrective Action: The organization has enhanced its payment workflow to guarantee prompt disbursement of funds to providers. Improvements include automated alerts and internal checkpoints designed to prioritize payments immediately after grant funds are received. Anticipated Completion Date: Correc...
Corrective Action: The organization has enhanced its payment workflow to guarantee prompt disbursement of funds to providers. Improvements include automated alerts and internal checkpoints designed to prioritize payments immediately after grant funds are received. Anticipated Completion Date: Corrected.
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
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