Corrective Action Plans

Finding 537874 (2024-001)

Significant Deficiency 2024

NY

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit peri...

CORRECTIVE ACTION PLAN U.S. Department Education Hobart and William Smith Colleges respectfully submit the following corrective action plan for the year ended June 30, 2024 Name and address of independent public accounting firm: Bonadio & Co., LLP 171 Sully's Trail Pittsford, NY 14534 Audit period: July 1, 2023 - June 30, 2024 The findings from the 2024 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS AND QUESTIONED COSTS - MAJOR FEDERAL AWARD PROGRAMS SIGNIFICANT DEFICIENCY 2024-001 Timely Return of Title IV Funds Recommendation: We recommend that the Colleges assess and address staffing levels in the Student Financial Aid Department to ensure adequate resources are available to process Title IV fund returns timely. Additionally, the Colleges should develop policies and procedures to ensure timely processing of returns within the required 45-day period. Corrective Action Plan: Additional staffing has been put in place to ensure that we have enough resources to complete title IV refund processing in a timely fashion. A new assistant director (hired in November 2024) will be monitoring the notifications that students have withdrawn and notify the director when title IV refunds are required. The new assistant director is also currently being trained in title IV refund processing and has experience with title IV refunding prior to being hired. The associate director (hired in July 2024) is also an expert in the return of federal funding through EDCONNECT and perform a supportive role in this process. Lisa Hoskey, Director of Financial Aid, is responsible for implementing this plan and can be reached at Hoskey@hws.edu.

View Audit 348956

Finding 537872 (2024-004)

Significant Deficiency 2024

Grand Valley State University

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting

Finding Number: 2024-004 Condition: The University did not retain supporting documentation including key data elements to support timely submission of the required reports to the federal agency. Planned Corrective Action: The federal agency has a new reporting system for FFATA through SAM.gov that a...

Finding Number: 2024-004 Condition: The University did not retain supporting documentation including key data elements to support timely submission of the required reports to the federal agency. Planned Corrective Action: The federal agency has a new reporting system for FFATA through SAM.gov that allows for more accurate reporting and less technical system failures. GVSU Office of Sponsored Programs will file FFATA reports within the required 30-day timeline and will share receipt of filings with GVSU Finance and the MI-SBDC to acknowledge timely submissions. In the event of any system failures or delays in filing, GVSU OSP will capture a screenshot of the error and work with the agency tech support team as well as notify both Finance and MI-SBDC so the agency can be informed. Contact person responsible for corrective action: Kim Squiers, Director, Office of Sponsored Programs Anticipated Completion Date: New procedure was implemented with the recent filings completed on 1/24/2025.

View Audit 348946

Finding 537645 (2024-001)

Significant Deficiency 2024

Washington County Commission on Aging, Inc.

MD

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

This issue was identified during the FY 2023 audit which occurred in February 2024. Corrective action was taken immediately with the following controls implemented in the fourth quarter of fiscal year 2024: • The CFO evaluated the procedures involved in recording employee time on timesheets and tran...

This issue was identified during the FY 2023 audit which occurred in February 2024. Corrective action was taken immediately with the following controls implemented in the fourth quarter of fiscal year 2024: • The CFO evaluated the procedures involved in recording employee time on timesheets and transferring this data to the financial management system. • The CFO evaluated the need for additional controls to ensure accurate recording of time charged to programs as reflected on the employee's timesheet. • The CFO implemented new processes that establish checks and balances to verify that the programs charged in the general ledger align with the time recorded by the employees and is verified by their supervisor. • The CFO and HR director provided training to all staff and new hires on the importance of accurately capturing and recording payroll costs. • The CEO provided training to the CFO and staff accountant on the significance of aligning time charged with the programs designated in the general ledger for proper grant award billing. • The CFO conducts periodic reviews of payroll transactions to identify any discrepancies or irregularities promptly and take action immediately upon identification of such. These reviews will continue through FY 2025. The controls implemented above should reduce the risk of such errors occurring in the future.

View Audit 348933

Finding 537632 (2024-001)

Significant Deficiency 2024

Trinity Behavioral Care

SC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Management has and will continue to work diligently with our auditor to make every reasonable effort to resolve this issue. Due to the cost-benefits of eliminating this condition, segregation of duties may continue to be a reportable condition. Currently management performs reviews of all aspects ...

Management has and will continue to work diligently with our auditor to make every reasonable effort to resolve this issue. Due to the cost-benefits of eliminating this condition, segregation of duties may continue to be a reportable condition. Currently management performs reviews of all aspects of the finance department including every payroll, monthly review of all expenditures; and monthly review of all accounts received.

View Audit 348911

Finding 537627 (2024-002)

Material Weakness 2024

Norwalk City School District

OH

Subrecipient Monitoring § 200.332

2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR 200.332 which states, in part, pass-through entities must ensure every subaward includes requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own respo...

2 CFR 1000.10 gives regulatory effect to the U.S. Department of Treasury for 2 CFR 200.332 which states, in part, pass-through entities must ensure every subaward includes requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. The grant’s pass-through entity is the Ohio Office of Budget and Management (OBM). State Fiscal Recovery Funds K-12 School Safety Grants Frequently Asked Questions require recipient schools to complete quarterly financial status reports via the OBM grants portal until they have spent all funds and completed their projects. The District did not have proper internal controls in place to ensure the accurate completion and submission of the quarterly financial status reports. During testing of quarterly financial status reports for the Coronavirus State and Local Fiscal Recovery Funds (AL #21.027), we noted the quarterly financial status report for the period of July 1, 2023 through September 30, 2023 omitted $360,084 in grant expenditures paid during this period. Failure to have the proper controls in place to ensure the accurate submission of the quarterly financial status reports could result in Treasury taking action against the District for failure to comply with programmatic requirements. The District should implement and have controls in place to ensure the quarterly expenditure reports are accurate.

View Audit 348899

Finding 537612 (2024-001)

Material Weakness 2024

The Center: Resources for Teaching and Learning

IL

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties § 200.14

The Organization will review its procurement procedures to ensure they include performing and documenting the appropriate searches. The Organization accepts the recommendations.

View Audit 348881

Finding 537604 (2024-003)

Material Weakness 2024

Masshire North Central Workforce Board, Inc.

MA

Subrecipient Monitoring § 200.332

2024-003 Subrecipient Monitoring Responsible Official Mary Chase, Director of Finance Plan Detail Management plans to complete the fiscal year 2024 monitoring of its subrecipient and review its policies and procedures to ensure future monitoring of subrecipients is completed as least on an annual ...

2024-003 Subrecipient Monitoring Responsible Official Mary Chase, Director of Finance Plan Detail Management plans to complete the fiscal year 2024 monitoring of its subrecipient and review its policies and procedures to ensure future monitoring of subrecipients is completed as least on an annual basis. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in fiscal year 2025.

View Audit 348877

Finding 537601 (2024-002)

Significant Deficiency 2024

Masshire North Central Workforce Board, Inc.

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.414

2024-002 Indirect Costs Responsible Official Mary Chase, Director of Finance Plan Details We will adjust our grant award billings to the grantor to reflect the corrected indirect cost charges to each award and return any excess grant funds received. Additionally, management will update its proced...

2024-002 Indirect Costs Responsible Official Mary Chase, Director of Finance Plan Details We will adjust our grant award billings to the grantor to reflect the corrected indirect cost charges to each award and return any excess grant funds received. Additionally, management will update its procedures for calculating modified total direct costs and related indirect cost charges to federal grant awards. Anticipated Completion Date The corrective action is in the process of being implemented and expected to be completed in 2025.

View Audit 348877 Questioned Costs: $1

Finding 537590 (2024-005)

Material Weakness 2024

Metropolitan School District of Shakamak

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2022-005 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Brian Rehmel, Maintenance Supervisor Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding, Description of Corrective Action Plan: The Superintendent and Ma...

FINDING 2022-005 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Brian Rehmel, Maintenance Supervisor Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding, Description of Corrective Action Plan: The Superintendent and Maintenance Supervisor will begin ensuring all vendor contracts with labor installation in excess of $2,000 which are funded by federal grants including Davis Bacon Wage Rate Requirement clauses and implement a formal review process to ensure the required weekly payroll reports certifications are collected and reviewed to ensure compliance with federal regulations Anticipated Completion Date: Immediate review will begin of all vendor contracts funded by federal grants.

View Audit 348863

Finding 537587 (2024-004)

Material Weakness 2024

Metropolitan School District of Shakamak

IN

Internal Control / Segregation of Duties Material Weakness Reporting § 200.302 § 200.303 § 200.328

FINDING 2022-004 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer; Jeri Morin, Data Coordinator Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action P...

FINDING 2022-004 Contact Person Responsible for Corrective Action: Jeff Gambill, Superintendent; Jennifer Barcus, Corporation Treasurer; Jeri Morin, Data Coordinator Contact Phone Number: 812-665-3550 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Superintendent will prepare all annual data reports and have a documented formal review from the Corporation Treasurer and the Data Coordinator, prior to submission, to validate the accuracy and completeness of the data submitted. Anticipated Completion Date: Immediate review will begin of all annual data reports.

View Audit 348863

Finding 537575 (2024-001)

Material Weakness 2024

Stetson University, Inc.

FL

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding: 2024-001 Suspension and Debarment Condition: The University was not able to provide an audit trail to support the verification that a vendor was not suspended and debarred before entering into a contract. Anticipated Completion Date: Implemented in October 2024. Person Responsible: Carol Bu...

Finding: 2024-001 Suspension and Debarment Condition: The University was not able to provide an audit trail to support the verification that a vendor was not suspended and debarred before entering into a contract. Anticipated Completion Date: Implemented in October 2024. Person Responsible: Carol Buckels, Director of Grants, Sponsored Research & Strategic Initiatives Corrective Actions Taken or Planned: The Sponsored Research Administration Office (SRA) ensures all purchases, reimbursements, and any other expenditure submitted for payment are first approved by the Principal Investigator (PI). SRA will review the approved budget to ensure funding is available. If the payment request is for purchases that require payment to specific vendors, the SRA verifies that the entity being used for these purchases is not suspended or debarred, or otherwise excluded from participating in the transaction. This verification is accomplished by checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA). SRA submits the verification along with the purchasing request or check request to accounts payable or purchasing for processing. If the expenditure amount is above the SRA approval level, the request is then escalated for additional approval (Director of Academic Administration, Provost, etc.) before sending to accounts payable or purchasing for processing.

View Audit 348854

Finding 537566 (2024-002)

Significant Deficiency 2024

Seniorsplus

ME

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties § 200.303

Management is committed to compliance in accordance with all grant agreements and will work to formally document the Agency’s internal controls over Federal and State awards. Additional training will be provided as needed to prevent future findings.

View Audit 348846

Finding 537552 (2024-002)

Significant Deficiency 2024

Winona-Montgomery Consolidated School District

MS

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Subrecipient Monitoring

2024-002 a. Name of Contact Person Responsible for Corrective Action: Lynea Watson – Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, including compliance with all ...

2024-002 a. Name of Contact Person Responsible for Corrective Action: Lynea Watson – Business Manager b. Corrective Action Planned: We will implement policies or procedures to establish an internal control system that will ensure strong financial accountability, including compliance with all federal grant requirements. c. Anticipated Completion Date: Immediately.

View Audit 348831

Finding 537546 (2024-001)

Significant Deficiency 2024

Integral Care

TX

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.1 § 200.414

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was n...

Corrective Action Plan Finding 2024-001 Finding Summary: The Center did not exclude charges for patient care when calculating modified total direct costs (MTDC) in accordance with Uniform Guidance and TxGMS and thus the indirect rate used in calculating the indirect amount charged to the grant was not consistently accurate. Corrective Action Plan: The Center has historically calculated the indirect amount using the same methodology over time. Given the small volume of patient receipts, the impact on the total indirect amount is minor. We believe that had we modified our calculations, we would have had enough modified total direct costs to cover the change in the calculation. The Center will modify all future calculations to ensure alignment. We will also review the fiscal year covered under this audit to understand what the impact of the change would have been on the split between cost types. Note that since we are midway through our next fiscal year, and we consider the differences minor, we have determined that we will correct for any future reimbursement requests, but will not modify prior reimbursement requests. Similarly, we will conduct a review of that fiscal year to determine the impact of the change and verify it is not significant. Responsible Individuals: Rusty Taylor, CFO Joe Carrington, Director of Financial Planning and Analysis Anticipated Completion Date: August 2025

View Audit 348829 Questioned Costs: $1

Finding 537542 (2024-002)

Material Weakness 2024

Warrick County School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

Finding 2024‐002 Finding Subject: Special Education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Todd A. Armstrong, Assistant Superintendent Contact Phone Number and Email Address: (812) 897‐6036 tarmstrong@warrick.k12.in.us Views of the...

Finding 2024‐002 Finding Subject: Special Education Cluster (IDEA) ‐ Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Todd A. Armstrong, Assistant Superintendent Contact Phone Number and Email Address: (812) 897‐6036 tarmstrong@warrick.k12.in.us Views of the Responsible Official: We concur with the finding. Additional Explanation: Although the vendors selected provided specific services outlined in the federal grant, proper documentation of how those vendors were selected was not maintained. Moreover, the department believed by following the spending allotted in the grant, they were meeting necessary purchasing guidelines. Internal controls did not identify this misstep and allowed the services to be purchased. To avoid this in the future, guidelines will be prepared for all departments submitting purchase requests, and an additional control will be put in place to verify that procedures are followed. Description of Corrective Action Plan: 1) Create and write an administrative guideline that outlines expected purchasing procedures. 2) Distribute and make available the administrative guideline to employees. 3) Create an additional internal control in the business office to verify that those procedures were met with each requisition or request for purchase. 4) Provide necessary corrections to any request that does not follow guidelines. Mr. Armstrong will oversee, direct, and coordinate this process. He will work with the Corporation administrative team to develop and write the guidelines. The Business department will distribute the guidelines to all interested parties and have guidelines available upon request. Mr. Armstrong will outline expectations and determine when they have been met satisfactorily. Anticipated Completion Date: The remedy for this finding will be in place prior to June 30, 2025.

View Audit 348824

Finding 537541 (2024-003)

None 2024

Jefferson County Industrial Development Agency

NY

Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: We accept the validity of this finding for the same reasons stated above in finding 2024-002. We actively monitored the subrecipient’s management of the subaward through documentation and regular personal contact. However, because we did...

Views of Responsible Officials and Planned Corrective Actions: We accept the validity of this finding for the same reasons stated above in finding 2024-002. We actively monitored the subrecipient’s management of the subaward through documentation and regular personal contact. However, because we did not recognize the organization as a subrecipient, we did not adhere to the proper subrecipient monitoring requirements outlined in the Uniform Guidance. Corrective Action: As noted above in the corrective action to finding 2024-002, we have notified the organization of their subrecipient status; the requirement to conduct a Single Audit of its administration of their subaward; and the need to provide the JCIDA with a copy of the organization’s most recent audited financial statements and federal Single Audit reports once completed, if they expended over $750,000 of federal awards. We will include these requirements in future subrecipient contracts.

View Audit 348822

Finding 537540 (2024-002)

Significant Deficiency 2024

Jefferson County Industrial Development Agency

NY

Subrecipient Monitoring Significant Deficiency

Views of Responsible Officials and Planned Corrective Actions: We acknowledge the validity of this finding and offer the following explanation. While we recognized the Agency’s role as a subrecipient, we did not fully understand the guidelines for distinguishing between a “contractor” and a “subreci...

Views of Responsible Officials and Planned Corrective Actions: We acknowledge the validity of this finding and offer the following explanation. While we recognized the Agency’s role as a subrecipient, we did not fully understand the guidelines for distinguishing between a “contractor” and a “subrecipient” when making a subaward to another organization. However, through a thorough discussion and assessment of the guidelines with the auditors, along with a joint review of the GSA-CX-1.8: Subrecipient and Contractor Determination Form, we have gained clarity on the proper process for making accurate determinations in future subawards. Corrective Action: For future grant awards, Agency staff will review the use of funds in accordance with federal guidelines to determine whether the recipient qualifies as a subrecipient or a contractor. Additionally, the Agency has taken steps to notify the organization of their subrecipient status and their obligation to conduct a Single Audit in compliance with Government Accounting Standards and Uniform Guidance requirements.

View Audit 348822

Finding 537537 (2024-001)

Significant Deficiency 2024

Town of Boylston

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2025 ...

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: A financial policy for managing receipt of federal awards is in the process of being created by the Financial Policies Committee Anticipated Completion Date: December 31, 2025 Contact: April Steward, Town Administrator

View Audit 348815

Finding 537519 (2024-001)

None 2024

William Marsh Rice University

TX

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

William Marsh Rice University Response The following is William Marsh Rice University’s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ended June 30, 2024. Finding 2024-001 – Loan Disbursement Notification Cluster: Student Financial Assistance Cluster ...

William Marsh Rice University Response The following is William Marsh Rice University’s Response to the audit of Federal programs in accordance with the Uniform Guidance for the year ended June 30, 2024. Finding 2024-001 – Loan Disbursement Notification Cluster: Student Financial Assistance Cluster Awarding Agency: Department of Education Award Name: Federal Direct Student Loans Award Year: July 1, 2023 – June 30, 2024 Assistance Listing Number: 84.268 Pass-through Entity: Not applicable We acknowledge the audit finding regarding the missing documentation of the loan disbursement notification for the 2023-2024 academic year. The issue began when an automated rule was disabled by a system update. This prevented the loan disbursement notices from being sent to students. Upon recognizing the underlying reason, the loan disbursement notice, which is sent one day after a loan disbursement posts to a student’s account, had its system rules reengaged. This was achieved through a collaborative effort involving the Office of Financial Aid, the Bursar's Office, and Administrative Systems. Notices resumed on September 26, 2024, and we have since conducted spot checks to confirm that the notices are being sent as required. To prevent a recurrence of this issue, we have implemented the following measures: 1. Annual Review: We have updated our staff calendar with an annual reminder to review and request updates to the text and rules of the loan disbursement notice. 2. Documentation: We have ensured that the scheduled disbursement dates and the right to cancel are disclosed in multiple areas, including the all-freshmen notice, other loan/aid award notices, the loan section of our website, and the financial aid section of General Announcements for both undergraduate and graduate students. Prior to and including the 2023-2024 academic year, this information has been updated and made available on an annual basis in these areas. This practice will continue. Effective Date: September 26, 2024 Person(s) responsible for implementation: Paul Negrete, Executive Director for University Financial Aid Services, 713-348-5905 We believe these actions address the audit finding and will help maintain compliance with notification requirements moving forward. Sincerely, Paul Negrete Executive Director University Financial Aid Services

View Audit 348737

Finding 537488 (2024-003)

Significant Deficiency 2024

City and Borough of Juneau, Alaska

AK

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.306

FEDERAL AWARD FINDING Finding: 2024-003 Significant Deficiency in Internal Controls over Compliance and Compliance – Setup and Monitoring of Reporting and Match Name of Contact Person: Angie Flick, Director of Finance Corrective Action: The accountants will be going through additional training on se...

FEDERAL AWARD FINDING Finding: 2024-003 Significant Deficiency in Internal Controls over Compliance and Compliance – Setup and Monitoring of Reporting and Match Name of Contact Person: Angie Flick, Director of Finance Corrective Action: The accountants will be going through additional training on setting up grants in the system and how to reconcile them. CBJ will also be completing a grant reconciliation process quarterly instead of annually. This will act both as a control as well as an opportunity to make timely corrections in the case of error. Proposed Completion Date: September 30, 2025

View Audit 348728

Finding 537486 (2024-003)

Significant Deficiency 2024

Town of Manchester

MD

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility § 200.214 § 200.303

DEPARTMENT OF TREASURY 2024-003 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls ...

DEPARTMENT OF TREASURY 2024-003 Coronavirus State and Local Fiscal Recovery Funds -Assistance Listing No. 21.027 Recommendation: We recommend management ensure policies and procedures include the three options for determining suspension and debarment status listed in 2 CFR 180.300 and that controls are sufficient to ensure that the suspension and debarment status is verified for all vendors prior to issuance of the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town will ensure all new vendors will sign a suspension and debarment agreement prior to any payments being made. Name of the contact person responsible for corrective action: Kelly Baldwin, Director of Finance Planned completion date for corrective action plan: March 31, 2025 If the Cognizant or Oversight Agency has questions regarding this plan, please call Kelly Baldwin, Director of Finance at 410-239-3200.

View Audit 348723

Finding 537482 (2024-001)

Significant Deficiency 2024

National Association of Criminal Defence Lawyers, Inc.

DC

Subrecipient Monitoring § 200.332

Views of Responsible Officials: Management acknowledges the comment and, following the fiscal year-end, has implemented internal procedures to evaluate subrecipients. These procedures assess risk levels, determine the scope and frequency of monitoring, and ensure compliance with applicable Federal s...

Views of Responsible Officials: Management acknowledges the comment and, following the fiscal year-end, has implemented internal procedures to evaluate subrecipients. These procedures assess risk levels, determine the scope and frequency of monitoring, and ensure compliance with applicable Federal statutes and regulations.

View Audit 348713

Finding 537455 (2024-001)

Significant Deficiency 2024

Brac Usa, Inc.

NY

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332 § 200.501

Views of Responsible Officials and Planned Corrective Actions: We are committed to strengthening our internal controls and procedures to ensure full compliance with Uniform Guidance requirements. We also acknowledge that the audit waiver BRAC Bangladesh received from the USAID Mission in Bangladesh ...

Views of Responsible Officials and Planned Corrective Actions: We are committed to strengthening our internal controls and procedures to ensure full compliance with Uniform Guidance requirements. We also acknowledge that the audit waiver BRAC Bangladesh received from the USAID Mission in Bangladesh was not sufficient to exempt them from conducting a program-specific audit of the Department of State (BPRM) funded project, SPRMCO23CA0152. In response to the finding, BRAC Bangladesh has already conducted an audit of the project, which demonstrated that the financial statements and schedule of expenditures were free from material misstatements. Moving forward, we will amend our subagreement templates to include specific language around USG audit requirements, and the submission of audit reports will be included in the reporting section of the agreements. We will also update our Fiscal Policies and Procedures Manual to formalize the process for receiving and reviewing audit reports, and establishing follow-up procedures to resolve potential audit findings. We will also maintain clear documentation of the submission, review, and follow up of audits.

View Audit 348663

Finding 537453 (2024-003)

Significant Deficiency 2024

Saint Peter's University and Affiliates

NJ

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

STEM - PODER – Federal Assistance Listing Number 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreemen...

STEM - PODER – Federal Assistance Listing Number 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is in the process of developing and implementing a formal policy and procedure to verify that a vendor is not debarred or suspended in the System for Award Management (SAM) database. The procedure, which will be in place by the end of FY 2025, will outline roles, responsibilities, and documentation requirements to ensure consistent compliance. Name(s) of the contact person(s) responsible for corrective action: Diane DiStaulo, Director of Accounting Operations, (201) 761-7415 Planned completion date for corrective action plan: by the end of FY2025

View Audit 348651

Finding 537436 (2024-002)

Material Weakness 2024

Southwest Organizing Project

IL

Subrecipient Monitoring § 200.332

Finding No. 2024-002 21.027: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Name: Edith Robles Department: Finance Title: Director of Finance Anticipated Completion Date: June 30, 2025 Corrective Action Plan: An adequate subrecipient risk a...

Finding No. 2024-002 21.027: COVID - 19: Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Name: Edith Robles Department: Finance Title: Director of Finance Anticipated Completion Date: June 30, 2025 Corrective Action Plan: An adequate subrecipient risk assessment policy will be put in place to evaluate and monitor subrecipients. Southwest Organizing Project will provide subrecipients with all required Federal awards identifiers. Edith Robles will ensure that Federal award identifiers are included in subrecipients grant agreements.

View Audit 348633

Corrective Action Plans

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