Corrective Action Plans

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Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: The Town plans to draft and adopt policies. Anticipated Completion Date: 12/31/2025 Contact: Andrew Alward, Town Administrator
Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: The Town plans to draft and adopt policies. Anticipated Completion Date: 12/31/2025 Contact: Andrew Alward, Town Administrator
Management’s Response and Corrective Action Plan: MLSC management acknowledges the finding and concurs with the auditor’s recommendation. Management would like to note that MSLC has an existing Petty Cash Policy, which was recently updated and approved by the Board of Directors to ensure full compli...
Management’s Response and Corrective Action Plan: MLSC management acknowledges the finding and concurs with the auditor’s recommendation. Management would like to note that MSLC has an existing Petty Cash Policy, which was recently updated and approved by the Board of Directors to ensure full compliance with LSC Financial Guide §3.2.5 that address the following: • Segregation of duties • Required monthly reconciliation of all petty cash funds • Allowable use of petty cash • Documentation necessary to support each petty cash disbursement • Procedures to follow in the event of overage or shortage in the fund Responsible person: Chief Fiscal Officer, Jocelyn Mallari Corrective action planned: The updated Petty Cash Policy is immediately implemented to strengthen internal control, ensure accountability, and prevent future loss or mismanagement. A monthly petty cash reconciliations for each office is scheduled. These corrective actions will ensure compliance with LSC requirements Anticipated completion date: Completed
Management’s Response and Corrective Action Plan: See the response on finding 2024-009
Management’s Response and Corrective Action Plan: See the response on finding 2024-009
Management’s Response and Corrective Action Plan: Management agrees, and has addressed this as follows: Responsible person: Lee Pliscou MLSC Board of Directors approved a revised accounting manual in October 2025 which requires an annual cybersecurity assessment and response in compliance with LSC F...
Management’s Response and Corrective Action Plan: Management agrees, and has addressed this as follows: Responsible person: Lee Pliscou MLSC Board of Directors approved a revised accounting manual in October 2025 which requires an annual cybersecurity assessment and response in compliance with LSC Financial Guide § 2.5.3, together with a formal risk assessment of banking operations to identify and address vulnerabilities, as required by LSC Financial Guide § 3.2.1. Specifically, our cybersecurity policies include the following requirements: ● Perform (and document) an annual risk assessment ● Resolve any risk findings or conclusions ● Maintain physical access controls for servers and storage rooms ● Develop and periodically test an emergency disaster prevention and recovery plan ● Perform regular back up of electronic records and systems stored offsite or in a virtual environment with easy-to-use restoration options ● Formally assign computer and data security responsibilities The risk assessment process: ● Identifies the physical and digital assets susceptible to cyberattacks ● Identifies risks to those assets (risks should be evaluated annually for changes) ● Evaluates the risks (e.g., high, medium, or low) based on likelihood and impact ● Documents the results of the risk assessment, including the development and implementation of appropriate controls Finding 2024-008 LSC Financial Guide § 2.5.3 Electronic Data Processing and Cybersecurity, continued Also, per our new Accounting Manual, MLSC conducts a risk assessment of its electronic banking policies and procedures to identify areas that need additional safeguards and protections. We do this in conjunction with the annual cybersecurity risk assessment. As of November 2025, MLSC has contracted with a consultant to provide such an assessment, and the contractor has delivered a first draft of an assessment. Anticipated completion date: MLSC has already completed the requirement to have policies in compliance with LSC Financial Guide Sections 2.5.3 (Electronic Data Processing and Cybersecurity) and 3.2.1 (Bank accounts). MLSC will complete the annual assessment by February 28, 2026.
Management’s Response and Corrective Action Plan: Management agrees. Responsible person: Executive Director Lee Pliscou Corrective action planned: This has been corrected as of October 2025. MLSC Board of Directors approved a revised MLSC Accounting Manual with updates intended to comply with LSC’s ...
Management’s Response and Corrective Action Plan: Management agrees. Responsible person: Executive Director Lee Pliscou Corrective action planned: This has been corrected as of October 2025. MLSC Board of Directors approved a revised MLSC Accounting Manual with updates intended to comply with LSC’s Financial Guide on cost allocation. In particular, our new cost allocation policy addresses: ● Direct and indirect cost definitions ● Direct cost allocation methodology ● Indirect cost allocation methodology including allocation bases (total direct costs) ● Frequency of allocation (annual) ● Who conducts the allocation and who performs the review (Chief Fiscal Officer, Executive Director) ● Documentation requirements to support the allocation (calculation work papers) ● Reconciliation process related to salaries and wages directly charged to LSC grants and contracts ● Methodology to address “exception for certain indirect costs.” Anticipated completion date: Completed.
Finding Number: 2024-004 Failure to Identify Single Audit Requirement Views of Responsible Officials and Corrective Action: The Organization was not explicitly made aware of the Uniform Guidance requirements and mistakenly assumed that since this originated from the state, it was state funding. The ...
Finding Number: 2024-004 Failure to Identify Single Audit Requirement Views of Responsible Officials and Corrective Action: The Organization was not explicitly made aware of the Uniform Guidance requirements and mistakenly assumed that since this originated from the state, it was state funding. The Organization is aware of this situation and will create and implement a formal process to review federal and state expenditures incurred and evaluate whether there are state or federal compliance audit implications for all government grants upon signing the agreement. We will then proactively communicate this with our auditor so that plans can be made to perform the applicable compliance audit. We do not view this as an ongoing deficiency, and we deem our corrective action plan to be one that fully addresses this control deficiency. Name of Responsible Person: Mike Cohoon, Executive Director Projected Implementation Date: December, 2025
Views of Responsible Officials: We agree with the auditor’s findings and recommendations. We are going to review, strengthen, and more closely supervise all of our accounting procedures including response time to the Development Team’s requests for reports. We are also engaging in discussions about ...
Views of Responsible Officials: We agree with the auditor’s findings and recommendations. We are going to review, strengthen, and more closely supervise all of our accounting procedures including response time to the Development Team’s requests for reports. We are also engaging in discussions about how and when the Development Team requests information for the needed reports. A Grant Manager has been hired and we hope that Grantseeker, our grant tracking program, can be utilized more effectively which include tracking reporting timelines.
Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requir...
Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requirements at the time of subaward, including the Federal award identification, all compliance requirements, and any additional terms and conditions imposed by the pass-through entity. The Town did not execute a formal subrecipient agreement with Fishers Island Ferry District, to whom federal funds were passed through during the audit period. Specifically, no written agreement was in place outlining the subrecipient’s responsibilities, applicable compliance requirements, or the terms and conditions of the award. Recommendation: We recommend that the Town develop and implement procedures to ensure that formal written subrecipient agreements are executed prior to the disbursement of federal funds. These agreements should contain all elements required by 2 CFR § 200.332(a), including the identification of the federal award, applicable compliance requirements, and any additional terms and conditions. Corrective Action Plan: In coordination with the Supervisor’s office, Town Attorney’s office, and Comptroller’s office, formal subrecipient agreements will be prepared and executed, with adoption of Town Board resolutions, between the Town of Southold and pass-through entities concurrently as Federal grant contracts are awarded, as applicable. Responsible Individual: Albert J. Krupski Jr., Town Supervisor Paul DeChance, Town Attorney Michelle Nickonovitz, Town Comptroller Planned Date of Implementation: Corrective action plan procedures have already been communicated and implemented to ensure that formal written subrecipient agreements with pass-through entities are executed prior to the disbursement of federal funds.
Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...
Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator
Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...
Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator
1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accura...
1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accuracy prior to submission. 3. Assigned dedicated staff oversight for federal financial reporting, with cross-training implemented to strengthen continuity and mitigate risk in the event of staff turnover. 4. Conducted periodic evaluations of the reporting process, incorporating feedback and lessons learned from prior submissions, monitoring visits, and audit findings to drive ongoing improvements. 5. Reviewed and updated internal financial policies and procedures to align with current federal reporting requirements and best practices, with updates formally documented and disseminated to staff.
We are taking steps to address the ongoing issue by coordinating with department heads and the Treasurer to ensure all grant paperwork is properly received and documented.
We are taking steps to address the ongoing issue by coordinating with department heads and the Treasurer to ensure all grant paperwork is properly received and documented.
FINDING 2024-001: Audit Report Deadline (Repeated 2023-001) Response: Following turnover in the City Manager (June 2024) and Finance Director (November 2024) positions, city staff have been actively working to ensure compliance regarding the delayed audit submission. The Finance Director, who joined...
FINDING 2024-001: Audit Report Deadline (Repeated 2023-001) Response: Following turnover in the City Manager (June 2024) and Finance Director (November 2024) positions, city staff have been actively working to ensure compliance regarding the delayed audit submission. The Finance Director, who joined the city in November 2024, postponed issuing RFPs to audit firms until the new City Manager assumed the role in April 2025. By July 2025, the City Manager and Finance Director engaged Nexus to complete the 2024 audit in the fall of 2025. To ensure compliance, the city will work with Nexus to have the 2025 Audit completed by March of 2026.
The SEFA information needed for this finding was from the 2025 budget. The 2025 budget can be amended up to 12/31/2025. Even though the ARPA funds in question were not reported on the SEFA page of the 2025 budget, it was reported within the budget within its own fund, which would show actual expendi...
The SEFA information needed for this finding was from the 2025 budget. The 2025 budget can be amended up to 12/31/2025. Even though the ARPA funds in question were not reported on the SEFA page of the 2025 budget, it was reported within the budget within its own fund, which would show actual expenditures of the year ended December 31, 2024. Going forward the County Clerk will have the Treasurer review the SEFA report for accuracy.
Inadequate Grant Recordkeeping The County will work to improve grant documentation and will consider having someone review grant reports prior to their submission. In the absence of necessary knowledge and expertise, the County will continue to rely on the auditors to assist with prepration of the S...
Inadequate Grant Recordkeeping The County will work to improve grant documentation and will consider having someone review grant reports prior to their submission. In the absence of necessary knowledge and expertise, the County will continue to rely on the auditors to assist with prepration of the Schedule of Expenditures of Federal Awards and reconciling the financial records to the Consolidated Year-End Financial Report.
Insufficient Grant Monitoring The County will work to improve grant documentation and will consider implementing a review process to ensure the grant records agree to the grant reports that are filed.
Insufficient Grant Monitoring The County will work to improve grant documentation and will consider implementing a review process to ensure the grant records agree to the grant reports that are filed.
Insufficient Subrecipient Monitoring The Health Department will establish procedures for subrecient monitoring.
Insufficient Subrecipient Monitoring The Health Department will establish procedures for subrecient monitoring.
Scotland County’s response for issues found: 1. We will double check to make sure we didn’t miss something for the SEFA report. 2. We will update the 2024 SEFA for the corrected amounts. 3. The Highway Planning and Construction (MODOT Intermodal) included the railroad bridge that no one could tell u...
Scotland County’s response for issues found: 1. We will double check to make sure we didn’t miss something for the SEFA report. 2. We will update the 2024 SEFA for the corrected amounts. 3. The Highway Planning and Construction (MODOT Intermodal) included the railroad bridge that no one could tell us where the money was coming from. This accounted for $1,228,104.64. We will correct this on the SEFA. 4. The ARPA was the interest received in 2024. We didn’t receive any more money from the state in 2024. We will get this added to the SEFA. 5. The HAVA Election Security Grant was missed when we were putting them in the report. We will get this added to the SEFA.
FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Special Tests and Provisions Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assis...
FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Special Tests and Provisions Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425U210012 (Year: 2021) Questioned Costs: None Description: Construction-related weekly payroll timesheets were not produced to satisfy the Wage Rate Requirements according to the Davis-Bacon Act. Corrective Action Plans: The School District will review and update the current procedures to ensure that the Wage Rate requirements are met. Estimated Completion Date: June 30, 2025 Contact Person: Daisy M. Prather, Finance Director Telephone: (478) 836-3131, extension 5007 Email: daisy.prather@crawfordschools.org
Condition and Context: The County does not have a complete set of written cash management policies and procedures required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Managemen...
Condition and Context: The County does not have a complete set of written cash management policies and procedures required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.
Condition and Context: During our audit of the Public Safety Partnership and Community Policing Grant (CFDA 16.710), we were unable to obtain a copy of the required SF-425 (Federal Financial Report) submitted by the County. Recommendation: We recommend that the County implement procedures to ensure ...
Condition and Context: During our audit of the Public Safety Partnership and Community Policing Grant (CFDA 16.710), we were unable to obtain a copy of the required SF-425 (Federal Financial Report) submitted by the County. Recommendation: We recommend that the County implement procedures to ensure that copies of all required federal reports are retained in accordance with federal record retention requirements and made available for audit purposes. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish procedures to ensure that all required federal reports are retained and readily available for future monitoring and audits.
Finding 2024-002 – Subrecipient Monitoring (Significant Deficiency) Recommendation: We recommend that procedures be implemented to ensure all subrecipients are notified of subaward requirements as outlined in 2 CFR 200.332(b) and the County implement a process to ensure all subrecipients audits are ...
Finding 2024-002 – Subrecipient Monitoring (Significant Deficiency) Recommendation: We recommend that procedures be implemented to ensure all subrecipients are notified of subaward requirements as outlined in 2 CFR 200.332(b) and the County implement a process to ensure all subrecipients audits are reviewed and deficiencies be followed up on. We also recommend that the County perform annual risk assessments for all subrecipients. The Area Agency on Aging failed to conduct the required annual risk assessment prior to disbursing funds. Corrective Action: • All divisions within the Department of Human Services (excluding Gracedale) will conduct an annual risk assessment for each provider during the contracting process. • DHS Policy 300.8 will be revised to include a standardized, department-wide risk assessment form for use across all divisions. The County did not ensure that all Foster Care Title IV-E and aging subrecipients were notified via contract or letter of their subaward Assistance Listing Number (ALN) and the amount paid during the year. Corrective Action: When issuing contracts, the County will include a notification letter to each provider indicating whether they have the potential to be a subrecipient of federal funds. If applicable, the letter will also include the relevant Assistance Listing Number (ALN). After the close of each fiscal year, the County will issue a summary letter to all subrecipients detailing the total amount of federal, state, and county funds paid to them. The portion of federal funding will be clearly identified and accompanied by the corresponding ALN. Cindy Smith, Financial and Information Systems Director for the Department of Human Services and her staff will be responsible for the corrective actions for finding 2024-002. The Department of Human Services began issuing notification letters in fall 2025 to vendors identified as potential subrecipients of federal funding. These notifications apply to fiscal year 2025–2026. In addition, summary letters informing vendors of federal award amounts are currently being distributed for fiscal year 2024–2025.
Condition: Suspension and debarment compliance was not verified for four covered transactions. Corrective Action Planned: The Town will implement procedures to include a suspension and debarment certification in all federal contracts that are considered covered transactions to ensure that the contra...
Condition: Suspension and debarment compliance was not verified for four covered transactions. Corrective Action Planned: The Town will implement procedures to include a suspension and debarment certification in all federal contracts that are considered covered transactions to ensure that the contractors are eligible to receive federal funds and not excluded or disqualified from doing business. Anticipated Completion Date: March 31, 2026 Contact: Bryan Sawyer, Town Administrator
Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: The Town will formally document procedures in writing to support compliance with applicable federal awards requirements. Anticipated Completion Date: March 31, 2026 Contact: Bryan Sawy...
Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: The Town will formally document procedures in writing to support compliance with applicable federal awards requirements. Anticipated Completion Date: March 31, 2026 Contact: Bryan Sawyer, Town Administrator
Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: Virginia Department of Health; Not Applicable Pass-Through Entity Number: INORWB611-GY23; INORWB611-GY24; Not Applicable Awards: Assistance Listing 93.917 – HIV Emergency Relief Project...
Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: Virginia Department of Health; Not Applicable Pass-Through Entity Number: INORWB611-GY23; INORWB611-GY24; Not Applicable Awards: Assistance Listing 93.917 – HIV Emergency Relief Project Grants; Assistance Listing 93.918 – Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease Award Periods: April 1, 2023 to March 31, 2024; April 1, 2024 to March 31, 2025; May 1, 2023 to April 30, 2024; May 1, 2024 to April 30, 2025 Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Timely Application of Program Income Prior to Requesting Additional Cash Payments Recommendation: During the latter part of the fiscal year and as a result of prior year audit findings, IJP implemented various checkpoints in their monthly processes to ensure that program income was disbursed prior to requesting cash reimbursements. IJP should continue to assess existing policies and procedures to ensure the program income balance is spent timely. HRSA recommends that recipients and subrecipients strive to proactively secure and estimate the extent to which program income will be accrued. View of responsible officials: Management concurs with the finding and has implemented procedures to ensure appropriate and timely application of program income. Corrective Action Planned: Inova Grants Accounting and Inova Juniper Program (IJP) directors will work collaboratively to disburse funds available from program income prior to requesting additional cash payments from RWHAP funds. Inova implemented a Program Income from Sponsored Programs policy in February 2025. Inova will assess this written procedure and revise as necessary to ensure that program income is applied before requesting federal reimbursement. Inova will review federal grant requirements related to program income and identify sources of program income during kickoff meetings for new awards. Mandatory training will be conducted for program and finance staff responsible for the administration of these awards. (2 CFR 200.307 and 200.305) Inova will require a monthly reconciliation of program income earned and expenditures by grant. Program income tracking will also be included in monthly grant variance reports. Planned Completion Date for Corrective Action Planned: Ongoing with completion date of December 31, 2025.
View Audit 372193 Questioned Costs: $1
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