Corrective Action Plans

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Management acknowledges the audit finding regarding timely submission of reports and retaining documentation of submissions. We will implement a new combined monitoring and record retention internal control process for financial, performance, and special reporting requirements, to ensure timely subm...
Management acknowledges the audit finding regarding timely submission of reports and retaining documentation of submissions. We will implement a new combined monitoring and record retention internal control process for financial, performance, and special reporting requirements, to ensure timely submission and retention of supporting documentation for required sponsor reporting. This process will be implemented by December 31, 2025.
Management acknowledges the findings related to compliance with GLBA requirements. The missing elements were primarily due to existing policies and procedures not specifically covering the information technology system utilized by the School of Nursing. Management will update their information techn...
Management acknowledges the findings related to compliance with GLBA requirements. The missing elements were primarily due to existing policies and procedures not specifically covering the information technology system utilized by the School of Nursing. Management will update their information technology policies and procedures to ensure full compliance with the 7 required elements outlined by the GLBA. This will include updating risk assessment procedures, designing safeguards based on risk assessments procedures, monitoring these safeguards, and documenting the results. These policy and procedure updates will be implemented by December 31, 2025.
Management concurs with KPMG’s assessment that the risk assessment and monitoring control activities were not sufficiently designed to ensure adequate segregation of duties or to provide evidence of control operation. These gaps were primarily due to limited staffing and processes that have not evol...
Management concurs with KPMG’s assessment that the risk assessment and monitoring control activities were not sufficiently designed to ensure adequate segregation of duties or to provide evidence of control operation. These gaps were primarily due to limited staffing and processes that have not evolved to meet all compliance requirements. Management will implement new control policies and procedures that ensure proper segregation of duties and introduce review mechanisms at a sufficient level of precision to detect and prevent noncompliance. These policies and procedures will be implemented by December 31, 2025.
Federal Funding Accountability and Transparency Act (FFATA) Filing for Subawards. Assistance Listing No. 93.493 Congressional Directives: Kupuna Support Navigator Program (KSNP) The KSNP project manager and senior management reviewed and submitted the FFATA required reporting, which included the sub...
Federal Funding Accountability and Transparency Act (FFATA) Filing for Subawards. Assistance Listing No. 93.493 Congressional Directives: Kupuna Support Navigator Program (KSNP) The KSNP project manager and senior management reviewed and submitted the FFATA required reporting, which included the subrecipient's name, subaward date, and subaward amount on SAM.gov website prior to the completion of this federal grant, which ended on June 30, 2025. The funder confirmed receipt of our reporting and did not specify any implications for late submission. As recommended by the auditors, HIPHI has developed a process to help identify the subawards subject to the FFATA reporting requirements prior to the start of the grant, and to ensure that reporting is reviewed, approved for completeness and accuracy, and filed in a timely manner. The Director of Finance, Finance and Accounting Manager, Program Managers and contract signers will be responsible for implementing these corrective actions by the end of 2025.
Finding: Subrecipient Single Audits. The Organization’s grant and subgrant agreements explicitly require subgrantees to undergo a single audit if they expend $750,000 or more in a fiscal year, as stipulated by the Department of State. However, audits were not performed for subgrantees exceeding this...
Finding: Subrecipient Single Audits. The Organization’s grant and subgrant agreements explicitly require subgrantees to undergo a single audit if they expend $750,000 or more in a fiscal year, as stipulated by the Department of State. However, audits were not performed for subgrantees exceeding this threshold in Cameroon, South Sudan, and Iraq. This non-compliance was caused by failures in the subrecipient control monitoring process. Corrective Action Plan JRS/USA recognizes the risk presented when Country Offices (COs) or Regional Offices (ROs) are unable to meet audit requirements, particularly when receiving U.S. federal funds. While JRS/USA does not have direct authority to mandate CO/RO audits in all regions, we recognize our responsibility to ensure federal compliance across the global network. To address this, JRS/USA will implement a stricter due diligence and pre-award assessment process. Specifically, going forward, COs/ROs must demonstrate the ability to meet audit and financial reporting requirements as a condition for receiving federal funding. If these requirements are not met, JRS USA will take corrective action, which may include suspending their inclusion in federal awards until compliance can be assured. JRS/USA will also revisit the previously proposed “go/no-go” framework and explore its formal adoption as part of a broader compliance risk management strategy. To address this gap and strengthen subrecipient oversight related to audit compliance, JRS/USA is implementing the following measures: 1. Reinforced Audit Clause Communication JRS/USA has reviewed and re-communicated the audit requirements to all subrecipients (country offices), particularly those with high federal expenditures. Subgrantees are being reminded annually in writing of their obligation to procure a Single Audit or Program-Specific Audit if they meet the $750,000 threshold. 2. Enhanced Subrecipient Monitoring Process The subrecipient monitoring framework has been updated to include: a) Annual tracking of total federal expenditures by each subrecipient (country office) b) Flagging of subrecipients approaching the $750,000 threshold c) A review checkpoint at year-end to determine audit applicability d) Clear documentation requirements and timelines for submitting audit report 3. Audit Compliance Checklist and Tracker A standardized checklist has been created to track audit requirements and receipt of audit documentation from all subrecipients (country offices). This checklist is maintained centrally by the JRS/USA compliance or grants team and reviewed quarterly. 4. Technical Support to Subrecipients Subrecipients (country offices) that may lack familiarity with the Single Audit requirement are being offered guidance and support on: a) Identifying qualified auditors b) Understanding scope and timing of required audits c) Budgeting for audit costs appropriately 5. Subaward Risk Assessments Updated The risk assessment conducted during subaward issuance and annual monitoring now includes specific indicators for federal expenditure levels and audit compliance risk. This ensures earlier detection and mitigation for high-risk subrecipients. Timeline for Implementation All corrective actions have been implemented or will be fully in effect by January 30, 2026. Responsible Party Samira Ahmed, Senior Grants and Compliance Specialist, will be responsible for ensuring subrecipient audit compliance and ongoing monitoring.
Finding No. 2024-002 - Reporting – Significant Deficiency Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available Name of Pass-t...
Finding No. 2024-002 - Reporting – Significant Deficiency Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available Name of Pass-through Entity (if applicable): Nassau County Condition: During our testing, we noted that the Organization did not provide the required monthly reports to Nassau County. Recommendation: We recommend that the Organization establish policies, procedures, and controls to ensure that the required information is submitted on a timely basis. Action Taken: Management has incorporated procedures into our grant compliance and administration policies and procedures to ensure that a Project Director reviews, understands and takes the necessary steps to comply with reporting requirements or other, as set forth by the client agreements. This step includes but is not limited to the Project Director completing a Grant Award File Checklist. Anticipated completion date: Immediately.
Finding No. 2024-001 - Procurement, Suspension and Debarment - Material Weakness Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not a...
Finding No. 2024-001 - Procurement, Suspension and Debarment - Material Weakness Name of Federal Agency: U.S. Department of Treasury Federal Program Name: COVID-19: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Not available Name of Pass-through Entity (if applicable): City of Irving Condition: During our testing, we noted that the Organization did not provide adequate supporting documentation for ensuring proper suspension and debarment checks were performed. Recommendation: We recommend that the Organization establish written suspension and debarment policies and procedures to ensure that the Organization is in compliance with the Uniform Guidance and that all staff are trained on this policy to ensure compliance and related internal controls over compliance are operating effectively. Action Taken: Management has clarified the necessary roles and responsibilities for this requirement in our grant compliance and administration policies and procedures that includes appropriate searches for suspension and debarment, amongst others. prior to executing any financial transactions with individuals and/or organizations. Anticipated completion date: Immediately.
FINDING 2024-002 – Reporting; Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance The grant contract conditions require that applicable reports be filed quarterly. State of Washington Tourism initially submitted performance reports monthly, but in Q4 of 2024 adju...
FINDING 2024-002 – Reporting; Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance The grant contract conditions require that applicable reports be filed quarterly. State of Washington Tourism initially submitted performance reports monthly, but in Q4 of 2024 adjusted the performance reports to quarterly in accordance with award agreement timeframe. The Accounting Manager will complete the report and provide documented support at the end of each quarter in the future. The reports will be reviewed, approved, and submitted by the Director of Strategic Partnership and Tourism Development. These changes took effect April 2025.
Corrective Action: To prevent further incidents, WSIN plans to revise its written accounting procedures to strengthen internal control policies on subaward monitoring and the requirements of the FFATA reporting. Also, with the FFATA reporting now residing in SAM.gov, WSIN will have immediate access ...
Corrective Action: To prevent further incidents, WSIN plans to revise its written accounting procedures to strengthen internal control policies on subaward monitoring and the requirements of the FFATA reporting. Also, with the FFATA reporting now residing in SAM.gov, WSIN will have immediate access to directly input all necessary subaward information. There will be no more waiting periods or delays for the subaward information to be auto loaded or accessed.
2024-002 – Documentation of Controls over Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment, Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery...
2024-002 – Documentation of Controls over Suspension and Debarment (Repeat Finding) Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Procurement, Suspension and Debarment, Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, All Awards. Auditor Description of Condition and Effect. During our testing of suspension and debarment for three vendors and six subrecipients, it was determined that the Organization did not verify that vendors or subrecipients were not suspended, debarred or otherwise excluded when the Organization contracted with them to provide goods or services for five of the nine vendors and subrecipients. The searches at www.sam.gov were done in early 2025 by management, which was well after the date of the applicable contractual agreement and expenditure activity. The failure to monitor suspension and debarment could cause funds to be disbursed to vendors or subrecipients who are not eligible to have goods and services purchased with federal monies. Auditor Recommendation. We recommend that the Organization retain documentation of their procurement process including checking vendors for potential exclusions from federal award work. We further recommend that these checks be done prior to entering into a contractual agreement. Corrective Action. LEAP will be following the recommendation of retaining all documentation of our procurement process including the checking of vendors both at state and federal levels for any potential exclusions from federal award work, and ensuring these checks be done prior to contract execution. LEAP will be substantially modifying its procurement policy that is part of its Grants Management SOP in order to more explicitly detail expectations and procedural steps to meet the requirements of Uniform Guidance with regards to sequence of events leading up to contract execution, including the state and federal checks for exclusion. Further, LEAP’s leadership will be holding a module within the aforementioned internal training for all management team members to walk through a new check list tool that aligns with policy and Uniform Guidance, and case study exercise will also hit on this topic to ensure learning occurs around the internal controls improvements made with policy revamp. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025
2024-001 – Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance/Material Weakness in Internal Control over Compliance (Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, All Awards. Auditor Descr...
2024-001 – Lack of Subrecipient Monitoring Activities Finding Type. Immaterial Noncompliance/Material Weakness in Internal Control over Compliance (Subrecipient Monitoring). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, All Awards. Auditor Description of Condition and Effect. Six subrecipients were selected for testing during the audit procedures. There was no subrecipient agreement noted for one of the subrecipients selected, therefore the required federal award information was not properly communicated. Additionally, no risk assessment was performed, nor was a monitoring plan within documentation of monitoring activities noted for this subrecipient. For the remaining five subrecipients selected for testing, the required federal award information was not properly communicated within the agreements. Lastly, the Organization does not have a procedure requiring the review of subrecipient audits. As a result of this condition, the Organization did not fully comply with the requirements of the Uniform Guidance. Auditor Recommendation. We recommend that management become familiar with the subrecipient monitoring requirements and draft a policy and procedures that provide reasonable assurance that future subrecipient arrangements will be in compliance with the Uniform Guidance. Corrective Action. In an effort for LEAP to become more familiar with the subrecipient monitoring requirements and drafting policy and procedures that provide assurance that future subrecipient arrangements will be in full compliance with the Uniform Guidance federal regulations, LEAP will be modifying its Grants Management SOP to more explicitly detail expectations and procedural steps to meet the requirements of Uniform Guidance. Further, LEAP’s leadership will be holding an internal training for all management team members to discuss this revamped set of policies, go through case study exercises and question and answer session to make sure that all those managing grants or the employees that manage grants have a full understanding of what is expected of them, and their role in various management and oversight processes for the organization. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025
Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement po...
Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG 2 CFR 200.318 through 200.327 and will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. This will be in tandem with establishing effective internal controls as per Uniform Guidance 2 CFR 200.303. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by December 31, 2025.
Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely ...
Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely with project partners of federal grants to establish reporting deadlines and monitor individual reporting requirements throughout the year. This will be in tandem with establishing effective internal controls as per UGG 2 CFR 200.303. The Foundation will take steps to ensure that all required reports are submitted in a timely manner and all relevant documentation and evidence of reports’ submissions are retained in an effective manner. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and the process for internal monitoring documentation to be established by December 31, 2025.
Description of Finding: The Foundation did not have effective internal control policies in place to ensure proper compliance with the federal awards. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will create a more ...
Description of Finding: The Foundation did not have effective internal control policies in place to ensure proper compliance with the federal awards. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will create a more in-depth federal award process and collaborate with project partners to ensure their understanding of the compliance requirements as per Uniform Guidance (UGG) 2 CFR 200.303. The Foundation will also begin internal monitoring to ensure project partners are following established policies and procedures through the duration of each award. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and the process for internal monitoring documentation to be established by December 31, 2025.
2024-002 Noncompliance: Activities Allowed/Unallowed; Allowable Costs/Activities; Reporting A. Comments on Findings and Recommendations: We concur with the auditor’s findings and recommendations regarding reporting of project expenses and unidentified errors in project reconciliations completed by s...
2024-002 Noncompliance: Activities Allowed/Unallowed; Allowable Costs/Activities; Reporting A. Comments on Findings and Recommendations: We concur with the auditor’s findings and recommendations regarding reporting of project expenses and unidentified errors in project reconciliations completed by staff. B. Actions Taken or Planned: Management concurs. Large fiber installation project still in process at year-end. Subsequent reconciliations have been completed. Controls and other project processes have been improved to ensure more timely reconciliation of material charge-outs to the timing of the installation of material. Anticipated completion date: Completed Contact information for this finding: Amanda Burnett, Chief Financial Officer, 573-471-5821
View Audit 369998 Questioned Costs: $1
2024-001 Material Weakness in Internal Control A. Comments on Findings and Recommendations: We concur with the auditor’s findings and recommendations regarding reporting of project expenses and unidentified errors in project reconciliations completed by staff. B. Actions Taken or Planned: Management...
2024-001 Material Weakness in Internal Control A. Comments on Findings and Recommendations: We concur with the auditor’s findings and recommendations regarding reporting of project expenses and unidentified errors in project reconciliations completed by staff. B. Actions Taken or Planned: Management concurs. Large fiber installation project still in process at year-end. Subsequent reconciliations have been completed. Controls and other project processes have been improved to ensure more timely reconciliation of material charge-outs to the timing of the installation of material. Anticipated completion date: Completed Contact information for this finding: Amanda Burnett, Chief Financial Officer, 573-471-5821
2024-002 Procurement Documentation Retention Corrective Action Plan The Center for Black Excellence and Culture Inc will obtain procurement documentation for all vendors and keep for our records electronically in our shared google drive folders. We will have the board review and approve a criteria f...
2024-002 Procurement Documentation Retention Corrective Action Plan The Center for Black Excellence and Culture Inc will obtain procurement documentation for all vendors and keep for our records electronically in our shared google drive folders. We will have the board review and approve a criteria for RFP evaluation and a procurement policy. Person(s) Responsible: Jason Fields, Chief Operations Officer Timing for Implementation: No later than December 31, 2025
Program Name - STOP Violence Grant- Victim Services CFDA Number - 16.588 Pass-through Entity - Michigan Department of Health and Human Service Condition and Description - For 4 out of 20 samples tested, during our testing of participant eligibility under the STOP Violence against Women Formula Grant...
Program Name - STOP Violence Grant- Victim Services CFDA Number - 16.588 Pass-through Entity - Michigan Department of Health and Human Service Condition and Description - For 4 out of 20 samples tested, during our testing of participant eligibility under the STOP Violence against Women Formula Grants, the Organization was unable to provide enrollment forms or supporting documentation. These forms are necessary to verify that participants met the program's eligibility criteria. YWCA Response- The YWCA Victim Services acknowledges this finding and has implemented the following corrective action plan to ensure compliance. Corrective Action Plan - Procedures exist to ensure all clients are enrolled and eligible for services under the STOP grant. In addition to documentation in the Apricot system, an additional legal screening process and intake forms are used to determine eligibility and complete client enrollment within a Victim Services application called MyCase. During the audit, documentation for the four identified cases from MyCase was erroneously excluded, causing the finding. As a subsequent event, the documentation for intake and eligibility for the four identified cases was provided to the external auditors. This process will continue, and future audits will include client documentation for both systems. Additionally, Enforcement of enrollment procedures within Apricot, and oversight from department Directors, has been made a priority. Time Frame for Correction -Appropriate procedures were in place during the full audit year of 2024 and will continue into future years. Corrective action related to documentation within the Apricot system was implemented in August 2025. Individuals Responsible - Jessica Glynn, Vice President of Victim Services and Kellie Swikoski, Grant Manager.
View Audit 369986 Questioned Costs: $1
Views of Responsible Officials: The delay resulted primarily from turnover within the grants management team and the concurrent implementation of a new subaward monitoring system during the reporting period. These factors temporarily affected the timely completion and review of FFATA submissions. To...
Views of Responsible Officials: The delay resulted primarily from turnover within the grants management team and the concurrent implementation of a new subaward monitoring system during the reporting period. These factors temporarily affected the timely completion and review of FFATA submissions. To address the issue and prevent recurrence, HI has taken the following corrective actions: 1. Process Strengthening: Internal grants management procedures have been updated to include a detailed FFATA reporting checklist and a pre-submission timeline that allows for earlier internal review. 2. Staff Training: All grants and compliance staff received refresher training in February 2025 on FFATA reporting requirements and internal deadlines. 3. Oversight and Monitoring: The Director of Grants and Compliance will review FFATA submissions monthly to ensure adherence to Federal reporting deadlines. HI is committed to maintaining full compliance with Federal requirements and will continue to monitor the effectiveness of these corrective measures throughout the current fiscal year.Anticipated Completion Date: February 2025 (with ongoing monthly monitoring throughout the current fiscal year). Responsible Official: Hannah Guedenet, U.S. Executive Director.
2024-004 - Subrecipient Monitoring Activities Auditor Description of Condition and Effect: During subrecipient monitoring testing, the ALN number and award number were not included in the four subrecipient agreements subjected to testing. Additionally, the Organization does not have a policies/proce...
2024-004 - Subrecipient Monitoring Activities Auditor Description of Condition and Effect: During subrecipient monitoring testing, the ALN number and award number were not included in the four subrecipient agreements subjected to testing. Additionally, the Organization does not have a policies/procedure in place to evaluate and address subrecipient's fraud risk and risk of noncompliance. Auditor Recommendation: We recommend that the Organization adopt additional policies and procedures related to subrecipient monitoring to ensure compliance with Uniform Guidance. Corrective Action: The Organization will implement stronger control in place to ensure that subrecipient disclosure requirements are included in the subrecipient agreements. In addition, the Organization will put in place a formal policy to address subrecipient fraud risk and risk of noncompliance. Responsible Person: Dora Gonzales Anticipated Completion Date: December 2025
2024-003 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Condition and Effect: The Organization did not register or submit any subaward information through the FFATA Subaward Reporting System (“FSRS”) reporting system as required by the Uniform Guidance...
2024-003 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Condition and Effect: The Organization did not register or submit any subaward information through the FFATA Subaward Reporting System (“FSRS”) reporting system as required by the Uniform Guidance. The Organization did not follow federal requirements for FFATA reporting through the FSRS and as a result has not completed the appropriate subaward reporting that is required for prime recipients. Auditor Recommendation: We recommend that the Organization establish and implement procedures for FFATA reporting through FSRS and ensure that all key data are reported timely moving forward. Corrective Action: When granting funds as a subaward to a pass-through entity, the Organization will update its records for subawards to include the required information and therefore comply with FFATA reporting requirements for direct awards. Responsible Person: Dora Gonzales Anticipated Completion Date: December 2025
Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with...
Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with the Department of Health and Human Services and other regulatory bodies to ensure proper completion of subaward reports in FSRS, the SF429 and other required reporting. The above noted issue was discovered during the course of the 2024 audit. Upon discovery of the requirement, Management took the above noted steps to become compliant. The finding repeated in 2024 is solely due to the lack of clarity as to the timing of the reporting. Effective to date, all FSRS and applicable SF429 reports have been filed correctly and timely.
Finding 1157927 (2024-001)
Material Weakness 2024
Federal Award Findings and Questioned Costs – Year ending December 31, 2024 Finding 2024-001 – Internal control deficiency and noncompliance over activities allowed or unallowed, allowable costs/cost principles, reporting, and special tests and provisions related to amounts reimbursed for the projec...
Federal Award Findings and Questioned Costs – Year ending December 31, 2024 Finding 2024-001 – Internal control deficiency and noncompliance over activities allowed or unallowed, allowable costs/cost principles, reporting, and special tests and provisions related to amounts reimbursed for the project worksheets. Identification of the federal program: Assistance Listing Number 97.036: • COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) • U.S. Department of Homeland Security • Federal award identification number: o Project number 699651 – CV-727 2020 Q2 PPE and Screening Thermometers • Federal award year – January 20, 2020 to May 11, 2023 • Pass-through entity – Arizona Department of Emergency and Military Affairs (Arizona DEMA) Condition: During the testing over the expenditures included in the project worksheets, management did not have effective internal controls in place to ensure expenditures reported for reimbursement in the FEMA project worksheets were actual paid expenditures. This resulted in an overstatement of the amount reimbursed by FEMA. Management performed an analysis of all expenditures submitted to FEMA and determined there were 4 expenditures reported for reimbursement in the FEMA project worksheets that were not based on actual paid expenditures resulting in an overstatement of the amount reimbursed by FEMA in the amount of $1,406,446. Cause: Management did not have effective internal controls in place over the compliance requirements as stated in the criteria or specific requirement section of the report. Effect or potential effect: Management was reimbursed by FEMA for expenditures that were not based on actual paid expenditures which resulted in an overstatement of the amount reimbursed by FEMA. Without sufficient internal controls, other compliance matters could occur in the future. Questioned costs: $1,406,446 – Assistance Listing Number 97.036 – Federal award identification number – Project number 699651 – CV-727 2020 Q2 PPE and Screening Thermometers Questioned costs were computed by calculating the difference between the expenditures submitted for reimbursement in the FEMA project worksheets and the actual paid expenditures. Context: During the testing over the expenditures included in the project worksheets, the auditors obtained a listing of expenditures submitted for reimbursement to FEMA and selected a sample of 67 for testing the compliance requirements. There was 1 out of 67 selections where the expenditure reported for reimbursement was not based on actual paid expenditure. The sampling was a statistically valid sample. Management performed an analysis of all expenditures submitted to FEMA and determined there were 4 expenditures reported for reimbursement in the FEMA project worksheets that were not based on actual paid expenditures resulting in an overstatement of the amount reimbursed by FEMA in the amount of $1,406,446. Management’s control regarding the review of the project worksheet expenditures did not identify this matter when submitting the project worksheet for reimbursement to FEMA. Identification as a repeat finding, if applicable: No. Recommendation: Management should develop and implement effective internal controls to ensure expenditures reported for reimbursement in the FEMA project worksheets are actual paid expenditures. Management should refund the questioned costs to FEMA and work with FEMA to determine the extent of additional courses of action. Views of responsible officials: Management concurs with the audit finding and has implemented a corrective action plan to address the identified issue. Management has notified Arizona DEMA of the identified expenditures and has begun the process of reimbursing the $1,406,446 to FEMA. For all future FEMA project applications, Management will conduct a comprehensive reconciliation process prior to submission. This process will include a detailed review of invoice documentation and verification of payment to ensure compliance with applicable federal requirements. Responsible Parties: Heather Mahoney, Network Controller Anticipated Date of Completion: September 30, 2025
View Audit 369958 Questioned Costs: $1
2024-006 Community Economic Adjustment of Establishment, Expansion, Realignment, or Closure of a Military Installation/ Finance Performance Reporting Deadlines Starting in Fiscal Year 2025-2026, LRA has implemented adequate tracking and oversight mechanisms to ensure timely submission of required re...
2024-006 Community Economic Adjustment of Establishment, Expansion, Realignment, or Closure of a Military Installation/ Finance Performance Reporting Deadlines Starting in Fiscal Year 2025-2026, LRA has implemented adequate tracking and oversight mechanisms to ensure timely submission of required reports. It developed and maintained a centralized compliance calendar listing all federal reporting deadlines with internals submission deadlines at least fifteen to thirty days before deferral due dates to allow for review and approval before final submission. Once the Finance Department recruits and gives adequate training to the additional staff it will strengthen its internal controls over grant reporting by assigning clear responsibilities to the preparation and timely submission of all required reports. The Finance Department has implemented within its monthly accounting closing procedures tracking and reporting calendar detailing pending reports, due dates, and completion status. Jamille E Muriente Díaz, Financial Affair Director Telephone: 787-705-7188 Email: Jamille.muriente@lra.pr.gov Target Completion Date - 6/30/2026
2024-003 Disaster Grants - Public Assistance Finance (Not A Major Program) FEMA Working Capital Advances LRA acknowledges the finding related to the Working Capital Advances (WCA) received through COR3 and their retention in the Authority’s bank account for more than 365 days without being disbursed...
2024-003 Disaster Grants - Public Assistance Finance (Not A Major Program) FEMA Working Capital Advances LRA acknowledges the finding related to the Working Capital Advances (WCA) received through COR3 and their retention in the Authority’s bank account for more than 365 days without being disbursed. LRA has established and currently maintains written procedures for the management of federal funds, which are designed to comply with applicable federal cash management requirements. LRA is committed to safeguarding federal resources and ensuring their use strictly in accordance with Uniform Guidance. The delays experienced in the disbursement of the WCA funds are primarily attributable to external regulatory factors beyond the direct control of the Authority, including: • The ongoing review by the Federal Emergency Management Agency (FEMA)’s Environmental and Historic Preservation (EHP) division, which is a prerequisite for project execution. • FEMA’s Environmental consultations are required under federal and local regulations, which have extended project timelines. • The project versioning process arising from requests for improved projects that include additional mitigation measures under the Hazard Mitigation Plan (HMP). These regulatory and compliance-driven requirements have temporarily limited the Authority’s ability to execute disbursements, resulting in the retention of funds until the necessary approvals are finalized. It is important to note that the Authority has continued to actively manage these projects, engaging with FEMA and other relevant agencies to ensure that all environmental, historic preservation, and mitigation requirements are fully addressed before project implementation begins. Furthermore, the Authority recognizes the recent programmatic changes to the WCA program implemented by COR3. In response, the Authority is strengthening its financial management practices to align with these revisions and will ensure that future advance requests are supported by a comprehensive spending plan, considering each project’s status to minimize delays associated with FEMA approvals. In cases where project reviews extend beyond anticipated timelines, the LRA may return the corresponding WCA funds to avoid prolonged retention. Once FEMA approval is obtained, the LRA will then reapply to COR3 for the necessary advances. Ramón Lizardi, Facilities Director Telephone: 787-705-7188 Email: Ramón.lizardi@lra.pr.gov Target Completion Date - 6/30/2025
View Audit 369939 Questioned Costs: $1
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