Corrective Action Plans

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Corrective Plan of Action: Silver Key Senior Services has had review and approval processes in place since early 2024; however, gaps arose in consistent documentation. Going forward, all compliance procedures will be followed and documented, including documenting verbal communications. All Controlle...
Corrective Plan of Action: Silver Key Senior Services has had review and approval processes in place since early 2024; however, gaps arose in consistent documentation. Going forward, all compliance procedures will be followed and documented, including documenting verbal communications. All Controller (new role in lieu of CFO) approvals will be maintained in writing, and transactions by the Controller will continue to be reviewed by the CEO. Quarterly spot checks will be conducted to confirm compliance. Anticipated Completion Date: Corrections were made as soon as the issue was identified; procedures are now in place to ensure consistent documentation
FA 2024-001 Improve Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Thro...
FA 2024-001 Improve Budgetary Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial 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: $21,615 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund program revealed instances in which expenditures had not been properly approved by the pass- through entity. Corrective Action Plans: Going forward, the Sumter County Schools Program Director will review, sign, and date all purchase orders to signify that the Program Director has verified that the federal program costs have been written and approved in the consolidated application and/or the budget has been amended to include the costs and approved in the consolidated application and the costs are accurately reflected in the general ledger prior to payment. Estimated Completion Date: August 1, 2025 Contact Person: Jannie Carter, Finance Director Telephone: (229)931-8500 Email: janniecarter@sumterschools.org
View Audit 367287 Questioned Costs: $1
Finding 2024-003: Cash Management Description of Finding: For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipien...
Finding 2024-003: Cash Management Description of Finding: For recipients and subrecipients other than States, payment methods must minimize the time elapsing between the transfer of funds from the Federal agency or the pass-through entity and the disbursement of funds by the recipient or subrecipient regardless of whether the payment is made by electronic funds transfer or by other means. (2 CFR 200.305 (b)) Once funds are disbursed, i.e. transferred from LOCCS to the PHA’s bank account, the PHA must pay the applicable bill(s) within 3 business days after the deposit of the funds into the PHA’s bank account. (HUD Capital Fund Guidebook; Section 7.9) Statement of Concurrence or NonConcurrence: A sample of 4 drawdowns of capital funds from ELOCCs during the year identified 1 instance in which the Authority did not process payment to the vendor within 3 business days of receiving the funds. Corrective Action: The Authority processes a weekly check run for all payables. The timing of the receipts from ELOCCs missed the run and the invoice was added to the following weekly run. The authority will better monitor the receipt of funds and if necessary perform an additional check run to disburse the funds to the recipient. Name of Contact Person: Cheryl Thibeault Projected Completion Date: 09/30/2025
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Palouse Conservation District January 1, 2024 through December 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Feder...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Palouse Conservation District January 1, 2024 through December 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements.Name, address, and telephone of District contact person: Rachel Magers 1615 NE Eastgate Bldg. H Pullman, WA 99163 (509) 332-4101 ext. 110 Corrective action the auditee plans to take in response to the finding: The Palouse Conservation District appreciates the opportunity to respond to the finding and acknowledges the conclusion of the Washington State Auditor’s Office. While the District is aware of the federal suspension and debarment requirements, there was misunderstanding in retaining the proper documentation of the exclusion records from the U.S. General Services Administration’s System for Award Management. The deficiency in internal controls was identified prior to the end of FY24 and the District has implemented proper document retention to comply with the federal requirement. To further strengthen our internal controls and prevent recurrence, the District is implementing additional measures: 1. Internal Verification Log – A formalized verification log will be incorporated into our procurement process to ensure verification and documentation are completed before contracts are signed and payments are processed. 2. Staff Training and Monitoring – Additional training will be conducted to reinforce compliance procedures, and periodic internal reviews will be performed to ensure adherence to federal requirements. The Palouse Conservation District recognizes the importance of maintaining strong internal controls and ensuring compliance with federal requirements. We appreciate the auditor’s recommendations and are committed to the continual improvement of our processes. Anticipated date to complete the corrective action: October 2025
Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-001 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) Description of Finding: Th...
Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2024 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2024-001 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) Description of Finding: The FFATA subawards were not submitted timely to the Federal Funding Accountability and Transparency Act Subaward Reporting System (“FSRS”). The review and approval occurred after the FFATA subaward was submitted to the FSRS. Statement of Concurrence: We concur with the finding above. Corrective Action: BCHN has created a policy regarding the FFATA reporting process. In this process the Electronic Handbook (EHB) is reviewed weekly to ensure that if new awarded funding is released, BCHN is alerted to the need to complete the FFATA report. BCHN has created a spreadsheet to track all the awarded funding and due dates for FFATA reports. Every month, at the board meeting, the spreadsheet is presented to the board with any new awarded funding and when the FFATA report is completed. BCHN has begun a process where the FFATA report is put together by the Finance Manager and reviewed and signed off by the CFO before submitting the report. Completion Date: October 2024. Name of Contact Person: Alicia Tenny Chief Financial Officer Tel. No.: (917) 364-1156 E-mail: atenny@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call Alicia Tenny at (917) 364-1156. Sincerely yours, _________________________ Alicia Tenny Chief Financial Officer
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Spokane January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 2...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Spokane January 1, 2024 through December 31, 2024 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-002 Finding caption: The City did not have adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Skyler Brown, Grants and Contracts Financial Manager W 808 Spokane Falls Blvd Spokane, WA 99201 (509) 625-6294 Corrective action the auditee plans to take in response to the finding: The City currently has a contracting process to verify and document its contractors, consultants and vendors are neither debarred nor suspended. This process adds required certification language to all City agreements to document compliance. While this purchase was reviewed and the compliant status of the providers were verified through the existing cooperative agreement, the City’s process did not capture the needed requirement to verify at the lower tier. This was identified in the prior audit, and due to the timing of this issue and the prior audit finding, the corrections put in place to catch these kinds of purchases going forward had not been put in place yet, and the debarment search on this purchase occurred after the purchase had been made. The City has put into place a requirement that all subawards, purchase agreements and contracts involving federal funds over $25,000 include the required certification even if the contract is derived from “piggy backing” and includes debarment language. Every Contract that receives grant funding goes through the Grants office during the contracting approval process, and this debarment upload is something Grants office is now looking for before approving a contract to move further along the approval process. Anticipated date to complete the corrective action: Currently Active
August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #5 – Sovereign Equity Fund – Fisc...
August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #5 – Sovereign Equity Fund – Fiscal Year End 12/31/2024 To Whom It May Concern: FFATA Reporting - Organization failed to report first-tier subawards in the FSRS system as required under the Federal Funding Accountability and Transparency Act. Corrective Actions: • Designate a responsible party to oversee FFATA compliance. • Update award tracking system to recognize and implement procedures for all first-tier subawards ≥$30,000 for FFATA reporting. • Incorporate FFATA reporting deadlines into grants calendar (due by the end of the month following the award date). • Provide FFATA compliance training and ensure timely access to FSRS.gov. Responsible Party: Executive Director Target Completion Date: Within 14 days; calendar tracking system in use for next subaward Sincerely, Courtney Chavis Executive Director
August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #4 – Sovereign Equity Fund – Fisc...
August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #4 – Sovereign Equity Fund – Fiscal Year End 12/31/2024 To Whom It May Concern: Subrecipient Monitoring - Subrecipient agreements lacked required federal clauses and were not monitored according to risk assessments. Corrective Actions: • Develop a subrecipient monitoring policy aligned with 2 CFR §200.331-333. • Standardize agreement templates to include all required clauses for federal award subrecipient agreements (e.g., audit requirements, FFATA, termination provisions). • Implement a subrecipient risk assessment tool to determine monitoring frequency and risk level identification. • Assign staff for annual subrecipient desk reviews or site visits based on risk levels. Responsible Party: Executive Director / Legal & Compliance Team Target Completion Date: Risk assessment and financial monitoring tool in use and agreement templates updated within 45 days. Sincerely, Courtney Chavis Executive Director
August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #3 – Sovereign Equity Fund – Fisc...
August 15, 2025 United States Department of Agriculture National Institute of Food and Agriculture Awards Management Division 805 Pennsylvania Ave Kansas City, MO 64105 Attention: Federal Audit Clearinghouse (FAC) Subject: Corrective Action Plan Submission – Finding #3 – Sovereign Equity Fund – Fiscal Year End 12/31/2024 To Whom It May Concern: Funds were drawn down in advance under a reimbursement-based award, potentially violating federal cash management standards (2 CFR §200.305). As referenced and in relation to Finding #2 - Grant funds were drawn in excess of current expenditure needs, which resulted in the Organization being required to return the excess funds to the federal government. 2024-002 – Cash Management, 2 CFR 200.305 (Payment). Corrective Actions: • The Organization has returned the excess funds to the federal government.. • Revise internal procedures to include verification of expenditures for eligible and allowable expenses before initiating a draw request. • Develop a drawdown checklist and require supporting documentation for incurred costs, retain supporting documentation for all drawdowns. • Require Executive Director approval prior to all federal drawdowns. • Conduct training on federal reimbursement protocols for program and finance staff. Responsible Party: Grants Manager / Executive Director Target Completion Date: Policy update within 2 weeks; checklist rollout within 30 days Sincerely, Courtney Chavis Executive Director
View Audit 367244 Questioned Costs: $1
Corrective Actions Taken:
Corrective Actions Taken:
1. A Board-approved Budgeting Policy was implemented and most recently revised in June 2025.
1. A Board-approved Budgeting Policy was implemented and most recently revised in June 2025.
2. Separate budgets are now developed and maintained for federal, non-federal, and total project funds. Each federal award is budgeted and monitored independently.
2. Separate budgets are now developed and maintained for federal, non-federal, and total project funds. Each federal award is budgeted and monitored independently.
3. Budget-to-actual activity is reviewed monthly using standardized variance reporting tools.
3. Budget-to-actual activity is reviewed monthly using standardized variance reporting tools.
4. The CEO is responsible for ensuring that all expenditures align with the HRSA-approved total project budget.
4. The CEO is responsible for ensuring that all expenditures align with the HRSA-approved total project budget.
5. Budget revisions are evaluated under 45 CFR § 75.308, and HRSA prior approval is requested when required.
5. Budget revisions are evaluated under 45 CFR § 75.308, and HRSA prior approval is requested when required.
6. All budgets and budget modifications are approved by the Board of Directors and reflected in monthly financial management reports.
6. All budgets and budget modifications are approved by the Board of Directors and reflected in monthly financial management reports.
Corrective Action Plan:
Corrective Action Plan:
1. The Controller, outside account and CEO conduct monthly budget-to-actual reviews for all federal awards, using variance analysis tools.
1. The Controller, outside account and CEO conduct monthly budget-to-actual reviews for all federal awards, using variance analysis tools.
2. Variance reports are submitted to the CEO and reviewed with the Finance Committee on a monthly basis.
2. Variance reports are submitted to the CEO and reviewed with the Finance Committee on a monthly basis.
3. HRSA budget categories were added to the general ledger in 2024 to enable accurate expenditure tracking by category.
3. HRSA budget categories were added to the general ledger in 2024 to enable accurate expenditure tracking by category.
4. Training on budget monitoring and federal requirements was conducted in June 2024 and will be repeated annually.
4. Training on budget monitoring and federal requirements was conducted in June 2024 and will be repeated annually.
5. Budget compliance is reviewed quarterly as part of SCMRC’s internal financial monitoring processes.
5. Budget compliance is reviewed quarterly as part of SCMRC’s internal financial monitoring processes.
Corrective Actions Taken:
Corrective Actions Taken:
1. Responsibility for tracking the period of performance for all federal grants was assigned to the Controller in April 2025, with oversight provided by the CEO and Finance Committee.
1. Responsibility for tracking the period of performance for all federal grants was assigned to the Controller in April 2025, with oversight provided by the CEO and Finance Committee.
2. A centralized compliance calendar is now maintained to track grant start and end dates, obligation deadlines, and reporting due dates.
2. A centralized compliance calendar is now maintained to track grant start and end dates, obligation deadlines, and reporting due dates.
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