Corrective Action Plans

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The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance p...
The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance policy and procedures framework. The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including reporting. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.
OTAG recognizes the need to strengthen internal controls related to cash management reporting, matching requirement monitoring, and grant period-of-performance compliance. A comprehensive review of existing Master Cooperative Agreement Appendices management processes has been initiated to identify c...
OTAG recognizes the need to strengthen internal controls related to cash management reporting, matching requirement monitoring, and grant period-of-performance compliance. A comprehensive review of existing Master Cooperative Agreement Appendices management processes has been initiated to identify control weaknesses and implement corrective measures. OTAG will implement tracking tools to monitor award periods, liquidation deadlines, and expenditure charging. Personnel will verify Master Cooperative Agreement Appendices periods prior to processing transactions. Expenditures charged to awards will undergo review to confirm alignment with the applicable award and performance period with cross reconciliation of the Government of the Virgin Islands procurement methods, and the Government of the Virgin Islands fiscal enterprise system. Policy and Procedure Enhancements: OTAG will update SOPPs to address cash management, reporting requirements, matching calculations, expenditure monitoring, and period-of-performance reviews. Training will be provided to personnel upon implementation of the revised procedures. Preventive Measures: •Monthly grant reconciliation reviews. •Quarterly compliance monitoring. •Management review of reimbursement requests and matching calculations. •Annual internal compliance assessment. •Centralized documentation repository for grant records. Monitoring & Accountability: The Adjutant General and Executive Director will monitor implementation and effectiveness. Quarterly compliance reports will be provided to agency leadership, and corrective actions will be tracked through completion.
The Government concurs with the auditor’s findings and recommendations. DOH has implemented no corrective action, as grant is closed.
The Government concurs with the auditor’s findings and recommendations. DOH has implemented no corrective action, as grant is closed.
The Government concurs with the auditor’s findings and recommendations. DOH has implemented no corrective action, as grant is closed.
The Government concurs with the auditor’s findings and recommendations. DOH has implemented no corrective action, as grant is closed.
As of July 2024, DOH revised drawdown Standard Operating Procedures (SOPs) to mandate that all supporting documents include a signature or initial to certify that a proper review was conducted at certification level of certification. DOH have also incorporated this updated procedure into Federal Gra...
As of July 2024, DOH revised drawdown Standard Operating Procedures (SOPs) to mandate that all supporting documents include a signature or initial to certify that a proper review was conducted at certification level of certification. DOH have also incorporated this updated procedure into Federal Grants update trainings and made it accessible to all staff on Business Process Improvement SharePoint site.
As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Federal Grants ...
As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Federal Grants Financial Analyst is being integrated into the workflow to ensure compliance. Additionally, a Director of Federal Grants has been onboarded to add an additional level of oversight.
Finding 1223264 (2024-002)
Material Weakness 2024
Finding ref number: 2024-002 Finding caption: The County did not have adequate internal controls for ensuring compliance with federal suspension and debarment requirements, and it did not comply with federal reporting requirements. Name, address, and telephone of County contact person: Mandy Kim, Ch...
Finding ref number: 2024-002 Finding caption: The County did not have adequate internal controls for ensuring compliance with federal suspension and debarment requirements, and it did not comply with federal reporting requirements. Name, address, and telephone of County contact person: Mandy Kim, Chief Financial Officer 35 C Street NW Ephrata, WA 98823 (509) 754-2011 Corrective action the auditee plans to take in response to the finding: The County is strengthening internal controls over suspension/debarment and SLFRF reporting. Actions include: 1. Implementing required suspension/debarment checks and documenting verification for all federally funded contracts. 2. Updating policies and providing staff training on compliance requirements. 3. Establishing quarterly reconciliations to ensure SLFRF obligations and expenditures agrees to the general ledger. 4. Enhancing supervisory review and maintaining supporting documentation for all federal reports. Anticipated date to complete the corrective action: 12/31/2026
2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) fo...
2024-008 – CORONAVIRUS CAPITAL PROJECT FUND – LACK OF SUPPORT FOR PROCUREMENT – ALN 21.029 - MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition: Williston Basin Public School District No. 7 did not maintain support surrounding the selection process for the construction management at-risk (CMAR) for the CTE Center. Therefore, we were unable to determine if the CMAR selection was properly completed. In addition, Willison Basin Public School did not have a procurement policy. Management’s Response: We agree. The District will work to ensure that future projects are properly procured within state law and federal guidelines. Anticipated Completion Date: FY 2025
1. Supporting Documentation Policy and Procedures • The District has adopted a revised Written Documentation Policy requiring that all expenditures, including payroll, non-payroll, credit card, and Amazon business account transactions, be supported by approved invoices, receipts, or equivalent docum...
1. Supporting Documentation Policy and Procedures • The District has adopted a revised Written Documentation Policy requiring that all expenditures, including payroll, non-payroll, credit card, and Amazon business account transactions, be supported by approved invoices, receipts, or equivalent documentation prior to payment processing. • All credit card and Amazon purchases now require pre-approval by the applicable department head through the purchase requisition process and an approved purchase order is documented for use of the credit card. The credit card must be signed out with the finance department and all receipts are turned in immediately when the credit card is returned to the finance department. Transactions lacking documentation will be flagged for immediate follow-up. 2. Payroll Accuracy and Leave Record Maintenance • The District has implemented a formal review process for all additional pay authorizations. All extra-duty pay, stipends, and additional compensation must now be supported by a written authorization from the Board of Directors prior to payroll processing. • The District is updating its leave management system to ensure accurate tracking of sick leave used and accumulated for all employees, in compliance with Ark. Code Ann. § 6-17-1205. Leave records will be reconciled monthly by the finance department. • AMS Impact Group conducts a secondary review of all payroll runs prior to submission to verify supporting documentation is complete and on file. This began in October 2025. 3. Journal Entry Controls • The District has established a formal journal entry approval policy. Effective December 2025 all journal entries must include written documentation of the purpose, supporting calculations or backup, and an authorized approval signature/email approval prior to posting. • Beginning in December 2025, AMS Impact Group reviews and approves all journal entries before they are recorded in the general ledger. No journal entry is to be posted without documented approval. 4. Procurement Authority and Contract Approval • The District has reviewed and reinforced its compliance with School Board Policy Rule 7.5 regarding procurement thresholds. All contracts or purchase commitments exceeding the competitive bid threshold ($21,604 for commodities) must be presented to and approved by the Board of Directors prior to execution. • A procurement review workflow has been established in which the Finance Director reviews all proposed contracts for threshold compliance before the Superintendent signs. Contracts requiring Board approval will be placed on the next available Board agenda before execution. • District administration has communicated these procurement requirements to all staff with purchasing authority. Training will be provided to department heads and administrators on allowable purchasing limits. 5. Management Oversight and Staffing • The District has filled or is actively recruiting for key financial positions that were vacant during the audit period. Adequate staffing is essential to sustaining effective internal control activities. • The District will engage its external financial consultant (AMS Impact Group) to provide ongoing monitoring support and to assist with training of newly hired financial staff.
Finding Number 2024-007 Corrective Action Plan (CAP) CSG has implemented a CAP following the previous finding in the FY 2023 Audit. The Department of Administrative Services requires a printed verification search on Sams.gov for all transactions in the amount of $25,000 and above. This verification ...
Finding Number 2024-007 Corrective Action Plan (CAP) CSG has implemented a CAP following the previous finding in the FY 2023 Audit. The Department of Administrative Services requires a printed verification search on Sams.gov for all transactions in the amount of $25,000 and above. This verification is provided at the department level and reviewed by the Funds Department and Compact Funds Control Commission (CFCC). A memorandum was provided to the Funds Department requiring them to return payment requests of $25,000 and above that do not have this search verification. CSG will draft an official policy on Procurement Suspension and Debarment specifically regarding verification search on Sams.gov. Anticipated Completion Date December 31, 2026 Responsible Person (Contact Details) Jonas Paul, Director (DAS) jpaulckdas@gmail.com Kayviann Hallers Umwech, Internal Control (DAS) kayviannhallers@gmail.com Roxalyn Kaminanga, Chief (DAS) roxalynkaminanga@gmail.com
Finding Number 2024-006 Corrective Action Plan (CAP) CSG will draft and implement a policy on Period of Performance, specifically regarding the timely reversals of voided expenditures during the fiscal year. This policy will include: • The appropriate departments and/or persons responsible for voidi...
Finding Number 2024-006 Corrective Action Plan (CAP) CSG will draft and implement a policy on Period of Performance, specifically regarding the timely reversals of voided expenditures during the fiscal year. This policy will include: • The appropriate departments and/or persons responsible for voiding transactions must do so within a timely manner. • All recognized transactions to be cancelled must be voided and removed from expenditures by the closing of the fiscal period. Anticipated Completion Date December 31, 2026 Responsible Person (Contact Details) Jonas Paul, Director (DAS) jpaulckdas@gmail.com Kayviann Hallers Umwech, Internal Control (DAS) kayviannhallers@gmail.com Roxalyn Kaminanga, Chief (DAS) roxalynkaminanga@gmail.com
Finding Number 2024-005 Corrective Action Plan (CAP) CSG will draft and implement a policy on Equipment and Real Property Management, specifically regarding safe-guarding equipment and reporting. Policy will include: • A requirement for each department to assign a custodian to manage all capitalized...
Finding Number 2024-005 Corrective Action Plan (CAP) CSG will draft and implement a policy on Equipment and Real Property Management, specifically regarding safe-guarding equipment and reporting. Policy will include: • A requirement for each department to assign a custodian to manage all capitalized equipment. • A requirement for each department to report all incidents via an Equipment Incident Report form. • Each department will be required to update DAS on the status of all capitalized equipment on a quarterly basis. • A Physical Inventory Count will be done annually to ensure proper reporting of existing equipment. Anticipated Completion Date December 31, 2026 Responsible Person (Contact Details) Jonas Paul, Director (DAS) jpaulckdas@gmail.com Kayviann Hallers Umwech, Internal Control (DAS) kayviannhallers@gmail.com Roxalyn Kaminanga, Chief (DAS) roxalynkaminanga@gmail.com
Finding Number 2024-004 Corrective Action Plan (CAP) CSG will draft and implement a policy on Cash Management specifically regarding cash disbursement to vendors for infrastructure projects. • CSG will assign a designated person to request drawdowns for Infrastructure projects. This same individual ...
Finding Number 2024-004 Corrective Action Plan (CAP) CSG will draft and implement a policy on Cash Management specifically regarding cash disbursement to vendors for infrastructure projects. • CSG will assign a designated person to request drawdowns for Infrastructure projects. This same individual will keep track of this request and will notify the appropriate individuals at Chuuk State Finance who will authorize the disbursement of the check/s to the vendor. • A specific timeframe in which CSG will minimize the time between cash drawdown received from FSM National Government and disbursement to vendors will be established upon consultation with grantor agency. Anticipated Completion Date December 31, 2026 Responsible Person (Contact Details) Jonas Paul, Director (DAS) jpaulckdas@gmail.com Kayviann Hallers Umwech, Internal Control (DAS) kayviannhallers@gmail.com Roxalyn Kaminanga, Chief (DAS) roxalynkaminanga@gmail.com
Implement policies and procedures requiring a vendor to provide proof of good standing with Sam.gov when bidding a project. The county will double check for accuracy.
Implement policies and procedures requiring a vendor to provide proof of good standing with Sam.gov when bidding a project. The county will double check for accuracy.
Develop procurement policy for federal grants noting that bids on federal grants will be advertised for at least three weeks.
Develop procurement policy for federal grants noting that bids on federal grants will be advertised for at least three weeks.
The Board acknowledges the recommendation regarding documentation and will ensure improved documentation is maintained in the future to support sole source determinations and purchasing decisions.
The Board acknowledges the recommendation regarding documentation and will ensure improved documentation is maintained in the future to support sole source determinations and purchasing decisions.
Develop and document formal policies and procedures for grant management, including repo1iing, monitoring, and compliance. Implement these policies and ensure that each office is using them correctly.
Develop and document formal policies and procedures for grant management, including repo1iing, monitoring, and compliance. Implement these policies and ensure that each office is using them correctly.
Finding 2024-009: Reporting – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not maintain copies of performance-related reports submitted to the grantor for the Title V program. Corrective Action: Management is implementing a formal process t...
Finding 2024-009: Reporting – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not maintain copies of performance-related reports submitted to the grantor for the Title V program. Corrective Action: Management is implementing a formal process to retain all supporting documentation for performance-related reports submitted to grantors in accordance with Federal requirements. NACA is also hiring and training a Grant Director to strengthen oversight of grant reporting, compliance, and documentation requirements. As part of the monthly and grant reporting process, staff will ensure that copies of all submissions are saved. A review step will also be added to confirm that all required documentation has been retained prior to final submission. Management will continue to evaluate and adjust processes as needed to ensure compliance and completeness. Name of Person Responsible: Walter McCullough, CFO and finance staff Anticipated Date of Completion: May 31, 2026
Finding 2024-008: Cash Management – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not retain copies of cost reimbursement reports submitted to the grantor for the Urban Health Clinic, Substance Abuse Prevention, and Title V programs. Correct...
Finding 2024-008: Cash Management – Material Weakness Condition: As a result of the audit procedures, it was noted that the Organization did not retain copies of cost reimbursement reports submitted to the grantor for the Urban Health Clinic, Substance Abuse Prevention, and Title V programs. Corrective Action: Management is implementing a formal process to retain all cost reimbursement reports submitted to grantors in accordance with Federal record retention requirements. NACA is also hiring and training a Grant Director to strengthen oversight of grant reporting, reimbursement processes, and documentation requirements. This will include establishing a centralized and organized filing system, to ensure all submitted reimbursement reports are maintained and accessible. As part of the monthly reimbursement and grant reporting process, staff will ensure that copies of all submissions are saved and reconciled to the accounting records. A review step will also be added to confirm that all required documentation has been retained and properly organized prior to final submission. Management will continue to evaluate and adjust processes as needed to ensure compliance and completeness. Name of Person Responsible: Walter McCullough, CFO and finance staff Anticipated Date of Completion: May 31, 2026
Finding 2024 -006: Overbilling of Indirect Costs – Material Weakness Condition: During the course of the audit, Baker Tilly determined that, for certain time periods, NACA applied an incorrect indirect cost rate, resulting in over billings to the funding source. Corrective Action: Along with the aud...
Finding 2024 -006: Overbilling of Indirect Costs – Material Weakness Condition: During the course of the audit, Baker Tilly determined that, for certain time periods, NACA applied an incorrect indirect cost rate, resulting in over billings to the funding source. Corrective Action: Along with the auditors and the process during the course, management disclosed and determined there was an overcharge of indirect costs. Currently, NACA is under a negotiated cost agreement. We have already disclosed the overbilling to I H S, who is our cognizant grantor, and plan is to disclose to other federal and local agencies. If needed, a payback plan will be established. Communication will be via email for documentation purposes. Name of Person Responsible: Walter McCullough, CFO Anticipated Date of Completion: April 30, 2026.
Views of responsible officials and planned corrective actions – Management concurs with the auditor’s finding. The Organization acknowledges that patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization’s policy. All billin...
Views of responsible officials and planned corrective actions – Management concurs with the auditor’s finding. The Organization acknowledges that patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization’s policy. All billing staff will receive retraining on the correct manual posting procedures for sliding fee scale adjustments after insurance payments, ensuring compliance with patient income verification and applicable percentage guidelines. We will also continue ongoing monitoring and review of accounts receiving sliding fee scale adjustments to ensure accurate and compliance application of the approved discount and percentages. Anticipated Completion Date – 90 days from audit issuance Responsible Contact Person – Donald Griffis, Business Analyst
UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported b...
UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026
procedures to ensure payments are clearly identifiable by participant and reconciled to approved eligibility records before assistance is provided. Each payment will be supported by participant identification, eligibility approval, assistance type, approved amount, funding source, payment date, and ...
procedures to ensure payments are clearly identifiable by participant and reconciled to approved eligibility records before assistance is provided. Each payment will be supported by participant identification, eligibility approval, assistance type, approved amount, funding source, payment date, and supporting documentation. UCM has established TANF Eligibility Determination Guidelines, a List of Acceptable Documents, and an Assistance Agreement Form to support eligibility determinations and benefit payment documentation. Per VDSS guidance, once eligibility is established at the beginning of the program, a change in status during the participant’s stay does not disqualify the participant from receiving further services. Felony record documentation is not required in the participant file as felony record status is not part of the eligibility requirement per VDSS. Evidence of review and approval will be retained in the participant file. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Case Managers Shruti Jha, Senior Director of Finance Liya Tseye & Carmen Romero, Accountants Laura D’Ambrogi, Grants Manager Anticipated Completion Date: Substantially completed as of April 6, 2026. Ongoing payment review, eligibility monitoring, reconciliation, and supervisory review will continue during the program year.
UCM will strengthen internal controls over TANF eligibility determinations by formalizing written procedures that clearly identify the documentation required to support each eligibility criterion before assistance is provided. The procedures will define required documentation for financial eligibili...
UCM will strengthen internal controls over TANF eligibility determinations by formalizing written procedures that clearly identify the documentation required to support each eligibility criterion before assistance is provided. The procedures will define required documentation for financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, applicable legal eligibility requirements, and work participation requirements when applicable. UCM reviewed and discussed the findings with the auditor, Senior Director of Finance, and Chief Program Officer. UCM also reviewed the Virginia Department of Social Services post-training materials on TANF Employment Advancement Eligibility Determination Training, and clarified identified areas of the findings with the Virginia Department of Social Services as they relate to the subrecipient signed contract. UCM designed new Screening Guidelines for incoming program participants, including a documented supervisory review and approval process, which were completed on April 16, 2026. The new screening guidelines require participant files to include sufficient documentation supporting eligibility determinations and require supervisory review before assistance is provided. A supervisor or designated reviewer will verify that the participant file contains the required eligibility documentation, that eligibility criteria have been met, and that the assistance is consistent with TANF requirements, VDSS guidance, the subrecipient contract, and program guidelines. UCM reviewed and trained staff on the new eligibility screening guidelines, acceptable documents, and income requirements on April 28, 2026. Staff responsible for TANF eligibility determinations, case management, direct assistance, and grant compliance will continue to receive training as needed to ensure they understand TANF documentation requirements and maintain complete and accurate participant files. UCM will also periodically monitor participant files to confirm continued compliance and identify any additional training or process improvements needed. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Case Managers VDSS Program Consultant Anticipated Completion Date: Substantially completed as of April 28, 2026. Ongoing implementation, supervisory review, staff training, and monitoring will continue during the program year.
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive subrecipient management framework. We are prioritizing the formalization of subaward agreement templates, the implementation of a rigorous risk-based monitoring program, and the institutionalization of standardized ove...
VIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive subrecipient management framework. We are prioritizing the formalization of subaward agreement templates, the implementation of a rigorous risk-based monitoring program, and the institutionalization of standardized oversight procedures to ensure full compliance with all federal pass-through entity responsibilities. Action Steps: 1. Develop and implement a formal "Entity Classification Protocol" based on 2 CFR §200.331 to correctly identify subrecipients versus contractors for all existing and future TANF agreements. 2. Redesign all subaward templates to include the mandatory thirteen (13) elements required by 2 CFR §200.332(a), including FAIN, ALN, period of performance, and audit access clauses. 3. Implement a mandatory Subrecipient Risk Assessment tool to evaluate every subrecipient's fraud risk, financial management capacity, and history of audit findings before funding is disbursed. 4. Establish a monitoring protocol that includes mandatory reviews of financial and performance reports, verification of Single Audits (Subpart F), and scheduled on-site programmatic site visits. 5. Create a formal "Enforcement Policy" to manage subrecipient Non-Compliance, outlining the process for issuing management decisions on audit findings and implementing corrective action plans. 6. Launch an intensive training program for all program and procurement staff on the Uniform Guidance requirements for pass-through entities, focusing on proper identification, monitoring, and federal reporting accountability. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Gerhil Medina Baez Auxiliary Administrator Operational ServicesVIEWS OF RESPONSIBLE OFFICIALS ADSEF is committed to establishing a comprehensive subrecipient management framework. We are prioritizing the formalization of subaward agreement templates, the implementation of a rigorous risk-based monitoring program, and the institutionalization of standardized oversight procedures to ensure full compliance with all federal pass-through entity responsibilities. Action Steps: 1. Develop and implement a formal "Entity Classification Protocol" based on 2 CFR §200.331 to correctly identify subrecipients versus contractors for all existing and future TANF agreements. 2. Redesign all subaward templates to include the mandatory thirteen (13) elements required by 2 CFR §200.332(a), including FAIN, ALN, period of performance, and audit access clauses. 3. Implement a mandatory Subrecipient Risk Assessment tool to evaluate every subrecipient's fraud risk, financial management capacity, and history of audit findings before funding is disbursed. 4. Establish a monitoring protocol that includes mandatory reviews of financial and performance reports, verification of Single Audits (Subpart F), and scheduled on-site programmatic site visits. 5. Create a formal "Enforcement Policy" to manage subrecipient Non-Compliance, outlining the process for issuing management decisions on audit findings and implementing corrective action plans. 6. Launch an intensive training program for all program and procurement staff on the Uniform Guidance requirements for pass-through entities, focusing on proper identification, monitoring, and federal reporting accountability. IMPLEMENTATION DATE During Fiscal Year 2026-2027 RESPONSIBLE PERSON Blanca M. Medina Díaz Administrator Gerhil Medina Baez Auxiliary Administrator Operational Services
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