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Finding 563582 (2024-001)
Significant Deficiency 2024
We acknowledge the finding and have already addressed the issue. Additionally, we have incorporated this procedure into our compliance checklist. As a result, monthly reminders will be sent to a designated group within the Finance team to help prevent recurrence.
We acknowledge the finding and have already addressed the issue. Additionally, we have incorporated this procedure into our compliance checklist. As a result, monthly reminders will be sent to a designated group within the Finance team to help prevent recurrence.
Finding 563581 (2024-004)
Significant Deficiency 2024
A tracking system (Kidkare) has been established to ensure day care homes are reviewed at least every six months, as required. The City also creates a spreadsheet to help track day care homes monitoring status during staff turnover/ transition.
A tracking system (Kidkare) has been established to ensure day care homes are reviewed at least every six months, as required. The City also creates a spreadsheet to help track day care homes monitoring status during staff turnover/ transition.
Finding 2024-015 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Comments on Finding Prior to executing subgrant agreements, in accorda...
Finding 2024-015 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Comments on Finding Prior to executing subgrant agreements, in accordance with 2 CFR 200, the Mayor’s Office of Recovery Programs (Recovery Office) confirms that subrecipients have a Unique Entity Identifier (UEI) through SAM.gov. The Recovery Office is responsible for ensuring that UEI information is correctly entered into subgrant agreements that are between the Recovery Office and a subrecipient. Additionally, the Recovery Office shared the UEI requirement with City agencies and developed template ARPA subgrant agreements that City agencies must use with their subrecipients. These templates include a specific field in which to enter the UEI. City agencies are responsible for ensuring that this information is correctly entered into the subgrant agreement. Whether the subgrant agreement is executed by the Recovery Office or another City agency, the Recovery Office collects and retains the SAM.gov record for each subrecipient on the City’s secure network and records the UEI number in a spreadsheet. UEIs are also included in all statutorily required quarterly and annual reporting to the U.S. Department of Treasury. This information has consistently and accurately been reported to the Treasury. However, though required reports to Treasury are accurate, the Recovery Office acknowledges that the UEI was missing or incorrect for some subgrant agreements. This is due to the following: • Clerical errors in the preparation of draft agreements; and • An early version of a funding exhibit in ARPA template subgrant agreements that did not include a specific field in which to enter the UEI (this funding exhibit has since been corrected). CAP for Agreements Executed by the Mayor’s Office of Recovery Programs Subgrant Agreement Review • The Recovery Office will complete a review of all executed subgrant agreements to confirm that the correct Unique Entity Identifier (UEI) appears in the agreement. o This review will exclude Interagency Agreements with City agencies since they are not considered subrecipients, but as the prime recipient, the City of Baltimore. o This review will also exclude any agreements related to projects classified under Expenditure Category 6.1 in ARPA SLFRF guidance. According to Frequently Asked Questions (FAQs) issued by the Treasury, this EC does not give rise to subrecipient relationships, therefore UEI information is not required1. Resolution of Identified UEI Errors in Subgrant Agreements • For any subgrant agreements with an incorrect or missing UEI, the Recovery Office will submit a single memorandum that presents correct UEIs to the Board of Estimates (BOE) to ensure that the official record has correct UEI information. New Subgrant Agreements • The Recovery Office will implement a revised business process for the review of subgrant agreements. All ARPA funding was obligated as of December 31, 2024. According to Treasury guidance, there are very limited circumstances in which a jurisdiction may enter new subgrant agreements after the statutory obligation deadline. If the Recovery Office does execute a new subgrant agreement, the Recovery Office Project Manager must include the following two items in their request for the Chief Recovery Officer’s signature on the document: o a copy of the subrecipient’s SAM.gov record; and o written confirmation that the UEI number presented in the agreement matches the subrecipient’s SAM.gov record. CAP for Agreements Signed by Other City of Baltimore Agencies Subgrant Agreement Review • The Recovery Office will distribute a list to City agencies with all subgrants funded by ARPA. The list will include the subgrant agreement amount, subgrantee name, Workday identifiers (e.g., Purchase Order or Supplier Contract numbers), and the UEI number on file. o This review will also exclude any agreements related to projects classified under Expenditure Category 6.1 in ARPA SLFRF guidance. According to Treasury FAQs, this EC does not give rise to subrecipient relationships2. o City agencies must complete a review of all ARPA-funded subgrant agreements included on the list and confirm that the UEIs are accurate. Resolution of Identified UEI Errors in Subgrant Agreements • For any subgrant agreements with an incorrect or missing UEI, the Recovery Office will require each City agency to submit a single memorandum that presents correct UEIs to the Board of Estimates (BOE) to ensure that the official record has correct UEI information. • Using the list distributed by the Recovery Office, City agencies will confirm that the correction memo has been submitted and approved by the BOE. New Subgrant Agreements • The Recovery Office will implement a revised business process for the review of subgrant agreements in Workday. Though the Recovery Office does not execute ARPA-funded agreements initiated by other City agencies, executed agreements are routed in Workday for Recovery Office approval. The Recovery Office Project Manager will review the UEI presented in the agreement and confirm its accuracy. If it is missing or inaccurate, the Project Manager will notify the agency and instruct them to submit a memorandum to the BOE with the correct UEI information. 1 According to FAQ 13.14 Treasury is not collecting subaward data for projects categorized under Expenditure Category Group 6 “Revenue Replacement.” Treasury has determined that there are no subawards under this eligible use category. U.S. Department of the Treasury. (2021). Final Rule Frequently Asked Questions (FAQ). Retrieved from https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf. 2 According to FAQ 13.14 Treasury is not collecting subaward data for projects categorized under Expenditure Category Group 6 “Revenue Replacement.” Treasury has determined that there are no subawards under this eligible use category. U.S. Department of the Treasury. (2021). Final Rule Frequently Asked Questions (FAQ). Retrieved from https://home.treasury.gov/system/files/136/SLFRF-Final-Rule-FAQ.pdf. Contact Person: Elizabeth Tatum, Deputy Director, Mayor’s Office of Recovery Programs Completion Date: June 30, 2025
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Auditee’s Corrective Action Plan: BCHD has develo...
Finding 2024-028 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-024 Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routing internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. E. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. F. Subrecipient contract agreement templates are being updated to ensure subaward is clearly identified and includes the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025
Finding 2024-026 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-022 Auditee’s Corrective Action Plan: BCHD fiscal department ...
Finding 2024-026 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-022 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Auditee’s Corrective Action Plan: BCHD has developed a subrecipient moni...
Finding 2024-025 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-021 Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routing internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. E. Update subrecipient contract agreement templates ensure subawards are clearly identified and include the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025
Finding 2024-024 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-020 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its...
Finding 2024-024 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-020 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025
Finding 2024-023 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-019 Auditee’s Corrective Action Plan: BCHD fiscal department continues to rev...
Finding 2024-023 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-019 Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established a Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025
Finding 2023-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 BCHD has developed a subrecipient monitoring policy currently ro...
Finding 2023-022 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-017 BCHD has developed a subrecipient monitoring policy currently routed internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2 CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit to ensure subrecipients are properly identified and to develop a comprehensive monitoring schedule for the agency. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. E. Updated monitoring and risk assessment tools to include requesting and documenting both single audit reports and SAMS.gov status. E. Update subrecipient contract agreement templates ensure subawards are clearly identified and include the Federal Award Identification Number, subrecipient’s UEI, along with clear monitoring expectations. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: June 30, 2025
Finding 2024-021 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-016 Auditee’s Corrective Action Plan: The Federal Financial Report (FFR) is a cumu...
Finding 2024-021 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-016 Auditee’s Corrective Action Plan: The Federal Financial Report (FFR) is a cumulative report covering the entire project or award period, which for this grant spans from March 1, 2020, to February 28, 2025. As a result, the cumulative amounts reported on the FFR will not align with the amounts recorded in the general ledger for fiscal year 2024. BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. D. Established the Contract and Compliance Unit responsible for overseeing the filing of the FFATA report. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025
Finding 2024-019 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise i...
Finding 2024-019 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Auditee’s Corrective Action Plan: BCHD fiscal department continues to revise its internal processes to strengthen capacity and to ensure compliance with 2 CFR 200 by implementing the following: A. Comprehensive staff training, supported by documented Standard Operating Procedures, training guides and updated policies which will include processes for timely submission of grant reports with required fiscal approvals. B. Create a standard reconciliation process that will ensure expenditures reported on required grantor reports are properly reflected in the general ledger in addition to clearly identifying variances from the SEFA due to timing. C. Created an internal comprehensive grants tracker via Smartsheet which includes all grant award periods, reporting requirements, due dates and other pertinent grant award data. Contact Person: Unyime Ekpa, Chief Financial Officer, Baltimore City Health Department Completion Date: September 30, 2025
Finding 2024-018 U.S. Department of Health and Human Services AL No. 93.600 Head Start Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: While the FAIN was included in the package approved by BOE and sent t...
Finding 2024-018 U.S. Department of Health and Human Services AL No. 93.600 Head Start Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: While the FAIN was included in the package approved by BOE and sent to the subrecipient and the budget and the Federal award also included in the package showed that only direct costs would be reimbursed, the City’s Law Department will revise Exhibit G Funding Source in Subrecipient contracts to include the FAIN, the subrecipient’s UEI and a statement regarding indirect costs. Consequently, the information noted as missing will be specifically referenced/included in contracts signed by the subrecipients moving forward. Contact Person: Shannon Burroughs-Campbell, Executive Director of Baltimore City Head Start Lisa Dooley, Head Start Accountant Completion Date: June 30, 2025
Finding 2024-017 U.S. Department of Health and Human Services AL No. 93.600 Head Start Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOCFS has noted the requirement to complete the FFATA report on the annual Baltimor...
Finding 2024-017 U.S. Department of Health and Human Services AL No. 93.600 Head Start Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOCFS has noted the requirement to complete the FFATA report on the annual Baltimore City Head Start Administrative Calendar and will put an alert in the Workday system. Filing the FFATA for each sub-recipient will be completed once the entire contract is approved by the BOE. Contact Person: Shannon Burroughs-Campbell, Executive Director of Baltimore City Head Start Lisa Dooley, Head Start Accountant Completion Date: June 30, 2025
Finding 2024-016 U.S. Department of Health and Human Services AL No. 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat ...
Finding 2024-016 U.S. Department of Health and Human Services AL No. 93.391 Activities to Support State, Tribal, Local and Territorial (STLT) Health Department Response to Public Health or Healthcare Crises Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: BCHD has developed a subrecipient monitoring policy currently routed internally for approval that addresses the assessment, monitoring and documentation portions of subrecipient monitoring as well as other key elements to ensure adherence to 2CFR 200. The following tools have been created and implemented or in progress to use during monitoring: A. Subrecipient vs. Contractor Determination Checklist that must be completed by staff when submitting contract request to the contract unit. B. Comprehensive risk assessment tool to determine monitoring plan for subrecipient. C. Both programmatic and fiscal baseline monitoring tools. Programmatic tools are at the beginning stages of implementation and continue to be customized for specific grant award requirements when necessary. D. Updated expense tracker for the accountants to utilize for review of subrecipient invoices. E. Both monitoring and risk assessment tools were created to request and document single audit and SAMS.gov status. Contact Person: Nkenge Williams, Director of Audits, Baltimore City Health Department Completion Date: June 30, 2025
Finding 2024-014 U.S. Department of Housing and Urban Development AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Auditee’s Corrective Action Plan: Condition #1 Response MOHS...
Finding 2024-014 U.S. Department of Housing and Urban Development AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2023-011 Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 2 out of 2subrecipient files did not have evidence that subrecipient was monitored. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM, Unique Entity Identification #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports. Condition #2 Response MOHS acknowledges the finding that 2 out of 2 selections did not have information related to the funding source and pass through entity on the notice of award. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM, Unique Entity Identification #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports. Contact Person: Lakeysha Williams, Director of Programs, Mayor’s Office of Homeless Services Completion Date: April 7, 2025
Finding 2024-013 U.S. Department of Housing and Urban Development AL No. 14.241 Housing Opportunities for Persons with AIDS Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-010 Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowle...
Finding 2024-013 U.S. Department of Housing and Urban Development AL No. 14.241 Housing Opportunities for Persons with AIDS Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2023-010 Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges that evidence that the Federal Funding Accountability and Transparency Act (FFATA) report was prepared and submitted, was not provided. Corrective Action: MOHS will follow the City’s Grant Management office’s established process of establishing and maintaining a hardcopy audit file. This file will include: a. Federal System Registrations: SAM, DUNS #s, Grants.gov information; b. Federal Financial Accountability and Transparency (FFATA) information; c. FFR Submissions (SF-425 Federal Financial Report); d. Grant Agreements; and, e. Prior Year Single Audits/Monitoring Reports. Contact Person: Lakeysha Williams, Director of Programs, Mayor’s Office of Homeless Services Completion Date: April 7, 2025
Finding 2024-012 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: Yes; 2023-009 Auditee’s Corrective Action Plan: Condition #1 Response MOHS ...
Finding 2024-012 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: Yes; 2023-009 Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges that 1 of 60 files did not have evidence of the case manager’s review of the file for eligibility requirements. Corrective Action: The HAP Housing Contract Specialist will conduct an annual review of the client eligibility documentation to ensure that all eligibility documentation is maintained in the client’s file. Condition #2 Response MOHS acknowledges that 1 out of 60 selections did not contain the rent calculation worksheet. Corrective Action: MOHS collects client income at intake and annually to determine eligibility and the tenant’s rent portion. The rent calculation worksheet ensures that the tenant’s rent portion does not exceed 30% of the client’s income. This rent calculation worksheet and income verification is maintained in the client’s file. Condition #3 Response MOHS acknowledges the 1 out of 60 selections did not have evidence of property inspection. Corrective Action: MOHS requires that all housing units under the program be inspected prior to the client’s lease up and annually. We will ensure that units assisted under the program are inspected annually and the passed inspection is maintained in the client’s file. Condition #4 Response MOHS acknowledges that 1 out of 60 selections did not have the supporting third-party documentation of income. Corrective Action: MOHS policy requires that clients are required to submit third party verification of income, assets, and medical expenses at program entry and annual recertification to ensure proper calculation of tenant rent. Contact Person: Lakeysha Williams, Director of Programs, Mayor’s Office of Homeless Services Completion Date: April 7, 2025
Finding 2024-011 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-008 Auditee’s Corrective Action Plan: Condition #1 MOHS Fiscal kno...
Finding 2024-011 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: Yes; 2023-008 Auditee’s Corrective Action Plan: Condition #1 MOHS Fiscal knowledges the finding that 2 out of 10 selections had not evidence of approval of the drawdown request and management. Condition #2 MOHS fiscal acknowledges that 1 of 10 selections, there was no evidence that the drawdown request was submitted on the IDIS portal Corrective Action With the implementation of the “Fiscal and Compliance Manual”, MOHS Fiscal staff are now required to maintains copies of the Submitted expenditure reports to the Fiscal “G drive”. For draws, MOHS Fiscal Staff are now required to adopt a naming conversion for each grant, draw request, Confirmation of payment posting to the GL, save supporting documentation, including the proof of the IDIS voucher) to the Fiscal “G drive” and complete reconciliations. Contact Person: Diamond Okojie, Fiscal Director, Mayor’s Office of Homeless Services Completion Date: April 7, 2025
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually a...
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually and work between spreadsheets and multiple systems to input and track receipt grant awards and spend on personnel, supplies and services and sub-recipient awards related to grants. The steps to address this legacy finding have been phased and include the technology implementation, staff training and additional oversight. As noted, the City implemented Workday, an Enterprise Resource Planning (ERP) system, across workstreams so that Financial Accounting, Grants, Procurement, Supplier Accounts, Banking, Payroll and Human Resources are all in one system. As with any ERP, an ongoing process of evaluation and updates are needed to continuously align workflow and business processes. This approach has led to continued improvement over the years as the grants management module is fully implemented in Workday. Since implementation, additional enhancements have been adopted and utilized with a robust workflow process for grant approval, grant budget tracking, and invoice scheduling. In addition to the technology adoption, an increase in citywide grants training and oversight has been implemented. The progress is detailed below: • FY 23 represented the first year in the new system. To compile the SEFA, the City used a hybrid approach to leverage Workday and Agency provided data. o There were some data accuracy challenges from data entry errors. To address those data entry challenges the award modification business process was improved post-implementation to add a GMO review and approval step of award modifications. o As of May 2024, all award modifications now require centralized GMO review to verify data accuracy. o Additional process changes in FY 23 included implementation of the requirement as part of the FY 24 budget preparation process that grant worktags must be created and budgeted for during the City’s annual budget process. The grant worktag creation process includes approvals at the agency program and fiscal levels, as well as at the Department of Finance level. • In FY24 further Award Module enhancements were adopted to provide key new data points in Workday. o Each grant award now includes information: Federal Assistance Listing Number (fna CFDA#), Passthrough Agencies & Passthrough Identifier. o Additionally, in FY 24, GMO, in collaboration with BAPS launched the Grants Workstream Training sessions. These monthly citywide virtual live trainings are on a variety of grant management related topics, averaging 60 attendees per session. Attendees are city agency grant managers and city agency fiscal staff. • In FY 24 and FY 25 the topics covered included: o FY 24 Grant Work tag Preparation o FY 24 SEFA Preparation o Grant Accounting Best Practices and Workday Billing o Award Set-up Best Practice & Potential Pitfalls o Extra Features in Workday (including reporting and how to set up award tasks and deadlines) o Subrecipient Monitoring Best Practices o Cost-reimbursable grant invoicing in Workday o FY 25 SEFA preparation o FY 26 Grant Work tag Preparation o Grant Management Roles and Responsibilities o Specific training on the SEFA, including information on understanding the importance of the SEFA, what information is included and how to review SEFA data, was conducted. Citywide training sessions were held in FY 24 and FY 25 to ensure that the reporting is understood by city agencies, with special emphasis on subrecipient payments being reported properly. The training schedule is ongoing and continuous. • To improve SEFA reporting data, in FY 25 there is an emphasis on subrecipient set up and spending to ensure that functionality is refined to improve uniformity in subrecipient set up. GMO, in conjunction with BAPS, the Bureau of Procurement and city agencies will work to refine subrecipient set up, spending and monitoring, including improved reporting. o GMO has hosted three subrecipient monitoring and management–related trainings since December 2024. Additionally, to improve subrecipient managing and monitoring, GMO modified the award setup business process in Workday to include verification of subaward status before final award setup approval. In FY 25, GMO provided training on how to setup subawards accurately in Workday. As discussed above, these trainings will be ongoing. • Additionally, GMO and the BBMR will collaborate on a subaward dashboard to monitor subrecipient spending data in real time. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: FY26 3rd Quarter- • Design and complete a grants management dashboard within Workday • Ongoing and continuous - GMO will continue to conduct trainings on SEFA reporting and subrecipient management and reporting.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensur...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all current and new staff are trained on tenants’ 90-day EIV reports and ensuring they are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. ACTION TAKEN The Project will be monitoring use of the EIV system for move ins and recertifications.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuri...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all bank account balances at each bank remain below the FDIC limit. ACTION TAKEN The Project will be monitoring bank accounts more frequently throughout the year to ensure bank balances do not exceed the FDIC limit.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Section 202 Supportive Housing for the Elderly Program, Capital Advance - Accumulated Balance, CFDA 14.157. RECOMMENDATION The auditor recommends ensuring all bank account balances at each...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Section 202 Supportive Housing for the Elderly Program, Capital Advance - Accumulated Balance, CFDA 14.157. RECOMMENDATION The auditor recommends ensuring all bank account balances at each bank remain below the FDIC limit. ACTION TAKEN The Project is consistently monitoring bank accounts more frequently throughout the year to ensure bank balances do not exceed the FDIC limits.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Programs: Major Program: Section 202 Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all bank account bala...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2024-001: Major Programs: Major Program: Section 202 Supportive Housing for the Elderly, Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all bank account balances at each bank remain below the FDIC limit. ACTION TAKEN The Project is monitoring bank accounts more frequently throughout the year to ensure bank balances do not exceed the FDIC limits.
2024-004 Education Stabilization Fund – COVID 19 – Assistance Listing No. 84.425, Special Tests & Provisions – Davis-Bacon Act RECOMMENDATION: The School Board should take the necessary steps to ensure that staff are appropriately trained and contractor payrolls are monitored timely. Corrective Acti...
2024-004 Education Stabilization Fund – COVID 19 – Assistance Listing No. 84.425, Special Tests & Provisions – Davis-Bacon Act RECOMMENDATION: The School Board should take the necessary steps to ensure that staff are appropriately trained and contractor payrolls are monitored timely. Corrective Action Plan: The School System’s grant administration team will complete the necessary training related to Davis-Bacon to ensure that contractors are in compliance with the Davis Bacon Act. Anticipated Completion Date: June 30, 2025
Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second empl...
Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review. This was implemented in September of 2024. Contact person responsible for corrective action: Lucy Rosenberg and Michelle Estell Anticipated Completion Date: 09/01/2024
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