Corrective Action Plans

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Subrecipient Monitoring and Suspension & Debarment. Neighborhood & Community Services (NCS) has existing processes to ensure subrecipient monitoring requirements and suspension and debarment requirements. While not all JAG subrecipients had previously been included, beginning in 2025, all subrecipie...
Subrecipient Monitoring and Suspension & Debarment. Neighborhood & Community Services (NCS) has existing processes to ensure subrecipient monitoring requirements and suspension and debarment requirements. While not all JAG subrecipients had previously been included, beginning in 2025, all subrecipients of JAG funding are being included in NCS processes. Specifically, one position (Contract/Program Auditor) is assigned to each contract and is responsible for verifying and documenting suspension and debarment at award and at the annual renewal and also for ensuring monitoring is completed. Prior to the audit, NCS had begun scheduling with the subrecipient that had not been monitored, consistent with NCS processes. NCS is currently also developing a grant handbook to ensure that all staff are aware of general and specific grant requirements and processes for managing grants. Procurement. The City’s procurement policies and procedures outline the process for the competitive procurement of services using federal funds, in alignment with federal regulations. However, the City acknowledges that certain aspects of the current policies maybe unclear or inconsistence with existing procedures. Additionally, the City recognizes that its internal controls are not fully effective in ensuring that all departments consistently comply with these policies and procedures. To strengthen internal control, the City will revise its procedure and develop and implement training around federal grants for staff responsible for managing or overseeing these contracts.
To meet Federal Funding and Transparency Act (FFATA) reporting requirements, the City will take the following actions: Update training material for all accounting staff and City departments managing federal grants. Update and distribute monthly email to departments to clarify the required informatio...
To meet Federal Funding and Transparency Act (FFATA) reporting requirements, the City will take the following actions: Update training material for all accounting staff and City departments managing federal grants. Update and distribute monthly email to departments to clarify the required information for FFATA filing and require responses with supporting documentation for review. If responses are not received in a timely manner, a second email will be sent to those individuals, requiring an immediate action. Periodically review federal reporting requirements for any updates and adjust the reporting process as needed, utilizing resources such as the State Auditor’s Office (SAO) Newsletter, conferences, and trainings.
Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this pol...
Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this policy and procedure to ensure rental rates fall within federal grant compliance requirements at the time of each lease signing or renewal. Documentation of rent reasonableness certification will be performed by NWYS housing staff, reviewed by NWYS housing service leadership, and maintained in the client’s permanent file, as defined in the NWYS Rent Reasonableness Policy. Name(s) of Responsible Party:  NWYS Housing leadership staff – Luis Reyna, Addison Ausley, Daniel Pry Anticipated Completion Date:  9/5/25
View Audit 368841 Questioned Costs: $1
Finding 1156477 (2024-002)
Material Weakness 2024
Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underly...
Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underlying the attestations were erroneous. In addition, LifeWire was not able to secure an attestation from a former employee before they departed the organization. In 2025, LifeWire is revising their attestation procedure such that contract-supported staff members will attest to the nature of their work instead of amounts of time to contracts. This will simplify the administrative burden of attestations and reduce opportunities for errors while still meeting our audit and contract funders’ requirements. We anticipate this revised method will be rolled out by the end of Q3-2025. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: Procedure rollout will be completed by the end of Q3-2025. Anticipated full compliance with the requirement will be in evidence through the end of 2025 and beyond.
Finding 1156474 (2024-001)
Material Weakness 2024
Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental...
Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental payment request made with public funds. LifeWire’s AP approval process requires review and approval by members of the Director team before payments can be issued. In 2025, all rental payments made with CoC funds now have documented evidence of internal approval and review. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: The new process was rolled out in November 2024.
We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.
We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.
View Audit 368800 Questioned Costs: $1
Corrective Action Plan Finding Reference: Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting (FFATA) Date of finding: Financial Audit 2024 Responsible Parties: Amy Frizzi and David Mangene 1. Management's Response Management accepts the finding and agrees with the a...
Corrective Action Plan Finding Reference: Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting (FFATA) Date of finding: Financial Audit 2024 Responsible Parties: Amy Frizzi and David Mangene 1. Management's Response Management accepts the finding and agrees with the auditor's recommendations and further acknowledges that a subaward contract under which FFATA reporting was required was not submitted within the required 30 days after the subaward was executed. 2. Corrective Action FFATA Reporting: Wadhwani Institute for Artificial Intelligence Foundation (WIAI) is working to gain access to the SAM.gov reporting capabilities for the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) to ensure proper reporting for any and all required FFATA reporting is met for new federal subawards. Process Enhancement: WIAI will ensure comprehensive reporting processes for federal grants are in place prior to engaging as a prime or subrecipient, including tracking reporting and other significant deadlines. 2024 Finding Resolution: The specific grant referenced in this finding was terminated in January 2025. The awarding agency (USAID) has since been functionally dismantled by the Trump administration, with 83% of programs eliminated as of March 2025 and remaining functions transferred to the State Department. Given the agency's operational dissolution and the grant's termination, late FFATA reporting for the 2024 subaward is not feasible through normal channels. Management will monitor for any guidance from the State Department regarding reporting obligations for grants from the former USAID structure. 3. Timeline FSRS Access: Target completion by December 2025 (pending SAM.gov registration resolution) Process Documentation: Within 60 days of FSRS access being obtained Full Implementation: Upon receipt of next federal subaward requiring FFATA reporting Ongoing Monitoring: Monthly grant reviews and comprehensive year-end validation Prepared by: Ann Marie Ilibasic, Grants & Compliance Consultant Reviewed by: David Martin, Audit Committee Chair Next Review Date: Fiscal Year End 2025
Finding 1156463 (2024-001)
Material Weakness 2024
The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contra...
The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contract requests through established King County Procurement processes, and timelines to submit similar requests through central procurement with sufficient time to allow central procurement to perform all the necessary legal and compliance checks necessary for the associated transactions. After initial training, all existing key personnel will receive repeat training every 2 years; all new staff will receive training as part of onboarding procedures.
Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will streng...
Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will strengthen its internal controls around debarment checks for vendors in both its procurement and contracting processes to address the finding as follows: Procurement • PFC will use a process checklist for its procurements, similar to the checklist PFC developed for its coalition members. • The checklist will include an additional step for a debarment search on SAM.gov and require internal confirmation and documentation that this debarment check is valid. • This process checklist will be reviewed and signed off when complete by PFC management for each procurement. • PFC will include completed checklists to accompany each procurement memo. Contracting • PFC will continue including debarment language in each of its vendor contracts to ensure adherence to 2 CFR Section 180.300. • For vendors with contracts above $25,000, PFC will implement quality control by running a debarment search twice annually, once in June and once in December every year. This documentation will be saved to the vendor file.
Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hour...
Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hours incurred compared to the estimated amounts by individuals assigned to federal grant programs prior to requesting reimbursement from the funding course. The review will be performed by an individual other than the preparer of the reimbursement request, with knowledge of the federal grant program and will be formally documented.
Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member ...
Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member - the CSP Grant Manager - to oversee FFATA reporting and maintain a comprehensive log of all qualifying subawards. The CSP Grant Manager will provide training to finance and grants management staff on FFATA reporting requirements and timelines. Joyanna Smith, CPOO, will conduct monthly reviews of subaward activity to ensure all required reporting is completed by the end of the month following the obligation date. FFATA reporting will be incorporated into INCS’s quarterly internal compliance monitoring process to sustain ongoing compliance.
Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on...
Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on the Finding: The Corporation concurs with the recommendation and will make the deposit to fully fund the reserve for replacements fund.
View Audit 368702 Questioned Costs: $1
Finding 1156380 (2024-005)
Material Weakness 2024
The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Can...
The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Candid and Charity Navigator. Financial statements were also reviewed, but documentation of these reviews and verifications was not consistently retained, and certain federal requirements were not fully incorporated into the process. 9/11 Day has now adopted a written policy that ensures that, in its role as a pass-through entity, all subgrants will be made in full compliance with the minimum required elements found under 2 CFR 200.332(b). This shall include implementing a comprehensive tracking and monitoring system for all subgrantees, regardless of funding level, with enhanced verification requirements for those receiving over $30,000. All subaward agreements will be updated to include the minimum required elements under 2 CFR 200.332(b), and the evaluation of subgrantee risk will incorporate all suggested elements under 2 CFR 200.332(c), including consideration of fraud risk and risk of noncompliance. The system will record the time and date of all eligibility verifications and retain supporting documentation, including MOUs, SAM.gov confirmation of suspension and debarment status, IRS Form 990s, financial statements, and audit confirmations. In compliance with 2 CFR 200.332(e)(1), subgrantees will now be required to submit both performance and financial reports, which will be reviewed and compared against project budgets. In addition, 9/11 Day will evaluate subgrantees’ Single Audits, if filed, in accordance with 2 CFR 200.332(e)(2)–(4) and will review any reported deficiencies. All monitoring activities will be documented and logged throughout the life of each project to ensure stronger oversight, complete documentation, and compliance with federal requirements.
Finding 1156379 (2024-004)
Material Weakness 2024
In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a ...
In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a centralized tracking log, and for those receiving pass-through funds exceeding $30,000, the required reporting will be completed directly in SAM.gov, which now includes the Federal Subaward Reporting System (FSRS). Each subgrantee’s eligibility will be verified in SAM.gov, with the date and results of the verification recorded, and all supporting documentation retained on file. This corrective action ensures that all subawards are properly logged, reported, and compliant with FFATA requirements.
View Audit 368692 Questioned Costs: $1
Human Services Department (HSD) HSD acknowledges this finding. While the Department successfully tracked, collected, reviewed, and issued management decision letters to its subrecipients as a standard practice. In this instance a formal management decision was missed for this specific sub-recipient ...
Human Services Department (HSD) HSD acknowledges this finding. While the Department successfully tracked, collected, reviewed, and issued management decision letters to its subrecipients as a standard practice. In this instance a formal management decision was missed for this specific sub-recipient during the review period. The Department has taken corrective measures to strengthen its compliance process, clarify roles and responsibilities to ensure timely completion of this requirement. Office of Economic Development (OED) OED acknowledges this finding. OED intends to take corrective measures through strengthening internal controls over subrecipient single audit monitoring: • Including a step in our internal monitoring processes to document when Program Managers pull and review single audits with federally funded partners • Retaining a monitoring workbook to track and date collection of single audit reports Office of Housing (OH) • OH acknowledges that neither a review of applicable audits nor management decision was sent to subrecipients who had audit findings. OH staff will evaluate its current policies to determine the best way to identify, review and follow-up on any subrecipient audits that may include findings. This review will include appropriate written follow up on actions OH recommends the subrecipient to take to correct the finding(s).
The Human Services Department (HSD) acknowledges this finding regarding the late submission of five FFATA reports and inaccuracies in CAPER reporting. These issues arose during a period of prolonged vacancies and while staff were in the process of being trained on reporting requirements, which reduc...
The Human Services Department (HSD) acknowledges this finding regarding the late submission of five FFATA reports and inaccuracies in CAPER reporting. These issues arose during a period of prolonged vacancies and while staff were in the process of being trained on reporting requirements, which reduced oversight capacity and contributed to delays and errors. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. HSD updated department-wide FFATA Reporting Policies and Procedures following the federal transition to SAM.gov. Staff completed federal training, and prior reports were reviewed and corrected. The Department implemented controls to close workflow gaps to ensure obligations and data corrections are captured before submission. Additionally, ongoing training is being provided to reinforce compliance. These actions strengthen internal controls and are intended to ensure FFATA and CAPER reports are accurate, complete, and submitted in a timely manner moving forward.
The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of co...
The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of contracting with a third-party vendor to complete its annual inspections, including HOME inspections for 2025. The contractor will inspect HUD’s NSPIRE level. With this additional support, OH anticipates it will have the capacity to see that corrections have been completed and documented consistent with the HOME program requirements.
The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) M...
The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. The contract specialist receives structured management oversight and ongoing training to strengthen capacity for accurate budget monitoring. In July 2025, the FGMU updated its ESG policies and procedures to incorporate improved controls for earmarking. In addition, the Department has instituted regular training sessions for all staff responsible for federal grant management to reinforce compliance with earmarking and other federal requirements. These corrective actions are designed to strengthen internal controls, provide clearer oversight, and ensure that future expenditures remain within established budget and earmarking limits.
MCR has established a procedure to require a completed application with signature and supporting documentation in order to qualify for a sliding fee scale. Any incomplete applications or those with incomes greater than 200% of the poverty level will only result in consideration for courtesy discount...
MCR has established a procedure to require a completed application with signature and supporting documentation in order to qualify for a sliding fee scale. Any incomplete applications or those with incomes greater than 200% of the poverty level will only result in consideration for courtesy discount. Financial counselors have 7 business days from the return of a patient application to determine completeness and eligibity for sliding fee scale. The Chief Financial Officer, Kara Onorato, will be responsible for ensuring that this process is followed. This revised process will be put in place on October 1, 2025.
View Audit 368617 Questioned Costs: $1
Finding 2024-004 Significant Deficiency in Controls over Compliance and Noncompliance - Reporting Federal Program: 93.137 Community Programs to Improve Minority Health Year: 2024 Federal Agency: Department of Health and Human Services Condition - A total of $910,157 of costs was passed through to se...
Finding 2024-004 Significant Deficiency in Controls over Compliance and Noncompliance - Reporting Federal Program: 93.137 Community Programs to Improve Minority Health Year: 2024 Federal Agency: Department of Health and Human Services Condition - A total of $910,157 of costs was passed through to selected sub recipients during the year and the subawards were not reported in the FSRS. Corrective Action Plan – Henry Ford Health agrees with this finding and has created a workgroup to ensure that current information on FSRS is accurate and to also to clarify responsibility for ongoing reporting and review of subrecipient disclosure requirements to ensure timeliness and accuracy. Anticipated Completion Date – December 31, 2025. Contact Person – J. Douglas Clark, Senior Vice President and Chief Accounting Officer.
The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ...
The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ensure all employees' salary schedules are updated when we process the system-wide update. We will have an additional person to review and sign the new salary schedules before the first payroll is processed in the new fiscal year.
The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ...
The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ensure all employees' salary schedules are updated when we process the system-wide update. We will have an additional person to review and sign the new salary schedules before the first payroll is processed in the new fiscal year.
Finding 2024-003 – Subrecipient Cash ManagementAssistance Listing No.: MultipleThe Office of Sponsored Programs ( OSP) will address the recommendation and review its current processes, policies, and procedures to minimize the time between invoice receipt and the transfer of federal funds to the subr...
Finding 2024-003 – Subrecipient Cash ManagementAssistance Listing No.: MultipleThe Office of Sponsored Programs ( OSP) will address the recommendation and review its current processes, policies, and procedures to minimize the time between invoice receipt and the transfer of federal funds to the subrecipient. This includes implementation of the following preventative controls to ensure that payments are made within the required timeline: a. Active communications with Principal Investigators of subawards on invoice approval timeline at award initiation and creation of procedures for documenting and advising OSP of invoices requiring correction and /or modification. b. Work with Post Award Staff to ensure that adequate documentation is created and maintained related to the follow-up that occurs when issues are being investigated and resolved that cause a delay in invoice processing.c. Development and utilization of a report for internal reporting and tracking of pending sub-invoices payments approaching the 30-day deadline. d. Implementation of the Invoice Receipt Date as a required field for subaward invoicing in Workday rather than the optional field it is at present. Responsible Official: Cate Ekstrom, Director of Research
Finding 2024-002 – Subrecipient MonitoringAssistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)Management will implement the established Research procedures for subrecipient risk assessments in accordance with Uniform Guidance Section 200.332(b)....
Finding 2024-002 – Subrecipient MonitoringAssistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)Management will implement the established Research procedures for subrecipient risk assessments in accordance with Uniform Guidance Section 200.332(b). Update the Research subrecipient monitoring checklist and use the subrecipient forms. This approach will be applied to all new subrecipient relationships starting in 2025 and beyond. Additionally, management will collaborate with Endeavor Health's legal, finance, and compliance teams to assess current processes and make any necessary corrections to improve the review and documentation of results going forward.Responsible Officials: Ashlee Jean Roffe, Director of Nutrition and Community Health, Community CARE
1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accura...
1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accuracy prior to submission. 3. Assigned dedicated staff oversight for federal financial reporting, with cross-training implemented to strengthen continuity and mitigate risk in the event of staff turnover. 4. Conducted periodic evaluations of the reporting process, incorporating feedback and lessons learned from prior submissions, monitoring visits, and audit findings to drive ongoing improvements. 5. Reviewed and updated internal financial policies and procedures to align with current federal reporting requirements and best practices, with updates formally documented and disseminated to staff.
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