Corrective Action Plans

Finding 540423 (2024-002)

Material Weakness 2024

County of Fresno

CA

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies a...

Finding 2024-002 – HOME Loans Affordable Period Monitoring Management’s Response or Department’s Response Management concurs with the finding. Views of Responsible Officials and Corrective Action The Department will provide training to staff on HOME monitoring requirements, updating policies and procedures, as necessary, to address all current regulatory requirements. The Department’s multifamily monitoring for all projects in the HOME period of affordability will be completed prior to June 30, 2025. As part of the monitoring process, the Department will document all records requiring annual or semi-annual oversight and review for compliance with HOME requirements. Should the monitoring result in any findings requiring corrective action, the Department will ensure all findings are addressed by September 30, 2025. Anticipated Completion Date May 2025 Contact Information of Responsible Official Name: Augustine Ramirez Title: Division Manager, DPWP Community Development Division Phone: 559-600-4266

View Audit 350241

Finding 540415 (2024-005)

Significant Deficiency 2024

County of Maui

HI

Subrecipient Monitoring § 200.332

Ref. No. Federal Award Findings 2024-005 Subrecipient Monitoring - Significant Deficiency Recommendation We recommend thee County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 View of Responsible Offici...

Ref. No. Federal Award Findings 2024-005 Subrecipient Monitoring - Significant Deficiency Recommendation We recommend thee County follow its policies and procedures for its subrecipients to ensure proper monitoring activities are performed as required by 2 CFR §200.332 View of Responsible Officials and Planned Corrective Action Management concurs with this finding. As mentioned in Corrective Action 2024-001, due to the increase in federal grants, multiple departments are responsible for the oversight of these grants. The Department of Finance continues to face staffing challenges and did not have adequate personnel and resources for the continuous monitoring of these funds. A Countywide Grant Compliance Specialist position is in the process of being created by the Department of Personnel Services. This position will be primarily responsible for the monitoring of grants in according with the Uniform Guidance. End Date: Ongoing Responding Person(s): Marci Sato Accounting System Administrator Department of Finance Phone No. 808-270-7503

View Audit 350238

Finding 540343 (2024-001)

Significant Deficiency 2024

City of San Diego

CA

Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact t...

Reference Number: 2024-001 Audit Finding: Federal Funding Accountability and Transparency Act – Significant Deficiency Corrective Action: Management believes that the intent of transparency was met with the data staff entered into IDIS and made available on the city’s website and SAM.gov. The fact that the FSRS.gov system has since been retired and integrated into the SAM.gov system acknowledges the need for reducing duplicate recording in favor of an integrated system. Staff’s understanding of the process was in line with available guidance currently still posted on HUD’s website (https://www.hud.gov/sites/dfiles/CPD/documents/CPD_FSRS_Learning_Session_Final_8.26.21.pdf). The City of San Diego did not receive notification of the FSRS deadline from HUD for Fiscal Year (FY) 2024. With regard to the dates entered in the FSRS.gov system, the agreements’ effective dates cover the entire fiscal year, and the awards were approved by our City Council to be in effect for the full fiscal year. Hence, staff entered the date July 1, 2023. Management accepts that going forward, dates should be entered based on the date the agreements are fully executed. Management agrees to include specific FFATA training and procedures in all CDBG manuals and checklists including procedures for compliance, if and when federal agency communication is late or lacking. Implementation Date: The conditions described above have already been corrected. FFATA training and procedures will be implemented within 30 days. Contact: Michele Marano Assistant Deputy Director, Community Development Economic Development Department City of San Diego Email: mmarano@sandiego.gov Phone: 619.236.6381

View Audit 350217

Finding 540342 (2024-004)

Significant Deficiency 2024

Yolo County Transportation District

CA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.318 § 200.326 § 200.327

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant d...

2024-004 Views of Responsible Officials and Planned Corrective Actions: Management agrees with the recommendation and has implemented measures to improve procurement recordkeeping and compliance. A structured procurement folders and subfolders system has been established to maintain all relevant documentation. Management is actively working with consultants to update policies and procedures. Staff is scheduled to complete a structured three-session training through GFOA to enhance their understanding of federal procurement regulations and best practices. The District will continue training and development efforts in public procurement, with a particular focus on federal compliance, strengthening internal controls, improving documentation, and ensuring adherence to regulatory requirements Responsible Party: Director of Finance & Administration and Department Managers Implementation Date: Ongoing; full implementation expected by June 30, 2025

View Audit 350214

Finding 539677 (2024-006)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver ...

Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (ASU) Responsible Official: Charlette Mock, Director of Accounting Corrective Action Planned: ASU uses a servicer to deliver credit balance to students. The contract with the servicer should have been uploaded to the Dept of Ed database. Since the audit finding, the contract has been uploaded. ASU will upload the contract timely going forward. Estimated Completion Date: Effective Immediately Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (MVSU) Responsible Official: Mrs. Brittney Manuel-Carpenter, Account Receivable Supervisor Corrective Action Planned: MVSU acknowledged the findings of reference 2024-06 SFA-Special Test- Using a Servicer to Deliver Title IV Credit Balances. MVSU acknowledges that the servicer contract is uploaded to the Department of Education database and is available for viewing. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-006: SFA Special Tests and Provisions - Using a Servicer or Financial Institution to Deliver Title IV Credit Balances to a Card or Other Access Device (USM) Responsible Official: David Williamson, Director of Financial Aid Corrective Action Planned: University will contact the Department of Education Cash Management to correct the URL link. While the link was broken on the Cash Management site it was active on the USM Business Services website: https://www.usm.edu/business-services/refunds.php and is continually maintained on their site. Estimated Completion Date: April 1, 2025

View Audit 350191

Finding 539676 (2024-004)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Special Tests & Provisions Matching / Level of Effort / Earmarking

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that...

Finding Reference: 2024-004 - SFA Special Tests and Provisions - GLBA (MVSU) Responsible Official: Dameon A. Shaw, Vice President for Information Technology Corrective Actions Planned: 1. Develop a Comprehensive Information Security Program to ensure MVSU has a full information security program that addresses all 7 required elements of the GLBA regulations: • Review GLBA Requirements: Conduct a thorough review of the Gramm-Leach-Bliley Act (GLBA) regulations to understand the 7 required elements. - Completed • Gap Analysis: A gap analysis has been performed to identify missing elements in the current information security program. - Completed • Program Development: Develop and implement policies and procedures to address the identified gaps. This includes administrative, technical, and physical safeguards. - In Progress • Training: Provide training to staff on the new policies and procedures to ensure compliance and proper implementation. - Planning • vCISO Support: Leverage the expertise of the newly hired virtual Chief Information Security Officer (vCISO) to guide the development and implementation of the information security program. - In Progress 2. Conduct a Comprehensive Risk Assessment to identify and address significant gaps in the risk assessment process: • Risk Assessment Framework: Establish a risk assessment framework that aligns with GLBA requirements. - In Progress • Identify Risks: Identify potential risks to the confidentiality, integrity, and availability of customer information. – In Progress • Evaluate Controls: Assess the effectiveness of existing controls and identify areas for improvement. – In Progress • Mitigation Plan: Develop a risk mitigation plan to address identified vulnerabilities and implement appropriate controls. - Planning • vCISO Support: Utilize the vCISO's expertise to ensure a thorough and effective risk assessment process. – In Progress 3. Monitoring and Continuous Improvement to ensure ongoing compliance and continuous improvement of the information security program: • Regular Audits: Conduct regular audits to ensure compliance with GLBA regulations and the effectiveness of the information security program. – Planning • Feedback Mechanism: Establish a feedback mechanism to gather input from staff and stakeholders on the effectiveness of the program. - Planning • Update Policies: Periodically review and update policies and procedures to address emerging threats and changes in regulations. – In Progress • vCISO Support: Engage the vCISO in monitoring and continuous improvement efforts to maintain high standards of information security. – In Progress 4. Reporting and Accountability to ensure accountability and transparency in the implementation of the corrective action plan: • Assign Responsibility: Assign responsibility for the implementation of the corrective action plan to a dedicated team or individual. - Planning • Progress Reports: Provide regular progress reports to senior management and stakeholders on the implementation of the corrective action plan. - Planning • Documentation: Maintain thorough documentation of all actions taken to address the identified issues. - Planning • vCISO Support: Include the vCISO in reporting and accountability processes to ensure expert oversight and guidance. – In Progress By following this corrective action plan and leveraging the expertise of the vCISO, MVSU can address the deficiencies in its information security program and risk assessment process, ensuring compliance with GLBA regulations and protecting customer information effectively. Estimated Completion Date: November 30, 2025

View Audit 350191

Finding 539669 (2024-009)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Subrecipient Monitoring § 200.332 § 200.501

Finding Reference: 2024-009 - Subrecipient Monitoring (UM) Responsible Official: Dr. John Higginbotham, Vice Chancellor of Research and Economic Development Corrective Action Planned: On March 13, 2025, the University of Mississippi issued amendments to notify the two subrecipients that the subawar...

Finding Reference: 2024-009 - Subrecipient Monitoring (UM) Responsible Official: Dr. John Higginbotham, Vice Chancellor of Research and Economic Development Corrective Action Planned: On March 13, 2025, the University of Mississippi issued amendments to notify the two subrecipients that the subawards issued under ALN 95.010 during the fiscal year ended June 30, 2024, were not classified as research and development. The University of Mississippi will ensure that subaward agreements, including all attachments, are reviewed for accuracy by a second party before issuance. Estimated Completion Date: March 13, 2025 Finding Reference: 2024-009 - Subrecipient Monitoring (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: Similar to UMMC’s response on Finding Reference 2024-001, UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. The firm also provided Workday training sessions to help us understand how the different fields are supposed to be utilized, especially in cases where UMMC is either a subrecipient or has a subaward with a different institution. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539652 (2024-001)

Significant Deficiency 2024

State of Mississippi Institutions of Higher Learning

MS

Subrecipient Monitoring Reporting Student Financial Aid § 200.502

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department...

Finding Reference: 2024-001 - SEFA Reporting (ASU) Responsible Official: Sabrena Johnson, Director of Grants and Contracts Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $298,151 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, Alcorn State University has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: May 31, 2025 Finding Reference: 2024-001 - SEFA Reporting (DSU) Responsible Official: Jacnita Robinson, Grant Accountant Corrective Action Planned: Delta State University acknowledges the audit finding related to errors in the Schedule of Expenditures of Federal Awards (SEFA) reporting. The federal award in question was not intentionally omitted from the SEFA. At the time of SEFA preparation, Delta State University believed the award would be reported on the Mississippi Department of Finance and Administration’s SEFA, as they were identified as the recipient of the award. The University’s intention was to prevent the duplication of expenditures and avoid double-booking the same federal funds on both SEFAs. To prevent this type of error in the future, Delta State University will review and revise its internal controls and procedures for identifying and classifying federal awards. Additional training will be provided to the staff responsible for award set-up and SEFA reporting to ensure proper classification and communication with state agencies regarding the reporting responsibilities for pass-through and beneficiary awards. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (JSU) Responsible Official: Dr. Almesha Campbell, Vice President for Research and Economic Development Corrective Action Planned: Jackson State University will follow the procedures outlined for preparing the Schedule of Expenditures of Federal Awards. Such procedures include, but are not limited to the following: • Verify the ALN provided on the award documents and cover page and then enter it in Banner during the award set-up process. In addition, review the ALNs for continuation awards. If errors are identified during this process, they will be corrected. • Review previous year’s SEFA report and data support to ensure the report is in the format requested by IHL • Correspond with the Division of Business and Finance to include additional expenditures. Currently, the expenditures to include are 1) Direct Loans, 2) Expenditures with ALN 21.027, and 3) Perkins Loans Expenditures • The Director for Fiscal Reporting and Compliance will complete a subsequent review after the Director for Grants and Contracts prepares the report for submission. Furthermore, the newly created Oversight Committee will review the SEFA before submission to ensure that the Federal Perkins Loan program expenditures are included on the SEFA. Estimated Completion Date: June 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (MUW) Responsible Official: Rachel Sudduth, Assistant Director of University Accounting Corrective Action Planned: University Accounting will review and revise its current reporting procedures and review requirements to ensure that federal expenditures are properly identified and classified, this would also include federal expenditures made through Mississippi Bureau of Buildings. Estimated Completion Date: March 21, 2025 Finding Reference: 2024-001 - SEFA Reporting (MVSU) Responsible Official: Mr. Samuel Melton, Director of Sponsored Programs/Title III Corrective Action Planned: Mississippi Valley State University will ensure that federal awards are correctly coded when preparing the Schedule of Expenditures of Federal Awards using the following procedures: • The Office of Business and Finance and Office of Sponsored Programs will verify the ALN provided on the award documents provided by the sponsor (i.e., federal agency and/or pass-through entity). If errors are identified during this process, they will be corrected. • The Director of Accounting will complete a subsequent review after the designated Staff Accountant prepares the report for submission. Estimated Completion Date: September 30, 2025 Finding Reference: 2024-001 - SEFA Reporting (UM) Responsible Official: Dr. Steven G. Holley, Vice Chancellor for Administration and Finance Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024, was revised to include $131,454 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN 21.027. Additionally, the University of Mississippi has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 30, 2024 Finding Reference: 2024-001 - SEFA Reporting (USM) Responsible Official: Andrea Phillips, Controller Corrective Action Planned: The Schedule of Expenditures of Federal Awards (SEFA) for the year ended June 30, 2024 was revised to include $597,135 from the Mississippi Department of Finance and Administration - Bureau of Buildings under ALN# 21.027. Additionally, USM has updated its SEFA preparation procedures to ensure accurate reporting of federal funds expended on its behalf by third parties, including this bureau. Estimated Completion Date: October 23, 2024 Finding Reference: 2024-001 - SEFA Reporting (UMMC) Responsible Official: Mustafa Khawaja, Interim Director of Post-Award Corrective Action Planned: UMMC engaged with a Workday certified consulting firm to review the operational effectiveness of the configuration of Workday, review reports available, and assess processes and procedures. As part of the engagement, this firm also evaluated various operational processes within the contract and grants office. The engagement began in June of 2024 and has made significant changes to Workday to bring operational efficiency into our processes and configurations; as well as, developed reports that identify variances and differences that need to be researched and corrected. The team also corrected reports that were pulling data inaccurately and trained internal UMMC IT staff on how to address system corrections going forward and the methodology to develop/modify IT reports. The firm also revamped our award setup process in Workday and built checklists along with Standard Operating Procedures that bring efficiencies and accuracy into our Award setup process. We also built in roles for review of an award at the time of setup to ensure that errors are quickly identified and corrected in the system. Estimated Completion Date: June 30, 2025

View Audit 350191

Finding 539649 (2024-004)

Significant Deficiency 2024

Municipality of Florida

PR

Subrecipient Monitoring Reporting

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

Finding 539647 (2024-003)

Significant Deficiency 2024

Municipality of Florida

PR

Subrecipient Monitoring Reporting § 200.328

The Municipality will establish additional procedures to maintain the schedule of the required reports in order to avoid this situation.

View Audit 350185

Finding 539640 (2024-005)

Significant Deficiency 2024

Nbcc

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to d...

xiii. Management Response and Corrective Action Plan: One of the individuals tested was identified as not being enrolled in the audited grant during the audit period. This is correct. The individual was exited from the program in the previous audit period and written documentation was uploaded to demonstrate this. However, the case manager neglected to exit the individual from HMIS during the previous audit period. This has been corrected. No services or funds were provided to this individual following their exit from the program. Our program has a good track record of data compliance and we expect this was an exception and not the rule. Program management will review and train staff again on data compliance during a weekly staff meeting, and will also counsel the involved staff member on the error to ensure there is no similar future error. xiv. Contact Person (s) Responsible for Corrective Action: Cassie Roach, Safe Parking Program Director, croach@sbnbcc.org Joel Goforth, Homeless Services Director, jgoforth@sbnbcc.org xv. Anticipated Completion Date: The anticipated completion date is April 30, 2025.

View Audit 350179

Finding 539638 (2024-003)

Significant Deficiency 2024

Nbcc

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of ...

vii. Management Response and Corrective Action Plan: The travel in question involved staff travel to the annual National Alliance to End Homelessness (NAEH) conference. As evidenced by correspondence with HUD AAQ, it has long been established that attending an NAEH conference is an eligible use of CoC and ESG grant funds. We perceived the historical general approval to be in alignment with the contract requirement of obtaining written approval for the reimbursement of costs incurred for travel outside the county. All costs submitted for reimbursement were eligible and reasonable expenses. We now understand this historical approval by HUD was not transferrable to this grant and therefore, moving forward, we will secure email approval of travel eligibility for specific grant reimbursement prior to travel. To that end, we have already been in contact with Housing and Community Development (HCD) fiscal staff at Santa Barbara County about a reliable method to secure said approvals in advance moving forward. If travel is not approved for a specific grant, or not obtained prior to travel, other unrestricted income will be utilized for that portion of the travel expenses. viii. Contact Person (s) Responsible for Corrective Action: Kristine Schwarz, Executive Director, kschwarz@sbnbcc.org Victoria Garfield, Grants Administrator, vgarfield@sbnbcc.org ix. Anticipated Completion Date: Staff anticipate attending the annual NAEH conference this year, therefore we will request approval once registration is confirmed and expect to receive approval or rejection from County CD staff by no later than the date of travel, or approximately July 15, 2025.

View Audit 350179 Questioned Costs: $1

Finding 539635 (2024-001)

Significant Deficiency 2024

City of Concord

CA

Subrecipient Monitoring Reporting

Finding Reference Number: SA2024-001 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV ...

Finding Reference Number: SA2024-001 - Federal Funding Accountability and Transparency Act (FFATA) Reporting Assistance Listing Number: 14.218 Assistance Listing Title: Community Development Block Grant – Entitlement Grant COVID-19 - Community Development Block Grants/ Entitlement Grants-CV Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-23-MC-06-0009 COVID-19 – B-20-MW-06-0009 • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Suzanne McDonald, Finance Operations Manager and Brenda Kain, Interim Community Services Manager • Corrective Action Plan: Management concurs with this recommendation. As of October 2024, the city has new staff managing the CDBG program. This staff will be trained on the FFATA reporting requirements and on how to meet those reporting requirements using the new SAM.gov/fsfr reporting platform. • Anticipated Completion Date: Calendar Year 2025

View Audit 350178

Finding 539632 (2024-002)

None 2024

Argus Manor Association

WA

HUD Housing Programs Subrecipient Monitoring Reporting

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in...

S3800-010: Finding Reference Number 2024-002 S3800-030: Statement of Condition: Our audit procedures revealed that the security deposit cash account was underfunded for nine (9) out of the twelve (12) months tested. Specifically, the required balance for security deposits was not fully met in these months, resulting in a deficiency in the account. Although the funding deficit amounts were not always significant, it is important that the security deposit cash account be fully funded at all times. S3800-080: Auditor Recommendation: We recommend that property management implement a more robust process for monitoring and reconciling the security deposit cash account on a monthly basis. This process should ensure that the account balance is consistently maintained at the required level. Furthermore, management should conduct periodic reviews of the security deposit balances to identify and address any discrepancies promptly. Training for staff involved in managing security deposits should be considered to ensure compliance with HUD regulations and internal policies. FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT (Continued) S3800-010: Finding Reference Number 2024-002 (Continued) S3800-045: Actions Taken or to be Taken: It is management’s policy to fully fund the security deposit account so the balance in cash meets or exceeds the total liability of deposits collected from tenants. Management discussed the importance of reviewing funding monthly with the Project Accountant, and new procedures have been implemented to include a monthly process to compare the security deposit liability to the bank account and fund any shortages to ensure the security deposit bank account is consistently maintained at the required level.

View Audit 350177

Finding 539631 (2024-001)

Material Weakness 2024

Argus Manor Association

WA

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

S3800-010: Finding Reference Number 2024-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an indep...

S3800-010: Finding Reference Number 2024-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an independent contractor prior to finalization of new tenant move-in. However, during our testing, we noted five (5) move-in files out of five (5) move-in files tested where tenants were approved for move-in prior to review and approval by the independent contractor, circumventing the control. S3800-080: Auditor Recommendation: We recommend that the client immediately implement corrective actions to ensure compliance with internal control procedures. Specifically: 1. The compliance specialist should be required to wait for proper approval of tenant eligibility files before processing them. 2. Review and reinforce the approval process through additional training for staff to ensure they understand the critical importance of obtaining necessary approvals before proceeding. 3. Implement stronger oversight and monitoring mechanisms to ensure that files are not processed before approval. S3800-045: Actions Taken or to be Taken: Management has reviewed the policies and procedures with the property manager, who also serves as the compliance specialist. The property manager was instructed that no tenants are to be granted occupancy until the file has been approved by the independent contractor conducting the compliance review.

View Audit 350177

Finding 539630 (2024-003)

Material Weakness 2024

County of San Joaquin

CA

Subrecipient Monitoring § 200.332 § 200.502

The County acknowledges the importance of proper documentation for subrecipient monitoring. To address this finding, the County will implement the following: 1. Enhanced Review Process – County departments responsible for subrecipient agreements will conduct a thorough review of subrecipient monito...

The County acknowledges the importance of proper documentation for subrecipient monitoring. To address this finding, the County will implement the following: 1. Enhanced Review Process – County departments responsible for subrecipient agreements will conduct a thorough review of subrecipient monitoring activities to ensure compliance with federal and regulations. This will include verifying that all required monitoring steps, including risk assessments and are properly conducted and documented. 2. Documentation and Record-Keeping Improvements – County departments will be required to maintain clear and consistent documentation of all subrecipient monitoring activities. This includes risk assessments, financial reports, site visit records (if applicable), and any corrective actions taken.

View Audit 350172

Finding 539622 (2024-001)

None 2024

City of Seaside

CA

Subrecipient Monitoring

The City concurs with the finding. City staff will ensure CDBG Policies and Procedures are updated to outline process and responsibilities about the new sub-award reporting requirements in SAM.GOV instead of FSRS.gov, which has retired as of March 8, 2025. The City’s SAM.GOV administrator assigned C...

The City concurs with the finding. City staff will ensure CDBG Policies and Procedures are updated to outline process and responsibilities about the new sub-award reporting requirements in SAM.GOV instead of FSRS.gov, which has retired as of March 8, 2025. The City’s SAM.GOV administrator assigned CDBG Staff new roles in SAM.GOV so new contracts and awards can be reported, per FFATA requirements.

View Audit 350160

Finding 539564 (2024-001)

Significant Deficiency 2024

Jewish Community Center of Staten Island, Inc.

NY

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

2024-001 Special Tests and Provisions Name of Contact Person: Adam Miller, Chief Financial Officer Corrective Action: The JCC was unable to meet certain performance-based provisions of the contract, such as number of participants and break out of those participants by age category. The JCC acknowled...

2024-001 Special Tests and Provisions Name of Contact Person: Adam Miller, Chief Financial Officer Corrective Action: The JCC was unable to meet certain performance-based provisions of the contract, such as number of participants and break out of those participants by age category. The JCC acknowledges and agrees with the finding, and is in the process of developing procedures to ensure compliance with the grant/contract provisions and will start implementing this recommendation during the year ended June 30, 2025. The procedures: • The JCC will designate the responsibility of contract compliance to a specific individual at the JCC. • The JCC will ensure strict compliance with the IS49 Beacon program’s grant/contract provisions.

View Audit 350115

Finding 539551 (2024-005)

Significant Deficiency 2024

City of Alexandria

VA

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties § 200.213 § 200.303 § 200.318

DCHS has reviewed its procedures and will ensure that awards are reported timely and accurately to FSRS and that documenation of compliance will be available for review.

View Audit 350101

Finding 539550 (2024-004)

Material Weakness 2024

City of Alexandria

VA

Subrecipient Monitoring Material Weakness Reporting § 200.303

DCHS has reviewed its procedures and will ensure that suspension and debarement status is documented prior to contracting with a vendor.

View Audit 350101

Finding 539549 (2024-003)

Material Weakness 2024

City of Alexandria

VA

Subrecipient Monitoring § 200.303 § 200.332

DCHS has reviewed its procedures and will ensure that subrecipient monitoring activities are documented for compliance review.

View Audit 350101

Finding 539539 (2024-002)

Significant Deficiency 2024

City of Cupertino

CA

Subrecipient Monitoring Special Tests & Provisions Internal Control / Segregation of Duties

The City acknowledges the finding regarding the untimely completion of Quality Assurance Program (QAP) checklists (Appendices K, E, and L) for federally funded projects. Although the required Quality Assurance Tests were performed, documentation of the checklists was not completed in real time. To c...

The City acknowledges the finding regarding the untimely completion of Quality Assurance Program (QAP) checklists (Appendices K, E, and L) for federally funded projects. Although the required Quality Assurance Tests were performed, documentation of the checklists was not completed in real time. To correct this, the City has reinforced internal procedures to ensure that these checklists are completed and signed at the appropriate project milestones. Staff have been retrained on QAP requirements, and a tracking system has been implemented to ensure timely completion of all necessary documentation. Responsible Person: Susan Michael, Capital Improvement Programs Manager Expected Implementation Date: March 2025

View Audit 350078

Finding 539538 (2024-001)

Significant Deficiency 2024

City of Cupertino

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

The City acknowledges the finding related to the lack of documentation for verifying vendors against the System for Award Management (SAM) for federally funded purchases. While the City performed the necessary verification steps, documentation was not consistently maintained. To address this, the Ci...

The City acknowledges the finding related to the lack of documentation for verifying vendors against the System for Award Management (SAM) for federally funded purchases. While the City performed the necessary verification steps, documentation was not consistently maintained. To address this, the City has formalized a process requiring departments to perform and document SAM checks for all applicable vendors. New staff involved in procurement have been trained on these procedures, and verification is now included as a required step in the procurement process. Responsible Person: Susan Michael, Capital Improvement Programs Manager Expected Implementation Date: March 2025

View Audit 350078

Finding 539516 (2024-003)

Significant Deficiency 2024

Region III Workforce Investment Board of Kanawha County, Inc.

WV

Questioned Costs Subrecipient Monitoring § 200.303 § 200.332

2024-003 Subrecipient Monitoring U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in ...

2024-003 Subrecipient Monitoring U.S. Department of Labor Assistance Listing Number 17.258/17.259/17.278 Recommendation: We recommend that the Board implement its recently adopted policies and procedures and commit the appropriate personnel to subrecipient monitoring to ensure that the Board is in compliance with all federal requirements. Action Taken: The Board has formally integrated the new adopted policies and procedures into our operational framework to ensure consistency and adherence to federal guidelines. Specific staff members have been designated to subrecipient monitoring responsibilities, ensuring adequate oversight and compliance. Executive staff will conduct period internal reviews to assess the effectiveness of our monitoring processes and make improvements as needed.

View Audit 350052 Questioned Costs: $1

Finding 539491 (2024-004)

Material Weakness 2024

Frazer School District

MT

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

FINDING 2024-004: Impact Aid Application Controls (Repeated 2023-004) Response: The District has implemented that the documentation for the Impact Aid application will be kept in the Business Manager office rather than the Superintendent office to ensure that this documentation is maintained for fut...

FINDING 2024-004: Impact Aid Application Controls (Repeated 2023-004) Response: The District has implemented that the documentation for the Impact Aid application will be kept in the Business Manager office rather than the Superintendent office to ensure that this documentation is maintained for future years.

View Audit 350039

Corrective Action Plans

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