Corrective Action Plans

Finding 1171072 (2023-001)

Material Weakness 2023

Albuquerque Area Indian Health Board, Inc.

NM

Reporting Subrecipient Monitoring

The AAIHB has missed the filing deadline for the FY 2023 Data Collection Form. The AAIHB will file the FY 2023 Data Collection Form within 30 days. The AAIHB will review and revise its internal review processes to ensure future Data Collection Forms are completed and filed in a timely manner. Correc...

The AAIHB has missed the filing deadline for the FY 2023 Data Collection Form. The AAIHB will file the FY 2023 Data Collection Form within 30 days. The AAIHB will review and revise its internal review processes to ensure future Data Collection Forms are completed and filed in a timely manner. Corrective action plan timeline is to submit FY 2024 audit and data collection forms within 30 days. Executive Director and Finance Officer

View Audit 384454

Finding 1171005 (2023-003)

Material Weakness 2023

Nation's Finest and Subsidiaries

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303

FINDING 2023-003 – Reporting: Significant Deficiency over Internal Controls over Compliance Condition/context – In a representative sample of monthly, quarterly, and annual reports due during the year ended December 31, 2023, auditors noted six of the six tested annual financial reports (SF-425) did...

FINDING 2023-003 – Reporting: Significant Deficiency over Internal Controls over Compliance Condition/context – In a representative sample of monthly, quarterly, and annual reports due during the year ended December 31, 2023, auditors noted six of the six tested annual financial reports (SF-425) did not agree to the underlying profit and loss detail from the Organization’s General Ledger(s) for the related grants. In addition, the certified authorized official was not an employee of the Organization and there was a lack of documentation for how the certifying official was deemed appropriate. In the sample quarterly reports, the Organization had contradicting responses related to whether reimbursement requests reflect actual spending of designated Supportive Services for Veteran Families (SSVF) funding. Corrective Action Plan: • Internal Controls are being evaluated and addressed with the Board of Directors on clarity of Financial Policy and Procedures • Implement a formal reconciliation process to ensure all grant financial reports agree to the underlying general ledger and profit and loss statements. • Establish a documented policy identifying employees authorized to certify grant reports, ensuring these individuals are employees of the Organization and appropriately trained. • Conduct regular training and internal reviews to confirm consistent understanding of grant-specific reporting requirements, particularly those related to reimbursement-based funding such as SSVF. • Develop a standard operating procedure (SOP) for reviewing and approving financial reports before submission to funders. Prior to sending to funder/portal. Must have reconciliation to numbers prior to next period reporting. • Site Review of reporting will have oversight of Financial Dept and reconciliation communication. Name of Contact Person: Chris Flaherty, Chief Executive Officer 707.890.6491 Laura Williams, Chief Financial Officer 707.335.0010 Projected Completion Date: We cannot alleviate within 12 months

View Audit 384402

Finding 1170637 (2023-008)

Material Weakness 2023

City of Adelanto

CA

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.334

Recommendation: We recommend the City enhance its internal control by implementing policies and procedures to track wage rate requirements compliance, and ensure that all certified payrolls and supporting wage-rate documentation are retained. Views of Responsible Officials: Management concurs with t...

Recommendation: We recommend the City enhance its internal control by implementing policies and procedures to track wage rate requirements compliance, and ensure that all certified payrolls and supporting wage-rate documentation are retained. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced higher than expected staff turnover in the finance department during the timeframe noted in this audit, which caused a backlog in audit preparation and submission, along with certain financial controls implementation interruption. At the time of this audit publishing, Management believes that implementation of such procedures is in compliance with the noted recommendation. Persons Responsible for Corrective Action: City Finance Staff (various) City Department Heads applying for grant funding (various) City Project Managers (various) Anticipated Completion Date for Corrective Action: Corrective action has been immediately implemented in response to the auditors’ recommendation. As financial reporting is still in the process of becoming current, the City anticipates finding to be removed in future fiscal years.

View Audit 383868

Finding 1170634 (2023-007)

Material Weakness 2023

City of Adelanto

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.334 § 200.415

Recommendation: We recommended the City establish internal control procedures to ensure that all reimbursement requests are reviewed and approved by an authorized official prior to submission. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced highe...

Recommendation: We recommended the City establish internal control procedures to ensure that all reimbursement requests are reviewed and approved by an authorized official prior to submission. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced higher than expected staff turnover in the finance department during the timeframe noted in this audit, which caused a backlog in audit preparation and submission, along with certain financial controls implementation interruption. At the time of this audit publishing, Management believes that implementation of such procedures is in compliance with the noted recommendation. Persons Responsible for Corrective Action: City Finance Staff (various) City Department Heads applying for grant funding (various) Anticipated Completion Date for Corrective Action: Corrective action has been immediately implemented in response to the auditors’ recommendation. As financial reporting is still in the process of becoming current, the City anticipates finding to be removed in future fiscal years.

View Audit 383868

Finding 1170631 (2023-009)

Material Weakness 2023

City of Adelanto

CA

Subrecipient Monitoring § 200.332 § 200.403 § 200.521

Recommendation: We recommended the City enhance its subrecipient monitoring activities and establish a formal record-keeping policy to ensure complete and timely documentation of expenses. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced higher th...

Recommendation: We recommended the City enhance its subrecipient monitoring activities and establish a formal record-keeping policy to ensure complete and timely documentation of expenses. Views of Responsible Officials: Management concurs with the finding. The City of Adelanto experienced higher than expected staff turnover in the finance department during the timeframe noted in this audit, which caused a backlog in audit preparation and submission, along with certain financial controls implementation interruption. At the time of this audit publishing, Management believes that implementation of such procedures is in compliance with the noted recommendation. Persons Responsible for Corrective Action: City Finance Staff (various) City Department Heads applying for grant funding (various) Anticipated Completion Date for Corrective Action: Corrective action has been immediately implemented in response to the auditors’ recommendation. As financial reporting is still in the process of becoming current, the City anticipates finding to be removed in future fiscal years.

View Audit 383868

Finding 1170544 (2023-005)

Material Weakness 2023

County of Delaware

PA

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

This finding occurred as a result of staff shortages, new employees and increased caseloads. The Domestic Relations Department filled vacant positions through 2023. The Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time fra...

This finding occurred as a result of staff shortages, new employees and increased caseloads. The Domestic Relations Department filled vacant positions through 2023. The Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/ petitions to case files and file documentation beginning in November 2023.

View Audit 383805

Finding 1170543 (2023-004)

Material Weakness 2023

County of Delaware

PA

Student Financial Aid Subrecipient Monitoring Eligibility

Turnover and vacancies in positions resulting in applications and petitions not being completed within 20 days of receipt. The Domestic Relations Department filled vacant positions through 2023. In response to the prior year finding, the Domestic Relations Department provided semi-annual training to...

Turnover and vacancies in positions resulting in applications and petitions not being completed within 20 days of receipt. The Domestic Relations Department filled vacant positions through 2023. In response to the prior year finding, the Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/petitions to case files and file documentation beginning in November 2023.

View Audit 383805

Finding 1170542 (2023-003)

Material Weakness 2023

County of Delaware

PA

Special Tests & Provisions Subrecipient Monitoring Reporting

This finding occurred as a result of a data entry error in the file. The Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/petitions to case files and file documentation beginning in No...

This finding occurred as a result of a data entry error in the file. The Domestic Relations Department provided semi-annual training to the Intake Unit staff in Case Initiation, record retention, time frame for conversion of applications/petitions to case files and file documentation beginning in November 2023.

View Audit 383805

Finding 1170541 (2023-008)

Material Weakness 2023

County of Delaware

PA

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

The County Human Services department noted that the service providers were paid at their negotiated rates agreed upon by contract terms, however no reconciliation was completed for the remainder eligible cost adjustments to the service providers for the fiscal year ended June 30, 2023. The County Hu...

The County Human Services department noted that the service providers were paid at their negotiated rates agreed upon by contract terms, however no reconciliation was completed for the remainder eligible cost adjustments to the service providers for the fiscal year ended June 30, 2023. The County Human Services department will complete the reconciliation of the service providers costs reports for the fiscal year ended June 30, 2024 before March 2025.

View Audit 383805

Finding 1170540 (2023-007)

Material Weakness 2023

County of Delaware

PA

Subrecipient Monitoring Material Weakness Reporting

The County Human Services department will complete the Roster of Personnel (PW 1171) be submitted for the fiscal year ended June 30, 2023 by December 2024 and review the processes and controls to ensure the rosters is completed annually.

View Audit 383805

Finding 1170539 (2023-002)

Material Weakness 2023

County of Delaware

PA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

The County Human Services department has requested approval from PA DHS of its 2021-2022 fiscal year re-submission in September 2024. Following approval of the 2021-2022 submission and re-investment the County Human Services department will complete the submission of the 2022-2023 fiscal year report...

The County Human Services department has requested approval from PA DHS of its 2021-2022 fiscal year re-submission in September 2024. Following approval of the 2021-2022 submission and re-investment the County Human Services department will complete the submission of the 2022-2023 fiscal year report. The County Human Services department will reconcile the underlying expenditure detail in the accounting system to the expenditures reported. Internal approvals prior to submission and underlying records for reports will be maintained by the County Human Services department.

View Audit 383805

Finding 1170532 (2023-006)

Material Weakness 2023

County of Delaware

PA

Subrecipient Monitoring § 200.332

The County Child and Youth Services department started requiring a corrective action plan for all subrecipients with findings as a result of their on-site monitoring in 2023 that include the entity’s plan to correct the errors noted, individual responsible and timeline for corrections to be implemen...

The County Child and Youth Services department started requiring a corrective action plan for all subrecipients with findings as a result of their on-site monitoring in 2023 that include the entity’s plan to correct the errors noted, individual responsible and timeline for corrections to be implemented. Finding noted are for monitoring completed in January and March 2023, prior to the requirement of written corrective action plans being implemented.

View Audit 383805

Finding 1170351 (2023-001)

Material Weakness 2023

New Directions, Inc.

CA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Management concurs that there were staffing and turnover challenges for the Organization. Adequate policies and procedures are in place to ensure timeliness of data requested. Additionally, we will establish milestones to ensure future audits progress within the Uniform Guidance timeline.

View Audit 383444

Finding 1169874 (2023-003)

Material Weakness 2023

City of Reedsburg

WI

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

Corrective Action Plan: The Utility Commission General Manager or Communications System Supervisor will review the quarterly progress reports prepared by someone else. Section II of the Project Status Report instructions states “Answer each question to the best of your ability.” The work orders do n...

Corrective Action Plan: The Utility Commission General Manager or Communications System Supervisor will review the quarterly progress reports prepared by someone else. Section II of the Project Status Report instructions states “Answer each question to the best of your ability.” The work orders do not include all costs related to labor benefits and taxes, and also the electronics and customer premise equipment associated with the projects. These costs are calculated and added in when the project is completed and is being closed out. Estimating these items for the quarterly Project Status Report is providing the project costs spent through the respective quarter to the best of our ability due to the limitations of the work order reporting process. Planned Completion Date for the Corrective Action: On-going Contact Persons Responsible for the Corrective Action Plan: The following Reedsburg Utility staff members are responsible for items outlined above in the Corrective Action Plan: • Brett Schuppner, Reedsburg Utility General Manager • Ken Las, Communications System Supervisor

View Audit 383031

Finding 1169782 (2023-005)

Material Weakness 2023

Temenos Community Development Corporation

TX

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

2023-005 Compliance and Internal Controls over Program Income (Significant Deficiency) U.S. Department of Housing and Urban Development 14.267 – Continuum of Care Program 2023 Funding Recommendation: The Organization should establish procedures to ensure that controls related to program income are c...

2023-005 Compliance and Internal Controls over Program Income (Significant Deficiency) U.S. Department of Housing and Urban Development 14.267 – Continuum of Care Program 2023 Funding Recommendation: The Organization should establish procedures to ensure that controls related to program income are consistently implemented. In addition, documentation should be included in each participant's files to support income calculations and the participant's share of rent payable to the program. Corrective Action: We would like to clarify our approach to income documentation within client files: 1. Income Documentation: While not all clients have income, we will ensure that clients without income provide a zero-income affidavit (also known as a non-income affidavit) to document their status. 2. Stabilized Case Management: Our current case managers have been with Temenos CDC (TCDC) for over a year, providing stability and experience in verifying client income. 3. Policy and Procedure Updates: Recent updates to our policies and procedures have introduced standardized forms that clearly differentiate between households with income and those without. 1. Households with income will include the mandatory TCDC income calculation sheet. 2. Households without income will be required to submit the zero-income affidavit. 4. File Checklists: We have created file checklists to ensure uniformity across all client files, enhancing our documentation process. 5. Annual Audits: All client files will be audited by a supervisor at least once a year to ensure compliance with our policies. 6. HMIS Training: Case managers are required to complete mandatory HMIS training, which supports effective compliance in file management and income verification. These measures are designed to strengthen our documentation practices and ensure compliance with audit requirements. Responsible Parties: Sandra Robicheaux – ED Ramona Edwards – Property Manager Wanda Williams – Case Manager Damita Gardner – Case Manager Terence Gomes – Case Manager Date to be Corrected: Mandatory Training Implemented 01/2025 Updated Document Requirements 11/2025

View Audit 382882

Finding 1169771 (2023-002)

Material Weakness 2023

Temenos Community Development Corporation

TX

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303 § 200.320

2023-002 Compliance and Internal Controls over Procurement (Material Weakness and Noncompliance) U.S. Department of Housing and Urban Development 14.267 – Continuum of Care Program 2023 Funding Recommendation: The Organization should establish procedures to ensure that controls related to procuremen...

2023-002 Compliance and Internal Controls over Procurement (Material Weakness and Noncompliance) U.S. Department of Housing and Urban Development 14.267 – Continuum of Care Program 2023 Funding Recommendation: The Organization should establish procedures to ensure that controls related to procurement are consistently implemented and that all written records are maintained to support that the compliance requirement is met. Corrective Action: In alignment with the recent leadership transition, a comprehensive policy and procedure manual has been established to ensure our procurement practices meet HUD guidelines. The following outlines our updated procurement policy: 1. Compliance with Standards: All procurement of property (goods, supplies, or equipment) and services must adhere to the standards of conduct and conflict-of-interest requirements outlined in 2 CFR 200.317 and 200.318. 2. Micro Purchases (Under $9,999): Temenos CDC (TCDC) will document the reasonableness of costs for all micro purchases to ensure appropriate spending practices. 3. Small Purchases ($10,000 and above): For small purchases exceeding $10,000, TCDC will solicit a minimum of three bids for services to promote competitive pricing. 4. Vendor Vetting: 1. All new vendors will be vetted through the SAM (System for Award Management) Department prior to the initiation of services. 2. Continuous service providers will be subject to an annual vetting process to ensure ongoing compliance and quality. These measures are designed to reinforce our commitment to transparency, accountability, and compliance with HUD requirements. Responsible Parties: Sandra Robicheaux - Executive Director Madelyn Wages – Director of Supportive Services Ramona Edwards – Property Manager Date to be Corrected: Implementation for above changes went into effect 6/01/2024

View Audit 382882

Finding 1169749 (2023-002)

Material Weakness 2023

City of Bay St. Louis, Mississippi

MS

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring

The City will continue to work with the grant administrator who is managing the grant for the funding agency. The Administration will only submit invoices once for reimbursement and identify which invoices are local funding versus grant funding to avoid this in the future.

View Audit 382844

Finding 1169562 (2023-004)

Material Weakness 2023

LUTI R-VI SCHOOL DISTRICT

MO

Subrecipient Monitoring Internal Control / Segregation of Duties

Internal Control over Major Federal Program Compliance Program: Education Stabilization Fund (CFDA 84.425) Condition: Lack of policies and procedures for verifying and monitoring Wage Rate Requirements. Material Weakness Corrective Action Plan: The District will adopt policies to require prevailing ...

Internal Control over Major Federal Program Compliance Program: Education Stabilization Fund (CFDA 84.425) Condition: Lack of policies and procedures for verifying and monitoring Wage Rate Requirements. Material Weakness Corrective Action Plan: The District will adopt policies to require prevailing wage payments for contractor employees working an federally funded projects. The District will adopt policies and implement procedures requiring contractors on federally funded projects provide certified payroll reports to the District to ensure compliance with Wage Rate Requirements. The District will implement verification procedures to ensure contractor compliance with prevailing wage payments to employees. Planned Completion Date: March 20, 2024 Responsible Contact Perosn: Kathalee Cole, Superintendent (417) 273-4274

View Audit 382546

Finding 1168942 (2023-002)

Material Weakness 2023

Town of Malden

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Town of Malden January 1, 2023 through December 31, 2023 This schedule presents the corrective action the Town is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Town of Malden January 1, 2023 through December 31, 2023 This schedule presents the corrective action the Town is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-002 Finding caption: The Town did not have adequate internal controls and did not comply with federal wage rate requirements. Name, address, and telephone of Town contact person: Dan Harwood, Mayor PO Box 248, Malden, Washington 99149 (509) 569-3771 Corrective action the auditee plans to take in response to the finding: We agree with the SAO staff as far as the Town staff being new to federal grants and the requirements of recordkeeping associated with it. It is obvious that the Town staff can not handle the workload of administering all the grants that the town has obtained since the 2020 Babb Road Fire. We are in the process of contracting an outside party that will handle most of the current grants. The Town staff thought they processed all the certified payroll information that was received. We were surprised that there were some missing. The State Department of Commerce has been working with the staff on making sure that the certified payroll process was complete. With any future grants we will make sure that Town staff will pursue training on Certified Payroll to make sure all papers are received. Anticipated date to complete the corrective action: These actions will be done when we receive future federal grants.

View Audit 381466

Finding 1168848 (2023-003)

Material Weakness 2023

City of Upper Sandusky

OH

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.329

The City will work to ensure all reports for grant funding are completed.

View Audit 381205

Finding 1168707 (2023-003)

Material Weakness 2023

City of Woodland

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Woodland January 1, 2023 through December 31, 2023 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (C...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Woodland January 1, 2023 through December 31, 2023 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-003 Finding caption: The City did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of City contact person: City of Woodland Contact: Amanda Hougan 230 Davidson Ave Title: City Clerk PO Box 9 Phone: 360-225-8281 ext 101 Woodland, WA 98674 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The City has added a step in the checklist process to always check for suspension and debarment and then save a screenshot of the results in the project file. Anticipated date to complete the corrective action: 11/25/2025

View Audit 380707

Finding 1168604 (2023-002)

Material Weakness 2023

Line Mountain School District

PA

Subrecipient Monitoring Reporting

Finding 2023-2 –Reporting Contact Person: Kaitlin M. Rosselli, Business Manager Recommendation: We recommend that the District strengthen internal controls over grant reporting to ensure all required Reconciliation of Cash on Hand Quarterly Reports and final expenditure reports are prepared accurate...

Finding 2023-2 –Reporting Contact Person: Kaitlin M. Rosselli, Business Manager Recommendation: We recommend that the District strengthen internal controls over grant reporting to ensure all required Reconciliation of Cash on Hand Quarterly Reports and final expenditure reports are prepared accurately and submitted timely in accordance with grant requirements. The District should implement a formal review and monitoring process and provide training to staff responsible for grant reporting to ensure ongoing compliance. Action: The District Office will work directly with the Federal Programs Coordinator to ensure more timely submissions of Reconciliation of Cash on Hand Quarterly Reports and Final Expenditure Reports are prepared accurately and submitted timely in accordance with grant requirements. The Business Manager will do this by creating reminders on the Business Manager’s calendar that include due dates each quarter and reminding the Federal Programs Coordinator when their respective reports are due. The District will implement and form a review and monitoring process and provide any necessary training to staff responsible for grant reporting to ensure ongoing compliance. Date for Completion: These steps have already been put into place and will continue to be built upon.

View Audit 380500

Finding 1168603 (2023-004)

Material Weakness 2023

Line Mountain School District

PA

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

2023-4 –Activities Allowed Contact Person: Kaitlin M. Rosselli, Business Manager Recommendation: We recommend that the District strengthen internal controls over payroll charged to Federal awards by ensuring required approvals are obtained and review processes occur. Additionally, the District shoul...

2023-4 –Activities Allowed Contact Person: Kaitlin M. Rosselli, Business Manager Recommendation: We recommend that the District strengthen internal controls over payroll charged to Federal awards by ensuring required approvals are obtained and review processes occur. Additionally, the District should review their record retention policy to ensure sufficient supporting documentation is retained to demonstrate compliance with Federal requirements. Action: The District will ensure that all payroll timecards are approved and signed by the appropriate supervisor before being processed for payment. The payroll clerk will not process the timecard unless it is signed and approved. Additionally, we will review the District’s record retention policy to ensure sufficient supporting documentation is retained to demonstrate compliance with Federal requirements. The District will thoroughly review timecards to avoid clerical errors in the future. Date for Completion: These steps have already been put into place and will continue to be built upon.

View Audit 380500

Finding 1168598 (2023-005)

Material Weakness 2023

City of Lock Haven, Pennsylvania

PA

Subrecipient Monitoring Reporting Special Tests & Provisions

The City has engaged an independent accountant and works with its financial advisors to ensure future audits are completed in a timely manner.

View Audit 380490

Finding 1168080 (2023-004)

Material Weakness 2023

NEW YORK CITY FOUNDATION FOR COMPUTER SCIENCE EDUCATION, INC.

NY

Subrecipient Monitoring § 200.331 § 200.332

Response to finding 2023-004 – Subrecipient Monitoring Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-004. Due to the organizational pause at the end of 2024 and the transiti...

Response to finding 2023-004 – Subrecipient Monitoring Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-004. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization had limited capacity to maintain formalized subrecipient monitoring procedures aligned with 2 CFR 200.332. As CSforALL prepares for the 2026 rebuilding phase, management is establishing structured policies and procedures to ensure full compliance with federal subrecipient monitoring requirements. Corrective Action taken in 2025: During 2025, the Operations Manager ensured that all subrecipients associated with the current Alliance grant have signed or will sign formal Statements of Work with explicit deliverables and expectations required for payment. External parties without a Statement of Work are now required to submit proper documentation, invoicing, and proof of deliverables before any funds are released. No payments have been made to participants under the FY 2025 Alliance grant to date, as CSforALL is ensuring that all required policies and procedures are in place prior to both drawing down and paying out funds. Weekly and quarterly meetings have been established with external partners responsible for deliverables to confirm timelines, verify progress, and ensure alignment with payment expectations. Corrective Action Planned for 2026: Beginning in 2026, CSforALL will formalize subrecipient monitoring policies aligned with 2 CFR 200.332, including risk assessments for all subrecipients, review and documentation of Single Audit reports where applicable, issuance of management decisions, and structured ongoing monitoring activities. All monitoring documentation will be maintained in a centralized, accessible system to ensure consistent compliance throughout the 2026 operating year and beyond.

View Audit 379802

Corrective Action Plans

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