Corrective Action Plans

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Response to finding 2023-003 – Lack of Documented Approval for Payroll Transactions Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-003. Due to the organizational pause at the...
Response to finding 2023-003 – Lack of Documented Approval for Payroll Transactions Views of Responsible Officials: CSforALL management agrees with the conditions identified by SAX Advisory Group, including the noted causes and resulting effects under 2023-003. Due to the organizational pause at the end of 2024 and the transition period throughout 2025, the Organization discontinued its prior payroll system when staff were laid off and shifted remaining personnel to contractor status. During this period, approval and payment of contractor invoices were processed through Ramp, with documentation maintained but not within a formalized payroll approval workflow. As CSforALL prepares for the 2026 rebuilding phase, management has re-established a structured payroll approval and documentation process aligned with audit recommendations. Corrective Action taken in 2025: Beginning in August 2025, the Organization transitioned to ADP, a trusted payroll service integrated with QuickBooks, in anticipation of restoring full payroll operations in 2026. Since implementation, payroll reporting and documentation have been maintained accurately each month by the Operations Manager and the Accountant, with formal approval granted by the Advisory Consultant. All invoices, payments, and payroll records are shared and stored bi-weekly as payroll is executed, establishing a consistent and documented approval trail. Corrective Action Planned for 2026: Beginning in January 2026, CSforALL will apply standardized supervisory approval procedures within ADP for all payroll transactions. Management will implement periodic monitoring of payroll records, ensure consistent use of the approved timekeeping and approval system, and maintain documentation of all supervisory approvals to ensure compliance with established internal controls throughout the 2026 operating year and beyond.
Federal Program: Assistance Listing #'s 93. 778, Medical Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: 13-1415MATP-4-2; 93.658, Foster Care Title IV-E, Passed Through Pennsylvania Department of Human Services, Pass-Through Entit...
Federal Program: Assistance Listing #'s 93. 778, Medical Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: 13-1415MATP-4-2; 93.658, Foster Care Title IV-E, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: not available; 21.027, COVI D-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury; 93.558, Temporary Assistance for Needy Families, Passed Through Pennsylvania Department of Labor and Industry, Pass-Through Entity Identifying Number: not available. Criteria: The tracking and matching of grant revenues and expenditures and the related grant receivable and unearned revenue amounts is necessary to assist in making management decisions and for the proper reporting and use of those funds in accordance with each of the individual grant requirements. In addition, this information is essential in preparing the County's Schedule of Expenditures of Federal Awards (SEFA}. Condition/Context: The County's system of tracking its grants and matching revenues with expenditures lacks the necessary level of sophistication, given the number and complexities of the County's grant activities, which hampers the County's ability to maintain an accurate general ledger and prepare a complete and accurate SEFA. The current year SEFA also required the restatement of beginning accrued revenue balances. Effect: Grants receivable and unearned revenue amounts are not readily ascertainable to assist in making management decisions or for use in the timely preparation of the County's SEFA. The County did not prepare a complete and accurate SEFA in a timely manner to comply with its financial reporting requirements. Cause: The County has not prioritized a formal system for tracking its grant activities. Recommendation: We recommend that the County develop and implement a formal system for tracking its grant related activities and in doing so require that all departments with responsibility for federal award programs provide periodic reconciliations of their grant reports to the general ledger to a responsible management official. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the restatement of the beginning accrued revenue balances on the SEFA and is working to realign staff responsibilities to provide a dedicated business office staff member to oversee, track, report and manage all of the County's grant awards. Designated Member responsible for Corrective Action Plan: Kayla E. Herman Expected Complete Date: 06/30/2026
Federal Program: Assistance Listing #'s 93.778, Medical Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: 13-1415MATP- 4-2; 93.658, Foster Care Title IV-E, Passed Through Pennsylvania Department of Human Services, PassThrough Entity...
Federal Program: Assistance Listing #'s 93.778, Medical Assistance Program, Passed Through Pennsylvania Department of Human Services, Pass-Through Entity Identifying Number: 13-1415MATP- 4-2; 93.658, Foster Care Title IV-E, Passed Through Pennsylvania Department of Human Services, PassThrough Entity Identifying Number: not available; 21.027, COVID-19 - Coronavirus State and Local Fiscal Recovery Funds, U.S. Department of Treasury; 93.558, Temporary Assistance for Needy Families, Passed Through Pennsylvania Department of Labor and Industry, Pass-Through Entity Identifying Number: not available. Criteria: Pursuant to the provisions of the Uniform Guidance, under Section 200.512(a), the County is required to complete and submit its Single Audit and related Data Collection Form within nine months of the end of its fiscal period (September 30) of the following year. Condition/Context The County's Single Audit and reporting package was delayed for the year ended December 31, 2022 beyond the nine-month due date. Effect: The County is not in compliance with certain requirements of the Uniform Guidance, including the Single Audit reporting requirements. Questioned Costs: None. Cause: Reconciliations and reports were not completed on a timely basis, and therefore, the completion and filing of its December 31, 2022 Single Audit and reporting package was not prioritized. Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes. Views of Responsible Officials and Planned Corrective Actions: The County plans to have information ready for the auditors to get 2024 done in a reasonable time frame. This finding will likely carry to 2024 but between staffing and priorities, the County hopes to have cleared by the 2025 audit. Designated Member responsible for Corrective Action Plan: Kayla E. Herman Expected Complete Date: 06/30/2026
Finding 2023-006: This is for Special Education Condition 1: For 4 of the transactions total question costs $512. The supporting documentations were not provided. Conditional 2: No departmental timecards or timesheets were provided to support compensation. Condition 3. Payroll with timecards, there ...
Finding 2023-006: This is for Special Education Condition 1: For 4 of the transactions total question costs $512. The supporting documentations were not provided. Conditional 2: No departmental timecards or timesheets were provided to support compensation. Condition 3. Payroll with timecards, there were no verification performed at the departments to ensure that what is being paid are correct. Root Cause Analysis a. Condition 1: Ineffective documentation retention at treasury, exacerbated by office relocation. b. Condition 2: Ineffective retention at departmental agencies where timesheets are held. c. Conditions 3(a) and 3(c): Weak internal controls over reconciliation between departmental timesheets and treasury uniform timesheets. Treasury does not regularly obtain departmental timesheets. d. Condition 3(b): Manual timecard errors from daily stamp-based systems. Corrective Actions 1. Strengthen documentation retention controls. 2. Enhance monitoring at the departmental level or implement a uniform timekeeping system to reduce reconciliation issues. 3. Require submission of departmental timekeeping reports to treasury for secondary reconciliation. 4. Ensure explanatory documentation is retained when uniform timesheets differ from departmental records. Responsible Parties For CAP 1. Director of DOTA and Payroll division For CAP 2. Special Education Administrator and his timekeepers For CAP 3. Director of DOTA and Payroll division For CAP 4. Both Department of DOTA and Special Ed Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.
Finding 2023-005: Condition 1: The State’s capital asset register reflected no Compact Sector–funded capitalized infrastructure additions since FY 2016, despite completed contracts during 2016 through 2021. The State was unable to provide supporting documentation evidencing capitalizable values, pro...
Finding 2023-005: Condition 1: The State’s capital asset register reflected no Compact Sector–funded capitalized infrastructure additions since FY 2016, despite completed contracts during 2016 through 2021. The State was unable to provide supporting documentation evidencing capitalizable values, project ownership, or other required details. Conditional 2: Four (4) assets or batches of assets that met the State’s capitalization requirements were not capitalized until corrected through audit adjustments Root Cause Analysis For both conditions there is a lack of internal control monitoring over fixed asset capitalization. Corrective Actions 1. For Condition 1, the State should obtain documentation to support capitalizable values and confirm ownership. 2. For Condition 2, all assets related to health-sector acquisitions, the State should improve coordination between the Department of Health and Human Services and the State Treasury to ensure eligible items are capitalized at requisition or purchase order stage. Responsible Parties For Corrective Action Plan 1: Director of DOTA and Procurement Officer For Corrective Action Plan 2: Director of Health and his administrative officers Director of DOTA, Certification and Procurement officer Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.
Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision...
Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision. For 11 (or 23%) of 49 personnel records tested under the Compact Sector Education and Supplemental Education grants, no documentation was available to show that the annual performance evaluation had been performed. Root Cause Analysis • For advance payments, either concurrence was not obtained, or documentation was not retained; and a lack of familiarity with specific grant conditions may have contributed to the noncompliance. • For evaluations, documentation retention controls over personnel files were inadequate. Corrective Actions • For the health grants, if advance payments are necessary, the State should (a) use general fund advances with later reimbursement; (b) establish a letter of credit; or (c) obtain prior OIA concurrence. • For the Education and Supplemental Education grants, the State should strengthen controls to ensure annual evaluations are completed and retained in personnel files. Responsible Parties For bullet point one: Director of Health and his administrative officers Director of DOTA, certification and payable section For bullet point two: Director of Education and Personnel Managers Timeline Verification of Effectiveness Conduct regular assessments to ensure the effective implementation of the aforementioned action plans.
Finding 2023-002: This finding is for Education Department Condition 1. Impact: For 3 or (5%) of 60 non-payroll transactions tested, (a) no financial records were available to substantiate allowability; or (b) the available procurement file documentation was insufficient to substantiate allowability...
Finding 2023-002: This finding is for Education Department Condition 1. Impact: For 3 or (5%) of 60 non-payroll transactions tested, (a) no financial records were available to substantiate allowability; or (b) the available procurement file documentation was insufficient to substantiate allowability, as follows: The noncompliance resulted in a total questioned cost of $604. Condition 2. For 13 or (20%) of 65 payroll transactions tested, no departmental timecards or timesheet documentation was provided to support compensation, taxes, and fringe benefits. Condition 3. Of the 49 payroll transactions tested where departmental timecards or timesheet support was provided, we identified the following: 1) For 1 employee, the uniform timesheet reported 16 hours of sick leave, while the departmental timesheet reported 80 hours of regular work. 2) For 1 employee, the uniform timesheet was not signed by all required authorized signatories. 3) For 1 employee, the uniform timesheet reported 56 regular hours, while the departmental timesheet reflected 43 regular hours; however, the employee was paid for 80 regular hours, resulting in an overpayment of approximately $76 (processed on May 2, 2023). Root Cause Analysis • For Condition 1, ineffective documentation filing and retention controls were exacerbated by the relocation of the State Treasury office during the audit period. • For Condition 2, ineffective documentation filing and retention controls existed at the departmental agency level, where timesheets or other timekeeping records were retained. • For Condition 3(a), insufficient internal controls at the departmental level failed to ensure reconciliation of departmental timesheets with uniform timesheets submitted to the State Treasury. The Treasury does not consistently receive departmental support and therefore relies on agency review and certification. • For Condition 3(b), required signatory authorization controls failed at both the departmental and treasury levels. • For Condition 3(c), existing controls failed to detect and prevent the overpayment. Corrective Actions 1) For Condition 1. Strengthen documentation filing and retention controls. 2) For Condition 2 & 3 a) Enhance monitoring controls at the departmental level or implementing a uniform timekeeping system to reduce reconciliation burdens b) Establish policies requiring submission of department timekeeping report to the State treasury to allow for secondary reconciliation c) Reinforcing the requirement that when changes are made affecting uniform timesheets but not departmental records, appropriate explanatory documentation be retained. Responsible Parties For Condition 1. • Director of DOTA/Payable Section - Strengthen documentation filing and retention controls. For Condition 2 & 3 • Director of Education/Timekeepers - Enhance monitoring controls at the departmental level or implementing a uniform timekeeping system to reduce reconciliation burdens • Director of DOTA and Payroll Section - Establish policies requiring submission of departmental timekeeping reports to the State treasury to allow for secondary reconciliation. • Director of DOTA and Payroll Section - Reinforce the requirement that when changes are made affecting uniform timesheets but not departmental records, appropriate explanatory documentation be retained. Timeline Verification of Effectiveness For condition 1, the State Treasury will perform routine inspections of the filing systems to verify compliance and address individuals who resist necessary changes. For Conditions 2 and 3, payroll will not be disbursed to any department that fails to adhere to the new action plan
Action Item Title 2023-006 – Federal Award Findings Status (Open: In-process) Condition Single Audit Reporting Package Submission The Corporation did not comply with the Single Audit Reporting Package submission date requirement for the years ended June 30, 2023, and 2022. Identified root cause Due ...
Action Item Title 2023-006 – Federal Award Findings Status (Open: In-process) Condition Single Audit Reporting Package Submission The Corporation did not comply with the Single Audit Reporting Package submission date requirement for the years ended June 30, 2023, and 2022. Identified root cause Due to the Commonwealth of Puerto Rico's (the Commonwealth) filing for Title III under PROMESA, most of its instrumentalities were required to reduce staff as part of the Fiscal Plan to lower expenditures. This staff reduction resulted in a lack of personnel, which impacted key internal controls. Grantee resolution plan The Corporation will submit the outstanding Single Audit Reporting Packages Completion date 2022 2023 Submitted and accepted by the Federal Audit Clearinghouse on August 20, 2024. May 2025 Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov
Action Item Title 2023-005 – Federal Award Findings Status (Open: In-process) Condition General Procurement Standards - Written Policies Suspension and Debarment - Covered Transaction The Corporation has an outdated institutional procurement manual approved in 2014 that lacks written policies to asc...
Action Item Title 2023-005 – Federal Award Findings Status (Open: In-process) Condition General Procurement Standards - Written Policies Suspension and Debarment - Covered Transaction The Corporation has an outdated institutional procurement manual approved in 2014 that lacks written policies to ascertain compliance with the provisions of federal statutes, regulations, or the terms and conditions of federal awards regarding procurement, suspension, and debarment requirements. From a sample of eighteen disbursements, we selected eight disbursements to ascertain compliance with 2 CFR section 180.220, specifically regarding the inclusion of procurement contracts as covered transactions. We examined the procurement documents provided by the Corporation. From that sample, we identified that the Corporation did not perform the required verification process for covered transactions during the year ended June 30, 2023. Identified root cause The Corporation lacks internal controls and policies to ensure compliance with federal procurement requirements. In addition, the Corporation relies on the procedures performed by the Administration of General Services to comply with procurement requirements. As a result, the Corporation did not maintain its own documentation. Grantee resolution plan Procurement Policies and Covered Transactions The Corporation is currently in the process of reviewing its Procurement Procedure to align it with ASG guidelines and incorporate federal regulations. Completion date By December 31, 2025. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov
Action Item Title 2023-004 – Federal Award Findings Status (Open: In-process) Condition Inactive SAM Registration Impacting Eligibility The Corporation’s SAM registration expired on September 6, 2023. Identified root cause The Corporation has been unable to update the SAM’s registration due to probl...
Action Item Title 2023-004 – Federal Award Findings Status (Open: In-process) Condition Inactive SAM Registration Impacting Eligibility The Corporation’s SAM registration expired on September 6, 2023. Identified root cause The Corporation has been unable to update the SAM’s registration due to problems with the platform to correct their physical address. Grantee resolution plan After multiple attempts, the entity’s information was successfully validated on December 21, 2024. Completion date Corrected on December 21, 2024. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov
Action Item Title 2023-003 – Federal Award Findings Status (Open: In-process) Condition Matching Non-Federal Funds The Corporation expended $523,590 from FEMA funds but did not meet the required cost-sharing amount of $52,359 from the Community Development Block Grant - Disaster Recovery (CDBG-DR) f...
Action Item Title 2023-003 – Federal Award Findings Status (Open: In-process) Condition Matching Non-Federal Funds The Corporation expended $523,590 from FEMA funds but did not meet the required cost-sharing amount of $52,359 from the Community Development Block Grant - Disaster Recovery (CDBG-DR) funds. On September 9, 2021, the Corporation signed a Community Development Block Grant – Disaster Recovery (CDBG-DR) Non-Federal Match Program Agreement with the PRDOH, to comply with FEMA's matching requirement. The Corporation only requested a reimbursement of $4,224. Identified root cause The Corporation’s failure to request the full matching amount was due to inadequate monitoring and oversight of the matching requirement. The Corporation did not ensure that the necessary CDBG funds were allocated to meet the 10% cost-sharing requirement. Grantee resolution plan Matching Non-Federal Funds The Corporation’s CDBG Subrecipient Agreement does not currently support FEMA’s 10% local match requirement due to stricter federal compliance rules under HUD, which exceed FEMA’s. As a result, the Corporation contacted the Central Office for Recovery, Reconstruction, and Resiliency (COR3), its pass-through entity, to request assistance in identifying alternative funding sources to fulfill the 10% matching requirement. We recognize the importance of complying with the matching requirements established by the federal regulations applicable to the program. We clarify that the funds used as "matching" come from eligible sources by the regulations of the Department of Housing and Urban Development (HUD) and have been properly documented in our financial records. During the audited period, all necessary actions were taken to ensure that the matching funds met the requirements of eligibility, proportionality, and traceability. Nevertheless, we have considered the auditor’s comments and, as a corrective and proactive measure, we are strengthening our controls and documentation procedures to ensure full compliance with future audits. We appreciate the observation noted in the Single Audit report regarding compliance with the matching fund requirements for CDBG funds. We would like to clarify that our entity has complied with the applicable federal provisions regarding the contribution of equivalent funds, as established in 24 CFR Part 570 and the guidelines issued by HUD. Supporting documentation that validates compliance with the required match has been collected. It is available for review, including financial statements, reports of local contributions, and project records demonstrating the investment of non-federal resources applicable to the program. If there is any discrepancy in the interpretation regarding the source or eligibility of the matching funds presented, we are willing to clarify and provide additional evidence to support their use in accordance with the regulations. It should also be noted that the Corporation is periodically audited by the Housing Department, ensuring compliance with all relevant requirements. We remain committed to transparency and the rigorous fulfillment of all federal requirements. We appreciate the recommendations provided to continue strengthening our internal control and documentation processes. Completion date Pending assistance and resolution from COR3. Name and Title of contact: Linnette Dávila Alemán- Financial and Budget Assistant Manager Phone: 787-724-4747 ext. 2105 Email: ldavila@cba.pr.gov Jetppeht Pérez de Corcho Morgado – General Manager Phone: 787-724-4747 ext. 2102 Email: jperez@cba.pr.gov
Finding 2023-004 – Subaward Monitoring In response to the finding, GEM enhances subaward monitoring by instituting the following: GEM has established written procedures to ensure appropriate oversight of sub-awardee compliance with NSF program requirements. Going forward, we will maintain focused ov...
Finding 2023-004 – Subaward Monitoring In response to the finding, GEM enhances subaward monitoring by instituting the following: GEM has established written procedures to ensure appropriate oversight of sub-awardee compliance with NSF program requirements. Going forward, we will maintain focused oversight to ensure all policies and procedures are consistently followed. Date of completion: We received the "No cost extension" and this was completed by September 30, 2023. Responsible party: Dr. Marcus Huggans, Principal Investigator
• Implement procedural reviews and standardized templates to enhance subrecipient oversight, monitoring, and documentation. • Note: Questioned costs unwarranted as no tests conducted on state-level expenditures. 9/30/2026 Mr. Marcus Samo, Secretary of FSMNG Health Email: marcus.samu@fsmhealth.gov.fm
• Implement procedural reviews and standardized templates to enhance subrecipient oversight, monitoring, and documentation. • Note: Questioned costs unwarranted as no tests conducted on state-level expenditures. 9/30/2026 Mr. Marcus Samo, Secretary of FSMNG Health Email: marcus.samu@fsmhealth.gov.fm
• Monitor submission of SF-425 reports quarterly via staff meetings to ensure timely and accurate filing. • Enhance file maintenance for deeper reviews and accessibility. • Note: Re-review located 100% of cited "missing" reports; underlying support was available. Tagging is not mandatory. 9/30/2026 ...
• Monitor submission of SF-425 reports quarterly via staff meetings to ensure timely and accurate filing. • Enhance file maintenance for deeper reviews and accessibility. • Note: Re-review located 100% of cited "missing" reports; underlying support was available. Tagging is not mandatory. 9/30/2026 Ms. Senny Phillip, Asst. Secretary of Investment & International Financing Email: senny.phillip@gov.fm
• Strengthen monitoring controls to verify period of performance, including obligation/incurrence and liquidation timelines. • Collaborate with grantors to clarify and document allowable liquidation periods for drawdowns. • Implement systematic filing of supporting documents for easy retrieval. • No...
• Strengthen monitoring controls to verify period of performance, including obligation/incurrence and liquidation timelines. • Collaborate with grantors to clarify and document allowable liquidation periods for drawdowns. • Implement systematic filing of supporting documents for easy retrieval. • Note: Drawdowns conducted in close collaboration with grantors, confirming compliance with agreed terms. 9/30/2026 Ms. Senny Phillip, Asst. Secretary of Investment & International Financing Email: senny.phillip@gov.fm
• Review all files for completeness before submission to auditors starting FY2024 onward. • Enhance systematic filing and accessibility of drawdown reports and supporting documentation. • Note: Re-review located >90% of cited "missing" documents; underlying support was available. Tagging is not mand...
• Review all files for completeness before submission to auditors starting FY2024 onward. • Enhance systematic filing and accessibility of drawdown reports and supporting documentation. • Note: Re-review located >90% of cited "missing" documents; underlying support was available. Tagging is not mandatory. 12/15/25 (SPAF submitted) / Ongoing 09/30/26 Ms. Christina Elnei, Asst. Secretary of National Treasury Email: christina.elnei@dofa.gov.fm
Disagree with adverse compliance opinion and findings, as auditors applied Uniform Guidance (2 CFR Part 200) requirements, which are inapplicable to Compact sector grants (ALN 15.875) governed exclusively by the Compact of Free Association, as amended, and the Fiscal Procedures Agreement (FPA). • Re...
Disagree with adverse compliance opinion and findings, as auditors applied Uniform Guidance (2 CFR Part 200) requirements, which are inapplicable to Compact sector grants (ALN 15.875) governed exclusively by the Compact of Free Association, as amended, and the Fiscal Procedures Agreement (FPA). • Request U.S. Department of the Interior, Office of Insular Affairs, to disregard these findings for grant administration and questioned costs resolution, as they do not reflect noncompliance with Compact/FPA standards. • Maintain commitment to accountability under Compact/FPA standards. 9/30/2026 Ms. Christina Elnei, Asst. Secretary of National Treasury (primary contact) Email: christina.elnei@dofa.gov.fm
Disagree with adverse compliance opinion and findings, as auditors applied Uniform Guidance (2 CFR Part 200) requirements, which are inapplicable to Compact sector grants (ALN 15.875) governed exclusively by the Compact of Free Association, as amended, and the Fiscal Procedures Agreement (FPA). • Re...
Disagree with adverse compliance opinion and findings, as auditors applied Uniform Guidance (2 CFR Part 200) requirements, which are inapplicable to Compact sector grants (ALN 15.875) governed exclusively by the Compact of Free Association, as amended, and the Fiscal Procedures Agreement (FPA). • Request U.S. Department of the Interior, Office of Insular Affairs, to disregard these findings for grant administration and questioned costs resolution, as they do not reflect noncompliance with Compact/FPA standards. • Maintain commitment to accountability under Compact/FPA standards. 9/30/2026 Ms. Christina Elnei, Asst. Secretary of National Treasury (primary contact) Email: christina.elnei@dofa.gov.fm
2023-003 ALLOWABLE ACTIVITIES AND ALLOWABLE COSTS - SIGNIFICANT DEFICIENCY Federal Program Emergency Rental Assistance ALN 21.023; passed through the County of Berks. Condition/Cause For 23 out of 60 cases tested, the amount paid for rent or utilities did not agree to a lease agreement or bills on f...
2023-003 ALLOWABLE ACTIVITIES AND ALLOWABLE COSTS - SIGNIFICANT DEFICIENCY Federal Program Emergency Rental Assistance ALN 21.023; passed through the County of Berks. Condition/Cause For 23 out of 60 cases tested, the amount paid for rent or utilities did not agree to a lease agreement or bills on file for the following reasons: (I) clerical errors, (2) duplicate payments due to multiple staff working on the same file, or (3) failure to request or maintain support before payment was made. Known questioned costs associated with the 23 exceptions noted in our testing were $9,867. Based on the projection of the sampling results to the remaining population, we project additional likely questioned costs of approximately $173,400. The Authority did not have controls in place to detect the noncompliance prior to issuing payments. We recommend the Authority revisit and strengthen internal controls over tracking individual payments for transactions entered as batches, particularly when related to federal awards. We encourage the Authority to continue working to identify the individual transactions making up the remainder of the federal expenditures under this program. We also recommend the Authority revisit and strengthen internal controls over allowable activities and allowable costs related to grant programs. Management Response The Authority launched the Emergency Rental Assistance Program (ERAP) with little administrative guidance from the U.S. Treasury. The Authority contracted with the Berks Coalition to End Homelessness (BCEH) to undertake various aspects of the Emergency Rental Assistance Program and in the late fall of 2021, the Authority began reviewing all case documentation provided by BCEH. This review eliminated the vast majority of the errors noted. The Authority also updated case documentation checklists as well as provided training for staff involved with ERAP. Current Status of Corrective Action Plan The Authority has resolved this finding. An additional review was added at the close of each case.
2023-001 REPORTING - SIGNIFICANT DEFICIENCY Federal Program Community Development Block Grant/Entitlement Grant ALN 14.218; passed through the County of Berks Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause The auditee did not have any documented or impleme...
2023-001 REPORTING - SIGNIFICANT DEFICIENCY Federal Program Community Development Block Grant/Entitlement Grant ALN 14.218; passed through the County of Berks Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause The auditee did not have any documented or implemented internal controls over the review of federal program reporting requirements. Reports were prepared and submitted without documentation of supervisory review or verification of accuracy and completeness. Management did not design or implement procedures to review reports prior to submission, relying solely on the preparer's knowledge without formal oversight. Recommendation We recommend that all grant reports are reviewed by a person independent of the preparer who has knowledge of the grant requirements. This review should include comparing the amounts reported to detailed support for accuracy. We also recommend the Authority review its recordkeeping procedures for documentation related to grant reporting. There should be a process in place to ensure all required documentation is maintained and filed in an orderly system that allows the Authority to locate and provide documentation when required. Management Response In general, management agrees with the finding. It should be noted that internal controls for supervisory review of reporting requirements were in place but were not written controls or processes. Reporting for the CDBG Program is accomplished through the preparation of the annual Comprehensive Annual Performance and Evaluation Repo11 CAPER). Written policies and procedures for the CAPER have been developed. Reporting for the Emergency Rental Assistance Program is accomplished through an online reporting system of the U.S. Treasury and by email to the Pennsylvania Human Services Department. Written policies and procedures have been developed.
Schools and Roads - Grants to States (Compliance) We recommend that the County establish and implement formal procedures to ensure public notices related to Title III funds are issued and documented at least 45 days prior to any obligation or expenditure. This process should include clear assignment...
Schools and Roads - Grants to States (Compliance) We recommend that the County establish and implement formal procedures to ensure public notices related to Title III funds are issued and documented at least 45 days prior to any obligation or expenditure. This process should include clear assignment of responsibilities and retention of documentation as part of grant compliance records. Management's Response: The County concurs with the findings. Responsible Individual: Allen Hisky, Clerk of the Board of Supervisors; Corrective Action Plan: The Clerk of the Board will ensure that sufficient internal controls are in place for proper notification of Public Hearings at least 45 days proper to obligation or expenditures. This process should include clear assignment of responsibilities and retention of documentation as part of grant compliance records; Anticipated Completion Date: June 30, 2026.
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Compliance) We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Management's Response: The County concurs with the fi...
Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Compliance) We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Management's Response: The County concurs with the findings; Responsible Individual: Nicole Reinert, Public Health Director; Corrective Action Plan: Administrative staff will schedule out all required report dates in the Outlook calendar at least three weeks before the due date to keep responsible parties informed of deadlines. These set reminders will ensure timely submissions. The Department Head will review the submission process to eliminate congested workflow to ensure efficiency and identify any tasks that can be automated or improved. Regular check-ins will take place to discuss the status of ongoing reports.; Anticipated Completion Date: June 30, 2026.
Schools and Roads - Grants to States (Compliance) We recommend that the County establish internal control procedures to ensure that required certifications for Title III expenditures and unobligated funds are completed, reviewed, and submitted timely in accordance with federal requirements. Manageme...
Schools and Roads - Grants to States (Compliance) We recommend that the County establish internal control procedures to ensure that required certifications for Title III expenditures and unobligated funds are completed, reviewed, and submitted timely in accordance with federal requirements. Management's Response: The County concurs with the findings. Responsible Individual: Allen Hisky, Clerk of the board of Supervisors; Corrective Action Plan: The Clerk of the Board will ensure that sufficient internal controls are in place for proper notification of Certification Title III Expenditures and Unobligated Funds by statutory deadline. This process should include clear assignment to responsibilities and retention of documentation as part of grant compliance records.; Anticipated Completion Date: June 30, 2026.
The County will ensure vendors are not suspended or debarred in the future.
The County will ensure vendors are not suspended or debarred in the future.
The County will implement a new policy to ensure all subrecipients that are given federal funds of $25,000 or more are properly monitored.
The County will implement a new policy to ensure all subrecipients that are given federal funds of $25,000 or more are properly monitored.
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