Corrective Action Plans

Finding 1156463 (2024-001)

Material Weakness 2024

King County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contra...

The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contract requests through established King County Procurement processes, and timelines to submit similar requests through central procurement with sufficient time to allow central procurement to perform all the necessary legal and compliance checks necessary for the associated transactions. After initial training, all existing key personnel will receive repeat training every 2 years; all new staff will receive training as part of onboarding procedures.

View Audit 368796

Finding 1156460 (2024-001)

Material Weakness 2024

Power Forward Communities, Inc.

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.180

Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will streng...

Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will strengthen its internal controls around debarment checks for vendors in both its procurement and contracting processes to address the finding as follows: Procurement • PFC will use a process checklist for its procurements, similar to the checklist PFC developed for its coalition members. • The checklist will include an additional step for a debarment search on SAM.gov and require internal confirmation and documentation that this debarment check is valid. • This process checklist will be reviewed and signed off when complete by PFC management for each procurement. • PFC will include completed checklists to accompany each procurement memo. Contracting • PFC will continue including debarment language in each of its vendor contracts to ensure adherence to 2 CFR Section 180.300. • For vendors with contracts above $25,000, PFC will implement quality control by running a debarment search twice annually, once in June and once in December every year. This documentation will be saved to the vendor file.

View Audit 368780

Finding 1156452 (2024-001)

Material Weakness 2024

Unleashing Potential

MO

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.430

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hour...

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hours incurred compared to the estimated amounts by individuals assigned to federal grant programs prior to requesting reimbursement from the funding course. The review will be performed by an individual other than the preparer of the reimbursement request, with knowledge of the federal grant program and will be formally documented.

View Audit 368766

Finding 1156451 (2024-001)

Material Weakness 2024

Illinois Network of Charter Schools

IL

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member ...

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member - the CSP Grant Manager - to oversee FFATA reporting and maintain a comprehensive log of all qualifying subawards. The CSP Grant Manager will provide training to finance and grants management staff on FFATA reporting requirements and timelines. Joyanna Smith, CPOO, will conduct monthly reviews of subaward activity to ensure all required reporting is completed by the end of the month following the obligation date. FFATA reporting will be incorporated into INCS’s quarterly internal compliance monitoring process to sustain ongoing compliance.

View Audit 368752

Finding 1156392 (2024-001)

Material Weakness 2024

Liberty Terrace Apartments

IN

HUD Housing Programs Questioned Costs Special Tests & Provisions

Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on...

Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on the Finding: The Corporation concurs with the recommendation and will make the deposit to fully fund the reserve for replacements fund.

View Audit 368702 Questioned Costs: $1

Finding 1156380 (2024-005)

Material Weakness 2024

9/11 Day

CA

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303 § 200.332

The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Can...

The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Candid and Charity Navigator. Financial statements were also reviewed, but documentation of these reviews and verifications was not consistently retained, and certain federal requirements were not fully incorporated into the process. 9/11 Day has now adopted a written policy that ensures that, in its role as a pass-through entity, all subgrants will be made in full compliance with the minimum required elements found under 2 CFR 200.332(b). This shall include implementing a comprehensive tracking and monitoring system for all subgrantees, regardless of funding level, with enhanced verification requirements for those receiving over $30,000. All subaward agreements will be updated to include the minimum required elements under 2 CFR 200.332(b), and the evaluation of subgrantee risk will incorporate all suggested elements under 2 CFR 200.332(c), including consideration of fraud risk and risk of noncompliance. The system will record the time and date of all eligibility verifications and retain supporting documentation, including MOUs, SAM.gov confirmation of suspension and debarment status, IRS Form 990s, financial statements, and audit confirmations. In compliance with 2 CFR 200.332(e)(1), subgrantees will now be required to submit both performance and financial reports, which will be reviewed and compared against project budgets. In addition, 9/11 Day will evaluate subgrantees’ Single Audits, if filed, in accordance with 2 CFR 200.332(e)(2)–(4) and will review any reported deficiencies. All monitoring activities will be documented and logged throughout the life of each project to ensure stronger oversight, complete documentation, and compliance with federal requirements.

View Audit 368692

Finding 1156379 (2024-004)

Material Weakness 2024

9/11 Day

CA

Questioned Costs Subrecipient Monitoring Reporting § 200.303 § 200.328 § 200.329

In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a ...

In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a centralized tracking log, and for those receiving pass-through funds exceeding $30,000, the required reporting will be completed directly in SAM.gov, which now includes the Federal Subaward Reporting System (FSRS). Each subgrantee’s eligibility will be verified in SAM.gov, with the date and results of the verification recorded, and all supporting documentation retained on file. This corrective action ensures that all subawards are properly logged, reported, and compliant with FFATA requirements.

View Audit 368692 Questioned Costs: $1

Finding 1156359 (2024-001)

Material Weakness 2024

City of Seattle

WA

Subrecipient Monitoring

Human Services Department (HSD) HSD acknowledges this finding. While the Department successfully tracked, collected, reviewed, and issued management decision letters to its subrecipients as a standard practice. In this instance a formal management decision was missed for this specific sub-recipient ...

Human Services Department (HSD) HSD acknowledges this finding. While the Department successfully tracked, collected, reviewed, and issued management decision letters to its subrecipients as a standard practice. In this instance a formal management decision was missed for this specific sub-recipient during the review period. The Department has taken corrective measures to strengthen its compliance process, clarify roles and responsibilities to ensure timely completion of this requirement. Office of Economic Development (OED) OED acknowledges this finding. OED intends to take corrective measures through strengthening internal controls over subrecipient single audit monitoring: • Including a step in our internal monitoring processes to document when Program Managers pull and review single audits with federally funded partners • Retaining a monitoring workbook to track and date collection of single audit reports Office of Housing (OH) • OH acknowledges that neither a review of applicable audits nor management decision was sent to subrecipients who had audit findings. OH staff will evaluate its current policies to determine the best way to identify, review and follow-up on any subrecipient audits that may include findings. This review will include appropriate written follow up on actions OH recommends the subrecipient to take to correct the finding(s).

View Audit 368642

Finding 1156356 (2024-002)

Material Weakness 2024

City of Seattle

WA

Subrecipient Monitoring Reporting

The Human Services Department (HSD) acknowledges this finding regarding the late submission of five FFATA reports and inaccuracies in CAPER reporting. These issues arose during a period of prolonged vacancies and while staff were in the process of being trained on reporting requirements, which reduc...

The Human Services Department (HSD) acknowledges this finding regarding the late submission of five FFATA reports and inaccuracies in CAPER reporting. These issues arose during a period of prolonged vacancies and while staff were in the process of being trained on reporting requirements, which reduced oversight capacity and contributed to delays and errors. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. HSD updated department-wide FFATA Reporting Policies and Procedures following the federal transition to SAM.gov. Staff completed federal training, and prior reports were reviewed and corrected. The Department implemented controls to close workflow gaps to ensure obligations and data corrections are captured before submission. Additionally, ongoing training is being provided to reinforce compliance. These actions strengthen internal controls and are intended to ensure FFATA and CAPER reports are accurate, complete, and submitted in a timely manner moving forward.

View Audit 368642

Finding 1156352 (2024-003)

Material Weakness 2024

City of Seattle

WA

Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs

The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of co...

The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of contracting with a third-party vendor to complete its annual inspections, including HOME inspections for 2025. The contractor will inspect HUD’s NSPIRE level. With this additional support, OH anticipates it will have the capacity to see that corrections have been completed and documented consistent with the HOME program requirements.

View Audit 368642

Finding 1156346 (2024-004)

Material Weakness 2024

City of Seattle

WA

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

The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) M...

The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. The contract specialist receives structured management oversight and ongoing training to strengthen capacity for accurate budget monitoring. In July 2025, the FGMU updated its ESG policies and procedures to incorporate improved controls for earmarking. In addition, the Department has instituted regular training sessions for all staff responsible for federal grant management to reinforce compliance with earmarking and other federal requirements. These corrective actions are designed to strengthen internal controls, provide clearer oversight, and ensure that future expenditures remain within established budget and earmarking limits.

View Audit 368642

Finding 1156330 (2024-010)

Material Weakness 2024

McR Health, Inc.

FL

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

MCR has established a procedure to require a completed application with signature and supporting documentation in order to qualify for a sliding fee scale. Any incomplete applications or those with incomes greater than 200% of the poverty level will only result in consideration for courtesy discount...

MCR has established a procedure to require a completed application with signature and supporting documentation in order to qualify for a sliding fee scale. Any incomplete applications or those with incomes greater than 200% of the poverty level will only result in consideration for courtesy discount. Financial counselors have 7 business days from the return of a patient application to determine completeness and eligibity for sliding fee scale. The Chief Financial Officer, Kara Onorato, will be responsible for ensuring that this process is followed. This revised process will be put in place on October 1, 2025.

View Audit 368617 Questioned Costs: $1

Finding 1156316 (2024-004)

Material Weakness 2024

Henry Ford Health System

MI

Subrecipient Monitoring

Finding 2024-004 Significant Deficiency in Controls over Compliance and Noncompliance - Reporting Federal Program: 93.137 Community Programs to Improve Minority Health Year: 2024 Federal Agency: Department of Health and Human Services Condition - A total of $910,157 of costs was passed through to se...

Finding 2024-004 Significant Deficiency in Controls over Compliance and Noncompliance - Reporting Federal Program: 93.137 Community Programs to Improve Minority Health Year: 2024 Federal Agency: Department of Health and Human Services Condition - A total of $910,157 of costs was passed through to selected sub recipients during the year and the subawards were not reported in the FSRS. Corrective Action Plan – Henry Ford Health agrees with this finding and has created a workgroup to ensure that current information on FSRS is accurate and to also to clarify responsibility for ongoing reporting and review of subrecipient disclosure requirements to ensure timeliness and accuracy. Anticipated Completion Date – December 31, 2025. Contact Person – J. Douglas Clark, Senior Vice President and Chief Accounting Officer.

View Audit 368602

Finding 1156310 (2024-002)

Material Weakness 2024

Wilcox County Board of Education

AL

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ...

The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ensure all employees' salary schedules are updated when we process the system-wide update. We will have an additional person to review and sign the new salary schedules before the first payroll is processed in the new fiscal year.

View Audit 368582

Finding 1156309 (2024-001)

Material Weakness 2024

Wilcox County Board of Education

AL

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ...

The Board of Education has acknowledged the finding and has agreed to the finding. We have reviewed the affected payroll records and confirmed the underpayment. We have issued a check to pay the difference owed to the employee. At fiscal year end, we will implement a more detailed review process to ensure all employees' salary schedules are updated when we process the system-wide update. We will have an additional person to review and sign the new salary schedules before the first payroll is processed in the new fiscal year.

View Audit 368582

Finding 1156308 (2024-003)

Material Weakness 2024

Northshore University Healthsystem

IL

Subrecipient Monitoring Questioned Costs Cash Management § 200.303 § 200.305

Finding 2024-003 – Subrecipient Cash ManagementAssistance Listing No.: MultipleThe Office of Sponsored Programs ( OSP) will address the recommendation and review its current processes, policies, and procedures to minimize the time between invoice receipt and the transfer of federal funds to the subr...

Finding 2024-003 – Subrecipient Cash ManagementAssistance Listing No.: MultipleThe Office of Sponsored Programs ( OSP) will address the recommendation and review its current processes, policies, and procedures to minimize the time between invoice receipt and the transfer of federal funds to the subrecipient. This includes implementation of the following preventative controls to ensure that payments are made within the required timeline: a. Active communications with Principal Investigators of subawards on invoice approval timeline at award initiation and creation of procedures for documenting and advising OSP of invoices requiring correction and /or modification. b. Work with Post Award Staff to ensure that adequate documentation is created and maintained related to the follow-up that occurs when issues are being investigated and resolved that cause a delay in invoice processing.c. Development and utilization of a report for internal reporting and tracking of pending sub-invoices payments approaching the 30-day deadline. d. Implementation of the Invoice Receipt Date as a required field for subaward invoicing in Workday rather than the optional field it is at present. Responsible Official: Cate Ekstrom, Director of Research

View Audit 368577

Finding 1156235 (2024-002)

Material Weakness 2024

Northshore University Healthsystem

IL

Subrecipient Monitoring

Finding 2024-002 – Subrecipient MonitoringAssistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)Management will implement the established Research procedures for subrecipient risk assessments in accordance with Uniform Guidance Section 200.332(b)....

Finding 2024-002 – Subrecipient MonitoringAssistance Listing No.: 93.323, COVID-19 Epidemiology and Laboratory Capacity for Infectious Diseases (ELC)Management will implement the established Research procedures for subrecipient risk assessments in accordance with Uniform Guidance Section 200.332(b). Update the Research subrecipient monitoring checklist and use the subrecipient forms. This approach will be applied to all new subrecipient relationships starting in 2025 and beyond. Additionally, management will collaborate with Endeavor Health's legal, finance, and compliance teams to assess current processes and make any necessary corrections to improve the review and documentation of results going forward.Responsible Officials: Ashlee Jean Roffe, Director of Nutrition and Community Health, Community CARE

View Audit 368577

Finding 1156140 (2024-001)

Material Weakness 2024

The Baltimore Station, Inc.

MD

Reporting Subrecipient Monitoring

1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accura...

1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accuracy prior to submission. 3. Assigned dedicated staff oversight for federal financial reporting, with cross-training implemented to strengthen continuity and mitigate risk in the event of staff turnover. 4. Conducted periodic evaluations of the reporting process, incorporating feedback and lessons learned from prior submissions, monitoring visits, and audit findings to drive ongoing improvements. 5. Reviewed and updated internal financial policies and procedures to align with current federal reporting requirements and best practices, with updates formally documented and disseminated to staff.

View Audit 368562

Finding 1156127 (2024-004)

Material Weakness 2024

Karen Organization of Minnesota

MN

Questioned Costs Subrecipient Monitoring

Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing No. 93.566 Recommendation: Auditor recommends that KOM review the various subrecipient requirements with the individuals involved in this process to ensure they understand the requirements. Explanation...

Refugee and Entrant Assistance State/Replacement Designee Administered Programs Assistance Listing No. 93.566 Recommendation: Auditor recommends that KOM review the various subrecipient requirements with the individuals involved in this process to ensure they understand the requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: While there is no disagreement with the finding, the finding was first identified after the referenced grant had already expired. The subsequent response to the finding and its remedy have since addressed this issue. This finding was identified in the 2023 single audit presented to the Organization’s Board of Directors in October 2024. The federal award referenced in this finding expired on September 30, 2024. The Organization adjusted subaward agreement templates to include subrecipients’ UEI, federal assistance listings numbers and titles, and dollar amounts made available under the federal award. The Organization has ensured that all federal subaward agreements signed on or after October 1, 2024, include the required information. Name(s) of the contact person(s) responsible for corrective action Eh Tah Khu, Co- Executive Director Planned completion date for corrective action plan: October 2024

View Audit 368547 Questioned Costs: $1

Finding 1156016 (2024-001)

Material Weakness 2024

Hamilton County Economic Development Corporation

IN

Subrecipient Monitoring § 200.331 § 200.332 § 200.521

Corrective Action Plan – Hamilton County Economic Development Corporation (dba Invest Hamilton County) Public Accounting Firm CliftonLarsonAllen LLP Audit Period Year ended December 31, 2024 The finding from the December 31, 2024 consolidated schedule of findings is discussed below. The findings is ...

Corrective Action Plan – Hamilton County Economic Development Corporation (dba Invest Hamilton County) Public Accounting Firm CliftonLarsonAllen LLP Audit Period Year ended December 31, 2024 The finding from the December 31, 2024 consolidated schedule of findings is discussed below. The findings is numbered consistently with the numbers assigned in the schedule. Section III 2024-001: Condition: The Organization did not clearly communicate the required federal award information and applicable requirements to the subrecipients. The Organization did not evaluate the risk of non-compliance of the subrecipients in order to identify the appropriate monitoring procedures. Statistical sampling was not used in making sample selections. Response: The response to this finding in 2023 was provided less than one month prior to the end of the grant activity period, and therefore adaptation to the management period was not feasible for this project. The Organizations’ Board and Chief Executive OMicer (CEO) and key HCEDC StaM recognize the need to further refine subrecipient monitoring. Subrecipients within the identified project are all school districts already under single audit with associated levels of financial controls and reporting. Participating districts, via their appropriate elected boards, were informed the conditions of the grant and individually voted to accept obligations and requirements. HCEDC management, in alignment with outsourced controller services via CliftonLarsonAllen LLP, have now further increased controls and monitoring activity. Through the onboarding of a new Grants Management System (GMS) in Fall 2024, subrecipient monitoring activity and profiles are now created for each eligible award. In 2024 and 2025, the HCEDC has also been much more active in communicating reporting and grants management requirements to subrecipients, including multiple amendments to the ESSER grant program. The new GMS system is built specifically to assist organizations with single audit compliance and has multiple features specific to subrecipient reporting and monitoring. If there are any questions regarding this plan, please contact the undersigned at 317-663-4457. Mike Thibideau PRESIDENT & CEO – INVEST HAMILTON COUNTY 37 East Main Street Carmel, IN 46032

View Audit 368523

Finding 1156013 (2024-001)

Material Weakness 2024

The Healthcare Connection INC

OH

Special Tests & Provisions Questioned Costs Subrecipient Monitoring

93.224/93.527 - Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Recommendation: We recommend that management continue to educate front des...

93.224/93.527 - Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Recommendation: We recommend that management continue to educate front desk and intake staff on the importance of the required patient application documentation and review of support before applying a sliding fee adjustment to the patient account. In addition, we suggest management establish a policy to perform regular monitoring of sample patient file fee applications and to document the results. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: Management of the Organization agrees with the above finding and recommendations and has established a system on internal monitoring, on a random, basis of sliding fee discounts applied by front desk staff. Name(s) of the contact person(s) responsible for corrective action: Jolene Joseph Planned completion date for corrective action plan: December 31, 2025.

View Audit 368497

Finding 1155988 (2024-002)

Material Weakness 2024

City of Richmond

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2024-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number and Year(o...

FINDING 2024-002 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Number and Year(or Other Identifying Numbers): FY2021 Pass-Through Entity: Direct Grant Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Other Matters Condition Prior to entering into subawards and covered transactions with State and Local Fiscal Recovery Funds (SLFRF) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a non-procurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with the executives of a prospective vendor. A sample of five covered transactions, totaling $667,753, that equaled or exceeded $25,000 paid from SLFRF funds was selected for testing. For one of the transactions tested in the amount of $98,583, the City did not retain documentation showing that they verified that the vendor was not suspended or debarred from receiving federal funds prior to issuing the payment. Context The City had not designed or implemented effective policies and procedures to verify that contractors were not suspended or debarred, or otherwise excluded from participating in federal programs prior to entering into covered transactions using SLFRF funds. While a control process was in place, it did not ensure that all vendors were not suspended or debarred from receipt of federal grant funds for goods and services. Contact Person Responsible for Corrective Action: Tracy McGinnis - Controller Contact Phone Number and Email Address: 765-983-7222; tmcginnis@richmondindiana.gov Views of Responsible Officials: We concur with the finding. INDIANA STATE BOARD OF ACCOUNTS 24 Description of Corrective Action Plan: The City will include a suspension and debarment clause into our federal contracts with vendors receiving federal funds going forward. Responsible Party and Timeline for Completion: The Controller, Deputy Controller and the Director of Strategic Initiatives will collaborate on a process for the Corrective Action to be implemented in January 2026 for the next fiscal year.

View Audit 368457

Finding 1155982 (2024-001)

Material Weakness 2024

Borincana Foundation, Inc.

PR

Subrecipient Monitoring Internal Control / Segregation of Duties HUD Housing Programs § 200.328

Federal Program: Community Development Block Grant – Disaster Recovery (CDBG-DR) (ALN 14.228) Condition: Untimely submission of monthly progress reports. Planned Corrective Action: Management acknowledges the finding related to the timeliness of monthly report submissions. Although reports were prep...

Federal Program: Community Development Block Grant – Disaster Recovery (CDBG-DR) (ALN 14.228) Condition: Untimely submission of monthly progress reports. Planned Corrective Action: Management acknowledges the finding related to the timeliness of monthly report submissions. Although reports were prepared internally by the required due date, submission to the PRDOH reporting system was delayed pending review and approval of the prior month’s report by PRDOH . To strengthen compliance with reporting requirements, the Organization will implement the following corrective actions: • Internal documentation: Maintain dated copies of all monthly reports prepared by the 5th day following the reporting period to demonstrate timely preparation. • Communication with PRDOH: Retain written communications with PRDOH when reports cannot be submitted due to pending approvals, documenting the cause of delay. • Formal request: Submit a written request to PRDOH seeking clarification of reporting requirements and advocating for a process that permits timely submission regardless of system approval delays. • Monitoring: assign responsibility to the Finance and Compliance Officer to track reporting deadlines and ensure documentation of both preparation and submission efforts. Responsible Official: Thomas P. King Anticipated Completion Date: Ongoing – procedures to be implemented beginning with reports due for October 2025.

View Audit 368421

Finding 1155981 (2024-001)

Material Weakness 2024

City of Bothell

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

The City takes its responsibility to safeguard public funds seriously and is committed to improving internal controls over grant management that affect the City’s ability to comply with federal regulations. The City’s decentralized model for procurement and grant management has created challenges to...

The City takes its responsibility to safeguard public funds seriously and is committed to improving internal controls over grant management that affect the City’s ability to comply with federal regulations. The City’s decentralized model for procurement and grant management has created challenges to meet federal compliance requirements. The City is committed to safeguarding public funds while meeting the needs of residents. A full-time analyst has already been hired to oversee SLFRF funds and assist staff with meeting compliance requirements. A full-time Contracts and Procurement Officer has also been hired to train staff and update the City’s procurement policies and procedures. Improving federal compliance will be a primary function of this role. Additional training is being created to educate City staff on federal compliance requirements. The City is currently working with our legal team on options to include suspension and debarment language in contracts, reducing administrative burden on City staff while ensuring compliance. These improvements reflect the City’s commitment to improving internal controls and ensuring that federal funds are managed with the highest level of compliance and accountability.

View Audit 368415

Finding 1155980 (2024-002)

Material Weakness 2024

Town of Darrington

WA

Subrecipient Monitoring

The Town will provide additional training for all employees involved.

View Audit 368401

Corrective Action Plans

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