Corrective Action Plans

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Finding 2025-001: Reporting – Material weakness in internal controls over compliance and compliance finding. Management Response Effective May 12, 2026, the agency enhanced its performance reporting oversight by requiring the Chief of Mission and the Executive Vice President of Victim Services to re...
Finding 2025-001: Reporting – Material weakness in internal controls over compliance and compliance finding. Management Response Effective May 12, 2026, the agency enhanced its performance reporting oversight by requiring the Chief of Mission and the Executive Vice President of Victim Services to review and approve preliminary reports to funding entities drafted by the compliance department, prior to submission. The agency’s compliance department, which consists of a Database Manager, Compliance Manager, and Executive Vice President of Compliance, is tasked with ensuring reliability and validity of client-level database entered in the client database. Monthly, the agency’s compliance department reconciles the number of new and unduplicated participants served by the agency as a whole and within each grant-funded program. The compliance department’s report originator will save the source data electronically, ensuring it matches the official figures submitted to the funding entity. Source data reports will be available upon request by agency staff and/or funders.
Corrective Action Plan Finding No: 2025-002 Condition: During the audit, the City did not verify that the contractor or subcontractor submitted the required certified payrolls for work performed under the federally assisted construction contract. As a result, the City did not maintain or review suff...
Corrective Action Plan Finding No: 2025-002 Condition: During the audit, the City did not verify that the contractor or subcontractor submitted the required certified payrolls for work performed under the federally assisted construction contract. As a result, the City did not maintain or review sufficient documentation to demonstrate compliance with wage rate requirements for all applicable weeks during the audit period. Management’s Plan: The City recognizes the need to improve internal controls related to grant disbursements for labor provided by our contractors. The project this past year included participation from multiple federal funding agencies and payments by the City as well as direct payments to contractors by the funding agencies. We have already added additional procedures and checkpoints to provide for adequate documentation related to certified payrolls. In addition, the City is planning to procure a grant tracking system to automate tracking the details for every project. Anticipated Date of Completion: 12/31/26 Name of Contact Person: Cheri Grieco, Finance Director
Corrective Action Plan Finding No: 2025-001 Condition: During the audit, our procedures indicated that capital expenditures were primarily reviewed at an individual invoice level to determine whether they exceeded the capitalization threshold. We also noted that communication between the City’s fina...
Corrective Action Plan Finding No: 2025-001 Condition: During the audit, our procedures indicated that capital expenditures were primarily reviewed at an individual invoice level to determine whether they exceeded the capitalization threshold. We also noted that communication between the City’s finance department and engineers or other City staff responsible for managing grants and capital projects is not consistently formalized. Management’s Plan: Management is committed to strengthening coordination and oversight of the City’s grant-funded capital projects through centralizing project tracking via grant/project management software, implementing rigorous compliance monitoring, and improving intradepartmental communication. By centralizing our grants through the course of their lifespans, we intend to better track the progress of our grant projects and budgets and with the inclusion of grant document storage, to enhance compliance across departments. We will also designate coordination teams consisting of liaisons across administration, finance, engineering, public works, and grant writers to ensure internal alignment. Anticipated Date of Completion: 4/30/2027 Name of Contact Person: Cheri Grieco, Finance Director
Management agrees with the finding and acknowledges that internal controls over inventory issuance were not consistently followed by an individual. While procedures existed requiring documentation of pick tickets, compliance with these procedures was not adequately enforced on a small number of tran...
Management agrees with the finding and acknowledges that internal controls over inventory issuance were not consistently followed by an individual. While procedures existed requiring documentation of pick tickets, compliance with these procedures was not adequately enforced on a small number of transactions. The Cooperative has begun strengthening its internal control processes to ensure that all inventory withdrawals are properly authorized and documented prior to release. In addition, management will implement monitoring procedures, including periodic reviews of inventory documentation, to ensure compliance with established controls. Training will also be provided to all relevant personnel to reinforce proper procedures and the importance of adherence to internal control requirements. Management expects these corrective actions to be fully implemented by May 15, 2026.
Finding summary – Patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization’s policy. Corrective Action Planned – 1. Crossing has implemented a billing workflow to automatically apply sliding fee scale discounts to all eligi...
Finding summary – Patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization’s policy. Corrective Action Planned – 1. Crossing has implemented a billing workflow to automatically apply sliding fee scale discounts to all eligible self-pay accounts during the billing process, eliminating manual charge adjustments and improving consistency with established guidelines. 2. All billing staff have received retraining on the correct manual posting procedures for sliding fee scale adjustments after insurance payment, ensuring compliance with patient income verification and applicable percentage guidelines. 3. We will continue ongoing monitoring and review of accounts receiving sliding fee scale adjustments to ensure accurate and compliant application of the approved discount and percentages. Anticipated Completion Date – Completed 4/1/2026 Responsible Contact Person – Margret Guy, Director of Revenue; Julie Brilley, CEO Management Response - Management concurs with the auditor's finding. The Organization acknowledges that patients received sliding fee discounts that were inconsistent with the stated sliding fee discount categories under the Organization’s policy. The corrective action plan has been successfully implemented and will be monitored regularly to ensure compliance.
Condition: Suspension and debarment compliance was not verified for nine covered transactions. Corrective Action Plan: The Town will verify that all vendors paid with ARPA (SLFRF) funds are not suspended or debarred by checking sam.gov prior to payment. Documentation of the verification will be reta...
Condition: Suspension and debarment compliance was not verified for nine covered transactions. Corrective Action Plan: The Town will verify that all vendors paid with ARPA (SLFRF) funds are not suspended or debarred by checking sam.gov prior to payment. Documentation of the verification will be retained with the supporting payment records. Anticipated Completion Date: June 30, 2026 Contact Information: Eric A. Kinsherf, CPA, Town Accountant
The Board of County Commissioners have hired a grant administrator to assist with the reporting process. We will ensure that the reports are accurate and reported in the proper period.
The Board of County Commissioners have hired a grant administrator to assist with the reporting process. We will ensure that the reports are accurate and reported in the proper period.
The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that Comanche County receives to ensure that proper internal controls are implemented.
The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that Comanche County receives to ensure that proper internal controls are implemented.
The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.
The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.
2025-002 Cash Management Corrective action planned: Management will implement controls over all draws from the Payment Management System to minimize the time elapsed between the drawdown of funds from PMS and the payment for expenditures. The controls will incorporate the following: Prepare a detail...
2025-002 Cash Management Corrective action planned: Management will implement controls over all draws from the Payment Management System to minimize the time elapsed between the drawdown of funds from PMS and the payment for expenditures. The controls will incorporate the following: Prepare a detailed listing of expenditures claimed for reimbursement for each drawdown request. The expenditures listing will be reviewed by appropriate personnel to ensure cash payments for the expenditure are made before the date of the draw or within a reasonable time after the draw. Drawdowns are authorized and approved by the appropriate personnel before the drawdown is made and will be tracked and summarized in a ledger. Anticipated completion date: June 2026 Contact person responsible for corrective action: Harjeet Sidhu, Chief Financial Officer
Finding Number: 2025-001 Condition: The City did not have established written cash management procedures for processing of federal payments. Planned Corrective Action: Develop and implement written Cash Managament Procedure for processing federal payments Contact person responsible for corrective ac...
Finding Number: 2025-001 Condition: The City did not have established written cash management procedures for processing of federal payments. Planned Corrective Action: Develop and implement written Cash Managament Procedure for processing federal payments Contact person responsible for corrective action: Benjamin Grier Anticipated Completion Date: 05/22/2026
Finding Number: 2025-001 Recommendation: Inform subrecipients of the required federal award info outlined in § 200.332 Requirements for pass-through entities. Action Taken: 1. Corrective Action was put into place in July of 2025 with the following changes. 2. In FY2025, AANA posted on its MAST websi...
Finding Number: 2025-001 Recommendation: Inform subrecipients of the required federal award info outlined in § 200.332 Requirements for pass-through entities. Action Taken: 1. Corrective Action was put into place in July of 2025 with the following changes. 2. In FY2025, AANA posted on its MAST website and application that: “The MAST program is funded by the United States Federal Government and is subject to all applicable federal statutes, regulations, and requirements. The receiving entity is not debarred, suspended, or otherwise excluded from using federal funds.” 3. AANA has included the following as a footnote on any MAST manuscripts and printed text: “Supported by a grant administered by The Arthroscopy Association of North America (AANA), with funding provided by the Military Advanced Surgical Treatment (MAST) Program.” 4. We are requesting the following information through the contracting process with any MAST Subrecipient: a. Subrecipient's name (must match the name associated with its unique entity identifier) b. Subrecipient's unique entity identifier c. Subaward Period of Performance Start and End Date d. Subaward Budget Period Start and End Date e. Amount of Federal Funds Obligated in the subaward f. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity, including the current financial obligation g. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity h. Federal award project description, as required by the Federal Funding Accountability and Transparency Act (FFATA) i. Identification of whether the Federal award is for research and development j. Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with § 200.414) i. An approved indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, a pass-through entity must determine the appropriate rate in collaboration with the subrecipient. The indirect cost rate may be either: 1. An indirect cost rate negotiated between the pass-through entity and the subrecipient. These rates may be based on a prior negotiated rate between a different pass-through entity and the subrecipient, in which case the passthrough entity is not required to collect information justifying the rate but may elect to do so; or 2. The de minimis indirect cost rate. k. A requirement that the subrecipient permit the pass-through entity and auditors to access the subrecipient's records and financial statements for the pass-through entity to fulfill its monitoring requirements l. Verify that a subrecipient is audited as required m. This corrective action went into effect in July 2025, as a result of the timing, the condition resulting in the corrective action continued to exist in part of the period under audit. Responsible Contact Person for Planned Corrective Action: Dennis Siena Actual Completion Date: July 1, 2025
Management's View and Corrective Action Plan Audit Finding for the Year Ended December 31, 2025 2025-001 – Schedule of Expenditures of Federal Awards Reporting Significant Deficiency - Community Development Block Grant Cluster Entitlement/Special Purpose Grants Response Management agrees that the Co...
Management's View and Corrective Action Plan Audit Finding for the Year Ended December 31, 2025 2025-001 – Schedule of Expenditures of Federal Awards Reporting Significant Deficiency - Community Development Block Grant Cluster Entitlement/Special Purpose Grants Response Management agrees that the Community Development Block Grant Cluster Entitlement/Special Grant was not identified in the system as federally funded at the time of grant set up in 2024. During the preparation of the prior year Schedule of Expenditures of Federal Awards (“Federal Schedule”), this award was omitted from the Federal Schedule since it was not identified as a federal grant within the grant listings. Management has implemented the following improvements: • Management will confirm federal grants with all government agencies the Association has received grants from each calendar year end • Retrain staff on identification of federal grants • Institute appropriate review procedures of the Federal Schedule Completion date: March 31, 2026 Responsible person contact name: Heather Livernois, Vice President, Finance/Chief Accounting Officer
Corrective Action: The City acknowledges that HUD Cash on Hand reports were not submitted within the required deadline and that FFATA reports were not submitted. The Finance Department had various vacancies during Fiscal Year 2025 which caused resource constraints and caused required reporting to be...
Corrective Action: The City acknowledges that HUD Cash on Hand reports were not submitted within the required deadline and that FFATA reports were not submitted. The Finance Department had various vacancies during Fiscal Year 2025 which caused resource constraints and caused required reporting to be submitted late. Finance also experienced a loss of key staff that would have completed FFATA reporting requirements, current staff were not aware of this reporting requirement. The Finance Department will work on correcting reporting issues related to grant reporting that were mentioned in the finding. Finance department was notified of the required FFATA reporting during audit process. The Finance staff will review the required FFATA reporting and will create a tracking mechanism to ensure proper subrecipient awards are reported in a timely manner when awarded. Finance will also create a tracking mechanism for quarterly HUD Cash on Hand reports to ensure the reporting is completed by the required HUD deadline. Proposed Completion Date: Partially during Fiscal Year ending June 30, 2026, and full correction for Fiscal Year ending June 30, 2027. For any questions regarding Corrective Action Plan, please contact Scott Williams, Director of Finance or Janet Franco, Deputy Director of Finance.
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2025-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring a...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2025-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all bank account balances at each bank remain below the FDIC limit. ACTION TAKEN The Project will be monitoring bank accounts more frequently throughout the year and has been restructuring the bank accounts ensure bank balances do not exceed the FDIC limit.
Finding Number: 2025-004 Condition: All disbursements need either an approved invoice or credit card receipt for the amount charged to the grant. Planned Corrective Action: Imagine! will send out a communication to all employees reviewing the current internal control process that requires receipts a...
Finding Number: 2025-004 Condition: All disbursements need either an approved invoice or credit card receipt for the amount charged to the grant. Planned Corrective Action: Imagine! will send out a communication to all employees reviewing the current internal control process that requires receipts and / or invoices from vendors to be attached to credit card disbursements. Employees who do not abide by the process are subject to losing credit card privileges. Contact person responsible for corrective action: Melody Kim Anticipated Completion Date: 7/31/2026
The Organization filed the required reports in 2026.
The Organization filed the required reports in 2026.
Consolidated Health Centers Grant – Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categori...
Consolidated Health Centers Grant – Assistance Listing No. 93.224 & 93.527 Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have found that our electronic medical record (eCW) is automatically classifying the federal poverty level (FPL) for all patients no matter if we have their insurance or household income inputted into the system. This has led to some inaccuracies in the rating of their FPL in eCW. We are actively manually overriding this setting, so we will have full control when to run the FPL after patient information is collected.
See the response at Finding 2025-004 for the history of homes purchased under the Department of Labor’s National Farmworkers Jobs Program and administration of the program. The Organization received the results of the July 2025 program monitoring report by the Department of Labor on March 30, 2026. ...
See the response at Finding 2025-004 for the history of homes purchased under the Department of Labor’s National Farmworkers Jobs Program and administration of the program. The Organization received the results of the July 2025 program monitoring report by the Department of Labor on March 30, 2026. The Organization is currently working to resolve the compliance findings and to provide additional documentation, as requested. Additionally, the Organization is reviewing the monitoring report to determine whether changes to the current grant controls are deemed necessary. In the event that the Department of Labor deems that pre-approval is necessary, adequate pre-obligation workflow procedures will be developed and implemented immediately.
The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.
The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.
The Board of County Commissioners will work with all County Officials to inform them of all grants and federal monies that Pottawatomie County receives to ensure that proper internal controls are implemented.
The Board of County Commissioners will work with all County Officials to inform them of all grants and federal monies that Pottawatomie County receives to ensure that proper internal controls are implemented.
The Board of County Commissioners will work to assess and identify risks to design a written county-wide controls policy over federal grant programs to ensure compliance with grant requirements.
The Board of County Commissioners will work to assess and identify risks to design a written county-wide controls policy over federal grant programs to ensure compliance with grant requirements.
The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consist...
The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consistent with Uniform Guidance requirements, including cost/price analysis and justification for contractor selection, collection and review of Davis-Bacon documentation, including wage determinations and certified payrolls, when applicable, verification that required permits are obtained prior to construction and retention of inspection and completion documentation, and secondary review by City staff to ensure all required documentation is complete prior to project closeout. Additionally, the City will provide training to staff involved in CDBG program administration. Responsible Persons: Community Development Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
The City will update its written procurement procedures to incorporate suspension and debarment review requirements consistent with 2 CFR Part 180 and 2 CFR §200.214. Training will be provided for staff responsible for purchasing and grant administration to ensure compliance with federal requirement...
The City will update its written procurement procedures to incorporate suspension and debarment review requirements consistent with 2 CFR Part 180 and 2 CFR §200.214. Training will be provided for staff responsible for purchasing and grant administration to ensure compliance with federal requirements. Responsible Persons: Police Chief/Finance Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27
2025-003: Allocating Funds to Eligible School Attendance Areas and Schools Condition: The district’s approved Title I application established school-level building allocations under Title I Targeting Step 5 using a per-pupil allocation methodology based on low-income counts. The district should docu...
2025-003: Allocating Funds to Eligible School Attendance Areas and Schools Condition: The district’s approved Title I application established school-level building allocations under Title I Targeting Step 5 using a per-pupil allocation methodology based on low-income counts. The district should document school-level expenditures to verify that the per-pupil allocation is followed. The district does not have effective controls to monitor school-level expenditures for compliance with approved Title I building allocations. Six of the 20 schools overspent their allocation by approximately $554,000. The other schools were under their allocations as a result. Corrective Action Planned: The district is working with ISBE to ensure that our site-based resource allocations align with the district’s budget. Name of the Contact Person Responsible for Corrective Action: Mr. Daniel Ulrich, Executive Direct of Finance/ District Accountants/Auditor, Judy Freeman, District Accounts Grant Auditor, Chanbopha Loera Anticipated Completion Date: July 1st 2026.
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