Corrective Action Plans

Finding 512253 (2023-007)

Material Weakness 2023

Metropolitan School District of Warren County

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective ...

Finding 2023-007 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren has construction projects at two sites payable out of ARP. MSD Warren’s contracts for those projects contain Davis-Bacon provisions. MSD Warren will collect payroll data to verify compliance with Davis-Bacon. Anticipated Completion Date: 12/15/24

View Audit 330027

Finding 512252 (2023-006)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revis...

Finding 2023-006 – Education Stabilization Fund – Reporting Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: MSD Warren will submit a revised ESSER data report to DOE. Anticipated Completion Date: Completed as of the date of this report.

View Audit 330027

Finding 512248 (2023-004)

Significant Deficiency 2023

Metropolitan School District of Warren County

IN

Internal Control / Segregation of Duties Significant Deficiency Matching / Level of Effort / Earmarking

Finding 2023-004 – Title I Grants to Local Educational Agencies - Special Test and Provisions – Annual Report Card, High School Graduation Rate Audit Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur...

Finding 2023-004 – Title I Grants to Local Educational Agencies - Special Test and Provisions – Annual Report Card, High School Graduation Rate Audit Contact Person Responsible for Corrective Action: Matthew Parkinson, CFO Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The CFO and Associate Superintendent will send a memo to principals and registrars defining documentation that must be maintained for mobility purposes. Anticipated Completion Date: 6/30/24

View Audit 330027

Finding 512236 (2023-004)

Significant Deficiency 2023

City of Clarksville

TX

Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs

City of Clarksville, TX accounting department and Mayor will develop a process in which the audit will be completed in a timely manner to submit it to the FAC by hiring an auditor earlier in the year and submitting it to the Clearing house within 30 days of the audit report or nine months after the ...

City of Clarksville, TX accounting department and Mayor will develop a process in which the audit will be completed in a timely manner to submit it to the FAC by hiring an auditor earlier in the year and submitting it to the Clearing house within 30 days of the audit report or nine months after the Organization’s year end

View Audit 330016

Finding 512224 (2023-002)

Material Weakness 2023

Community Action Partnership of Solano (dba) Cap Solano

CA

Subrecipient Monitoring § 200.332

Subrecipient Monitoring Name of Contact Person: Tamara Colden, Assistant Director Housing and Community Services Department Corrective Action: The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise mo...

Subrecipient Monitoring Name of Contact Person: Tamara Colden, Assistant Director Housing and Community Services Department Corrective Action: The Subrecipient Monitoring policy and procedures were updated in August 2022 to include the procedures for evaluating risk for subrecipients and revise monitoring procedures. These procedures were updated to include checking the Federal Awards clearinghouse annually to assess audit requirements for all subrecipients and ensure the monitoring policy includes procedures when those audits result in any concerns or findings for subrecipients. A revised risk assessment will be conducted for each subrecipient. A new subrecipient monitoring policy was implemented in March 2023 to address this finding and staff has followed this policy since that time and will continue to do so. Proposed Completion Date: 06/30/2023

View Audit 329990

Finding 512206 (2023-001)

Significant Deficiency 2023

Boone County Fiscal Court

KY

Subrecipient Monitoring Reporting Significant Deficiency § 200.331

Already corrected in Q4 CY23 ARPA Report.

View Audit 329966

Finding 512197 (2023-002)

Material Weakness 2023

Portage County

OH

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.328

The Mental Health and Recovery Board of Portage County will submit program final expenditures in the GFMS system within the grant close-out reporting period.

View Audit 329956

Finding 512194 (2023-001)

Material Weakness 2023

Portage County

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

Portage County will continue to verify that a vendor is not suspended or debarred by checking the SAM exclusions, prior to contracting with any vendor that will be paid $25,000 or more with federal funds. Purchase orders and contracts using federal funds are routed through the Director of Budget an...

Portage County will continue to verify that a vendor is not suspended or debarred by checking the SAM exclusions, prior to contracting with any vendor that will be paid $25,000 or more with federal funds. Purchase orders and contracts using federal funds are routed through the Director of Budget and Finance for this verification. A time-stamped copy of the results of the SAM exclusions search will be saved in a vendor file.

View Audit 329956

Finding 512083 (2023-003)

Material Weakness 2023

Aliquippa School District

PA

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302 § 200.328 § 200.329

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Of...

CONDITION: The District did not properly record its federal program expenditures for the ESSER and ARP ESER federal grant programs using the various funding source expenditure codes as prescribed by the Chart of Accounts for PA Local Educational Agencies maintained by the PA Office of the Budget, Office of Comptroller Operations and well as Section 2 CFR 200.302(a) of the Uniform Guidance. CRITERIA: The financial management system of the District must provide for 1) identification in it’s accounts, of all Federal awards received and expended and the Federal programs under which they were received, and 2) accurate, current and complete disclosure of the financial results of each federal award or program in accordance with the reporting requirements set forth in sections 200.328 and 200.329 of the Uniform Guidance. 74CORRECTIVE ACTION PLAN: The School District concurs with the above noted finding. The School District has employed a new Business Manager whose responsibilities include the oversight of the financial management system and the posting of all transactions into that system. Procedures will be put into place during the remaining months of the 2023-2024 fiscal year, and all subsequent years, for ensuring federal program expenditures are properly coded within the District’s financial management system so as allow for proper reporting related to those expenditures.

View Audit 329826

Finding 511975 (2023-004)

Material Weakness 2023

Fredericksburg Area Health and Support Services, Inc.

VA

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.430

Finding: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. The amount of payroll and related costs discovered to be incorrect was a net...

Finding: The Organization allowed payroll related costs to be submitted for reimbursement under the grant for time that did not match approved timesheets. This is not in compliance with program allowable cost requirements. The amount of payroll and related costs discovered to be incorrect was a net amount of $1,336, which when projected onto the remaining payroll and related costs that were not tested, amounted to $28,521. Corrective Action Taken or Planned: The Organization will review audit findings and ensure accurate future reimbursements, develop a comprehensive process for verifying time sheets against service delivery, and implement a paper timesheet system in which supervisors must enter time based on timesheets, ensuring 1:1 reimbursement. Name of Contact Person: Jacob Ducey, Grants Manager Phone Number of Contact Person: (540) 907-4555 Projected Completion Date: October 31, 2024

View Audit 329739 Questioned Costs: $1

Finding 511929 (2023-001)

Significant Deficiency 2023

Boys & Girls Clubs in Tennessee

TN

Subrecipient Monitoring § 200.332

The Alliance team will enhance its procedures to execute subaward agreements in advance of awarding funds.

View Audit 329647

Finding 510793 (2023-001)

Significant Deficiency 2023

Second Harvest North Central Food Bank

MN

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

2023-001 Emergency Food Assistance – Assistance Listing No. 10.569 Recommendation: We recommend the Organization follow its procurement policy that includes procedures for suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...

2023-001 Emergency Food Assistance – Assistance Listing No. 10.569 Recommendation: We recommend the Organization follow its procurement policy that includes procedures for suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Second Harvest North Central Food Bank will update its procurement policy to reflect the review over the required procedures related to suspension and debarment. Name of the contact person responsible for corrective action: Shaye Moris Planned completion date for corrective action plan: December 31, 2024 If the Minnesota Department of Human Services Office of Economic Opportunity has questions regarding this plan, please call Shaye Moris at 218-336-2300.

View Audit 329585

Finding 510789 (2023-006)

Material Weakness 2023

The University of Chicago

IL

Reporting Subrecipient Monitoring § 200.303 § 200.510

Finding No. 2023-006: Inaccurate Reporting on the Supplementary Schedule of Expenditures of Federal Awards ALN and Program Expenditures: 97.036 ($5,258,177) Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Corrective Action: Process Improvements: - The Universit...

Finding No. 2023-006: Inaccurate Reporting on the Supplementary Schedule of Expenditures of Federal Awards ALN and Program Expenditures: 97.036 ($5,258,177) Program Name: Disaster Grants – Public Assistance (Presidentially Declared Disasters) Corrective Action: Process Improvements: - The University will establish a Supplementary Schedule of Expenditures of Federal Awards (SEFA) controls narrative to formalize preparation and reconciliation processes of SEFA data. - The central University Research Administration team (URA), in coordination with Finance and Administration, will review SEFA preparation and data collection processes and establish a formalized reconciliation process. - Biannually, URA will conduct third party searches to verify funding received at each entity. Expected Implementation: August 2024 – December 2024 Contact: Jennifer A. Ponting (Associate Vice President, Research Administration)

View Audit 329564

Finding 510787 (2023-005)

Material Weakness 2023

The University of Chicago

IL

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding No. 2023-005: Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data CFDA Numbers: 84.425 Program: Higher Education Emergency Relief Fund Corrective Action: Institutional expenditure reporting was reviewed and revised reports were posted to the institution’s w...

Finding No. 2023-005: Inaccurate Reporting of Higher Education Emergency Relief Fund (HEERF) Quarterly Data CFDA Numbers: 84.425 Program: Higher Education Emergency Relief Fund Corrective Action: Institutional expenditure reporting was reviewed and revised reports were posted to the institution’s website. Implementation Date: March 6, 2024 Contact Person: Amanda Fijal

View Audit 329564

Finding 509728 (2023-002)

Material Weakness 2023

Jamul Indian Village

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2023-002 –Procurement and Suspension and Debarment - Material Weakness in Internal Controls Over Compliance and Material Non-Compliance Planned Corrective Action: The Tribe has established policies and procedures over the use of all funds for procurement, including federal funds. The Tribe’s...

Finding 2023-002 –Procurement and Suspension and Debarment - Material Weakness in Internal Controls Over Compliance and Material Non-Compliance Planned Corrective Action: The Tribe has established policies and procedures over the use of all funds for procurement, including federal funds. The Tribe’s policies and procedures have created internal controls designed to ensure management of federal awards are in compliance with all applicable terms of the award, laws, and regulations, whether federal or otherwise. To enhance the internal controls over the procurement of goods and services, the Tribe will create training materials on procurement processes and requirements, to assist procuring parties understand their responsibilities in the procurement and management of goods and/or services, when using federal funds. This flowchart on procurement will be completed and disseminated throughout the Tribe for easy review by all Tribe procuring parties. Name of Responsible Party: Erica M. Pinto, Chairwoman and Tina Heimerdinger, Controller Anticipated Completion Date: End of fiscal year 2024

View Audit 329392

Finding 509686 (2023-012)

None 2023

City of Philadelphia

PA

Questioned Costs Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.344 § 200.403

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS agrees with the issues outlined, which stem from the delayed processing of invoices and untimely payments. These challenges are largely the result of ...

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS agrees with the issues outlined, which stem from the delayed processing of invoices and untimely payments. These challenges are largely the result of longstanding issues with over-allocations and the need to catch up on processing a backlog of documents. We appreciate you bringing this to our attention, as it provides an opportunity to refine our procedures and put in place measures to prevent these issues from recurring in the future. This feedback will be valuable as we work to improve our processes and enhance our ability to manage workloads more effectively. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

View Audit 329338 Questioned Costs: $1

Finding 509685 (2023-011)

Significant Deficiency 2023

City of Philadelphia

PA

Subrecipient Monitoring

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS will make the needed changes to all Rent Reasonable policies, standard operating procedures, housing standards, scopes of service, and monitoring tools ...

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS will make the needed changes to all Rent Reasonable policies, standard operating procedures, housing standards, scopes of service, and monitoring tools to reflect the requirement above. Additionally, this will be communicated to internal staff and the provider community, especially those that have been allowed to complete their own rent reasonable assessments. It is also a possibility that we will no longer allow the Providers to conduct the rent reasonable verification themselves. This has yet to be determined. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-037, 215-520-3556

View Audit 329338

Finding 509684 (2023-010)

Significant Deficiency 2023

City of Philadelphia

PA

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

Assistance Listing 14.267 Continuum of Care Program ...

Assistance Listing 14.267 Continuum of Care Program Views of the Responsible Officials and Corrective Action Plan: OHS acknowledges the finding and agrees with the need to develop a corrective action plan. Given that this will require collaboration across multiple units, we are unable to provide a specific timeline for a comprehensive and accurate response at this moment. However, I will take immediate steps to initiate the necessary discussions. It is important to note that the prevailing, though incorrect, understanding within our team was that when a match involves cash, the primary source of verification occurs during the filing of the Annual Performance Report (APR). Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

View Audit 329338

Finding 509683 (2023-009)

Significant Deficiency 2023

City of Philadelphia

PA

Subrecipient Monitoring § 200.331

Assistance Listing 14.239 Home Investment Partnerships Program Assistance Listing 93.569 Community Services Block Grant ...

Assistance Listing 14.239 Home Investment Partnerships Program Assistance Listing 93.569 Community Services Block Grant Views of the Responsible Officials and Corrective Action Plan: OHS is in the process of finalizing a risk assessment and a RA policy and procedure to ensure that the RAs are completed timely and inform our monitoring plan. Both will be in compliance with OMB’s Uniform Guidance 2 CFR §200.331(b). PHMC will be the first subrecipient that will be tested. We will provide that risk assessment to your office and our partners at DHCD when it is completed. It is the goal to have this RA finalized and all grant funded program providers assessed for risk by 12/31/2024. Contact Person: Jerome R. Hill, Director of Compliance, Office of Homeless Services, 215-686-0371, 215-520-3556

View Audit 329338

Finding 509628 (2023-003)

Material Weakness 2023

Allen County

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.329

Reporting Errors for the Coronavirus State and Local Recovery Funds were discovered. Reporting errors were unintentional and were a result of not more closely following the Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The employee who was responsible for entering...

Reporting Errors for the Coronavirus State and Local Recovery Funds were discovered. Reporting errors were unintentional and were a result of not more closely following the Coronavirus State and Local Fiscal Recovery Funds Compliance and Reporting Guide. The employee who was responsible for entering the information into the portal is no longer with Allen County. New responsible staff will be trained appropriately according to the most currently released guidance and every effort will be made to ensure accuracy and complete reporting.

View Audit 329231

Finding 509626 (2023-001)

Material Weakness 2023

Allen County

OH

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.202 § 200.208 § 200.301 § 200.328

This is repeat Finding from 2022. Key personnel have since been replaced at the RPC and those in in the new positions understand the importance of proper and timely reporting and accurate financial records. The Auditor’s Office will meet with the new executive director, the current (new) finance dir...

This is repeat Finding from 2022. Key personnel have since been replaced at the RPC and those in in the new positions understand the importance of proper and timely reporting and accurate financial records. The Auditor’s Office will meet with the new executive director, the current (new) finance director, and board members to emphasize the importance of deadlines and financial accountability when working with Grants. Additional Controls will be emphasized to assist with timely filing, as well as Invoice Entry to ensure duplicate payments are not made.

View Audit 329231

Finding 509620 (2023-001)

Significant Deficiency 2023

Mississippi Alliance of Boys & Girls Clubs, Inc.

MS

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Management will review grant agreements for any conditions or barriers present to recognize revenue. For cost reimbursement grants, grant revenue is recognized upon date of invoice sent by the Alliance to the state requesting payment. The date of receipt will be reviewed to determine the appropriate...

Management will review grant agreements for any conditions or barriers present to recognize revenue. For cost reimbursement grants, grant revenue is recognized upon date of invoice sent by the Alliance to the state requesting payment. The date of receipt will be reviewed to determine the appropriate fiscal year or advance payment classification, as applicable.

View Audit 329210

Finding 509618 (2023-003)

Significant Deficiency 2023

Massachusetts Alliance of Boys & Girls Clubs, Inc.

GA

Subrecipient Monitoring Internal Control / Segregation of Duties

The Alliance will enhance its procedures and internal controls over subrecipient monitoring to ensure that evidence of proper review of local club invoices is maintained.

View Audit 329209

Finding 509617 (2023-002)

None 2023

Massachusetts Alliance of Boys & Girls Clubs, Inc.

GA

Subrecipient Monitoring § 200.332

The Alliance will implement internal controls and administrative oversight to ensure subrecipient monitoring requirements are being followed and adequately documented.

View Audit 329209

Finding 509320 (2023-002)

Material Weakness 2023

Delaware Academy of Medicine, Inc.

DE

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The Academy will ensure that only eligible expenses are included in the overhead calculation and that other rules and limitations are adhered to. The Academy increased the overhead rate to 10% default rate after learning of this overhead rule during the 2022 audit (mid-2023).

View Audit 329117 Questioned Costs: $1

Corrective Action Plans

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