Corrective Action Plans

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SIGNIFICANT DEFICIENCY Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 2024-001 Recommendation: The College should work to implement a standardized and detailed risk management...
SIGNIFICANT DEFICIENCY Finding 2024-001 - 84.268, 84.063, 84.033, 84.007 Student Financial Aid Cluster Federal Agency - U.S. Department of Education Grant Period - Year ended August 31, 2024 2024-001 Recommendation: The College should work to implement a standardized and detailed risk management framework, such as those provided by National Institute of Standards and Technology (NIST). Risk assessment documentation should include detailed information regarding current procedures in place, justifications for scoring, safeguards for each identified risk, and remediation plans. As part of this process, the College should then review the current policies and procedures at least annually to determine if any updates should be made. Corrective Action Plan: The College agrees with the finding and as of March 2025 the College has contracted with an outside third party to perform an formal risk assessment. Once the risk assessment has been performed the College will work on ensuring the appropriate safeguards are in place and remediation plans identified. Additionally policies continue to be reviewed and updated through the governance process at the College. FLCC Responsible Party: Jason Tack, VP of Finance and Administration, jason.tack@flcc.edu, 585-785-1208. Audit finding will be corrected by 8/31/2025.
Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and C...
Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and Cause: There were three instances out of 40 distributions tested where this signoff was not completed. Due to the hectic environment at the lead agencies during food distribution day, oversights have occurred when obtaining the required client signoff. Statement of Concurrence or Nonconcurrence: PARF management has reviewed the 2024-001 finding and concurs with the recommendations as stated. Corrective Action: PARF has an extensive training process in place for lead agencies, in relation to grant award compliance requirements, which includes the provision of training manuals and monthly phone calls to review matters. In addition, PARF provides updates to the lead agencies as new or amended requirements are enacted. Further, PARF does periodic reviews of the lead agencies and completes the biennial review Form 502035 CSFP Management Evaluation. PARF will continue to reiterate the required signoff process with the lead agencies during phone calls, training session and reviews. In addition for FY 2025 PARF will be conducting a mandatory webinar to ensure all the lead agencies are understanding the procedure and why it is important for 100 percent accuracies -https://docs.google.com/presentation/d/1YZgcq7SY4DmvhYrKZE8sp-NDhpuzn827PZDZ0xAKDw/edit?usp=sharing
Management will develop procedures to ensure that reports are submitted timely and any new filing deadlines will be documented and met without exception.
Management will develop procedures to ensure that reports are submitted timely and any new filing deadlines will be documented and met without exception.
Management will develop additional controls to ensure that bank reconciliations are prepared timely and perform second review as per current internal control policy.
Management will develop additional controls to ensure that bank reconciliations are prepared timely and perform second review as per current internal control policy.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Nu...
Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER I and ESSER III amounts reported for the reports covering the FY22 time period ($22,163 and $409,347, respectively) did not agree to the underlying expenditure records ($3,796 and $404,347 respectively) for the period of July 1, 2021 through June 30, 2022. Additionally, we noted that the ESSER II amount reported for the reports covering the FY23 time period ($131,439) did not agree to the underlying expenditure records ($153,216) for the period of July 1, 2022 through June 30, 2023). We also noted there was no documented, secondary review of the information in the FY23 annual data reports by someone other than the preparer. Contact Person Responsible for Corrective Action: Dr. David Stashevsky Contact Phone Number: 765-378-3329 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The assistant superintendent will manage the grant with the superintendent providing oversight. The assistant superintendent will coordinate the receipts and expenditures of funds with the corporation treasurer. The superintendent will review all financial reports and approve in writing with notification sent to the assistant superintendent and treasurer. Anticipated Completion Date: The correction will be on the next annual report when it is due.
Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Num...
Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the reporting compliance requirements. The School Corporation was not formally reviewing the ESSER reports being submitted by comparing the underlying expenditure detail to the amounts reported for each grant for the reporting period. Context: The School Corporation was required to submit six Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. Crowe noted the following reporting errors for the Year 3 reports (July 1, 2021 through June 30, 2022). The ESSER If amount reported on the Year 3 report ($585,040) did not agree to the underlying expenditure records ($581,468). This is the exact amount reported as the SEA reserve amount on the Annual Data Report. Crowe noted the ESSER Ill amount reported on the Year 3 report ($0) did not agree to the underlying expenditure records ($351,831). Crowe noted the following reporting error for the Year 4 reports (July 1, 2022 through June 30, 2023). The ESSER Ill amount reported on the Year 4 report ($1,062,765) did not agree to the underlying expenditure records ($1,054,618). This is the exact amount reported as the SEA reserve amount on the Annual Data Report. Corrective Action Plan: The School Corporation will implement internal control procedures to ensure the amounts reported in the annual data reports agree to the underlying support and detail from the internal records. A formal review process will be implemented. Person responsible for implementation and projected implementation date: The Corporation's Treasurer and Superintendent will be responsible for implementing the corrective action, which will be implemented immediately.
On contracts and purchase orders where the City is utilizing Federal funds – we will add a clause to contracts and require a certification on purchase orders for suspension and debarment. This will require the vendor to certify that they are not debarred, suspended, or otherwise excluded from or in...
On contracts and purchase orders where the City is utilizing Federal funds – we will add a clause to contracts and require a certification on purchase orders for suspension and debarment. This will require the vendor to certify that they are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.
The District will update the procurement policy to reflect all the required files as noted in the procurement standards set out at 2 CFR sections 200.318 through 200.327. The District Board of Directors will review and approve all updates through Board action at a Regular Meeting of the Board of Dir...
The District will update the procurement policy to reflect all the required files as noted in the procurement standards set out at 2 CFR sections 200.318 through 200.327. The District Board of Directors will review and approve all updates through Board action at a Regular Meeting of the Board of Directors
Form AD-1048 has been completed for all contactors that are being used in regards to the grant. Procedures have be put to place to ensure that any new contractor used by the District has the necessary forms filled out as subject to the grants terms.
Form AD-1048 has been completed for all contactors that are being used in regards to the grant. Procedures have be put to place to ensure that any new contractor used by the District has the necessary forms filled out as subject to the grants terms.
Finding 529197 (2024-001)
Significant Deficiency 2024
Finding: For sub-awards subject to the Transparency Act, the awarding entity must enter the award information in agreement with the award contract to the FSRS portal. Management was unaware of the requirement for award information to be input into the FSRS portal for a sub-award that was subject to ...
Finding: For sub-awards subject to the Transparency Act, the awarding entity must enter the award information in agreement with the award contract to the FSRS portal. Management was unaware of the requirement for award information to be input into the FSRS portal for a sub-award that was subject to the Transparency Act. Corrective Action: 1. Review and ensure policies are up to date and comply with the federal awards that are subject to the Funding Accountability and Transparency Act. 2. For new federal awards, identify whether the award is subject to the Federal Funding Accountability and Transparency Act and develop a task list to ensure the reporting requirement is fulfilled timely. 3. Designate the reporting responsibility with respect to FFATA reporting to the accounting manager with oversight from the Controller and CFOO. 4. Establish periodic meetings between programs, compliance and finance to report on the FFATA compliance when applicable.
OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Camille Lamothe, Senior Risk Assessment Coordinator Correc...
OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Camille Lamothe, Senior Risk Assessment Coordinator Corrective Action Plan: Oregon Food Bank finalized and implemented a procurement policy and a specific procurement policy for purchases made with federal funds, aligned with federal procurement standards and effective October 2024. Internal controls will be established to ensure adherence to the policy, and procedures will require retaining documentation of the procurement process to demonstrate compliance. These improvements will enhance transparency, strengthen accountability, and reduce compliance risk, ensuring a more efficient and well-documented procurement process that supports the organization’s long-term financial integrity and operational effectiveness. The anticipated completion date is June 30, 2026.
Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services / Farmers Market Fund Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182, 10.331 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative, Gus Schumacher Nut...
Food Distribution Cluster US Department of Agriculture / Oregon Department of Human Services / Farmers Market Fund Federal Assistance Listing Number: 10.565, 10.568, 10.569, 10.182, 10.331 Federal Program Name: Food Distribution Cluster, Local Food Purchase Assistance Cooperative, Gus Schumacher Nutrition Incentive Program OFB’s View on Finding: OFB acknowledges the finding and agrees with the auditors' assessment Responsible Party: Katie Kenton, Interim Co-Director of Finance (Strategic Finance); Nan Wang, Interim Co-Director of Finance (Operational Finance); Starr Yurkewycz, Director of Partnerships and Programs; Nathan Harris, Director of Community Philanthropy; Shannon Oliver, Interim Director of Operations Corrective Action Plan: Finance will assess requirements and establish procedures and internal controls to ensure the consistent application, billing, and reporting of indirect cost rates across all federal awards. This will include collaborating with grant writing staff during the pre-application and pre-award phases to centralize grant preparation and ensure indirect rates are accurately applied in grant proposals and budgets. Multiple dedicated review steps in the grant lifecycle will be developed to both ensure accuracy of the rates charged and address any changes from the Federal Government. Existing strengths, tools, and capacity will be reviewed to support this process, including alignment with subrecipient indirect cost practices. Training will be provided to individuals responsible for these controls to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date is June 30, 2026.
View Audit 347167 Questioned Costs: $1
VIEWS OF RESPONSIBLE OFFICIALS The designated officer of the CDBG-DR/MIT Program to perform this task resigned suddenly. We recruited and trained a new officer, but during the transition process some First-Tier Sub awardee contracts were not reported in the Subaward Reporting System (FSRS) in a time...
VIEWS OF RESPONSIBLE OFFICIALS The designated officer of the CDBG-DR/MIT Program to perform this task resigned suddenly. We recruited and trained a new officer, but during the transition process some First-Tier Sub awardee contracts were not reported in the Subaward Reporting System (FSRS) in a timely manner. To prevent this condition in the future, we have trained more than one officer for this task, and have placed a level of supervision to fully comply with this obligation. IMPLEMENTATION DATE Already implemented RESPONSIBLE PERSON Félix Hernández Cabán Director of Disaster Recovery CDBG-DR Program Finance & Monitoring Division
FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identif...
FINDING 2024-001 Information on the federal program: Subject: Education Stabilization Fund (ESSER) – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit two Annual Data Reports to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. The Annual Data Reports were prepared by School Corporation management and reviewed by someone other than the preparer, however, the review process in place did not prevent, or detect and correct, errors. During testing of the accuracy of the annual data reports, the following errors were noted: • The Year 2 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $2,219,321 for the period of July 1, 2021 through June 30, 2022 compared to underlying disbursement detail of $2,715,940. • The Year 3 Annual Data Report for the ESSER III (84.425U) grant award reported total disbursements of $224,309 for the period of July 1, 2022 through June 30, 2023 compared to underlying disbursement detail of $306,194. Contact Person Responsible for Corrective Action: Kasey Clark Contact Phone Number: 574-772-1604 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There will be two people who look over the ESSER reports before submitting to the state to make sure they agree with the reports. Anticipated Completion Date: When next report is due.
Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to v...
Corrective Actions Taken Commons has taken the following actions to protect against such fraudulent incidents in the future: • Engaged a firm to assist with managing the incident; • Opened a new bank account; • Added account verification services with our banking partner, which will be utilized to verify account updates; • Limited the amount of per vendor/subrecipient daily payments to our insurance limits, with verifications prior to releasing additional funds when the total payment exceeds the insurance limits; • Subrecipient payment receipt is verified by both the subrecipient and the Commons grants team; • Updated our policy and procedures to direct our subrecipients to request banking changes through our procurement system and not through email; and • Expanded implementation of our Kissflow procurement system across the organization, which includes new vendor process as well as a change of vendor information module. Vendor changes would be approved first by the program/department that works with the vendor prior to Finance approval. Completion Date With the exception of implementing the change of vendor information module in Kissflow, the above actions have all been completed by the date of this report. The projected completion date for Kissflow change of vendor information module is April 30, 2025. Responsible Party Dana Thomas, Chief Financial Officer Angela Allen, Vice President of Finance
Views of Responsible Officials: Because the subawards were given to partners who NSF requested that ESA work with, it was not deemed necessary to perform the risk assessment. These will be done in the future. To address audit finding regarding subawardee risk assessments, ESA will create a defined r...
Views of Responsible Officials: Because the subawards were given to partners who NSF requested that ESA work with, it was not deemed necessary to perform the risk assessment. These will be done in the future. To address audit finding regarding subawardee risk assessments, ESA will create a defined risk assessment policy that will be implemented for all subawardees.
Finding 529093 (2024-022)
Significant Deficiency 2024
University System Response/Corrective Action Plan Agree. A new Subrecipient Policy and new Subrecipient Monitoring Procedure were put in place effective November 2024. In accordance with the new Policy and Procedure, risk assessments are being completed before subaward agreements are issued. Contac...
University System Response/Corrective Action Plan Agree. A new Subrecipient Policy and new Subrecipient Monitoring Procedure were put in place effective November 2024. In accordance with the new Policy and Procedure, risk assessments are being completed before subaward agreements are issued. Contact Person: Lauren Pite, Director Grants & Contracts Anticipated Completion Date: Completed
View Audit 346994 Questioned Costs: $1
Adjutant General Response/Corrective Action Plan: The agency agrees with the finding. In March 2024, the agency self-identified the reporting change and adjusted internal procedures to report new subawards based on obligation amount vs reporting on payments over $30,000 at the end of every month...
Adjutant General Response/Corrective Action Plan: The agency agrees with the finding. In March 2024, the agency self-identified the reporting change and adjusted internal procedures to report new subawards based on obligation amount vs reporting on payments over $30,000 at the end of every month. Any obligations that have been identified as missed in the transition have since been reported, and the new method of reporting on obligations will be followed moving forward. The agency will ensure per Federal regulation 2 CFR 170, Appendix A that each subaward that equals or exceeds $30,000 no later than the end of the month following the month in which the obligation was made will be reported. Contact Person: Jennifer Scheet, Division Chief – Fiscal & Admin Services, 701-333-2079, jenniferscheet@nd.gov Anticipated Completion Date: The audit period covered July 1, 2022 – June 30, 2024 and the agency corrected the reporting in March 2024 after self-identifying the reporting criteria.
Finding 529056 (2024-006)
Significant Deficiency 2024
Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. The department will monitor expenses within the budget and grant period based on guidance from the federal agency to ensure that the date of expenditu...
Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. The department will monitor expenses within the budget and grant period based on guidance from the federal agency to ensure that the date of expenditures are not claimed before grant funds are received. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024
View Audit 346994 Questioned Costs: $1
Finding 529055 (2024-005)
Significant Deficiency 2024
Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. To address this, the department will run quarterly reports from AWARE to identify any payments charged to the incorrect period of performance. Grant ...
Department of Health and Human Services Response/Corrective Action Plan The Department of Health and Human Services agrees with the recommendation. To address this, the department will run quarterly reports from AWARE to identify any payments charged to the incorrect period of performance. Grant guidance has been updated to ensure items with unique service dates are properly reviewed. Additionally, during the three-month liquidation period, a monthly review of all expenditures will be conducted to verify they are applied to the correct period of performance. These actions will strengthen oversight and ensure compliance with grant requirements. Contact Person: Eric Haas, Assistant CFO Anticipated Completion Date: December 2024
View Audit 346994 Questioned Costs: $1
Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has: A. Communicated all required information of 2 CFR 200.332(b) to subrecipients B. Developed procedures to ensure grant agreement templates are updated and that all Cor...
Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has: A. Communicated all required information of 2 CFR 200.332(b) to subrecipients B. Developed procedures to ensure grant agreement templates are updated and that all Coronavirus Capital Projects Fund award information is communicated to subrecipients C. Reissued grant agreements to outline the required information. Contact Person: Wayde Sick, Director and Executive Officer and Gwen Ferderer, Finance Director Anticipated Completion Date: September 2024
Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has developed a system to identify which subrecipients are subject to required audits and are tracking subrecipients to ensure timely submission of required audit reports a...
Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has developed a system to identify which subrecipients are subject to required audits and are tracking subrecipients to ensure timely submission of required audit reports and appropriate corrective actions. Contact Person: Wayde Sick, Director and Executive Officer and Gwen Ferderer, Finance Director Anticipated Completion Date: August 2024
Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has established a methodology for compiling and reporting financial data that is in accordance with appropriate accounting standards and principles and has corrected report...
Career and Technical Education Response/Corrective Action Plan: The department agrees with this recommendation The department has established a methodology for compiling and reporting financial data that is in accordance with appropriate accounting standards and principles and has corrected reporting obligations, and expenditures. The department has also worked directly with the Treasury Department to make sure the square footage being claimed is consistent with what they are looking for. Contact Person: Wayde Sick, Director and Executive Officer and Gwen Ferderer, Finance Director Anticipated Completion Date: August 2024
Finding 529023 (2024-015)
Significant Deficiency 2024
Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. The issue has already been corrected as stated in the finding. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: The issue has already been corrected.
Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. The issue has already been corrected as stated in the finding. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: The issue has already been corrected.
View Audit 346994 Questioned Costs: $1
Finding 528989 (2024-017)
Significant Deficiency 2024
Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. We have updated our grant award templates to include all required information. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This has already been implemented effective 2/1/2025.
Department of Public Instruction Response/Corrective Action Plan: We agree with the finding. We have updated our grant award templates to include all required information. Contact Person: Jamie Mertz, CFO Anticipated Completion Date: This has already been implemented effective 2/1/2025.
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