Corrective Action Plans

Finding 480625 (2023-001)

Significant Deficiency 2023

The Utica Center for Development, Inc.

NY

Subrecipient Monitoring Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Planned Action: We will develop required written policies and procedures as required by the 0MB's Uniform Guidance.

View Audit 316821

Finding 480623 (2023-004)

Significant Deficiency 2023

St. Joseph County

IN

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.331 § 200.332

Contact Person Responsible for Corrective Action: Abby Doyle, Chief Deputy Auditor Contact Phone Number: (574) 235-9668 ext.7201 Views of Responsible Official: We concur with the audit finding with respect to the monitoring of subrecipients for the American Rescue Plan funding. The County monitored...

Contact Person Responsible for Corrective Action: Abby Doyle, Chief Deputy Auditor Contact Phone Number: (574) 235-9668 ext.7201 Views of Responsible Official: We concur with the audit finding with respect to the monitoring of subrecipients for the American Rescue Plan funding. The County monitored the subrecipient agrees for the 50% matching requirement, and the subrecipient was paid properly. However, we did not obtain quarterly progress reports on the program. Description of Corrective Action Plan: On March 4, 2024, the County contacted each entity that signed a sub-recipient agreement for American Rescue Plan (ARP) funding and asked them to complete and sign the attached Proof of Project Efforts Schedule. The schedule provides the County with a description of the project and uses of ARP funds. In addition, the schedule provides a listing of project expenditures and paid invoices. The completed forms have been received and filed. Completion Date: March 29, 2024

View Audit 316813

Finding 480604 (2023-001)

None 2023

Borough of Lindenwold School District

NJ

School Nutrition Programs Subrecipient Monitoring Cash Management

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board...

Corrective Action Required by The Board - The School District was not in compliance with CFR section 210.14 which requires that the net cash resources in the food service fund to be below its three month average expenditures at year end. Recommendation Number Corrective Action Required by The Board - The responsible officials are in agreement with the calculation. COVID's financial impact on the food service fund and ultimately the food service reserves has created this inflated financial position. We will use these funds to continue to invest in our food service equipment as well as upgrade our food options and meal quality, within USDA regulations.

View Audit 316793

Finding 480511 (2023-002)

Significant Deficiency 2023

Southwest Ohio Regional Transit Authority

OH

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Views of Responsible Official: The Project Grant Administrator did prepare and submit the FRA quarterly reports. This person was the official reviewer of the project progress for the FRA quarterly report submission. The financial information for the report was first compiled by the Capital Project...

Views of Responsible Official: The Project Grant Administrator did prepare and submit the FRA quarterly reports. This person was the official reviewer of the project progress for the FRA quarterly report submission. The financial information for the report was first compiled by the Capital Projects and Grant Tracking (CPGT) Administrator Accountant. (Note that CPGT is reconciled with CODA, the SORTA accounting system, before this information is provided.) The Project Grant Administrator received project implementation information from the Construction Project Manager. The Grant Administrator married this information with what was provided by the CPGT Administrator/Accountant, as well as what was in Maximo (the SORTA procurement system), The Project Grant Administrator also visited the project site to verify progress of the FRA project(s) when needed. The final quarterly reports were used by the Director of Grants as well as FRA to keep up with the implementation progress of the project(s). Any actual draw down of funding for the project was prepared separately by the CPGT Administrator/Accountant and signed off by the Director of Accounting. We concur with the finding that the FFATA report for reporting of an award to a subrecipient above a certain dollar threshold was submitted in November of 2023, which was after the regulatory date for submission. Description of Corrective Action Plan: The Federal Railroad Administration (FRA) CRISI Grant- that this finding relates to has been completed and is now closed. Thus, there will not be any further Quarterly reports prepared or submitted under this particular Grant. And, it is not anticipated that SORTA will be administering any other FRA CRISI Grants in the foreseeable future. In relation to the FFATA reporting, the Grants Department will add the FFATA reporting requirements to the Grants Processes and Procedures so that should SORTA encounter a grant subrecipient situation with a future grant, Grants staff will have a reminder and reference to help ensure the reporting requirements are performed in a timely manner. Responsible Party and Timeline for Completion: Federal regulation requires name and title of person overseeing corrective action plan and anticipated completion date. The Director or Grants, Mary Huller, will complete the modification to the Processes and Procedures to include FFATA reporting requirements by the end of August 2024.

View Audit 316703

Finding 480494 (2023-001)

None 2023

Children First Community Homes and Services, INC

FL

Subrecipient Monitoring Reporting § 200.512

VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: Management will begin the single audit process as soon as possible when the books close. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The Organization ...

VIEWS OF RESPONSIBLE OFFICIALS & CORRECTIVE ACTION PLAN: Management will begin the single audit process as soon as possible when the books close. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The Organization will implement the recommendation. Officials Responsible for Ensuring CAP: The Organization’s appointed staff member is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date for the CAP is June 30, 2024. Plan to Monitor Completion of CAP: The Board of Directors will be monitoring this corrective action plan.

View Audit 316682

Finding 480482 (2023-001)

Significant Deficiency 2023

Richland Medical Center, Inc. D/b/a Central Ozarks Medical Center

MO

Special Tests & Provisions Subrecipient Monitoring Eligibility

Section Ill- Federal Award Findings and Questioned Costs Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID - 19 Health Center Program (Community Health Centers, Migrant Health...

Section Ill- Federal Award Findings and Questioned Costs Health Center Program Cluster, Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), COVID - 19 Health Center Program (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, and Public Housing Primary Care), Grants for New and Expanded Services under the Health Center Program and COVID-19 Grants for New and Expanded Services under the Health Center Program Federal Assistance Listing Numbers: 93.224 and 93.527 Item 2023-001- Special Tests Recommendation The Organization should strengthen internal controls in place to effectively ensure that patients receive the correct sliding fee discount. Repeat Finding Yes Action Taken As of May 1, 2023, the Director of Revenue and/or designee runs a slide fee report daily the reflects everyone that applied the day before. Billing personnel separate the report and audit the files to ensure the correct slide has been applied. The paper application is forwarded to the billing department for a third audit if the application is in order and has been uploaded into the patients' files and then it is manually filed. The CFO will perform random audits and will present to the Board and CEO a quarterly report with the results. In addition, As of July 1, 2023, the Access Coordinators who normally collect and process the slide fee discount program applications are now reporting to the finance department with the Director of Revenue supervising and training staff. In addition, there will now be a Lead Access Coordinator in very clinic that will audit and perform additional training where necessary.

View Audit 316663

Finding 480460 (2023-001)

Significant Deficiency 2023

American Physical Society

MD

Subrecipient Monitoring § 200.303 § 200.331 § 200.332 § 200.521

In June 2023, following the completion of the 2022 Single Federal Audit, APS immediately implemented additional policies, procedures, and controls to ensure that all subrecipients submit programmatic and financial reports in a timely manner and that these reports are reviewed by the Principal Invest...

In June 2023, following the completion of the 2022 Single Federal Audit, APS immediately implemented additional policies, procedures, and controls to ensure that all subrecipients submit programmatic and financial reports in a timely manner and that these reports are reviewed by the Principal Investigator/Program Manager and Grant Administrator through a new reporting form. This form logs electronic signatures from both the sub-awardee and APS staff. In addition, APS implemented a procedure to review the single federal audit of each sub-awardee annually. APS will review and monitor award amounts and for the required filings annually to ensure that the award amounts are accurate and updated timely to meet all reporting requirements set forth under the Transparency Act. APS implemented the corrective action plan on June 5, 2023. Management's contact responsible for the implementation of the Corrective Action Plan: Name: Jane Hopkins Gould Position: Chief Financial & Operating Officer Telephone number: 301-209-3276

View Audit 316657

Finding 480458 (2023-003)

Significant Deficiency 2023

Placer Hills Union School District

CA

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

The District will review the CNIPS report going forward and maintain the necessary supporting documentation of approvals.

View Audit 316649

Finding 480453 (2023-002)

Material Weakness 2023

Placer Hills Union School District

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

The district will ensure that all federally paid employees have a supporting and accurate Federal Time Certification record.

View Audit 316649 Questioned Costs: $1

Finding 480437 (2023-023)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

HSEM concurs with the finding. Condition A: NH HSEM Mitigation and Recovery leadership has updated the award letter templates to ensure the necessary information is included as outlined in the condition. Conditions B – D: NH HSEM Mitigation and Recovery leadership updated the Risk Assessment Quic...

HSEM concurs with the finding. Condition A: NH HSEM Mitigation and Recovery leadership has updated the award letter templates to ensure the necessary information is included as outlined in the condition. Conditions B – D: NH HSEM Mitigation and Recovery leadership updated the Risk Assessment Quick Reference Guide (QRG) and Subrecipient monitoring QRG. A two hour in-person training was conducted on January 31, 2024, to Mitigation and Recovery staff which focused on conducting risk assessments and subrecipient monitoring. This will be reviewed with staff again during an upcoming Section meeting in March 2024.

View Audit 316627

Finding 480433 (2023-021)

Material Weakness 2023

State of New Hampshire

NH

Special Tests & Provisions Subrecipient Monitoring Cash Management

HSEM concurs with the finding. As a result of the audit, the practice of using individual emails to submit correspondence to FEMA was immediately addressed with staff and future correspondence will only be sent using the general shared email inbox. Regularly during staff meetings employees are remin...

HSEM concurs with the finding. As a result of the audit, the practice of using individual emails to submit correspondence to FEMA was immediately addressed with staff and future correspondence will only be sent using the general shared email inbox. Regularly during staff meetings employees are reminded to copy communications to the general shared inbox. Additionally, HSEM is currently working with the State’s Department of Information and Technology to gain access to prior staff’s emails. To note, the final paragraph in the Conditions section makes an incorrect statement regarding the submittal timeline requirements for Project Completion and Certification reports. PCCs are due within 90 days of project completion, not project obligation.

View Audit 316627

Finding 480428 (2023-017)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

Condition A: DHHS partially concurs. The review of expenditure details is an integral part of DHHS’ Subrecipient Monitoring and standard language is included in the templates for legal agreements. These five subrecipients were deemed low or no risk, examination of expenditure detail is considered ...

Condition A: DHHS partially concurs. The review of expenditure details is an integral part of DHHS’ Subrecipient Monitoring and standard language is included in the templates for legal agreements. These five subrecipients were deemed low or no risk, examination of expenditure detail is considered sufficient monitoring. All five of these subrecipients had the inclusion of the monthly detail requirement in the contracts and this was performed prior to the invoice being submitted to AP for payment. DHHS will re-evaluate current practices to ensure that the documentation is sufficient for the current subrecipient monitoring process. Regarding the two selections identified as having risk assessments which did not specify recommended monitoring procedures: The Risk Assessment Tool for one subrecipient was performed after the subaward award. However, as indicated on the Tool, programmatic monitoring activities were included in the contract. DHHS reviewed the monthly back-up documentation provided with the submitted invoices prior to sending them to AP for payment. The risk assessment tool for the second selection was performed after the subaward award. However, as indicated on the tool, programmatic monitoring activities were included in the contract. We reviewed the monthly back-up documentation provided with the submitted invoices prior to sending them to AP for payment. Condition B: DHHS partially concurs. The review of expenditure details is an integral part of DHHS’ Subrecipient Monitoring and standard language is included in the templates for legal agreements. The subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient fiscal monitoring. DHHS employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. A review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system DHHS will re-evaluate the risk response parameters to determine that the level of documentation is sufficient to ensure that the procedures performed would be able to identify noncompliance at the subrecipient level. Condition C: DHHS concurs. DHHS will be updating procedures to include contacting vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.

View Audit 316627

Finding 480426 (2023-016)

Material Weakness 2023

State of New Hampshire

NH

Reporting Subrecipient Monitoring

The Department underwent turnover and medical issues during the reporting period. The Department has hired additional program staff and arranged for annual training through a federal contractor to assist in reporting requirements. The Department is also in the process of procuring a new weatherizat...

The Department underwent turnover and medical issues during the reporting period. The Department has hired additional program staff and arranged for annual training through a federal contractor to assist in reporting requirements. The Department is also in the process of procuring a new weatherization and fuel assistance system which will assist in providing timely and accurate reporting data. The Department is also reviewing and updating policies and procedures, to include cross training and turnover contingencies.

View Audit 316627

Finding 480424 (2023-015)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.251 § 200.332 § 200.414 § 200.521

The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department ...

The Department Concurs with paragraph A – Since this same finding was reported in March of 2023 for FY22, items a, c, and d are now included on all federal subaward contracts and policies have been updated to reflect this. The Department will ensure b is also included going forward. The Department concurs with paragraph B - The finding was a result of personnel turnover and medical issues. The Department has hired and trained additional program staff and updated policies to ensure programmatic monitoring and subsequent reports are done in a timely manner. The Department partially concurs with paragraph C. Fiscal monitoring was done for all 3 subrecipients during the federal program year. However, 1 subrecipient monitoring fell outside the state fiscal year so was not covered during the audit period. The Department has changed the wording on its risk assessment procedures to ensure no misinterpretation of the timeframe each subrecipient will be monitored in accordance with its risk assessment. The Department has also changed the requirements of the frequency of fiscal monitoring in each of the risk assessment categories. The Department Concurs with paragraph D – The Department is reviewing policies and procedures and will update them to ensure compliance with 2 CFR section 200.332(a), 2 CFR section 200.332(b) and 2 CFR section 200.521. The Department also created a tracking mechanism to ensure we receive, review, and issue management decisions (if required) in a timely manner. The Department concurs with Paragraph E - The Department is reviewing policies and procedures for both reporting and subrecipient monitoring to ensure data is tested and verified. The Department has already gained increased access to data in current software and is in the process of selecting a vendor for new software that will provide more testing and enhanced internal controls.

View Audit 316627

Finding 480416 (2023-011)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.332 § 200.501 § 200.521

Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the ...

Condition A: DHHS concurs. Pursuant to the Subrecipient Monitoring Policy, the risk assessment and determination of subrecipient monitoring activities is performed during the procurement process with the Grants Administrator and the Program Lead. It is the responsibility of Program to perform the requested subrecipient monitoring. The Department provides annual training on the Subrecipient Monitoring Policy. We will reinforce the requirements of the Policy and the ramifications for the Department for the non-compliance in this year’s annual training. Regarding the incomplete Risk Assessment Tool, we will update the Subrecipient Monitoring Policy to include a secondary review of the Tool prior to implementation, as part of our internal controls. Condition B: DHHS does not concur. The Department employs the review of expenditure details, as allowed under 200.332 (d)(1), as an integral part of the Departments Subrecipient Monitoring. The Department’s review of the expenditures provides monitoring for the following concerns: • The familiarity a subrecipient has utilizing Federal funds • The subrecipient management teams’ familiarity with Federal funding • Single Audit findings • Any prior return of funding due to non-compliance • The subrecipient’s compliance with the requirements of 200.300 and 302 • Whether the subrecipient has a new financial system Standard language for the submission of expenditure detail is included in all templates for legal agreements. These subrecipients were deemed low or no risk, therefore, examination of expenditure detail is considered sufficient monitoring. Subrecipient monitoring activities are memorialized in the legal agreements. The Risk Assessment Tool provides a space for the monitoring activities to be selected, however, the Subrecipient Monitoring Policy does require the memorialization of the activities on the Tool for compliance, only to be memorialized in the legal agreement. Condition C DHHS partially concurs. As the subrecipient’s audit report had no findings, we are not required to issue a management decision letter. However, we will be updating our procedures to include contacting the vendors to remind them of the deadline regarding the submission of their single audit in the Federal Audit Clearinghouse.

View Audit 316627

Finding 480414 (2023-010)

Material Weakness 2023

State of New Hampshire

NH

Reporting Subrecipient Monitoring Material Weakness § 200.303

This function (FFATA reporting) has now been designated to our Federal Reporting Group, which will allow for redundancy in personnel. A new policy and procedure, which will include internal controls, will be developed and implemented.

View Audit 316627

Finding 480402 (2023-008)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring Reporting Material Weakness § 200.303

The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission a...

The Office of ESEA Title programs and Covid-19 education programs have established an internal process to sample and test reports compiled to ensure operations are executed as intended. These internal controls include a monthly reporting sign off Excel sheet, certification on each FFATA submission and a secondary certification for accuracy verification, and a division wide process for FFATA filing and verification. Division wide training occurred on October 26, 2023. Due to grant award notification (GAN) changes and development within our grants management system (GMS), the FFATA process has also been developing and shifting; therefore the FFATA process will be revisited annually and updated as needed. A revised procedure for FFATA reporting will be completed prior to additional training being offered. To ensure that processes are being followed, newly hired staff is trained appropriately, and updates to the GAN process are considered within the FFATA process we will hold another training this spring, March 14th, 2024, prior to new subawards being issued.

View Audit 316627

Finding 480399 (2023-005)

Material Weakness 2023

State of New Hampshire

NH

Subrecipient Monitoring § 200.251 § 200.303 § 200.332 § 200.414 § 200.521

Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 20...

Corrective Action Planned (Condition A): The DAS analyzed the six items erroneously reported as subawards and noted the errors were isolated to two specific agencies, the Department of Health and Human Services and the Department of Environmental Services. In response to the prior year finding 2022-002, the DAS had strengthened internal controls related to the review and validation of amounts reported by individual state agencies as pass through expenditures. This included an additional control specifically verifying SLFRF pass through expenditures reported by each agency. The DAS will offer additional training relative to identification and reporting of subaward expenditures in its annual statewide Single Audit training and re-evaluate the precision of execution of controls over the validation of pass through reporting in assembling the SEFA for fiscal year 2024. Corrective Action Planned (Conditions B through E): The State largely concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. The State has already begun this corrective action plan with the agencies. With regards to condition C, for a. and b. for payments by agencies, there are standard procedures for review and authorization of invoices and payments and those payments are documented. For c. The State has already implemented an agency wide framework for subrecipient monitoring. The State will provide re-training for those agencies that had not properly documented monitoring as outlined by the subrecipient risk assessments and ensure monitoring reports are documented. With regards to condition D, The State has already implemented an agency wide framework to help ensure policies and procedures are in place concerning Uniform Guidance Reports. We will work those agencies that had not documented the date received and the review of the Uniform Guidance Reports to ensure written documentation occurs. Where findings have been reported in the Uniform Guidance Report, ensure timely Management Letters are documented and provided with the summary review of Uniform Guidance Report.

View Audit 316627

Finding 480398 (2023-004)

Material Weakness 2023

State of New Hampshire

NH

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Corrective Action Planned (Condition A): The DAS would note the definition of a subaward per 2 CFR 200.1 specifies a subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. State procurement policies require contracts,...

Corrective Action Planned (Condition A): The DAS would note the definition of a subaward per 2 CFR 200.1 specifies a subaward may be provided through any form of legal agreement, including an agreement that the pass-through entity considers a contract. State procurement policies require contracts, including contracts deemed subawards, greater than $10,000 are subject to legislative and executive branch approval prior to final execution. The resulting contracts are managed within the State’s financial system using purchase orders which in turn encumber funds. To support the testing of procurements, the State provided a detailed listing of purchase orders initiated during the audit period and in doing so clearly expressed the resulting population would include contracts considered subawards. Accordingly, the State deems the portion of selections identified as subawards to be reasonable and appropriate given the population sampled. However, the DAS will re-evaluate the precision of execution of controls over the validation of the subrecipient population in fiscal year 2024. Corrective Action Planned (Condition B): The State concurs with the findings and recommendations and has implemented procedures to address the identified conditions already or will do so. With regards to condition B, The State will work with the individual agencies to ensure that individual agencies maintain and document the search of SAM.gov for suspension and debarment.

View Audit 316627

Finding 480347 (2023-001)

Significant Deficiency 2023

Carearc, INC

KS

Special Tests & Provisions Subrecipient Monitoring Eligibility

Finding 2023.001 - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken CareArc was notified of the 2023 annual audit...

Finding 2023.001 - Sliding Fee Scale Documentation Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken CareArc was notified of the 2023 annual audit finding related to Sliding Fee Discounts being applied incorrectly according to the Health Center Program Compliance Manual and out of compliance with our sliding fee policy. CareArc's CFO was aware of the incorrect slide adjustments during the sampling process of the audit. The two patients on Slide B that should have received 50% discount, only received 49% ($3.00 miscalculation) as our electronic medical records did not identify an internal lab as being all inclusive of the same-day office visit. The corrective action plan was to have the Electronic Medical Records system recognize internal labs as being all inclusive of the same-day office visit. This issue was identified by CareArc through an internal audit in September 2023 and we began working with Health Choice Network (HCN). HCN is our vendor that helps program our electronic medical records system. HCN has helped CareArc correct the system going forward. CareArc is working with HCN on creating a report on historical slide applications to correct accounts earlier in 2023. CareArc was able to manually correct the two identified patient accounts. The corrective action plan is still in process of being implemented by CareArc with the assistance of HCN/EPIC with an estimated completion in September 2024. If there are any question regarding this plan, please e-mail Seresa Howe at showe@carearc.org.

View Audit 316606

Finding 480313 (2023-001)

Significant Deficiency 2023

Middleborough Housing Authority

MA

HUD Housing Programs Subrecipient Monitoring Reporting

The Authority had a change in Executive Director and Fee Accountant, which resulted in delayed access to the FASPHA system. The Authority will ensure timely submissions going forward.

View Audit 316534

Finding 480265 (2023-001)

Material Weakness 2023

Hancock County, Illinois

IL

Subrecipient Monitoring Internal Control / Segregation of Duties

Corrective Action Plan: The County Board will continue to review all claims provided to them. Anticipated Completion Date: The County is not in a financial position to hire additional employees. The increased monitoring has already begun. Responsible Parties: Mark Menn, County Board Chairman. 500 M...

Corrective Action Plan: The County Board will continue to review all claims provided to them. Anticipated Completion Date: The County is not in a financial position to hire additional employees. The increased monitoring has already begun. Responsible Parties: Mark Menn, County Board Chairman. 500 Main Street, P.O. Box 248 Carthage, Illinois 62321. (217) 357-3986; Kris Pilkington, County Treasurer. 500 Main Street, P.O. Box 248 Carthage, Illinois 62321. (217) 357-3986; Holly Wilde-Tillman, County Clerk. 500 Main Street, P.O. Box 248 Carthage, Illinois 62321. (217) 357-3911

View Audit 316494

Finding 480248 (2023-003)

Significant Deficiency 2023

African Development Center

MN

Reporting Subrecipient Monitoring Significant Deficiency § 200.329

Microloan Program – Assistance Listing No. 59.046 Recommendation: We recommend management develop procedures to ensure the required reporting is completed within the timeline allowed by the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit find...

Microloan Program – Assistance Listing No. 59.046 Recommendation: We recommend management develop procedures to ensure the required reporting is completed within the timeline allowed by the granting agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ADC will hire a new loan officer who will also be an SBA Microloan Program Manager then develop and implement procedures to ensure the required reporting is completed within the timeline allowed by the granting agency. Name(s) of the contact person(s) responsible for corrective action: Felicia Ravelomanatsoa (CFO) Planned completion date for corrective action plan: December 31, 2024

View Audit 316477

Finding 480132 (2023-002)

Material Weakness 2023

Freetown-Lakeville Regional School District

MA

Subrecipient Monitoring Reporting

We have received the audit findings regarding the material weakness identified in the reconciliation of the general ledger with the fiscal year 2023 reporting to the Commonwealth of Massachusetts. We appreciate the thorough review and the recommendations provided to enhance our financial management ...

We have received the audit findings regarding the material weakness identified in the reconciliation of the general ledger with the fiscal year 2023 reporting to the Commonwealth of Massachusetts. We appreciate the thorough review and the recommendations provided to enhance our financial management processes. We acknowledge the seriousness of the discrepancies identified, including the understatement of fiscal year 2023 expenditures by approximately $263,000 and the additional $208,000 of fiscal year 2024 expenditures not posted to the grant within the ledger. We are committed to addressing this material weakness promptly and effectively. In response to your recommendations, we propose the following actions: Posting Financial Activity: We will ensure all financial activity is posted as intended, as part of our overall monitoring and grants administration processes. This will involve enhanced oversight and verification procedures to confirm the accuracy of entries. Consistent Reconciliation: Biweekly/monthly reconciliation meetings will be conducted between the finance team and grants administration personnel. This will ensure that adjusting entries are posted in a timely manner, maintaining the accuracy of the general ledger and financial reports filed with pass-through entities. We will develop a reconciliation checklist/agenda to guide these meetings and ensure all discrepancies are identified and addressed promptly. Evaluation of Grants Management Policies and Procedures: We will conduct a thorough evaluation of our current grants management policies and procedures. This review will focus on identifying areas for improvement and refining our practices to enhance accuracy and compliance. As part of our routine risk assessment program, we will incorporate regular evaluations of our grants management processes to identify and mitigate risks proactively. Staff Training and Development: We will provide targeted training for our finance and grants administration staff to ensure they are well-versed in the updated procedures and reconciliation processes. This will help in maintaining the accuracy and integrity of our financial records. Cross-training programs will be implemented to ensure continuity and coverage during staff absences or turnover. Monitoring and Continuous Improvement: A robust monitoring system will be established to continuously assess the performance of our internal controls and reconciliation processes. Regular internal reviews will be conducted to ensure compliance and identify areas for further improvement. We will establish clear timelines and reporting methodologies to facilitate ongoing monitoring and timely detection and correction of errors and misstatements. We are confident that these actions will address the material weakness and significantly enhance our financial reporting processes.

View Audit 316452

Finding 480099 (2023-004)

Significant Deficiency 2023

Jefferson County Government

CO

Subrecipient Monitoring § 200.332

FISCAL YEAR OF FINDING: 2023 AUDITOR FINDING: 1. At the time of the award – County did not make subrecipients aware of Federal Assistance Listing Number or title. 2. Risk Assessment could not be provided for 2022 or 2023 to support the level of monitoring. 3. Audited financials for family tree for...

FISCAL YEAR OF FINDING: 2023 AUDITOR FINDING: 1. At the time of the award – County did not make subrecipients aware of Federal Assistance Listing Number or title. 2. Risk Assessment could not be provided for 2022 or 2023 to support the level of monitoring. 3. Audited financials for family tree for 2022 or 2023 were not obtained by the County. 4. Family Tree did not have any case review monitoring performed during 2023 – October 15, 2022. Criteria: Condition: During testing, we noted the following: - The Assistance Listings number and Title were not provided to the County's two subrecipients in accordance with 2 CFR Part 200.332(a) - The County did not have a formal documented risk assessment completed for either of the County's two subrecipients in accordance with 2 CFR Part 200.332(b) - The County did not obtain or review one of the subrecipients single audit reports in accordance with 2 CFR Part 200.332(f) Effect: The subrecipient may be unaware whether the funds are federal or what compliance requirements they are responsible for. In addition, The County may not perform the adequate level of monitoring as formal risk assessments were not completed. Finaly, the County did not review the single audit report and while any finding would not directly be related to the subaward program, failure to review such reports and take appropriate action could result in non-compliance by the subrecipient continuing for an inappropriate length of time. Cause: The County does not have adequate internal controls over subrecipient monitoring to ensure that the County is in compliance with subrecipient monitoring requirements. Recommendation: We recommend that the County develop a risk assessment template or form to be completed over each federal subrecipient. The County should provide training to those administering grants over the development risk assessment template or form and the associated monitoring to be performed based on each assessed risk. In addition, the County should develop a subrecipient grant template to help ensure all required information is included within each award. Finally, the County should establish a policy or procedure over obtaining and reviewing audits completed over each of their subrecipients. CLIENT PLANNED ACTION: 1. On 4/8/24, Jefferson County sent the two ERA subrecipients the Federal Assistance Listing Number. The County policy is to include the Subaward Data Form, which includes the Federal Assistance Listing Number (see attached), as an Exhibit in all subrecipient contracts. This was inadvertently not included in the ERA contract. 2. On 4/8/24, Jefferson County completed a formal Risk Assessments for both The Action Center and Family Tree and placed in the files. The two subrecipients are long-time partners and federal fund recipients and have undergone continuous scrutiny through regular monitoring, and a rigorous draw reimbursement process. Due to this history and knowledge, both partners were determined to be very low risk at the time of ERA awards. Moving forward, the County will complete a formal Risk Assessment for the records prior to the execution of a contract or within 6 months of execution of a contract. 3. The County has now collected the audited financial statements for the two subrecipients and retained them in the files. Subrecipient audits are regularly reviewed as part of the monitoring process to assess for any findings or concerns. Moving forward, the County will obtain the most recent audit reports and place them in the files prior to the execution of a contract or within 6 months of execution of a contract. 4. The County performed a monitoring including the scrutiny of 20% of all case files during the 2022 ERA Program and there were no findings. The County had plans to monitor the ERA2 Program at the time of this audit, after the program was running at full capacity. The County has now moved up this time frame according to the above feedback and is currently undergoing a monitoring of the 2023 cases from the two subrecipients. This process aligns with the previous year, as the program has more time during the early spring months when cases are slower. Monitoring of subrecipients began the week of April 8th. CLIENT RESPONSIBLE PARTY: Kat Douglas, Community and Workforce Development Director COMPLETION DATE: 6/25/24

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