Corrective Action Plans

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Finding Number: 2023-032 Summary of finding: Subawards were not entered into, assistance listing numbers were not communicated at the time of disbursement, an evaluation of the subrecipients risk for noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed,...
Finding Number: 2023-032 Summary of finding: Subawards were not entered into, assistance listing numbers were not communicated at the time of disbursement, an evaluation of the subrecipients risk for noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed, and subrecipient audit reports were not reviewed. Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements. Recommendation: The State agency should enhance internal controls to ensure compliance with subrecipient monitoring requirements. CAP Response: The agency agrees and accepts this finding and has taken the following steps to enhance internal controls to ensure compliance: The agency now has a subaward process and a subgrants manual. At the requirement of NDA Fiscal, approved subaward packets are being used for all applicable funding sources which include subrecipient risk assessments and subrecipient monitoring is being completed. Subaward packets are first approved by NDA Fiscal prior to distribution to recipients. The agency is developing a subaward process checklist to improve compliance with the process. Anticipated date of completion: December 30, 2025 CAP Contacts: Cathy Balcon, Administrator, Division of Administration Patricia Hoppe, Administrator, Division of Food and Nutrition
Finding 576390 (2023-030)
Significant Deficiency 2023
No 2023-030 Request for Update Condition: “Certain applicable provisions described in Appendix II to Part 200 were not included in contracts as required. Procedures were not followed to verify if an entity was suspended or debarred before entering into a covered transaction.” Recommendation: “We rec...
No 2023-030 Request for Update Condition: “Certain applicable provisions described in Appendix II to Part 200 were not included in contracts as required. Procedures were not followed to verify if an entity was suspended or debarred before entering into a covered transaction.” Recommendation: “We recommend State Purchasing enhance internal controls to ensure all contracts under federal awards contain the applicable provisions and procedures are followed to ensure entities are not suspended or debarred prior to entering into covered transactions.” Agency Response and Corrective Action to be Taken: View of Responsible Official: The Nevada State Purchasing Department agrees with the finding. As part of Purchasing’s standard contracting procedures, and shortly after the audit findings were discussed with GFO in January 2024, the Purchasing Division commenced fulfilling the recommendations regarding provisions described in Appendix II to Part 200 that had not been consistently included in contracts as indicated below. When Purchasing leads a Request for Proposal (RFP) process and is notified - via Section 4 of the RFP Template provided to agencies utilizing Federal Awarded Funds – Purchasing ensures that all applicable federal provisions and procedures are incorporated into the solicitation, either by reference or as attachments. For state agencies conducting their own solicitation, Purchasing provides an RFP Template that requires identification of the relevant Code of Federal Regulations (CFR) to be referenced and included in the resulting contract, thereby supporting compliance with federal requirements. This corrective action (RE: provisions) has been actively in place since approximately January 2024. As part of Purchasing’s updated internal controls, and shortly after the audit finding was reported, the Purchasing Division commenced fulfilling the recommendation as indicated below regarding suspended or debarred entities. Prior to Purchasing awarding a contract, the responsible Purchasing Officer performs a SAM.gov check on the vendor in question, prints out the page indicating that the entity is not suspended or debarred and then the document is attached to the Bid in ePro (Nevada’s official online portal for government procurement), which is posted publicly. This corrective action (RE: debarred entities) has been actively in place since approximately July 2023. Department or Agency Responsible for Corrective Action Plan Agency: Department of Administration – Purchasing Division Contact: William Taylor, Administrator 515 E. Musser Street, Suite 300 Carson City, NV 89701 775-515-5173 BTaylor@admin.nv.gov
Audit Finding: 2023-029 Homeowner Assistance Fund: 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Summary: Subawards and disbursements did not contain all the required information, an evaluation of each subrecipient’s risk of noncompliance for purposes of determ...
Audit Finding: 2023-029 Homeowner Assistance Fund: 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Summary: Subawards and disbursements did not contain all the required information, an evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed. Recommendation: Implement internal controls to ensure compliance with subrecipient monitoring requirements. Agency Response: The Nevada Housing Division (“Division”) agrees with the finding. The Division also acknowledges this is a prior year finding. The timing of the FY22 and FY23 state audits did not allow for any corrective actions to be reflected. Corrective Action: The Division established an internal audit and compliance committee to enhance oversight of existing policies for assessing risk, monitoring, and sharing best practices across its business in January of 2024. The internal audit and compliance committee is responsible for reviewing internal controls and policies on an annual basis, following up on any audit findings and ensuring follow-through of corrective action plans. Finally, the Division received legislative approval for an Auditor 3 position that will commence in October 2025 to support fiscal and overall grant compliance. Adoption of Corrective Action: January 2024 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov
Audit Finding: 2023-027 Emergency Rental Assistance Program: 21.023 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Subawards did not contain all the required information, assistance listing numbers were not communicated at the time o...
Audit Finding: 2023-027 Emergency Rental Assistance Program: 21.023 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Subawards did not contain all the required information, assistance listing numbers were not communicated at the time of disbursement, and there was not adequate subrecipient monitoring. Recommendation: Enhance internal controls to ensure compliance with subrecipient monitoring. Agency Response: The Nevada Housing Division (“Division”) agrees with the finding. The Division also acknowledges this is a prior year finding. The timing of the FY22 and FY23 state audits did not allow for any corrective actions to be reflected. Additionally, the Division would like to note, and be given consideration for, the substantive fact of the context of the time period in a pandemic, a once in a lifetime crisis that was impacting daily work and personal lives of all Nevadans, including Division staff. Corrective Action: In FY25, the Division moved ERAP to the Grants Team for management of the subrecipients and reporting. Additionally, the Division established an internal audit and compliance committee to enhance oversight of existing policies for assessing risk, monitoring, and sharing best practices across its business in January of 2024. The internal audit and compliance committee is responsible for reviewing internal controls and policies on an annual basis, following up on any audit findings and ensuring follow-through of corrective action plans. Finally, the Division received legislative approval for an Auditor 3 position that will commence in October 2025 to support fiscal and overall grant compliance. Adoption of Corrective Action: January 2024 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov
Finding 576384 (2023-025)
Significant Deficiency 2023
Audit Finding 2023-025 U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Summary of Finding: The Nevada Department ...
Audit Finding 2023-025 U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Summary of Finding: The Nevada Department of Transportation (NDOT) is required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. A VE analysis was not performed when required by NDOT policy because NDOT did not have adequate internal controls to ensure their VE policy was followed. Recommendation: NDOT should enhance internal controls to ensure the VE policy is followed or, if necessary, the VE policy is updated as needed and provided that it complies with federal requirements. Agency Response Does the Agency Agree with Finding: Yes Additional Comments: Current NDOT policy has a lower cost threshold (i.e. stricter) for VE analysis than the federal requirement, and the finding references and evaluated project at that lower threshold. NDOT has also had significant organizational and staffing changes since the creation of this, and many other, policies and is currently in the process of updating all agency policies. Corrective Action Action to be Taken: NDOT will update the internal policy and processes relating to VE, including roles and responsibilities and internal controls to match or exceed federal requirements and to meet agency needs and resources. Date of Completion or Estimated Completion: October 1, 2026 Contact Person: Mark Wooster, Performance Analysis Division Head, mwooster@dot.nv.gov
Finding 576289 (2023-008)
Material Weakness 2023
U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Direct Payment Award Period: 2023 Recommendation: We recommend that the County establish clear policies and procedures for formal review and approval of subrecipient monitoring checklis...
U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Direct Payment Award Period: 2023 Recommendation: We recommend that the County establish clear policies and procedures for formal review and approval of subrecipient monitoring checklists. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: The County already had established policies, procedures, and checklists related to subrecipient monitoring, but the selected subrecipient relationship did not have adequate, formal documentation that monitoring checklists were completed. Going forward the County will continue to train staff to follow these policies. The County has also put more resources towards its finance department’s audit unit in 2024 and 2025 to follow-up on the proper implementation of corrective action plans related to audit findings. Name of the contact person responsible for corrective action: Will Wallo, Finance Director Planned completion date for corrective action plan: December 31, 2024
Corrective Actions Taken or Planned Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation. Responsible person: Jackie Ramirez, Operations & Finance Associate Director ...
Corrective Actions Taken or Planned Management concurs with the finding and has already begun strengthening its reporting procedures to include the retention of submission confirmations as part of its grant documentation. Responsible person: Jackie Ramirez, Operations & Finance Associate Director Expected Implementation date: October 31, 2025.
The Organization is in the process of updating its procurement and expenditure approval procedures and will implement training for staff involved in managing federally funded programs.
The Organization is in the process of updating its procurement and expenditure approval procedures and will implement training for staff involved in managing federally funded programs.
The closing process will be improved to perform detailed reviews of the closing process and to obtain reliable and complete general ledger.
The closing process will be improved to perform detailed reviews of the closing process and to obtain reliable and complete general ledger.
Clean Water State Revolving Fund – ALN: 66.458 Finding: Schedule of Expenditures of Federal Awards Preparation Recommendation: Procedures should be implemented to ensure completion of an entry to the Schedule of Federal Expenditures of Federal Awards to achieve a reliable reporting of total expe...
Clean Water State Revolving Fund – ALN: 66.458 Finding: Schedule of Expenditures of Federal Awards Preparation Recommendation: Procedures should be implemented to ensure completion of an entry to the Schedule of Federal Expenditures of Federal Awards to achieve a reliable reporting of total expenditures for an audit period. Action Taken: The City of Hartwell recognizes its responsibility to prepare and present an accurate Schedule of Expenditures of Federal Awards (SEFA) in accordance with Uniform Guidance. To address this finding, the City will implement formal written procedures for the preparation and review of the SEFA.
Clean Water State Revolving Fund – ALN: 66.458 Finding: Material Weakness in Cash Management Controls Recommendation: We recommend that the City develop and implement formal, documented procedures and internal controls to ensure that federal funds are drawn only when needed and disbursed in a ti...
Clean Water State Revolving Fund – ALN: 66.458 Finding: Material Weakness in Cash Management Controls Recommendation: We recommend that the City develop and implement formal, documented procedures and internal controls to ensure that federal funds are drawn only when needed and disbursed in a timely manner in accordance with federal cash management requirements. This should include documented monitoring of the timing of drawdowns and corresponding disbursements. Action Taken: The City of Hartwell acknowledges the importance of establishing formal internal controls over federal cash management activities. In response to this finding, the City will develop and implement written policies and procedures specifically addressing the timing of federal drawdowns and subsequent disbursements. These actions are expected to mitigate the risk of future noncompliance and address the material weakness identified. SIGNIFICANT DEFICIENCY None Reported
Finding 2023-009 – Completion and Submission of Annual Single Audit - Significant Deficiency/Noncompliance Condition/Context: The County's Single Audit and reporting package was delayed for the year-ended December 31, 2022, as a result of turnover within its Budget and Finance Office, beyond the n...
Finding 2023-009 – Completion and Submission of Annual Single Audit - Significant Deficiency/Noncompliance Condition/Context: The County's Single Audit and reporting package was delayed for the year-ended December 31, 2022, as a result of turnover within its Budget and Finance Office, beyond the nine month due date. Corrective Action: The Controller’s office has new procedures in place to help facilitate the year end closing process so the audit can be completed in a timely manner. Responsible for Implementing Corrective Action: Controller’s Office Anticipated Completion Date: We anticipate this to be completed in coordination with the 2026 audit.
Finding 2023-008 - Uniform Guidance Subrecipient Monitoring - Significant Deficiency/Noncompliance Condition/Context: As part of our follow-up on previous audit findings and based on our current year testing, it was noted that the County is not formally documenting its monitoring activities over i...
Finding 2023-008 - Uniform Guidance Subrecipient Monitoring - Significant Deficiency/Noncompliance Condition/Context: As part of our follow-up on previous audit findings and based on our current year testing, it was noted that the County is not formally documenting its monitoring activities over its subrecipients in compliance with the Uniform Guidance. Corrective Action: The Office of Financial Management will implement a process to document all subrecipient activities in compliance with the Uniform Guidance. Responsible for Implementing Corrective Action: Office of Financial Management Anticipated Completion Date: We anticipate this to be completed in coordination with the 2026 audit.
Finding 575808 (2023-005)
Significant Deficiency 2023
The Organization is now billing actual costs for supplies as it has done for all other expenditures. Reimbursement request procedures and all accounting functions and segregation practices will be formulated in a written document that will be in place within 120 days of completion of the audit. The ...
The Organization is now billing actual costs for supplies as it has done for all other expenditures. Reimbursement request procedures and all accounting functions and segregation practices will be formulated in a written document that will be in place within 120 days of completion of the audit. The Organization accepts and understands that detailed reimbursement policies and procedures should be fully developed and implemented, and actual expenditures should be billed. The Organization believes that the actual cost of supplies allocated to the project exceeded the questioned cost. The Organization will adhere to reimbursement request policies and procedures that will be documented in a written accounting manual. The Organization agrees that the reimbursement request procedures should be performed by employees with properly segregated roles and responsibilities. While the Organization did not have enough staff to segregate all accounting responsibilities, it is continually working to define and monitor segregation policies and procedures and train employees on their duties and responsibilities to ensure that reimbursement requests and all accounting functions are properly separated
View Audit 365796 Questioned Costs: $1
Finding 575807 (2023-004)
Significant Deficiency 2023
The Organization corrected the finding prior to the audit and will continue to use the 10% de minimis indirect rate until it receives a government approved rate. The Organization allows that the indirect costs charged to the grant exceeded the maximum allowed under the grant. The Organization unders...
The Organization corrected the finding prior to the audit and will continue to use the 10% de minimis indirect rate until it receives a government approved rate. The Organization allows that the indirect costs charged to the grant exceeded the maximum allowed under the grant. The Organization understood that it could charge a higher initial provisional indirect rate, reflecting the Organization’s actual rate of allowable indirect costs, as stated in the subrecipient agreement while a negotiated indirect cost rate was pending. As the negotiated rate was not completed, The Organization understands that the initial provisional rate was not applicable and the 10% de minimis rate applies from the inception of the award agreement. The Organization will charge the de minimis indirect rate to the project until a federally negotiated rate agreement is approved by the government
View Audit 365796 Questioned Costs: $1
Finding 575804 (2023-002)
Significant Deficiency 2023
Accounting records have been modified to record unbilled costs under grants and contracts, and billings submitted after completion of this audit will be reconciled to the general ledger. The Organization acknowledges that all accounting system records did not agree to the billing invoices and recogn...
Accounting records have been modified to record unbilled costs under grants and contracts, and billings submitted after completion of this audit will be reconciled to the general ledger. The Organization acknowledges that all accounting system records did not agree to the billing invoices and recognizes the importance of maintaining accurate and timely accounting records. The Organization notes that it was not found that any variances between system records and billing invoices resulted in questioned costs. The Organization will establish and follow detailed policies and procedures to thoroughly track and record all grant award expense transactions. Accounting records will be modified to include the recordation of unbilled costs under grants and contracts. Billings will be reconciled to the general ledger prior to the submission of invoices to third parties
Finding 575777 (2023-004)
Significant Deficiency 2023
Management is aware of deposit requirements and has committed the resources to ensure minimum deposit requirements are met.
Management is aware of deposit requirements and has committed the resources to ensure minimum deposit requirements are met.
The district engaged in multiple construction projects using ESSER funds. Two projects were not in compliance with the prevailing wage reporting requirements. The district has updated policy 6114 – Cost Principles – Spending Federal Funds on 6/27/2022 and 1/27/2025 to comply with the Davis-Bacon A...
The district engaged in multiple construction projects using ESSER funds. Two projects were not in compliance with the prevailing wage reporting requirements. The district has updated policy 6114 – Cost Principles – Spending Federal Funds on 6/27/2022 and 1/27/2025 to comply with the Davis-Bacon Act. In addition, the district now ensures all construction contracts are presented to and reviewed by legal counsel to ensure compliance with federal, state and local laws.
Finding 2023-001 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Sam Muse, Finance and Administration Director Corrective Action: JEDC will implement a policy in which, whenever Federal or State dollars are transferred to JEDC, JEDC will obtain written clarific...
Finding 2023-001 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Sam Muse, Finance and Administration Director Corrective Action: JEDC will implement a policy in which, whenever Federal or State dollars are transferred to JEDC, JEDC will obtain written clarification from the entity transferring the money expressly indicating whether JEDC is a contractor or a subrecipient of the monies. Additionally, JEDC will use a “checklist” to confirm and verify that determination and will seek additional clarification if there is any disagreement in the classifications. Proposed Completion Date: July 1, 2024.
Finding Number 2023-002 Contact Person(s): Brianna Mariani – BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: ...
Finding Number 2023-002 Contact Person(s): Brianna Mariani – BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and only grant Housing Hope has administered that required subrecipient monitoring. The grant has since ended and the organization does not anticipate entering any future agreements that would require subrecipient monitoring. To ensure compliance should such an agreement arise again, Housing Hope will adopt a Subrecipient Monitoring Policy. This policy will outline the criteria for identifying subrecipient relationships and establish a standardized process for monitoring subrecipients, if any are engaged in the future. Anticipated completion date: The Subrecipient Monitoring Policy will be adopted by October 2025 Board meeting.
Finding 575294 (2023-002)
Significant Deficiency 2023
Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.
Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.
Corrective Action Plan: ALN 93.441: The Tribe’s HR Department will develop and implement policies and procedures requiring that character investigations be performed for all program personnel. In addition, notation of the appropriate independent verification will be clearly notated. ALN 93.575 and 9...
Corrective Action Plan: ALN 93.441: The Tribe’s HR Department will develop and implement policies and procedures requiring that character investigations be performed for all program personnel. In addition, notation of the appropriate independent verification will be clearly notated. ALN 93.575 and 93.596: The Program hired a Training Monitor. The Training Monitor is responsible for scheduling training and ensuring all providers are up to date on training that is required by the CCDF program. The documentation will be kept on file. Person(s) Responsible: Violet Black Cloud, Human Resources Director,Jackie Brownotter, Child Care Assistance Program Director Estimated Completion Date: September 30, 2025, December 31, 2024
2023-002 Compliance and Internal Controls over Subrecipient Fiscal Monitoring (Significant Deficiency) Corrective Action: In accordance with 2 CFR Section 200.332, The Resource Group as the pass-through entity will ensure subrecipient fiscal monitoring is completed in 2024 to ensure compliance with ...
2023-002 Compliance and Internal Controls over Subrecipient Fiscal Monitoring (Significant Deficiency) Corrective Action: In accordance with 2 CFR Section 200.332, The Resource Group as the pass-through entity will ensure subrecipient fiscal monitoring is completed in 2024 to ensure compliance with federal and state requirements. The Finance Director is responsible for oversight and administration of fiscal monitoring. Fiscal monitoring will be conducted at least annually in accordance with HRSA Monitoring Standards 45 CFR 74.51 and 45 CFR 75.352. As a pass-through entity, fiscal monitoring will include at minimum reviews of financial performance and compliance with federal and state statues, regulations and terms and conditions. The process will include desktop/remote verification of applicable financial policy and procedures and an onsite review. A standardized monitoring tool will be used to evaluate financial compliance. The fiscal monitoring observations will result in a monitoring report, disseminated to the subrecipient within 60 days of the onsite review. Progress to date: 1. To support the financial monitoring efforts, technical assistance was received on February 5-7, 2024, from the DSHS Fiscal Support and Oversight Department. The primary objective of the visit was to discuss financial monitoring requirements as it applies to state and federal regulations, statues and terms and conditions. The standardized monitoring tool was also evaluated for compliance. 2. The Finance Director developed and implemented a comprehensive fiscal monitoring schedule for calendar year 2024. In alignment with strengthened oversight practices, onsite fiscal reviews of subrecipients commenced in February 2024. As part of the enhanced monitoring approach, the testing period for subrecipient fiscal reviews was expanded beyond the standard scope to include transactions and activities from both Fiscal Year 2022 and Fiscal Year 2023. 3. As of September 2024, the Finance Director completed 100% of fiscal monitoring visits. a. Support Documentation: to establish additional guidelines for fiscal monitoring, the Fiscal Monitoring Policy was drafted and approved by the Board on November 18, 2024. 3 Responsible Party: Finance Director, Garland Thompson Date Complete: November 18, 2024
Status: In progress. Planned Corrective Action: The New Orleans Career Center will update its financial policies to require verifying all vendors against the SAM.gov suspension and debarment list. Person(s) Responsible: Claire Jecklin, CEO; Darius Munchak, CFO Estimated Completion Date: December 31,...
Status: In progress. Planned Corrective Action: The New Orleans Career Center will update its financial policies to require verifying all vendors against the SAM.gov suspension and debarment list. Person(s) Responsible: Claire Jecklin, CEO; Darius Munchak, CFO Estimated Completion Date: December 31, 2025
Status: In progress. Planned Corrective Action: The New Orleans Career Center will update its financial policies to ensure that employees classified to federal programs receive updated offer letters detailing their compensation. Person(s) Responsible: Claire Jecklin, CEO; Darius Munchak, CFO Estimat...
Status: In progress. Planned Corrective Action: The New Orleans Career Center will update its financial policies to ensure that employees classified to federal programs receive updated offer letters detailing their compensation. Person(s) Responsible: Claire Jecklin, CEO; Darius Munchak, CFO Estimated Completion Date: December 31, 2025
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