Corrective Action Plans

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Finding 402736 (2023-045)
Significant Deficiency 2023
Finding 2023-045 Temporary Assistance for Needy Families, ALN 93.558 - MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a. and c., MDHHS will continue to provide training for local office security coordinators (LOS...
Finding 2023-045 Temporary Assistance for Needy Families, ALN 93.558 - MiSACWIS Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a. and c., MDHHS will continue to provide training for local office security coordinators (LOSCs) via quarterly webinars to emphasize the appropriate procedures for granting access, reviewing, and comparing access. All new information related to security access is presented to the LOSCs during the webinars and one-on-one assistance is available as needed for additional support. For part b., MDHHS currently has a process in place to review the user narrative describing the incompatible role exceptions within the DSA Michigan Statewide Automated Child Welfare Information System (MiSACWIS) request as part of the approval process. MDHHS will continue to work on adding an incompatible role form in the DSA MiSACWIS request with automated routing for appropriate approval. Anticipated Completion Date a. and c. Corrective action is ongoing. b. MDHHS has not yet determined an anticipated completion date because implementation is dependent on funding, approval, and prioritization of other proposed system changes. Responsible Individual(s) Alana Lowe, MDHHS Deon Nelson, MDHHS
Finding 402721 (2023-043)
Significant Deficiency 2023
Finding 2023-043 Immunization Cooperative Agreements, ALN 93.268 - MCIR User Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS received approval for an exception allowing them to disable inactive accounts after 120 days instead of 60 days, which was i...
Finding 2023-043 Immunization Cooperative Agreements, ALN 93.268 - MCIR User Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS received approval for an exception allowing them to disable inactive accounts after 120 days instead of 60 days, which was implemented May 8, 2024. The exception was requested and granted because the Michigan Care Improvement Registry (MCIR) users include non-SOM users that do not log in as frequently. MDHHS will develop and implement a manual process to deactivate users from the MDHHS sites in MCIR that have not been accessed in 120 days. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Abigail Cheney, MDHHS Ryan Malosh, MDHHS Beatrice Salada, MDHHS
Finding 402719 (2023-042)
Significant Deficiency 2023
Finding 2023-042 Public Health Emergency Preparedness, ALN 93.069 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS hired a financial analyst during May 2024 to assist with subrecipient monitoring. MDHHS evaluated the...
Finding 2023-042 Public Health Emergency Preparedness, ALN 93.069 - Risk Assessment and During-the-Award Monitoring Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS hired a financial analyst during May 2024 to assist with subrecipient monitoring. MDHHS evaluated the subrecipient monitoring plan and revised as needed. Although MDHHS conducts quarterly reviews of Financial Status Reports and requests supporting documentation based on reviews, MDHHS will annually consider if any additional monitoring activities are necessary based on the annual risk assessment results. Anticipated Completion Date Completed Responsible Individual(s) Jay Fiedler, MDHHS Brianna Briggs, MDHHS
Finding 402594 (2023-037)
Significant Deficiency 2023
Finding 2023-037 CCDF Cluster, ALN 93.575 and 93.596 - Subaward Information Management Views MiLEAP agrees with the finding. Planned Corrective Action MiLEAP will develop procedures for reviewing award documents, which will include verifying a unique entity identifier and federal award project d...
Finding 2023-037 CCDF Cluster, ALN 93.575 and 93.596 - Subaward Information Management Views MiLEAP agrees with the finding. Planned Corrective Action MiLEAP will develop procedures for reviewing award documents, which will include verifying a unique entity identifier and federal award project description are included on each award. Anticipated Completion Date October 1, 2024 Responsible Individual(s) Lisa Brewer Walraven, MiLEAP
Finding 2023-010 MDE - FFATA Reporting Management Views MDE and the Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP) agree with the finding. Planned Corrective Action For part a., MDE and MiLEAP, going forward, will verify all grants will be tracked for the Federal Fu...
Finding 2023-010 MDE - FFATA Reporting Management Views MDE and the Michigan Department of Lifelong Education, Advancement, and Potential (MiLEAP) agree with the finding. Planned Corrective Action For part a., MDE and MiLEAP, going forward, will verify all grants will be tracked for the Federal Funding Accountability and Transparency Act (FFATA), reviewing all systems the grants are awarded from. For part b.1., MDE and MiLEAP will continue to coordinate with the program offices to improve the FFATA reporting process in order to submit subaward information in accordance with FFATA and other applicable federal guidance. The corrective action will begin on October 1, 2024 with an anticipated completion date of October 31, 2025. For part b.2., MDE and MiLEAP have completed FFATA reporting using the actual expenditures for the purpose of verifying subrecipients have not exceeded the awarded amounts. To meet the requirements as outlined in 2 CFR 170, MDE and MiLEAP will update the reporting process to include all key data elements, including the net dollar amount of federal funds awarded to the subawardee, including modifications. Part b.3., MDE will work with all MDE program offices and MiLEAP to include the correct program descriptions in the FFATA reporting. Anticipated Completion Date a. Completed b.1. October 31, 2025 b.2. October 31, 2025 b.3. December 31, 2024 Responsible Individual(s) Spencer Simmons, MDE Bethanie Kramer, MiLEAP
Finding 402557 (2023-012)
Significant Deficiency 2023
Finding 2023-012 Title I Grants to Local Educational Agencies, ALN 84.010 and Supporting Effective Instruction State Grants, ALN 84.367 - Participation of Private School Children Management Views MDE agrees with the finding. Planned Corrective Action In spring 2023, the MDE Office of Educational S...
Finding 2023-012 Title I Grants to Local Educational Agencies, ALN 84.010 and Supporting Effective Instruction State Grants, ALN 84.367 - Participation of Private School Children Management Views MDE agrees with the finding. Planned Corrective Action In spring 2023, the MDE Office of Educational Supports developed a new system of support and created a new Local Education Agency (LEA) application and documentation collection process in the MDE Grant Electronic Monitoring System/Michigan Administrative Review System (GEMS/MARS) for fiscal year 2024. In September 2023, a new Equitable Services Ombudsman was hired to work collaboratively with leadership in the Office of Educational Supports to support LEAs and monitor the private school consultation process according to federal requirements. In January 2024, the LEA collection process in GEMS/MARS began for the Equitable Service Ombudsman to review LEAs consultation documents and provide ongoing technical assistance and support. MDE anticipates developing additional LEA resources and supports by June 30, 2025. Anticipated Completion Date June 30, 2025 Responsible Individual(s) Michael Powell, MDE Chanel DeGuzman, MDE
Finding 402553 (2023-032)
Significant Deficiency 2023
Finding 2023-032 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Subaward Information Management Views MDHHS and MDE agree with the finding. Planned Corrective Action For part a., MDHHS updated the grantee profile in EGrAMS with the correct unique entity identifier (UEI). In additi...
Finding 2023-032 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Subaward Information Management Views MDHHS and MDE agree with the finding. Planned Corrective Action For part a., MDHHS updated the grantee profile in EGrAMS with the correct unique entity identifier (UEI). In addition, the MDHHS Federal Reporting Section will ensure all federal grant awards are recorded in SIGMA and included on the department’s Grants Received Report. The Grants Received Report will be maintained on the department’s SharePoint site for use by those within the department. All data elements required to comply with federal funding requirements, such as 2 CFR 200, will be included on the Grants Received Report. In the event data elements are missing from the report, the MDHHS Federal Reporting Section will follow up with the awarding agency, program area, or others to update the missing data elements within 30 days of receipt of the award. The Bureau of Grants and Purchasing will use the information from the Grants Received Report to communicate information to the subrecipients in accordance with 2 CFR 200. For part b., the grant award notification (GAN) recipient information is pulled directly from the Education Entity Master, including the UEI and the Federal Award Identification Number (FAIN). The GAN template is included as part of the grant requirement gathering process. Beginning with the 2024 fiscal year, MDE will require all grant awards using MDE Coronavirus State and Local Fiscal Recovery Funds to use this MDE GAN notification process. For those subrecipients whose grants continue past fiscal year 2023, MDE will evaluate any exceptions and determine whether subsequent communication can be made to the subrecipients to provide the correct subaward information. Anticipated Completion Date a. September 30, 2024 b. October 1, 2024 Responsible Individual(s) a. Jeanette Hensler and Steve Bendele, MDHHS b. Spencer Simmons, MDE Richard Lower, MiLEAP
Finding 402551 (2023-030)
Significant Deficiency 2023
Finding 2023-030 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Workfront Security Management and Access Controls Management Views DTMB agrees with the finding. Planned Corrective Action For part a., DTMB has implemented processes and documentation to track user access requests to...
Finding 2023-030 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Workfront Security Management and Access Controls Management Views DTMB agrees with the finding. Planned Corrective Action For part a., DTMB has implemented processes and documentation to track user access requests to support approval of the system role for all Workfront users. For part b., DTMB has updated processes to ensure it maintains documentation to support the review of all privileged Workfront accounts on a semiannual basis. Anticipated Completion Date Completed Responsible Individual(s) Jennifer Edmonds, DTMB
Finding 2023-058 Unemployment Insurance, ALN 17.225 See Department of Labor and Economic Opportunity, Unemployment Insurance Agency - Unemployment Compensation Fund, Report on Expenditure of Federal Awards, Year Ended September 30, 2023, Corrective Action Plan, Finding 2023-001.
Finding 2023-058 Unemployment Insurance, ALN 17.225 See Department of Labor and Economic Opportunity, Unemployment Insurance Agency - Unemployment Compensation Fund, Report on Expenditure of Federal Awards, Year Ended September 30, 2023, Corrective Action Plan, Finding 2023-001.
View Audit 309982 Questioned Costs: $1
Finding 402527 (2023-023)
Significant Deficiency 2023
Finding 2023-023 Pandemic EBT Food Benefits, ALN 10.542 - Accuracy of Financial Reports Management Views MDHHS agrees with the finding. Planned Corrective Action The Food and Nutrition Service has ended the P-EBT program and there will be no additional expenses after February 2024. However, for th...
Finding 2023-023 Pandemic EBT Food Benefits, ALN 10.542 - Accuracy of Financial Reports Management Views MDHHS agrees with the finding. Planned Corrective Action The Food and Nutrition Service has ended the P-EBT program and there will be no additional expenses after February 2024. However, for the last report submitted during May 2024, MDHHS implemented a report review process prior to certification to ensure the P-EBT financial report information is accurate. Anticipated Completion Date Completed Responsible Individual(s) Bethany Cabanaw, MDHHS
Finding 402492 (2023-006)
Significant Deficiency 2023
Finding 2023-006 MDE, Security Management and Access Controls Management Views The Michigan Department of Education (MDE) agrees with the finding. Planned Corrective Action For part a., as part of the Michigan Nutrition Data (MiND) 2.0 Implementation Project, MDE will institute a mechanism to capt...
Finding 2023-006 MDE, Security Management and Access Controls Management Views The Michigan Department of Education (MDE) agrees with the finding. Planned Corrective Action For part a., as part of the Michigan Nutrition Data (MiND) 2.0 Implementation Project, MDE will institute a mechanism to capture the person to whom the access has been delegated. MDE will review the policies and procedures with department staff that is responsible for security access controls for the Next Generation Grant, Application and Cash Management System (NexSys) to ensure proper access control policies are followed. For part b., MDE will update policies and procedures to ensure review of all accounts on a semi-annual basis. For parts c. and d., MDE will continue to work with DTMB to find more efficient ways to ensure all non-privileged users are recertified and improve the technical solution to deactivate users after 18 months of inactivity. For part e., as part of the movement of the grants management unit at MDE to a different office, MDE is reviewing the policies around high-risk transactions and will update the policies to meet established standards. Anticipated Completion Date October 1, 2024 Responsible Individual(s) David Judd, MDE
Finding 402476 (2023-020)
Significant Deficiency 2023
Finding 2023-020 SNAP Cluster, ALN 10.551 and 10.561 - System and Organization Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., the Electronic Benefits Transfer (EBT) service provider releases all SOC reports via an administrative view on the provide...
Finding 2023-020 SNAP Cluster, ALN 10.551 and 10.561 - System and Organization Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For part a., the Electronic Benefits Transfer (EBT) service provider releases all SOC reports via an administrative view on the provider website. MDHHS will maintain documentation of the date the reports are pulled from the EBT service provider site. Additionally, MDHHS will modify the review process so that the individual completing the evaluation is different from the individual approving the evaluation to ensure segregation of duties is maintained. For parts b. and c., MDHHS will assess the current process and make improvements as needed to ensure subservice organizations are adequately evaluated. Based on the evaluation, MDHHS will perform reviews of sub-organization SOC reports where required. Anticipated Completion Date September 30, 2024 Responsible Individual(s) Andrew Piper, DHHS Dani Wager, DHHS
Finding 2023-004 Income Eligibility and Verification System Management Views MDHHS agrees with parts a., b., and d. of the finding. MDHHS disagrees with parts c. and e. of the finding. For part c., MDHHS disagrees that a process is not fully established to monitor the electronic notifications prov...
Finding 2023-004 Income Eligibility and Verification System Management Views MDHHS agrees with parts a., b., and d. of the finding. MDHHS disagrees with parts c. and e. of the finding. For part c., MDHHS disagrees that a process is not fully established to monitor the electronic notifications provided to county/district office caseworkers to ensure they utilized the Income Eligibility Verification System (IEVS) information to determine the recipients' eligibility. Although MDHHS did not implement the Bridges change to require an action comment before the county/district office caseworkers dispose of the electronic notifications until July 2023, MDHHS had policies and procedures in effect during fiscal year 2023 to help ensure monitoring of electronic notifications was taking place. Review of IEVS information is fully incorporated into the case read procedure governed by Bridges Administrative Manual 301 and detailed further in desk aids and reading guides. The Economic Stability Administration (ESA) provides regular direction and reminders of case read requirements via ESA Memos. For part e., MDHHS disagrees that IEVS information is required to be requested and obtained for modified adjusted gross income (MAGI) based recipients since eligibility is verified upon determination through the MAGI eligibility determination process and then granted for a 12-month continuous eligibility period. Requesting and obtaining IEVS information throughout the eligibility period would be irrelevant since eligibility is continuous. Planned Corrective Action For parts a. and b., MDHHS’s ESA will continue to provide training and policy support to ensure that the local office specialists appropriately utilize the IEVS interface information in determining recipients’ eligibility when applicable. ESA implemented a technical solution during July 2023 for applicable interfaces to ensure the IEVS information is being addressed timely and used correctly in eligibility determinations. For part d., MDHHS is collaborating with other work areas to facilitate the match process for the IEVS interfaces for recipients funded by Temporary Assistance for Needy Families (TANF) adoption subsidies. For parts c., and e., MDHHS disagrees with the finding and does not intend to take further action. Anticipated Completion Date a. and b. Ongoing c. Not applicable d. September 30, 2024 e. Not applicable Responsible Individual(s) a., b., and c. Veronica Maxson, MDHHS d. Kathonya Rice, MDHHS e. Logan Dreasky, MDHHS
View Audit 309982 Questioned Costs: $1
Finding 2023-002 Bridges Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a., c., and d., MDHHS implemented the Database Security Application (DSA) on October 2, 2023, which includes documenting incompatible role exception ...
Finding 2023-002 Bridges Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a., c., and d., MDHHS implemented the Database Security Application (DSA) on October 2, 2023, which includes documenting incompatible role exception requests and user access request approvals. The DSA also includes semi-annual review of privileged users and annual review for all users. For parts b. and e., MDHHS will revise internal business processes to include an additional level of monitoring and review to ensure compliance with the existing directives related to monitoring and review requirements. Anticipated Completion Date a., c., and d. Completed b. and e. August 2024 Responsible Individual(s) a., c., and d. Deon Nelson, MDHHS b. and e. Veronica Maxson, MDHHS
Finding Related to Federal Awards 2023-001 Procurement – Suspension and Debarment Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Bond Guarantee Program - ALN 21.014 Federal Grant Numbers: 19-BGA-00003 ...
Finding Related to Federal Awards 2023-001 Procurement – Suspension and Debarment Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Bond Guarantee Program - ALN 21.014 Federal Grant Numbers: 19-BGA-00003 Contact Person: Varun Agnihotri, Manager Director, Portfolio Management, 732-640-2061 Corrective Action: A process and checklist will be put in place to ensure the independent status search is performed on recipients when a payment is made. The process and checklist will include a verification by someone other than the person preparing the request. Anticipated Completion Date: September 30, 2024
The City will use a subrecipient audit certification form and a subrecipient risk assessment questionnaire to evaluate a subrecipient's risk/experience with federal funds as well as assess their federal funding threshold for having a single audit.
The City will use a subrecipient audit certification form and a subrecipient risk assessment questionnaire to evaluate a subrecipient's risk/experience with federal funds as well as assess their federal funding threshold for having a single audit.
The City will ensure that subrecipient contracts will include language about suspension and debarment. The City will also download a PDF copy of the subrecipients registration on SAM.GOV showing the subrecipient's Exclusion Summary Status.
The City will ensure that subrecipient contracts will include language about suspension and debarment. The City will also download a PDF copy of the subrecipients registration on SAM.GOV showing the subrecipient's Exclusion Summary Status.
The City will work with all HOPWA subrecipients to ensure that a complete and accurate CAPER is completed in the appropriate format as required by HUD. This will include a focus on inputting the correct (eg, actual expended vs. award amount) funding amount.
The City will work with all HOPWA subrecipients to ensure that a complete and accurate CAPER is completed in the appropriate format as required by HUD. This will include a focus on inputting the correct (eg, actual expended vs. award amount) funding amount.
The City will use the contract start date (7/1) as the Obligation date, and will submit the FFATA report accordingly.
The City will use the contract start date (7/1) as the Obligation date, and will submit the FFATA report accordingly.
The City will incorporate a more formal review of financial audits of subrecipients in conjunction with new contracts moving forward. These audits, and City staff's verification of assessment will be included in each subrecipient file.
The City will incorporate a more formal review of financial audits of subrecipients in conjunction with new contracts moving forward. These audits, and City staff's verification of assessment will be included in each subrecipient file.
The two individuals determined to have incomes in excess of HOME Program limits were noted in our FY23 monitoring of properties assisted with HOME funds. The HOME Program allows for a unit to be occupied by a household who was initially eligible and whose income later increases, but requires that a ...
The two individuals determined to have incomes in excess of HOME Program limits were noted in our FY23 monitoring of properties assisted with HOME funds. The HOME Program allows for a unit to be occupied by a household who was initially eligible and whose income later increases, but requires that a comparable unit be designated as a HOME unit and leased to an eligible household when one is available. Owners of each property were made aware of the circumstance when City monitoring was completed. Each will designate comparable units to be HOME units when available and lease them to eligible households.
The City has established an Audit Review Certification form that is completed by employees to formally document review of subrecipient agencies' audit reports.
The City has established an Audit Review Certification form that is completed by employees to formally document review of subrecipient agencies' audit reports.
Based on prior year (FY22) findings, the City established the following procedures to ensure payment requests received from subrecipients are paid within 30 days of receipt of a complete request for reimbursement: 1. Department of Human Service Programs (DHSP) Contract Manager reviews invoices withi...
Based on prior year (FY22) findings, the City established the following procedures to ensure payment requests received from subrecipients are paid within 30 days of receipt of a complete request for reimbursement: 1. Department of Human Service Programs (DHSP) Contract Manager reviews invoices within 5 business days of receipt of request for reimbursement from subrecipient. a. If invoice is complete, original date of receipt is recorded. b. If invoice is incomplete, subrecipient is notified of items or documentation that is missing and receipt date is updated to reflect date of receipt of complete invoice. 2. Contract Manager approves payment request and submits to DHSP Fiscal staff for processing. 3. Fiscal staff processes and submits to Auditing Department as Priority payment. Four of the 19 sampled payment requests were received or processed after receipt of the FY22 audit findings, and all of those requests for reimbursement were paid within 30 days of receipt.
Based on the finding in the prior year audit, the City updated the subrecipient contract template in spring 2023 prior to execution of contracts for the FY24 ESG program year and will continue to utilize the updated template to ensure required language certifying that the agency, its officers, and e...
Based on the finding in the prior year audit, the City updated the subrecipient contract template in spring 2023 prior to execution of contracts for the FY24 ESG program year and will continue to utilize the updated template to ensure required language certifying that the agency, its officers, and employees are not suspended or debarred from doing business with the federal government. Staff will continue to verify that subrecipients are not suspended or debarred by checking against the Sam.gov Exclusion List and registration pages prior to executing contracts, and will document those checks through grant management meeting minutes and Smartsheet tracking.
The Finance Director and the Assistant Finance Director both attended additional training regarding the preparation of the Schedule of Expenditures of Federal Awards. A complete internal control schedule separate from the Purchasing Policy will be written and in place by June 30, 2024.
The Finance Director and the Assistant Finance Director both attended additional training regarding the preparation of the Schedule of Expenditures of Federal Awards. A complete internal control schedule separate from the Purchasing Policy will be written and in place by June 30, 2024.
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