Corrective Action Plans

Finding 508522 (2023-009)

Material Weakness 2023

MD

Subrecipient Monitoring Cash Management Eligibility § 200.303

U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Eligibility Repeat Finding: Yes Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 14...

U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Eligibility Repeat Finding: Yes Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 14 out of 40 files did not have management review. Corrective Action: The Program Manager will conduct quality control reviews for 30% of files that have been recertified each month. The quality control review will verify all eligibility components under the program were met. Condition #2 Response MOHS acknowledges the finding that 25 out of 40 selections did not have the supporting thirdparty documentation of income. MOHS followed the HOPWA guidance outlined in the Self- Certification of Income and Credible Information on HIV Status waivers released by HUD for September 2021 and March 2023. The waiver permits HOPWA grantees and project sponsors to rely upon a family member’s self-certification of income and credible information on their HIV status. The HUD-CPD notices are referenced in Exhibits A-B of this response. The program accepted the self-certification of income until the waivers from HUD ended for COVID-19 on March 31, 2023. Corrective Action: MOHS has resumed following the process of requesting third party verification of income, assets, and medical expenses to ensure proper calculation of tenant rent. Client records are being updated with the appropriate verification of income documentation from the third-party source. Condition #3 Response MOHS acknowledges the finding 6 out of 40 selections did not have documentation of the rent reasonableness. Corrective Action: MOHS uses GoSection8, an online rent comparable website to conduct rent reasonableness. Rent reasonableness is conducted at the initial move-in and with each rent increase request. Documentation of the comparison is maintained in the client record. Contact Person: Lakeysha Williams – 410-396-4887 or Lakeysha.williams@baltimorecity.gov Completion Date: July 2024

View Audit 329082

Finding 508521 (2023-008)

Material Weakness 2023

City of Baltimore, Maryland

MD

Cash Management Subrecipient Monitoring § 200.303

U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Auditee’s Corrective Action Plan: MOHS has developed a comprehensive standard operations p...

U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Auditee’s Corrective Action Plan: MOHS has developed a comprehensive standard operations procedure for our program compliance and fiscal teams. This manual includes a standardized process of completing drawer requests, having supporting documentation that aligns with the request stored in each contracts permanent file on the agencies shared “G drive which is accessible to all fiscal staff. In addition, our fiscal team is required to adopt a naming conversion for each grant and draw request, Confirmation of payment posting to the GL and save supporting documentation to the Fiscal “G drive”. Contact Person: MOHS Fiscal Director – Diamond Okojie Completion Date: July 2024

View Audit 329082

Finding 508490 (2023-026)

Significant Deficiency 2023

City of Baltimore, Maryland

MD

Subrecipient Monitoring Cash Management Reporting § 200.303

U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Significant Deficiency in Internal Controls and Noncompliance over Special Tests - Housing Quality Standards Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the compr...

U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Significant Deficiency in Internal Controls and Noncompliance over Special Tests - Housing Quality Standards Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the comprehensive review of this program and concurs with this finding. It is the responsibility of DHCD to perform physical inspections annually. This process includes creating and maintaining inspection review forms and correspondence with the inspected properties. We believe the oversights discovered were caused in part to an increase in the workload of the sole compliance officer performing the physical inspections. Because of this increase in workload, exacerbated by impromptu medical leave, the other compliance officers have received some cross training in HQS inspecting and are now available to assist in the record keeping process. The unit is also in the process of hiring an additional Compliance Officer to assume the physical inspection responsibilities. Additionally, all active compliance officers will review the program’s standard operating procedures for inspections. If necessary, any needed adjustments to the plan will be made at this time. We will also review all FY 24 inspections to ensure that all Inspection Findings and Corrective Measures have been issued and are available in the department’s shared drive. Contact Person: Eugene Greene, HOME Program Manager Completion Date: December 2024

View Audit 329082

Finding 508489 (2023-025)

Material Weakness 2023

City of Baltimore, Maryland

MD

Subrecipient Monitoring Cash Management Material Weakness § 200.303

U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Material Weakness in Internal Controls and Noncompliance over Program Income Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the comprehensive review of this program ...

U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Material Weakness in Internal Controls and Noncompliance over Program Income Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the comprehensive review of this program and concurs with this finding. The Department of Housing and Community Development (DHCD) understands that while the City of Baltimore’s Department of Finance is responsible for recording and reporting program income into the general ledger, DHCD must ensure that ensure funds are properly recorded in the accounting records. Therefore, DHCD will work with the Department of Finance to ensure that program income deposits are documented correctly, are properly reflected on the general ledger and deposited into the correct accounts. Going forward, DHCD will request the general ledger details for all program income deposits on a minimum quarterly basis to ensure its accuracy and availability. Contact Person: Eugene Greene, HOME Program Manager Completion Date: December 2024

View Audit 329082

Finding 508443 (2023-006)

Material Weakness 2023

City of Baltimore, Maryland

MD

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.414 § 200.502 § 200.508 § 200.510

Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although W...

Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients’ information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. The City has: • Held weekly meetings for two years with agency grant representatives to design and configure the Workday grant module. • Uploaded the grant award, sponsor information and grant budget data into a Workday. • Implemented a “new grant” request which uses a Workday business process. • In the process of reviewing and correcting recoverable costs per grant award so it is properly recorded. • Within Workday we are able to track grant performance period, CFDA, manage and capture grant related expenditures and calculate automated billing to sponsors on recoverable costs Business processes have been developed and implemented in Workday’s grant management module to include: Definition of the grant funding source by creating a system-generated grant work tag (identifier) upon receipt of the Sponsor’s Notice of Award; populated fields in Workday with passthrough award data with Prime Sponsor and Bill to sponsor Billing data, and modification of the create award process to add the Grants Management Office to final approval. In FY 24 the City implemented a citywide Grants Management Committee coordinated by the Mayor's Office of Performance and Innovation. Through feedback from this workgroup we identified an expanded scope of responsibility for the Grants Management Office; including oversight and compliance, technology, training and budget monitoring. In the short term a new Grants Director position was created and onboarding is to occur in the first quarter of FY25. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024

View Audit 329082

Finding 508411 (2023-006)

Material Weakness 2023

Sanilac County Community Mental Health Authority

MI

Reporting Subrecipient Monitoring Material Weakness § 200.502 § 200.510

Condition: The Authority did not identify that they were subject to an audit under the Uniform Guidance (U.G.) and a schedule of expenditures of federal awards (SEFA) was not prepared by management. Recommendation: The Authority should review federal, state, and local grants to determine if they a...

Condition: The Authority did not identify that they were subject to an audit under the Uniform Guidance (U.G.) and a schedule of expenditures of federal awards (SEFA) was not prepared by management. Recommendation: The Authority should review federal, state, and local grants to determine if they are federally funded and, if federally funded, utilize the account number outlined in the State of Michigan chart of accounts to track federal funding. Planned Corrective Action: A schedule of federal awards will be created to track total costs covered by federal awards beginning in FY24. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

View Audit 329033

Finding 508408 (2023-003)

Material Weakness 2023

Sanilac County Community Mental Health Authority

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.317 § 200.318 § 200.319 § 200.320 § 200.327

Condition: The Authority did not utilize federal procurement requirements cited above for the tele-health services and SUD Peer Recovery Service contracted service providers utilized for the Certified Community Behavioral Health Clinics project. (no documentation for sole source, no proof that it wa...

Condition: The Authority did not utilize federal procurement requirements cited above for the tele-health services and SUD Peer Recovery Service contracted service providers utilized for the Certified Community Behavioral Health Clinics project. (no documentation for sole source, no proof that it was advertised, google search was provided from 7/24/24 is not sufficient, board cannot waive federal requirement). Recommendation: The Authority follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Planned Corrective Action: Going forward the Authority will follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024

View Audit 329033 Questioned Costs: $1

Finding 508369 (2023-004)

Significant Deficiency 2023

Ford County, Kansas

KS

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking § 200.305

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine...

The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Grantee Response: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

View Audit 328978

Finding 508265 (2023-003)

None 2023

McDonald County, Missouri

MO

Subrecipient Monitoring Reporting

The County Clerk and County Treasurer watched the live informational Zoom meeting to learn how to fill out the SLFRF Project and Expenditures Report correctly. For entities who received less than $10 million in SLFRF, the entity was allowed to report the total amount as a loss in revenue. The slide ...

The County Clerk and County Treasurer watched the live informational Zoom meeting to learn how to fill out the SLFRF Project and Expenditures Report correctly. For entities who received less than $10 million in SLFRF, the entity was allowed to report the total amount as a loss in revenue. The slide show was difficult to understand and follow, but we mistakenly thought we were supposed to put $0 on that part of the report. After the auditors discussed this error with me, I went to the reporting website to correct the error; however, the website would not allow changes to the report after a certain period of time. In the future we will report the difference in total expenditures between the two reporting periods. McDonald County is of the opinion that the U.S. Department of Treasury has changed reporting requirements, information, and acceptable expenditures so many times, they have made the reporting requirements difficult to understand or follow. We will do our best to not have an error in the next report.

View Audit 328800

Finding 508222 (2023-002)

Material Weakness 2023

Snohomish School District No. 201

WA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2023-002 Finding caption: The District’s internal controls were inadequate for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Tom Laufmann, Executive Director of Business Services 1601 Ave D Snohomish, WA 98...

Finding ref number: 2023-002 Finding caption: The District’s internal controls were inadequate for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Tom Laufmann, Executive Director of Business Services 1601 Ave D Snohomish, WA 98290 360-563-7239 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). For future contracts, the district will make sure to follow all policies and procedures. In particular, the district will ensure that multiple quotes will be obtained before entering any contract and that all staff involved in contract awards are re-educated and aware of this requirement. Anticipated date to complete the corrective action: 8/31/24

View Audit 328694 Questioned Costs: $1

Finding 508217 (2023-001)

None 2023

Snohomish School District No. 201

WA

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs

Finding ref number: 2023-001 Finding caption: The District charged unallowable costs to the Supply Chain Assistance award of the Child Nutrition Cluster. Name, address, and telephone of District contact person: Tom Laufmann, Executive Director of Business Services 1601 Ave D Snohomish, WA 98290 3...

Finding ref number: 2023-001 Finding caption: The District charged unallowable costs to the Supply Chain Assistance award of the Child Nutrition Cluster. Name, address, and telephone of District contact person: Tom Laufmann, Executive Director of Business Services 1601 Ave D Snohomish, WA 98290 360-563-7239 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The district is making multiple checks for processed vs unprocessed foods claimed in the Supply Chain Assistance award. This includes multiple staff reviewing the claimed items and cross-checking against the 2022-23 claim. All items deemed processed are removed from the claim. Anticipated date to complete the corrective action: 8/31/2024

View Audit 328694 Questioned Costs: $1

Finding 508206 (2023-001)

Material Weakness 2023

Young Women's Christian Association of Newburyport

MA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Pursuant to Standards for Internal Control in the Federal Government, Principle 16-Performing Monitoring Activities, management should monitor its internal control system through ongoing monitoring and separate evaluations including but not limited to comparisons, reconciliations and other routine a...

Pursuant to Standards for Internal Control in the Federal Government, Principle 16-Performing Monitoring Activities, management should monitor its internal control system through ongoing monitoring and separate evaluations including but not limited to comparisons, reconciliations and other routine actions. Young Women’s Christian Association of Newburyport, d/b/a YWCA Greater Newburyport, its Affiliate and Subsidiaries’ is in the process of developing internal control procedures over reconciliation and recognition of Federal funds. The person responsible for this periodic reconciliation of Federal funds will indicate their review keeping documentation of their analysis on file with the accounting office. John Feehan, Executive Director, is responsible for implementing this corrective action plan.

View Audit 328674

Finding 508045 (2023-003)

None 2023

Town of Clinton

MA

Subrecipient Monitoring Period of Performance Reporting § 200.344

2023-003: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout proced...

2023-003: Deficiency in Internal Controls and Compliance Finding -COVID-19 – Education Stabilization Fund – ALN 84.425: Two final financial reports due during the prior fiscal years were not submitted. (Questioned Costs: None) The Town of Clinton/School Department will follow grants closeout procedures, consequently, the district will monitor closely all grants spending throughout each grant cycle. For both state-administered and direct grants, regardless of the period of availability, the District must liquidate all obligations incurred under the award Reports not later than 90 days after the end of the funding period unless an extension is authorized. These procedures have been updated in the Financial Procedures Manual (pages 226-230 under Section G— Timely Obligation of Funds)

View Audit 328582

Finding 508033 (2023-004)

Material Weakness 2023

Fredonia-Moccasin Unified School District No. 6

AZ

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

2023-004 ACTIVITIES ALLOWED OR UNALLOWED Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111175-01A and 21FESIII-111175-01A Questioned Costs: $13...

2023-004 ACTIVITIES ALLOWED OR UNALLOWED Program: Education Stabilization Fund Federal Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESSII-111175-01A and 21FESIII-111175-01A Questioned Costs: $133,105 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: A. Activities Allowed or Unallowed Condition/Context: During our testing of expenditures, it was noted that eleven expenditures with a total of $133,105 were not included within the Education Stabilization Fund budget as approved by the Arizona Department of Education. Corrective Action: The District will ensure all expenditures are approved by the SEA before purchase. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Dorene Mudrow, Superintendent

View Audit 328565 Questioned Costs: $1

Finding 508015 (2023-005)

None 2023

Dolton School District 149

IL

Reporting Subrecipient Monitoring

Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 6 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting...

Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 6 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/2024. Name of Contact Person: Dr. Maureen M. White, Superintendent. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.

View Audit 328528

Finding 508014 (2023-004)

None 2023

Dolton School District 149

IL

Reporting Subrecipient Monitoring

Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 12 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporti...

Condition: The District did not comply with the requirements of filing quarterly and period reports by the due dates set by ISBE. A total of 12 reports were filed late. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: 6/30/2024. Name of Contact Person: Dr. Maureen M. White, Superintendent. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.

View Audit 328528

Finding 507988 (2023-002)

Material Weakness 2023

Solidaridad North America

CA

Subrecipient Monitoring Allowable Costs / Cost Principles

The Organization will implement procedures to guarantee the proper supervision for subgrantees in a timely manner.

View Audit 328475

Finding 507975 (2023-002)

Significant Deficiency 2023

Boys & Girls Club of Huntington County, Inc.

IN

Reporting Subrecipient Monitoring Significant Deficiency § 200.501

2023-002 Twenty-First Century Community Learning Centers -Assistance Li st ing No. 84.287 Significant Deficiency in Internal Control Over Compliance -Appropriate Monitoring of Levels of Federal Funding Recommendation: The Auditor recommends BGCH should implement policies and procedures to periodical...

2023-002 Twenty-First Century Community Learning Centers -Assistance Li st ing No. 84.287 Significant Deficiency in Internal Control Over Compliance -Appropriate Monitoring of Levels of Federal Funding Recommendation: The Auditor recommends BGCH should implement policies and procedures to periodically monitor federal funding and expenditure levels throughout the year to ensure a level of awareness regarding whether an audit under the Uniform Guidance may be applicable for the current year. In addition, the Organization should prepare a schedule of federal expenditures (SEFA) as part of its year-end closing process, which reconciles to the general ledger. The SEFA and data used to prepare the SEFA should be reviewed by a separate individual within the Organization with knowledge of the related reporting requirements, as outlined in the Uniform Guidance, to ensure its accuracy and completeness. The schedule should be used to determine whether an audit in accordance with the provisions of the Uniform Guidance is required so that an auditor may be engaged to perform a timely audit. Planned Corrective Action: We agree with the recommendation and plan to have the corrective action implemented by December 31, 2024. Boys & Girls Club of Huntington Finance Board Subcommittee discusses this item throughout the fiscal year and is in the Board minutes, but has not put a written policy in place. A policy will be created by the Finance Board Subcommittee at the October meeting, presented to the full Board of Directors at the November Board meeting and voted on at the December 2024 Board meeting.

View Audit 328454

Finding 507908 (2023-002)

Significant Deficiency 2023

Centennial Board of Cooperative Educational Services

CO

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management

7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they w...

7. Management Response: Centennial BOCES will begin monitoring and collecting monthly time and effort for all listed employees of subgrantees. Centennial BOCES will continue to collect time and effort documentation within Centennial BOCES staff. The BOCES will treat subgrantee employees as if they were Centennial BOCES employees regarding collection of time and effort reports following appropriate policies and procedures. At fiscal year-end a reconciliation of all documents required, including time and effort documentation, will be completed.

View Audit 328448

Finding 507799 (2023-003)

Significant Deficiency 2023

Wilsona School District

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.439

The District will ensure that all proposed capital expenditures originating from any Federal sources that are in excess of $5,000 are pre-approved by CDE prior to executing the proposed transaction.

View Audit 328293 Questioned Costs: $1

Finding 507793 (2023-002)

Significant Deficiency 2023

Wilsona School District

CA

Subrecipient Monitoring Reporting Significant Deficiency

Moving forward, the District will ensure that all items reported to various agencies, including the California Department of Education, are supported and are retained to external review.

View Audit 328293

Finding 507424 (2023-015)

Significant Deficiency 2023

The Howard University

DC

Subrecipient Monitoring § 200.403

Name of Responsible Individual: Bruce Jones, Vice President of Research, Marchon Jackson, Associate Vice President of Research, Dana Hector, Assistant Vice President, Sponsored Grants & Programs Corrective Action: The process to review subrecipient invoices will be improved by requiring the review ...

Name of Responsible Individual: Bruce Jones, Vice President of Research, Marchon Jackson, Associate Vice President of Research, Dana Hector, Assistant Vice President, Sponsored Grants & Programs Corrective Action: The process to review subrecipient invoices will be improved by requiring the review of supporting documents to ensure expenses are allowable by the newly established Sponsored Program Office (SPO) post award team. This team will thoroughly review supporting documents to ensure expenses are allowable, allocable, reasonable and recorded in the proper period according to university policies and grant terms. Invoices will be reviewed by SPO and will serve as the key control point before transactions are forwarded to accounting to post to sponsored awards. The Director of Compliance will conduct spot checks on all sponsored transactional activity, especially for high-risk grants to provide an additional layer of oversight. The new review process and training for these responsibilities will be implemented by spring 2025 as part of the broader campus-wide workflow training and staffing up of the new SPO post-award office. The Director of Post Award Compliance will be hired by March 2025. Anticipated Completion Date: March 31, 2025

View Audit 328267

Finding 507058 (2023-014)

Significant Deficiency 2023

The Howard University

DC

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR ...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: The internal control procedures for federal expenditures will be reviewed and updated to ensure that they comply with federal regulations such as the Uniform Guidance (2 CFR 200) and the Federal Acquisition Regulation (“FAR”). The roles and responsibilities of staff involved in managing and reviewing federal expenditures will be explicitly defined. All personnel handling federal funds will be trained on policies, compliance requirements, and how to detect red flags in grant activity. The approval workflow for federal expenditures will be assessed and updated by adding Sponsored Programs Office to the approval path to assist in preventing fraud and ensure compliance with regulations. The internal controls will be updated by December 2024 and training will commence in early 2025 Anticipated Completion Date: December 31, 2024

View Audit 328267 Questioned Costs: $1

Finding 507052 (2023-013)

Significant Deficiency 2023

The Howard University

DC

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporti...

Name of Responsible Individual: Brenda Willis, Senior Executive Director of Financial Grants & Contracts Corrective Action: Howard University is implementing the billing and reporting modules in the Workday ERP to significantly reduce manual reconciliations and improve accuracy in financial reporting. The reporting errors identified by the auditors have been adjusted and the reporting corrected. A more detailed review of the billing has been implemented and a more formally documented review process is being developed. It is expected to be completed by December 2024. Anticipated Completion Date: December 31, 2024

View Audit 328267

Finding 506325 (2023-011)

Significant Deficiency 2023

The Howard University

DC

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from f...

Name of Responsible Individual: Designated Compliance Officer and Warren Petty, Chief Human Resource Officer Corrective Action: Awards between the University and federal sponsors, publications (including conference presentations, promotional material, agendas, and internet sites) that result from federal grant support must include an acknowledgment of support and a disclaimer that the contents are the authors' responsibility and not the grantors. As this is a repeat finding, the University has reviewed previous measures. It is revising internal procedures and internal controls to promote compliance with federal agreements by including the required acknowledgments and disclaimers in all relevant publications. Action Steps: 1. Communication a. Create Current Researcher Email List Serv for distribution of information/reminders. b. Send out a campus-wide email detailing the audit finding and the importance of compliance. Communication will Include information about the upcoming training requirements. c. We will distribute information regarding this finding to our researchers every quarter via the listserv. d. Completion: The first distribution will occur on October 1, 2024 2. Develop Training Materials a. Create training materials that outline the requirements for acknowledgments and disclaimers in publications. b. Include examples of compliant and non-compliant publications. c. Completion: Second Quarter of FY 2025 3. Campus-Wide Training a. Comprehensive Online training includes an exam through Blackboard/an electronic delivery method. b. Annual mandatory training sessions are required for all faculty, researchers, and administrative staff involved in grant-funded project. c. Completion: Second Quarter of FY 2025 4. Award Specific Training a. During the Award Kickoff Meetings award, specific requirements for acknowledgment of support and a disclaimer terms and conditions will be reviewed with the Principal Investigator. b. Links to Most Federal sponsors' requirements are also maintained on the Office of Research website at Federal Sponsor Requirements for Acknowledging Funding | Howard University Office of Research. This information will be communicated during kickoff meetings. 5. Ongoing Monitoring and Compliance a. Maintain records of all training attendance. b. Sponsored Programs Office Pre-Award will be responsible for quarterly random spot checks of publications. c. Prior to the Submission of the proposal, the Sponsored Programs Office (Pre-Award) will review compliance with training requirements. d. Non-compliant Faculty will not be able to submit proposals if training is delinquent. Anticipated Completion Date: June 30, 2025

View Audit 328267

Corrective Action Plans

Filters