Corrective Action Plans

Finding 503332 (2023-004)

Significant Deficiency 2023

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.430

The City has implemented the recommendation first contained in 2022-007. There is a process in place where supervisor review and approval of timesheets is completed and documented. That process continues and will be in place for the entirety of the fiscal year ending June 30, 2024. Responsible Perso...

The City has implemented the recommendation first contained in 2022-007. There is a process in place where supervisor review and approval of timesheets is completed and documented. That process continues and will be in place for the entirety of the fiscal year ending June 30, 2024. Responsible Person: Kevin Saycocie Expected Implementation Date: 07/01/2024

View Audit 325493

Finding 503330 (2023-006)

Material Weakness 2023

City of Montebello

CA

Subrecipient Monitoring Internal Control / Segregation of Duties HUD Housing Programs

Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit ...

Management endeavors to submit all required reports by required deadlines. While acknowledging that this does not always occur, the City has made vast improvements on timeliness of reports, especially PR29’s for CDBG and HOME. The year-end reports (June 30) due by July 30 can be difficult to submit timely if year-end close has not been completed. Regardless management is committed to ensuring all reports are filed within the 30 day timeframe. Responsible Person: Sarby Singh Expected Implementation Date: 07/01/2024

View Audit 325493

Finding 503328 (2023-001)

None 2023

Michigan Veterans Foundation, Inc.

MI

Subrecipient Monitoring Reporting § 200.507

MVF will implement additional training and monitoring to ensure timeliness with compliance requirements.

View Audit 325485

Finding 503298 (2023-002)

Significant Deficiency 2023

Saint Charles County, Missouri

MO

Procurement, Suspension & Debarment Subrecipient Monitoring

Suspension and Debarment U.S. Department of Transportation U.S. Department of Treasury U.S. Department of Health and Human Services Recommendation: None, the County has implemented internal controls to ensure suspension and debarment assessments are performed before a contract is awarded. Explanat...

Suspension and Debarment U.S. Department of Transportation U.S. Department of Treasury U.S. Department of Health and Human Services Recommendation: None, the County has implemented internal controls to ensure suspension and debarment assessments are performed before a contract is awarded. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will continue to ensure that suspension and debarment assessment are performed. Name(s) of the contact person(s) responsible for corrective action: Tracy Bayne Planned completion date for corrective action plan: Appropriate corrected actions were implement on December 31, 2023.

View Audit 325463

Finding 503296 (2023-001)

Significant Deficiency 2023

Saint Charles County, Missouri

MO

Subrecipient Monitoring Reporting Significant Deficiency

FFATA Reporting U.S. Department of Housing and Urban Development Recommendation: We recommend the County implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports and training employees on the FFATA reporting requirements...

FFATA Reporting U.S. Department of Housing and Urban Development Recommendation: We recommend the County implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports and training employees on the FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will identify all federal awards that FFATA reporting is required. Once all of the requirements are identified, the County will then determine if there are eligible subrecipients or contracts that need to be reported on the FFATA website. Name(s) of the contact person(s) responsible for corrective action: Tracy Bayne Planned completion date for corrective action plan: December 31, 2024

View Audit 325463

Finding 503289 (2023-002)

Material Weakness 2023

Catholic Charities of the Diocese of Tulsa, Inc.

OK

Allowable Costs / Cost Principles Subrecipient Monitoring

Department’s Response: We concur. Views of Responsible Officials and Corrective Action: Time charged to the grants was based on an estimate of efforts and did not have records to support actual time spent on grant activities. Subsequent to June 30, 2023, CCEOK implemented policies to ensure timeshee...

Department’s Response: We concur. Views of Responsible Officials and Corrective Action: Time charged to the grants was based on an estimate of efforts and did not have records to support actual time spent on grant activities. Subsequent to June 30, 2023, CCEOK implemented policies to ensure timesheets completed by staff and approved by program managers are used to calculate compensation billed to federal awards to ensure that employee time billed to the grants adequately supported. Any true up calculations needed to ensure accuracy will be completed by the end of the grant period. Name of Contact Person: Lisa Wheeler, CPA Director of Finance Lwheeler@CCEOK.org 918-508-7118 Projected Implementation: July 1, 2024

View Audit 325382

Finding 503177 (2023-005)

Material Weakness 2023

Wallowa Resources, Inc.

OR

Questioned Costs Subrecipient Monitoring Material Weakness

2023-005: U.S. Department of Agriculture - Soil and Water Conservation - Assistance Listing #10.902 Reporting: Material Weakness in Internal Control over Compliance and Material Non-Compliance Finding Summary: Due to an error with the online submission portal, Wallowa Resources was unable to submit...

2023-005: U.S. Department of Agriculture - Soil and Water Conservation - Assistance Listing #10.902 Reporting: Material Weakness in Internal Control over Compliance and Material Non-Compliance Finding Summary: Due to an error with the online submission portal, Wallowa Resources was unable to submit the required information to FSRS. Corrective Action Pan: USDA fixed the online submission portal in September 2024, and Wallowa Resources immediately submitted the required information to FSRS. Wallowa Resources will ensure that any future obligations to first-tier subrecipients will be reported via FSRS in a timely manner. Responsible Individual(s): Joni Maasdam, Finance Manager. Anticipated Completion Date: Completed September 2024.

View Audit 325232 Questioned Costs: $1

Finding 503176 (2023-004)

Significant Deficiency 2023

Wallowa Resources, Inc.

OR

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.331 § 200.332

2023-004: U.S. Department of Agriculture - Soil and Water Conservation - Assistance Listing #10.902 Subrecipient Monitoring: Significant Deficiency in Internal Control over Compliance and Non-Compliance Finding Summary: Several required elements per 2 CFR 200.331 being absent from the subrecipient ...

2023-004: U.S. Department of Agriculture - Soil and Water Conservation - Assistance Listing #10.902 Subrecipient Monitoring: Significant Deficiency in Internal Control over Compliance and Non-Compliance Finding Summary: Several required elements per 2 CFR 200.331 being absent from the subrecipient agreements, including: Subrecipients’ unique entity identifier, Federal award date of award to Wallowa Resources by the USDA, and ALN number and dollar amount made available by the USDA Wallowa Resources was unable to provide support that subrecipients were assessed for suspension and debarment during the risk assessment. Corrective Action Plan: Wallowa Resources will implement a formal subrecipient monitoring policy using the guidance of 2 CFR 200.332. We are aware of this policy and have used it before. It was an oversight in this case – due in part to the fact that the subrecipients were recommended to us by NRCS staff and were in good standing with NRCS. Responsible Individual(s): Joni Maasdam, Finance Manager. Anticipated Completion Date: October 2024.

View Audit 325232

Finding 503161 (2023-006)

Material Weakness 2023

City of Auburn, Maine

ME

Subrecipient Monitoring Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Management Response/Corrective Action Plan: Additional reports will be run to verify totals before filings of quarterly reports, paying particular attention to end of year and the needed reversal of the prior year payroll accrual. Errors found in reports will be corrected in subsequent records as al...

Management Response/Corrective Action Plan: Additional reports will be run to verify totals before filings of quarterly reports, paying particular attention to end of year and the needed reversal of the prior year payroll accrual. Errors found in reports will be corrected in subsequent records as allowable under Department of Treasury grant reporting guidelines.

View Audit 325183

Finding 503072 (2023-007)

Material Weakness 2023

Point of Freedom

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.512

Finding 2023-007: Timely Submission of Single Audit Report (SAR) and Document Collection Form (DCF) To eliminate this finding recurring in future periods, POF will create an internal Annual Audit Plan (AAP), identifying required tasks, deliverables, due dates, and responsible internal and external ...

Finding 2023-007: Timely Submission of Single Audit Report (SAR) and Document Collection Form (DCF) To eliminate this finding recurring in future periods, POF will create an internal Annual Audit Plan (AAP), identifying required tasks, deliverables, due dates, and responsible internal and external personnel for each task. POF’s AAP will include five-six (5-6) months' lead time prior to future mandatory submission dates. Simultaneously, POF will communicate the AAP timelines with the Audit Engagement Partner to ensure audit staffing continuity and availability. POF will achieve accurate, complete, and timely future SAR and DCF submissions through incorporating these process improvements along with strengthening its internal controls, gaining experience in its first two Single Audits, and in acquiring an understanding of the Auditor’s role in verifying compliance and the adequacy of related supporting documentation.

View Audit 325057

Finding 503071 (2023-006)

Material Weakness 2023

Point of Freedom

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Eligibility

Finding 2023-006 Supporting Documents for Eligibility Requirements During September 2024, POF updated its Housing Procedures Manual in compliance with Section 200.303 of Uniform Guidance and Ohio Recovery House Regulations. This document now more fully addresses, among other things, eligibility and...

Finding 2023-006 Supporting Documents for Eligibility Requirements During September 2024, POF updated its Housing Procedures Manual in compliance with Section 200.303 of Uniform Guidance and Ohio Recovery House Regulations. This document now more fully addresses, among other things, eligibility and required minimum documentation standards. POF has already begun to build individual client files to retain and periodically update these required supporting documents for all Its affected residential clients.

View Audit 325057

Finding 503070 (2023-005)

Material Weakness 2023

Point of Freedom

OH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.1 § 200.303

Finding 2023-005 Accuracy of Federal Reports POF's initial and current exposure a few months later to Single Audit compliance requirements have sharpened its focus on the need to purposefully identify and maintain corroborating evidence regarding its timely submission and acceptance by each of the ...

Finding 2023-005 Accuracy of Federal Reports POF's initial and current exposure a few months later to Single Audit compliance requirements have sharpened its focus on the need to purposefully identify and maintain corroborating evidence regarding its timely submission and acceptance by each of the respective funding sources. While POF believes that all these reporting requirements were timely met and accepted by all funding sources, It did not consistently maintain either the report itself, or the related documentation such as copies of the emails sent or the associated read-receipts as evidence of these reports. Effective July 1, POF routinely and consistently accumulated and organized these documents as well as ancillary evidence of their transmission to, receipt by, and acknowledgement of acceptance by the federal agency. POF will be more diligent in its transmissions to funders. POF noted that the 2022 Closeout Report was inexplicably re-submitted instead of the correct 2023 Closeout Report. This is unacceptable, and POF will add a second set of reviews by a second person to improve quality control in this area. As necessary, POF will seek professional education and advice in implementing policies, practices, and procedures in addition to those already described herein.

View Audit 325057

Finding 503069 (2023-004)

Material Weakness 2023

Point of Freedom

OH

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.516

Finding 2023-004 Adequate Allowable Cost Documentation As indicated in the 2022 POFCAP response to Finding 2022-003, and as reiterated herein, POF began to implement additional internal control procedures and practices effective July 1, 2024, to ensure that underlying cost documentation is adequate...

Finding 2023-004 Adequate Allowable Cost Documentation As indicated in the 2022 POFCAP response to Finding 2022-003, and as reiterated herein, POF began to implement additional internal control procedures and practices effective July 1, 2024, to ensure that underlying cost documentation is adequate, reasonable, and complete in accordance with 2 CFR Part 200 Subpart E and other regulatory requirements. More specifically, vendor invoices as of that date and related supporting documents such as weekly meeting reports and sign-in sheets are being scanned and retained electronically. As in 2022, the contact information from the 2023 weekly reports was transmitted to either Wright State University or The Ohio State University for data mining purposes. On July 22, 20224, the POF Board of Directors unanimously adopted the POF Record Retention Policy, as recommended by the auditors. The Board also unanimously adopted a Code of Conduct along with Conflict of Interest, and Whistleblower policies as further evidence of their commitment to instituting policies and procedures designed to strengthen internal controls and comply with federal regulations. Questioned Cost Totaling $19,179 Effective July 1, 2024, POF's new internal control policies, and procedures will eliminate or drastically reduce future discrepancies of this nature.

View Audit 325057 Questioned Costs: $1

Finding 503037 (2023-001)

Significant Deficiency 2023

Family Service Center of Galveston County

TX

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Family Service Center recognizes the important of a complete and accurate SEFA. Family Service Center will thoroughly review all federal and state award contracts to insure accurate and correct CFDA numbers are recorded properly on the SEFA

View Audit 325016

Finding 503036 (2023-009)

Material Weakness 2023

County of Orangeburg

SC

Procurement, Suspension & Debarment Subrecipient Monitoring

In fiscal year 2023, this function was the responsibility of the Grants Administrator. However, because of the high turn-over rate with this position, this finding was the result of a management oversight. The County has added the Procurement Director’s position to the contact of person(s) responsib...

In fiscal year 2023, this function was the responsibility of the Grants Administrator. However, because of the high turn-over rate with this position, this finding was the result of a management oversight. The County has added the Procurement Director’s position to the contact of person(s) responsible for this action. The current Procurement Director began employment with the County in October 2023.

View Audit 325007

Finding 502973 (2023-001)

Significant Deficiency 2023

Grace House INC

MS

Subrecipient Monitoring Cash Management Material Weakness

Views of Responsible Officials and Planned Corrective Action – Grace House has created and will implement the following new controls: a) Every reimbursement request made by any employee will require approval from the Executive Director, Assistant Director, or board of directors vote where appropriat...

Views of Responsible Officials and Planned Corrective Action – Grace House has created and will implement the following new controls: a) Every reimbursement request made by any employee will require approval from the Executive Director, Assistant Director, or board of directors vote where appropriate. b) For rental invoices, the immediate supervisor must approve all rental invoices for payment processing before being submitted to the administrative office. If the immediate supervisor is absent, the invoice must be approved by the Executive Director or Assistant Director. c) When a new client invoice is submitted for approval for an existing approved landlord, the invoice along with the traditional client identifying information will be reviewed by both the immediate supervisor and the Executive Director.d) When a new client invoice is submitted for approval for a new landlord, the invoice will be reviewed by both the immediate supervisor and the Executive Director. Each invoice requires a W9 form to validate the legal name, property records verifying ownership matching the legal name on the W9, a picture ID of the individual listed on the W9, and a copy of the agreement if a property management company is listed on the W9 instead of an individual. e) All new clients and landlords will be researched through an investigative software to prove there is no evidence of false identity. f) Grace House has contracted an independent certified fraud investigator to conduct periodic reviews for compliance with fraud prevention policies at least semiannually but beginning quarterly through 2025

View Audit 324929

Finding 502962 (2023-005)

Significant Deficiency 2023

Campbell County

WY

Subrecipient Monitoring § 200.331

Community Services Block Grant, ALN 93.569 Condition/Cause/Context: The County did not follow the documented policy or procedure for evaluating potential subgrantees’ risk of noncompliance prior to award of subgrants for purposes of determining the appropriate subrecipient monitoring. The County wa...

Community Services Block Grant, ALN 93.569 Condition/Cause/Context: The County did not follow the documented policy or procedure for evaluating potential subgrantees’ risk of noncompliance prior to award of subgrants for purposes of determining the appropriate subrecipient monitoring. The County was not aware of their own policy and requirements of Uniform Guidance related to pass-through entities” responsibility to perform and retain written risk assessment as part of subrecipient monitoring. The County does have a policy in place in conformity with Federal Uniform Guidance criteria relating to evaluating the risk of noncompliance prior to awarding subgrants. However, the policy was not followed during the fiscal year under audit. Views of Responsible Officials and Planned Corrective Action: The Campbell County Board of Commissioners concur with this finding and the related audit recommendation. Campbell County perpetually evaluates, updates, and compiles formal written policies and procedures for grants administration. The grants administration policy is consistent with the requirements of Uniform Guidance, as documented within the previously compiled and adopted County Uniform Guidance implementation package. In response to the criteria and condition of the finding regarding the written risk assessment was performed for the overall program and for the subrecipients. However, the written formal documentation was not retained for three of the four subrecipients through oversight. Formal checklists will be compiled and maintained within each grant file to ensure compliance with Guidance and retention of relevant documentation. The following individuals can be contacted for further information: Commissioner’s Office: Shelly Edwards, Chief Finance Executive, Sandra Beeman, Administrative Director and Kristin Young, Grants Management Specialist

View Audit 324926

Finding 502900 (2023-001)

Significant Deficiency 2023

Reset to Success Foundation, Inc.

IL

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

We will engage with an outside consultant/independent CPA firm to review and manage the internal control process. This corrective action will be implemented by December 31, 2024 by the Administrator and Board.

View Audit 324851

Finding 502724 (2023-008)

Significant Deficiency 2023

Martin University

IN

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring § 200.303

United States Department of Education 2023-008 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financ...

United States Department of Education 2023-008 Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2024

View Audit 324814

Finding 502715 (2023-007)

None 2023

County of Lee, Virginia

VA

Questioned Costs Subrecipient Monitoring Cash Management

The County will obtain and review periodic financial statements and/or underlying documentation and obtain a copy of the annual audit report in accordance with Uniform Guidance.

View Audit 324806 Questioned Costs: $1

Finding 502709 (2023-013)

Significant Deficiency 2023

Grady County

OK

Subrecipient Monitoring Period of Performance Reporting § 200.1 § 200.303 § 200.329 § 200.344

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

View Audit 324754

Finding 502708 (2023-012)

Material Weakness 2023

Grady County

OK

Subrecipient Monitoring § 200.332

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants.

View Audit 324754

Finding 502707 (2023-007)

Material Weakness 2023

Grady County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

View Audit 324754

Finding 502706 (2023-006)

Material Weakness 2023

Grady County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties

We will work to implement a risk assessment plan. We will implement controls to help make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compliance supplement...

We will work to implement a risk assessment plan. We will implement controls to help make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compliance supplement to work from.

View Audit 324754

Finding 502674 (2023-003)

Material Weakness 2023

City of Homer, Alaska

AK

Subrecipient Monitoring Material Weakness Reporting § 200.512

Finding 2023-003 Deadline for Federal Single Audit – Reporting – Noncompliance and Material Weakness in Internal Control over Compliance Planned Corrective Actions: The Finance Department is continuing its efforts in establishing and enforcing internal deadlines to ensure the financial statements ar...

Finding 2023-003 Deadline for Federal Single Audit – Reporting – Noncompliance and Material Weakness in Internal Control over Compliance Planned Corrective Actions: The Finance Department is continuing its efforts in establishing and enforcing internal deadlines to ensure the financial statements are audited within the appropriate reporting deadlines. The department has shifted staff duties to ensure the FY24 financial statements will be completed within the appropriate reporting deadlines. Individual(s) Responsible for Corrective Action Plan Elizabeth Fischer (Finance Director) Jenna deLumeau (Controller) Anticipated Completion Date: The department has developed internal deadlines to ensure the FY24 financial statements will be completed within the appropriate reporting deadlines. This has been completed.

View Audit 324691

Corrective Action Plans

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