Corrective Action Plans

Finding 398580 (2023-001)

Material Weakness 2023

WA

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

The District made sure the Federal Wage Rate requirements were in the contract as a requirement. The District relied on the contracted Architect to ensure these requirements were followed before the district received the pay application. The District now understands that a designated district progr...

The District made sure the Federal Wage Rate requirements were in the contract as a requirement. The District relied on the contracted Architect to ensure these requirements were followed before the district received the pay application. The District now understands that a designated district program director should receive weekly certified payroll reports to ensure compliance. On the next project that requires Prevailing Wage Rates, the District will make sure to receive weekly certified payroll reports to ensure compliance.

View Audit 307312

Finding 398554 (2023-003)

Significant Deficiency 2023

First Housing Corporation D/b/a Cathedral Manor

CT

HUD Housing Programs Eligibility Subrecipient Monitoring

4. Finding 2023-003 – Major Federal Award Programs Audit c. Comments on the Finding and Recommendation We concur with the auditors finding as follows: In connection with our lease files review we noted the following deficiencies: • 1 out of 1 move-outs tested did not have the inspection signed by t...

4. Finding 2023-003 – Major Federal Award Programs Audit c. Comments on the Finding and Recommendation We concur with the auditors finding as follows: In connection with our lease files review we noted the following deficiencies: • 1 out of 1 move-outs tested did not have the inspection signed by the tenant or an employee at the property. • 1 out of 1 move-outs tested did not have the inspection dated by an employee at the property. • 1 out of 1 move-ins tests did not have the tenant’s Enterprise Verification Form (“EIV”) performed timely within the 90 days HUD requires. d. Action(s) Taken or Planned on the Finding Management Agent Management has hired a new Compliance Manager and engaged a 3rd party compliance monitoring company to review all files and EIV processes effective 5/1/2024. Regards Kimalee Williams

View Audit 307266

Finding 398515 (2023-001)

Significant Deficiency 2023

City of Haverhill

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 10...

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Education The City of Haverhill, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2023. Name and address of independent public accounting firm: Powers & Sullivan, LLC 100 Quannapowitt Parkway, Suite 101 Wakefield, MA 01880 Audit period: July 1, 2022 through June 30, 2023 The finding from the June 30, 2023, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. DEPARTMENT OF EDUCATION Passed through the Massachusetts Department of Elementary and Secondary Education Title I Grants to Local Educational Agencies Title I Grants to Local Educational Agencies Federal Assistance Listing No. 84.010 Special Education Cluster Special Education Grants to States and Special Education Preschool Grants Federal Assistance Listing Numbers, 84.027 and 84.173. COVID-19 Education Stabilization COVID-19 Education Stabilization Federal Assistance Listing Numbers, 84.425, 84.425C, 84.425D, 84.425U, and 84.425W Twenty-First Century Community Learning Centers Twenty-First Century Community Learning Centers Federal Assistance Listing Numbers, 84.287 and 84.287C 2023-001: Controls for Monitoring Payroll Charged to the Grant Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Compliance and Significant Deficiency in Internal Control over Compliance Criteria or Specific Requirement: Grantees must provide reasonable assurance that Federal awards are expended only for allowable activities and that the costs of goods and services charged to Federal awards are allowable and in accordance with the applicable cost principles. Condition: Management has not established written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management also has not adopted and implemented standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Questioned Costs: None reported. Context: Payroll expenditures charged to the programs are required to be supported with documentation substantiating that the employees are eligible to be charged to the grant and that the payroll charged relates to time spent accomplishing grant objectives. This supporting documentation should be standardized and should include all required elements in accordance with Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. The City did not have an adequate system of internal controls in place to provide sufficient documentation to demonstrate compliance with federal and state time and effort reporting requirements in accordance with the provisions of Title 2 U.S. Code of Federal Regulations Part 225 Cost Principals for State, Local, and Indian Tribal Governments. Effect: The City has not complied with the federal and state time and effort reporting requirements. Cause: Lack of documented policies, procedures and guidelines in place to ensure compliance with time and effort reporting requirements. Repeat Finding: This matter was reported as a finding for the Title I major program and special education cluster grants in the previous year as finding 2022-001. Recommendation: Management should establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures should indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and should indicate due dates for when this information must be provided to the school business office. Management should also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training should be provided to ensure that the program managers fully understand the time and effort reporting requirements. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and will establish written guidelines and procedures outlining the time and effort reporting and documentation requirements that department heads must adhere with to ensure compliance with federal and state time and effort reporting requirements. Such guidelines and procedures will indicate under what circumstances semi-annual certifications and personnel activity reports (PARS) are required and will indicate due dates for when this information must be provided to the school business office. Management will also adopt and implement standardized forms for semi-annual certifications and PARS that include all data required by federal and state guidelines. Once the written guidelines and procedures have been established, training will be provided to ensure that the program managers fully understand the time and effort reporting requirements. Management intends to implement these procedures in fiscal 2024. If the Oversight Agency has questions regarding this plan, please call Michael Pfifferling, Assistant Superintendent of Finance and Operations at 978-374-3400. Sincerely yours, Michael Pfifferling Assistant Superintendent of Finance and Operations City of Haverhill

View Audit 307261

Finding 398514 (2023-001)

Material Weakness 2023

Seattle School District No. 1

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attenti...

The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attention until 10 months into the 22/23 audit period, leaving no time for discussion or changes in interpretation and process. The audit’s condition states that our internal controls were ineffective for ensuring we requested reimbursement only for students and staff with a documented unmet need and that our internal controls were ineffective for demonstrating per location and per user limitations. Based on guidance from the Federal Communications Commission (excerpted below), the District contends we have spent all funds for allowable costs, that those costs were reasonable and necessary, and for students and staff with unmet needs. Districts were able to determine whether students and staff had unmet needs. For our district this meant addressing instances where students may have shared a home device with other siblings; student or staff devices were too old or slow to function properly when running multiple required applications; and / or student owned devices did not have the appropriate security in place to protect students during remote learning (especially from unauthorized websites). Home drives, where all educational digital resources were stored, couldn’t be accessed unless using a district issued device. Additionally, the district’s technical support could not access personally owned devices to provide for thousands of trouble tickets and support issues students faced during remote learning. Based on these factors, unmet need was defined broadly, but within allowed parameters and inventory records were kept, albeit, not perfectly. Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by the health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person. Seattle Public Schools followed guidance from the Federal Communications Commission outlined in a document titled: . “Emergency Connectivity Fund Common Misconceptions”, “Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate. Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus is eligible for Emergency Connectivity Fund Support.” Additionally, from the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: “We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.” And from question 51: “…we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students…with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.” Finally, SAO did not apply any reasonable measure to reduce questioned costs but did state they know that at least some of the equipment addressed unmet needs, while still choosing to question all costs. That is clearly out of alignment with the FCC guidance. There are no corrective actions to take at this time as the funding source has been exhausted and the timeline has passed.

View Audit 307259 Questioned Costs: $1

Finding 398502 (2023-001)

Significant Deficiency 2023

The Women's Home

TX

Subrecipient Monitoring Cash Management Reporting

Corrective Action Plan: We have held recent discussions with the City of Houston regarding the Fiscal Report. As a result, it has been agreed that we will submit the Fiscal Report within the required timeframe. The Home will develop a process to ensure that once the Board of Directors has approve...

Corrective Action Plan: We have held recent discussions with the City of Houston regarding the Fiscal Report. As a result, it has been agreed that we will submit the Fiscal Report within the required timeframe. The Home will develop a process to ensure that once the Board of Directors has approved the quarterly financial information, the previously submitted Fiscal Reports will be reviewed for consistency. If differences exist, The Home will submit an amended Fiscal Report to the City of Houston for the applicable quarter. Contact Person Responsible for Corrective Action: Ms. Anna Coffey, Chief Executive Officer. Anticipated Completion Date: This was completed in conjunction with the filing of the Fiscal Report for March 31, 2024.

View Audit 307245

Finding 398497 (2023-002)

Material Weakness 2023

Kalamazoo Youth Development Network

MI

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.212 § 200.318

Condition: During testing we noted the Organization did not retain support showing they had searched if an entity was debarred, suspended or otherwise excluded. Planned corrective action: KYD Network and the American Rescue Plan Act (ARPA) Compliance Contractor will conduct a search to ensure all A...

Condition: During testing we noted the Organization did not retain support showing they had searched if an entity was debarred, suspended or otherwise excluded. Planned corrective action: KYD Network and the American Rescue Plan Act (ARPA) Compliance Contractor will conduct a search to ensure all ARPA funded organizations have not been debarred, suspended, or otherwise excluded from receiving federal funds prior to receiving ARPA summer program funds. The results of the search will be included in the ARPA spreadsheet. Responsible Person: Viridiana Carvajal, Co-Executive Director, and American Rescue Plan Act (ARPA) Compliance Contractor Anticipated completion date: May 10, 2024. This action already has been implemented for the 2024 ARPA summer program.

View Audit 307230

Finding 398482 (2023-001)

Material Weakness 2023

Crazy Horse School

SD

Subrecipient Monitoring Cash Management Matching / Level of Effort / Earmarking

2023-001 FINDING: Deficit Fund Balances Questioned Costs: None noted. Recommendation: We recommend the School continue to implement their plan to liquidate all remaining debt from the general fund. We also recommend they continue a vigilant oversight of all budgets of the School. Response: The curre...

2023-001 FINDING: Deficit Fund Balances Questioned Costs: None noted. Recommendation: We recommend the School continue to implement their plan to liquidate all remaining debt from the general fund. We also recommend they continue a vigilant oversight of all budgets of the School. Response: The current Business Manager is enforcing the CHS Policies that do not permit expenditures in excess of the approved budget without Board approval. In addition, the current Business Manager does not include any carryover from prior budgets in the existing budget until the audit is completed and the financial statements are reconciled. The Business Manager has restricted use of General Fund revenues to remedy the deficit, including income received by the School that is non-program income, and the School Board is responsible for monitoring expenditures monthly. ANTICIPATED COMPLETION DATE: June 30, 2025 PERSON(S) RESPONSIBLE: Leslie Cuny, Business Manager

View Audit 307206

Finding 398463 (2023-001)

Significant Deficiency 2023

YWCA of Southern Arizona

AZ

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318 § 200.326

Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Melissa M. Tomlinson, CPA, CGFM, Director of Finance Anticipated Completion Date: May 2024 Planned Corrective Action: The YWCA will develop and implemen...

Program Name/Assistance Listing Title: COVID‐19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Melissa M. Tomlinson, CPA, CGFM, Director of Finance Anticipated Completion Date: May 2024 Planned Corrective Action: The YWCA will develop and implement formal procurement procedures aligned with federal regulations, including thresholds for prior‐purchase authorization and vendor checks for suspension and debarment. Staff training will be conducted to ensure competency, and oversight mechanisms will be strengthened through regular monitoring and integration of SAM verification processes. Comprehensive documentation and record‐keeping practices will be established, with periodic reviews to facilitate continuous improvement. Through these actions, the YWCA aims to enhance compliance with federal procurement standards and ensure transparent and accountable procurement practices.

View Audit 307188

Finding 398461 (2023-002)

Significant Deficiency 2023

Texas Council on Family Violence, INC

TX

Subrecipient Monitoring § 200.332

Policies and procedures will reflect the Program lead prepares sub-grants and CFO will review to ensure correct fund source/CFDA is noted. This approach creates a check and balance. A committee involving program staff and finance staff will review all documentation including application, and post aw...

Policies and procedures will reflect the Program lead prepares sub-grants and CFO will review to ensure correct fund source/CFDA is noted. This approach creates a check and balance. A committee involving program staff and finance staff will review all documentation including application, and post award documentation.

View Audit 307186

Finding 398460 (2023-001)

Material Weakness 2023

Mount Vernon School District No. 320

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment and restricted purpose requirements. Name, address, and telephone of District contact person: Tim Papendorf, Information Services ...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment and restricted purpose requirements. Name, address, and telephone of District contact person: Tim Papendorf, Information Services Supervisor 124 E. Lawrence Street, Mount Vernon, WA 98273 360-428-6110 Corrective action the auditee plans to take in response to the finding: Concern: The district failed to maintain sufficient documentation proving that the equipment provided to students matched their actual unmet needs. Reimbursement was sought based on estimated unmet needs rather than documented, actual unmet needs. Response: The Mount Vernon School District mandates that students use districtassigned devices for remote learning. According to grant training provided to the district, if students are required to use district-owned devices for remote learning, Chromebooks could be distributed to any student who did not have a district-assigned device that meets hardware standards. The standards used to assess the hardware included Chromebooks that were older than four years, unable to support the necessary software and digital learning tools, and devices at their end-of-life stage, meaning they no longer received automatic updates from Google. We assessed our inventory and supplied new Chromebooks to students based on our understanding of their needs. Chromebooks were only provided to students who lacked a device that met our hardware standards. Resolution: During this audit, the district learned that its understanding was inaccurate. However, we are confident our need exceeded our request. In May 2020, Page 71Office of the Washington State Auditor sao.wa.gov as directed by OSPI, the district conducted a survey which revealed that only 38% of our families had access to a device at home suitable for online learning. Given our students in poverty population was 4,365 during the 2022-23 school year, the 1,869 devices for which funding was requested only partially met our overall device needs. This audit has improved our understanding of the requirements related to verifying unmet needs. Moving forward, we will directly contact families and collect signatures to confirm their needs. These records will be attached to student profiles within our asset management system (Destiny) before ECF funded Chromebooks are assigned to them. Concern: Inventory records were incomplete, missing the names of 273 students assigned laptops funded by the ECF, thus failing to fully meet FCC documentation requirements. Response: The district acknowledges challenges related to student device assignment. Staff reductions and changes in our inventory and check-out processes necessitate updates and training, which is ongoing. We are committed to ensuring accurate and timely updates to our records. Resolution: A list of inventory discrepancies has been distributed, and action is being taken to update our records. To strengthen our existing systems, we will implement additional biannual training sessions with our inventory managers. These trainings will cover best practices for record keeping and emphasize the importance of maintaining accurate inventory records. We will conduct monthly audits of our records, and correction requests will be sent to individual sites to promptly address any information inaccuracies. Concern: MVSD lacked documentation to show that it only provided one device per student or location, leading to possible over-issuance of equipment. Response: While the district acknowledges the need to improve its student assignment inventory within Destiny, we have confirmed that only one device is assigned per student through the use of our additional inventory system (Google Workspace). Resolution: The district will enhance its inventory practices and explore additional redundancies to ensure effective contingencies if future data issues arise. Anticipated date to complete the corrective action: ● Unmet Needs Documentation: May 31, 2024 ● Inventory Update: June 20th, 2024 ● Staff Training: June 20th, 2024 (Ongoing)

View Audit 307176 Questioned Costs: $1

Finding 398452 (2023-001)

Significant Deficiency 2023

Northeast Texas Public Health District

TX

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring

The Northeast Texas Public Health District (NET Health) will take steps to ensure overall effective grant monitoring and to increase communications between NET Health Grant Managers and the Chief Financial Officer and Chief Executive Officer. The NET Health Leadership Team will discuss any issues du...

The Northeast Texas Public Health District (NET Health) will take steps to ensure overall effective grant monitoring and to increase communications between NET Health Grant Managers and the Chief Financial Officer and Chief Executive Officer. The NET Health Leadership Team will discuss any issues during our weekly Leadership Team meetings to ensure compliance. These weekly meetings will address costs expended within the grant parameters and ensure grant funds will be more evenly expended during the year as appropriate. NET Heatlh will continue to develop effective methods of grant oversight as it finds weaknesses in its processes. To ensure compliance with the period of performance requirements, NET Health will change its processes effectively immediately. Going forward checks will only be prepared, dated, signed, and mailed to vendors after work is completed or items are received. There will be enhanced internal controls by establishing procedures to monitor and ensure timely payment of accrued expenditures, such as regularly accounting for any outstanding checks and actively communicating with vendors on performance requirements. In addition, we will enhance communication and coordination among relevant departments to expedite the payment process while maintaining compliance with grant regulations. George T. Roberts, CEO, and Lawanda Owens, CFO, are the persons responsible for this action plan going forward. NET Health is expected to have this action plan implemented by May 1, 2024.

View Audit 307138 Questioned Costs: $1

Finding 398429 (2023-002)

Significant Deficiency 2023

Duck Lake Water Association

WA

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.318

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) A formal procurement policy will be developed and implemented at the agency’s earliest convenience, but no later than July 31, 2024. 2) Provide training to procur...

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1) A formal procurement policy will be developed and implemented at the agency’s earliest convenience, but no later than July 31, 2024. 2) Provide training to procurement personnel on the new policy and procedures. Name of the contact person responsible for corrective action: Talana Lay, Board Treasurer Planned completion date for corrective action plan: July 31, 2024 If the U.S. Environmental Protection Agency has questions regarding this plan, please call Talana Lay at 509-322-5973.

View Audit 307120

Finding 398424 (2023-001)

Material Weakness 2023

North Mason School District No. 403

WA

Procurement, Suspension & Debarment School Nutrition Programs Subrecipient Monitoring

Finding ref number: 2023-001 ...

Finding ref number: 2023-001 Finding caption: The District lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective action the auditee plans to take in response to the finding: The District was experiencing high turnover with leadership roles in both its Food Service Department and Business Office when the failure to ensure compliance with federal suspension and debarment requirements occurred with one of its procurement contracts in August 2022. For corrective action the District put in place a requirement that all purchase order requests involving federal funds that amount to (or potentially could amount to) $25,000 or higher must include as an attachment in Skyward Financial Management the contract (when applicable) with verification that the vendor is not suspended and debarred and/or current documentation from Sam.gov verifying the vendor is not suspended or debarred. Any requisition involving federal funds that could amount to or exceed $25,000 that does not also include suspension and debarment verification will not be approved by the finance director and Business Office staff who process purchase order requests (as a control, both the finance director and the accounts payable technician must approve the request). Further, by requiring the suspension and debarment verification in Skyward as an attachment with the purchase order request, Business Office staff (regardless of staff turnover) will be able quickly locate and retrieve the documentation as needed for future audits and other external or internal purposes. Anticipated date to complete the corrective action: This corrective action was put into effect on April 18, 2024.

View Audit 307117

Finding 398422 (2023-004)

Material Weakness 2023

Metro Towers, Inc. St. James Place

MO

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-004 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete as per the requirement of the HUD audit guide related to tenant security deposits and a responsible official will ensure the process is being followed on a monthly basis. Anticipated Completion Date June 30, 2024

View Audit 307115

Finding 398421 (2023-003)

Significant Deficiency 2023

Metro Towers, Inc. St. James Place

MO

Questioned Costs HUD Housing Programs Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-003 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will file HUD Form 9839-B with HUD and ask them to retrospectively approve this form effective February 28, 2023. Anticipated Completion Date June 30, 2024

View Audit 307115 Questioned Costs: $1

Finding 398420 (2023-002)

Material Weakness 2023

Metro Towers, Inc. St. James Place

MO

Questioned Costs HUD Housing Programs Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-002 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will deposit the shortfall of $544 into the reserve for replacement account, as well as the shortfalls for 2019, 2020, 2021 and 2022, as soon as possible and ensure the process is being followed to deposit and reconcile the reserve for replacement account on a monthly basis. Anticipated Completion Date June 30, 2024

View Audit 307115 Questioned Costs: $1

Finding 398419 (2023-001)

Material Weakness 2023

Metro Towers, Inc. St. James Place

MO

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2023 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2023. Finding 2023-001 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2024

View Audit 307115

Finding 398413 (2023-001)

Significant Deficiency 2023

Wahkiakum School District No. 200

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum School District No. 200 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code o...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Wahkiakum School District No. 200 September 1, 2022 through August 31, 2023 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2023-001 Finding caption: The District did not have adequate controls for ensuring compliance with federal requirements for allowable costs and cost principles Name, address, and telephone of District contact person: Sue Ellyson, Business Manager P.O. Box 398 Cathlamet, WA 98612 (360) 795-3971 Corrective action the auditee plans to take in response to the finding: The District will be more prompt in requesting refunds. Anticipated date to complete the corrective action: The refund was requested 3/1/24 and received 3/15/24.

View Audit 307112 Questioned Costs: $1

Finding 398402 (2023-001)

Material Weakness 2023

South Kitsap School District No. 402

WA

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

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Andrea Cooper 2689 Hoover Ave SE Port Orchard, WA 98366 360-874-7015 Corrective...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Andrea Cooper 2689 Hoover Ave SE Port Orchard, WA 98366 360-874-7015 Corrective action the auditee plans to take in response to the finding: The District was compliant with federal wage rates and will ensure that all public works projects funded with federal funds have appropriate contract language included in order to comply with all federal wage rate requirements. Anticipated date to complete the corrective action: Immediately.

View Audit 307099

Finding 398332 (2023-002)

Significant Deficiency 2023

Goodwill Industries International, INC

MD

Subrecipient Monitoring Reporting Significant Deficiency

Management concurs with this recommendation. GII Mission Team plans to complete the FFATA reporting on its Subaward Reporting System (FSRS) for the Federal Communications Commission grant (FCC). The team will provide training to relevant staff on GII’s New Grant Start Up checklist from the GII Grant...

Management concurs with this recommendation. GII Mission Team plans to complete the FFATA reporting on its Subaward Reporting System (FSRS) for the Federal Communications Commission grant (FCC). The team will provide training to relevant staff on GII’s New Grant Start Up checklist from the GII Grant Management Toolkit that requires a review of Grant Terms and Conditions including the FFATA reporting requirement for federal grants, and training on the process for reporting the FFATA on FSRS. This includes collection of required elements, such as the UEI number, congressional districts zip codes, and level of Federal grants received from subrecipients. Additionally, the supervisor must review and approve the report before submission. Confirmation of successful submission is required for the grant records. GII will review grant startup checklist within 30 days of receipt of grant with program manager and grant accounting staff to ensure all required activities are completed. The team will ensure that the grant start up process is followed with all new federal grants. With the described action plan, GII will strengthen supervision and review controls over evaluating subawards for reporting requirements under FFATA and tracking whether reporting occurs timely and accurately. Persons Responsible for Corrective Action: Martin Scaglione Kristin Pratt Chief Mission Officer Sr. Director Grant Operations and Administration Implementation of the Correction Action Plan: All corrective actions will be completed by June 30, 2024.

View Audit 306999

Finding 398303 (2023-005)

Significant Deficiency 2023

Eugene School District 4j

OR

Subrecipient Monitoring Significant Deficiency

18. Deficiency #18 SA-2023-005 a. Significant Deficiency - Recipients and sub-recipients that use ESF funds for remodeling, renovation or construction projects that are over $2,000 and use laborers and mechanics must meet Davis-Bacon prevailing wage requirements. b. Proper documentation was not rece...

18. Deficiency #18 SA-2023-005 a. Significant Deficiency - Recipients and sub-recipients that use ESF funds for remodeling, renovation or construction projects that are over $2,000 and use laborers and mechanics must meet Davis-Bacon prevailing wage requirements. b. Proper documentation was not received before disbursement to show prevailing wage requirements in relation to Charter School payments. Documentation was received during the audit when requested by charter schools and no errors/issues were found. Documentation and notes for the future have been noted for future disbursements. c. This was implemented as of February 2024. Governing

View Audit 306983

Finding 398278 (2023-001)

Significant Deficiency 2023

Eugene School District 4j

OR

Reporting Subrecipient Monitoring Significant Deficiency

14. Deficiency #14 SA-2023-001 a. Significant Deficiency - The District misstated the pass through amounts to sub-recipients for this program. The District made subsequent corrections. b. Proper documentation was not received by Charter Schools for payments made with federal ESSER dollars. Subsequen...

14. Deficiency #14 SA-2023-001 a. Significant Deficiency - The District misstated the pass through amounts to sub-recipients for this program. The District made subsequent corrections. b. Proper documentation was not received by Charter Schools for payments made with federal ESSER dollars. Subsequent documentation was received during the audit process. This documentation has been noted for any future disbursements to ensure proper documentation is received beforehand. c. This was implemented as of March 2024

View Audit 306983

Finding 398261 (2023-001)

Material Weakness 2023

Bremerton School District No. 100-C

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Cathie Seevers 134 Marion Ave N Bremerton, WA 9...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs and restricted purpose requirements. Name, address, and telephone of District contact person: Cathie Seevers 134 Marion Ave N Bremerton, WA 98312 360-473-1034 Corrective action the auditee plans to take in response to the finding: This audit finding is for ECF Funds that were awarded through the FCC. While we thought we complied when purchasing chrome books for hybrid learning, there were some other requirements that we were not able to document. Because our asset management system does not retain a list of previous ‘owners’ of each chrome book (the system replaces that student with the new student’s name and does not keep the history) we were unable to tell you exactly what student had several of our chrome books at that snapshot in time. We are now aware of the importance of this feature and will record these differently to maintain a history of users. BSD does not intend to use any more ECF funds. Anticipated date to complete the corrective action: May 1, 2024

View Audit 306962 Questioned Costs: $1

Finding 398250 (2023-001)

Significant Deficiency 2023

Rialto Unified School District

CA

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

The District will revisit the drop protocols with staff to ensure that all required documentation is on file prior to processing drop code in the calpads.

View Audit 306933

Finding 398242 (2023-001)

Material Weakness 2023

White Pass School District No. 303

WA

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

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Angela Bowen 516 Silverbrook Rd, Randall, WA 98377 360-497-3791 Corrective action t...

Finding ref number: 2023-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements. Name, address, and telephone of District contact person: Angela Bowen 516 Silverbrook Rd, Randall, WA 98377 360-497-3791 Corrective action the auditee plans to take in response to the finding: The White Pass School District will immediately implement the following controls to assure that the District has adequate internal controls in place for any future expenditures for Capital Projects where federal funds will be used. 1-The District will review the Federal Procurement and contractor requirements prior to submitting applications to use federal funds for Capital Projects. 2- The District will have a meeting with the appropriate staff involved with the project to insure that compliance with the Federal Program Procurement including compliance with the federal wage rate requirements are met. 3- As part of the verification process to ensure adequate internal controls the District will identify who the person will be who will secure and monitor weekly certified payroll from the contractors to stay in compliance with the federal wage rate requirements at the beginning of each project. Anticipated date to complete the corrective action: Effective immediately 5/13/2024

View Audit 306916

Corrective Action Plans

Filters