Corrective Action Plans

Finding 501028 (2023-001)

Significant Deficiency 2023

IL

Special Tests & Provisions Subrecipient Monitoring § 200.303

Corrective Action Plan The Chicago Park District will implement the following strategies to improve the management of the Summer Food Service Program (SFSP). • Review and analyze audit findings with seasonal staff, Area Managers, and Administration in order to prevent findings. • Prepare additions...

Corrective Action Plan The Chicago Park District will implement the following strategies to improve the management of the Summer Food Service Program (SFSP). • Review and analyze audit findings with seasonal staff, Area Managers, and Administration in order to prevent findings. • Prepare additions to CPD Monitor manual to reflect the ISBE regulation to conduct at least one site review during first four weeks of operations and 2 follow up visits if required. • Nutrition Services will send weekly emails to remind staff requirements of SFSP documentation and utilize the Area Managers to assist with quality assurance and compliance with state/ federal regulations. • Provide weekly assessment of monitor reports to promote accuracy in meal distribution, and reduction of food waste by reducing second meals ordered. Conduct occurring review weekly on Wednesdays. • Continue train monitors to review SFSP binders, check food temperature, date of service and signature recorded on all invoices and DMC, and attendance. • Mandate that at least three of staff members per site are trained in SFSP (pending number of staff at park location) • Upload daily attendance list for day camp with weekly summaries, keep hard copies in binders to ensure access for audit purposes. • Provide multiple in person trainings before start of the season to all field staff emphasize the importance of accuracy and details when following the Policy and Procedures of the Summer Food Service Program. • Add audio to the electronic training offered through the Success Center. Anticipated Completion Date: September 30, 2024 Name of the Contact Person Responsible for Corrective Action: Sandra Olson, Director of Programming Meghan O’Boyle, Wellness Manager

View Audit 323269

Finding 501012 (2023-003)

Material Weakness 2023

Umpqua Public Transportation District

OR

Subrecipient Monitoring Cash Management Material Weakness § 200.302

Finding 2023-003 – Fiscal Management System (Material Weakness) Criteria: CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following: Identification, in its accounts, of all Federal awards received and e...

Finding 2023-003 – Fiscal Management System (Material Weakness) Criteria: CFR Part 200.302.b Auditee Responsibilities includes the requirement that the financial management system of each non-Federal entity provide the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. Accurate, current, and complete disclosure of the financial results of each Federal award or program. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation. The reimbursement reports were to be reviewed by the District Manager prior to submission. Approval of the reimbursement requests and supporting reports by the District Manager were often delayed. Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring timely review of reports and filing of the reimbursement requests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper financial reporting. Lack of timely filing of reimbursement requests could result in overstating accounts receivable balances and critical revenues lost due to cutoff terms of the grant award. Questioned Cost: No Context: Delays in filing reimbursement claims and internal disputes regarding grant reimbursement request procedures were evident. The weak or nonexistent controls over the reimbursement request procedures resulted in lost revenues and delayed recognition of revenue, which required adjustments to correct the financial statements. Repeat of a Prior-Year Finding: Yes, Financial Statement Findings 2022-001 Recommendation: The District should establish a more simplified and effective process for the review and approval of GAAP basis reporting and grant reimbursement requests and grant reporting. As part of this process, supporting general ledger reports and supporting data should be subject to a qualified individual to review and approval on a timely basis. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that process that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledger recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data reports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District

View Audit 323248

Finding 501005 (2023-002)

Significant Deficiency 2023

Umpqua Public Transportation District

OR

Cash Management Subrecipient Monitoring Reporting § 200.302 § 200.328 § 200.329

Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20...

Finding 2023-002 - Source Documentation (Significant Deficiency) CFDA Title and Number: 20.513 (5310) Enhanced Mobility of Seniors and Individuals with Disabilities. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management CFDA Title and Number: 20.509 (5311) CARES 5311 Operating Assistance. Formula Grants for Rural. Name of Federal Agency: Transit Services Program Cluster Internal Control over Compliance: Cash Management Criteria: 2 CFR Part 200.302(b)(1) The financial management system of each non-federal entity must provide for the following: Identification, in its accounts, of all Federal awards received and expended and the Federal programs under which they were received. 200.302(b)(2) Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The District prepared reimbursement calculations according to an internally developed spreadsheet tool, rather than using amounts directly obtained from the general ledger and supporting documentation. Cause: General ledger data used to prepare spreadsheets, then used to complete reimbursement requests added unnecessary complexity and potential for errors in the reimbursement and request and grant reporting process. Internal control procedures assuring accurate and timely review of reports and filing of the reimbursement requests were not designed or implemented. Effect or Potential Effect: The lack of effective internal control activities over financial reporting could allow for inadvertent errors, such as calculation errors, payments for unauthorized purposes, and result in improper grant accounting, reporting, and reimbursement. Questioned Cost: No Context: Internal disputes regarding grant reimbursement request procedures were evident. The weak or nonexistent controls over the reimbursement request procedures created a potential for inaccurate, incomplete reporting. Repeat of a Prior-Year Finding: Yes, Findings and Questioned Costs 2022-003 Recommendation: The District should continue to improve grant accounting efforts, and establish a more simplified and effective process for the review and approval of grant accounting and reimbursement requests. Additional training of management should occur to ensure they fully understand all compliance regulations and have the skills to assist in designing and implementing effective controls. Monitoring of the control procedures related to the grant accounting and reimbursement request should be performed regularly to ensure reports are filed accurately and timely. Information and communication regarding identified weaknesses and opportunities to improve the policies and procedures should occur among management and the individual performing the monitoring of the procedures. District's Response: The District’s Finance Manager and District Manager are working towards using general ledger reporting exclusively for reimbursement request reporting. General ledger activity became more timely as improvements were implemented based on prior year findings. Management acknowledges delays in that process that continued as a result, to some extent, of the use of the self-developed spreadsheet reports then used for completing grant reimbursement requests. Corrective Action Plan: The District’s Finance Manager will continue to make improvements in general ledger recording and reporting systems so that those reports can then be used without intermediary report methods to prepare reimbursement request forms. Review of the reimbursement requests will take place within data reports generated directly from the general ledger. The district will engage an individual or firm to ensure that the timing and overall processes related to grant reimbursement and reporting does not result in reporting errors or omissions. . Planned Implementation Date: September 30, 2024 Responsible Person: General Manager, Umpqua Public Transit District

View Audit 323248

Finding 500943 (2023-007)

Material Weakness 2023

Wabanaki Health and Wellness

ME

Subrecipient Monitoring § 200.208 § 200.332 § 200.339 § 200.425 § 200.501

2023- 007 - Material Weakness in Internal Control and Material Noncompliance – Sub-recipient Monitoring and Management WPHW understands this finding and recognizes that correction that were planned for FY23 were not able to be fully implemented. One of the significant challenges WPHW had over the pa...

2023- 007 - Material Weakness in Internal Control and Material Noncompliance – Sub-recipient Monitoring and Management WPHW understands this finding and recognizes that correction that were planned for FY23 were not able to be fully implemented. One of the significant challenges WPHW had over the past couple of year, in addition to IT system challenges, is staffing. WPHW has hired three individuals to develop our contracting process and had performance issues with all three individuals. In addition to the difficulties with the NetSuite implementation, we have had to re-evaluate our sub-recipient monitoring and management business process. The following process will address this finding: 1) Director of Accounting and the Accounting Manager will review CFR 200.332 and develop a revised business process for the WPHW contract system a. Accounting Team will hire 2 Accounting Specialists who will each have specific sub-recipient monitoring responsibilities 2) Director of Accounting and the Accounting Manager will review all current contract to ensure the following: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: i. Federal, State or other award identification. ii. Subrecipient name (which must match the name associated with its unique entity identifier); iii. Subrecipient's unique entity identifier; iv. Award Identification Number (FAIN/SAIN); v. Award Date of award to the recipient by the Federal agency; vi. Subaward Period of Performance Start and End Date; vii. Subaward Budget Period Start and End Date; viii. Amount of Federal Funds (if applicable) Obligated by this action by the pass-through entity to the subrecipient; ix. Total Amount of Federal Funds Obligated, if applicable, to the subrecipient by the pass-through entity including the current financial obligation; x. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xi. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xii. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xiii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiv. Identification of whether the award is R&D; and xv. Indirect cost rate for the Federal, State, or other award (including if the de minimis rate is charged) per § 200.414. b. All requirements imposed by the pass-through entity on the subrecipient are in accordance with Federal, State, Local statutes, regulations and the terms and conditions of the award; c. Determines and ensure completion of required financial and performance reports; d. Has an approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government or utilizes the de minimus. e. States that subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part f. Details appropriate terms and conditions concerning closeout of the subaward. g. Subrecipient risk assessment that accesses: i. prior experience with the same or similar subawards; ii. previous audits iii. personnel or substantially changed systems iv. Prior monitoring results 1. Subaward conditions will be placed if issues arise 3) Implement sub-recipient monitoring process. a. Conduct invoice review monthly i. All invoices must include full back up and support for expenses ii. All invoices will be reviewed as they are received to ensure expenses are allowable iii. Any issues that arise will be addressed prior to invoice payment b. Conduct contract monitoring visit annually i. Hold a meeting with the sub-recipient to review the following: 1. Reviewing financial and performance reports 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the subaward. 3. Training and technical assistance on program-related matters 4. Determine corrective action for any deficiencies or findings and determine risk 5. Discussion of enforcement action against noncompliant subrecipient This process will be reviewed, and implementation will begin during Q4 FY24. All current FY24 contracts will be reviewed, and monitoring visits scheduled. For FY25, all contracts will be in compliance with requirements.

View Audit 323235

Finding 500931 (2023-003)

Significant Deficiency 2023

Native Sun Community Power Development

MN

Subrecipient Monitoring Reporting Significant Deficiency

Planned Corrective Action: We will implement a process to ensure FSRS reporting is completed on a timely basis. It will be included in the monthly drawdown activities. Specific to 2023, this was filed by Lisa Daniels on 9/27/2024. Rhonda will oversee the submission of this reporting requirement goin...

Planned Corrective Action: We will implement a process to ensure FSRS reporting is completed on a timely basis. It will be included in the monthly drawdown activities. Specific to 2023, this was filed by Lisa Daniels on 9/27/2024. Rhonda will oversee the submission of this reporting requirement going forward. Name of Contact Person: Lisa Daniels, Program Director & Rhonda Conn, Program Director Anticipated Completion Date: October 1, 2024

View Audit 323232

Finding 500918 (2023-003)

Significant Deficiency 2023

Search for Common Ground

DC

Procurement, Suspension & Debarment Subrecipient Monitoring

2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Contact: Wajid Ali Title: Senior Manager Internal Policies and Compliance Phone Number: (202) 777-2297 Estimated Completion Date: June 30, 2025 Corrective Action Plan: We Agree with the fin...

2023-003 Internal Control over Compliance and Compliance with Procurement, Suspension and Debarment Contact: Wajid Ali Title: Senior Manager Internal Policies and Compliance Phone Number: (202) 777-2297 Estimated Completion Date: June 30, 2025 Corrective Action Plan: We Agree with the finding that background checks were done after the agreement date and before payment in few cases, during late 2023 and early 2024, we have rolled out a Global Procurement system (google sheet based internal workflow package) that is designed to mandate procurement steps in a systematic manner. This is already helping us streamline procurement in major countries. This system is planned to be fully rolled out by the Second Quarter of 2025 and is currently implemented in about half of the countries and 4 other countries will be included by end of 2024. This will enable us to complete the background checks before entering any commitment.

View Audit 323222

Finding 500417 (2023-001)

Material Weakness 2023

St. Francis Village, Inc.

TX

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Finding 2023-001: Adjustments, both individually and in aggregate were material to the financial statements. Adjustments were needed to correct cash, accounts receivable, fixed assets, accounts payable, accrued expense, and debt balances. Several key review processes were not occurring. a. Responsib...

Finding 2023-001: Adjustments, both individually and in aggregate were material to the financial statements. Adjustments were needed to correct cash, accounts receivable, fixed assets, accounts payable, accrued expense, and debt balances. Several key review processes were not occurring. a. Responsible Official’s Response: Management will modify its internal control practices to ensure that proper daily and monthly accounting processes and procedures are being followed for all asset and liability accounts by the Business Manager and reviewed timely each month by the Executive Director. Management is in the process of hiring a Controller to assist with monthly accounting cycle, reconciliations, and financial statement reporting, allowing the Executive Director to have more oversight responsibilities for the financial statements as a whole. b. Planned Implementation Date of Corrective Action: Management will implement this change immediately. c. Person Responsible for Corrective Action: Executive Director in conjunction with advice from the Board of Directors.

View Audit 323177

Finding 500405 (2023-003)

Significant Deficiency 2023

Town of Paoli

IN

Reporting Subrecipient Monitoring Significant Deficiency § 200.328

Management of the Town will work to adopt a formal federal reporting policy and monitoring system that will ensure accurate and timely reporting of all grants. The Town will also assign a reporting leader to become familiar with all reporting requirements and monitor the timeline of the reporting r...

Management of the Town will work to adopt a formal federal reporting policy and monitoring system that will ensure accurate and timely reporting of all grants. The Town will also assign a reporting leader to become familiar with all reporting requirements and monitor the timeline of the reporting requirements.

View Audit 323172

Finding 500396 (2023-005)

Material Weakness 2023

City of Greeley

CO

Subrecipient Monitoring Material Weakness Reporting § 200.303

Finding Number: 2023-005 Condition: Related to the Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027), there was no evidence that reports were reviewed for completeness and accuracy prior to submission. Planned Corrective Action: The City hired a full-time Grants Manager in February 202...

Finding Number: 2023-005 Condition: Related to the Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027), there was no evidence that reports were reviewed for completeness and accuracy prior to submission. Planned Corrective Action: The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed and approved by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents. Contact person responsible for corrective action: Stacey Swanson, Grant & Special Revenue Manager Anticipated Completion Date: December 31, 2024

View Audit 323158

Finding 500393 (2023-004)

Material Weakness 2023

City of Greeley

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

Finding Number: 2023-004 Condition: Related to the Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027), the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. Planned Corrective Action: Procedures will be enhanced to e...

Finding Number: 2023-004 Condition: Related to the Coronavirus State and Local Fiscal Recovery Funds (ALN 21.027), the City did not retain evidence that they performed the suspension and debarment check prior to entering into the contract. Planned Corrective Action: Procedures will be enhanced to ensure prior to entering into an agreement with an outside entity using federal funds, the City will perform the suspension and debarment check. Documentation of this review will be retained with the grant documents. In addition, the City will research grant management software options to further enhance grant monitoring. Contact person responsible for corrective action: Stacey Swanson, Grant & Special Revenue Manager Anticipated Completion Date: December 31, 2024

View Audit 323158

Finding 500392 (2023-003)

Material Weakness 2023

City of Greeley

CO

Subrecipient Monitoring Material Weakness Reporting § 200.303

Finding Number: 2023-003 Condition: Related to the WaterSMART grant (ALN 15.507), controls in place were not adequate to ensure expenses were reported in the proper categories on the performance reports. Planned Corrective Action: The City hired a full-time Grants Manager in February 2024 to establ...

Finding Number: 2023-003 Condition: Related to the WaterSMART grant (ALN 15.507), controls in place were not adequate to ensure expenses were reported in the proper categories on the performance reports. Planned Corrective Action: The City hired a full-time Grants Manager in February 2024 to establish procedures to track grants that are awarded and expended by the City. New procedures will be developed to ensure that financial and performance reports for grants will be reviewed by the Grants Manager prior to submission of the reports to the awarding entities. Documentation of this review will be retained with the grant documents. Contact person responsible for corrective action: Stacey Swanson, Grant & Special Revenue Manager Anticipated Completion Date: December 31, 2024

View Audit 323158

Finding 500390 (2023-001)

Material Weakness 2023

Northwest Youth Services

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Corrective Action Plan: • Housing service leadership staff will ensure that each unit lease served through NWYS will have on file documentation of reasonable rental rates and residential use at the time of lease signing or renewal, to ensure compliance with all grant requirements. Responsible Divi...

Corrective Action Plan: • Housing service leadership staff will ensure that each unit lease served through NWYS will have on file documentation of reasonable rental rates and residential use at the time of lease signing or renewal, to ensure compliance with all grant requirements. Responsible Division/Office and Individual: • NWYS Housing leadership staff – Luis Reyna, Andy Johnson, Rebecca Pendergraft, Addison Ausley • Finance leadership staff – Stephanie Wagner, Dianne Ersser Estimated Completion Date: 9/30/2024

View Audit 323157 Questioned Costs: $1

Finding 500385 (2023-003)

Material Weakness 2023

Jackson County, Colorado

CO

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

Material Weakness, Internal Control Over Compliance and Compliance, Allowable Costs and Activities, Reporting Personnel Responsible for Corrective Action: Samantha Martin, County Administrator Anticipated Completion Date: 12/31/2024 Corrective Action Plan: The County agrees with the auditor’s rec...

Material Weakness, Internal Control Over Compliance and Compliance, Allowable Costs and Activities, Reporting Personnel Responsible for Corrective Action: Samantha Martin, County Administrator Anticipated Completion Date: 12/31/2024 Corrective Action Plan: The County agrees with the auditor’s recommendation to improve its internal controls related to federal grant allowable costs and activities determinations and reporting requirements and will implement a process that ensures federal expenditure accounting and reports are prepared and then reviewed and approved by a separate employee prior to submission.

View Audit 323150

Finding 500384 (2023-001)

Material Weakness 2023

Whatley Health Services, Inc.

AL

Subrecipient Monitoring Program Income

2023-001 Program Income The Corporation is increasing its efforts to ensure that its policies and procedures surrounding documentation of patient income, identification, and registration is followed, and specifically that this documentation is archived correctly within every patient file. The Corpor...

2023-001 Program Income The Corporation is increasing its efforts to ensure that its policies and procedures surrounding documentation of patient income, identification, and registration is followed, and specifically that this documentation is archived correctly within every patient file. The Corporation has conducted several staff trainings and has revised its review procedures for checking compliance to improve monitoring of the process by the Corporation. Completion Date: Estimated December 2024. Contact Person: Rajuan Sherman - Chief Financial Officer - 2731 M.L. King, Jr. Blvd, Tuscaloosa, AL 35403 - (205) 614-6070 - rsherman@whatleyhealth.org.

View Audit 323140

Finding 500364 (2023-001)

None 2023

Palatine Manor Housing Development Fund Corporation 014-Ee-099

NY

HUD Housing Programs Subrecipient Monitoring Eligibility

FINDINGS - FINANCIAL STATEMENT AUDIT None FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2023-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 R...

FINDINGS - FINANCIAL STATEMENT AUDIT None FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2023-001: Major Program: Supportive Housing for the Elderly (Section 202 Capital Advance - Accumulated Balance), Federal Assistance Listing Number 14.157 RECOMMENDATION The auditor recommends ensuring all current and new staff are trained on tenants’ 90-day EIV reports and ensuring they are generated within the required time period to verify tenant information promptly and help reduce errors in subsidy payments. ACTION TAKEN The Project will be monitoring use of the EIV system for move ins and recertifications.

View Audit 323119

Finding 500351 (2023-004)

Significant Deficiency 2023

Fulton County Government

GA

Subrecipient Monitoring

We continue to update our compliance processes, following implementation of the Fulton County Subrecipient Monitoring Policy and our compliance review project, initiated in 2022. Based on project and staffing that are in place, we can ensure that subrecipients are monitored during the contract perio...

We continue to update our compliance processes, following implementation of the Fulton County Subrecipient Monitoring Policy and our compliance review project, initiated in 2022. Based on project and staffing that are in place, we can ensure that subrecipients are monitored during the contract period noted in the contractual agreements. We have identified and updated the annual monitoring plan to ensure that all subrecipient are monitored and in compliance with the 2 CFR 200.331 federal standards.

View Audit 323109

Finding 500350 (2023-003)

Material Weakness 2023

Fulton County Government

GA

Subrecipient Monitoring

The Fulton County Department of Senior Services concurs with the finding. Although the Department follows the monitoring standards established by the pass-through entity, the recent period subrecipient monitoring is in process and the current year monitoring will be completed within the grant period...

The Fulton County Department of Senior Services concurs with the finding. Although the Department follows the monitoring standards established by the pass-through entity, the recent period subrecipient monitoring is in process and the current year monitoring will be completed within the grant period. Risk assessments were done and have been formally documented and provided to the auditor. The Department will maintain an annual monitoring plan to ensure that all subrecipients are monitored in compliance with 2 CFR200 requirements.

View Audit 323109

Finding 500349 (2023-002)

Material Weakness 2023

Fulton County Government

GA

Subrecipient Monitoring

The Fulton County District Attorney’s Office (FCDAO) was made aware during the recent Department of Justice (DOJ) audit in July 2024 of the need to strengthen compliance in this process. Effective August 2024, processes were revised to meet the 2 CFR 200 compliance requirement. Currently, FCDAO is c...

The Fulton County District Attorney’s Office (FCDAO) was made aware during the recent Department of Justice (DOJ) audit in July 2024 of the need to strengthen compliance in this process. Effective August 2024, processes were revised to meet the 2 CFR 200 compliance requirement. Currently, FCDAO is conducting the required monitoring to meet the response timeline given by the DOJ. The revised subrecipient monitoring process has been documented into a department procedure and is now included in the FCDAO’s standard operating procedure.

View Audit 323109

Finding 500342 (2023-001)

Material Weakness 2023

La Plata County Colorado

CO

Subrecipient Monitoring Internal Control / Segregation of Duties Material Weakness

Finding 2023-001 Material Weakness, Internal Control Over Compliance and Compliance, Reporting Personnel Responsible for Corrective Action: Adam Rogers Anticipated Completion Date: Already completed Corrective Action Plan: The County agrees with the auditor’s recommendation to improve its internal c...

Finding 2023-001 Material Weakness, Internal Control Over Compliance and Compliance, Reporting Personnel Responsible for Corrective Action: Adam Rogers Anticipated Completion Date: Already completed Corrective Action Plan: The County agrees with the auditor’s recommendation to improve its internal controls related to federal grant reporting requirements and has implemented a process that ensures federal expenditure accounting and reports are prepared by the Grants Analyst and then reviewed and approved by the Deputy Director of Finance or Director of Finance to provide oversight and detect and correct errors before reports are submitted.

View Audit 323102

Finding 500330 (2023-002)

Significant Deficiency 2023

Firelands Regional Health System

OH

Questioned Costs Student Financial Aid Matching / Level of Effort / Earmarking

The System returned the remainder of funds required. Firelands Regional Medical Center School of Nursing has implemented the following control to prevent this error in the future. The Financial Coordinator will submit a copy of the Return of Title IV funds report to the business office when retur...

The System returned the remainder of funds required. Firelands Regional Medical Center School of Nursing has implemented the following control to prevent this error in the future. The Financial Coordinator will submit a copy of the Return of Title IV funds report to the business office when returning funds. The business office will use this report to make sure the appropriate amount is posted to the student's account.

View Audit 323097 Questioned Costs: $1

Finding 500322 (2023-006)

Material Weakness 2023

Greater Columbia Accountable Community of Health

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

Recommendation: We recommend that the Organization implements policies and procedures to perform subrecipient monitoring and that monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in respon...

Recommendation: We recommend that the Organization implements policies and procedures to perform subrecipient monitoring and that monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will undertake a thorough review and subsequent update of our documented policies and procedures related to federal awards. This review aims to ascertain whether any adjustments are necessary to guarantee that subawarded federal funds are utilized exclusively for their designated purposes. We are dedicated to enhancing our internal controls to adhere to federal regulations concerning the monitoring of our subrecipients. We plan to engage a consultant to help us develop policies and procedures for subrecipient monitoring, as well as to propose an organizational framework for fiscal monitoring that will strengthen our internal controls. We anticipate having the finalized policies, procedures, and training implemented by 12/31/2024. We will develop and implement a risk assessment program for subrecipients, enabling management to monitor the outcomes and demonstrate compliance with federal requirements. Records will be maintained to show that risk assessments were performed. We are dedicated to offering annual training sessions aimed at reinforcing the single audit requirements to our subrecipients. We will establish a subrecipient monitoring/compliance workgroup to define roles and responsibilities for assessing and updating policies and procedures related to subrecipient monitoring and to strengthen internal controls. Name(s) of the contact person(s) responsible for corrective action: Jan Warren/Amber Henderson (Compliance), Haydee Hill (CFO), Sharon Brown (CEO). Planned completion date for corrective action plan: 12/31/2024

View Audit 323092

Finding 500320 (2023-004)

Material Weakness 2023

Greater Columbia Accountable Community of Health

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Cash Management § 200.305

Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Explanation of disagreement with au...

Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will review and update our policies and procedures for managing accounts payable. Furthermore, we will provide additional orientation and training sessions focused on disbursements for subrecipients involved in federal grant programs. We will improve the enforcement of policies and procedures by setting up a system to track the receipt and payment of bills. Additionally, we will implement a weekly review by the compliance team to ensure that payments are made on time and that accurate documentation is retained to support any delays in payment requests that are found to be inappropriate. Name(s) of the contact person(s) responsible for corrective action: Jan Warren/Amber Henderson (Compliance), Haydee Hill (CFO) Planned completion date for corrective action plan: 12/30/2024

View Audit 323092

Finding 500317 (2023-001)

Material Weakness 2023

Okaloosa Aids Support and Informational Services INC Dba Oasis Florida

FL

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

All new client’s eligibility documents are reviewed by the Lead Case Manager to ensure that every required document for eligibility is in place. These clients were given a 30-day eligibility initially, allowing them time to collect required documents for complete eligibility. This was done for years...

All new client’s eligibility documents are reviewed by the Lead Case Manager to ensure that every required document for eligibility is in place. These clients were given a 30-day eligibility initially, allowing them time to collect required documents for complete eligibility. This was done for years, allowing clients to be seen by a medical provider quickly. This practice ended in 2023. 30-day eligibility is no longer allowed.

View Audit 323086

Finding 500287 (2023-004)

Significant Deficiency 2023

Southland Development Authority

IL

Subrecipient Monitoring Reporting

Finding 2023-004: Reporting The auditors noted the following areas for improvement: ● The SDA could not provide evidence of an internal review and approval on submitted performance metric report. ● The SDA was unable to provide proof of submission for one NT-106 performance metric report and three N...

Finding 2023-004: Reporting The auditors noted the following areas for improvement: ● The SDA could not provide evidence of an internal review and approval on submitted performance metric report. ● The SDA was unable to provide proof of submission for one NT-106 performance metric report and three NT-110 performance metric reports. ● The SDA submitted 2 reports late, one for NT-108 and one for NT-110. The auditors recommend the following: 1. Management implements procedures to ensure all required reports are prepared, reviewed, and submitted on time, with supporting documentation maintained in compliance with grant agreements. SDA Response ● Cook County has acknowledged receipt of all of the SDA performance grant reporting in a timely manner, however was unable to produce the specific submission information due to a change in the County system to GovGrants to the level requested by the SDA auditor. ● The delay in submission for the NT-108 report was due to the Cook County system change to GovGrants. The delay in submission to NT-110 is acknowledged, with the note that the due date for NT-110 metrics was shortened compared to the prior year. SDA Corrective Actions Management has fully transitioned to GovGrants for all metric and financial reporting, which will permit self-access to the data for all submitted reports in 2024. For NT-110, the SDA continues to document submission via email in addition to keeping track of all reports in Sharepoint. These actions aim to resolve this finding in all future audits. The full implementation of our checklist tool and quarterly review will further enhance our compliance.

View Audit 323067

Finding 500285 (2023-002)

Significant Deficiency 2023

Southland Development Authority

IL

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Finding 2023-002: Internal Controls over Allowable Costs The auditors noted the following areas for improvement: ● Time & Effort Certifications (T&E) were missing from 18 out of 40 tested contractor invoices. ● All payroll for W-2 employees was billed to grants based on a percentage of time spent ve...

Finding 2023-002: Internal Controls over Allowable Costs The auditors noted the following areas for improvement: ● Time & Effort Certifications (T&E) were missing from 18 out of 40 tested contractor invoices. ● All payroll for W-2 employees was billed to grants based on a percentage of time spent versus actual time spent. ● From a list of 244 clients, 21 client intake forms (used to determine eligibility for services) for Business Growth Services clients were unable to be produced. The auditors recommend the following: 1. Management to implement procedures to ensure all expenditures, including personnel costs, are properly reviewed, approved, and supported with documentation in accordance with federal regulations. SDA Response The SDA accepts the above findings and would like to add the following information for context: ● The requirement to collect T&E forms wasn’t initially established until the completion of the 2022 audit and after the departure of some personnel. Management attempted to collect T&E forms from prior contractors, but was not successful in securing the specific forms identified by the auditors. ● The SDA created a payroll classification document during 2023 which outlined T&E for all W-2 employees at a set rate for the year. This document, however, was not accepted by the auditors as evidence of actual hours expended on each grant, resulting in this finding. ● The SDA onboarded a new Director of Business Growth Services (BGS) in 2023, which led to changes in both the operational structure and the nature of the data collected for BGS activities. During this period, a data migration took place to a newer version of Salesforce that was built specifically for the SDA. Unfortunately, some data was either lost or unmapped during the migration process, leading to discrepancies in the completeness of historical records. SDA Corrective Actions Management is committed to continue training for personnel to ensure timely completion and compliance of hiring as well as time and effort documentation going forward. The SDA is implementing a new checklist tool to bolster compliance. This checklist will help the Director of Finance and Administration identify and correct any missing compliance well in advance of the next audit. In addition, Management is implementing a new quarterly review process to assess both compliance and financial accounts. The new quarterly review process will ensure documentation is maintained and accounted for each transaction, particularly for restricted grants, to minimize any post-close adjustments. The combination of both the new checklist tool and review process will support continued timeliness and eliminate this finding in future audits.

View Audit 323067 Questioned Costs: $1

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