Corrective Action Plans

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Finding 522963 (2023-005)
Significant Deficiency 2023
Management accepts this finding. Sponsored Research Service and the Controller’s Office work in tandem on the closing process. The Controller’s office has a schedule of projects ready to close and has assigned this pool of projects among the research accounting staff. In February 2024, the Controlle...
Management accepts this finding. Sponsored Research Service and the Controller’s Office work in tandem on the closing process. The Controller’s office has a schedule of projects ready to close and has assigned this pool of projects among the research accounting staff. In February 2024, the Controller’s Office hired a second Research Accountant. With the additions of these two positions the University will work towards closing out projects within 90-120 days. In March 2024, the Controller’s Office developed a Close out excel form to aid in capturing each of the necessary steps required on the accounting side of the process.
Finding 522826 (2023-001)
Significant Deficiency 2023
The University has taken several steps to address the continuing concerns raised in this audit. With regard to journal entry review and posting processes, effective July 1, 2023 all manual journal entries are processed through a PeopleSoft workflow that requires secondary approval by either the Cont...
The University has taken several steps to address the continuing concerns raised in this audit. With regard to journal entry review and posting processes, effective July 1, 2023 all manual journal entries are processed through a PeopleSoft workflow that requires secondary approval by either the Controller or one of the two Associate Controllers prior to posting to the general ledger system. Without this approval action, a manual journal entry will not post to the general ledger. The listing of open manual journal entries is maintained within the PeopleSoft workflow tool for the three authorized reviewers. In January 2023, the University purchased the FloQast workflow management system in an effort to address internal control concerns identified in the prior year audit. This product is specifically designed to manage financial account reconciliation, variance analysis and closing processes. FloQast receives a daily file import of the PeopleSoft trial balance for all general ledger accounts. Reconciliation of each general ledger account is assigned to a University staff member for either monthly or quarterly review. Reconciliations occur within the FloQast system with secondary staff approvals as needed for key general ledger accounts. FloQast will provide user alerts to any reconciled account becoming out of balance due to adjusting entries. Further, as historical balances are added to the FloQast system, variance analysis reports will be generated down to the individual account level. Finally, monthly, quarterly and annual closeout procedures are being built into the FloQast workflow process to allow for timely identification and status tracking of each process, by both the process owner and the final approver. While accounting processes exist in an internal process memo utilized by the Controller’s Office staff, a formalized process and procedures manual is being developed and will be maintained on a publically facing page of the University intranet to allow all campus users access for reference. As of July 18, 2023, the University added two new positions; Internal Auditor, reporting directly to the Vice President of Financial Affairs and the Audit Committee Chair, and Project Accounting Analyst, reporting to the Controller. While the Internal Auditor will have broad ranging oversight to University systems, it is expected that further University-wide policies and procedures will be developed as a result of these reviews, including those directly impacting financial operations and controls. The purpose of the Project Accounting Analyst position is to review and monitor net asset balances at the project level. A key component of the position involves meeting with campus account managers in conjunction with the Budget Office staff on a quarterly basis to review current activity, address questions related to transactional activity and promote prompt and timely close out of projects. In conjunction with this work, stale projects are being reviewed for potential closeout or ability to utilize available funding sources for current operations. All of these activities are designed to maintain better insight and control over net asset balances. This position is also tasked with developing policies and procedures around the creation and management of project accounts. Over the past year, Management has utilized the resources of the National Association of College and University Business Officers (NACUBO) for consulting, training and advising purposes. Management will continue to utilize this resource and other available resources to further enhance knowledge and develop best practices. Management has committed to contracting with an outside accounting firm to provide further training, support and best practice guidance to the accounting staff. Further, an effort is underway to fill current vacancies within the Controller’s Office with individuals trained to a higher level of accounting knowledge, as well as knowledge specific to the higher education and not for profit fund accounting sector. Through the current audit cycle, a series of reports and procedures have been developed to aid in a more timely and accurate preparation of financial statements.
Finding 522783 (2023-009)
Significant Deficiency 2023
2023-009 – Subrecipient Monitoring Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Subrecipient Monitoring). Program. Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human ...
2023-009 – Subrecipient Monitoring Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Subrecipient Monitoring). Program. Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01. Auditor Description of Condition and Effect: Subaward contracts review did not contain appropriate information related to the federal program. No assistance listing number or federal program name was noted in the language of the agreements. In addition, no evidence of formal risk assessment was documented. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls. Auditor Recommendation: We recommend that the City implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained. Corrective Action: The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented. Part of the solution will be implementing grant management software. Responsible Person: Phillip Moore, Chief Financial Officer Anticipated Completion Date: January 21, 2025
Finding 522781 (2023-010)
Significant Deficiency 2023
2023-010– Special Reporting for Federal Funding Accountability and Transparency Act Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Choice Neighborhoods Implementation Grant; U.S. Department of Housing and Urban Development; ...
2023-010– Special Reporting for Federal Funding Accountability and Transparency Act Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Programs. Choice Neighborhoods Implementation Grant; U.S. Department of Housing and Urban Development; Assistance Listing Number 14.889' Award Number MI5F519CNG117. Substance Abuse and Mental Health Services - Projects of Regional and National Significance; U.S. Department of Health and Human Services; Assistance Listing Number 93.243; Award Number 1H79SM084918-01. Auditor Description of Condition and Effect: Despite passing through qualifying amounts, the City could produce no evidence that the subawards had been reported through the FSRS. The City is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the City's internal controls. Auditor Recommendation: We recommend that the City implement necessary internal controls to ensure that reporting of subawards greater than $30,000 is submitted to the FSRS for all direct grants. Corrective Action: The City will implement the necessary internal controls to ensure the policy for compliance is followed and documented. Responsible Person: Phillip Moore, Chief Financial Officer Anticipated Completion Date: January 21, 2025
I was a newly elected official in 2023 with no prior training in the County Clerk’s office. I had no knowledge of how SEFA monies were to be reported. After this finding was brought to my attention, internal controls were implemented. A process/procedure was put into place where all grants received ...
I was a newly elected official in 2023 with no prior training in the County Clerk’s office. I had no knowledge of how SEFA monies were to be reported. After this finding was brought to my attention, internal controls were implemented. A process/procedure was put into place where all grants received are tracked, as are the expenditures for each grant. The clerk and deputy clerk are now involved in the grant tracking procedure as well as reviewing the SEFA report for accuracy after it is prepared. In January 2025 a Grant Policy was adopted by the Caldwell County Commission to make all county employees aware of the process for reporting and tracking grants received. The Grant Expenditures and Reimbursements Tracking Procedures were also revised. The procedure now involves not only the county clerk and deputy clerk, but also the grant applicant, accounts payable clerk, and the county Collector/Treasurer. The SEFA report will be reviewed by all involved to help ensure accuracy. Anticipated Completion Date: It is anticipated that the 2025 SEFA grant reporting will be much more accurate than in previous years. However, considering the new Grant Policy and the revised Grant Expenditures and Reimbursement Tracking Procedures were not in place until January 2025, it is anticipated that the date of completion will be January 2026.
County’s Response: The County Clerk will implement a procedure to keep more detailed records that accurately states the expenditures of federal awards of the County.
County’s Response: The County Clerk will implement a procedure to keep more detailed records that accurately states the expenditures of federal awards of the County.
Finding #2023-001 Allowable Costs and Cost Principles: Douglas Wilson was unable to determine if the Center complied with the 15% requirement or the $25,000 technical assistance limit for the CCBHC grant. Douglas Wilson was also unable to test a sample of direct costs charged to the program because...
Finding #2023-001 Allowable Costs and Cost Principles: Douglas Wilson was unable to determine if the Center complied with the 15% requirement or the $25,000 technical assistance limit for the CCBHC grant. Douglas Wilson was also unable to test a sample of direct costs charged to the program because transaction details were not provided. Per the recommendation of Douglas Wilson, we have updated the Center’s existing financial policy and procedures to include language specifically related to how the Center will retain documentation to support costs that are charged to the CCBHC grant, and also track and monitor compliance with the 15% and $25,000 maximum requirements for the grant (see Financial Policies and Procedures Policy A-14). Responsible official: Sydney Blair, Chief Executive Officer, 406.791.9603 Expected completion date: June 30, 2025
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to disbursing loans within aggregate loan limits. Responsible Administrators: Director of Financial Aid Effective: Immediately and ongoing
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administ...
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to competing and submitting the audit. The College has a new CFO and Controller. These measures will ensure stability and a timely audit. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective immediately and ongoing
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Fin...
Management concurs with this finding. The College will adhere to its policies, procedures, processes, and federal guidelines as it relates to calculating and awarding Pell. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing
View Audit 341725 Questioned Costs: $1
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Direct...
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal guidelines as it relates to disbursing and administering federal aid. The College will return any ineligible funds accordingly. Responsible Administrators: Director of Financial Aid, Chief Financial Officer & V.P. of Academic Affairs Effective: Immediately and ongoing
View Audit 341725 Questioned Costs: $1
Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Regist...
Management concurs with this finding. The College will set policies, procedures and practices in place and adhere to ensure that changes in students’ enrollment are reported accurately and timely as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Registrar Effective: Immediately and ongoing
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guid...
Management concurs with this finding. The College will review and adhere to its practices, policies, and procedures along with federal regulations as it relates to resolving credit balances. The College will resolve credit balances timely and within the 14-day period as defined in the Federal guidelines. Responsible Administrators: Director of Financial Aid & Chief Financial Officer Effective: Immediately and ongoing
Management will maintain supporting schedules and prepare timely reconciliations to the general ledger on a monthly basis. Required adjustments will be communicated to the management of the accounting function and posted to the general ledger. Management will conduct a final review of the monthly ...
Management will maintain supporting schedules and prepare timely reconciliations to the general ledger on a monthly basis. Required adjustments will be communicated to the management of the accounting function and posted to the general ledger. Management will conduct a final review of the monthly financials prior to finalization, ensuring all requested correcting adjustments have been made and any unnatural balances have been investigated and corrected.
Finding 521997 (2023-001)
Significant Deficiency 2023
Finding Reference Number #SA2023-001: Suspension and Debarment for Contracts and Subcontracts Assistance Listing Numbers: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award Identification Number: ...
Finding Reference Number #SA2023-001: Suspension and Debarment for Contracts and Subcontracts Assistance Listing Numbers: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award Identification Number: SLFRP4371 266737 Pass-Through Entity: California State Water Resources Control Board  Fiscal Year of Initial Finding: 2021  Name(s) of the contact person: Isaac Moreno, Finance Director  Corrective Action Plan: The City has drafted an updated citywide procurement policy that includes the requirement to be compliant with 2 C.F.R Part 180 and is expected to be approved in June 2025.  Anticipated Completion Date: 6/30/2025
Management Response and Corrective Action Plan Finding 2023-002 – Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: 93.837 and 93.847 Responsible Individual: Roy Bourne, Director, ...
Management Response and Corrective Action Plan Finding 2023-002 – Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: 93.837 and 93.847 Responsible Individual: Roy Bourne, Director, Research Finance and Operations Contact Information: rbourne2@joslin.harvard.edu; 617-309-5741 Joslin Diabetes Center’s (Center) subrecipient monitoring process did not clearly indicate risk assessment procedures or the required monitoring activities in certain audited instances. While the Center has a Subrecipient Monitoring and Management policy, review suggests that a thorough evaluation of this plan, formal documentation, and secondary oversight will improve internal control. Management agrees with the recommendation and will evaluate the subrecipient monitoring process according to 2 CFR 200.332 and update established policy where applicable. Corrective Action Plan: - Management will review the Subrecipient Monitoring and Management policy for relevant updates and improvements to internal control - Results of risk assessment procedures and subrecipient monitoring will be formally documented within the tracking log - Log entries will be updated to reflect a reviewers note documenting material and date of review - Director of Research Finance and Operations will review log semi-annually for secondary oversight Expected Completion Date: June 30, 2025 Status of Completion: In Process
Management Responses: The Organization has corrected prior year filings. Moving forward, the Organization will file with the Federal Clearinghouse in a timely manner.
Management Responses: The Organization has corrected prior year filings. Moving forward, the Organization will file with the Federal Clearinghouse in a timely manner.
View Audit 341049 Questioned Costs: $1
Finding 521096 (2023-009)
Significant Deficiency 2023
Condition: Suspension and debarment compliance was not verified for two covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also u...
Condition: Suspension and debarment compliance was not verified for two covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also update our School Contract language to include specific wording where the Vendor acknowledges the law and forfeits the contract if they are on the debarment list after the contract has been signed. A statement will be added to the contracts that states the following: ‘The Contractor (or use the term in the contract that identifies the vendor instead of Contractor) certifies under the pains and penalties of perjury, that the Contractor is not currently debarred or suspended by the Federal government, or any of its agencies, entities or subdivisions, nor is the Contractor currently debarred or suspended by the Commonwealth Massachusetts or any of its agencies, entities or subdivisions.’ If there is a section in the contract where the vendor certifies to other conditions (i.e. state taxes paid), then this language could be included under that section as another certification requirement. A Google Drive has been created to upload all supporting documents on a yearly basis. Anticipated Completion Date: 2/17/2025 Contact: Noel Velez, Director of Finance and Fiona Maxwell, Procurement Director
Finding 521085 (2023-007)
Significant Deficiency 2023
Condition: Suspension and debarment compliance was not verified for five covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also ...
Condition: Suspension and debarment compliance was not verified for five covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also update our School Contract language to include specific wording where the Vendor acknowledges the law and forfeits the contract if they are on the debarment list after the contract has been signed. A statement will be added to the contracts that states the following: ‘The Contractor (or use the term in the contract that identifies the vendor instead of Contractor) certifies under the pains and penalties of perjury, that the Contractor is not currently debarred or suspended by the Federal government, or any of its agencies, entities or subdivisions, nor is the Contractor currently debarred or suspended by the Commonwealth Massachusetts or any of its agencies, entities or subdivisions.’ If there is a section in the contract where the vendor certifies to other conditions (i.e. state taxes paid), then this language could be included under that section as another certification requirement. A Google Drive has been created to upload all supporting documents on a yearly basis. Anticipated Completion Date: 2/17/2025 Contact: Noel Velez, Director of Finance and Fiona Maxwell, Procurement Director
Internal control over payroll and disbursements In January 2023 changes to any pay rates were submitted on a Personnel Action Form (PAF) by the Operations Manager. The PAF included the old pay rate and the new pay rate and was submitted to the Executive Director for review and approval. After app...
Internal control over payroll and disbursements In January 2023 changes to any pay rates were submitted on a Personnel Action Form (PAF) by the Operations Manager. The PAF included the old pay rate and the new pay rate and was submitted to the Executive Director for review and approval. After approval, the form was filed in the employees paper file, as well as uploaded to their electronic record on the ProService platform. In May 2024, we hired a Human Resources Specialist who is responsible for updating and maintaining all personnel files and processing of payroll records. In October 2023, we hired an Accounting Specialist (AS) who is responsible for the processing of all vendor disbursements. Prior to ordering items or services, a Purchase Requisiton (PR) is submitted by the program manager to the Executive Director or Programs Director for review and approval. Upon approval the PR is submitted to the Controller for expense and grant coding. PR is then submitted to the AS to assign a PR number and enter the expenses on the PR tracking log. When the PR has been assigned a PR number it is sent to the Operations Manager for purchasing. When the invoice is received the PR is matched to the invoice indicating proper approvals. If the purchase is over $5,000, a Procurement form is completed to solicit 3 bids and reviewed and approved by the Executive Director. If the purchase is over $20,000, the Procurement form is submitted to the Board of Directors for approval. All Procurement forms are attached to invoices for payment processing. Internal control over account balances During the fiscal year, it was noted that there were credit card entries that were duplicated, and have been corrected as of the date of this report. Due to miscommunication with the previous fiscal staff, payments made by credit card were entered as an invoice and as an adjusting journal entry.
Federal program title – Home Partnership Investment Program – HOME loan – CFDA 14.239 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance...
Federal program title – Home Partnership Investment Program – HOME loan – CFDA 14.239 Recommendation: CLA recommends the County develop procedures, such as including a compliance checklist in the receivables listing sent to the auditor’s office, to ensure that outstanding loan continuing compliance is performed timely and documented in accordance with the HOME grant loan provision. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grants department had two employees in FY 22/23. The Grant coordinator and assistant both terminated county employment in fiscal year 22/23 and left virtually no records. Information and materials, they did leave behind were stuffed in boxes and tracking in the electronic workbook was not fully completed. Admin staff trained the Grant employees but was unaware they were not following the process and procedures, and only saving information to their personal computer. Current admin staff requested the documents from prior staff members and they were received, though we are unsure if all were sent. Staff is doing their due diligence and working diligently to get back on track in monitoring activities, and train the newly hired staff. There is insufficient budget to hire the staff needed to fully monitor the Home Program loan efforts. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins. Planned completion date for correcting action plan: Undetermined at this time as the staff continues their current minimal Home Program loan efforts while still maintaining all other duties, and being short staffed. Existing Home Program workload is being closed out as fast as possible.
View Audit 340608 Questioned Costs: $1
Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as including a compliance check list in the receivables listing sent to auditor’s office, to ensure that outstanding loan continuing compliance is perfor...
Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as including a compliance check list in the receivables listing sent to auditor’s office, to ensure that outstanding loan continuing compliance is performed timely and documented in accordance with the CDBG grant loan provision. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Grants department had two employees in FY 22/23. The Grant coordinator and assistant both terminated county employment in fiscal year 22/23 and left virtually no records. Information and materials, they did leave behind were stuffed in boxes and tracking in the electronic workbook was not fully completed. Admin staff trained the Grant employees but was unaware they were not following the process and procedures, and only saving information to their personal computer. Current admin staff requested the documents from prior staff members and they were received, though we are unsure if all were sent. Staff is doing their due diligence and working diligently to get back on track in monitoring activities, and train the newly hired staff. There is insufficient budget to hire the staff needed to fully monitor the CDBG efforts. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins Planned completion date for correcting action plan: Undetermined at this time as the staff continues their current minimal CDBG efforts while still maintaining all other duties, and being short staffed. Existing CDBG workload is being closed out as fast as possible.
View Audit 340608 Questioned Costs: $1
Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as reporting checklist to ensure that reporting requirements are tracked and met. Additionally, CLA recommends that the County perform cross training wi...
Federal program title – Community Development Block Grant – CDBG – CFDA 14.228 Recommendation: CLA recommends the County develop procedures, such as reporting checklist to ensure that reporting requirements are tracked and met. Additionally, CLA recommends that the County perform cross training with employees to ensure that knowledge is shared among the team members. Action taken in response to finding: The Grants department had two employees in FY 22/23. The Grant coordinator and assistant both terminated county employment in fiscal year 22/23 and left virtually no records. Information and materials, they did leave behind were stuffed in boxes and tracking in the electronic workbook was not fully completed. Admin staff trained the Grant employees but was unaware they were not following the process and procedures, and only saving information to their personal computer. Current admin staff requested the documents from prior staff members and they were received, though we are unsure if all were sent. Staff is doing their due diligence and working diligently to get back on track in monitoring activities, and train the newly hired staff. There is insufficient budget to hire the staff needed to fully monitor the CDBG efforts. Name(s) of the contact person(s) responsible for corrective action: Under direction of the County Administrative Officer, the Senior Financial Analyst Suzie Hawkins Planned completion date for correcting action plan: Undetermined at this time as the staff continues their current minimal CDBG efforts while still maintaining all other duties, and being short staffed. Existing CDBG workload is being closed out as fast as possible.
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