Corrective Action Plans

Finding 499302 (2023-001)

None 2023

Access Tusc

OH

Subrecipient Monitoring

Access Tusc is developing an annual review of all grant contracts to determine program, financial, and operational requirements and ensure that Access Tusc is in compliance. During the audit process, it was determined that our liability insurance was to be at $1,500,000 and it was $1,000,000. That h...

Access Tusc is developing an annual review of all grant contracts to determine program, financial, and operational requirements and ensure that Access Tusc is in compliance. During the audit process, it was determined that our liability insurance was to be at $1,500,000 and it was $1,000,000. That has been corrected and the new expanded insurance coverage is currently in existence.

View Audit 322139

Finding 499294 (2023-001)

Significant Deficiency 2023

Port Graham Village Council

AK

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.317 § 200.318 § 200.327

Finding 2023-001 Internal Control over Procurement Name of Contact Person: Francis Norman Corrective Action: Procurement Policy will be updated and followed Proposed Completion Date: 7/18/2024

View Audit 322114

Finding 499288 (2023-001)

Significant Deficiency 2023

The Housing Authority of the City of Key West, Florida

FL

Questioned Costs HUD Housing Programs Subrecipient Monitoring

2023-001 - HQS Enforcements and Annual HQS Inspections Housing Voucher Cluster - Assistance Listing No. 14.871 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in ...

2023-001 - HQS Enforcements and Annual HQS Inspections Housing Voucher Cluster - Assistance Listing No. 14.871 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month, to determine if the tenant files were prepared in accordance with internal policies and until the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: In response to the HOS enforcement and annual inspections finding for the Housing Authority of the City of Key West, FL 12-31-2023 audit, management has completed the following items in order to address the issue: • Hired a new HCV Program Manager, • Procured a new outside HCV inspection contractor, • Provided current staff training on HCV program HOS requirements, • Adopted the recommendation from our independent auditors to have the Assistant to the Director of Housing sample 10% of the HCV recertification files monthly to ensure compliance with federal regulations and housing quality standards - files that are found to be out of compliance will be reported to the Director of Housing & Executive Director. In addition, the following items will be done: • Consider changing the administrative plan to prohibit time extensions beyond 30 days, thereby requiring abatement of HAP effective the 31st day in all cases, • Update the job description of the Assistant to the Director of Housing & change the title of the position to Assistant to the Director of Housing/Compliance Specialist. Name(s) of the contact person(s) responsible for corrective action: Randy Sterling, Executive Director Planned completion date for corrective action plan: October 31, 2024.

View Audit 322102 Questioned Costs: $1

Finding 499276 (2023-003)

Significant Deficiency 2023

Town of Warwick

NY

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

With regard to Section III Federal Award Findings and Questioned Costs, 2023-03, Suspension or Debarment, whereby you identified a concern in that the Town of Warwick did not have sufficient internal controls of Federal suspension and debarment verification, please be advised of the following correc...

With regard to Section III Federal Award Findings and Questioned Costs, 2023-03, Suspension or Debarment, whereby you identified a concern in that the Town of Warwick did not have sufficient internal controls of Federal suspension and debarment verification, please be advised of the following corrective action, which is effective immediately.It is the policy of the Town of Warwick to refrain from entering into contracts with (1) business entities, which are subject to Suspension or Debarment from Federal or State contracts, or (2) business entities, which utilize subcontractors which are subject to Suspension or Debarment from Federal or State contracts. Going forward, all RFPs will include the requirement that all bids specifically include language stating that the subject vender attests that it is not subject to Suspension or Debarment from Federal or State contracts, nor will it utilize any subcontractors subject to Suspension or Debarment from Federal or State contracts. When bids are opened and considered, the Town Clerk will check to ensure that the necessary language is included in the bid. The Town Clerk will also verify that the bidder, and any named subcontractor is not subject to Suspension or Debarment from Federal or State contracts. The Town will not consider any bid that lacks this necessary language. In the event that the Town Clerk identifies that a bidder, despite its attestation, is subject to Suspension or Debarment from Federal or State contracts, the Town Clerk will so inform that bidder. In the event that the Town enters into a contract, that is not subject to the bidding process, the Town Attorney shall review all proposed contracts includes language that the relevant party attests that it is not it is not subject to Suspension or Debarment from Federal or State contracts, nor will it utilize any subcontractors subject to Suspension or Debarment from Federal or State contracts. Should the relevant party become subject to Suspension or Debarment from Federal or State contracts, or utilize any subcontractors subject to Suspension or Debarment from Federal or State contracts, such would be grounds for termination of the subject contract.

View Audit 322086

Finding 499235 (2023-003)

Significant Deficiency 2023

Entrepreneurship for All, Inc.

MA

Subrecipient Monitoring Significant Deficiency Internal Control / Segregation of Duties

Item # 2023-003 Reconciliation of Bank Accounts (Significant Deficiency in Internal Control) Criteria: Under GAAP, bank accounts are required to be reconciled on a regular basis to ensure that they are properly stated under the accrual basis of accounting. Condition: During the year under audit, ...

Item # 2023-003 Reconciliation of Bank Accounts (Significant Deficiency in Internal Control) Criteria: Under GAAP, bank accounts are required to be reconciled on a regular basis to ensure that they are properly stated under the accrual basis of accounting. Condition: During the year under audit, the Organization did not reconcile the ending balances of all accounts held with financial institutions during the fiscal year. Cause: The Organization did not compare the balances per statements received for bank accounts from financial institutions with its own internal account balances and failed to make the necessary accrual based accounting adjustments for reconciling items. Effect: Failure to update internal controls to comply with the requirements of the GAAP could result in ineffective monitoring of costs allocated to the federal program. Recommendation: The Organization should strengthen its internal control practices by updating its policies and procedures to comply with GAAP. Views of Responsible Officials and Planned Corrective Actions: Management has been making updates to its policies and procedures throughout 2024 to be in full compliance with GAAP. This exercise is anticipated to be complete by the end of the fiscal year.

View Audit 322032

Finding 499232 (2023-001)

Significant Deficiency 2023

Samaritas and Subsidiaries

MI

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management

For the Year Ended December 31, 2023 Finding Number 2023-001 Contact Person(s): Cynthia Sikina, Interim CFO Wendy Perry, Director of Budget & Contracts Corrective Action Planned: Contract terms will be reviewed to ensure understanding of the billing terms and will be documented in the contract manag...

For the Year Ended December 31, 2023 Finding Number 2023-001 Contact Person(s): Cynthia Sikina, Interim CFO Wendy Perry, Director of Budget & Contracts Corrective Action Planned: Contract terms will be reviewed to ensure understanding of the billing terms and will be documented in the contract management system in accordance with the Samaritas contract approval procedure. Cash draws will be aligned with actual cash expenditures for any cost reimbursement contract/grant to limit draws to immediate cash needs in accordance with Title 2 U.S. Code of Federal Regulations Uniform Administrative Requirements, Cost Principles and Audit Requirements for Federal Awards (the Uniform Guidance), Subpart D – Post Federal Award Requirements, Section 200.305 Federal Payment. Anticipated Completion Date: Date completed June 30, 2023

View Audit 322026

Finding 499231 (2023-002)

Material Weakness 2023

Everett Recovery Cafe

WA

Internal Control / Segregation of Duties Subrecipient Monitoring Period of Performance

Management’s Response: Management agrees with the finding. Management plans to complete a review of resources assigned to accounting and finance departments as well as identify and implement sufficient internal controls over expenditures cutoff to ensure compliance with the period of performance com...

Management’s Response: Management agrees with the finding. Management plans to complete a review of resources assigned to accounting and finance departments as well as identify and implement sufficient internal controls over expenditures cutoff to ensure compliance with the period of performance compliance requirement.

View Audit 322025

Finding 499214 (2023-001)

Material Weakness 2023

Southwest Behavioral Health Services, Inc. and Subsidiaries

AZ

Subrecipient Monitoring Reporting Material Weakness § 200.303

Finding Number: 2023-001- Schedule of Expenditures of Federal Awards (SEFA) Preparation – Material Weakness Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control ...

Finding Number: 2023-001- Schedule of Expenditures of Federal Awards (SEFA) Preparation – Material Weakness Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the federal award to ensure compliance with federal statutes, regulations, and the terms and conditions of the federal award. This includes properly identifying all federal awards subject to the Uniform Guidance and fairly presenting the required information in the schedule of expenditures of federal awards. Condition: Subsequent to the issuance of the Audit Report on the Consolidated Financial Statements and Supplementary Information for the year ended September 30, 2023, it was discovered that there was an omission of two federal grants with expenditures totaling $1,591,715 from the schedule of expenditures of federal awards. Cause: The Organization did not communicate with Care 1st Health Plan regarding the details of certain contracts to determine the amounts were subject to the Uniform Guidance and were to be included on the schedule of expenditures of federal awards. In addition, Care 1st Health Plan became the Regional Behavioral Health Authority for the Northern Arizona region effective October 1, 2022. Due to this transition, various changes occurred causing uncertainties with classifications of certain types of federal awards as subrecipient awards versus as contractor payments. Effect: The schedule of expenditures of federal awards was understated by $1,591,715, which resulted in the restatement of the previously issued schedule of expenditures of federal awards to correct the omission. Questioned Costs: Not applicable. Recommendation: We recommend that all funding contracts are carefully reviewed to determine whether amounts awarded should be classified as contractor payments or as subrecipient payments. If there is any uncertainty, we recommend that the Organization contact the funding source for clarification. Name of Contact Person: Mike Fett, CFO Phone Number: 602-265-8338 Anticipated Completion Date: September 30, 2024 Views of Responsible Officials and Corrective Actions: Southwest Behavioral Health Services, Inc. and Subsidiaries will establish procedures to review all contracts and to if necessary, to communicate with funding sources to ensure that receipts of federal funding are properly classified as being subrecipient versus contractor arrangements to ensure completeness of the Schedule of Expenditures of Federal Awards.

View Audit 322000

Finding 499188 (2023-003)

None 2023

New York City Housing Authority

NY

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Number 2023-003 PROCUREMENT AND SUSPENSION AND DEBARMENT – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Procurement And Suspension and Debarment - Non-federal en...

Finding Number 2023-003 PROCUREMENT AND SUSPENSION AND DEBARMENT – DEFICIENCY - COMPLIANCE Agency Name FEDERAL AGENCY: U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Program ALN 14.850 – PUBLIC AND INDIAN HOUSING Contract # N/A Criteria Procurement And Suspension and Debarment - Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov | Home (click on Search Record, then click on Advanced Search-Exclusions) (Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System (EPLS)), (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Non-federal entities receiving contracts from the federal government are required to comply with the contract clause at FAR 52.209-6 before entering into a subcontract that will exceed $30,000, other than a subcontract for a commercially available off-the-shelf item. Condition/Context The Authority received funding from the Public and Indian Housing Program. The Authority has procurement and suspension and Debarment policies. Of the sixty (60) vendor files selected for testing, we noted 3 vendor’s suspension and Debarment documentation were not provided by the Authority. The Authority did review suspension and Debarment status in SAM.GOV for the samples in question, which had no documentation of suspension and Debarment and all vendors were active and no suspensions noted. Recommendation We recommend the Authority strengthen its controls over the Public and Indian Housing Program’s suspension and Debarment policies to ensure that all vendors are not suspended or debarred. Corrective Action Plan In June 2022, NYCHA implemented the Dun & Bradstreet (D&B) Supplier Risk Management tool for development/program units to check federal debarment status of micro vendors. In addition, in February 2023, NYCHA also implemented the self-certification debarment form for micro vendors. Currently, all micro vendors who wish to be placed on the Micro Prequalification List (Micro PQL) for Responsibility to be eligible for a micro award undergo an integrity/responsibility review by a centralized vendor responsibility department prior to being placed on the Micro PQL. This review includes debarment checks among many other integrity assessments. The Micro PQL will go in effect on September 30, 2024. Given that NYCHA’s micro spend comprises less than 4% of total spend in 2021 through 2023 (and approximately 1.1% as of Q3 of 2024), concomitant with the fact that NYCHA has already implemented corrective actions to ensure all vendors are checked for debarments, NYCHA believes the risk of this deficiency to be insignificant. Action Date Already implemented Final Implementation Already implemented Name And Phone Number Of Person Responsible For Implementation Sergio Paneque Chief Procurement Officer 212-306-3528 Sergio.paneque@nycha.nyc.gov

View Audit 321980 Questioned Costs: $1

Finding 499184 (2023-001)

None 2023

Operator Foundation

TX

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions Finding Reference: 2023-001 Responsible Individual: Melissa Mason Operator Foundation received a pass-through, subgrant extension from a partner organization under 19.22 Regional Democracy Program during the calendar year 2023. The subgr...

Views of Responsible Officials and Planned Corrective Actions Finding Reference: 2023-001 Responsible Individual: Melissa Mason Operator Foundation received a pass-through, subgrant extension from a partner organization under 19.22 Regional Democracy Program during the calendar year 2023. The subgrant paperwork Operator received from the partner did not include an Audit Certification form. The form was later provided and requested by the pass through entity on March 18, 2024, and Operator provided the form on the same day that the email request was received. However, passthrough recipients are required to submit a completed Audit Certification Form within 30 days of the end of each subrecipient fiscal year. Operator’s controls did not realize that the form was missing from the provided award package. Corrective Action Plan (CAP) Operator Foundation will strengthen the internal controls as it relates to submitting required reports to its granting agencies by establishing policies and procedures to ensure that reporting information is submitted timely. Operator will review each grant at inception and list out requirements related to reporting and deadlines. Operator Foundation will ensure that all reporting requirements are put on the organizational tracking system including calendars and that reminders are set to ensure timely submission. Operator will communicate any missing requirements in award packages to the funder for the purpose of strengthening compliance of all responsible parties receiving federal funds. Anticipated Completion date: 10/31/2024

View Audit 321976

Finding 499175 (2023-004)

Significant Deficiency 2023

Act for Alexandria

VA

Reporting Subrecipient Monitoring § 200.502 § 200.510

During our review of the December 31, 2023 Schedule of Expenditures of Federal Awards (SEFA) prepared by management, we noted that controls over the preparation of the SEFA were not properly designed resulting in adjustments to the SEFA for amounts passed through to subrecipients that were identifie...

During our review of the December 31, 2023 Schedule of Expenditures of Federal Awards (SEFA) prepared by management, we noted that controls over the preparation of the SEFA were not properly designed resulting in adjustments to the SEFA for amounts passed through to subrecipients that were identified during the audit. Recommendation: We recommend management review current internal controls over preparation and tracking of federal expenditures to ensure that all federal awards are captured and reported in the correct period and that internal controls are properly designed to detect and correct errors to the SEFA. Views of Responsible Officials and Planned Corrective Action: ACT accepts the auditors' recommendation. In preparing the SEFA for future Single Audit periods, ACT will update its processes to include a more rigorous review of the SEFA schedule prior to submission to the auditors. The process will include preparation of the SEFA by ACT’s accounting team, followed by a review and signoff by ACT’s Program Officer and the CEO. An internal schedule prepared by the accounting team that totals amounts separately for beneficiary payments and for subrecipient pass-through payments will be included as part of the review process for the SEFA and presented for signoff by the Program Officer and CEO. For further discussion, please contact Heather Peeler, President and CEO at healther.peeler@actforalexandria.org. 703-739-7778.

View Audit 321962

Finding 499174 (2023-003)

None 2023

Act for Alexandria

VA

Subrecipient Monitoring § 200.332 § 200.513 § 200.521

Condition and Context: ACT noted that it did not request and review audited financial statements for all subrecipients. Recommendation: ACT evaluates the policies and procedures to ensure appropriate monitoring is performed over all subrecipients and reviews audited financial statements for those su...

Condition and Context: ACT noted that it did not request and review audited financial statements for all subrecipients. Recommendation: ACT evaluates the policies and procedures to ensure appropriate monitoring is performed over all subrecipients and reviews audited financial statements for those subrecipients that are required to have an audit performed. Views of Responsible Officials and Planned Corrective Action: ACT accepts the auditors’ recommendation. We will review and update the monitoring policies and procedures to include requesting and reviewing the audited financial statements for those subrecipients that are required to have an audit performed.

View Audit 321962

Finding 499172 (2023-001)

None 2023

Act for Alexandria

VA

Subrecipient Monitoring § 200.1 § 200.332 § 200.414

All three of the subawards selected for testing, the recipient’s UEI number was missing from the subaward. Recommendation: ACT evaluates policies and procedures to ensure all required information is communicated with the subrecipient. Views of Responsible Officials and Planned Corrective Action: ACT...

All three of the subawards selected for testing, the recipient’s UEI number was missing from the subaward. Recommendation: ACT evaluates policies and procedures to ensure all required information is communicated with the subrecipient. Views of Responsible Officials and Planned Corrective Action: ACT accepts the auditors’ recommendation. We will review and update policies and procedures to ensure all required information is included in subaward agreements and communicated to subrecipients, including the recipient’s UEI numbe

View Audit 321962

Finding 499170 (2023-002)

Material Weakness 2023

City of Pasco

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2023-002 ...

Finding ref number: 2023-002 Finding caption: The City did not have adequate controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Darcy Buckley, Finance Director 525 N. 3rd Avenue Pasco, WA (509) 545-3432 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). The instances identified during the audit were related to procurement completed by staff whom rarely manages or is involved in grants. As a result, all staff taking part purchasing in any capacity as well as managers will be receiving training on Federal purchasing thresholds and requirements. Additionally, the City is actively exploring ERP features or system controls as a secondary safeguard in identifying grant funded activity. Anticipated date to complete the corrective action: 12/31/2024

View Audit 321953

Finding 499167 (2023-003)

Significant Deficiency 2023

National Casa Association

WA

Subrecipient Monitoring Reporting § 200.303

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update FFATA reporting procedures to document and maintain documentation of Supervisory review and approval of FFATA data preparation. Completion Date: March 29, 2023 and July 10, 2024. Explana...

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Update FFATA reporting procedures to document and maintain documentation of Supervisory review and approval of FFATA data preparation. Completion Date: March 29, 2023 and July 10, 2024. Explanation: National CASA/GAL has consistently maintained policies and procedures to ensure FFATA reports are filed timely. Documentation of review/approval from a person separate from the person filing the FFATA report was not readily available in some instances, so procedures were updated to include maintenance of such review/approval. FFATA reports are required to be filed “by the end of the month following the month after the subaward obligation date”. National CASA/GAL filed FFATA reports to adhere to this deadline in compliance with what it understood to be the obligation date, understanding an obligation date could not occur prior to the grant period. This finding was noted in the 2022 audit which was issued August 13, 2024. The 2023 audit, completed in September 2024, included in its scope, the same FFATA reports from the same federal grant that had been reviewed in the 2022 audit and OJJDP/OCFO monitoring visit. National CASA/GAL did not have an opportunity between the 2022 and 2023 audits to cure this finding in practice until the issuance of new subrecipient awards in 2024.

View Audit 321944

Finding 499166 (2023-002)

Significant Deficiency 2023

National Casa Association

WA

Subrecipient Monitoring § 200.1 § 200.332 § 200.405 § 200.414

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Maintain the updated subrecipient award agreements to ensure the final approved scope of work and project description are specified. Completion Date: March 29, 2023 Explanation: Policies and pr...

Responsible: Denice Hairston, Chief Quality, Compliance and Accountability Officer Corrective Actions: Maintain the updated subrecipient award agreements to ensure the final approved scope of work and project description are specified. Completion Date: March 29, 2023 Explanation: Policies and procedures were updated in 2023 in response to an OJJDP/OCFO recommendation to ensure subaward files contain the requisite components for the award agreement. In addition to these updates, which include a master file checklist, National CASA/GAL has updated the subrecipient Terms & Conditions agreement to include CFR requirements as recommended. This finding was noted in the 2022 audit which was issued August 13, 2024. The 2023 audit, completed in September 2024, included in its scope, similar subrecipient awards from the same federal grant that had been reviewed in the 2022 audit and OJJDP/OCFO monitoring visit. National CASA/GAL did not have an opportunity between the 2022 and 2023 audits to cure this finding in practice until the issuance of new subrecipient awards in 2024.

View Audit 321944

Finding 499138 (2023-001)

Significant Deficiency 2023

Wireless Infrastructure Association and Affiliates

VA

Cash Management Subrecipient Monitoring HUD Housing Programs § 200.305

WIA management will implement the following corrective action plan: In order to ensure compliance with the timeliness of disbursements of federal funds contemplated under 2 CFR 200.305(b), WIA will implement the following additional procedures for federally-funded expenses. A detailed evaluation ...

WIA management will implement the following corrective action plan: In order to ensure compliance with the timeliness of disbursements of federal funds contemplated under 2 CFR 200.305(b), WIA will implement the following additional procedures for federally-funded expenses. A detailed evaluation of project deliverables and timelines will be conducted by the Project Manager and Project Director for any program subject to compliance with Federal guidelines. The timelines, deliverables and affected funding mechanism(s) will be aligned to determine if there may be a delay beyond a reasonable period which would impact the submission and processing of payments to subcontractors. If it is determined that a delay is possible or likely, consideration will be given to contract amendments which better support the processing of payments aligned with 2 CFR 200.305(b). Further, the Finance team member assigned to the associated program will provide regular guidance to the project team which may include a detailed briefing on the CFR and any relevant concerns with cash management. Disbursements of federal funds will be issued in a timely manner in all instances. The additional set of procedures described above will be implemented in September 2024. In addition, we are currently working through finalizing the contract for Phase 2 of the specific contract related to this finding. We anticipate these negotiations will be completed by October 31st, 2024. Once the Phase 2 agreement has been reached, we will immediately release the Phase 1 funds to the vendor and obtain guidance from The Ohio State University as to the proper disposition of any interest that has been earned by WIA from the withheld Phase 1 payment. Marta Sokol, Chief Financial Officer is the individual responsible for oversight of this corrective action plan. Mrs. Sokol can be reached at 703.535.7447 or Marta.Sokol@wia.org.

View Audit 321912

Finding 499114 (2023-002)

Significant Deficiency 2023

Bronx Community Health Network, Inc.

NY

Subrecipient Monitoring Reporting HUD Housing Programs § 200.303

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2023 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2023-002 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) – Significant Deficienc...

Bronx Community Health Network, Inc. (“BCHN”) Corrective Action Plan For the Year Ended December 31, 2023 Health Resources and Services Administration (“HRSA”) Federal Award Finding Finding 2023-002 – Reporting: Federal Funding Accountability and Transparency Act (“FFATA”) – Significant Deficiency Description of Finding: There was no evidence of review and approval by someone other than the preparer of the FFATA subawards that were submitted to the FSRS. The FFATA subawards were not submitted timely to the Federal Funding Accountability and Transparency Act Subaward Reporting System (“FSRS”). Statement of Concurrence: We concur with the finding above. Corrective Action: As of September 1, 2023, BCHN implemented a workflow where FFATA information will be reported to the FSRS upon receipt of the Notices of Award. In addition, as of September 9, 2024, the FFATA report will be reviewed by someone other than the preparer prior to submission and evidence of the approval maintained. Completion Date: September 9, 2024. Name of Contact Person: James Paine, Ph.D. Chief Executive Officer Tel. No.: (718) 405-4993 E-mail: jpaine@bchnhealth.org If HRSA has questions regarding this Corrective Action Plan, please call James Paine at (718) 405-4993. Sincerely yours, _________________________ James Paine, Ph.D. Chief Executive Officer

View Audit 321903

Finding 499094 (2023-001)

Material Weakness 2023

King County

WA

Subrecipient Monitoring

King County Department of Public Health (DPH) implemented an escalation plan incorporating increased communication strategies for non-compliance with Department leadership to ensure adherence to FFATA reporting requirements. A corrective action plan was established to address the 2022-001 Finding an...

King County Department of Public Health (DPH) implemented an escalation plan incorporating increased communication strategies for non-compliance with Department leadership to ensure adherence to FFATA reporting requirements. A corrective action plan was established to address the 2022-001 Finding and included actions to provide consistent training to personnel regarding FFATA reporting, as well as conducting management reviews through quarterly monitoring to ensure reporting requirements and deadlines are met. DPH will build upon the established corrective action plan by also reinforcing training and job aids for consistent application of reporting responsibilities and deadlines; the Department’s Financial Compliance and Grant Management Team will also conduct enhanced quarterly monitoring reviews. In addition, DPH will institute quarterly notifications for non-compliance with FFATA requirements to a list of established Department contacts.

View Audit 321890

Finding 499074 (2023-002)

Material Weakness 2023

City of West Lafayette

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding 2023-002 Finding Subject: • Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment. Summary of Finding: • Documentation was not created when vendor was verified that it was not suspended nor debarred. Contact Person: Peter Gray Contact Phone: 765-775-5150 Views of Respo...

Finding 2023-002 Finding Subject: • Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment. Summary of Finding: • Documentation was not created when vendor was verified that it was not suspended nor debarred. Contact Person: Peter Gray Contact Phone: 765-775-5150 Views of Responsible Official: • We concur with the finding. Explanation and Reasons for Disagreement: • N/A Description of Corrective Action: • The City did perform procedures to verify that the vendor was not suspended nor debarred. However, no documentation was created. The vendors in question were not, and are not currently, suspended nor debarred. • We will create an affidavit for vendors that receive Federal funds to sign that they are not suspended nor debarred from receiving Federal Funds. Any change in that status is to be reported to us. Anticipated Completion Date: 31 October 2024

View Audit 321859

Finding 499073 (2023-001)

None 2023

Borough of Sharpsville

PA

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.318 § 200.326

September 27, 2024 Borough of Sharpsville State Single Audit Corrective Action Plan For the Fiscal Year Ended 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Borough of Sharpsville To whom it may concern: AUDIT FINDINGS Finding Reference Number: 2023-001 Description o...

September 27, 2024 Borough of Sharpsville State Single Audit Corrective Action Plan For the Fiscal Year Ended 2023 Federal Audit Clearinghouse Re: Corrective Action Plan for Borough of Sharpsville To whom it may concern: AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No documented procurement procedures Statement of Concurrence or Nonconcurrence: The Borough of Sharpsville agrees with the finding in Borough of Sharpsville 2023 Single Audit Report Schedule of Findings. Corrective Action: The borough will revise its outdated procurement policy to comply with all state and federal programs which meet uniform guidance. Name of Contact Person: Kenneth P. Robertson, Borough Manager-Secretary/Treasurer (724) 962-7896 krobertson@sharpsville.org Projected Completion Date: Borough of Sharpsville anticipates resolving the audit finding by resolution of borough council at its November 2024 meeting. Any questions or concerns should be directed to Kenneth Robertson at (724) 962-7896. Sincerely yours, Kenneth P. Robertson Borough Manager-Secretary/Treasurer

View Audit 321851

Finding 499060 (2023-002)

Material Weakness 2023

Metropolitan School District of Lawrence Township

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-002 Finding Subject: COVID- 19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For one of the three reports tested, the report was not supported by the unit...

FINDING 2023-002 Finding Subject: COVID- 19 – Education Stabilization Fund - Reporting Summary of Finding: The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For one of the three reports tested, the report was not supported by the unit’s records. The financial information provided did not agree with the data submitted in the Reports, therefore we could not determine their accuracy. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will work to ensure the ESSER report amounts tie to the accounting records and will improve record keeping of supporting documentation. If the amounts do not match, District will document support for all claims. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

View Audit 321827

Finding 499056 (2023-001)

Material Weakness 2023

Metropolitan School District of Lawrence Township

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2023-001 Finding Subject: Special Education Cluster – Procurement, Suspension, and Debarment Summary of Finding: The School Corporation did not obtain price or rate quotes for the four vendors tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000...

FINDING 2023-001 Finding Subject: Special Education Cluster – Procurement, Suspension, and Debarment Summary of Finding: The School Corporation did not obtain price or rate quotes for the four vendors tested that was less than the simplified acquisition threshold of $150,000 but exceeded the $10,000 micro-purchase threshold. Documentation detailing the history of procurement, which must include the reason for the procurement method used, was not available for audit. There was no evidence of the School Corporation verifying two vendors tested for Suspension and Debarment that these vendors were not excluded or disqualified from participation in federal assistance programs or activities. Contact Person Responsible for Corrective Action: Matt Miles Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: This is a repeat finding due to the immediate timing of the prior audit and a lag for new controls to take effect. The School District will obtain 3 quotes or do a bid process in the future. If there is limited availability, we will document the reason 3 quotes are not possible. Additionally, the District will check for suspension and debarment, create a write-up of our findings, and obtain Board approval for the contract. Anticipated Completion Date: Corrective action steps have been implemented and will be refreshed.

View Audit 321827

Finding 499013 (2023-002)

Significant Deficiency 2023

Black Belt Community Foundation

AL

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

Management will provide additional training to employees on the Foundation’s fiscal policies and procedures, including policies directly affecting contracts and procurement.

View Audit 321796

Finding 499004 (2023-002)

Significant Deficiency 2023

Thurston County Economic Development Council

WA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Defense ALN: 12.002 Recommendation: JSP recommends that the Organization includes all required elements in the subrecipient contracts. We also recommend that the organization reviews subrecip...

Significant Deficiency in Internal Control and Compliance over Major Programs Funding Agency: Department of Defense ALN: 12.002 Recommendation: JSP recommends that the Organization includes all required elements in the subrecipient contracts. We also recommend that the organization reviews subrecipient's financial records and documentation for program expenses, prior to reimbursing the subrecipient with federal funds. There is no disagreement with the audit finding. Action planned in response to finding: An amendment to the subrecipient contracts ending March 31, 2025 shall be implemented to include language from the referenced CFR citations to reflect (1) the requirement of proper documentation of allowable expenditures attached to payment requests (2) the subrecipient permits the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary and (3) the closeout terms and conditions of the subaward. Names of the contact person(s) responsible for corrective action: Michael Cade (EDC Executive Director), Heidi McCutcheon (EDC Deputy Director), and Tiffany Scroggs (EDC APEX Accelerator State Director). Planned completion date for corrective action plan: September 30, 2024

View Audit 321792

Corrective Action Plans

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