Corrective Action Plans

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Finding 2025-002: Eligibility – Temporary Assistance for Needy Families Name of Contact Person: Bobbie Crooker, Director of Energy and Housing Services Management’s Views and Corrective Action Plan: The Department of Energy and Housing Services (EHS) at MaineHousing agrees with the finding. The elig...
Finding 2025-002: Eligibility – Temporary Assistance for Needy Families Name of Contact Person: Bobbie Crooker, Director of Energy and Housing Services Management’s Views and Corrective Action Plan: The Department of Energy and Housing Services (EHS) at MaineHousing agrees with the finding. The eligibility determination error occurred because the applicant initially presented a qualifying dependent child that met program requirements. However, the applicant subsequently failed to provide the required verification documentation. Although the applicant should have been deemed ineligible due to noncompliance, the system did not update accordingly to adjust the benefit level. The system has since been corrected to address this issue. Application intake and approval are performed by Community Action Agencies (CAAs) on behalf of MaineHousing. To provide greater assurance that CAAs accurately determine and document participant eligibility, MaineHousing has strengthened its oversight and monitoring procedures. As part of this corrective action, MaineHousing enhanced its monitoring procedures to include additional supervisory review of CAA applications and eligibility determinations. These procedures supplement the annual required risk monitoring performed for each CAA and better enable MaineHousing to identify and address determination errors or related control weaknesses in a timely manner. EHS has reviewed the circumstances surrounding the specific case identified and has determined that it appears that the known questioned costs did not exceed reportable federal thresholds and no further recovery action is necessary. This program was administered as part of a subrecipient agreement with the Maine Department of Health and Human Services (DHHS). Due to structural and fiscal changes at DHHS, MaineHousing concluded its administration of these TANF funds effective July 1, 2026. Proposed Completion Date: Completed
Finding 2025-001: Reporting – Community Development Block Grant/State’s Program and Non- Entitlement Grants in Hawaii Name of Contact Person: Ashley Carson, Chief Counsel Management’s Views and Corrective Action Plan: The Legal & Compliance Department is responsible for the submission of the Annual ...
Finding 2025-001: Reporting – Community Development Block Grant/State’s Program and Non- Entitlement Grants in Hawaii Name of Contact Person: Ashley Carson, Chief Counsel Management’s Views and Corrective Action Plan: The Legal & Compliance Department is responsible for the submission of the Annual Performance Report for the Recovery Housing Program and agree with the finding. For 2025, MaineHousing was experiencing an error in HUD’s Disaster Recovery Grant Reporting (DRGR) system with submission of the report and reached out to HUD for assistance. HUD was non-responsive to the first two requests for assistance, and a third request was not made until after the report filing deadline. HUD responded to the third request and assisted by providing technical assistance which allowed the report to be submitted. The report was not filed in a timely manner due to the DRGR system errors and the elapsed time between follow-ups with HUD. As system errors for DRGR are a common issue, the following corrective action will ensure that MaineHousing is proactive in the submission of Annual Performance Report for Recovery Housing. The Annual Performance Report for the Recovery Housing Program is due on October 30th. No later than September 15th each year, MaineHousing will attempt to verify any issues with the DRGR system ahead of the reporting deadline and immediately reach out to HUD for technical assistance with any issues found. MaineHousing will gather the information for the Recovery Housing Annual Performance Report at least 45 days ahead of the October 30th deadline (if available) and attempt submission of that report no later than October 5th. If errors occur in DRGR in submitting the report, MaineHousing will immediately contact HUD and continue to follow up weekly until the issue is resolved, attempting other modes of contact if HUD is unresponsive. If the report cannot be submitted in a timely manner, MaineHousing will request that HUD confirm in writing that late submission is acceptable given the circumstances. Proposed Completion Date: Completed
Finding 2025-002 Corrective Action: Management concurs with the finding. The Organization will implement a formal review and approval process over monthly CACFP requests for reimbursement. Prior to submission, the Grant Manager, who is independent of the preparation process, will review the monthly ...
Finding 2025-002 Corrective Action: Management concurs with the finding. The Organization will implement a formal review and approval process over monthly CACFP requests for reimbursement. Prior to submission, the Grant Manager, who is independent of the preparation process, will review the monthly request for reimbursement and supporting documentation, including payroll and nonpayroll costs allocated to the CACFP to verify that costs are appropriately allocated to the program and are allowable under the applicable federal requirements. Evidence of the review and approval will be documented and retained with the monthly reimbursement documentation. Anticipated Completion Date: September 2026 Personnel Responsible for Corrective Action: Alison Elder, CFO
The County will enhance its internal controls over reporting and review federal guidance for reporting under the Coronavirus State and Local Fiscal Recovery Funds.
The County will enhance its internal controls over reporting and review federal guidance for reporting under the Coronavirus State and Local Fiscal Recovery Funds.
Finding 2025-009: Noncompliance – Special Tests and Provisions Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will establish written procedures and a compliance calendar addressing waiting-list administration, annual utility allowance reviews, an...
Finding 2025-009: Noncompliance – Special Tests and Provisions Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will establish written procedures and a compliance calendar addressing waiting-list administration, annual utility allowance reviews, and required inspection quality-control reviews. The Agency will take the following actions: Waiting-List Administration • Review existing waiting-list records and procedures. • Maintain documentation supporting applications, preferences, applicant selections, withdrawals, removals, updates, and offers of assistance. • Ensure applicants are selected in accordance with the Administrative Plan and documented waiting-list order. • Restrict and monitor access to waiting-list records. • Periodically reconcile system-generated waiting-list reports to supporting documentation. • Conduct and document periodic waiting-list purges in accordance with the Administrative Plan. Utility Allowances • Complete and document an annual review of the Voucher program’s utility allowance schedules. • Retain utility rates, consumption information, calculations, conclusions, and supporting documentation. • Present revisions to the Board for approval when an adjustment is warranted. • Document the review even when no change to the utility allowance schedule is required. Inspection Quality Control • Establish procedures for selecting and completing the required number of quality-control inspections. • Ensure the quality-control sample is selected in accordance with applicable HUD requirements. • Use a qualified individual other than the original inspector to perform the quality-control review. • Document the units reviewed, deficiencies identified, comparison to the original inspection, and corrective action taken. • Apply the HUD inspection standard in effect for the Voucher program at the time of the inspection. • Use quality-control results to identify training needs and improve inspection consistency. Management will review compliance with these requirements periodically and report the results and any unresolved deficiencies to the Board of Commissioners. Estimated Completion Date: Written procedures and the compliance calendar will be implemented by October 31, 2026. The outstanding utility allowance review and initial inspection quality-control review will be completed by December 31, 2026, with annual and periodic monitoring thereafter. Responsible Parties: Executive Director, Housing Choice Voucher program staff, designated inspection personnel, and Board of Commissioners.
Finding 2025-008: Material Weakness in Internal Control Over Compliance – Housing Choice Voucher Program Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will develop and implement a comprehensive system of written internal controls and compliance ...
Finding 2025-008: Material Weakness in Internal Control Over Compliance – Housing Choice Voucher Program Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will develop and implement a comprehensive system of written internal controls and compliance procedures for the Housing Choice Voucher Program. The Agency will also: • Develop standardized tenant-file checklists covering eligibility, income, assets, deductions, citizenship or eligible immigration status, Social Security numbers, EIV documentation, rent reasonableness, inspections, leases, HAP contracts, annual and interim reexaminations, portability, and other applicable requirements. • Require the checklist to be completed and maintained in each participant file. • Establish and document supervisory or quality-control reviews of an appropriate sample of applicant and participant files. • Correct deficiencies identified during supervisory reviews and document the corrective action taken. • Update the Administrative Plan to incorporate applicable HOTMA provisions and current HUD guidance. • Establish procedures for reviewing HUD notices, regulations, handbooks, and other program guidance. • Provide regular training to employees responsible for administering the Voucher program. • Clearly assign program responsibilities and develop written procedures to reduce dependence on the knowledge of individual employees. • Maintain a compliance calendar for recurring program responsibilities and reporting deadlines. • Provide the Board with periodic reports regarding compliance reviews, deficiencies identified, and corrective actions completed. Estimated Completion Date: Checklists and supervisory-review procedures will be implemented by October 31, 2026. Written procedures, policy updates, and initial staff training will be completed by December 31, 2026, with ongoing monitoring thereafter. Responsible Parties: Executive Director, Housing Choice Voucher program staff, designated supervisory staff, and Board of Commissioners.
Material Weakness Finding No. 2025-006: Cash Management Views of Responsible Officials and Planned Corrective Action The Organization acknowledges the importance of compliance with 2 CFR §200.305, rules for federal payments; and understood and concurred with the prior year finding (2024-006) and cur...
Material Weakness Finding No. 2025-006: Cash Management Views of Responsible Officials and Planned Corrective Action The Organization acknowledges the importance of compliance with 2 CFR §200.305, rules for federal payments; and understood and concurred with the prior year finding (2024-006) and current year renumbered recommendation (2025-006). A. U.S. Department of Health and Human Services (HHS) Substance Abuse and Mental Health Services Federal Assistance Listing Number 93.243. The Organization received this award from the HHS, Substance Abuse and Mental Health Services Administration (SAMHSA), via the State of Hawaii, Department of Health (DOH). In other words, SAMHSA awarded federal dollars to the DOH, who then sub-awarded federal dollars to the Organization. The Organization further sub-awarded to eligible community-based organizations (CBOs), for the purpose of SAMHSA emergency response grants (SERG), as a result of the impacts of the Lahaina wildfires in August 2023. Payments from the DOH, is based on the Organization’s meeting the billing parameters as established by the DOH at the time of contracting. Actual billing by the Organization to the DOH, includes the aggregation of eligible expenditures incurred by sub-recipient CBOs, that are subject to reimbursement from the Organization via the DOH reimbursement. Sub-recipient CBO invoices are reviewed and validated by the Organization’s program staff prior to submission for the Organization’s aggregation and invoicing to DOH. 1. The Organization notes the following process in place as of the June 30, 2025 fiscal year end: Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls includes the review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds. This monthly process and review controls functioned to mitigate any internal control non-compliance. 2. The Organization also notes the following processes implemented after the June 30, 2025 fiscal year end: Internal Control Environment Policy – July 2025, Updated August 2026. Established and updated the following policies: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; and Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. Effective September 2026, the Organization will implement an internal control review of the federal funds to ensure compliance with 2 CFR §200.305 for Federal Assistance Listing Number 93.243. B. U.S. Department of Health and Human Services (HHS) Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. This federal award is referred to as either Public Health Services (PHS) or the Native Hawaiian Healthcare Improvement Act (Act) federal dollars. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: 1. System, Process & Review Controls In Practice. a. System Controls. Continued to operate in an environment in which system, process & review controls of the United States Department of Health and Human Services (HHS) are practiced in processing cash (draw) transactions in both the Electronic Handbook (EHB) and Payment Management System (PMS) systems, operated by HHS. Only the director of administrative operations and the CEO have system access to the EHB and PMS systems. b. Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls includes the review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds, and Native Hawaiian Health Program (Fund 007V), and Native Hawaiian Health Scholarship Program (Fund 017V). This monthly process and review controls functioned to mitigate any internal control non-compliance. c. HHS Drawdown Restriction. The Organization remained on HHS imposed drawdown restriction as of June 30, 2024 and June 30, 2025. The restriction was removed by HHS in July 2026. 2. The Organization also notes the following processes implemented after the June 30, 2025 fiscal year end: a. Internal Control Environment Policy – July 2025, Updated August 2026. Implemented and updated the following policies: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; and Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. b. Additional Process & Review Controls – EHB & PMS. Effective March 1, 2026, the Organization implemented, federal draws, process and review of internal controls implemented, via the chief of staff’s review of the director of administrative operations cash management analyses, federal grant receivable composition, reconciliation and related federal grant revenue computations, prior to any director of administrative operations and chief executive officer action in EHB and PMS, respectively. Finding No. 2025-006: Cash Management Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.
Material Weakness Finding No. 2025-005: Document Retention Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Feder...
Material Weakness Finding No. 2025-005: Document Retention Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), §200.334, requiring “Financial records, supporting documents, statistical records, and all other non-Federal records must be retained for a period of three years from the date of submission of the final expenditure report…”, and recommendation made. The Organization further refers to the corrective action plan of Finding No. 2025-002: Subrecipient Monitoring, which describes the Organization’s implemented changes re: Subrecipient Monitoring and Management, Retroactive Subrecipient Portfolio Risk Assessment and Correction(s), and Subrecipient Policies and Procedures. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work by the Organization: A. Contractor Performance Collection and Substantiation – November 2024. Incorporated specific review procedures to ensure the timely collection and substantiation of contractor performance deliverables (e.g., products, goods, services, activities, reports), consistent with the terms and conditions of the contract. B. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. C. Discussed with respective program director(s), the implementation of initiation, consideration, decision, documentation and monitoring phased activities. D. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. E. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date. Finding No. 2025-005: Document Retention Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D. Chief of Staff.
Material Weakness Finding No. 2025-002: Subrecipient Monitoring Views of Responsible Officials and Planned Corrective Action The Organization acknowledges 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, and its subrecipient monitoring and management provisions emphasizing accountability a...
Material Weakness Finding No. 2025-002: Subrecipient Monitoring Views of Responsible Officials and Planned Corrective Action The Organization acknowledges 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, and its subrecipient monitoring and management provisions emphasizing accountability and compliance in managing federal funds and subrecipients. The Organization concurs with the prior year (2024-002) and current year renumbered recommendation (2025-002) and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Subrecipient Monitoring and Management. Implemented internal process changes, effective November 1, 2024, specifically, prospectively, and consistently the: 1. Use of a checklist, to comprehensively assess risk of determining subrecipient or contractor classification, before entering into any subrecipient agreement; 2. Provision of identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards; 3. Submission of programmatic and financial reports as specified in the subrecipient agreement; 4. Review of a single audit in accordance with 2 CFR Part 200, Subpart F for subrecipients that expend $750,000 or more in federal funds during a fiscal year, if applicable; and 5. Review of their audit report(s) and addressing any finding(s) related to their federal award(s), including the related appropriate corrective actions, when applicable. B. Retroactive Subrecipient Portfolio Risk Assessment and Correction(s). Performed a risk assessment of the existing subrecipient portfolio to identify risks, for the audit periods July 1, 2022 – June 30, 2023, and July 1, 2023 – June 30, 2024. The objective of this risk assessment was to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, compliance and quality assurance goals. The completion of the Organization’s portfolio risk assessment resulted in correction of identified non-compliant subrecipient agreement(s). C. Subrecipient Policies and Procedures. Updated, by December 31, 2024, the implemented financial policies and procedures aligned to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance, including checklists, flowcharts, samples, data sheets, data sharing agreements, etc. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the implementation of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date. Finding No. 2025-002: Subrecipient Monitoring Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations and Sylvia Hussey, Ed.D., Chief of Staff.
Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Action Taken Upon review, it was determined that the configuration of the Sliding Fee Discount Program within our Practice Management System had been set up ...
Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Action Taken Upon review, it was determined that the configuration of the Sliding Fee Discount Program within our Practice Management System had been set up incorrectly. Specifically, the "Slide After Insurance Method" setting was configured as CHGAMT rather than BALANCE. The Sliding Fee Maintenance settings were corrected in the system on May 27, 2026, to ensure the Sliding Fee Discount Program is applied appropriately following insurance adjudication. In addition, ConnextCare conducted a comprehensive audit of all 2026 dates of service for patients actively enrolled in the Sliding Fee Discount Program. No additional occurrences of this issue were identified. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Tracy Wimmer, CFO at (315) 264-0991. Sincerely yours, Tracy Wimmer Sr. VP/Chief Financial Officer
We will correct our reporting issues with the next required report.
We will correct our reporting issues with the next required report.
Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted ...
Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted written standards of conduct governing actual, potential, and perceived conflicts of interest involving employees and governing body members who participate in the selection, award, or administration of contracts supported by federal funds. To address the finding, the Town will develop a written conflict of interest policy that complies with applicable federal requirements, including 2 CFR § 200.318(c)(1). At a minimum, the policy will: 1. Define actual, potential, and perceived conflicts of interest and prohibited conduct; 2. Identify the employees, officials, and governing body members subject to the policy; 3. Require prompt written disclosure of relevant financial interests and other potential conflicts; 4. Establish procedures for reviewing, documenting, and resolving disclosed conflicts; 5. Require affected individuals to refrain from participating in matters in which a conflict exists; 6. Establish appropriate disciplinary or corrective measures for violations; 7. Require periodic written conflict-of-interest acknowledgments and disclosures; and 8. Address the retention of acknowledgments, disclosures, determinations, and related compliance documentation. The proposed policy will be presented to the Town Council for formal consideration and adoption. Following adoption, the Town will distribute the policy to applicable employees and governing body members and provide appropriate training or written guidance regarding their responsibilities. The Town will retain completed acknowledgments, disclosures, and documentation of any conflict determinations in accordance with its applicable record-retention requirements. Management will periodically review the policy and related procedures to help ensure continued compliance with federal award requirements. Responsible Official Town Administrator Anticipated Completion Date December 31, 2026. Current Status The Town currently does not have a written conflict of interest policy.
Finding 2025-002 Federal Audit Clearinghouse Reporting Finding: The single audit reporting package and data collection form were not submitted to the Federal Audit Clearinghouse within the required timeframe established by the Uniform Guidance. Corrective Action The Town will implement procedures to...
Finding 2025-002 Federal Audit Clearinghouse Reporting Finding: The single audit reporting package and data collection form were not submitted to the Federal Audit Clearinghouse within the required timeframe established by the Uniform Guidance. Corrective Action The Town will implement procedures to ensure timely completion of audits, and submission of future Single Audit reporting requirements by: 1. Assigning responsibility for monitoring federal reporting deadlines to the Town Administrator. 2. Utilizing the services of the Town's contracted CPA to assist management in monitoring audit progress and ensuring all required reports are submitted within the timeframe required by 2 CFR §200.512. 3. Providing periodic updates to Town Council regarding the status of federal compliance requirements and reporting deadlines. Responsible Official Town Administrator Anticipated Completion Date Immediately implemented and fully operational by December 31, 2026. Current Status The Town has retained a third-party Certified Public Accountant to assist with bookkeeping, compliance monitoring, and timely submission of required reports to the Federal Audit Clearinghouse.
Views of Responsible Officials: We acknowledge this lapse. We have already updated procedures to ensure that we are registering subgrants correctly. Name and Title of Responsible Officials: Oliver Rivers, Chief Operating Officer and Deniz Sarkinovic, Senior Director of Compliance Anticipated Complet...
Views of Responsible Officials: We acknowledge this lapse. We have already updated procedures to ensure that we are registering subgrants correctly. Name and Title of Responsible Officials: Oliver Rivers, Chief Operating Officer and Deniz Sarkinovic, Senior Director of Compliance Anticipated Completion Date: September 30, 2026
Internal Control over Compliance- Subrecipient Monitoring Recommendation: We recommend all expenses incurred by subrecipients are reviewed and approved prior to reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to t...
Internal Control over Compliance- Subrecipient Monitoring Recommendation: We recommend all expenses incurred by subrecipients are reviewed and approved prior to reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Response by management to the finding: We acknowledge that prior to the completion of our January 1, 2024 – December 31, 2024 audit CASA relied on summary level expense reports from subrecipients under the PCCD grant and did not consistently verify underlying invoices. More detail regarding process in place at the time of FY2024 audit can be found in the corrective action plan for that year. Due to the timing of the FY2024 audits completion having been finalized in December 2025 procedural changes to address the concerns were not consistently implemented until the end of FY2025. As a result, the actions put in place in the prior year corrective action plan were not reflected in our FY2025 procedure. Actions taken prior to and since the issuance of the FY2024 audit include engagement of a new contracted accounting firm with a wider breadth of experience and expertise; an internal restructuring of staff to provide increased opportunity for oversight and review of contracted financial services, a new review protocol of invoices requiring verification of supporting documentation, and documentation of management approval of invoices. Also of note, the PCCD grant in question required a lengthy budget modification process, which required additional oversight and review of allowable costs. The term of this funding ends 9/30/2026 and will not be extended or renewed. Name of the contact person responsible for corrective action: Leigh Anne McKelvey, Executive Director Planned completion date for corrective action plan: 9/30/26 If the U.S. Department of the Treasury has questions regarding this plan, please call Leigh Anne McKelvey, Executive Director, at 610-565-2208.
Management concurs with this finding, in part. As discussed in Finding 2025-001, during the period under audit, CARS had historically classified the affected entities as contractors/vendors based on management’s review and understanding of the nature of those relationships. As a result of those clas...
Management concurs with this finding, in part. As discussed in Finding 2025-001, during the period under audit, CARS had historically classified the affected entities as contractors/vendors based on management’s review and understanding of the nature of those relationships. As a result of those classifications, CARS did not apply all of the formal subrecipient monitoring requirements of 2 CFR § 200.332 to these entities. Specifically, formal subrecipient risk assessments were not performed or documented, verification of required audits under Subpart F was not incorporated into a formal monitoring process, and certain subrecipient agreements contained incorrect Assistance Listing Numbers (ALNs). CARS believes it is important to distinguish the identified deficiencies from an absence of risk evaluation, oversight or monitoring of the entities. Although CARS did not perform or document formal subrecipient risk assessments in accordance with 2 CFR § 200.332, management considered factors relevant to organizational risk during the initial proposal and partner-selection process. These considerations included CARS’ prior experience with the organizations, their demonstrated performance and funding histories, organizational capabilities, and experience administering federally funded programs, as applicable. The basis for partner selection and related considerations were reflected in the proposal documentation. During the period under audit, CARS reviewed and approved reimbursement requests for allowability and performed ongoing programmatic monitoring of performance and progress. However, because the entities were classified as contractors/vendors, these risk evaluation and monitoring activities were performed within CARS’ existing proposal, vendor, and program oversight processes rather than within a formal subrecipient monitoring framework designed to address all requirements of 2 CFR § 200.332. Based on additional training regarding subaward management under 2 CFR Part 200 and the matters identified during the current audit, management recognizes that formal written policies, documented classification determinations, and additional monitoring controls are necessary to ensure that entities determined to be subrecipients are consistently monitored in accordance with applicable Uniform Guidance requirements. CARS began corrective action and, prior to issuance of the audit report, completed the following: 1. Confirmed the correct Assistance Listing Number for the NTTAC federal award and identified subrecipient agreements requiring correction; 2. Issued modifications to affected subrecipient agreements, as necessary, to communicate the correct ALN for the applicable Year 5 modifications; 3. Reviewed available subrecipient SEFA information related to FY2025 expenditures to evaluate the accuracy of the reported ALN and communicated necessary corrections, as applicable; and 4. Obtained and reviewed available Single Audit information for the affected subrecipients and confirmed that no findings related to federal funding received from CARS were identified in the reports reviewed. Corrective Action CARS will formalize and document its existing procedures as they specifically relate to subrecipients and the applicable requirements of 2 CFR § 200.331 and § 200.332. The policy and related procedures will include documented subrecipient-versus-contractor determinations; subrecipient risk assessments; verification of required subaward information, including the Assistance Listing Number (ALN); review of financial and programmatic performance information; verification of applicable Subpart F audit requirements; review and follow-up of audit findings or other significant developments; and documentation and retention of monitoring activities, conclusions, and corrective actions, as applicable. CARS will also establish a documented pre-execution review and approval control for applicable federally funded agreements to verify the appropriate classification of the relationship and the accuracy and completeness of required federal award information before execution. As part of implementation, CARS will review applicable existing federally funded agreements under the new policy. If an existing relationship is determined to meet the criteria of a subrecipient rather than a contractor, CARS will appropriately classify the agreement, correct applicable federal award information, including the ALN, as necessary, and apply and document the required subrecipient monitoring procedures prospectively. Responsible Party: Ranelle Bensch, Director of Finance & Compliance Target Implementation Date: March 2027
Management Response Management concurs with this finding, in part. CARS acknowledges that its SEFA preparation process did not include a formally documented procedure for evaluating and documenting subrecipient-versus-contractor determinations or a documented supervisory review control over the prep...
Management Response Management concurs with this finding, in part. CARS acknowledges that its SEFA preparation process did not include a formally documented procedure for evaluating and documenting subrecipient-versus-contractor determinations or a documented supervisory review control over the preparation of the SEFA. However, during the period under audit, management did review agreements at the time of award and considered the nature of each relationship in determining the appropriate classification based on its understanding of the subrecipient criteria established under Uniform Guidance, 2 CFR § 200.331. Accordingly, while CARS acknowledges that its evaluation and review processes were not formally documented, management believes it is important to distinguish the absence of formal documentation and controls from an absence of management review or consideration of the appropriate classification. CARS’ classification approach had also been discussed with the auditors during the annual Single Audits conducted for Years 1 through 4 of the current federal award. No exceptions related to the classification of these entities were identified during those prior audits. CARS recognizes, however, that responsibility for determining the appropriate classification of subrecipients and contractors and for ensuring accurate SEFA reporting rests with management. Based on additional training regarding subaward management under 2 CFR Part 200, together with the matters identified and discussed during the current audit, CARS agrees that establishing a formal written policy and documented review process will strengthen its internal controls and help ensure consistent application of the Uniform Guidance requirements. Upon identification of the classification issue during the current audit, CARS evaluated the affected entities and revised the SEFA prior to issuance of the audit report to properly reflect amounts provided to subrecipients. The revision did not change total federal expenditures reported on the SEFA. Corrective Action CARS will develop and implement written procedures for subrecipient-versus-contractor determinations and will establish formal SEFA preparation and review procedures, including documented supervisory review prior to issuance. Responsible Party: Ranelle Bensch, Director of Finance & Compliance Target Implementation Date: January 2027
Finding Reference This corrective action plan relates to audit finding 2025 001 as reported in the schedule of findings and questioned costs. Contact Persons Dwayne Shaw, Executive Director, and Michelle Wright, Office Manager , are responsible for implementing and monitoring the corrective actions,...
Finding Reference This corrective action plan relates to audit finding 2025 001 as reported in the schedule of findings and questioned costs. Contact Persons Dwayne Shaw, Executive Director, and Michelle Wright, Office Manager , are responsible for implementing and monitoring the corrective actions, maintaining related policies and procedures, and reporting status to those charged with governance. (207) 483-4336 Management’s Response / Concurrence Management agrees with the finding. The organization acknowledges that it does not currently have written policies and procedures addressing certain required Uniform Guidance compliance areas. Planned Corrective Action Management will develop, approve, and implement written policies and procedures designed to comply with applicable Uniform Guidance requirements, including policies over allowable costs/cost principles, cash management, and procurement, including suspension and debarment. Management will also communicate the new policies to relevant personnel and provide training as needed to support consistent implementation. Anticipated Completion Dates Management will finalize and implement the corrective action plan on or before September 30, 2026.
Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: University of Pittsburgh; Not Applicable; Not Applicable Pass-Through Entity Number: AWD00009525; Not Applicable; Not Applicable Awards: Assistance Listing 93.145 – HIV Related Training...
Federal Program Information Federal Agencies: Department of Health and Human Services (“HHS”) Pass-Through Entity: University of Pittsburgh; Not Applicable; Not Applicable Pass-Through Entity Number: AWD00009525; Not Applicable; Not Applicable Awards: Assistance Listing 93.145 – HIV Related Training and Technical Assistance; Assistance Listing 93.153 - Coordinated Services and Access to Research for Women, Infants, Children and Youth; Assistance Listing 93.939 – HIV Prevention Activities Non-Governmental Organization Based Award Periods: July 1, 2024 to June 30, 2025; July 1, 2025 to June 30, 2026; August 1, 2024 to July 31, 2025; August 1, 2025 to July 31, 2026; April 1, 2024 to March 31, 2025; July 1, 2024 to June 30, 2025; April 1, 2025 to March 31, 2026; July 1, 2025 to June 30, 2026 Type of Finding: Significant Deficiency in Internal Control Over Compliance Description: Internal control deficiency over Procurement and Suspension and Debarment Recommendation: Management should enhance its suspension and debarment control to ensure all vendors associated with federally funded programs are included in the screening population. Management should maintain evidence of its review of the completeness and accuracy of the vendor population provided to the third-party service provider and the results of the screening process. View of responsible officials: Management concurs with the finding and has implemented procedures to ensure completeness and accuracy of the approved vendor list for monthly suspension and debarment screening. Name(s) of the Contact Person(s) Responsible for Corrective Action: Lindsay Mccrory Eric Lyda Corrective Action Planned: Inova will enhance controls over the completeness, accuracy, and documentation of the vendor population subject to monthly suspension and debarment screening. Corrective actions include implementing procedures to validate the completeness of the vendor population, reconciling the population submitted for screening to source records, standardizing report generation to reduce reliance on manual processes, and strengthening documentation of control execution to ensure continued compliance with Uniform Guidance requirements. Inova will also formalize control responsibilities and provide training to support consistent execution of the screening process. Planned Completion Date for Corrective Action Planned: September 30, 2026 2026
The federal reporting system still poses problems getting information uploaded. The County will continue to seek training videos and emailed information to better understand the reporting system. For the last reporting cycle we had to reach out with emails and phone calls because the system wouldn’t...
The federal reporting system still poses problems getting information uploaded. The County will continue to seek training videos and emailed information to better understand the reporting system. For the last reporting cycle we had to reach out with emails and phone calls because the system wouldn’t allow reporting which had to be fixed on the federal reporting side before we could complete our reporting.
ignificant Deficiency in Internal Control over Compliance Description of Finding The Town was not able to provide written documentation that suspension and debarment procedures were performed prior to awarding a contract to a vendor involving federal awards for one of three transactions tested. Stat...
ignificant Deficiency in Internal Control over Compliance Description of Finding The Town was not able to provide written documentation that suspension and debarment procedures were performed prior to awarding a contract to a vendor involving federal awards for one of three transactions tested. Statement of Concurrence or Nonconcurrence Management concurs with the finding. Corrective Action Management will update the Town’s internal control policies to ensure that written documentation of suspension and debarment procedures performed is retained before awarding contracts to vendors involving federal awards. Name of Contact Person Caitlyn Choiniere, Finance Director Projected Completion Date 7/1/2026
2025-003 – WRITTEN POLICIES AND PROCEDURES REQUIRED BY THE UNIFORM GUIDANCE (REPEAT) Corrective Action Plan: Management developed written policies and procedures related to federal awards, which were formally adopted by the City Council at the June 18, 2025 Council meeting. Responsible Party(ies): •...
2025-003 – WRITTEN POLICIES AND PROCEDURES REQUIRED BY THE UNIFORM GUIDANCE (REPEAT) Corrective Action Plan: Management developed written policies and procedures related to federal awards, which were formally adopted by the City Council at the June 18, 2025 Council meeting. Responsible Party(ies): • City Council • City Manager • Deputy City Manager / Finance Director Anticipated Completion Date: June 18, 2025.
Internal control deficiency and noncompliance over procurement. Banner has a policy for the procurement of federally funded goods and services that fully complies with the Uniform Guidance standards, prescribed by the Office of Management and Budget, for managing federal awards. This policy was not ...
Internal control deficiency and noncompliance over procurement. Banner has a policy for the procurement of federally funded goods and services that fully complies with the Uniform Guidance standards, prescribed by the Office of Management and Budget, for managing federal awards. This policy was not followed when evaluating and selecting the general contractor for a Wyoming Medical Center construction project that was being partially funded (~25%) with federal funds. Specifically, proposals were not obtained through public advertising. The costs charged to the program were for allowable activities; however, the procurement was not conducted in accordance with federal procurement requirements. To ensure all protocols and controls are followed in compliance with Uniform Guidance standards, Banner will implement a process to notify all appropriate parties when federal funds are received or granted and provide education to key constituents on Uniform Guidance standards. Additionally, formal documentation supporting the rationale for selecting general contractors will be enhanced. Since this project is ongoing into 2026, this will be a duplicate finding on the 2026 Uniform Guidance audit. Contact: Elizabeth Montemayor, Chief Financial Officer – Banner Research Expected completion date: December 31, 2026
Finding 1229581 (2025-004)
Material Weakness 2025
Timely communication and coordination regarding Federal award activity and applicable compliance requirements to ensure required reporting is completed within applicable timeframe.
Timely communication and coordination regarding Federal award activity and applicable compliance requirements to ensure required reporting is completed within applicable timeframe.
Finding 1229580 (2025-003)
Material Weakness 2025
The Sheriff will discuss with the administrative staff to develop policies to ensure timely and accurate remittances to the Treasurer’s office.
The Sheriff will discuss with the administrative staff to develop policies to ensure timely and accurate remittances to the Treasurer’s office.
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