Corrective Action Plans

Finding 485647 (2023-005)

Material Weakness 2023

Cardiovascular Center Corporation of Puerto Rico and the Caribbean

PR

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Finding No. 2023-005 – Biweekly and quarterly reporting and finding No. 2023–006 – Audit requirements for auditees – report submission Conditions 1) For finding No. 2023-005: During our audit procedures regarding the compliance requirement related to reporting, we noted that, during the fiscal year ...

Finding No. 2023-005 – Biweekly and quarterly reporting and finding No. 2023–006 – Audit requirements for auditees – report submission Conditions 1) For finding No. 2023-005: During our audit procedures regarding the compliance requirement related to reporting, we noted that, during the fiscal year ended June 30, 2023: • For ALN 21.027 - Coronavirus State and Local Fiscal Recovery Fund - ARP Act ✓ The Corporation was not able to provide audit evidence for the submission of four (4) biweekly reports, out of a sample of eight (8) reporting dates. ✓ One (1) monthly report, out of a sample of eight (8) reporting dates, was submitted later than its due date as follows: • For ALN 97.036 - Disaster Grants – Public Assistance (Presidentially Declared Disasters) Program The Corporation was required to submit four (4) quarterly reports during the year ended June 30, 2023. The Corporation provided incomplete reports for quarters 3 and 4. The report of quarter 3 does not include the correct amounts already expensed by the Corporation, while the report of quarter 4 was not completed and signed by the preparer. 2) For finding No. 2023-006: The data collection form and the reporting package for the year ended on June 30, 2023 was not submitted to the Federal Audit Clearinghouse within the timeframe prescribed by the Uniform Guidance. Corporation response The Corporation agrees with the findings Corrective Action Plan Upon receipt of the audit findings, we initiated an immediate review of our monthly reporting procedures. We have identified specific areas that require attention and are implementing immediate corrective actions to address the identified deficiencies. • Policies and Procedures Review - Simultaneously, we are reviewing our existing policies and procedures related to monthly reporting. This includes a reassessing reporting timeline, data validation processes, and the overall framework for ensuring accuracy and completeness in our monthly reports. • Staff Training and Development - Recognizing the critical role of our personnel in the reporting process, we are providing additional training to the individuals involved. This training will emphasize the importance of adherence to reporting guidelines, accurate data entry, and the significance of meeting established deadlines. • Communication Protocol Enhancement - We recognize the importance of effective communication regarding reporting processes. To address this, we are enhancing us communication protocols to ensure that all relevant stakeholders are informed of reporting requirements, timelines, and any changes to procedures. • Finance Team - The Corporation has changed its management staff structure in the finance and budget department, with the mission of improving the monitoring process and compliance with federal and local regulations. A new Finance and Budget Director and the Associate Director of Finance and Budget have been appointed. Name of the contact person responsible for corrective action plan Jesús A. Rodríguez Avilés – Financial Planning and Analysis Director Anticipated Completion date June 30, 2025

View Audit 318454

Finding 485644 (2023-003)

Material Weakness 2023

Oconto County, Wisconsin

WI

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

Suspension & Debarment The county will review and update our procurement policies for the entire county to include suspension and debarment requirements to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Planned completion date for corrective action: December 31, 20...

Suspension & Debarment The county will review and update our procurement policies for the entire county to include suspension and debarment requirements to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants. Planned completion date for corrective action: December 31, 2024

View Audit 318441

Finding 485643 (2023-002)

Material Weakness 2023

Oconto County, Wisconsin

WI

Questioned Costs Subrecipient Monitoring § 200.332

Subrecipient Monitoring The county will review and update our internal processes and procedures and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the subrecipient monitoring policies established by the Oconto County Board are being ...

Subrecipient Monitoring The county will review and update our internal processes and procedures and provide additional training and education to all departments to ensure the minimum requirements of 2 CFR 200 and the subrecipient monitoring policies established by the Oconto County Board are being followed. Planned completion date for corrective action: December 31, 2024

View Audit 318441 Questioned Costs: $1

Finding 485634 (2023-002)

Significant Deficiency 2023

Clark County

IL

Subrecipient Monitoring

The County agrees that MVECA and Airvac should have been classified as contractors and has made numerous attempts to correct these classifications through the Treasury website. However, the ARPA reporting module does not permit the change of recipient classification once it has been entered. When ne...

The County agrees that MVECA and Airvac should have been classified as contractors and has made numerous attempts to correct these classifications through the Treasury website. However, the ARPA reporting module does not permit the change of recipient classification once it has been entered. When new reports are due, the portion of the report where recipient classification is located becomes locked and the reporter cannot change the classification. At this time, the issue cannot be corrected in the report. An error occurred in the reporting of the ARPA funds in the reporting module. ARPA interest income in the amount of $194,260 was used towards the payment of the Mental Health and Drug Treatment Facility. Those funds should not have been reported due to the fact that interest income expenses are not an item reported in the ARPA report. Corrective action is being taken in Q3 of 2024. Contact Individual: Jennifer Hutchinson, County Administrator Contact Number: 937-521-2055

View Audit 318409

Finding 485630 (2023-004)

Significant Deficiency 2023

City of Huntington Park

CA

Subrecipient Monitoring § 200.332 § 200.521

The City will establish an official written policy for subrecipient monitoring that is in line with the requirements of the Uniform Guidance.

View Audit 318408

Finding 485618 (2023-006)

None 2023

Dolton West School District 148

IL

Reporting Subrecipient Monitoring

Condition: The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE for seven reports. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of...

Condition: The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE for seven reports. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: June 30, 2024. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.

View Audit 318405

Finding 485617 (2023-007)

None 2023

Dolton West School District 148

IL

Reporting Subrecipient Monitoring

Condition: The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE for eleven reports. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date o...

Condition: The District did not comply with the requirements of filing quarterly and final reports by the due dates set by ISBE for eleven reports. Plan: Management will review its policies and procedures and implement changes to strengthen internal control over federal reporting. Anticipated Date of Completion: June 30, 2024. Name of Contact Person: Dr. Kevin J. Nohelty, Superintendent. Management Response: Management will work together with staff to verify that reporting deadlines are met moving forward.

View Audit 318405

Finding 485588 (2023-002)

Material Weakness 2023

Simpson Midtown INC

PA

Eligibility Subrecipient Monitoring HUD Housing Programs

Corrective Action Planned: Management has replaced the property manager with a more experienced property manager who has a full and complete understanding of the HUD regulations and processes. Management has developed policies and procedures to establish a timely database of all recertification dat...

Corrective Action Planned: Management has replaced the property manager with a more experienced property manager who has a full and complete understanding of the HUD regulations and processes. Management has developed policies and procedures to establish a timely database of all recertification dates. Name(s) of Contact Person(s) Responsible for Corrective Action: Marcia Drake, Property Manager, Ashley Kratzer, Corporate Controller

View Audit 318360

Finding 485564 (2023-004)

Significant Deficiency 2023

Southern Fulton School District

PA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

The finding from Section III – Activities Allowed or Unallowed Finding 2023-004 – General Ledger System Condition: Federal expenditures should be posted to the federal funding source accounts in the general ledger as they are incurred, and significant adjusting entries reclassing expenditures shoul...

The finding from Section III – Activities Allowed or Unallowed Finding 2023-004 – General Ledger System Condition: Federal expenditures should be posted to the federal funding source accounts in the general ledger as they are incurred, and significant adjusting entries reclassing expenditures should be at a minimum. This will allow for the proper reporting of the eligible amounts to claim for reimbursement. Views of Responsible Officials and Planned Corrective Actions: The District Business Manager is aware and responsible for appropriate reporting of expenditures related to federal funding. During the course of the 2022-2023 school year, appropriate processes and classifying of expenditures were not completed as they should have been, resulting in numerous after-closing journal entries to correct the issues. Moving forward, with the assistance and guidance of federal and state guidelines, all expenditures will be budgeted for within the grant application and reconciled with the district’s general ledger, to ensure proper allocations. Additionally, reporting that is to be done quarterly will also verify the placement of expenditures accurately. The person responsible for the corrective action plan will be the Business Manager and the anticipated completion date will be June 30, 2024, but no later than June 30, 2025 due to the delays that occurred in the completion of the audit ending June 30, 2023.

View Audit 318339

Finding 485562 (2023-002)

Significant Deficiency 2023

Southern Fulton School District

PA

Subrecipient Monitoring Cash Management Reporting

The finding from Section III – Federal Awards Findings and Questioned Costs Finding 2023-002 – Cash Management and Reporting Condition: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. The...

The finding from Section III – Federal Awards Findings and Questioned Costs Finding 2023-002 – Cash Management and Reporting Condition: The Pennsylvania Department of Revenue requires Reconciliation of Cash on Hand Quarterly Reports for any program for which they are receiving monthly payments. These quarterly reports are due the 10th working days of January, April, July, and October. The Pennsylvania Department of Education requires annual final expenditure reports to be filed documenting the financial transactions of each grant. The final reports are due within 30 days after the funds are expended but no later than 30 days after the ending of the date of the project. Districts are required to have appropriate controls over the accuracy of preparation and timely filing of final expenditure reports. Views of Responsible Officials and Planned Corrective Actions: The District Business Manager will work directly with the District Superintendent and the Federal Programs Coordinator, as well as any additional parties involved in the process of the Federal Grants filing the expenditure reports quarterly and filing of the final expenditure reports. Procedures will include creating reminders on the Business Manager’s calendars that include the due dates each quarter, reporting the appropriate expenditures in the accounting software, and creating a separate report listing the expenditures for that quarter and the remaining funds for future quarters. Account numbers that accurately reflect and represent the expenditures for related funding sources will be created and reviewed for necessary changes as the projects progress.

View Audit 318339

Finding 485506 (2023-001)

Significant Deficiency 2023

Neighborhood Health Association of Toledo, Inc.

OH

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs

Special Tests and Provisions 93.224/93.527 - Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Recommendation: We recommend that management ...

Special Tests and Provisions 93.224/93.527 - Consolidated Health Centers (Community Health Centers, Migrant Health Centers, Health Care for the Homeless, Public Housing Primary Care, and School Based Health Centers); (HHS Community Health Center Program) Recommendation: We recommend that management continue to work and educate front desk and intake staff on the importance of the required patient application documentation so that the required support is filed before applying a sliding fee discount to a patient account. In addition, continue with the system of monitoring that was established during fiscal year 2023 to review random samples of applications and sliding fees applied. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: We agreed with the above comment, and we are working with our intake and finance staff to ensure all documentation is maintained on file and scanned into the EMR system to maintain the required supporting documentation. During 2023 we have implemented a system of monitoring sliding fees applied to patient accounts. Name of the contact person responsible for corrective action: Doni Miller Planned completion date for corrective action plan: Fiscal year 2024

View Audit 318279

Finding 485484 (2023-021)

Material Weakness 2023

Monroe County Board of Education

WV

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management

Corrective Action: Monroe County Schools will take the following corrective actions to improve the activities allowed/unallowed – ESSER: • The Board will reimburse the ESSER program for the noncompliant expenditure and ensure future expenditures meet the federal requirements for ESSER program fundin...

Corrective Action: Monroe County Schools will take the following corrective actions to improve the activities allowed/unallowed – ESSER: • The Board will reimburse the ESSER program for the noncompliant expenditure and ensure future expenditures meet the federal requirements for ESSER program funding. • The Federal Programs Director and the new CSBO will be required to review 2 CFR 200 to develop an understanding of applicable expenditures incurred with federal funds. • The Federal Programs Director will be responsible for ensuring all federal expenses are allowable under the grant according to CFR 200. • The new CSBO will review federal expenses to ensure they are allowable under the grant according to CFR 200. Effective Date: September 30, 2024 Person(s) Responsible: CSBO and Director of Federal Programs, Monroe County Schools

View Audit 318240

Finding 485475 (2023-001)

Material Weakness 2023

City of Lacey

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2023-001 Finding caption: The City lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Kristy Wolf, Financial Services Manager. 420 College Street SE, Lacey, WA 98503...

Finding ref number: 2023-001 Finding caption: The City lacked adequate internal controls for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Kristy Wolf, Financial Services Manager. 420 College Street SE, Lacey, WA 98503-1238 (360) 438-2668 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). City of Lacey’s Response: The City of Lacey acknowledges the auditor's finding regarding the need for enhanced internal controls to verify that subrecipients are not suspended or debarred before entering into agreements involving federal funds. The City has overall strong internal controls surrounding the utilization of grant dollars. Specific to the Congressional funds, the City had a number of mitigating controls in place to ensure the appropriate use of the funds. The City, Saint Martin’s University, and Thurston EDC are strong partners in making sure the Lacey MakerSpace reaches its full potential and continues to enhance the community. City leadership and the stated partners were thrilled to receive $1 million dollars to go towards the much-needed expansion of the Lacey MakerSpace. After receiving the award, it became clear that moving to a subrecipient model with Saint Martin’s University was the appropriate course of action. The City received approval from the Small Business Administration (granting authority) to proceed with this action. The City then drafted and executed an interlocal agreement with Saint Martin’s University. The interlocal agreement clearly stated that, as a subrecipient, Saint Martin’s University would adhere to all federal requirements. The City also completed a subrecipient risk assessment with Saint Martin’s University prior to finalizing the subrecipient model and were deemed to be a low risk subrecipient. Saint Martin’s completed a suspension and debarment check on the project’s contractor who ultimately received the funds. The City will address its controls and oversight over grant contracts with subrecipient agreements to ensure proper adherence to suspension and debarment requirements. This will be accomplished by including a contract clause that explicitly requires all subrecipients to certify that they are not suspended, debarred, or otherwise excluded from federal programs. This clause will be applied to all relevant agreements and contracts moving forward. The City has also initiated communication with relevant City staff to ensure that they are fully aware of federal requirements regarding suspension and debarment. The City will implement a periodic review process to ensure continued compliance with federal requirements. This includes regular audits of contracts and subawards to confirm that all necessary documentation is in place and that the City’s internal controls are functioning effectively. The City of Lacey is committed to full compliance with all federal regulations and takes the auditor’s finding seriously. We believe that the steps we have taken and the controls we have put in place for future use will effectively address the issue and prevent further occurrences. We appreciate the auditor’s recommendations and will continue to monitor and enhance our internal controls to ensure the integrity of our operations and the proper use of federal funds. Anticipated date to complete the corrective action: 8/16/2024

View Audit 318219

Finding 485474 (2023-001)

Material Weakness 2023

Saint Michael's Clinics, Inc.

NJ

Internal Control / Segregation of Duties Eligibility Subrecipient Monitoring

Clinic management team acknowledges that from the audit selection made of 60 patients, 22 were not recertified during the six-month period and the supporting documentation was not always obtained or retained related to income verification, household size, residency, and health insurance status. A de...

Clinic management team acknowledges that from the audit selection made of 60 patients, 22 were not recertified during the six-month period and the supporting documentation was not always obtained or retained related to income verification, household size, residency, and health insurance status. A detail plan of correction has been developed and is listed below. With the exception of the last bullet below, these corrections were implemented in the fourth quarter of 2023 as a result of the 2022 finding. The last bullet was implemented in the first quarter of 2024. • Revamped the job titles and description to encourage better return on recruitment efforts of medical case manager positions. • A position of Certified Case Counselor (CCC) – Supervisor, was created and filled to provide direct oversight over the medical case managers that perform the bi-annual certifications, and other daily tasks. • Added a quality management process, where Clinic clients are called ahead of time to notify them of their recertification requirements. • Data Analyst(s) generate a report of patients due for recertification 60 days in advance of the due date. The CCC-Supervisor is directly accountable to review the progress of the re-certification and the process is monitored by the Assistant Manager of the clinic. The CCC-Supervisor and Assistant Manager monitor retention of all patient required supporting documentation in the patients’ medical records. • Patients that do not provide the required supporting documentation showing compliance with program eligibility as outlined in the grant agreement or are otherwise not able to be recertified six months after certification will be classified as inactive in the database used to submit invoices to the Ryan White HIV/AIDS Program. Contact Person: Rajesh Mehta, Chief Financial Officer, Peter Ho Memorial Clinic Expected Completion Date: September 30, 2024

View Audit 318209

Finding 485470 (2023-001)

Significant Deficiency 2023

Golden Years Senior Apartments, Inc. 122-Ee-078-Wah-Np

CA

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Statement of Condition #2023-001 (CFDA 14.157): During the year ended December 31, 2023, the Corporation made a payment on the CRA loan of $1,157 without HUD approval. Recommendation: Management should submit a residual receipts request to HUD for the withdrawal in the amount of $1,157. In the futu...

Statement of Condition #2023-001 (CFDA 14.157): During the year ended December 31, 2023, the Corporation made a payment on the CRA loan of $1,157 without HUD approval. Recommendation: Management should submit a residual receipts request to HUD for the withdrawal in the amount of $1,157. In the future, management should obtain approval from HUD before making any payments on the CRA loan. Action(s) taken or planned on the finding: Management concurs with the finding and will submit a residual receipts withdrawal request in the amount of $1,157 during the year ended December 31, 2024.

View Audit 318198 Questioned Costs: $1

Finding 485456 (2023-001)

Material Weakness 2023

Digital Harbor Foundation INC

MD

Subrecipient Monitoring § 200.331

Auditor’s Recommendation: We recommend that management require all sub-awardees to have a subaward agreement or memorandum of understanding (MOU). Action Taken: • As a First Year Single Auditee, the management team will ensure that senior leadership team, finance and accounting team, as well as p...

Auditor’s Recommendation: We recommend that management require all sub-awardees to have a subaward agreement or memorandum of understanding (MOU). Action Taken: • As a First Year Single Auditee, the management team will ensure that senior leadership team, finance and accounting team, as well as program manager/directors for federal awards receive some form of training and certify receipt of this training within six-months of these findings. • As a First Year Single Auditee, the management team will ensure that specific policies for sub-awards and sub-recipients will better ensure its internal practices are in alignment with Uniform Guidance standards for federal awards. • As a First Year Single Auditee, the management team will have an independent audit firm review these specific policies to ensure they are in alignment and conformance with Uniform Guidance standards.

View Audit 318182

Finding 485425 (2023-001)

Material Weakness 2023

County of Butler

PA

Questioned Costs Subrecipient Monitoring § 200.332

Corrective Action Plan - Finding 2023-001 Subrecipient Monitoring Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - ALN #21.027.The County will implement procedures to formally document and complete a risk assessment of subrecipients and for the development of mon...

Corrective Action Plan - Finding 2023-001 Subrecipient Monitoring Department of Treasury COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - ALN #21.027.The County will implement procedures to formally document and complete a risk assessment of subrecipients and for the development of monitoring procedures to address the risks. This corrective action plan calls for the County to annually prepare a risk assessment for each subrecipient and provider documented monitoring to address the risk. The County Budget Director will collect the audits for the respective subrecipient by June 30th. For those that have not completed their audit by June 30th, a follow up reminder will be sent each month inquiring as to the status for date of completion until which time the audit is received.The County Budget Director has developed a tracking spreadsheet to include receipt date of audit, review date of audit, risk assessment level and comments regarding audit. Any subrecipient receiving over $500,000 will automatically be considered a higher risk. In addition, any subrecipient that has findings or comments within their audit will also be considered a higher risk Currently, all expenditure requests must include copies of invoices and canceled checks to ensure that payment has been made prior to reimbursement. Quarterly reports are submitted and reviewed to update the County on progress of the projects. For those subrecipients that are documented as higher risk, additional monitoring procedures will occur. These procedures may include meeting with the subrecipient to discuss other funding sources to fund the project or follow up to any corrective action plans put in place to address the audit findings or comments. Anticipated Completion Date: September 30, 2024.Person Responsible for Corrective Action: Ann Brown Budget Director County of Butler PO Box 1208 Butler, PA 16003-1208 724-284-5105 abrown@co.butler.pa.us

View Audit 318160 Questioned Costs: $1

Finding 485404 (2023-009)

Significant Deficiency 2023

The City of Hoover, Alabama

AL

Procurement, Suspension & Debarment Subrecipient Monitoring

Management has agreed with this deficiency and will take additional steps to ensure processes are in place to prevent payments to vendors who are suspended or debarred vendors. Management anticipates completion by September 30, 2023.

View Audit 318146

Finding 485329 (2023-002)

Significant Deficiency 2023

Scott County

MN

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures for giving timely notice of an individual’s termination or resignation to other departments as well as ensuring departments are reviewing the information provided to granting agenci...

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures for giving timely notice of an individual’s termination or resignation to other departments as well as ensuring departments are reviewing the information provided to granting agencies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will incorporate procedures and controls to ensure timely notice is given to other departments of an individual’s termination and the information provided to granting agencies is reviewed. Name of the contact person responsible for corrective action: Steven Jones (Budget Analyst) Planned completion date for corrective action plan: December 31, 2024.

View Audit 318076

Finding 485328 (2023-001)

Significant Deficiency 2023

Scott County

MN

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Explanation of disagreement with audit finding: There is no ...

Foster Care Title IV-E – Assistance Listing No. 93.658 Recommendation: We recommend the County reviews its procedures to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will incorporate procedures and controls to ensure all casefile reviews are documented and all issues in the casefiles are followed up on and remedied properly. Name of the contact person responsible for corrective action: Steven Jones (Budget Analyst) Planned completion date for corrective action plan: December 31, 2024.

View Audit 318076

Finding 485273 (2023-002)

Significant Deficiency 2023

Town of Boxford

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Select Board and School Committee will adopt any required written policies and procedures under Uniform Guidance. Select Board and School Committee will formally adopt written policies and procedures under Uniform Guidance by September 30, 2024

View Audit 318025

Finding 485251 (2023-002)

Significant Deficiency 2023

Lake County, Illinois

IL

Subrecipient Monitoring Reporting

Finding 2023-002 Condition The County did not submit any reports under the Transparency Act as required during the year under audit. Our sample was not statistically valid. Corrective Action Plan Corrective Action Planned: The County will initiate a process to ensure reports will be filed as require...

Finding 2023-002 Condition The County did not submit any reports under the Transparency Act as required during the year under audit. Our sample was not statistically valid. Corrective Action Plan Corrective Action Planned: The County will initiate a process to ensure reports will be filed as required by the Federal Funding Accounting and Transparency Act. In addition, the County will determine if previous reports are to be prepared and submitted. On a prospective basis, the County will review and revise our procedures as necessary to ensure requirements are met of the Federal Funding Accounting and Transparency Act. Name(s) of Contact Person(s) Responsible for Corrective Action: Melissa Gallagher, Chief Financial Officer Anticipated Completion Date: December 31, 2024

View Audit 318016

Finding 485198 (2023-004)

Material Weakness 2023

City of Stockton

CA

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility

City’s Corrective Action Plan: At the time of Emergency Rental Assistance Program (ERAP) implementation, the guidance provided by U.S. Treasury was continuously evolving and the ERAP team was navigating a complex social and economic crisis. Residents became unemployed, had income reductions as direc...

City’s Corrective Action Plan: At the time of Emergency Rental Assistance Program (ERAP) implementation, the guidance provided by U.S. Treasury was continuously evolving and the ERAP team was navigating a complex social and economic crisis. Residents became unemployed, had income reductions as direct result of the pandemic, and/or had limited access to technology to complete application documents. Prior to official guidance recommending the use of an attestation form, some applicants provided written statements that they did not have any income. Furthermore, these applications were accompanied by eviction notices. These households were clearly at risk of experiencing homelessness or housing instability, which constitutes an “eligible household” as defined by 15 USC 9058a (k)(3)(A)(ii). This section of the U.S. Code states that a “household can demonstrate a risk of experiencing homelessness or housing instability” by providing a “past due utility or rent notice or eviction notice.” While the portal used to intake, review, and approve applications shows occasional inconsistencies with income verification boxes not checked off, all of the sampled cases were verified to be under the income threshold, provided an eviction notice, past due rent notice, and/or signed a written statement that they had zero income. Although certain boxes were not checked within the portal, all cases were verified through diligent and compassionate coordination with households requesting support. Furthermore, a risk assessment by the State's Housing & Community Development for the 2021 Program Year evaluated the City's risk profile as Low Risk. All program expenditures were concluded in fiscal year 2022-23. This was one-time funding. There will be some administrative costs related to the grant in fiscal year 2023-24, but no additional funding was received, therefore eligibility requirements will not be direct material in fiscal year 2023-24. Responsible Person: Jordan Peterson (Deputy Director of Redevelopment), Carrie Wright (Director of Economic Development) Expected Implementation Date: July 2023

View Audit 318000

Finding 485193 (2023-006)

Significant Deficiency 2023

City of Stockton

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Special Tests & Provisions

City’s Corrective Action Plan: The City concurs that during the height of the pandemic there were multiple sources of funds that needed to be expended at a rapid pace. The City's subrecipients were overwhelmed with providing services and the City at times did not enter into contracts within the 180 ...

City’s Corrective Action Plan: The City concurs that during the height of the pandemic there were multiple sources of funds that needed to be expended at a rapid pace. The City's subrecipients were overwhelmed with providing services and the City at times did not enter into contracts within the 180 days or pay out on invoices within 30 days. Since this occurrence, the City has implemented policies and procedures to provide award letters and process payments within 30 days or document why the payment cannot be made given the documentation provided. Responsible Person: Carrie Wright (Director of Economic Development), Juan Gonzalez (Housing Manager) Expected Implementation Date: March 2024

View Audit 318000

Finding 485191 (2023-005)

Significant Deficiency 2023

City of Stockton

CA

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting

City’s Corrective Action Plan: This is pandemic-related funding with limited guidance on reporting requirements. However, the City has tracked all expenditures and retained documentation for allowable costs. The City will maintain supporting documentation when a federal or grantor agency allows for ...

City’s Corrective Action Plan: This is pandemic-related funding with limited guidance on reporting requirements. However, the City has tracked all expenditures and retained documentation for allowable costs. The City will maintain supporting documentation when a federal or grantor agency allows for an extension or removes any reporting requirement. The City will centralize reporting requirements to assist in verifying compliance is met. Responsible Person: Carrie Wright (Director of Economic Development), Jennifer Winn (Grants Manager) Expected Implementation Date: September 2024

View Audit 318000

Corrective Action Plans

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