Corrective Action Plans

Finding 501222 (2023-004)

None 2023

State of Alabama

AL

Questioned Costs Subrecipient Monitoring Cash Management

Finding: The Uniform Guidance, 2 CFR Part 200, Appendix XI Compliance Supplement, dated May 2023, stipulates for a cost to be allowable under federal awards certain general criteria must be met, including costs that are adequately documented and necessary and reasonable for the performance of the fe...

Finding: The Uniform Guidance, 2 CFR Part 200, Appendix XI Compliance Supplement, dated May 2023, stipulates for a cost to be allowable under federal awards certain general criteria must be met, including costs that are adequately documented and necessary and reasonable for the performance of the federal award. The Alabama Department of Transportation (the “Department”) passed through a portion of the Formula Grants for Rural Areas and Tribal Transit Program federal award to subrecipients. One of the subrecipients requested and received reimbursement of program expenses. Subsequent to the payments of the invoices, the Department received information alleging that falsified or altered documents related to expenditures submitted by a subrecipient. Upon receipt of these allegations, the Department initiated a review of the supporting documents which had been submitted by the subrecipient. The review consisted of obtaining documents from vendors and comparing those documents to the ones submitted by the subrecipient. The results of this comparison indicated that the amounts owed and the description of goods and services provided columns had been changed. Nine of ten supporting documents for meeting expenses submitted for reimbursement by the subrecipient during the audit period were altered and were not true and accurate. These altered supporting documents totaled $94,123.56. The Alabama Department of Transportation reimbursed the subrecipient based on the altered documents and, therefore, improperly expended Formula Grants for Rural Areas and Tribal Transit Program federal award funds. Recommendation: The Alabama Department of Transportation should take actions to ensure that all reimbursements of expenses are adequately documented, based on true and accurate supporting documentation, and to ensure costs are allowable under the federal award. Response/Views: We agree that there appears to have been falsified supporting documentation submitted by a subrecipient. Corrective Action Planned: Once we were made aware of the allegation, we began a thorough review of the subrecipient’s invoices. Based on the information discovered during our review, we notified the Federal Transit Administration, Alabama Attorney General’s Office, Alabama Ethics Commission, and the Alabama Department of Examiners of Public Accounts. The Office of Inspector General for the U.S. Department of Transportation is currently investigating the case. The subrecipient involved in this matter is no longer associated with our Transit Program. The duties that they performed were either moved to another subrecipient or in-house. We have modified our invoice review process, and the changes have been applied to all subrecipients for the Transit Program. Anticipated Completion Date: We have taken the steps outlined above as of August 28, 2024. Contact Person(s): Jeff Hornsby, Chief Financial Officer

View Audit 323486 Questioned Costs: $1

Finding 501220 (2023-002)

Significant Deficiency 2023

State of Alabama

AL

Subrecipient Monitoring Reporting

Finding: The Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that is codified in 2 CFR Part 170, requires recipients (i.e., direct recipients) of grants or cooperativ...

Finding: The Federal Funding Accountability and Transparency Act (FFATA) (Pub. L. No. 109-282), as amended by Section 6202 of Pub. L. No. 110-252, hereafter referred to as the “Transparency Act” that is codified in 2 CFR Part 170, requires recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System. The Uniform Guidance, 2 CFR Part 200, Appendix XI Compliance Supplement, May 2023, requires the ALSDE to report applicable first-tier subawards and contract information as required in the “Transparency Act.” The ALSDE did not report applicable first-tier subawards and contractors subject to FFATA data for the monitored grants in the FSRS pursuant to Federal Regulations. The ALSDE did not have procedures in place to ensure that applicable first-tier subaward information was reported to the FSRS, resulting in a failure to provide a full disclosure to the public of all entities or organizations receiving federal funds during the fiscal year 2023. Recommendation: The ALSDE should develop, maintain, and implement effective procedures to ensure compliance with the FFATA. Response/Views: The finding reads as if the ALSDE did not report FFATA for the monitored grants. It was explained to us that this was just for 84.425. FFATA was reported for monitored grants with the exception of part of 84.425. There was a discrepancy in whether it should have been reported. Guidance with the United States Department of Education (USDE) indicated that if the Governor awarded GEER funds to a state agency with an agreement, then the state agency is responsible for reporting. If there is no agreement in place, then the responsibility falls to the Governor’s office. The ALSDE takes full responsibility for this finding. Corrective Action Planned: Steps are being taken to ensure all are aware of the ALSDE’s responsibility to treat 84.425 just as all other Federal awards required for FFATA reporting. These awards will be reported as we are currently doing per FSRS and Federal Regulations. Anticipated Completion Date: The ALSDE will have this corrected no later than 10/31/24. Contact Person(s): Lynn Shows, Accounting Director, lshows@alsde.edu, 334-699-4472

View Audit 323486

Finding 501206 (2023-002)

Significant Deficiency 2023

Ufcw Charity Foundation, Inc.

DC

Reporting Subrecipient Monitoring Significant Deficiency § 200.328 § 200.329

Finding 2023-002: Reportable Finding Considered a Significant Deficiency – Reporting Assistance Listing Number: 10.181 Agency: U.S. Department of Agriculture Program: Pandemic Relief Activities: Farm and Food Worker Relief Program (FFWR) Award Number: AM22FFWDC0002-02 Grant Years: 2023 Views of Resp...

Finding 2023-002: Reportable Finding Considered a Significant Deficiency – Reporting Assistance Listing Number: 10.181 Agency: U.S. Department of Agriculture Program: Pandemic Relief Activities: Farm and Food Worker Relief Program (FFWR) Award Number: AM22FFWDC0002-02 Grant Years: 2023 Views of Responsible Officials – We acknowledge the finding regarding the reconciliation of Form SF-425 for the period November 4, 2022, through April 3, 2023. The issue arose because the preparer did not properly reconcile financial records or obtain a secondary review prior to submission. We are committed to maintaining compliance with 2 CFR sections 200.328 and 200.329 and have already taken corrective steps. Corrective Actions – Root Cause Analysis: The deficiency was caused by the preparer’s failure to review and reconcile Form SF-425 with the financial records prior to submission. The preparer submitted the form without verifying the accuracy of the data. Revised Reporting and Review Process: • Action: We have implemented a formal review process where all Forms SF-425 are reconciled with the financial records before submission. This process includes: o The preparer reconciles the financial data with the underlying financial records. o A mandatory review by the Finance Director or another senior finance officer before submission. o Final approval is given by the Program Director and then the President. • Results: This process was successfully implemented for the April 4, 2023, through October 3, 2023, filing, significantly improving accuracy and compliance. • Responsible Person: The Finance Director is responsible for overseeing the reconciliation and review process. • Timeline: The new process is already in place and was followed for the second filing in 2023. Documentation of Review and Approval: • Action: All review and approval process steps are documented through email communications, ensuring that each step—from reconciliation to final approval—is tracked and recorded. • Responsible Person: The Finance Director ensures that email approvals are completed and stored as part of the official documentation. • Timeline: This documentation process is currently in place and was followed for the April 4, 2023, through October 3, 2023, submission. Conclusion: The corrective actions outlined above have been implemented and are already showing positive results, as demonstrated by the successful filing of the April 4, 2023, through October 3, 2023, From SF-425. By ensuring that every Form SF-425 is reconciled and reviewed before submission, we are confident that these measures will prevent future discrepancies. Completion Timeline: The revised review and approval process is fully implemented and has been successfully applied to the April 4, 2023, through October 3, 2023, filing.

View Audit 323477

Finding 501167 (2023-001)

Significant Deficiency 2023

John H. Boner Community Center, INC

IN

Reporting Subrecipient Monitoring

SIGNIFICANT DEFICIENCY 2023-001 US DEPARTMENT OF EDUCATION. Promise Neighborhoods. 84.215N for the year ended December 31, 2023. The Center received an independent contractor invoice in 2023 for services performed in 2022. This resulted in the reporting of $220,695 of the Center's 2022 federal award...

SIGNIFICANT DEFICIENCY 2023-001 US DEPARTMENT OF EDUCATION. Promise Neighborhoods. 84.215N for the year ended December 31, 2023. The Center received an independent contractor invoice in 2023 for services performed in 2022. This resulted in the reporting of $220,695 of the Center's 2022 federal award expenditures in the 2023 Schedule. Recommendation: We recommend that management establish a reconciliation process for all substantial grants to be completed within the first couple of months of the following year to identify potential differences and issues. This should include the inquiry of independent contractors and subrecipients as to unbilled services. Action Taken: We concur with the recommendation. Effective fiscal year 2024, management has established a reconciliation process to track contractor and vendor billings. This will include the inquiry of independent contractors and subrecipients as to unbilled services at fiscal year-end. If the U.S. Department of Education has questions regarding this plan, please call James Taylor 317 808-2300.

View Audit 323425

Finding 501155 (2023-002)

Significant Deficiency 2023

Heal the Hero Foundation

AZ

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.327

Management will create a formal, written procurement policy. Management will also review the noncompetitive procurement procedures and will document how and why our vendor(s) meets these requirements, if applicable.

View Audit 323403

Finding 501135 (2023-002)

Significant Deficiency 2023

Georgia Alliance of Boys & Girls Clubs, Inc.

GA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.305

Individuals Responsible for Corrective Action Plan: Kristine Steinmann, Alliance Director Shelby Mahoney, State Alliances Accounting Manager Corrective Action: The Alliance will enhance its procedures and internal controls around cash management to ensure that time between receipt of federal fun...

Individuals Responsible for Corrective Action Plan: Kristine Steinmann, Alliance Director Shelby Mahoney, State Alliances Accounting Manager Corrective Action: The Alliance will enhance its procedures and internal controls around cash management to ensure that time between receipt of federal funds and payment to its local clubs is minimized. The Alliance will also request notification of funding from the agency. Anticipated Completion Date: December 31, 2024

View Audit 323392

Finding 501133 (2023-001)

None 2023

Texas Alliance of Boys & Girls Clubs, Inc.

TX

Reporting Subrecipient Monitoring § 200.414 § 200.502

Individuals Responsible for Corrective Action Plan: BGCA Fiscal Team-Shelby Mahoney; Alliance Director Corrective Action: Review all federal grant contracts to determine if any separate funding sources should be listed for total funds received. Anticipated Completion Date: December 31, 2024

View Audit 323391

Finding 501132 (2023-001)

Significant Deficiency 2023

Boys and Girls Clubs in Colorado, Inc.

GA

Subrecipient Monitoring § 200.332

Individual Responsible for Corrective Action Plan: Ashley Prow, Alliance Director Corrective Action: The Alliance performed site visits as required, and will maintain documentation of these going forward to provide verification that these occurred in accordance with the contract and our document...

Individual Responsible for Corrective Action Plan: Ashley Prow, Alliance Director Corrective Action: The Alliance performed site visits as required, and will maintain documentation of these going forward to provide verification that these occurred in accordance with the contract and our documented subrecipient monitoring procedures. Anticipated Completion Date: December 31, 2024

View Audit 323390

Finding 501131 (2023-001)

Significant Deficiency 2023

Indiana Alliance of Boys and Girls Clubs, Inc.

GA

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.305

Individual Responsible for Corrective Action Plan: Lana Taylor, Alliance Director Shelby Mahoney, State Alliances Accounting Manager State Corrective Action: The Alliance will enhance its procedures and internal controls around cash management to ensure that time between receipt of federal funds...

Individual Responsible for Corrective Action Plan: Lana Taylor, Alliance Director Shelby Mahoney, State Alliances Accounting Manager State Corrective Action: The Alliance will enhance its procedures and internal controls around cash management to ensure that time between receipt of federal funds and payment to its local clubs is minimized. The Alliance will also request notification of funding from the agency. Anticipated Completion Date: December 31, 2024

View Audit 323389

Finding 501119 (2023-002)

Material Weakness 2023

The Carle Foundation

IL

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303 § 200.332

Corrective Action Plan: Trillium Place will update the sub-award contracts to include all required elements, including: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Contact Person(s): Ann C...

Corrective Action Plan: Trillium Place will update the sub-award contracts to include all required elements, including: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Contact Person(s): Ann Campen Anticipated Completion Date: 12/31/2024

View Audit 323383

Finding 501096 (2023-001)

Material Weakness 2023

Triple Bottom Line Foundation

CO

Subrecipient Monitoring Reporting

The 2023 SEFA was based on the 2022 audited SEFA schedule, updating it for the new 2023 federal programs. Since most of ICAST contracts are with state government agencies, in some instances it is not clear or apparent to ICAST staff, whether the source of funds are Federal for those state contracts...

The 2023 SEFA was based on the 2022 audited SEFA schedule, updating it for the new 2023 federal programs. Since most of ICAST contracts are with state government agencies, in some instances it is not clear or apparent to ICAST staff, whether the source of funds are Federal for those state contracts. The initial SEFA submission was identified as preliminary and was subsequently updated as ICAST learned more about the source of the state funds. The accrual figures were subject to ongoing deliberations with the state and federal agencies that led to delays in addressing the final reconciliation. ICAST is experiencing delays as long as six months for approval and payment of its invoices by both the state and the federal agencies monitoring its program funds. ICAST has addressed this finding in the following manner: 1. Management and staff will be taking refresher training on the Uniform Guidance requirements. New staff will be trained on it. 2. ICAST has begun to clarify upfront the source of funds for all contracts with its funders. Also ICAST is consolidating all contracts into a central location, with clear indication of the source of funds, to ensure complete and accurate records are available to management and staff when assessing programs for inclusion/exclusion on the SEFA. 3. ICAST continues to hire and train additional financial/accounting staff and management to ensure financial records are reviewed every month and items are followed up and resolved in a timely manner. 4. ICAST is reorganizing its accounting recordkeeping process, to ensure program information is more transparent and readily available.

View Audit 323382

Finding 501076 (2023-006)

Significant Deficiency 2023

Jvs Socal

CA

Eligibility Subrecipient Monitoring

We have created an eligibility checklist for the WIOA programs that lists all required documentation. Additional training will be provided to the WIOA intake team on required documentation. No later than November 1, 2024, AJCC Associate Directors will implement period spot checks to ensure all neces...

We have created an eligibility checklist for the WIOA programs that lists all required documentation. Additional training will be provided to the WIOA intake team on required documentation. No later than November 1, 2024, AJCC Associate Directors will implement period spot checks to ensure all necessary documents for eligibility are completed.

View Audit 323354

Finding 501075 (2023-005)

Significant Deficiency 2023

Jvs Socal

CA

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

JVS will implement a process before December 31, 2024, whereby each payroll period, a JVS Payroll department employee will 1) independently review all employee timesheet allocations, as approved by their supervisor and 2) make necessary modifications to the budgeted allocations reflected in its payr...

JVS will implement a process before December 31, 2024, whereby each payroll period, a JVS Payroll department employee will 1) independently review all employee timesheet allocations, as approved by their supervisor and 2) make necessary modifications to the budgeted allocations reflected in its payroll ERP module (Paylocity). In this manner, program labor distributions and resulting cost allocations will align to actual time incurred and permit accurate reporting for billing purposes. JVS is also researching a technological solution that will reduce the amount of time required from the above laborious effort.

View Audit 323354

Finding 501070 (2023-001)

Material Weakness 2023

Young Women's Christian Association of Metropoliatan St. Louis

MO

Reporting Subrecipient Monitoring Material Weakness

Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with...

Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with the Department of Health and Human Services and other regulatory bodies to ensure the proper completion of subaward reports in FSRS, the SF429 and other required reporting. The above noted issue was discovered during the course of the 2022 audit, but after the reporting deadlines for the 2023 year. Upon discovery of the requirement, Management took the above noted steps to become compliant with both 2022 and 2023. The finding repeated in 2023 solely due to the timing of the discover of the issue. Effective to date, all FSRS and applicable SF429 reports have been filed correctly and timely.

View Audit 323329

Finding 501044 (2023-001)

Significant Deficiency 2023

Community Medical Wellness Centers USA

CA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions The Organization have experienced turnover of staff in the Organization as well as changes in leadership. In response to this finding the Organization has put together a corrective action plan that targets training of staff and puts into ...

Views of Responsible Officials and Planned Corrective Actions The Organization have experienced turnover of staff in the Organization as well as changes in leadership. In response to this finding the Organization has put together a corrective action plan that targets training of staff and puts into place a monthly audit for ensuring compliance to the sliding fee discount policy. Responsible persons: Nichole Henderson, Quality Improvement Quality Assurance Director and Demetria Johnson, Billing Manager will be in charge of implementing the corrective action. Expected Implementation Date: Started August 1, 2024.

View Audit 323284 Questioned Costs: $1

Finding 501028 (2023-001)

Significant Deficiency 2023

Chicago Park District

IL

Special Tests & Provisions Subrecipient Monitoring § 200.303

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

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

View Audit 323269

Finding 501012 (2023-003)

Material Weakness 2023

Umpqua Public Transportation District

OR

Subrecipient Monitoring Cash Management Material Weakness § 200.302

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

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

View Audit 323248

Finding 501005 (2023-002)

Significant Deficiency 2023

Umpqua Public Transportation District

OR

Cash Management Subrecipient Monitoring Reporting § 200.302 § 200.328 § 200.329

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

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

View Audit 323248

Finding 500943 (2023-007)

Material Weakness 2023

Wabanaki Health and Wellness

ME

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

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

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

View Audit 323235

Finding 500931 (2023-003)

Significant Deficiency 2023

Native Sun Community Power Development

MN

Subrecipient Monitoring Reporting Significant Deficiency

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

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

View Audit 323232

Finding 500918 (2023-003)

Significant Deficiency 2023

Search for Common Ground

DC

Procurement, Suspension & Debarment Subrecipient Monitoring

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

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

View Audit 323222

Finding 500417 (2023-001)

Material Weakness 2023

St. Francis Village, Inc.

TX

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

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

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

View Audit 323177

Finding 500405 (2023-003)

Significant Deficiency 2023

Town of Paoli

IN

Reporting Subrecipient Monitoring Significant Deficiency § 200.328

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

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

View Audit 323172

Finding 500396 (2023-005)

Material Weakness 2023

City of Greeley

CO

Subrecipient Monitoring Material Weakness Reporting § 200.303

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

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

View Audit 323158

Finding 500393 (2023-004)

Material Weakness 2023

City of Greeley

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

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

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

View Audit 323158

Corrective Action Plans

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