Corrective Action Plans

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 Questioned Costs

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

HUD Housing Programs Questioned Costs 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 Questioned Costs Student Financial Aid

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 Questioned Costs Student Financial Aid

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

Questioned Costs 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 Questioned Costs Subrecipient Monitoring

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

Finding 485183 (2023-001)

Significant Deficiency 2023

Berrien County Board of Education

GA

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.303 § 200.318 § 200.320 § 200.403

Berrien County BOE FA 2023-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Feder...

Berrien County BOE FA 2023-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199 (Year: 2023), 225GA324N1199 (Year: 2023) Questioned Costs: $3,381 Description: A review of expenditures charged to the Child nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were reviewed and approved and that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: The new program director will attend training and review compliance requirements to ensure appropriate documentation is maintained. Estimated Completion Date: 30-Jun-24 Contact Person: Jolyn Schultz, Finance Director Telephone: 229-686-2081 Email: jolyn.schultz@berrien.k12.ga.us

View Audit 317993 Questioned Costs: $1

Finding 485161 (2023-002)

Material Weakness 2023

Trumbull County

OH

Subrecipient Monitoring Material Weakness Reporting

The County will enhance its internal controls over reporting and review federal guidance for reporting under the Coronavirus State and Local Fiscal Recovery Funds.

View Audit 317972

Finding 485159 (2023-002)

Significant Deficiency 2023

Scott County

MN

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid

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 317969

Finding 485158 (2023-001)

Significant Deficiency 2023

Scott County

MN

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid

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 317969

Finding 485146 (2023-002)

Material Weakness 2023

Morgan County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment. Summary of Finding: The County did not have any procedure or control in place to verify that applicable vendors were not suspended or debarred from participation in federal...

FINDING 2023-002 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Procurement and Suspension and Debarment. Summary of Finding: The County did not have any procedure or control in place to verify that applicable vendors were not suspended or debarred from participation in federal programs prior to entering into a covered transaction. Contact Person Responsible for Corrective Action: Linda Pruitt, County Auditor Contact Phone Number and Email Address: 765-342-1001, lpruitt@morgancounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The County will now require vendors entering into subawards and covered transactions with federal award funds to file a Suspension and Debarment Certification with the County prior to the execution of contract and at the beginning of each subsequent year, prior to the 1st payment of the year. Anticipated Completion Date: Immediate

View Audit 317960

Finding 485119 (2023-004)

Significant Deficiency 2023

Irl Council

FL

Subrecipient Monitoring § 200.303 § 200.331 § 200.332

2023-004 SUBRECIPIENT MONITORING Recommendations: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal...

2023-004 SUBRECIPIENT MONITORING Recommendations: The Council should review existing subrecipient agreements and amend any contracts that may be missing the required Uniform Guidance language. Management should ensure that future contracts use the template appropriate for the funding source (Federal, state or non-grant funded). To ensure compliance with the requirements for subrecipient monitoring, the Council should establish processes to (1) review and reports required by the subrecipient contract; (2) document the Council’s follow-up on action taken by the subrecipient on any deficiencies detected through audits, on-site reviews or other means; and (3) issue a management decision for audit findings pertaining to the Federal award provided to the subrecipient. Management’s Response: The timing of the federal award received from the EPA and the allocation of funds to certain projects approved in the workplan, resulted in several projects that had been completed and were originally funded through other revenue sources such as state license plate funds. The award time frame positioned these projects to be considered allowable pre-award expenses, however due to the timing of completion and award issuance, the agreements could not be amended to add the required federal subrecipient Uniform Guidance Language. The IRL Council will establish the following controls and implement actions to ensure subrecipient compliance: • Review all projects and activities currently allocated and funded by federal sources to insure the Uniform Guidance Language is in place with their respective agreements. For any agreement still in force, language will be amended immediately. For any agreement completed, the subrecipient shall be notified of the source of funds including the federal award identifier and amount of funding pertaining to that agreement to allow for subrecipient audit compliance. • All future subrecipient agreements funded by federal sources will not be executed until the respective federal award is in place and the Uniform Guidance Language is included. • All future and amended federally funded agreements will include language requesting audit reports and any finding with respect to the expenditure of federal funds. • The IRL Council will issue a written decision for audit findings pertaining to the Federal award provided to the subrecipient. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: December 31, 2024.

View Audit 317904

Finding 485117 (2023-003)

Significant Deficiency 2023

Irl Council

FL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

2023-003 SUSPENSION AND DEBARMENT Recommendations: CRI recommends the IRL Council implement controls to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. CRI suggests the Cou...

2023-003 SUSPENSION AND DEBARMENT Recommendations: CRI recommends the IRL Council implement controls to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. CRI suggests the Council include a clause in the subrecipient contracts stating the contractor is not suspended or debarred. This clause would need to be included in any modifications to the contracts that provide for additional funding. For other covered transactions, the Council should document their verification of the vendor’s status on the System for Award Management (SAM) Exclusions website. Management’s Response: The IRL Council will establish the following policies and controls to monitor and ensure compliance with SAM.gov requirements. • The IRL Council’s procurement process for federally funded projects will include an af􀏔idavit where applicants attach their SAM.gov proof at the time of proposal submission. • The IRL Council staff will review all proposal submissions to include SAM.gov review and provide screenshots of when the information was checked. These screenshots will be saved in the procurement file. • Current vendors and/or recipients of federal funds will be checked for SAM.gov compliance on an annual basis. The annual checks will be screenshot and uploaded into the vendor files. Vendor files will be updated accordingly with the date of the Sam.gov check by Finance. The annual compliance check will be a standard part of the end-of fiscal year closeout process. • Current vendors working on federally funded projects will be checked for SAM.gov compliance at the time of any change order, amendment, or contract adjustment that is requested. At the time of the change order, amendment or contract adjustment Sam.gov compliance will be checked and a Sam.gov screenshot will be uploaded into the vendor files. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: December 31, 2024.

View Audit 317904

Finding 485108 (2023-009)

Material Weakness 2023

City and County of Denver

CO

Subrecipient Monitoring Questioned Costs Material Weakness § 200.303

Status: Corrective action in progress Corrective Action: We agree with the recommendation. Regarding award number 08CH010552, we will update our internal procedures for reporting FFATA amounts in the period of obligation rather than when the expense was incurred. For 08HE000797 award, the grant acco...

Status: Corrective action in progress Corrective Action: We agree with the recommendation. Regarding award number 08CH010552, we will update our internal procedures for reporting FFATA amounts in the period of obligation rather than when the expense was incurred. For 08HE000797 award, the grant accountant that managed this award unexpectedly left the city. Given that other Coronavirus State and Local Fiscal Recovery Funds were exempt from the reporting and that he filed the FFATA for the main Head Start grant, we believe he misunderstood the guidance that this funding was also exempt. For all future Federal funding awards, we will ensure the grant accountant has a thorough understanding of the FFATA reporting requirements. Person(s) Responsible for Implementing: Accounting Services Implementation Date: July 2024

View Audit 317890

Finding 485106 (2023-007)

Significant Deficiency 2023

City and County of Denver

CO

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.303 § 200.403

Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will implement additional trainings and guidance for contract monitoring including invoice review and encourage a standard template in Excel to avoid calculation errors. The City is also currently implem...

Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will implement additional trainings and guidance for contract monitoring including invoice review and encourage a standard template in Excel to avoid calculation errors. The City is also currently implementing a city-wide grants management system and we hope to include invoice review and tracking in this new system by 2025. Person(s) Responsible for Implementing: DDPHE – Paige Cheney Implementation Date: September 2024 and potentially January 2025

View Audit 317890 Questioned Costs: $1

Finding 485103 (2023-005)

Significant Deficiency 2023

City and County of Denver

CO

Subrecipient Monitoring § 200.303 § 200.332

Status: Completed Corrective Action: The City agrees with the finding. After receiving 2022-007, DDPHE has consulted with the City’s Federal Grants Manager, other agencies that typically have subrecipients for Federal awards, and the City Attorney’s Office to review the current standard contract pro...

Status: Completed Corrective Action: The City agrees with the finding. After receiving 2022-007, DDPHE has consulted with the City’s Federal Grants Manager, other agencies that typically have subrecipients for Federal awards, and the City Attorney’s Office to review the current standard contract provisions to ensure they cover all required provisions and has modified those provisions accordingly. DDPHE has a new template for Scope of Work that includes the missing information that was identified by BDO. DDPHE also included a step to verify the recording of the SAM.gov in the scope of work. This will be implemented in any Federally funded contracts going forward and we will be trained on this during Contracts & Grants training on a regular basis. Person(s) Responsible for Implementing: DDPHE – Paige Cheney Implementation Date: October 2023

View Audit 317890

Finding 485101 (2023-004)

Material Weakness 2023

City and County of Denver

CO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Status: Completed Corrective Action: The City agrees with the finding. Remediation began with 2022-006. HOST makes every effort to comply with not only federal requirements but also City Charter requirements for timely payment. Occasionally there are exceptional circumstances where there is a need t...

Status: Completed Corrective Action: The City agrees with the finding. Remediation began with 2022-006. HOST makes every effort to comply with not only federal requirements but also City Charter requirements for timely payment. Occasionally there are exceptional circumstances where there is a need to update the City financial system Workday, for budget modifications or the like that could result in a delay of payment. In an effort to determine these items ahead of time we’ve updated our internal policies to require finance budget review prior to contract execution. Likewise, HOST is engaged in an application upgrade with Salesforce which is in the final User Acceptance Testing (UAT) phase to incorporate changes that now include status tracking for vendor invoice submissions and reimbursement payments. This will support a more comprehensive and accurate accounting of any legitimate postponed payments due to waiting on more required information from vendors, budget modifications, contract amendments, etc. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: Q1-2024

View Audit 317890

Finding 485097 (2023-002)

Significant Deficiency 2023

City and County of Denver

CO

Questioned Costs Special Tests & Provisions Procurement, Suspension & Debarment § 200.303

Status: Complete Corrective Action: This matter has been remediated, however, per the assessment this issue is a carryover into 2023 sub-awards based on the contract timeframes. The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to addres...

Status: Complete Corrective Action: This matter has been remediated, however, per the assessment this issue is a carryover into 2023 sub-awards based on the contract timeframes. The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to address the finding prior to December 31, 2023. To remediate prior findings 2022-005 and 2021-010, HOST updated the agency’s Grant Administrator Policies & Procedures, and our Contract & Performance Management Policies that now include language to ensure obligation of funding within the required deadlines. These policies were modified complete in June 2022 and July 2023. HOST’s current Notice of Funding Availability (NOFA) cycle for ESG funding will apply to subrecipient programs awarded beginning 01/01/2024, with anticipated contract executions in Q4 2023. Copies of both policies were provided to BDO on August 16, 2023, in response to the finding. This matter has been remediated, however, per the assessment this issue is a carryover into 2022 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: July 2023

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