Corrective Action Plans

Finding 1161217 (2022-016)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.308 § 200.309 § 200.344 § 200.403

Finding No.: 2022-016 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $494,836 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1...

Finding No.: 2022-016 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Period of Performance Questioned Costs: $494,836 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (E. Cabrera): The Office of Grant Management (OGM) respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintain all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Based on our records, grant award D20AP00005 remains active with a period of performance extending through September 30, 2025, while grant award D20AP00037 was closed on September 30, 2024. Both grants remained operational well beyond the originally prescribed September 30, 2022 deadline. Given the extended period of performance authorized by the awarding agency, all associated questioned costs ($494,660.00) are supported by active grant activity and should be deemed allowable. Accordingly, OGM respectfully requests that these questioned costs be removed, as they reflect legitimate expenditures incurred within the approved grant periods. Proposed Completion Date: Ongoing Condition 2 (N. Karakaya): CIP agrees with the finding. To address the finding and prevent recurrence, CIP will: - Revise and strengthen written financial management policies to clearly define documentation requirements to substantiate expenditures and ensure costs are within the award’s period of performance. - Incorporate federal regulation references, including 2 CFR 200.303 (Internal Controls) and 2 CFR 200.344 (Closeout). - Implement a standardized checklist for technical analyst and program managers to confirm that all expenditure documentation includes dates verifying that costs were incurred within the period of performance. - Require a secondary review and sign-off by the CIP Administrator prior to submission of documentation to auditors. - Conduct mandatory annual training for program on federal period of performance requirements and required supporting documentation standards. - Provide refresher sessions before each audit cycle. - Establish a quarterly self-audit of grant files to verify that documentation is complete and properly supports expenditures. - Document results of each review and address deficiencies immediately. The responsible official will report progress on corrective actions to the CNMI leadership and maintain documentation of all implemented changes. Evidence of compliance (updated policies, training records, and self-audit reports) will be provided to the auditors upon request. Proposed Completion Date: December 31, 2025

View Audit 371187 Questioned Costs: $1

Finding 1161215 (2022-014)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Questioned Costs Cash Management Subrecipient Monitoring

Finding No.: 2022-014 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Cash Management Questioned Costs: $482,041 Contact Person(s): Tracy B. Norita, Secretary of Finance / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (N. Karakaya): CIP a...

Finding No.: 2022-014 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Cash Management Questioned Costs: $482,041 Contact Person(s): Tracy B. Norita, Secretary of Finance / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (N. Karakaya): CIP agrees with the finding. However, this timing is inherent in our established process. For the Capital Improvement Program (CIP), once an expense is entered into Tyler Munis and posted, we request a drawdown for those expenses. The check clearing date will naturally occur after the drawdown request date because payment disbursement and check clearing are subsequent steps in the payment process. Our practice ensures that: • Drawdowns are based on recorded, approved, and posted expenditures, not on projected or unverified costs. • Requests for reimbursement are fully supported by documented and posted expenses, which comply with grant requirements. Corrective Action / Process Enhancement: Although we believe the current procedure meets federal and grantor requirements, we will: 1. Document the Existing Process: Prepare a written procedure that explains the sequence of posting expenses in Tyler Munis, requesting drawdowns, and issuing checks, to clarify why check clearing dates follow drawdown requests. 2. Communicate with Auditor/Grantor: Provide the written procedure to the auditors and grantor to ensure shared understanding of the process. 3. Consider Additional Controls (if recommended): If the grantor or auditor recommends further safeguards, CIP will evaluate and implement feasible enhancements. Proposed Completion Date: December 31, 2025

View Audit 371187 Questioned Costs: $1

Finding 1161192 (2022-012)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Questioned Costs School Nutrition Programs Matching / Level of Effort / Earmarking

Finding No.: 2022-012 AL Programs: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $58,494 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1 & 2: CNMI NAP respectfully disagrees. Audit finding states that documentation supporting...

Finding No.: 2022-012 AL Programs: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $58,494 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1 & 2: CNMI NAP respectfully disagrees. Audit finding states that documentation supporting eligibility determinations were not provided. Finding further states that CNMI NAP lacks monitoring control over the listing of validated eligibility roster data that were not uploaded into MAVEN eligibility system due to data entry capacity limitations (sic) were not being maintained; and Distributed coupons were not reconciled to the recorded expenditures for redeemed coupons. The resulting effect being that CNMI NAP is in noncompliance with the applicable eligibility requirements and questioned costs for condition 1. CNMI NAP was informed that this finding had been cleared so we are perplexed as to the re-emergence of this audit finding. CNMI NAP contends that: 1. Eligibility for P-EBT benefits is not determined by CNMI NAP. P-EBT eligibility was determined by identifying children who qualified for free or reduced-price school meals and then correlating that with a reduction of in-person schooling due to COVID-19. Children in households receiving SNAP and young children, under age six, were also eligible, provided their schools or childcare facilities closed or reduced hours for at least five consecutive days due to the pandemic. This data was provided by PSS, as well as the listing of eligible children that corresponded to this data set. 2. There are no “validated eligibility roster data case files” that were not uploaded into MAVEN due to data entry capacity limitations. All rosters provided by PSS were uploaded into MAVEN as this is the only way a case file can be generated in the system. 3. CNMI NAP has reconciled all benefits issued, including the P-EBT benefits for the audit year in question. This is a mandatory, non-negotiable process. Proposed Completion Date: Ongoing

View Audit 371187 Questioned Costs: $1

Finding 1161191 (2022-011)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Subrecipient Monitoring School Nutrition Programs Eligibility § 200.334

Finding No.: 2022-011 AL Program: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Activities Allowed or Unallowed Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: CNMI NAP respectfully disagrees with this finding. The April 2022 Compliance Supplem...

Finding No.: 2022-011 AL Program: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Activities Allowed or Unallowed Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: CNMI NAP respectfully disagrees with this finding. The April 2022 Compliance Supplement referenced by the auditor states: Special Tests and Provisions. 1. Verification of Free and Reduced-Price Applications (NSLP) Compliance Requirements: By November 15th of each school year, the LEA (or state in certain cases) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. A state agency may, with FNS approval, assume from LEAs under its jurisdiction the responsibility for performing the verifications. If the LEA performs the verification function it must be in accordance with instructions provided by the state agency. The LEA must follow up on children whose eligibility status has changed as the result of verification activities to put them in the correct category. CNMI NAP response: The 2022 Compliance Supplement states that the LEA, in this instance, PSS, is responsible for verifying the current free and reduced-price eligibility of households unless the LEA is exempt from the verification requirement. PSS is not exempt from the verification requirement and the CNMI NAP has never given instructions to PSS for data collection as it is the PSS’ responsibility to supply the data to NAP for P-EBT. NAP’s role is to distribute the benefits only. Similar to the SUN Bucks (S-EBT) program, PSS furnishes the student listing to NAP, after which NAP distributes the benefits according to the listing provided by PSS. Proposed Completion Date: Ongoing

View Audit 371187

Finding 1160584 (2022-002)

Material Weakness 2022

Summitview Child & Family Services

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.302

Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice a...

Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice and Payment Documentation: • All invoices related to the federal program will be promptly reviewed and approved by the appropriate personnel to ensure they reflect allowable costs under the specific terms and conditions of the award. • Management will establish clear procedures for the proper recording and classification of payments, ensuring that they are linked directly to the corresponding federal program expenses. • All supporting documentation (e.g., purchase orders, contracts, receipts) will be retained in electronic formats within the accounting system, in accordance with the Organization’s record retention policy, ensuring availability for future audits or reviews. Retention and Accessibility: • The Organization will maintain a secure, organized filing system for all invoices and payments, ensuring that each record is easily accessible for audit purposes. This system will include electronic records that are stored in a centralized database, with restricted access to authorized personnel. • Retained invoices and payment documentation will be kept for the full duration required by federal regulations, typically for a period of at least seven years after the final expenditure report for the federal award has been submitted, or as otherwise required by the specific federal agency. Periodic Reviews and Monitoring: • To ensure ongoing compliance, Management will perform periodic reviews of federal program expenditures and documentation. This will include random sampling of invoices and payment records to confirm that they are complete, accurate, and in compliance with federal regulations. • In the event of any discrepancies or issues identified during these reviews, Management will take immediate corrective action to address the issue and prevent recurrence. By maintaining thorough records of all invoices and payments, the Organization aims to not only comply with federal audit requirements but also to ensure transparency, accountability, and sound financial management of federal funds.

View Audit 370890 Questioned Costs: $1

Finding 1160200 (2022-016)

Material Weakness 2022

Fremont County School District No. 21

WY

Subrecipient Monitoring Reporting

Reporting – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However...

Reporting – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However, with other grants the processes have changed. Since FY2022 an accounting firm was hired to catch the school district up on grant requests. This accountant requested funds on a quarterly basis. On July 1, 2025, the District hired a Federal Grants Director to work with the Business Manager to complete the grant catch up process and to create a system that documents each expenditure and the timing of the requests. Once the system is in place cash requests will be completed monthly.

View Audit 370564

Finding 1160197 (2022-015)

Material Weakness 2022

Fremont County School District No. 21

WY

Questioned Costs Subrecipient Monitoring Reporting

Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going f...

Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However, with other grants the processes have changed. Since FY2022 an accounting firm was hired to catch the school district up on grant requests. This accountant requested funds on a quarterly basis. On July 1, 2025, the District hired a Federal Grants Director to work with the Business Manager to complete the grant catch up process and to create a system that documents each expenditure and the timing of the requests. Once the system is in place cash requests will be completed monthly.

View Audit 370564 Questioned Costs: $1

Finding 1160147 (2022-023)

Material Weakness 2022

College of the Marshall Islands

MH

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.334

Reporting: The College agrees with the finding. To address the repeat finding, the College will implement a standardized reporting check list and a calendar utilizing its Asana Project Management tool to track and monitor all required federal and grant deadlines.

View Audit 370531

Finding 1160142 (2022-021)

Material Weakness 2022

College of the Marshall Islands

MH

Subrecipient Monitoring Cash Management § 200.303 § 200.305

Cash Management: The College agrees with the finding. To strengthen internal controls over cash management, the College will establish written guidelines that will clearly define timelines, responsibilities, and approval processes for drawdown and disbursements. The College will reconcile drawdowns ...

Cash Management: The College agrees with the finding. To strengthen internal controls over cash management, the College will establish written guidelines that will clearly define timelines, responsibilities, and approval processes for drawdown and disbursements. The College will reconcile drawdowns to expenditures on a monthly/quarterly basis.

View Audit 370531

Finding 1160139 (2022-020)

Material Weakness 2022

College of the Marshall Islands

MH

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher tra...

Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher training to ensure proper and full use and utilization of its document management system and all other College systems.

View Audit 370531

Finding 1160136 (2022-018)

Material Weakness 2022

College of the Marshall Islands

MH

Subrecipient Monitoring Eligibility Reporting § 200.303

Reporting College of the Marshall Islands acknowledges the finding and agrees that both the Section II source data file of the Annual Performance Report (APR) and the required Final Performance Report could not be provided during the audit. This occurred due to inadequate internal controls and the l...

Reporting College of the Marshall Islands acknowledges the finding and agrees that both the Section II source data file of the Annual Performance Report (APR) and the required Final Performance Report could not be provided during the audit. This occurred due to inadequate internal controls and the limitations of the previous manual filing system, which led to incomplete retention and difficulty retrieving submitted reports during the audit fieldwork. To correct this, the College has upgraded and institutionalized a cloud-based filing system to ensure all source data files, APR submissions, and Final Performance Reports are properly stored, organized, and easily accessible. Internal control policies and procedures have been strengthened to require that all performance reports are submitted on time, with verified source data and confirmation of successful submission retained in the system. The TRIO Office has established a reporting calendar, supervisory review process, and digital archive protocol to ensure all APR and final reports are prepared, submitted, and properly retained. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to meet federal reporting requirements. Staff have been trained— and will continue to be trained twice a year—on performance reporting procedures and federal reporting standards to prevent recurrence of similar issues in future audits.

View Audit 370531

Finding 1160135 (2022-017)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Subrecipient Monitoring Eligibility § 200.303

Eligibility College of the Marshall Islands acknowledges the finding and agrees that several participant files lacked the required eligibility documentation, including proof of citizenship/residency, verification of academic support needed, documentation of age and grade level at initial selection, ...

Eligibility College of the Marshall Islands acknowledges the finding and agrees that several participant files lacked the required eligibility documentation, including proof of citizenship/residency, verification of academic support needed, documentation of age and grade level at initial selection, and confirmation of first-generation or low- income status. These gaps resulted from weak internal controls and the limitations of the previous manual filing system, which hindered proper tracking and retention of eligibility records during the audit fieldwork. To address these deficiencies, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, organized, and easily retrievable participant eligibility documentation. Internal control policies and procedures have been strengthened to require that all eligibility documents including citizenship/residency proof, age and grade verification, academic support need assessments, and first-generation/low-income eligibility forms—are obtained, reviewed, and approved before a student is enrolled and receives any program benefits or stipends. The TRIO Office has implemented a new eligibility checklist and supervisory review process to verify completeness and compliance for every participant file. With the upgraded systems and the support of newly hired skilled staff, the College is now better positioned to maintain accurate eligibility records. Staff have been trained and will continue to be trained twice a year on federal eligibility requirements and documentation standards to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160133 (2022-015)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student m...

Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student meal listings, as well as discrepancies between paid hours/rates and approved documentation. These gaps arose primarily from inadequate internal controls and the limitations of the previous manual filing system, which hindered timely verification during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, organized, and easily accessible documentation for all program expenditures. Internal controls have been strengthened to require proper supporting documents including signed employment contracts, verified timesheets, approval for incentive and leave payments, and student listings—before any program costs are processed or reported. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure accuracy and compliance. Staff have been trained—and will continue to be trained twice a year—on federal cost principles and documentation standards to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160132 (2022-014)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which ma...

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which made timely retrieval difficult during the audit fieldwork. The College has since upgraded and institutionalized a cloud-based filing system to improve recordkeeping, accessibility, and documentation retention for all program expenditures. Internal controls have been strengthened to ensure that all stipends, salaries, and benefits charged to the TRIO Upward Bound program are fully supported by proper documentation, verified, and reviewed before payment and reporting. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure compliance. Staff have been trained—and will continue to be trained twice a year—on federal grant cost principles and documentation requirements to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160131 (2022-013)

Material Weakness 2022

College of the Marshall Islands

MH

Subrecipient Monitoring § 200.303

Reporting College of the Marshall Islands acknowledges the finding and agrees that there were deficiencies in the submission and reconciliation of required reports—including missing Form SG1 expenditure budget breakdowns, missing and delayed Form SG2 performance and financial evaluation reports, and...

Reporting College of the Marshall Islands acknowledges the finding and agrees that there were deficiencies in the submission and reconciliation of required reports—including missing Form SG1 expenditure budget breakdowns, missing and delayed Form SG2 performance and financial evaluation reports, and variances between the reported expenditures and the SEFA amounts. These issues primarily resulted from the limitations of the previous manual filing and reporting system, which hindered timely retrieval and review of supporting documents during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing and reporting system to ensure all supporting documents and reports are systematically organized, accessible, and securely retained. Internal controls have been strengthened to enforce timely preparation, review, and submission of required Form SG1 and SG2 reports, and to ensure accurate reconciliation of reported expenditures against SEFA. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain proper documentation and meet federal reporting requirements. In addition, staff have been trained and will continue to be trained twice a year on federal reporting standards and sub- award requirements to prevent similar issues from recurring in future audits.

View Audit 370531

Finding 1160130 (2022-012)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303 § 200.318 § 200.320 § 200.323

Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based fili...

Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based filing system to ensure complete documentation, proper retention, and easy retrieval of procurement records. Internal control policies and procedures have been strengthened to ensure compliance with the RMI Procurement Code, including vendor selection documentation, verification of suspension and debarment status, and equitable distribution of micro- purchases. In addition, newly hired staff dedicated to Procurement and Accounts Payable have been onboarded to improve oversight and compliance. With these new systems, strengthened controls, and added staffing capacity, the College is now better positioned to maintain full compliance. Staff have been trained—and will continue to be trained twice a year—on procurement requirements and federal regulations to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160129 (2022-011)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Subrecipient Monitoring § 200.303

Period of Performance College of the Marshall Islands acknowledges the finding and confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institut...

Period of Performance College of the Marshall Islands acknowledges the finding and confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institutionalized a cloud-based filing system and strengthened internal controls to ensure all costs are properly aligned with the funding periods stipulated in the grant awards. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain accurate documentation and monitoring. Staff have been trained—and will continue to be trained twice a year— on compliance with federal grant requirements, including period of performance rules. These measures will ensure timely verification and prevent similar issues from recurring in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160128 (2022-010)

Material Weakness 2022

College of the Marshall Islands

MH

Equipment & Real Property Management Subrecipient Monitoring § 200.303 § 200.313

Equipment and Real Property Management College of the Marshall Islands acknowledges the finding and confirms that a new system has been put in place to transition from manual to automated processes for improved recordkeeping and monitoring. The College has implemented the MIP Fixed Asset Module to m...

Equipment and Real Property Management College of the Marshall Islands acknowledges the finding and confirms that a new system has been put in place to transition from manual to automated processes for improved recordkeeping and monitoring. The College has implemented the MIP Fixed Asset Module to maintain complete and accurate capital asset records, conduct timely reconciliations, and strengthen asset safeguarding controls. Internal procedures have been enhanced to ensure periodic physical inventory, prompt updates, and independent reviews of capital asset records. The full reconciliation and migration of all capital asset data into the new system is actively ongoing and scheduled to be completed by December 2025. These measures will ensure compliance with federal property management requirements and prevent recurrence of similar issues in the future.

View Audit 370531

Finding 1160127 (2022-009)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionali...

Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionalized a cloud- based filing system to ensure accurate recordkeeping, easy retrieval, and compliance with federal documentation requirements. Internal control procedures have been strengthened, and staff have received proper training, which will continue to be conducted twice a year on compliance with federal allowable cost principles and documentation standards. These measures will prevent recurrence of similar issues and ensure that all federal expenditures are adequately supported and fully compliant going forward.

View Audit 370531 Questioned Costs: $1

Finding 1160126 (2022-008)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly a...

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly aligned with the purpose of the related subgrants. These gaps occurred because of inadequate internal controls and the limitations of the previous manual filing system, which made it difficult to locate and verify supporting documents during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, accessible, and properly organized documentation for all grant-funded positions and expenditures. Internal controls have been strengthened to require signed employment and overload contracts, proper funding source verification, and supervisory review before any grant- related payroll costs are charged. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain compliance and oversight. Staff have been trained and will continue to be trained twice a year on federal allowability and cost principles to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160030 (2022-003)

Material Weakness 2022

US Helping Us, People Into Living, Inc.

DC

Procurement, Suspension & Debarment Subrecipient Monitoring

Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they ...

Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they are not in suspension or debarment. Us Helping Us acknowledges the audit finding regarding our organization’s inconsistent application of suspension and debarment screening procedures for vendors, suppliers, and contractors paid with Federal funds. We understand that compliance with 2 CFR Part 180 and 2 CFR § 200.214 is essential to ensure Federal funds are not awarded to parties that are suspended or debarred from doing business with the Federal Government. To further address this issue and prevent recurrence, Us Helping Us will implement the following measures: establishing a Standard Operating Procedure (SOP) for suspension and debarment checks, including when and how to perform them; integrated screening into the procurement workflow, requiring verification prior to contract execution or payment, designated staff responsible for performing and documenting checks using the System for Award Management (SAM.gov). Us Helping Us will now use one or more of the following Federally accepted methods for each covered transaction: SAM.gov search with screenshot documentation, Signed certification from the vendor affirming they are not suspended or debarred, and a Contract clause stating the vendor is not suspended or debarred, included in all Federally funded agreements. Training and Oversight will be provided to staff so that team members involved in procurement and grant management have received training on suspension and debarment requirements. An annual refresher training will be provided to ensure continued compliance. Internal audits will include a review of suspension and debarment documentation for all Federally funded transactions to ensure adherence. Our procurement policy has been updated to reflect mandatory suspension and debarment checks for all covered transactions, required documentation retention for audit purposes and procedures for verifying subrecipients and professional service providers. Us Helping Us is committed to maintaining full compliance with Federal regulations and ensuring that Federal funds are only awarded to eligible entities. Us Helping Us maintains documentation of these searches, retain them in vendor files. Screenings will be conducted on an annual basis. Retrospective screenings were conducted as requested during the audit. In addition to access to SAM.gov, Us Helping Us is using the services of Office of Inspector General (OIG) Exclusion Search and Software Company. Services provided include OIG Searches as well as SAM and State Exclusion searches. Us Helping Us staff will be educated about these procedures.The Executive Director and the Deputy Executive Director for Finance and Administration, Finance and Administration are responsible for developing, implementing, and maintaining the Plan, which is currently in place and any enhancements will be effective immediately.

View Audit 370488

Finding 1159823 (2022-007)

Material Weakness 2022

Republic of Palau

PW

Reporting Subrecipient Monitoring Significant Deficiency § 200.303

We concur with the finding. The ETA 9130 reports for FY22 were based on estimates due to limitations in the reliability of the WIOA accounting system at that time.

View Audit 370385

Finding 1159822 (2022-006)

Material Weakness 2022

Republic of Palau

PW

Questioned Costs Subrecipient Monitoring Eligibility

We concur with the finding. Beginning in FY25, claimants have been required to come in and correct errors on their weekly claim forms. Regarding the overpayment, the claimant has been provided with a completed overpayment waiver form covering the two weeks of paid benefits.

View Audit 370385 Questioned Costs: $1

Finding 1159821 (2022-005)

Material Weakness 2022

Republic of Palau

PW

Questioned Costs Subrecipient Monitoring § 200.332 § 200.339 § 200.501

We concur with the finding. The Republic has executed a signed subrecipient subaward agreement to formalize the relationship and ensure compliance with applicable requirements. Applicable laws and regulations include the COMPACT Fiscal Procedures for Palau, which take precedence as special terms and...

We concur with the finding. The Republic has executed a signed subrecipient subaward agreement to formalize the relationship and ensure compliance with applicable requirements. Applicable laws and regulations include the COMPACT Fiscal Procedures for Palau, which take precedence as special terms and conditions where both these procedures and 2 CFR 200 address the same matter. The Ministry of Finance has implemented internal control policies and procedures to identify and document subrecipient relationships at the time of award, monitor subrecipient activities through periodic reporting, and verify compliance with federal and local requirements prior to processing drawdown requests. We further confirm that the program audit requirement for this subrecipient has been met through the separate single audit.

View Audit 370385 Questioned Costs: $1

Finding 1157886 (2022-083)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Reporting § 200.303

The Government concurs with the auditor's findings and recommendations. A process related to financial and performance report preparation and submission will be formalized, and clear roles/responsibilities will be outlined. The Disaster Program Account Supervisors will be responsible for preparing t...

The Government concurs with the auditor's findings and recommendations. A process related to financial and performance report preparation and submission will be formalized, and clear roles/responsibilities will be outlined. The Disaster Program Account Supervisors will be responsible for preparing the reports on a quarterly basis and submitting them to the Territorial Hazard Mitigation Officer for review. The review process will include thorough reconciliation between the reports and other supporting data, such as accounting records.

View Audit 369907

Corrective Action Plans

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