Corrective Action Plans

Finding 1157885 (2022-082)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring § 200.303 § 200.331 § 200.332 § 200.521

The Government concurs with the auditor's findings and recommendations. The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the Recipient, it is the Territory's responsibility to notify the Subrecipient whe...

The Government concurs with the auditor's findings and recommendations. The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the Recipient, it is the Territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient agreement which outlines the terms and conditions of the program. The Disaster Program Financial Specialist is responsible for reconciling that the subrecipient agreement has been signed by the Applicant and Governor's Authorized Representative and provided to the Territorial Public Assistance Officer. As such, no funds will be disbursed until the Subrecipient signs and returns the subrecipient agreement. These agreements are saved in a centralized location for documentation and audit purposes.

View Audit 369907

Finding 1157884 (2022-081)

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. The formalized process related to financial and performance report preparation and submission is now in place with clear roles and responsibilities outlined. The Disaster Program Financial Specialist is responsible for preparing...

The Government concurs with the auditor's findings and recommendations. The formalized process related to financial and performance report preparation and submission is now in place with clear roles and responsibilities outlined. The Disaster Program Financial Specialist is responsible for preparing the reports quarterly and submitting them to the Territorial Public Assistance Officer for review. The review process includes thorough reconciliations between the reports and other supporting data, such as accounting records.

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Finding 1157879 (2022-076)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The Government concurs with the auditor's findings and recommendations. As Medicaid staffing shortages are addressed, reports are submitted for review via email. The Department has implemented a shared folder to ensure copies of the approval emails and any time extension requests are now stored in s...

The Government concurs with the auditor's findings and recommendations. As Medicaid staffing shortages are addressed, reports are submitted for review via email. The Department has implemented a shared folder to ensure copies of the approval emails and any time extension requests are now stored in said folder to ensure access for audit purposes as the submission portal does not allow for attachments.

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Finding 1157868 (2022-072)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Questioned Costs Period of Performance Procurement, Suspension & Debarment § 200.303 § 200.344

The Government concurs with the auditor's findings and recommendations. As part of the close-out process, all open purchase orders are now submitted to the Department of Finance to be closed. Additionally, the grant close out process has now shifted to OMB to ensure the grant is no longer available ...

The Government concurs with the auditor's findings and recommendations. As part of the close-out process, all open purchase orders are now submitted to the Department of Finance to be closed. Additionally, the grant close out process has now shifted to OMB to ensure the grant is no longer available for transactions entries or liquidations. Additionally, a dedicated Fiscal Analyst is being inserted into the workflow to ensure compliance.

View Audit 369907 Questioned Costs: $1

Finding 1157866 (2022-069)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring § 200.303

The Government concurs with the auditor's findings and recommendations. An internal audit process is in place and is being utilized. Specifically, this includes exchanging caseloads between workers and having the eligibility and subsidy determinations cross-checked by the different worker based on t...

The Government concurs with the auditor's findings and recommendations. An internal audit process is in place and is being utilized. Specifically, this includes exchanging caseloads between workers and having the eligibility and subsidy determinations cross-checked by the different worker based on the federally and locally established policies.

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Finding 1157865 (2022-068)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

The Government concurs with the auditor's findings and recommendations. While DHS remains in compliance with this finding from previously audited years, the untimely submission resulted in this finding. Moving forward, a shared file will be established to ensure that the requisite information for ea...

The Government concurs with the auditor's findings and recommendations. While DHS remains in compliance with this finding from previously audited years, the untimely submission resulted in this finding. Moving forward, a shared file will be established to ensure that the requisite information for each year is readily available for audit purposes.

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Finding 1157864 (2022-067)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The Government concurs with the auditor's findings and recommendations. A Federal Grants Financial Analyst specific to the CCDF program has been onboarded with responsibility for the accuracy and submission of the financial reports. Internal controls have been implemented whereas final review and ap...

The Government concurs with the auditor's findings and recommendations. A Federal Grants Financial Analyst specific to the CCDF program has been onboarded with responsibility for the accuracy and submission of the financial reports. Internal controls have been implemented whereas final review and approval is required by a supervisor.

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Finding 1157863 (2022-066)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The Government concurs with the auditor's findings and recommendations. A dedicated Fiscal Analyst has been hired and is now inserted into the approval workflow to ensure compliance. Additionally, any open purchase orders are now closed at the end of the grant year to ensure compliance.

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Finding 1157861 (2022-064)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Eligibility Matching / Level of Effort / Earmarking § 200.303

The Government concurs with the auditor's findings and recommendations. The DHS has implemented a checklist as an added internal control step to comply with the Federal requirements for review of provider enrollment applications by the provider relations staff.

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Finding 1157841 (2022-061)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

The Government concurs with the auditor's findings and recommendations. The Governing Board transitioned to virtual meetings due to the Pandemic with pre-empted the FY22 training and has incorporated electronic voting from board members into its procedures. Therefore, regular trainings occur that en...

The Government concurs with the auditor's findings and recommendations. The Governing Board transitioned to virtual meetings due to the Pandemic with pre-empted the FY22 training and has incorporated electronic voting from board members into its procedures. Therefore, regular trainings occur that enable the governing body to perform its legal, fiscal and oversight responsibilities.

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Finding 1157840 (2022-060)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Equipment & Real Property Management Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.303

The Government concurs with the auditor's findings and recommendations. Program is collaborating the Office of Legal Council to include SOPP verbiage to ensure that completion of said forms. Efforts and technical assistance are being provided by the Federal Office of Head Start Grants Office. All ou...

The Government concurs with the auditor's findings and recommendations. Program is collaborating the Office of Legal Council to include SOPP verbiage to ensure that completion of said forms. Efforts and technical assistance are being provided by the Federal Office of Head Start Grants Office. All outstanding reports will be submitted by the end of March 2025. This will be included in quarterly monitoring meeting.

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Finding 1157839 (2022-059)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

The Government concurs with the auditor's findings and recommendations. Program is collaborating with the Director of Asset Management and the Fiscal Analyst to include SOPP verbiage to ensure that completion of said forms are timely and submitted as required. Efforts are being supported by the Fede...

The Government concurs with the auditor's findings and recommendations. Program is collaborating with the Director of Asset Management and the Fiscal Analyst to include SOPP verbiage to ensure that completion of said forms are timely and submitted as required. Efforts are being supported by the Federal Office of Head Start Grants Office.

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Finding 1157828 (2022-056)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Reporting Subrecipient Monitoring § 200.303 § 200.403 § 200.430

The Government concurs with the auditor's findings and recommendations. DOH fully acknowledge and accept the auditor’s finding regarding DOH’s inability to reconcile the payroll expenses listed in the SEFA with those documented in the payroll register. This discrepancy arose because payroll adjustme...

The Government concurs with the auditor's findings and recommendations. DOH fully acknowledge and accept the auditor’s finding regarding DOH’s inability to reconcile the payroll expenses listed in the SEFA with those documented in the payroll register. This discrepancy arose because payroll adjustments were not completed in time to reflect accurately in the FY2022 SEFA. To address this, DOH team has received thorough training, and staff members now have the necessary access to make payroll adjustments in the Government Financial Management System as of FY2024. Moving forward, DOH will strengthen our SOPs by conducting monthly reconciliation meetings with all relevant program teams to ensure timely adjustments and continuous monitoring. Additionally, DOH will update procedures to guarantee that all new fiscal staff are granted complete financial system access and are trained on reconciliation and adjustment processes within two weeks of starting.

View Audit 369907

Finding 1157823 (2022-053)

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. VIDE acknowledges the deficiencies identified in the reporting processes for the COVID-19 Education Stabilization Fund (ESF-SEA). VIDE is committed to enhancing our reporting practices to ensure compliance with federal requireme...

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the deficiencies identified in the reporting processes for the COVID-19 Education Stabilization Fund (ESF-SEA). VIDE is committed to enhancing our reporting practices to ensure compliance with federal requirements and to prevent future occurrences. VIDE will implement a structured review and approval process for all performance and special reports, ensuring that each report is vetted by the appropriate officials. Training will be provided for all staff involved in report preparation and submission.

View Audit 369907

Finding 1157813 (2022-051)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring § 200.303 § 200.331 § 200.332 § 200.521

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the need for strengthened controls to ensure subrecipient compliance with federal audit requirements, as specified in 2 CFR Part 200, Subpart F. VIDE is committed to implementing effective measures to ensure th...

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the need for strengthened controls to ensure subrecipient compliance with federal audit requirements, as specified in 2 CFR Part 200, Subpart F. VIDE is committed to implementing effective measures to ensure that all subrecipients adhere to federal regulations and that sufficient oversight is provided. VIDE will ensure all subrecipient agreements include explicit reporting requirements and compliance expectations under 2 CFR Part 200, Subpart F. In addition, training will be given to internal staff on subrecipient monitoring requirements and best practices to ensure consistent implementation.

View Audit 369907

Finding 1157812 (2022-050)

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. VIDE acknowledges the audit finding concerning the failure to comply with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements for first-tier subawards. VIDE plan will prioritize the development...

The Government concurs with the auditor's findings and recommendations. VIDE acknowledges the audit finding concerning the failure to comply with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements for first-tier subawards. VIDE plan will prioritize the development and implementation of detailed reporting policies and procedures, with a focus on FFATA requirements. These policies will include clear procedures for identifying and tracking all subawards subject to FFATA reporting, specific guidelines for collecting and reporting required data elements, and established timelines for data submission. Roles and responsibilities for all involved personnel, including program staff, grants management staff, and the Federal Grants Office, will be clearly defined within these policies. To enhance our subaward tracking capabilities, VIDE will implement a dedicated system for tracking subawards and collecting the required data. This may involve enhancing our existing grants management system or implementing a new system specifically designed to capture all necessary data elements for FFATA reporting. Comprehensive training on the use of this system will be provided to all relevant staff. VIDE will also strengthen its data verification and validation procedures. This will include establishing a formal process for reviewing and verifying the accuracy and completeness of subaward data before submission. Data quality checks will be implemented within the tracking system, and regular reconciliations will be conducted between subaward data and other relevant records to ensure consistency and accuracy. To ensure that all relevant personnel are well-versed in the new policies and procedures, VIDE will conduct mandatory training sessions. These sessions will cover FFATA reporting requirements in detail, VIDE's new policies and procedures for subaward reporting, and proper data collection and submission procedures.

View Audit 369907

Finding 1157805 (2022-045)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring § 200.303 § 200.331 § 200.332 § 200.521

The Government concurs with the auditor's findings and recommendations. OMB will identify and monitor the federal awarding agencies and will request single audit results for the applicable recipients beginning FY25 and include the results in the monitoring reviews. For revenue replacement projects, ...

The Government concurs with the auditor's findings and recommendations. OMB will identify and monitor the federal awarding agencies and will request single audit results for the applicable recipients beginning FY25 and include the results in the monitoring reviews. For revenue replacement projects, based on Treasury’s Final Rule FAQ (13.14), “Recipients’ use of revenue loss funds does not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award.” As such, they are not subject to the Single Audit Act.

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Finding 1157804 (2022-044)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

The Government concurs with the auditor's findings and recommendations. OMB has established a reporting approval memo in which the OMB Director signs acknowledging the review and approval of the Treasury reports starting in calendar year 2024 reporting. OMB has improved the collection and storage of...

The Government concurs with the auditor's findings and recommendations. OMB has established a reporting approval memo in which the OMB Director signs acknowledging the review and approval of the Treasury reports starting in calendar year 2024 reporting. OMB has improved the collection and storage of underlying supporting financial information for all projects being reported in the quarterly reports and can provide the necessary support upon request as of FY23.

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Finding 1157802 (2022-042)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Questioned Costs Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.303

The Government concurs with the auditor's findings and recommendations. 1. Hiring of Key Personnel: o A Grants Administrator has been hired to oversee the grant management process and ensure compliance with all applicable 2CFR200 regulations as well as the grant award. The Grants Administrator was o...

The Government concurs with the auditor's findings and recommendations. 1. Hiring of Key Personnel: o A Grants Administrator has been hired to oversee the grant management process and ensure compliance with all applicable 2CFR200 regulations as well as the grant award. The Grants Administrator was onboarded in October 2023. o An external Accounting firm has been engaged to provide additional oversight and expertise in financial management and compliance. The firm began providing support in January 2022. 2. Development of Policies and Procedures: o Comprehensive policies have been developed to ensure compliance with all applicable 2CFR200 regulations and the grant award. These policies include: • Internal controls for the vetting of subrecipients to ensure they meet all eligibility criteria. • Documentation of the awards granted, including detailed records of the grant agreement, budget, scope and period of performance adjustments. • Monitoring of expenditures to ensure funds are used for allowable activities and costs. • Communication to subrecipients on non-compliance issues and guidance for remediation activities or recoupment of costs. o Finalizing contract for the development of GVI over-arching policies to include Fraud, Waste and Abuse policy which would include a whistleblower process to encourage reporting of any suspected fraud or non-compliance. 3. Internal Controls: o Implementation of robust internal controls to ensure compliance with federal regulations. These controls include: • Regular reviews of financial transactions and documentation. • Segregation of duties to prevent conflicts of interest and ensure accountability. Grant Analyst assigned to projects, Grant Administrator reviews and oversees daily work and final sign offs required by Director. • Training for staff on compliance requirements and internal control procedures. 4. Monitoring and Evaluation: o Establishment of a monitoring and evaluation framework through the OMB Compliance Unit to assess the effectiveness of internal controls and compliance measures. This framework includes: • Regular reporting and review of compliance activities and findings. • Continuous improvement processes to address any identified weaknesses or gaps in controls. o Establish an Audit committee to oversee the implementation and effectiveness of internal controls and compliance measures. 5. Training: o Instituted regular training sessions for all staff involved in grant management to ensure they are aware of and understand compliance requirements.

View Audit 369907 Questioned Costs: $1

Finding 1157801 (2022-041)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring § 200.303 § 200.331 § 200.332 § 200.521

The Government concurs with the auditor's findings and recommendations. OMB will develop and enforce a robust framework that includes detailed monitoring procedures, regular compliance checks, and comprehensive oversight mechanisms. This framework will ensure that all subrecipients adhere to federal...

The Government concurs with the auditor's findings and recommendations. OMB will develop and enforce a robust framework that includes detailed monitoring procedures, regular compliance checks, and comprehensive oversight mechanisms. This framework will ensure that all subrecipients adhere to federal requirements, thereby promoting accountability and proper use of federal funds. These measures will help mitigate risks, enhance transparency, and ensure that subrecipients fulfill their obligations under federal statutes effectively.

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Finding 1157800 (2022-040)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The Government concurs with the auditor's findings and recommendations. An analyst will be assigned to track reporting schedules, grant activity and store documents. The analyst will regularly monitor the reporting schedule for each grant award to ensure that all reports are submitted in a timely ma...

The Government concurs with the auditor's findings and recommendations. An analyst will be assigned to track reporting schedules, grant activity and store documents. The analyst will regularly monitor the reporting schedule for each grant award to ensure that all reports are submitted in a timely manner.

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Finding 1157799 (2022-039)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Questioned Costs Subrecipient Monitoring Period of Performance § 200.1 § 200.303

The Government concurs with the auditor's findings and recommendations. The office of Management and Budget will work with the Department of Finance to implement control measures that will prevent the approval of transaction beyond the period of performance.

View Audit 369907 Questioned Costs: $1

Finding 1157798 (2022-038)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

The Government concurs with the auditor's findings and recommendations. VIDOL will be implementing a RESEA case management system for reporting and program services. This case management system is currently in configuration phase of the project. Live production is expected by the 2nd quarter 2025. T...

The Government concurs with the auditor's findings and recommendations. VIDOL will be implementing a RESEA case management system for reporting and program services. This case management system is currently in configuration phase of the project. Live production is expected by the 2nd quarter 2025. This system will be the official system of record for recording all services for RESEA claimants that participate in the program.

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Finding 1157796 (2022-036)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The Government concurs with the auditor's findings and recommendations. VIDOL has obtained a federal grant award from USDOL, to assist in updating and redesigning of UI reporting and accounting system. This award is intended to rebuild the current reporting structure to assist with having complete, ...

The Government concurs with the auditor's findings and recommendations. VIDOL has obtained a federal grant award from USDOL, to assist in updating and redesigning of UI reporting and accounting system. This award is intended to rebuild the current reporting structure to assist with having complete, accurate, and timely processes in place. VIDOL has commenced work on preparing scope of works for the projects, and it is anticipated by 4th quarter of FY2026.

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Finding 1157794 (2022-034)

Material Weakness 2022

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The Government concurs with the auditor's findings and recommendations. VIDOL concurs with the auditors finding relative to the balance not reconciling with the general ledger. The underlying factor that caused the variance in this finding was related to the retrieved file for the audit, which did n...

The Government concurs with the auditor's findings and recommendations. VIDOL concurs with the auditors finding relative to the balance not reconciling with the general ledger. The underlying factor that caused the variance in this finding was related to the retrieved file for the audit, which did not cover the period of the review, thus the balances provided to the auditors would not reconcile with the source system and the Government ledger. To avoid future occurrences, VIDOL has updated the source system report writer that produces query on balances for accounting and tracking ledger balances. VIDOL has also recently issued a request for a proposal to have a contractor assist in installing a Trust Fund accounting system infrastructure and procedures. This system is anticipated to correct many accounting deficiencies and improve operations. Based on the project plan the launch timeline is anticipated by third quarter of 2026. Once this system is operational, adequate personnel are hired and trained, postings and ledger balance should allow for more accurate data on account balances. This system will also provide a structure wherein accrual, month end, and year end system closes can occur.

View Audit 369907

Corrective Action Plans

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