Corrective Action Plans

Finding 9717 (2023-004)

None 2023

MI

Subrecipient Monitoring School Nutrition Programs Matching / Level of Effort / Earmarking

Finding: 2023-004 – Written Policies Required by the Uniform Grant Guidance Auditor Description of Condition and Effect: Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. As a result of...

Finding: 2023-004 – Written Policies Required by the Uniform Grant Guidance Auditor Description of Condition and Effect: Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation: We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year. Corrective Action: As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance and plan to have those in place by the end of the fiscal year. Responsible Person: Mike Beltnick, CFO Anticipated Completion Date: June 30, 2024

View Audit 13486

Finding 9669 (2023-002)

Significant Deficiency 2023

Volunteers of America Colorado Branch

CO

Subrecipient Monitoring HUD Housing Programs Significant Deficiency

Finding Number: 2023-002 Condition: In a monitoring visit performed by U.S. Department of Housing and Urban Development (HUD), the grantor found that the supporting documentation submitted does not enable a third-party reviewer to make a clear determination that match requirements were met. Planned ...

Finding Number: 2023-002 Condition: In a monitoring visit performed by U.S. Department of Housing and Urban Development (HUD), the grantor found that the supporting documentation submitted does not enable a third-party reviewer to make a clear determination that match requirements were met. Planned Corrective Action: The Organization established a policy and procedure to calculate the match requirement, compare it with the required total, and proactively identify actions to address any shortages at the end of each month. The Organization also ensured that all matches were supported by documents in a format that third parties could verify. Contact person responsible for corrective action: Chiyoko Yokota, Chief Financial Officer & Angel Hurtado, VP of Programs Anticipated Completion Date: 1/31/2023

View Audit 13410

Finding 9667 (2023-001)

Significant Deficiency 2023

Volunteers of America Colorado Branch

CO

Subrecipient Monitoring Eligibility HUD Housing Programs

Finding Number: 2023-001 Condition: In a monitoring visit performed by HUD, the grantor found that rent reasonableness determination was not completed on five of the six files reviewed. In our testing we found that six of ten participants we tested did not have a rent reasonableness determination da...

Finding Number: 2023-001 Condition: In a monitoring visit performed by HUD, the grantor found that rent reasonableness determination was not completed on five of the six files reviewed. In our testing we found that six of ten participants we tested did not have a rent reasonableness determination dated prior to the grant funds being expended Planned Corrective Action: The Organization revised the program policy to compare the rent reasonableness of at least three similar units using the Rent Reasonableness Comparison worksheet before any lease-up and document the test with evidence that is reviewed and verified with a supervisor signature prior to execution of the lease. The Organization will repeat this process annually as long as the participant remains in the same unit. The Organization also hired an extra full-time program quality control staff to monitor the compliance with the procedures. Moreover, The Organization will have an internal audit by the finance department at the halfway point of the grant year. Contact person responsible for corrective action: Chiyoko Yokota, Chief Financial Officer & Angel Hurtado, VP of Programs Anticipated Completion Date: 1/31/2023

View Audit 13410

Finding 9636 (2023-003)

Significant Deficiency 2023

Detroit Housing Commission

MI

HUD Housing Programs Eligibility Subrecipient Monitoring

Finding Number: 2023-003 Condition: Participant files selected for testing did not include complete information to support the participant's income to determine the level of benefits provided. Planned Corrective Action: The Housing Choice Voucher Program will work towards and maintain program compli...

Finding Number: 2023-003 Condition: Participant files selected for testing did not include complete information to support the participant's income to determine the level of benefits provided. Planned Corrective Action: The Housing Choice Voucher Program will work towards and maintain program compliance to ensure we are meeting all regulatory requirements. We will do this through staff hiring and restructuring. Ongoing in- house as well as Industry training to stay current and skilled on all program rules and updates as it pertains to the HCV Program with monthly and weekly reporting and monitoring. DHC understands the challenges outlined above and we have implemented measures to improve, redefine, address, and resolve all items according to HUD best practices. We will continue our ongoing efforts and have measurable goals with set dates and timelines. That will show marked improvement over the next 6-12 months in the following areas.  Reduction of Annual recertifications.  Increased utilization.  Increased PBV potential/new RFP.  PIC error corrective actions.  Increased landlord outreach/landlord Fairs.  Customer Service improvement/Call Center Staffing.  Continued industry training for all HCV Housing Specialist.  HCV Department RFP contract proposal. Contact person responsible for corrective action: Felicia Burris, HCV Interim Director. Anticipated Completion Date: 06/30/2024

View Audit 13310

Finding 9635 (2023-002)

Material Weakness 2023

Detroit Housing Commission

MI

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Finding Number: 2023-002 Condition: Participant files selected for testing did not include complete information to support participant eligibility Planned Corrective Action: Staff will be retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Ren...

Finding Number: 2023-002 Condition: Participant files selected for testing did not include complete information to support participant eligibility Planned Corrective Action: Staff will be retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupancy Supervisor. The Department Manager and Supervisor will continue to utilize all Yardi monitoring reports to ensure the Department is operating in accordance with industry standards. Reporting will be done and monitored monthly to meet set goals. We know and maintain we will work in accordance with HUD rules and regulations where Annual Recertification processes are concerned. Weekly; Department Manager will review the certification pipeline to ensure compliance and follow up with the Housing Specialist to ensure compliance and meeting set weekly and monthly goals and metrics. Contact person responsible for corrective action: Felicia Burris, HCV Program Manager Anticipated Completion Date: 6/30/2023

View Audit 13310 Questioned Costs: $1

Finding 9634 (2023-001)

Material Weakness 2023

Detroit Housing Commission

MI

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding Number: 2023-001 Condition: DHC did not complete fiscal year 2023 recertification. Planned Corrective Action: Staff will be retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupanc...

Finding Number: 2023-001 Condition: DHC did not complete fiscal year 2023 recertification. Planned Corrective Action: Staff will be retrained on the compliance requirements under the standards of the HCV Program through the oversight of the Rental Assistance Department Manager and Continued Occupancy Supervisor. The Department Manager and Supervisor will continue to utilize all Yardi monitoring reports to ensure the Department is operating in accordance with industry standards. Reporting will be done and monitored monthly to meet set goals. We know and maintain we will work in accordance with HUD rules and regulations where Annual Recertification processes are concerned. Weekly; Department Manager will review the certification pipeline to ensure compliance and follow up with the Housing Specialist to ensure compliance and meeting set weekly and monthly goals and metrics. Contact person responsible for corrective action: Felicia Burris, HCV Program Manager Anticipated Completion Date: 6/30/2023

View Audit 13310

Finding 9625 (2023-001)

Significant Deficiency 2023

Higley Unified School District No. 60

AZ

Procurement, Suspension & Debarment Subrecipient Monitoring

Program Name/Assistance Listing Title: Special Education Cluster, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 84.027A, 84.027X, 84.173A, 84.173X, 21.027 Contact Person: Tyler Moore, Chief Financial Officer Anticipated Completion Date: June 30, 2024 Planned Corrective...

Program Name/Assistance Listing Title: Special Education Cluster, Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 84.027A, 84.027X, 84.173A, 84.173X, 21.027 Contact Person: Tyler Moore, Chief Financial Officer Anticipated Completion Date: June 30, 2024 Planned Corrective Action: Higley Unified School District No. 60 has updated the procurement policies to align with federal rules to verify vendors are not suspended or debarred.  Applicable finance staff have been trained on the additional rules and regulations regarding federal funding.  For the vendors that have reached the federal grant threshold of $25,000 or meet certain other criteria as specified in 2 CFR section 180.220; a binder has been created alphabetically listing their SAM.GOV documentation.  All new vendors added to Visions will have SAM.GOV documentation pulled.  Federal grant account codes will be monitored by the Director and Assistant Director of Finance to track potential account code changes after the initial purchase order has been created. The Purchasing Manager will be alerted to any new expenses being charged to a federal program.

View Audit 13309

Finding 9524 (2023-002)

Significant Deficiency 2023

Carbon County School District #1

WY

Subrecipient Monitoring Reporting

Name of Contact Person – Margaret Quintrall, Business Manager Corrective Action Carbon County School District #1 established a district folder for information used to complete all state and federal reporting requirements. Proposed Completion Date: July 5, 2023

View Audit 13186

Finding 9514 (2023-006)

None 2023

Grant County

OR

Questioned Costs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.516

Views of responsible officials and planned corrective actions: The County does not have available funding to hire a grant compliance officer, however, the County plans to seek training resources for current staff responsible for grant administration

View Audit 13148 Questioned Costs: $1

Finding 9509 (2023-001)

Significant Deficiency 2023

Heartland Medical Clinic, Inc., D/b/a Heartland Community Health Center

KS

Subrecipient Monitoring Eligibility HUD Housing Programs

To United States Department of Health and Human Services Heartland Community Health Center respectfully submits the following corrective action plan for the year ended April 30, 2023. CohnReznick, LLP 350 Church Street Hartford, CT 06103 Audit Period: April 30, 2023 The findings from the April 3...

To United States Department of Health and Human Services Heartland Community Health Center respectfully submits the following corrective action plan for the year ended April 30, 2023. CohnReznick, LLP 350 Church Street Hartford, CT 06103 Audit Period: April 30, 2023 The findings from the April 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Federal Awards Findings: Finding 2023.001 - Sliding Fee Scale Discount Recommendation The Organization should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Action Taken • Monthly Audits o The Front Office Coordinators at each location will routinely audit sliding fee verification on a monthly basis to verify that information has been captured and recorded correctly and all proof of income documentation is received. These monthly audits will be adopted as standard protocol and procedure for front office operations, effective January 2024. Any findings through the audit process will be reported to the COO. At least five patien.t charts will be audited monthly. o In addition, the billing manager will also review audit findings or summaries to ensure adequate adjustment to patient accounts to correlate with the patient's eligibility status. • Staff Training o Although Heartland has offered periodic sliding fee scale procedure training, administration will be scheduling additional training with a focus on required documentation and proper set up of sliding fee discounts. o Health Center Practice Administrator will review and implement and update standard operating procedure for sliding fee scale verification. o Employees will receive a copy of the sliding fee scale policy and sign that they have read the material. o Front office employees at all locations will complete a sliding fee schedule competency check-off sheet that will be reviewed by the Front Office Coordinators and billing manager. If there are any question regarding this plan, please e-mail Regina Oxford at roxford@heartlandhealth.org. Sincerely,

View Audit 13129

Finding 9481 (2023-001)

Significant Deficiency 2023

Santa Fe County

NM

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Corrective Action Plan: The Finance Division will add calendar reminders to confirm all subsequent reporting on the audited financial statements and federal grants are completed by the various deadlines. Person Responsible: Yvonne Herrera, Finance Division Director Estimated Completion Date: June ...

Corrective Action Plan: The Finance Division will add calendar reminders to confirm all subsequent reporting on the audited financial statements and federal grants are completed by the various deadlines. Person Responsible: Yvonne Herrera, Finance Division Director Estimated Completion Date: June 30, 2024

View Audit 13026

Finding 9471 (2023-001)

Material Weakness 2023

Lancaster City School District

OH

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

District Administration was originally made aware of the specific requirements/documentation necessary for contracts let with federal ESSER funds during our FY22 state audit. School Districts are usually not required to pay prevailing wages (state/local funds). The District had not used federal fu...

District Administration was originally made aware of the specific requirements/documentation necessary for contracts let with federal ESSER funds during our FY22 state audit. School Districts are usually not required to pay prevailing wages (state/local funds). The District had not used federal funds for construction in the past and was unaware of the requirement. On 9/27/22, the District policy (DJF), regarding purchasing procedures, was updated to include the Davis-Bacon requirements. The purchase orders for the $24,605 flooring project in question were created on 8/18/22 and checks were issued on 12/15/22, prior to our FY22 audit being completed and a corrective action plan being in place. The District intends to closely follow internal controls pertaining to federal grant management in order to prevent future issues as described in Finding 2023-001.

View Audit 12983

Finding 9460 (2023-001)

Significant Deficiency 2023

Warner University, Inc.

CO

Subrecipient Monitoring Significant Deficiency

Gramm Leach Bliley Act Planned Corrective Action: The current Information Security Program was created using Capin's template last year and was acceptable. Moving forward, we will document the safeguards we're putting in place by including them in the Information Security Program and documenting th...

Gramm Leach Bliley Act Planned Corrective Action: The current Information Security Program was created using Capin's template last year and was acceptable. Moving forward, we will document the safeguards we're putting in place by including them in the Information Security Program and documenting the decreased mitigated risk level. We have a legacy on premise legacy SIS application software that doesn't have the capacity for MFA. We will attempt to either move our on-premise application software and database to our vendor's location where MFA is required to get into their network, or we will source a third-party vendor that will work with a legacy application without MFA capacity and require MFA on the front-end before calling the application. We will also consider application software on University-owned computer workstations and laptops that require MFA upon logging into our campus network. We will source an outside company for penetration testing and vulnerability scanning. Then, review the results and put in a plan to address the critical items and track progress. We will document each vendor that hosts PII data. We will collect SOC reports, privacy statements, GLBA compliance documents, and other related documents. We will provide the Board of Trustees - Business/Finance Committee a written report on the current status of the Information Security Program document. Person Responsible for Corrective Action Plan: Kelvin D Tohme, Senior Director of Information Technology Anticipated Date of Completion: Spring 2024

View Audit 12966

Finding 9412 (2023-004)

Material Weakness 2023

Reorganized School District R-II of Cape Girardeau County

MO

School Nutrition Programs Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Name of Contact Person: Matt Lacy, Chief Financial Officer; Recommendation: We recommend the District verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000; Corrective Action: ...

Name of Contact Person: Matt Lacy, Chief Financial Officer; Recommendation: We recommend the District verify a vendor's status by checking the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000; Corrective Action: We will verify all vendors' status using the System for Award Management (SAM) maintained by the General Services Administration before making purchases expected to exceed $25,000.

View Audit 12919

Finding 9292 (2023-001)

None 2023

The Open Door Network

CA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.329

Planned Corrective Action: We agree with the auditor’s comments, and the following action will be taken to improve the condition. Director Will Triplett and Manager Clarissa Lostaunau will implement a written policy included in the HSP Policy and Procedure Manual outlining accurate process and comp...

Planned Corrective Action: We agree with the auditor’s comments, and the following action will be taken to improve the condition. Director Will Triplett and Manager Clarissa Lostaunau will implement a written policy included in the HSP Policy and Procedure Manual outlining accurate process and completion of the HSP 14 monthly reporting. The manual will include written steps on obtaining, verifying and storing all backup documentation for all data on the HSP 14. The team will also include a verification process before the submission of the report where two employees approve the monthly report as an internal control, one being from management. This will be completed by December 31, 2023 and led by Director of Transformational Services, Will Triplett.

View Audit 12756

Finding 9262 (2023-001)

Significant Deficiency 2023

City of Greenville, North Carolina

NC

Subrecipient Monitoring Reporting

Finding: 2023-001 Name of contact person: Jacob Joyner, Director of Financial Services Corrective Action: The City will add review steps to ensure that all applicable reporting requirements are met. Proposed Completion Date: February 1, 2024

View Audit 12655

Finding 9234 (2023-002)

Significant Deficiency 2023

Scotland County Board of Education

NC

Subrecipient Monitoring Cash Management Reporting

Name of Contact Person :Wannaa Chavis, Chief Finance Officer ...

Name of Contact Person :Wannaa Chavis, Chief Finance Officer Corrective Acrtion Plan: The finding resulted primarily from significant turnover within the Finance Department. Management has established procedures to ensure that all bank account and other required reconciliations are prepared on a timely basis going forward. The Finance department will also strive to keep key positions filled at all times and ensure that staff receives appropriate training regarding reconciliations. Proposed Completion Date: Immediately

View Audit 12648

Finding 9159 (2023-001)

Material Weakness 2023

Montgomery College

MD

Matching / Level of Effort / Earmarking Student Financial Aid Subrecipient Monitoring § 200.303

U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status, effective date, and program begin date was reported to N...

U.S. Department of Education 2023-001 NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.268 Condition: During testing of enrollment status reporting, we noted that the incorrect enrollment status, effective date, and program begin date was reported to NSLDS. Recommendation: The College should evaluate their procedures and policies related to reporting status changes to NSLDS and enhance as deemed necessary to ensure that accurate information is reported to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Cause-Enrollment Status Reporting: Montgomery College utilizes the National Student Clearinghouse (NSC) as a third-party provider in order to submit student information to the NSLDS. Student enrollment status corrections were uploaded to NSC timely, however, monitoring of the upload through success was inconsistent, resulting in error reports preventing the accurate and timely update to the enrollment statuses. No review was completed to ensure the upload was completed in NSLDS. Cause for Effective Date Reporting - Inaccurate Student withdrawal effective dates were not identified timely due to delays in the review of student withdrawal status. Cause for Program Start Date Reporting - Inaccurate Student program begin dates were due to a programming issue with the file transmission software. Program start date was updating each semester to the latest semester start date. There was insufficient review to identify the problem and recommend a solution to resolve. The following actions have been implemented to resolve the deficiencies: Review of error reports by an employee not responsible for correcting the errors to ensure completeness and timeliness of the corrections submitted. Use of internal weekly reports to identify students who dropped below half time status or withdrew entirely from a semester. Use of the NSC online error reporting tool to correct errors monthly. Errors are corrected using this tool within eight days of receipt of the error report, which provides the NSC two days to resubmit the information and meet the ten-day resolution requirement. Utilize the Enrollment Reporting Summary Report (SCHER1) to ensure completeness and timeliness of error correction submissions. The Dept of Enrollment Services has coordinated with the Office of Information Technology to adjust the programming on the file transmission to NSC to ensure accuracy and minimize discrepancies. Manually submit corrections directly to NSLDS on an as-needed basis. Name(s) of the contact person(s) responsible for corrective action: Director of Enrollment Services- Earnest Cartledge Planned completion date for corrective action plan: December 2023

View Audit 12532

Finding 9107 (2023-001)

Significant Deficiency 2023

Wood River Health Services, Inc.

CT

Special Tests & Provisions Subrecipient Monitoring Eligibility

November 27, 2023 United States Department of Health and Human Services Wood River Health Services, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2023 The findings from th...

November 27, 2023 United States Department of Health and Human Services Wood River Health Services, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2023. CohnReznick LLP 350 Church Street Hartford, CT 06103 Audit Period: June 30, 2023 The findings from the June 30, 2023 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS SIGNIFICANT DEFICIENCY 2023.001 – Sliding Fee Scale Documentation Recommendation The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly documented. Action Taken Wood River Health Services is committed to documenting the sliding fee discounts being applied. Actions we are taking: Re-education of the Sliding Fee Discount Schedule (SFDS) documentation process to all personnel in the Community Resources Area Create review cheat sheets for SFDS including the documentation needed for decision making Review of Community Resource approvals If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please contact Alison Croke acroke@wrhsri.org. Sincerely yours, Alison Croke, MHA President and Chief Executive Officer

View Audit 12461

Finding 9065 (2023-003)

Significant Deficiency 2023

Edgar School District

WI

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs

Elementary and Secondary School Emergency Relief Assistance Listing Nos. 84.425D and 84.425U Recommendation: CLA recommends that the District implement a formal review process over the reporting requirement relating to ESSER annual reports. Explanation of disagreement with audit finding: There is no...

Elementary and Secondary School Emergency Relief Assistance Listing Nos. 84.425D and 84.425U Recommendation: CLA recommends that the District implement a formal review process over the reporting requirement relating to ESSER annual reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Annual ESSER reporting will be prepared by the bookkeeper, reviewed and signed off by the District Administrator, and be submitted Name(s) of the contact person(s) responsible for corrective action: Cari Guden, District Administrator Planned completion date for corrective action plan: July 1st 2023

View Audit 12412

Finding 9062 (2023-004)

Significant Deficiency 2023

Edgar School District

WI

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.214

Child Nutrition Cluster - Assistance Listing nos. 10.553 and 10.555 Recommendation: CLA recommends the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transaction have vendors reviewed for suspension and debarment ...

Child Nutrition Cluster - Assistance Listing nos. 10.553 and 10.555 Recommendation: CLA recommends the District review and update policies and procedures over review of certain transactions to ensure that all federal grants with covered transaction have vendors reviewed for suspension and debarment status. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: All food service vendors will be checked for suspension and debarment on the Sam.gov website. Name(s) of the contact person(s) responsible for corrective action: Morgan Mueller, Bookkeeper Planned completion date for corrective action plan: July 1st 2023

View Audit 12412

Finding 9060 (2023-001)

Significant Deficiency 2023

Two Rivers Supervisory Union

VT

Subrecipient Monitoring § 200.332

CORRECTIVE ACTION PLAN (Concerning Finding 2023-001) December 21, 2023 Finding: 2023-001 Subrecipient Monitoring Federal Program Information: U.S. Department of Education Passed through the State of Vermont Agency of Education ALN: 84.425 - Education Stabilization Fund Contact Person Respons...

CORRECTIVE ACTION PLAN (Concerning Finding 2023-001) December 21, 2023 Finding: 2023-001 Subrecipient Monitoring Federal Program Information: U.S. Department of Education Passed through the State of Vermont Agency of Education ALN: 84.425 - Education Stabilization Fund Contact Person Responsible for Corrective Action: Cheryl Hammond, Business Manager Corrective Action: The Two Rivers Supervisory Union will take the following actions to address finding 2023-001:  Review 2 CFR 200.332(a)  Create a temple subreceipient form  Complete the form annually and create a new form with any chance to the sub granted amount  Begin this process immediately Anticipated Completion Date: December 21, 2023

View Audit 12404

Finding 9059 (2023-001)

Significant Deficiency 2023

Dayton Early College Academy

OH

Subrecipient Monitoring Period of Performance Reporting § 200.302 § 200.328 § 200.344

Finding Number: 2023-001 Planned Corrective Action: The Dayton Early College Academy will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 07/01/2023 Responsible Contact Person: Steven Hinshaw, Treasurer

View Audit 12390

Finding 9044 (2023-001)

Significant Deficiency 2023

National Trust for Historic Preservation in the United States

DC

Subrecipient Monitoring

With respect to the lack of performance of a risk assessment, formal, written subrecipient monitoring policies and procedures for the Trust are now in place and will cover the entire fiscal year period ending June 30, 2024. Management will strictly adhere to these policies and procedures with respec...

With respect to the lack of performance of a risk assessment, formal, written subrecipient monitoring policies and procedures for the Trust are now in place and will cover the entire fiscal year period ending June 30, 2024. Management will strictly adhere to these policies and procedures with respect to all new subrecipients and subrecipients that are still active and receiving reimbursements during the year. With respect to the lack of follow-up with findings in subrecipients’ audit reports, the Trust will update its subrecipient monitoring policies and procedures to include immediate follow-up and documentation of corrective actions taken by subrecipients to address audit findings in their single audit reports. Individual(s) Responsible for Corrective Action Plan: Denise Wise Vice President of Finance & Controller, NTHP 202-588-6192 John Chomiak Chief Financial & Administration Officer, NMSC 202-372-5617 Anticipated Completion Date: June 30, 2024

View Audit 12381

Finding 9041 (2023-002)

Significant Deficiency 2023

The Wellbeing Initiative, Inc.

NE

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.332 § 200.414

2023-002 - Noncompliance and Significant Deficiency in Internal Controls over Compliance for Subrecipient Monitoring Corrective Action Plan: Wellbeing Initiative has reviewed subrecipient monitoring criteria and updated the Internal Controls Policy and Procedure Manual to include the following...

2023-002 - Noncompliance and Significant Deficiency in Internal Controls over Compliance for Subrecipient Monitoring Corrective Action Plan: Wellbeing Initiative has reviewed subrecipient monitoring criteria and updated the Internal Controls Policy and Procedure Manual to include the following policy. The appropriate measures have been taken to ensure these requirements are met in the coming years. Item 10.8.b.i-xv. Subrecipient monitoring requirements for pass-through entities, include the requirement that pass-through entities ensure that every subaward is clearly identified to the subrecipient as a subaward and includes the following information at the time of the subaward and if any of these data elements change, include the changes in subsequent subaward modification. When some of this information is not available, the pass-through entity must provide the best information available to describe the Federal award and subaward. Required information includes but is not limited to: i. Subrecipient name (which must match the name associated with its unique entity identifier); ii. Subrecipient's unique entity identifier; iii. Federal Award Identification Number (FAIN); iv. Subaward Period of Performance Start and End Date; v. Subaward Budget Period Start and End Date; vi. Total Amount of Federal Funds Obligated to the subrecipient by the pass-through entity including the current financial obligation; vii. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; viii. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); ix. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; x. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xi. Indirect cost rate for the Federal award (including if the de minimis rate is charged) per § 200.414. xii. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; xiii. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports; xiv. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and xv. Appropriate terms and conditions concerning closeout of the subaward Anticipated Completion Date: Completed 11/16/2023 Responsible: Chief Executive Team: Danielle Smith and Sadie Thompson

View Audit 12371

Corrective Action Plans

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