Corrective Action Plans

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prior year audit reports or audit findings, Proper and accurate reporting on a consistent and
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The University concurs that annual subrecipient monitoring is required under Uniform Guidance and the OMB Compliance Supplement. Subrecipient monitoring activities are operationally performed within Research and Sponsored Programs (RSP). The lack of documented monitoring during the period under audi...
The University concurs that annual subrecipient monitoring is required under Uniform Guidance and the OMB Compliance Supplement. Subrecipient monitoring activities are operationally performed within Research and Sponsored Programs (RSP). The lack of documented monitoring during the period under audit is attributable to changes in staffing and workflows within RSP, which resulted in a lapse in the consistent execution and documentation of established monitoring procedures. Upon identification of this issue, the Office of the Controller (OoC), in its oversight role for financial reporting and compliance, coordinated with RSP and initiated corrective actions to ensure the subrecipient monitoring requirement will be consistently met going forward. The OoC is working with RSP to reestablish and formalize monitoring procedures and to ensure appropriate staffing resources and review processes are in place. As part of the corrective action plan, the University will complete monitoring in FY2026 for subrecipients with audited financial statements for Fiscal Year 2025 and Calendar Year 2025, where practicable. In addition, as a retrospective measure, the University will review available subrecipient audit reports for Fiscal Year 2024 to confirm whether monitoring requirements were met and to document the results of that review. Further, the OoC and RSP will collaboratively define and document roles and responsibilities for obtaining, reviewing, and retaining subrecipient audit reports on an annual basis. These actions are focused on strengthening annual audit verification procedures for subrecipients, ensure ongoing compliance with Uniform Guidance requirements, and prevent recurrence of the condition.
Context and Cause – During the year ended June 30, 2025, OMEP entered into four first-tier subawards greater than $30,000 under AL number 11.611. The auditor tested one of these subawards, noting that the award was not yet reported under the Federal Funding Accountability and Transparency Act to the...
Context and Cause – During the year ended June 30, 2025, OMEP entered into four first-tier subawards greater than $30,000 under AL number 11.611. The auditor tested one of these subawards, noting that the award was not yet reported under the Federal Funding Accountability and Transparency Act to the Federal Subaward Reporting System (FSRS). Per further inquiry, all of the first-tier subawards were yet to be reported to the FSRS. OMEP was aware of the FFATA reporting requirements, but the reporting was not made timely. Internal controls were not adequately designed, and procedures were not in place to track and report first-tier subawards within the time frame required by federal requirements. Recommendation – The Organization should establish written policies and procedures for reporting first-tier subawards. Action Taken: OMEP will add a fiscal policy, that includes a documented review of first tier subawards, to ensure they are input to the FSRS no later than the last day of month that follows the initial obligation to the sub awardee. Responsible parties: Controller. Anticipated completion date: June 30, 2026.
Finding 1174308 (2025-001)
Material Weakness 2025
Responsible Parties: Janet Payne, Human Services Director Ashley Lantz, Department of Social Services Director Finding 2025-001, Medicaid Program - Significant Deficiency-Eligibility Response/Corrective Action: Findings: During the FY26 Single Audit of Medicaid, it was determined that the Union Coun...
Responsible Parties: Janet Payne, Human Services Director Ashley Lantz, Department of Social Services Director Finding 2025-001, Medicaid Program - Significant Deficiency-Eligibility Response/Corrective Action: Findings: During the FY26 Single Audit of Medicaid, it was determined that the Union County Medicaid program has deficiencies in the areas of oversight, income and deduction calculations, self employment income, self attestation, and internal controls related to 2nd party review corrections. Root Cause: It has been determined that staffing issues as well as deficiencies in training, due to vacancies on the training team, and lack of supervisor oversight due to span of control contributed to these deficiencies. Corrective Action: Due the the preliminary findings of the Single Audit, Union County Medicaid has already begun working on corrective actions. We have completed the following actions: • When an error is determined on an internal or external 2nd party review, the worker has 2 days to complete the correction. Once corrections are completed, the worker is to notify the supervisor that it has been completed. Supervisors are given 2 days to review the corrections. This is being added to our 2nd party review sheet for tracking effective 2/1. Initial tracking will be available once all February 2nd party reviews are completed. • Updates to our training are currently in progress for both new and seasoned staff. We anticipate these updates to be completed mid-February 2026 with training being completed by May 31, 2026 with all Medicaid staff. • Division Manager began monthly meetings with Medicaid leadership in November 2025. Monthly meetings focus on previous month’s 2nd party review findings and training needs as a way to ensure ongoing training needs are properly addressed. Corrective action currently in process includes the following: • Training on audit findings will be conducted by May 31, 2026. Pre and post assessments will be given to determine effectiveness of training. All staff will sign a statement of attendance and understanding upon the completion of trainings. Training topics will include income, self-employment income and deductions, self attestation, notices, and proper documentation. • Continuing education training will be completed monthly. Trainings will vary from month to month and will focus on common errors found in 2nd party reviews. Sessions will be conducted in small groups to allow better communication and more one on one time between the trainers and staff. Continuing education training will begin by May 31, 2026. • - Supervisors will continue to conduct 2nd party reviews to assess comprehension and adherance to Medicaid policy. Each month, beginning March 2026, Division Manager will receive a report from CQI to ensure that the 2 day correction and review mandate is being adhered to. It is important to note that the Medicaid Program Manager position is now vacant. The position will be filled as quickly as possible, and the Division Manager is currently taking over all roles of the Program Manager. Union County will implement the Corrective Action Plan by June 30, 2026.
NONCOMPLIANCE WITH GRANT TERMS AND CONDITIONS; COMMUNITY DEVELOPMENT BLOCK GRANTS/STATES PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII, AL No. 14.228, GRANT No. MT-CDBG-CV-22-13, YEAR ENDED JUNE 30, 2025 Name of contact person: Jhona Peterson, City Clerk/Treasurer Corrective Action: As a general prac...
NONCOMPLIANCE WITH GRANT TERMS AND CONDITIONS; COMMUNITY DEVELOPMENT BLOCK GRANTS/STATES PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII, AL No. 14.228, GRANT No. MT-CDBG-CV-22-13, YEAR ENDED JUNE 30, 2025 Name of contact person: Jhona Peterson, City Clerk/Treasurer Corrective Action: As a general practice, the Mayor and City Council will work with the engineers and require all contractors and vendors to supply proof of suspension and debarment review prior to work contracts being finalized for all projects. Proposed Completion Date: Fiscal year 2026
Finding 1174173 (2025-001)
Material Weakness 2025
Name of contact person: Craig Hughes, Executive Director Corrective Action: Finance procedures will be updated to include submission confirmation of the reporting package to the Federal Audit Clearinghouse. Proposed Completion Date: January 31, 2026.
Name of contact person: Craig Hughes, Executive Director Corrective Action: Finance procedures will be updated to include submission confirmation of the reporting package to the Federal Audit Clearinghouse. Proposed Completion Date: January 31, 2026.
FINDING 2025-001 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card/High School Graduation Rate Contact Person Responsible for Corrective Action: Mike Krutz Contact Phone Number and Email Address: 219-650-5300 x5370, mkrutz@mvsc.k12.in.u...
FINDING 2025-001 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card/High School Graduation Rate Contact Person Responsible for Corrective Action: Mike Krutz Contact Phone Number and Email Address: 219-650-5300 x5370, mkrutz@mvsc.k12.in.us Views of Responsible Officials: We concur with the finding. We have taken the audit finding, conclusions and recommendations and created a corrective action plan to correct our processes for the future. Description of Corrective Action Plan: The High School Staff implemented procedures to ensure adequate documentation is received to support a student’s removal/withdrawal from a cohort. The Student Withdrawal Report Form has been updated to include the most current State Withdrawal Codes as well as a high school administrator’s signature for approval. The procedures for removal/withdrawal from a cohort are as follows: 1. The student and/or parent complete the Withdrawal Report Form with the assistance of the attendance secretary. The Withdrawal Checklist Form is started and initialed by the attendance secretary. 2. The student and/or parent meet with an administrator or designee to review the Withdrawal Report Form and complete the Exit Interview Form. The Checklist Form is initialed by administrator or designee signifying completion of this step. 3. The attendance secretary scans the forms into the current student management system. The Checklist Form is initialed by the attendance secretary signifying completion of this step. 4. The original forms are hand delivered to the Registrar who then completes transfer requests and verifications to receiving schools. The Checklist Form is initialed by the Registrar signifying completion of this step. 5. The Registrar upon receiving the original documents hand delivers the Checklist Form to an administrator who reviews and signs the form approving the withdrawal. 6. The original documents are filed in the student’s permanent record folder. 7. Cohorts are reviewed after each trimester by grade level administration and cross referenced with the student management system to check for anomalies. Grade level administration will report their findings to the head principal or designee. Dexter Suggs, Ph.D. Superintendent of Schools "Once a Pirate, Always a Pirate" BOARD OF SCHOOL TRUSTEES Judy C. Dunlap James Donohue DeLena N. Thomas Alex Dunlap III Robert J. Krause President Vice-President Secretary Member Member INDIANA STATE BOARD OF ACCOUNTS 28 MERRILLVILLE COMMUNITY SCHOOL CORPORATION 6701 Delaware Street, Merrillville, IN 46410 (219) 650-5300 FAX (219) 650-5320 www.mvsc.k12.in.us If a student stops attending school and the student/parent does not come in to complete the process, the following procedures are followed: 1. The guidance office secretary attempts (and documents attempts) to contact the parent via phone calls, emails (with read receipt), and certified letters. All paperwork is printed and put in the student file. 2. The guidance office secretary searches the Education ID Portal site to determine if the student is attending another high school. 3. Continual effort is made to contact the parents by the guidance secretary or grade level dean. 4. Once the parent is reached, the above procedures are followed (see step1-7 above). 5. After 3 methods of contact are made (call, email, certified letter), the Student Withdrawal Report is completed and signed by an administrator and withdrawal codes 14 (Unknown/No Show 18+) or 15 (Truancy-Underage No Show) are used. 6. When the school is unable to get in contact with the parent, reports are made to DCS, Merrillville Truancy Court, and the updated procedures for Missing Students/Unknown Location are to be initiated immediately. Additional Step to Corrective Action Plan: We are establishing an annual internal audit, to be completed by central office staff, to ensure that all procedures related to the removal or withdrawal of individuals from a cohort are consistently and properly followed. The internal audit will consist of 10-15 randomly selected withdrawn student’s records. This audit will review documentation, decision-making processes, and compliance with established guidelines to confirm alignment with policy and regulatory requirements. The goal is to promote accountability, maintain program integrity, and identify any areas for improvement or need for additional training. Anticipated Completion Date: June 15, 2026
Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if...
Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if there are delays in performing certain key tasks that a plan with a timeline be developed to address when missed tasks will be completed. Corrective action: The Foundation acknowledges that it did not obtain internal control surveys and audit certification forms for a portion of fiscal year 2025 due to reductions in force and other organizational changes which temporarily limited staff capacity to complete all monitoring activities. Internal control surveys and audit certification fully resumed in October 2025. At that time, we also went back to the period May-October 2025 to perform the procedures that were paused and completed monitoring for all subrecipient agreements that were still active. The procedures we performed retroactively did not indicate any heightened risks for the applicable subrecipients. Additionally, all current subrecipient agreements with end dates beyond October of 2025 have had monitoring completed or are scheduled to be completed (due to more recent start dates). To prevent recurrence, the Foundation has implemented procedural safeguards to ensure continuity of compliance monitoring (specifically internal control survey administration, audit certification and an audit review and follow-up) during periods of staffing or operational disruption. These safeguards include (1) reaffirming formal assignment of responsibility for internal control survey administration and audit certification/foll-up to designated roles rather than individual staff, (2) cross-training of additional personnel to perform these functions as needed, and (3) increased management review to confirm completion and timeliness of monitoring. The Foundation will proactively assess the potential impact of anticipated and unanticipated staffing changes on subrecipient monitoring and compliance activities. Management will identify critical functions (including internal controls surveys and audit certification collection) and will ensure appropriate coverage, cross-training, or alternative resources are in place to maintain compliance with federal requirements. These controls were designed to ensure continuity of compliance activities during periods of staffing transition or operational disruption. Management will monitor compliance with this process on an ongoing basis to ensure monitoring is consistently performed in accordance with policy. Proposed completion date: October 2025
Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and...
Single Audit – Federal Funds Finding Organization: Pathways In Education – Illinois (PIE-IL) Audit Period: FY25 (or applicable fiscal year) Prepared By: [Brittany Barsevick/Manager of Instructional Compliance] Date: [1/21/2026] Federal Program: ALN 84.010 Title I, Part A, Basic grants Low-Income and Neglected Audit Finding Reference: 2025-001 ________________________________________ 1. Finding Summary The Single Audit identified a deficiency in the documentation and communication of federally funded position percentages and the alignment of Time & Effort attestations with the actual period of work performed. Specifically, the current CPS Federal Funds platform (Oracle) generates Time & Effort Attestation reports based on the month reimbursement claims are submitted, rather than the period during which the work was performed, creating a compliance gap. ________________________________________ 2. Root Cause ● Staff were not consistently informed of the exact percentage of their position funded by federal sources at the start of each semester. ● Time & Effort attestations were generated from the CPS Oracle system based on claim submission timing, not the actual work period. ● There was no formal internal SOP layer to supplement Oracle-generated reports with staff attestation aligned to Semester 1 and Semester 2 work periods. ________________________________________ 3. Corrective Actions Action 1: Internal Funding Percentage Notification System Description: PIE-IL will implement an internal tracking and notification system to ensure all staff funded in whole or in part with federal funds are formally notified of the exact percentage of their position supported by federal funding. Implementation Steps: ● Develop a standardized Federal Funding Allocation Notice template. ● Distribute notices to all applicable staff at the start of Semester 1 and Semester 2. ● Require staff acknowledgment (electronic or signed) confirming receipt and understanding. ● Maintain records centrally in the federal compliance folder. Responsible Party: Manager of Instructional Compliance Timeline: Implemented by the first day of each semester Monitoring: Semester-based review of acknowledgment logs ________________________________________ Action 2: Semester-Based Time & Effort Attestation Description: All federally funded staff will complete and sign a Time & Effort Attestation for both Semester 1 and Semester 2, certifying that time worked aligns with the funding source and percentage assigned. Implementation Steps: ● Issue Time & Effort forms at the end of each semester. ● Require staff to certify actual work performed during the semester. ● Collect supervisor verification signatures. ● Store completed attestations in the federal compliance repository. Responsible Party: Site Administrators / Federal Compliance Officer Timeline: Within 10 business days of semester end Monitoring: Quarterly internal compliance audits ________________________________________ Action 3: Internal SOP as Supplemental Documentation Layer Description: PIE-IL will implement a formal Standard Operating Procedure (SOP) for Time & Effort as a self-managed, internal documentation layer that supplements CPS Oracle-generated attestation reports. This SOP will ensure that Time & Effort documentation reflects the actual period of work performed, rather than the month in which reimbursement claims are submitted. Implementation Steps: ● Draft and approve a written SOP outlining: ○ Semester-based attestation requirements ○ Alignment between funding percentages and staff assignments ○ Reconciliation process between internal records and Oracle reports ● Train administrators and federally funded staff on SOP procedures. ● Maintain SOP as a controlled document with annual review and updates. Responsible Party: Federal Programs Director / Compliance Manager Timeline: SOP finalized within 30 days of audit response submission Monitoring: Annual SOP review and internal compliance testing ________________________________________ 4. Reconciliation Process with CPS Oracle System PIE-IL will perform a monthly reconciliation between: ● Oracle-generated Time & Effort Attestation reports (claim-based), and ● Internal Semester-Based Time & Effort attestations (work-period-based). Any discrepancies will be documented, corrected, and reviewed by the Federal Compliance Officer prior to reimbursement submission. ________________________________________ 5. Evidence of Implementation The following documentation will be maintained for audit and monitoring purposes: ● Federal Funding Allocation Notices with staff acknowledgments ● Signed Semester 1 and Semester 2 Time & Effort Attestation forms ● Approved Time & Effort SOP document ● Training sign-in sheets and materials ● Monthly reconciliation logs between Oracle and internal records ________________________________________ 6. Completion Dates Corrective Action Target Completion Date Funding Percentage Notification System [9/30/2026] Semester-Based Time & Effort Attestation Process [02/06/2026] SOP Finalization and Staff Training [02/28/2026] Monthly Reconciliation Process Ongoing ________________________________________
The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.
The Academies will implement a monitoring system to ensure there are no clerical errors recording data in the system.
Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of...
Corrective Action Plan: Management agrees with the finding. The City had a preexisting agreement with the subrecipient for a project that was already in progress when the federal grant was awarded. The subrecipient had in-depth involvement during the federal grant application process and is aware of specific compliance requirements under the Uniform Guidance (2CFR Part 200). We will make sure that all future subrecipients of pass-through federal grants are notified in writing of the responsibility to adhere to federal administrative, cost, and audit requirements.
Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-...
Subject: Special Education Cluster (IDEA) - Suspension and Debarment Federal Agency: Department of Education Federal Program: Special Education Cluster Assistance Listing Number: 84.027, 84.027X Federal Award Year (or Other Identifying Numbers): 22611-023-PN01, 22611-023-ARP, 23611-023-PN01 , 24611-023- PN01 , 25611-023-PN01 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Suspension and Debarment Audit Findings: Significant Deficiency Condition: An effective system of internal controls was not in place at the School Corporation to ensure the HamiltonBoone- Madison Special Education Cooperative's compliance with applicable requirements related to the Special Education Cluster (IDEA), specifically with respect to Suspension and Debarment requirements. No instances of noncompliance (entering a contract with a vendor that was suspended or debarred) were identified in the transactions selected for testing. The matter represents a deficiency in internal controls over the Suspension and Debarment process, rather than identified noncompliance with program requirements. Context: Suspension and Debarment As part of its internal control procedures, the Cooperative utilizes the System for Award Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. This verification process is designed to ensure that vendors are not suspended, debarred, or otherwise excluded from participation in federal programs, in accordance with applicable procurement regulations. Three covered transactions that equaled or exceeded $25,000 were identified. Of the three transactions, all were selected for testing, totaling $141,578. The Cooperative did not verify the vendors' suspension and debarment status prior to payment for two of the three covered transactions. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Management will enhance oversight of the Hamilton-Boone-Madison Special Education Cooperative's procurement process to ensure all applicable procurement steps, including suspension and debarment checks, are completed and follow federal regulations for the program, prior to entering into a contract with the respective vendor. Responsible Party and Timeline for Completion: David Hortemiller, CFO and Susan Wilson, Director of Finance met with Steven Wornhoff, Director of HBM Cooperative and Kim Kuersteiner, HBM Technology Manager to establish a process to review all vendors for suspension and debarment. Training was provided in regard to the Sam.gov website. Since August 2024, the Hamilton-Boone-Madison Special Services Cooperative (the Cooperative) has used the System for Awards Management (SAM.gov) to verify the eligibility status of vendors prior to engaging in financial transactions. The Cooperative will continue to use this process for any transaction equaling or exceeding $25,000. Documentation of the verification process will be retained by the Cooperative.
The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any cr...
The College will diligently check each financial aid disbursement roster to review and refund any student account credit balances generated from a disbursement. This process is to maintain compliance with this requirement. The College will also create an Infomaker report each week to identify any credit balances that need refunded.
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be...
Financial Aid personnel responsible for loan disbursements will review both COD and Pfaid records to ensure they align with the corresponding student account disbursement information. Additionally, the office will conduct monthly COD mismatch reviews to determine whether maintenance files need to be submitted. This process will help ensure continued accuracy and compliance in federal reporting.
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
All Financial Aid personnel were re-trained on the SEOG minimum and maximum award parameters. The office will conduct quarterly reviews of awards to ensure compliance and verify that no students are incorrectly awarded.
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
The Organization will reinforce its filing control environment by implementing a documented reporting calendar and assigning responsibility to finance leadership for reviewing and certifying timely submission of future single audit reporting packages.
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager will provide a listing of all students receiving a refund. A grace period of 5 days for students to provide direct deposit information will be established, if after 5 there is still no direct deposit...
Views of Responsible Officials and Planned Corrective Actions – The CFO and Student Accounts Manager will provide a listing of all students receiving a refund. A grace period of 5 days for students to provide direct deposit information will be established, if after 5 there is still no direct deposit information, a check will be issued.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of the review and approval of grant reports prior to being submitted, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediatel...
The Chief Financial Officer will ensure notification to federally funded employees of their funding source twice a year and will make sure supervisors get reports and sign certifications for work duties in compliance with the federal grants twice a year. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
The Chief Financial Officer will ensure staff retain documentation of review and approval of the indirect costs charged to the federal programs, effective immediately. Date of implementation - effective immediately, January 30, 2026.
Congressional Directives – Assistance Listing No. 93.493 Recommendation: We recommend CAPECO ensure documentation is retained to support the date the suspension and debarment verification procedures are performed. Explanation of disagreement with audit finding: There is no disagreement with the audi...
Congressional Directives – Assistance Listing No. 93.493 Recommendation: We recommend CAPECO ensure documentation is retained to support the date the suspension and debarment verification procedures are performed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CAPECO will obtain time-stamped verification support from SAM.gov to ensure that potential contractors are free from debarment and suspension prior to executing the contract. Name(s) of the contact person(s) responsible for corrective action: Paula Hall, CEO and/or Katie Smith, CFO Planned completion date for corrective action plan: Effective Immediately
2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA)/Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster – Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) – FFATA...
2025-002 Finding – Federal Funding Accountability and Transparency Act (FFATA)/Transparency Act Reporting (Timeliness) Federal Agency: U.S. Department of Health and Human Services (HHS) Program: Head Start Cluster – Assistance Listing 93.600 (Head Start) Compliance Requirement: Reporting (L) – FFATA/Transparency Act Special Reporting Type of Finding: Compliance (no internal control deficiency) Finding Summary: Two first-tier subaward actions were submitted in SAM.gov after the required reporting timeframe. Based on the nature of the exceptions and the results of expanded procedures, the late submissions appear to be isolated to the period of the federal FSRS-to-SAM.gov transition rather than indicative of a systemic reporting breakdown. Management attributed the delays to federal system conversion issues, including access/role challenges, delayed training, and data migration/report rejection issues that required resolution with SAM.gov support. Accordingly, the noncompliance is limited to timeliness of transparency reporting (no questioned costs) and does not affect allowability of Head Start expenditures. Corrective Action Plan: Delays were primarily attributable to the federal transition from FSRS to SAM.gov, including access/role configuration challenges and system-related issues encountered during the conversion period. Reasonable and timely steps were taken to submit the required FFATA reports as soon as the federal system issues were resolved and to address any submission rejections or support requests as needed. Now that the filing of back logged reports is complete, we will continue with our existing FFATA reporting procedures. We will track contracts needing FFATA submission with an internal ticketing system to ensure that the filings are on time. We will retain appropriate documentation of submissions and related system communications to support compliance. We will submit said documentation to our business office as a secondary measure to ensure that the filing was done prior to processing said contract. Contact Person responsible for corrective action: Anthony Jordan, Division Director Anticipated completion date of Corrective Action Plan: This item is corrected as of 10/01/2025.
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