Corrective Action Plans

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Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going f...
Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However, with other grants the processes have changed. Since FY2022 an accounting firm was hired to catch the school district up on grant requests. This accountant requested funds on a quarterly basis. On July 1, 2025, the District hired a Federal Grants Director to work with the Business Manager to complete the grant catch up process and to create a system that documents each expenditure and the timing of the requests. Once the system is in place cash requests will be completed monthly.
View Audit 370564 Questioned Costs: $1
Reporting: The College agrees with the finding. To address the repeat finding, the College will implement a standardized reporting check list and a calendar utilizing its Asana Project Management tool to track and monitor all required federal and grant deadlines.
Reporting: The College agrees with the finding. To address the repeat finding, the College will implement a standardized reporting check list and a calendar utilizing its Asana Project Management tool to track and monitor all required federal and grant deadlines.
Cash Management: The College agrees with the finding. To strengthen internal controls over cash management, the College will establish written guidelines that will clearly define timelines, responsibilities, and approval processes for drawdown and disbursements. The College will reconcile drawdowns ...
Cash Management: The College agrees with the finding. To strengthen internal controls over cash management, the College will establish written guidelines that will clearly define timelines, responsibilities, and approval processes for drawdown and disbursements. The College will reconcile drawdowns to expenditures on a monthly/quarterly basis.
Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher tra...
Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher training to ensure proper and full use and utilization of its document management system and all other College systems.
Reporting College of the Marshall Islands acknowledges the finding and agrees that both the Section II source data file of the Annual Performance Report (APR) and the required Final Performance Report could not be provided during the audit. This occurred due to inadequate internal controls and the l...
Reporting College of the Marshall Islands acknowledges the finding and agrees that both the Section II source data file of the Annual Performance Report (APR) and the required Final Performance Report could not be provided during the audit. This occurred due to inadequate internal controls and the limitations of the previous manual filing system, which led to incomplete retention and difficulty retrieving submitted reports during the audit fieldwork. To correct this, the College has upgraded and institutionalized a cloud-based filing system to ensure all source data files, APR submissions, and Final Performance Reports are properly stored, organized, and easily accessible. Internal control policies and procedures have been strengthened to require that all performance reports are submitted on time, with verified source data and confirmation of successful submission retained in the system. The TRIO Office has established a reporting calendar, supervisory review process, and digital archive protocol to ensure all APR and final reports are prepared, submitted, and properly retained. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to meet federal reporting requirements. Staff have been trained— and will continue to be trained twice a year—on performance reporting procedures and federal reporting standards to prevent recurrence of similar issues in future audits.
Eligibility College of the Marshall Islands acknowledges the finding and agrees that several participant files lacked the required eligibility documentation, including proof of citizenship/residency, verification of academic support needed, documentation of age and grade level at initial selection, ...
Eligibility College of the Marshall Islands acknowledges the finding and agrees that several participant files lacked the required eligibility documentation, including proof of citizenship/residency, verification of academic support needed, documentation of age and grade level at initial selection, and confirmation of first-generation or low- income status. These gaps resulted from weak internal controls and the limitations of the previous manual filing system, which hindered proper tracking and retention of eligibility records during the audit fieldwork. To address these deficiencies, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, organized, and easily retrievable participant eligibility documentation. Internal control policies and procedures have been strengthened to require that all eligibility documents including citizenship/residency proof, age and grade verification, academic support need assessments, and first-generation/low-income eligibility forms—are obtained, reviewed, and approved before a student is enrolled and receives any program benefits or stipends. The TRIO Office has implemented a new eligibility checklist and supervisory review process to verify completeness and compliance for every participant file. With the upgraded systems and the support of newly hired skilled staff, the College is now better positioned to maintain accurate eligibility records. Staff have been trained and will continue to be trained twice a year on federal eligibility requirements and documentation standards to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student m...
Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student meal listings, as well as discrepancies between paid hours/rates and approved documentation. These gaps arose primarily from inadequate internal controls and the limitations of the previous manual filing system, which hindered timely verification during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, organized, and easily accessible documentation for all program expenditures. Internal controls have been strengthened to require proper supporting documents including signed employment contracts, verified timesheets, approval for incentive and leave payments, and student listings—before any program costs are processed or reported. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure accuracy and compliance. Staff have been trained—and will continue to be trained twice a year—on federal cost principles and documentation standards to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which ma...
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which made timely retrieval difficult during the audit fieldwork. The College has since upgraded and institutionalized a cloud-based filing system to improve recordkeeping, accessibility, and documentation retention for all program expenditures. Internal controls have been strengthened to ensure that all stipends, salaries, and benefits charged to the TRIO Upward Bound program are fully supported by proper documentation, verified, and reviewed before payment and reporting. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure compliance. Staff have been trained—and will continue to be trained twice a year—on federal grant cost principles and documentation requirements to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Reporting College of the Marshall Islands acknowledges the finding and agrees that there were deficiencies in the submission and reconciliation of required reports—including missing Form SG1 expenditure budget breakdowns, missing and delayed Form SG2 performance and financial evaluation reports, and...
Reporting College of the Marshall Islands acknowledges the finding and agrees that there were deficiencies in the submission and reconciliation of required reports—including missing Form SG1 expenditure budget breakdowns, missing and delayed Form SG2 performance and financial evaluation reports, and variances between the reported expenditures and the SEFA amounts. These issues primarily resulted from the limitations of the previous manual filing and reporting system, which hindered timely retrieval and review of supporting documents during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing and reporting system to ensure all supporting documents and reports are systematically organized, accessible, and securely retained. Internal controls have been strengthened to enforce timely preparation, review, and submission of required Form SG1 and SG2 reports, and to ensure accurate reconciliation of reported expenditures against SEFA. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain proper documentation and meet federal reporting requirements. In addition, staff have been trained and will continue to be trained twice a year on federal reporting standards and sub- award requirements to prevent similar issues from recurring in future audits.
Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based fili...
Procurement and Suspension and Debarment College of the Marshall Islands acknowledges the finding and confirms that the gaps noted resulted mainly from the previous manual filing system and limited internal procurement controls. The College has since upgraded and institutionalized a cloud-based filing system to ensure complete documentation, proper retention, and easy retrieval of procurement records. Internal control policies and procedures have been strengthened to ensure compliance with the RMI Procurement Code, including vendor selection documentation, verification of suspension and debarment status, and equitable distribution of micro- purchases. In addition, newly hired staff dedicated to Procurement and Accounts Payable have been onboarded to improve oversight and compliance. With these new systems, strengthened controls, and added staffing capacity, the College is now better positioned to maintain full compliance. Staff have been trained—and will continue to be trained twice a year—on procurement requirements and federal regulations to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Period of Performance College of the Marshall Islands acknowledges the finding and confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institut...
Period of Performance College of the Marshall Islands acknowledges the finding and confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institutionalized a cloud-based filing system and strengthened internal controls to ensure all costs are properly aligned with the funding periods stipulated in the grant awards. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain accurate documentation and monitoring. Staff have been trained—and will continue to be trained twice a year— on compliance with federal grant requirements, including period of performance rules. These measures will ensure timely verification and prevent similar issues from recurring in future audits.
View Audit 370531 Questioned Costs: $1
Equipment and Real Property Management College of the Marshall Islands acknowledges the finding and confirms that a new system has been put in place to transition from manual to automated processes for improved recordkeeping and monitoring. The College has implemented the MIP Fixed Asset Module to m...
Equipment and Real Property Management College of the Marshall Islands acknowledges the finding and confirms that a new system has been put in place to transition from manual to automated processes for improved recordkeeping and monitoring. The College has implemented the MIP Fixed Asset Module to maintain complete and accurate capital asset records, conduct timely reconciliations, and strengthen asset safeguarding controls. Internal procedures have been enhanced to ensure periodic physical inventory, prompt updates, and independent reviews of capital asset records. The full reconciliation and migration of all capital asset data into the new system is actively ongoing and scheduled to be completed by December 2025. These measures will ensure compliance with federal property management requirements and prevent recurrence of similar issues in the future.
Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionali...
Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and confirms that during the audit fieldwork, the required supporting documents could not be located due to the limitations of the previous manual filing system. The College has since upgraded and institutionalized a cloud- based filing system to ensure accurate recordkeeping, easy retrieval, and compliance with federal documentation requirements. Internal control procedures have been strengthened, and staff have received proper training, which will continue to be conducted twice a year on compliance with federal allowable cost principles and documentation standards. These measures will prevent recurrence of similar issues and ensure that all federal expenditures are adequately supported and fully compliant going forward.
View Audit 370531 Questioned Costs: $1
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly a...
Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll expenditures were not adequately supported by employment or overload contracts, and some salaries and related benefits charged were not clearly aligned with the purpose of the related subgrants. These gaps occurred because of inadequate internal controls and the limitations of the previous manual filing system, which made it difficult to locate and verify supporting documents during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, accessible, and properly organized documentation for all grant-funded positions and expenditures. Internal controls have been strengthened to require signed employment and overload contracts, proper funding source verification, and supervisory review before any grant- related payroll costs are charged. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain compliance and oversight. Staff have been trained and will continue to be trained twice a year on federal allowability and cost principles to prevent recurrence of similar issues in future audits.
View Audit 370531 Questioned Costs: $1
Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they ...
Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, in fiscal year 2022, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they are not in suspension or debarment. Us Helping Us acknowledges the audit finding regarding our organization’s inconsistent application of suspension and debarment screening procedures for vendors, suppliers, and contractors paid with Federal funds. We understand that compliance with 2 CFR Part 180 and 2 CFR § 200.214 is essential to ensure Federal funds are not awarded to parties that are suspended or debarred from doing business with the Federal Government. To further address this issue and prevent recurrence, Us Helping Us will implement the following measures: establishing a Standard Operating Procedure (SOP) for suspension and debarment checks, including when and how to perform them; integrated screening into the procurement workflow, requiring verification prior to contract execution or payment, designated staff responsible for performing and documenting checks using the System for Award Management (SAM.gov). Us Helping Us will now use one or more of the following Federally accepted methods for each covered transaction: SAM.gov search with screenshot documentation, Signed certification from the vendor affirming they are not suspended or debarred, and a Contract clause stating the vendor is not suspended or debarred, included in all Federally funded agreements. Training and Oversight will be provided to staff so that team members involved in procurement and grant management have received training on suspension and debarment requirements. An annual refresher training will be provided to ensure continued compliance. Internal audits will include a review of suspension and debarment documentation for all Federally funded transactions to ensure adherence. Our procurement policy has been updated to reflect mandatory suspension and debarment checks for all covered transactions, required documentation retention for audit purposes and procedures for verifying subrecipients and professional service providers. Us Helping Us is committed to maintaining full compliance with Federal regulations and ensuring that Federal funds are only awarded to eligible entities. Us Helping Us maintains documentation of these searches, retain them in vendor files. Screenings will be conducted on an annual basis. Retrospective screenings were conducted as requested during the audit. In addition to access to SAM.gov, Us Helping Us is using the services of Office of Inspector General (OIG) Exclusion Search and Software Company. Services provided include OIG Searches as well as SAM and State Exclusion searches. Us Helping Us staff will be educated about these procedures.The Executive Director and the Deputy Executive Director for Finance and Administration, Finance and Administration are responsible for developing, implementing, and maintaining the Plan, which is currently in place and any enhancements will be effective immediately.
We concur with the finding. The ETA 9130 reports for FY22 were based on estimates due to limitations in the reliability of the WIOA accounting system at that time.
We concur with the finding. The ETA 9130 reports for FY22 were based on estimates due to limitations in the reliability of the WIOA accounting system at that time.
We concur with the finding. Beginning in FY25, claimants have been required to come in and correct errors on their weekly claim forms. Regarding the overpayment, the claimant has been provided with a completed overpayment waiver form covering the two weeks of paid benefits.
We concur with the finding. Beginning in FY25, claimants have been required to come in and correct errors on their weekly claim forms. Regarding the overpayment, the claimant has been provided with a completed overpayment waiver form covering the two weeks of paid benefits.
View Audit 370385 Questioned Costs: $1
We concur with the finding. The Republic has executed a signed subrecipient subaward agreement to formalize the relationship and ensure compliance with applicable requirements. Applicable laws and regulations include the COMPACT Fiscal Procedures for Palau, which take precedence as special terms and...
We concur with the finding. The Republic has executed a signed subrecipient subaward agreement to formalize the relationship and ensure compliance with applicable requirements. Applicable laws and regulations include the COMPACT Fiscal Procedures for Palau, which take precedence as special terms and conditions where both these procedures and 2 CFR 200 address the same matter. The Ministry of Finance has implemented internal control policies and procedures to identify and document subrecipient relationships at the time of award, monitor subrecipient activities through periodic reporting, and verify compliance with federal and local requirements prior to processing drawdown requests. We further confirm that the program audit requirement for this subrecipient has been met through the separate single audit.
View Audit 370385 Questioned Costs: $1
The Government concurs with the auditor's findings and recommendations. A process related to financial and performance report preparation and submission will be formalized, and clear roles/responsibilities will be outlined. The Disaster Program Account Supervisors will be responsible for preparing t...
The Government concurs with the auditor's findings and recommendations. A process related to financial and performance report preparation and submission will be formalized, and clear roles/responsibilities will be outlined. The Disaster Program Account Supervisors will be responsible for preparing the reports on a quarterly basis and submitting them to the Territorial Hazard Mitigation Officer for review. The review process will include thorough reconciliation between the reports and other supporting data, such as accounting records.
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.
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.
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.
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
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.
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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