Corrective Action Plans

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Finding #2022-001 Eligibility Program: Home Investment Partnership Program (CFDA # 14.239) Condition: During the test work over continuing eligibility requirements for loan recipients of the program, it was noted that the City did not have sufficient controls in place nor were adequate records maint...
Finding #2022-001 Eligibility Program: Home Investment Partnership Program (CFDA # 14.239) Condition: During the test work over continuing eligibility requirements for loan recipients of the program, it was noted that the City did not have sufficient controls in place nor were adequate records maintained to verify that the property was the principal residence of the homebuyer during the period of affordability described in the finding. Corrective Action: During fiscal year 2022, the Department underwent a reorganization as the City Council approved the establishment of two separate departments, Housing & Community Development and Economic Development. In April 2022, the Department contracted with Keyser Marston and Associates to train newly hired staff to assist the Department with Loan portfolio monitoring and to ensure on-going compliance. In addition, the Department will be implementing new procedures through a program called Neighborly to facilitate and streamline the process for all outstanding loans. The Neighborly program will assist with loan tracking, communicating with loan participants and obtaining annual compliance certifications. The Department will be focusing its resources to ensure ongoing compliance and plans to close this finding in fiscal year 2023. Contact Person: Andy Nogal, Deputy Director Anticipated Completion Date: June 2023
View Audit 305456 Questioned Costs: $1
Finding Number: 2022-002 - Eligibility Programs: U.S. State Department. Award Listing Number 19.517 Overseas Refugee Assistance Programs for Africa: Sunrise Project, Cairo Urban Refugees VI U.S. State Department. Award Listing Number 19.517 Overseas Refugee Assistance Programs for Africa: Sunrise...
Finding Number: 2022-002 - Eligibility Programs: U.S. State Department. Award Listing Number 19.517 Overseas Refugee Assistance Programs for Africa: Sunrise Project, Cairo Urban Refugees VI U.S. State Department. Award Listing Number 19.517 Overseas Refugee Assistance Programs for Africa: Sunrise Project, Cairo Urban Refugees VII. Planned Corrective Action: Management has adjusted its internal policy related to files maintained related to eligibility. Due to the timing of the finding the first full period that this can be implemented will be in fiscal 2024. Person Responsible: Daniel DeFilippis, Controller Expected Completion Date: December 31, 2024
View Audit 305324 Questioned Costs: $1
Community Development Block Grants/Entitlement Grants – Assistance Listing No. 14.218 Recommendation: We recommend that the Agency provide additional training to program managers regarding the documentation of program compliance requirements and the development of internal controls to ensure that al...
Community Development Block Grants/Entitlement Grants – Assistance Listing No. 14.218 Recommendation: We recommend that the Agency provide additional training to program managers regarding the documentation of program compliance requirements and the development of internal controls to ensure that all compliance requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure the federal program managers review the requirements of the Federal Funding Accountability and Transparency Act Requirements, and take the webinars and training through HUD, U.S Department of Education, and/or NCDA. In addition, Federal Programs Desk Guides and subrecipient agreements will be updated to include language regarding requirements of the Federal Funding Accountability and Transparency Act. Name(s) of the contact person(s) responsible for corrective action: Stephanie Green Planned completion date for corrective action plan: Completed 12/2023
Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files Were prepared in accordance w...
Housing Choice Voucher Cluster – Assistance Listing No. 14.871/14.879 Recommendation: We recommend management should designate one person to review a sample of the files that have been recertified each month. The purpose of the review is to determine if the tenant files Were prepared in accordance with internal policies and verify the compliance deficiencies have been corrected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Melanie Olson, Program Manager for the Operations Unit, is working with her management team to regularly review a sample of completed recertification from each of the staff in this unit. File reviews are important, not only for quality control purposes but also to review staff performance and to provide additional training/clarification as needed. Name(s) of the contact person(s) responsible for corrective action: Melanie Olson Planned completion date for corrective action plan: immediately
Information on the Federal Program: Assistance Listing Number 93.600 – Head Start Cluster, United States Department of Health & Human Services. Pass-Through Entity: N/A. Award Number: 10CH011432. Compliance Requirements: Reporting. Type of Finding: Material Noncompliance. Criteria: The entity should...
Information on the Federal Program: Assistance Listing Number 93.600 – Head Start Cluster, United States Department of Health & Human Services. Pass-Through Entity: N/A. Award Number: 10CH011432. Compliance Requirements: Reporting. Type of Finding: Material Noncompliance. Criteria: The entity should have a system of internal controls in place to ensure submission of applicable reports on a timely basis. Condition: During our compliance testing, we noted the SF-429 report was not submitted as required. Cause: We believe accounting staff turnover and inexperienced replacements during the year under audit were led to the lack of and/or failure in internal controls. Effect: The required report was not submitted to the agency. Identification of Repeat Finding: This is not a repeat finding. Recommendation: Staff turnover appears to have stabilized with the new finance director and the changes she implemented related to procedures and staffing. CSC may consider obtaining part-time or temporary assistance to help with fiscal year clean-up/close out to avoid similar problems with the accounting records in the current fiscal year due to a lack of time for current staff to prepare the accounting records while also performing their normal duties. Action Taken: We concur with the recommendation and have begun adding staff and restructuring the Finance Department. We have brought in 3 contract employees to assist with audits, have added an operations supervisor to assist with internal control implementations, and are actively recruiting a temporary accounting tech and a permanent accounting analyst to round out our team. We have also restricted the area of supervision of the grants supervisor to grants only rather than all financial operations. Given the large number of grants processed through CSC, we believe that having an individual dedicated to ensuring compliance on our grants will ensure that this type of significant deficiency will not continue. Names(s) and Title(s) of Responsible Person(s): Katie Henry, Finance Director
In May 2022, a new CFO was hired and new procedures put in place. All reporting requirements are tracked by both the CFO as well as the Accounting Manager and reviewed on a monthly basis.
In May 2022, a new CFO was hired and new procedures put in place. All reporting requirements are tracked by both the CFO as well as the Accounting Manager and reviewed on a monthly basis.
The Settlement agrees with the finding. Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff ...
The Settlement agrees with the finding. Fiscal and program staff will update CACFP Policies and Procedures to ensure that all CACFP records are retained for a minimum of three years. CACFP eligibility will be clearly documented and retained for three years by program staff. Fiscal and program staff will update CACFP Policies and Procedures to reflect subrecipient eligibility and related paperwork. Staff will be trained on completing and maintaining CACFP enrollment and eligibility paperwork via CACFP online workshops. Managers will complete management KidKare training to optimize electronic record-keeping of CACP documentation. The Compliance Director will complete an unannounced monitoring review of enrollment paperwork quarterly. Policies and Procedures will be edited to reflect rules and regulations for enrollment and eligibility paperwork. Implementation began October 2023. Responsible parties: Fiscal and Program staff, Compliance Director Completion date: 10/1/2023
The Settlement agrees with the finding. The review and approval process were improved in FY23 by assigning a junior accountant to review and collect the claim information from each site, and then having the Grants and Claims Manager review the reconciliation and submit the invoice to CACFP. In the a...
The Settlement agrees with the finding. The review and approval process were improved in FY23 by assigning a junior accountant to review and collect the claim information from each site, and then having the Grants and Claims Manager review the reconciliation and submit the invoice to CACFP. In the absence of the Grants and Claims Manager, the Assistant Controller reviews and approves the reconciliation. Implementation began July 2022. Responsible parties: Junior Accountant, Grants and Claims Manager, Assistant Controllers Completion date: 7/1/2022
Finding Reference Number #SA2022-003: Monitoring CDBG and HOME Program Activities for Compliance with Program Rules and Regulations Assistance Listing Numbers: 14.228, 14.239 Assistance Listing Title: Community Development Block Grants/State's Program HOME Investment Partnerships Program Name ...
Finding Reference Number #SA2022-003: Monitoring CDBG and HOME Program Activities for Compliance with Program Rules and Regulations Assistance Listing Numbers: 14.228, 14.239 Assistance Listing Title: Community Development Block Grants/State's Program HOME Investment Partnerships Program Name of Federal Agency: Department of Housing and Urban Development Federal Award Identification Number: B-19-MC-06-0039, B-20-MC-06-0039, M-18-DC-06-0240, M-20-DC-06-0240 • Fiscal Year of Initial Finding: 2022 • Name(s) of the contact person: Gary Hampton, Development Services Director • Corrective Action Plan: CDBG Findings:  For the finding of an incorrect identification of activity in the Integrated Disbursement & Information System (IDIS), which was deemed an ineligible activity, the City has requested a Voluntary Grant Reduction (VGR) in order to compensate for the error. It is currently pending the Department of Housing and Urban Development (HUD) approval.  In regards to the finding from not having a current Residential Anti-Displacement and Relocation Assistance Plan, the City has developed the plan and it was approved by the City Council on 4/9/24. The document is to be uploaded to HUD prior to the end of the month of April 2024. HOME Findings:  In order to address the finding of an absence of dated signatures of all parties on the beneficiary written agreement for the two IDIS projects and a lack of HOME program policies and procedures to ensure written agreements include dated signatures of all parties, the City updated their “City of Turlock Home Consortium Policies and Procedures.”  The City updated their contract template so that it would address the finding of an absence of many federally required provisions in the City’s loan agreement with a property owner, including five components detailed in the monitoring letter that were missing from the agreement.  The amount of HOME funds invested in one IDIS project was not at or below the applicable maximum per-unit HOME subsidy limit as required under 24 CFR Section 92.250(a). The limit was exceeded by $133,625. The City has requested a VGR and it is pending HUD approval.  To address the finding of not having comprehensive written policies and procedures as required under HOME regulation 24 CFR Section 92.504(a), including Tenant Selection, Income Determination and Lease Compliance, the City as part of their update of the “City of Turlock Home Consortium Policies and Procedures” included such provisions. • Anticipated Completion Date: 6/30/2024
View Audit 304861 Questioned Costs: $1
Finding Reference Number #SA2022-001: Suspension and Debarment for Contracts and Subcontracts Assistance Listing Numbers: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award Identificati...
Finding Reference Number #SA2022-001: Suspension and Debarment for Contracts and Subcontracts Assistance Listing Numbers: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award Identification Number: SLFRP4371 266737 Pass-Through Entity: California State Water Resources Control Board • Fiscal Year of Initial Finding: 2021 • Name(s) of the contact person: Isaac Moreno, Finance Director • Corrective Action Plan: The City has drafted an updated citywide procurement policy that includes the requirement to be compliant with 2 C.F.R Part 180 and is expected to be approved in March 2024. In conjunction with the updated procurement policy, the purchasing department of the City will check for suspension and debarment for contracts and subcontracts as part of the request for proposal process and notify all departments to check vendors when utilizing Federal funds. • Anticipated Completion Date: 6/30/2024
View Audit 304861 Questioned Costs: $1
Finding 394963 (2022-006)
Significant Deficiency 2022
Federal Program Community Programs to Improve Minority Health - 93.137, Contract 1 CPIMP211290-01-00 Condition The City did not perform a risk assessment or any additional monitoring of subrecipients beyond reviewing requests for payment. Cause This is a new grant for the City in 2022 and there wa...
Federal Program Community Programs to Improve Minority Health - 93.137, Contract 1 CPIMP211290-01-00 Condition The City did not perform a risk assessment or any additional monitoring of subrecipients beyond reviewing requests for payment. Cause This is a new grant for the City in 2022 and there was turnover in the grant director position during the year. Recommendation We recommend that the City continue developing standard operating procedures for subrecipient monitoring of grant activities. This is especially important for grants handled outside the community development office. Management Response City management agrees with this finding. We have an assessment tool from the ARPA Small business program that can be repurposed as a risk assessment for this program. Both the City’s Director and employee assigned to this Federal award understand subrecipient monitoring is required for sub awardees. There are monthly subgrant reports and quarterly HUD reports to back up all the work being done under the grant. The Director of Finance will oversee the work of these two City employees. Anticipated Completion Date - Ongoing
Finding 2022-003 Federal Agency Name: Department of Housing and Urban Development Program Name: Block Grants for Community mental Health Services Federal Financial Assistance Listing: #93.958 Finding Summary: The Organization did not have adequate internal controls to ensure matching expenses were a...
Finding 2022-003 Federal Agency Name: Department of Housing and Urban Development Program Name: Block Grants for Community mental Health Services Federal Financial Assistance Listing: #93.958 Finding Summary: The Organization did not have adequate internal controls to ensure matching expenses were appropriately tracked to meet award requirements. In addition, it was identified that all expenses did not have adequate documentation supporting the review and approval of the amounts meeting the matching requirements. Additionally, select payroll allocations did not have supporting documentation for the amounts allocated to the program. Responsible Individuals: Nancy Burke, CEO Corrective Action Plan: We will implement controls and processes to appropriately track and monitor matching requirements in each period for all awards. In addition, we will implement approval processes to ensure proper qualification for the match requirements and allocations. Anticipated Completion Date: December 31, 2023
ALN: 14.850 – Public & Indian Housing – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Childers, Chief Executive Officer Projected Compl...
ALN: 14.850 – Public & Indian Housing – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Childers, Chief Executive Officer Projected Completion Date: March 31, 2025
ALN: 14.850 – Public & Indian Housing – Operating Subsidy and Utilities Expense Level Calculation Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Chi...
ALN: 14.850 – Public & Indian Housing – Operating Subsidy and Utilities Expense Level Calculation Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Childers, Chief Executive Officer Projected Completion Date: March 31, 2025
Treasurer will ensure audits are done in a timely manner moving forward.
Treasurer will ensure audits are done in a timely manner moving forward.
The City concurs with this finding. Full training with all staff responsible for expending federal funds has occurred. All vendors utilizing federal funding have been reviewed and debarment has been completed. As noted by the finding, all contractors/vendors were not suspended. Monthly reviews of fe...
The City concurs with this finding. Full training with all staff responsible for expending federal funds has occurred. All vendors utilizing federal funding have been reviewed and debarment has been completed. As noted by the finding, all contractors/vendors were not suspended. Monthly reviews of federal funds will be performed to assure compliance.
Food Distribution Cluster– Assistance Listing No. 10.569 During our testing, we identified there was no monitoring performed for 9 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2022. Recommendation: The Organization should prioritize the timely monitoring of p...
Food Distribution Cluster– Assistance Listing No. 10.569 During our testing, we identified there was no monitoring performed for 9 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2022. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Create a new folder checklist indicating all mandatory items that should be included in each agency folder for compliance. 2. Review all current documentation and assure each item has been properly placed in the appropriate folder. 3. Create a schedule to complete all outstanding monitoring. We are 10% complete to date. 4. Schedule 3-5 monitoring visits per week over the timeframe of January – March 2023. 5. File all monitoring reports in the appropriate folder. 6. Weekly Agency Relations check-ins scheduled beginning January 9th 2023. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2024.
Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure that all leased employees, staff, and volunteers participating in a program funded by a federal award, are subject to the same or higher standards of screening, training and orientation required by the federal a...
Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure that all leased employees, staff, and volunteers participating in a program funded by a federal award, are subject to the same or higher standards of screening, training and orientation required by the federal award. This will apply equally to Team Rubicon personnel and to any participating person(s) not directly or indirectly affiliated with Team Rubicon (e.g., external volunteers).
Finding 394234 (2022-002)
Significant Deficiency 2022
Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, document...
Planned Corrective Action: Team Rubicon will institute policies and procedures to ensure compliance with applicable procurement guidelines when accepting federal awards. These will include prohibition against contracts which could be influenced by a perceived or actual conflict of interest, documentation of a search for suspended and debarred parties, and guidelines for approved methods of procurement (including specific situations where noncompetitive procurement may be appropriate, and documentation to be required if so).
Planned Corrective Action: Team Rubicon will institute during the grant intake process an assessment of whether a grant designates Team Rubicon as either a contractor or a subrecipient. Additionally, management will assess with grantors whether funds are federally sourced and whether a Single Audit ...
Planned Corrective Action: Team Rubicon will institute during the grant intake process an assessment of whether a grant designates Team Rubicon as either a contractor or a subrecipient. Additionally, management will assess with grantors whether funds are federally sourced and whether a Single Audit (or any other compliance audit) is a necessary requirement or result of receiving the funding. Management will further ensure that any and all compliance requirements for government-funded grants or awards are communicated and adhered to across the organization. Management will also ensure the evaluation and monitoring of compliance with federal awards through strengthening related internal controls and processes.
Reporting – Late submission of the Single Audit Reporting Package and Data Collection Form to the Federal Audit Clearinghouse (FAC) InterIm Community Development Association agrees with the finding and recommendations made by the auditor. We note that one funder for one contract took a very long tim...
Reporting – Late submission of the Single Audit Reporting Package and Data Collection Form to the Federal Audit Clearinghouse (FAC) InterIm Community Development Association agrees with the finding and recommendations made by the auditor. We note that one funder for one contract took a very long time to clarify whether their funding should be classified as being federal in nature. InterIm Community Development Association management, working with its Board Treasurer, will identify additional accounting procedures and policies which will resolve the finding in the future.
Finding 394031 (2022-005)
Significant Deficiency 2022
Finding 2022-005 Review of Reporting – Significant Deficiency in Internal Control over Compliance Planned Corrective Actions: All reporting will be reviewed by at least one other staff member to ensure accuracy prior to submission. Individual(s) Responsible for Corrective Action Plan Elizabeth Fisch...
Finding 2022-005 Review of Reporting – Significant Deficiency in Internal Control over Compliance Planned Corrective Actions: All reporting will be reviewed by at least one other staff member to ensure accuracy prior to submission. Individual(s) Responsible for Corrective Action Plan Elizabeth Fischer (Finance Director) Jenna deLumeau (Controller) Anticipated Completion Date: This has been completed.
Finding 2022-004 Deadline for Federal Single Audit – Reporting – Noncompliance and Material Weakness in Internal Control over Compliance Planned Corrective Actions: The Finance Department is working to establish internal deadlines to ensure the financial statements are audited within the appropriate...
Finding 2022-004 Deadline for Federal Single Audit – Reporting – Noncompliance and Material Weakness in Internal Control over Compliance Planned Corrective Actions: The Finance Department is working to establish internal deadlines to ensure the financial statements are audited within the appropriate reporting deadlines. The department is aware that the FY23 financial statements will also be faced with this finding, but is shifting staff duties to ensure the FY24 financial statements will be completed within the appropriate reporting deadlines. Individual(s) Responsible for Corrective Action Plan Elizabeth Fischer (Finance Director) Jenna deLumeau (Controller) Anticipated Completion Date: The department has developed internal deadlines to ensure the FY24 financial statements will be completed within the appropriate reporting deadlines. This has been completed.
2022-006 a. Name of Contact Person Responsible for Corrective Action: Jeff Burks, General Manager, and Cynthia Fowler, Office Manager & Comptroller Phone Number: (256) 356-8622 b. Corrective Action Planned: The Water Works and Gas Board of the City of Red Bay will ensure payments under reimbursable ...
2022-006 a. Name of Contact Person Responsible for Corrective Action: Jeff Burks, General Manager, and Cynthia Fowler, Office Manager & Comptroller Phone Number: (256) 356-8622 b. Corrective Action Planned: The Water Works and Gas Board of the City of Red Bay will ensure payments under reimbursable grants are made prior to reimbursement requests. c. Anticipated Completion Date: Immediately
Finding 393928 (2022-001)
Significant Deficiency 2022
The City will prepare for financial statement audits to ensure are completed timely.
The City will prepare for financial statement audits to ensure are completed timely.
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