Corrective Action Plans

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Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 –...
Tyler Luce, Executive Vice President & CFO, respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting firm: Maner Costerisan, P.C. 2425 E. Grand River Ave, Ste 1 Lansing, MI 48912 Audit period: October 1, 2024 – September 30, 2025 The findings from the September 30, 2025 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2025-001 Recommendation: The entity should design and implement stronger internal controls over project funds, including enhanced segregation of duties, documented procurement procedures, conflict-of-interest monitoring, and periodic independent review of project expenditures to ensure compliance with Uniform Guidance. Management Comments: We agree with the facts and circumstances of this finding. Management has taken corrective action in response to this finding. The employees involved are no longer employed in connection with the project, and the matter was reported to the HUD Office of Inspector General. Management has reviewed and strengthened the project's controls over conflict-of-interest monitoring and enforcement of existing time-clock policies. In addition, we have and will continue to perform independent reviews of project expenditures to ensure compliance with Uniform Guidance.
Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District’s contact person: Renata Sorna, Assistant Director of Business, Finance and Operations North Kitsap School...
Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District’s contact person: Renata Sorna, Assistant Director of Business, Finance and Operations North Kitsap School District 18360 Caldart Ave NW Poulsbo, WA 98370 Tel: (360) 396-3011 Corrective action the auditee plans to take in response to the finding: We have reinstated the semi-annual and annual certification process requiring signatures from both employees and their direct supervisors to verify the work completed after that fact. In addition, we are developing a procedure for policy 6106: Allowable Costs for Federal Programs. Anticipated date to complete the corrective action: Reinstating the semi-annual certifications has already been completed for the 2025-2026 school year. We anticipate finalizing the procedure by the end of school year 2025-2026.
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: GTI management will develop and implement a formal process to track and report subrecipient invoices that have been received but n...
Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: GTI management will develop and implement a formal process to track and report subrecipient invoices that have been received but not yet paid. This includes: • Standardized Weekly Report: A report generated and reviewed weekly by Purchasing and Accounts Payable to identify, prioritize, and resolve outstanding actions for timely payment (Control Owners: AP Manager & Purchasing Manager; Implementation: September 30, 2026) • Weekly Invoice Review: The AP Specialist responsible for subrecipient invoices will review weekly to ensure invoices are prioritized and processed, with delays or exceptions escalated promptly to the AP Manager (Frequency: Weekly; Implementation: September 30, 2026) • Periodic Compliance Monitoring: Management will perform ongoing reviews of subrecipient invoice payment activity to monitor compliance with the 30-day payment requirement and adherence to internal policies (Control Owners: AP Manager & Program Revenue Operations; Frequency: Monthly with quarterly oversight; Implementation: Ongoing, formalized by September 30, 2026) Contact person responsible for corrective action: Naté Hoover, Program Revenue Operations Anticipated Completion Date: 9/30/2026
June 12, 2026 Response to Single Audit Finding 2025-001 Finding: Program: ALN 93.788 – State Opioid Response Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include ...
June 12, 2026 Response to Single Audit Finding 2025-001 Finding: Program: ALN 93.788 – State Opioid Response Criteria: As required by 2 CFR 200.332, the pass-through entity must communicate specific information to subrecipients, as applicable. Condition: Contracts with subrecipients did not include portions of required disclosures. Cause/Effect: Inadequate internal controls over compliance. Select contracts were not in compliance with 2 CFR 200.332. Management agrees with this finding and has already implemented measures to ensure that it is not repeated. The additional step of having the Finance Department review contracts with federal dollars to ensure that the ALN in the contract is consistent with the ALN on the contract award. This policy is in place as of June 12, 2026. Matt Berg is responsible for implementing this corrective action.
2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditur...
2025-008 Auditor’s Recommendation: We recommend the organization strengthen its internal controls over federal financial reporting by establishing and documenting procedures requiring that all reports submitted to federal awarding agencies or pass-through entities be prepared using actual expenditures recorded in the accounting system. These procedures should include a reconciliation of reported amounts to the general ledger and supporting documentation prior to submission, as well as an independent review process to ensure reported information is accurate, complete, and compliant with Uniform Guidance requirements. Corrective Action: UCM will develop and implement written procedures requiring that all financial reports submitted to federal awarding agencies or pass-through entities are prepared using actual expenditures recorded in UCM’s accounting system. Reported amounts will be reconciled to the general ledger and supported by appropriate documentation before submission, including general ledger detail, payroll records, accounts payable records, allocation schedules, invoices, receipts, proof of payment, and other records supporting the reported costs. UCM will implement a federal financial reporting checklist to document preparation, reconciliation, and review each report. The checklist will require verification that reported costs agree to actual expenditures, are recorded in the correct reporting period, are charged to the correct federal award, are supported by documentation, and are consistent with award terms and Uniform Guidance requirements. A qualified individual independent of the report preparation process will review and approve reports before submission, and evidence of review will be retained. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Independent Reviewer (CEO, Finance Committee Chair, or another qualified reviewer) Anticipated Completion Date: December 31, 2026
2025-007 Auditor’s Recommendation: The entity should strengthen internal controls over TANF benefit payments by implementing procedures to ensure payments are identifiable by participant and reconciled to eligibility records. The entity should also establish controls to verify benefit calculations a...
2025-007 Auditor’s Recommendation: The entity should strengthen internal controls over TANF benefit payments by implementing procedures to ensure payments are identifiable by participant and reconciled to eligibility records. The entity should also establish controls to verify benefit calculations and ensure assistance is discontinued when eligibility expires, and maintain sufficient documentation to demonstrate compliance with program requirements. Corrective Action: UCM will strengthen internal controls over TANF benefit payments by implementing procedures to ensure payments are clearly identifiable by participant and reconciled to approved eligibility records before assistance is provided. Each payment will be supported by participant identification, eligibility approval, assistance type, approved amount, funding source, payment date, and supporting documentation. UCM has established TANF Eligibility Determination Guidelines, a List of Acceptable Documents, and an Assistance Agreement Form to support eligibility determinations and benefit payment documentation. Per VDSS guidance, once eligibility is established at the beginning of the program, a change in status during the participant’s stay does not disqualify the participant from receiving further services. Felony record documentation is not required in the participant file as felony record status is not part of the eligibility requirement per VDSS. Evidence of review and approval will be retained in the participant file. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Case Managers Shruti Jha, Senior Director of Finance Liya Tseye & Carmen Romero, Accountants Laura D’Ambrogi, Grants Manager Anticipated Completion Date: Substantially completed as of April 6, 2026. Ongoing payment review, eligibility monitoring, reconciliation, and supervisory review will continue during the program year.
2025-006 Auditor’s Recommendation: UCM should strengthen internal controls over TANF eligibility determinations by developing and implementing written procedures that clearly define the documentation required to support all TANF eligibility criteria. These procedures should require that participant ...
2025-006 Auditor’s Recommendation: UCM should strengthen internal controls over TANF eligibility determinations by developing and implementing written procedures that clearly define the documentation required to support all TANF eligibility criteria. These procedures should require that participant files include sufficient documentation supporting financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, compliance with applicable legal eligibility requirements, and work participation when applicable. In addition, the entity should implement a documented supervisory review and approval process to verify eligibility determinations and supporting documentation prior to the provision of assistance. The entity should also provide training to staff responsible for eligibility determinations to ensure they understand federal TANF documentation requirements and maintain complete and accurate participant files. Corrective Action: UCM will strengthen internal controls over TANF eligibility determinations by formalizing written procedures that clearly identify the documentation required to support each eligibility criterion before assistance is provided. The procedures will define required documentation for financial eligibility, citizenship or qualified alien status, TANF benefit history, household composition, applicable legal eligibility requirements, and work participation requirements when applicable. UCM reviewed and discussed the findings with the auditor, Senior Director of Finance, and Chief Program Officer. UCM also reviewed the Virginia Department of Social Services post-training materials on TANF Employment Advancement Eligibility Determination Training, and clarified identified areas of the findings with the Virginia Department of Social Services as they relate to the subrecipient signed contract. UCM designed new Screening Guidelines for incoming program participants, including a documented supervisory review and approval process, which were completed on April 16, 2026. The new screening guidelines require participant files to include sufficient documentation supporting eligibility determinations and require supervisory review before assistance is provided. A supervisor or designated reviewer will verify that the participant file contains the required eligibility documentation, that eligibility criteria have been met, and that the assistance is consistent with TANF requirements, VDSS guidance, the subrecipient contract, and program guidelines. UCM reviewed and trained staff on the new eligibility screening guidelines, acceptable documents, and income requirements on April 28, 2026. Staff responsible for TANF eligibility determinations, case management, direct assistance, and grant compliance will continue to receive training as needed to ensure they understand TANF documentation requirements and maintain complete and accurate participant files. UCM will also periodically monitor participant files to confirm continued compliance and identify any additional training or process improvements needed. Responsible for Corrective Action: Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Case Managers VDSS Program Consultant Anticipated Completion Date: Substantially completed as of April 28, 2026. Ongoing implementation, supervisory review, staff training, and monitoring will continue during the program year.
2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedu...
2025-004 Auditor’s Recommendation: UCM should formalize and document internal control procedures over Federal award expenditures, including documented review and approval processes to ensure compliance with Uniform Guidance. Corrective Action: UCM will formalize and document internal control procedures over Federal award expenditures to ensure costs charged to Federal awards are allowable, allocable, reasonable, properly approved, and adequately supported in accordance with Uniform Guidance. Written procedures will be developed for expenditure review and approval, including documentation of business purpose, budget availability, cost eligibility under the award terms, proper account coding, funding source, supporting documentation, and evidence of approval. UCM will also strengthen controls over direct assistance to client expenditures by requiring documentation of client eligibility, assistance type, amount approved, funding source, program approval, finance review, and evidence of payment. Direct assistance expenditures will be reviewed to ensure they are allowable under the Federal award, consistent with program requirements, properly coded, and adequately supported before payment or reimbursement is processed. UCM will also implement a Federal award expenditure checklist or similar review tool to document review before expenditures are paid, posted, or reported. The checklist will include review of allowability, allocability, reasonableness, budget availability, funding source, supporting documentation, approval, and compliance with applicable Federal award requirements. For direct assistance to clients, the checklist will also confirm client eligibility, approved assistance type, required case documentation, and evidence of payment. Staff responsible for Federal award expenditures, direct client assistance, grant accounting, accounts payable, and program budget management will receive training on the updated procedures and Uniform Guidance requirements. Supporting documentation and evidence of review and approval will be retained with the expenditure records. Responsible for Corrective Action: Shruti Jha, Senior Director of Finance Gina Macanlalay, Director of Family Achievement Program Laura D’Ambrogi, Grants Manager Anticipated Completion Date: December 31, 2026
The College acknowledges the finding and agrees that required notifications to students must be provided prior to the disbursement of Title IV funds. The condition resulted from the absence of formal procedures and controls to ensure timely notification and documented review. The College is in the p...
The College acknowledges the finding and agrees that required notifications to students must be provided prior to the disbursement of Title IV funds. The condition resulted from the absence of formal procedures and controls to ensure timely notification and documented review. The College is in the process of implementing enhanced controls over student notification procedures. Formal policies and procedures will be established to ensure that notifications are generated and delivered prior to disbursement, including defined timing, content, and documentation requirements. The College will engage third-party consultants and implement system enhancements to improve the timing and sequencing of notifications and disbursements. In addition, the College will implement monitoring procedures, including tracking of notification and disbursement dates and documented supervisory review, to ensure compliance with timing requirements and timely identification and resolution of exceptions. Accounting, independent of the Office of Financial Aid, will perform a final review to verify that notifications are issued prior to disbursement and that established procedures are consistently followed. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that required notifications are provided timely and in accordance with federal requirements, and to prevent recurrence
The College acknowledges the finding and agrees that reporting to the Common Origination and Disbursement (COD) system must be accurate, complete, and submitted within required timeframes. The condition resulted from the absence of formal procedures and controls to validate key data elements and mon...
The College acknowledges the finding and agrees that reporting to the Common Origination and Disbursement (COD) system must be accurate, complete, and submitted within required timeframes. The condition resulted from the absence of formal procedures and controls to validate key data elements and monitor reporting timeliness. The College is in the process of implementing enhanced controls over COD reporting. The Office of Financial Aid will develop and formalize written procedures governing the reconciliation of awarding and disbursement activity with COD reporting, including defined responsibilities, documentation standards, and review requirements. The College will also engage third-party consultants to review current processes and assist with system enhancements. System configuration and process improvements will be implemented to support the automation of award and disbursement reporting through PeopleSoft. The Office of Financial Aid will implement quality control measures, including systematic validations and documented supervisory review, to ensure accuracy, consistency, and compliance in COD reporting. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that COD reporting is accurate, timely, and properly controlled, and to prevent recurrence.
Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and C...
Description of Finding: Criteria or Specific Requirement: The lead agencies, who are subrecipients under the Federal Awards, are required to have clients sign the Form 502045-A CSFP Sub-Agency Monthly Participant Sign-in Sheet to self-declare program eligibility before food is disbursed. Issue and Cause: There were two instances out of 40 distributions tested where this signoff was not completed. Due to the hectic environment at the lead agencies during food distribution day, oversights have occurred when obtaining the required client signoff. Statement of Concurrence or Nonconcurrence: PARF management has reviewed the 2025-001 finding and concurs with the recommendations as stated. Corrective Action: PARF has an extensive training process in place for lead agencies, in relation to grant award compliance requirements, which includes the provision of training manuals and monthly phone calls to review matters. In addition, PARF provides updates to the lead agencies as new or amended requirements are enacted. Further, PARF does periodic reviews of the lead agencies and completes the biennial review Form 502035 CSFP Management Evaluation. PARF will continue to reiterate the required signoff process with the lead agencies during phone calls, training session and reviews. In addition for FY 2026 PARF will be conducting a mandatory webinar to ensure all the lead agencies are understanding the procedure and why it is important for 100 percent accuracies -https://docs.google.com/presentation/d/1YZgcq7SY4DmvhYrKZE8sp-NDhpuzn827PZDZ0xAKDw/edit?usp=sharing
AUDITEE'S CORRECTIVE ACTION PLAN June 23, 2026 U. S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Prairie Opportunity, Inc., respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting form: Brown, Ewing & Co., P.A. 30...
AUDITEE'S CORRECTIVE ACTION PLAN June 23, 2026 U. S. DEPARTMENT OF HEALTH AND HUMAN SERVICES Prairie Opportunity, Inc., respectfully submits the following corrective action plan for the year ended September 30, 2025. Name and address of independent public accounting form: Brown, Ewing & Co., P.A. 308 Highland Park Cove, Ridgeland, MS 39157. Audit period: Year Ended September 30, 2025. The findings from the September 30, 2025 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. Section 1 of the schedule, Summary of Audit's Results, does not include findings and is not addressed. Section 3: Findings and Questioned Costs - Major Federal Award Program Audit FINDING 2025-001 FAILURE TO SUBMIT THE DATA COLLECTION FORM AND AUDIT REPORT TO THE FEDERAL AUDIT CLEARINGHOUSE TIMELY Condition: The auditee did not submit the required Data Collection Form (DCF) and reporting package to the Federal Audit Clearinghouse (FAC) within the timeframe mandated by federal regulations. The submission was made after the required deadline of June 30, 2025. Action Taken: Manangement of Prairie Opportunity, Inc. will implement internal administartive contol procedures and policies to ensure that the data collection form and the annual audit is submitted to the federal clearinghouse in a timely manner. If you have any questions regarding this plan, please call me at (662) 323-3397. Sincerely, Tomeka Rhine Tomeka Rhine, Executive Director
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the subrecipient monitoring compliance requirements under the Twenty-First Century Community Learning Centers program (Assistance Listing No. 84.287). The...
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the subrecipient monitoring compliance requirements under the Twenty-First Century Community Learning Centers program (Assistance Listing No. 84.287). The PRDE recognizes that the subrecipient monitoring procedures established in the “Manual de Programa 21st CCLC” are in place; however, the Department acknowledges that the documentation supporting compliance with those procedures was not made available to the auditors during the review. The PRDE is committed to strengthening its documentation practices and internal oversight mechanisms to ensure full compliance with 2 CFR § 200.332(f) and other applicable federal requirements. The PRDE further acknowledges that this is a repeat finding (prior year Finding 2024-012) and accepts the auditors’ recommendation to establish and implement formal procedures to obtain and review subrecipient audit reports in a timely manner, follow up on relevant audit findings, and maintain documentation of all monitoring activities performed IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Luis M. Oppenheimer Rosario Federal Program Coordinator 21stCCLC
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the procurement and suspension and debarment compliance requirements under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173)....
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the procurement and suspension and debarment compliance requirements under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173). The PRDE respectfully clarifies that the Department does have established processes and internal controls related to procurement activities, including those applicable to federally funded programs such as IDEA. The procurement procedures in place are consistent with applicable federal regulations, including 2 CFR §200.317 and 2 CFR §200.318(a)(i), as well as applicable Commonwealth of Puerto Rico laws and regulations. However, the PRDE acknowledges that the timely delivery of procurement documentation and the organization of contract records for IDEA-funded programs require improvement. The deficiencies noted are attributable primarily to delays in making documentation available to the auditors within the requested timeframes, and to the need for improved coordination between the IDEA program office and the Purchase Department of PRDE, which handles certain quotation processes IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Enid Diaz Nieves Executive Director III Administration and Transportation Unit Alayra Figueroa Gonzalez Associate Secretary for Special Education
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) accepts the finding identified by the auditors regarding the incorrect coding of five (5) reimbursement payments for equipment purchases in account E6170 (Donations and Contributions to Private Entities), rather than in th...
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) accepts the finding identified by the auditors regarding the incorrect coding of five (5) reimbursement payments for equipment purchases in account E6170 (Donations and Contributions to Private Entities), rather than in the appropriate E5000-series accounts, and the omission of said assets from the institutional property register. The PRDE has initiated the necessary corrective actions to address this deficiency. Specifically, all assets included within the affected reimbursement transactions have been identified, and a detailed inventory is being prepared in which each asset is classified according to the capitalization criteria established in the Restart Program Fiscal Process Guide (unit cost equal to or greater than $500.00 and useful life greater than two (2) years). This inventory distinguishes between capitalizable equipment (E5000 series) and non-capitalizable equipment (E4414), in accordance with applicable regulatory requirements. Once finalized, the inventory file will be submitted to the PRDE’s Office of Property for review and mass upload into the institutional property register, ensuring that all assets acquired with Restart Program funds are properly recorded under PRDE ownership, in compliance with Section 102(h)(3) of the 2018 Hurricane Relief Act and the requirements of 2 CFR §200.302(b)(3)(4). IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Edgar Delgado Serrano Interim Director of Federal Affairs Office
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed / Allowable Costs/Cost Principles compliance requirement under the IDEA Special Education Cluster (Assistance Listing ...
VIEWS OF RESPONSIBLE OFFICIALS The Puerto Rico Department of Education (PRDE) acknowledges the audit findings presented by the auditors regarding the Activities Allowed or Unallowed / Allowable Costs/Cost Principles compliance requirement under the IDEA Special Education Cluster (Assistance Listing Nos. 84.027 and 84.173). The PRDE recognizes that certain deficiencies identified by the auditors relate to inconsistencies in supporting documentation, documentation retained in departmental systems, and the need to strengthen administrative controls over the documentation supporting disbursements for private educational and therapy services. The Department further acknowledges opportunities to improve the consistency of information maintained in supporting schedules, contract documentation, proposals, and other records used during the invoice review and payment process. The PRDE respectfully clarifies that, in several instances identified during the audit, the questioned conditions were attributable to documentation inconsistencies, system-generated reporting errors, or documentation that supports the transactions but was not maintained or presented in a standardized manner during the audit process. Specifically, the Department notes that adjustment reports recorded in the financial system agreed with the disbursement vouchers despite errors identified in certain Excel master schedules; that invoice validations performed by the Centers are based on the corresponding "Carta de Aprobación de Consulta de Ubicación," which establishes the approved services and applicable rates for each student; and that federal regulations authorize IDEA Part B (ALN 84.027) funds to be used for eligible children ages 3 through 21, including expenses otherwise allowable under the Preschool Grant (ALN 84.173), as permitted under 34 CFR §300.202(a). With respect to students identified as over 21 years of age, the PRDE conducted an individual review of the affected student records and determined that the population includes students who exited the program at age 21 as well as students for whom documentation exists supporting the continuation of services through individualized educational determinations, transition planning activities, or compensatory educational services. The Department recognizes, however, that documentation supporting these determinations was not maintained in a standardized manner that facilitated timely retrieval during the audit. The PRDE further acknowledges that improvements are needed to ensure that procurement documentation, contract amendments, proposals, invoice support, Excel master schedules, and student-level supporting documentation are complete, accurate, consistent, and readily available for audit and monitoring purposes. Accordingly, the Department accepts the auditors' recommendations and is committed to implementing corrective actions designed to strengthen internal controls, standardize documentation practices, improve supervisory review procedures, and enhance coordination among the responsible program and administrative units IMPLEMENTATION DATE Fiscal Year 2026-2027 RESPONSIBLE PERSON Enid Diaz Nieves Executive Director III Alayra Figueroa Gonzalez Associate Secretary for Special Education
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2025-002: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMM...
FINDINGS - MAJOR FEDERAL AWARD PROGRAM AUDIT Department of Housing and Urban Development Finding, 2025-002: Major Programs: Capital Advance Program, Federal Assistance Listing Number 14.U01 and Section 8 New Construction and Substantial Rehabilitation, Federal Assistance Listing Number 14.182 RECOMMENDATION The auditor recommends moving some of the Project’s funds to other banks to ensure all bank account balances at each bank remain below the FDIC limit. ACTION TAKEN Carrasquillo Management LLC acknowledges the finding regarding the Project’s bank balances exceeding the Federal Deposit Insurance Corporation (FDIC) insured limit of $250,000. Corrective Actions: 1. Risk Mitigation Plan Carrasquillo Management LLC is in the process of restructuring the Project’s banking arrangements to ensure that no single institution holds more than the FDIC-insured limit of $250,000 per ownership category. This will be completed shortly after the refinance of the mortgage takes place in the next few months. Westfield Bank also uses Positive Pay systems to avoid any fraud to occur on the accounts. Any transactions coming out of the units have to be entered prior to being made and have to be approved. 2. Diversification of Funds The Project will open additional accounts with other FDIC-insured financial institutions and transfer excess funds accordingly. This will help safeguard assets and reduce exposure in the unlikely event of bank failure. 3. Ongoing Monitoring Management has implemented a monthly monitoring protocol to review account balances and ensure ongoing compliance with FDIC limits. This process includes scheduled reviews by the finance team to confirm that no account exceeds the insured threshold. 4. Policy Update Internal financial policies are being updated to include FDIC compliance requirements, ensuring that any future account openings or large fund deposits are properly reviewed and managed. Carrasquillo Management LLC is committed to protecting the financial assets of the Project and ensuring full compliance with HUD requirements and FDIC insurance guidelines.
CORRECTIVE ACTION PLAN Name of auditee: Bellflower Oak Street Manor Name of audit firm: Propp Christensen Caniglia LLP Period covered by the audit: October 1, 2024 through September 30, 2025 CAP prepared by: Name: Sean Calendar Position: Director of Accounting Telephone: (916) 357-5300 Comments: Man...
CORRECTIVE ACTION PLAN Name of auditee: Bellflower Oak Street Manor Name of audit firm: Propp Christensen Caniglia LLP Period covered by the audit: October 1, 2024 through September 30, 2025 CAP prepared by: Name: Sean Calendar Position: Director of Accounting Telephone: (916) 357-5300 Comments: Management agrees with the 2025-001 – 2025-003 findings. Actions: Management has agreed to enhance processes, controls, and personnel training under the newly engaged property management company to ensure ongoing compliance with HUD regulations. Additionally, management has agreed to deposit $9,912 into the replacement reserve account to fully fund the current-year requirement and transfer $44,273 into the residual receipts account to address the 2024 surplus cash requirement.
Management Response AIHEC concurs with this finding. AIHEC is formalizing its subrecipient monitoring procedures by implementing a standardized subrecipient risk assessment template to be completed prior to issuing any subaward, evaluating factors including the subrecipient's prior audit history, fi...
Management Response AIHEC concurs with this finding. AIHEC is formalizing its subrecipient monitoring procedures by implementing a standardized subrecipient risk assessment template to be completed prior to issuing any subaward, evaluating factors including the subrecipient's prior audit history, financial management capacity, and program complexity. AIHEC will maintain a subrecipient monitoring file for each active subaward documenting the risk assessment, periodic review of financial and performance reports, and follow-up on any deficiencies identified. AIHEC will also confirm and document, for each subrecipient expending $1,000,000 or more in federal awards during its fiscal year, that a Single Audit (or other audit required under Subpart F) was obtained and reviewed. In addition, AIHEC's new grant management software, Grant Vantage, includes subrecipient monitoring functionality, including a subrecipient portal that will allow subrecipients to log in directly and a centralized tracking of subrecipient reporting schedules. This subrecipient monitoring module has not yet been implemented, as AIHEC is currently focused on rolling out the core grants management functionality of the system; however, AIHEC expects to roll out the subrecipient monitoring module by September 30, 2026, which is expected to drastically improve AIHEC's subrecipient monitoring and oversight capabilities. The Director of Finance will be responsible for ensuring monitoring files are complete and current in the interim, with a semiannual internal review of all active subawards. Estimated Completion Date September 30, 2026 Responsible Party Angela Toles, Grants & Compliance Manager, with oversight by Diane Robertsy, Director of Finance
Management Response AIHEC concurs with this finding. The delays resulted from insufficient monitoring of reporting deadlines across multiple federal awards managed by different program staff, compounded by turnover in the Grants Management function during the fiscal year. AIHEC has hired a full-time...
Management Response AIHEC concurs with this finding. The delays resulted from insufficient monitoring of reporting deadlines across multiple federal awards managed by different program staff, compounded by turnover in the Grants Management function during the fiscal year. AIHEC has hired a full-time Grants & Compliance Manager, who joined the organization in December 2025 and has direct responsibility for tracking and ensuring timely submission of all federal financial and performance reports. In addition, AIHEC implemented a new grant management software system, Grant Vantage, beginning in April 2026. Grant Vantage maintains reporting schedules for each federal award, including the applicable lead times for RPPR, SF-425, and FFATA subaward reporting, and serves as a centralized repository for completed reports and submission documentation. Grant Vantage is continuing to be rolled out for full use across the organization, with the Grants & Compliance Manager overseeing adoption by program staff and the Director of Finance providing final review and submission sign-off. AIHEC will also continue to provide refresher training to program and finance staff on FFATA subaward reporting thresholds and procedures as the system rollout is completed. Estimated Completion Date Implemented April 2026; full organization-wide rollout by September 30, 2026. Responsible Party Angela Toles, Grants & Compliance Manager, with oversight by Diane Robertsy, Director of Finance.
Finding 2025-010: Reporting – FFATA Subawards Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will establish sufficient procedures or oversight controls to identify first-tier subawards subject to FFATA reporting requireme...
Finding 2025-010: Reporting – FFATA Subawards Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will establish sufficient procedures or oversight controls to identify first-tier subawards subject to FFATA reporting requirements and ensure the required subaward information was submitted timely. Additionally, personnel responsible for grant administration were not sufficiently aware of the applicable FFATA reporting requirements Implementation dates: July 31, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-008: Special Tests and Provisions – Revenue Diversion Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will draft and maintain a formal written policy or documented procedure to ensure airport-generated revenue...
Finding 2025-008: Special Tests and Provisions – Revenue Diversion Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will draft and maintain a formal written policy or documented procedure to ensure airport-generated revenues are used only for allowable airport-related purposes in accordance with federal revenue-use restrictions. Implementation dates: July 31, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-007: Reporting – FAA Form 5100-127 Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will enhance its existing reconciliation and review procedures by requiring documented tie-outs of FAA Form 5100-127 amounts t...
Finding 2025-007: Reporting – FAA Form 5100-127 Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will enhance its existing reconciliation and review procedures by requiring documented tie-outs of FAA Form 5100-127 amounts to the general ledger, retention of supporting documentation for all reported amounts, and evidence of supervisory review prior to submission. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-002: Reporting – HUD 50058 Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: Management acknowledges that the filings with HUD were not timely. Staff will work to ensure filings take place within 60 days of the effective dat...
Finding 2025-002: Reporting – HUD 50058 Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: Management acknowledges that the filings with HUD were not timely. Staff will work to ensure filings take place within 60 days of the effective date. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Provide funder-led training sessions for management and staff, maintain current budget tracking incorporated federal program compliance into relevant staff performance evaluations, implement a dual-storage documentation methodology combining a shared drive and a document management system (DMS) and ...
Provide funder-led training sessions for management and staff, maintain current budget tracking incorporated federal program compliance into relevant staff performance evaluations, implement a dual-storage documentation methodology combining a shared drive and a document management system (DMS) and update the Finance Manual.
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