Corrective Action Plans

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FINDING 2022-001 Contact Person Responsible for Corrective Action: Yvonne Hoffmaster Contact Phone Number: 219 873-1404 Ext. 2004 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To bring the City into compliance with effective internal controls to en...
FINDING 2022-001 Contact Person Responsible for Corrective Action: Yvonne Hoffmaster Contact Phone Number: 219 873-1404 Ext. 2004 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: To bring the City into compliance with effective internal controls to ensure requirements related to the grant agreement and the Suspension and Debarment are satisfied, the City has created a checklist, Exhibit A, that contain a sign off by the Department Head and Board of Works as necessary. Anticipated Completion Date: The checklist will begin to be utilized on May 1, 2023.
Finding: 2022-004 Name of Contact Person: Jeremy Christiansen, Superintendent Corrective Action: The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews the schedul...
Finding: 2022-004 Name of Contact Person: Jeremy Christiansen, Superintendent Corrective Action: The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews the schedule of expenditures of federal awards and approves all adjustments. Proposed Completion Date: Immediately
Finding 2022-001: Gramm-Leach Bliley Act (GLBA) Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk...
Finding 2022-001: Gramm-Leach Bliley Act (GLBA) Recommendation: The University should perform and document an annual risk assessment to determine the University's specific risks relevant to protecting consumer nonpublic personal information. At a minimum, the University should have at least one risk statement aligned or referenced to each of the three required areas noted in the GLBA law at 16 CFR 314.4 (b). Finally, the University should identify and document at least one safeguard (i.e., control) for each of the risks identified and document in the risk assessment. Each control should be aligned or referenced to the risk(s) to which the safeguard applies. Action Taken: The University has taken the following steps to address the risks identified during the audit: 1. Employee Training and Management a. The University deployed the Knowbe4 Security Awareness Program to all full time staff. The program provides training for managing user data and email messages. To date the University has distributed two campaigns to combat email phishing attempts. 2. Information systems, including network and software design, as well as information processing, storage, transmission and disposal a. The University has formulated a digital transformation strategy to reduce on premises systems and applications. All the critical business systems are hosted at a colocation or are SaaS solutions. b. The University performs backups of all on premises systems using technology that creates immutable storage. c. The University leverages the cybersecurity experience of resellers and manufacturers to ensure all core network technology is installed and configured to minimize any attack surface. 3. Detecting, preventing, and responding to attacks, intrusions, or other systems failures and document safeguards for identified risks as required by the Gramm-Leach Bliley Act (GLBA). a. The University has deployed a redundant pair of Fortinet Advanced Firewalls to monitor and block traffic with suspicious payloads. b. The University has updated to the latest version of Microsoft Advanced Threat Defender to serve as optimal end point protection for managing email traffic. c. The University contracted with the Cybersecurity and Infrastructure Security Agency (CISA) to perform vulnerability scans and penetration testing. The IT department evaluates the weekly reports and remediates highlighted deficiencies. d. The University has removed all admin rights from school managed computers, eliminating the ability to install local software. e. The University has deployed an updated VPN client to all school managed computers providing a secure tunnel for access network services. f. The University manages web browsers of all school managed computers. The University will take the results of the security assessment that was completed and draft the GLBA policy in conformity with the DOE requirements by June 2023. Responsible Individual for Corrective Action: Chief Information Officer ? Gregg Chottiner Anticipated Completion Date: June 30, 2023
Tri-County North will make sure that we follow the proper controls on wage requirements and standards to make sure that the contractor is in compliance with prevailing wage rate.
Tri-County North will make sure that we follow the proper controls on wage requirements and standards to make sure that the contractor is in compliance with prevailing wage rate.
Finding: Reports of commodity activity were submitted to the pass-through entity that were not consistent with the underlying commodities records of RKCAA. Corrective Response: RKCAA management agrees with the finding. RKCAA is updating and revising policies and procedures, including additional sup...
Finding: Reports of commodity activity were submitted to the pass-through entity that were not consistent with the underlying commodities records of RKCAA. Corrective Response: RKCAA management agrees with the finding. RKCAA is updating and revising policies and procedures, including additional supervision, training and reconciliations to better track and report the commodities activity to the pass-through entity. This process is expected to be completed by June 30, 2023. 06/30/2023 CFO Laura Brown 262-637-8377 ext 104
Finding: 2022-002 ? Material Weakness, Internal Control Over Compliance, Eligibility and Special Tests ? ALN 93.778 Medicaid Cluster Personnel Responsible for Corrective Action: Pam Noonan, Mesa County Finance Director Anticipated Completion Date: 09/29/2023 Cause: Internal controls over the el...
Finding: 2022-002 ? Material Weakness, Internal Control Over Compliance, Eligibility and Special Tests ? ALN 93.778 Medicaid Cluster Personnel Responsible for Corrective Action: Pam Noonan, Mesa County Finance Director Anticipated Completion Date: 09/29/2023 Cause: Internal controls over the eligibility determinations are the responsibility of management. Mesa County did not follow its formal process in place for reviews of eligibility determinations. View of Responsible Officials and Planned Corrective Action: Mesa County agrees with the finding and has put together a corrective action plan for the finding. Corrective Action Plan: Mesa County was aware that they were not meeting their internal or Health Care Policy and Financing (HCPF) and Colorado Department of Human Services (CDHS) review requirements for 2022. Mesa County created a new quality control case reviews policy and procedure effective June 2023. The new policy included internal, HCPF and CDHS review requirement for all programs. In addition, MCDHS quality assurance team will be providing oversight using a tool they create to ensure review requirements are being met for each program.
Finding: 2022-001 ? Material Weakness, Compliance and Internal Control over Compliance, Subrecipient Monitoring ? ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Pam Noonan, Mesa County Finance Director Anticipated Completion Date: 12/31/20...
Finding: 2022-001 ? Material Weakness, Compliance and Internal Control over Compliance, Subrecipient Monitoring ? ALN 21.027 Coronavirus State and Local Fiscal Recovery Funds Personnel Responsible for Corrective Action: Pam Noonan, Mesa County Finance Director Anticipated Completion Date: 12/31/2023 Cause: Mesa County embarked on the usual funding methodology of capitalizing on private investments in our low-income community, whereby a much-needed training facility and daycare is nonexistent, by utilizing New Market Tax Credits. Due to the complexity of the arrangement and the lack of adequate information provided by consultants, determinations and documentation of the subrecipient did not occur prior to granting funds to the recipient organization. View of Responsible Officials: Mesa County agrees with the finding and has put together a corrective action plan for the finding. Planned Corrective Action: Mesa County will develop procedures and educate County departments in order to ensure compliance with the grant management policy and subrecipient language included therein. Mesa County will formally communicate with the subrecipient organization the necessary Federal award identifiers and expected continued compliance and required documentation during the performance period.
Finding 2022-002 Activities Allowed or Unallowed and Allowable Costs/Cost Principles A material weakness in internal control over compliance was issued related to activities allowed or unallowed and allowable costs/cost principles for the Advocate Aurora Health (AAH) Disaster Grant ? Public Assista...
Finding 2022-002 Activities Allowed or Unallowed and Allowable Costs/Cost Principles A material weakness in internal control over compliance was issued related to activities allowed or unallowed and allowable costs/cost principles for the Advocate Aurora Health (AAH) Disaster Grant ? Public Assistance (Presidentially Declared Disasters). The Organization?s internal controls were not suitably designed to retain all supporting documentation over their review and approval of FEMA federal expenditures. Management did not retain supporting documentation to support the inventory usage reports used in the development of the FEMA expenditures. Management will ensure that a comprehensive review, approval, and document retention process is applied consistently for any future FEMA claims. The FEMA personal protective equipment (PPE) claim covered two years, which are 2020 and 2021. As noted in the audit, the Organization engaged a third party to perform a physical inventory of supplies at December 31, 2020 which included the PPE claimed in the SEFA obligation. The physical inventory was reconciled to the inventory management system. The audit selected a sample inventory count performed by third party and agreed the inventory counts back to the third party records noting no exceptions. A physical inventory was not performed at December 31, 2021. Due to the COVID pandemic, there were unusual circumstances that precluded an annual physical inventory in 2021, due to the easy transmission of COVID-19, by breathing in air carrying droplets or aerosol particles that contain the SARS-CoV-2 virus when close to an infected person or in poorly ventilated spaces with infected persons. Noting there were no system changes to the inventory system during 2021, we relied on the prior year audits and internal control review of the inventory system to provide comfort for the Organization for reliance on the inventory usage for this FEMA claim. In addition to relying on past inventory documented audit controls, the Organization routinely reviews the supply expense generated from the inventory system. This will be implemented effective October 1, 2023. Nan Nelson, SVP Region Chief Financial Officer, is responsible for this Corrective Action Plan.
Finding 2022-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles A material weakness in internal control over compliance was issued related to activities allowed or unallowed and allowable costs/cost principles for the R&D Cluster grant agreements of Advocate Aurora Health (the ...
Finding 2022-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles A material weakness in internal control over compliance was issued related to activities allowed or unallowed and allowable costs/cost principles for the R&D Cluster grant agreements of Advocate Aurora Health (the Organization). Charges of salaries and wages to the R&D Cluster were not consistently reviewed by a knowledgeable individual or not certified timely. In addition, certain individuals? effort certification did not account for 100% of their effort (R&D and institutional). This is a repeat finding (2021-002). The Office of Sponsored Research (OSR) committed in the 2020 Corrective Action Plan to implement a paper format effort certification process beginning March 2022. This process was fully implemented by the end of fiscal 2022. Also in 2022, Advocate Aurora Research Institute employees were transferred and integrated under one financial system. The integration of this system supports the monitoring of 100% of total effort. The OSR will also continue to utilize a paper effort certification process. The OSR team will generate effort certification form, distribute the effort certification form to the appropriate team member for manual or electronic signature and obtain a secondary approval signature from an individual who has first-hand knowledge of the team member's activities. All completed effort certification forms will be verified and initialed by a third individual. Effort certification logs will be maintained to ensure that all effort certifications are completed within 30 days. Completed effort certification forms will be maintained within OSR. Sarah Long, Director Sponsored Research, is responsible for this Corrective Action Plan.
Program: Airport Improvement Program Compliance: N ? Special Tests and Provisions Finding Type: Compliance and Internal Control Agency: Department of Transportation (DOT)/Federal Aviation Administration (FAA) Internal Control Impact: Significant Deficiency Finding: The City utilizes 745,190 square f...
Program: Airport Improvement Program Compliance: N ? Special Tests and Provisions Finding Type: Compliance and Internal Control Agency: Department of Transportation (DOT)/Federal Aviation Administration (FAA) Internal Control Impact: Significant Deficiency Finding: The City utilizes 745,190 square feet of land owned by the Aviation Department for the City?s Fire Department and Police Station serving the north Kansas City community including the Kansas City airport. The City pays ground rent of $0.168 per square foot per year based on a rate study done in 2003. Status: Corrective action plan in progress Corrective Action Plan: Fair and reasonableness of the rental rate: Upon completion of the New Terminal the Department will undertake either a Land Use Survey or a Market Rate Study to determine if our leased property is competitively priced. The Aviation Department has placed in FY24 budget a placeholder for a Market Study contract. Person(s) Responsible for Implementation: Fred O?Neill, Aviation Department Fiscal Officer, Telephone: (816) 243-3201; Email: Fred_ONeill@kcmo.org Implementation Date: Fair and reasonableness of the rental rate will be reviewed upon completion of the new terminal.
Program: Community Development Block Grants/Entitlement Grants Compliance: J-Program Income Finding Type: Compliance and Internal Control Agency: Department of Housing and Urban Development (HUD) Internal Control Impact: Material Weakness Finding: The City hired a third party to service single famil...
Program: Community Development Block Grants/Entitlement Grants Compliance: J-Program Income Finding Type: Compliance and Internal Control Agency: Department of Housing and Urban Development (HUD) Internal Control Impact: Material Weakness Finding: The City hired a third party to service single family home loans made with federal funds from this grant. The City did not maintain a listing or monitor the loans originated under this grant. Accordingly, the City cannot reconcile the loan servicer?s accounting reports to City records. Although the City indicated that they have other sources of program income, the City does not have a system which identifies other sources of program income. Status: Corrective action plan in progress Corrective Action Plan: The City has obtained information from the third-party loan servicer which will allow for the tracking and confirmation of existing loans with the goal of taking a more active role in the management of the portfolio including making decisions for write-off of non-performing balances and those where the cost of servicing the loan exceeds the loan payments. Person(s) Responsible for Implementation: Pearline McFall, Housing Department Fiscal Officer, Telephone: (816) 513-8432; Email: Pearline.McFall@kcmo.org Implementation Date: Ongoing
2022-002 Internal Controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number: 21.027 Recommendation: The Organization should develop writ...
2022-002 Internal Controls over Schedule of Expenditures of Federal Awards Preparation (Material Weakness) Federal Agency: Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing Number: 21.027 Recommendation: The Organization should develop written policies for the internal control over compliance of federal awards. Action Taken (Unaudited): Management plans to develop proper written policies and procedures for the internal control over compliance to ensure accuracy and completeness in the preparation of the schedule as required by Uniform Guidance. This policy includes adding another control by a third-party accountant to review federal award financial management. Contact Name ? Rebecca Buford Expected Completion Date ?12.31.23
Management Response and Corrective Action Plan Reference Number: 2022-001 Federal Program Title: Senior Community Services Employment Program Federal Catalog Number: 17.235 Federal Agency: U.S. Department of Labor, Employment and Training Administration Pass-Through ...
Management Response and Corrective Action Plan Reference Number: 2022-001 Federal Program Title: Senior Community Services Employment Program Federal Catalog Number: 17.235 Federal Agency: U.S. Department of Labor, Employment and Training Administration Pass-Through Entity: County of Los Angeles, Workforce Development, Aging and Community Services Federal Award Number and Year: 1820-TV105-SG; FY 2022 Category of Finding: Reporting Management acknowledges that the two (2) monthly cash request invoices submitted to the County of Los Angeles were not submitted within ten (10) calendar days following the month being reported. The management will ensure that the Accounting Department will strengthen its review process to ensure the monthly cash request invoices are submitted within 10 calendar days following the month being reported as stated on the contract.
The City?s corrective action follows. Action Taken: The City has developed an internal process to ensure compliance with contracting deadlines. The Community Development leadership team now conducts monthly contract check-in meetings with Program Coordinators. During these meetings, contract execut...
The City?s corrective action follows. Action Taken: The City has developed an internal process to ensure compliance with contracting deadlines. The Community Development leadership team now conducts monthly contract check-in meetings with Program Coordinators. During these meetings, contract execution timelines are discussed. If a subrecipient has not submitted contract documentation 90 days before the appropriate deadline, the Program Coordinator will contact the subrecipient to better understand why the contract documents were not submitted. The Program Coordinator will continue to contact the subrecipient, via email and telephone, each week until all materials are submitted and the agreement is executed. Additionally, all deadlines are clearly marked on a large calendar in a shared workspace as well as on individual electronic calendars. If you have any questions, I can be reached at 412-255-2640. Sincerely, Jake Pawlak Director, Office of Management & Budget
Finding 59499 (2022-001)
Significant Deficiency 2022
Finding 2022-001 Significant Deficiency in Internal Control over Compliance, Noncompliance ? Reporting Name of Contact Person: Brenda Ambrose, Tribal Administrator Jennifer Babcock, Accountant Corrective Action Plan: Audit firm will be chosen to perform audit and contract signed for audit t...
Finding 2022-001 Significant Deficiency in Internal Control over Compliance, Noncompliance ? Reporting Name of Contact Person: Brenda Ambrose, Tribal Administrator Jennifer Babcock, Accountant Corrective Action Plan: Audit firm will be chosen to perform audit and contract signed for audit to be completed the month following year end close. The audit will be schedule with Audit firm to have the audit completed 5 months after year end close. Proposed Completion Date: The plan is in place September 15, 2023 and the FY 23 Audit will be completed by February 28, 2024.
Finding Number: 2022-003 Condition: The Organization did not submit audited financial statements to REAC within the required time frame after the fiscal year end for the year ended December 31, 2022. Planned Corrective Action: No further corrective action will be taken. The Section 232 HUD insured m...
Finding Number: 2022-003 Condition: The Organization did not submit audited financial statements to REAC within the required time frame after the fiscal year end for the year ended December 31, 2022. Planned Corrective Action: No further corrective action will be taken. The Section 232 HUD insured mortgage is in default. The Mortgage Servicer made claim on the HUD insurance and has been paid. HUD is working through the process to bring the note/mortgage to sale later in 2023 or early 2024. Contact person responsible for corrective action: Daren Lee, Chief Operating Officer Anticipated Completion Date: March 31, 2024
Finding Number: 2022-002 Condition: As of December 31, 2022, principal and interest payments on the mortgage are delinquent by $53,154. In addition, the various escrows are underfunded by $13,635. Planned Corrective Action: No further corrective action will be taken. The Section 232 HUD insured mort...
Finding Number: 2022-002 Condition: As of December 31, 2022, principal and interest payments on the mortgage are delinquent by $53,154. In addition, the various escrows are underfunded by $13,635. Planned Corrective Action: No further corrective action will be taken. The Section 232 HUD insured mortgage is in default. The Mortgage Servicer made claim on the HUD insurance and has been paid. HUD is working through the process to bring the note/mortgage to sale later in 2023 or early 2024. Contact person responsible for corrective action: Daren Lee, Chief Operating Officer Anticipated Completion Date: March 31, 2024
View Audit 54583 Questioned Costs: $1
2022-002: Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Corrective Action Plan: The County immediately began reviewing it?s policy related to suspension and deb...
2022-002: Suspension and Debarment Federal Agency: U.S. Department of Treasury Federal Program Names: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Numbers: 21.027 Corrective Action Plan: The County immediately began reviewing it?s policy related to suspension and debarment and is reviewing procedures to ensure that requirements are consistently followed in future years.
2022-001 Income Certifications Name of contact person ? Angela Riley, CFO Corrective action ? The Corporation agrees with the finding, and has continued to implement strategies to address these issues throughout 2021 and 2022, including: assembled and deployed a team of external consultants and temp...
2022-001 Income Certifications Name of contact person ? Angela Riley, CFO Corrective action ? The Corporation agrees with the finding, and has continued to implement strategies to address these issues throughout 2021 and 2022, including: assembled and deployed a team of external consultants and temporary workers to assist site staff in completing tenant recertifications, hired a team of 6 additional roving property management/compliance teams to cover open property management positions and to support site staff in completing tenant recertifications, developed a new training program to onboard site staff, and developed a monitoring program to set expectations and hold employees accountable to those expectations. Proposed completion date ? Management has begun the corrective action and is expected to have additional internal controls and training done by December 31, 2023.
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their develope...
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their developers are currently working through. At the time of this finding, the technical issue on GSA?s side hasn?t been resolved. The procedure includes a flow chart, PowerPoint presentation, FAQ document, and process. Additionally, there have been numerous training opportunities both in person and online across the Division to train as many stakeholders as possible in the reporting and monitoring of FFATA to ensure timeliness and accuracy. In-person and online trainings were held on 01/04/23, 01/26/23, and 02/06/23. The United States Department of Education also recently held a FFATA webinar on 01/18/2023, which all ESF and ESEA program personnel involved in FFATA reporting where required to attend. Anticipated Completion Date: 02/06/2023 Contact Person: Jessica Lescarbeau, Bureau Administrator and Lindsey Labonville, Compliance Administrator
View of Responsible Officials NHED concurs with the finding identified in section A. This was an oversight on the part of NHED, and a process has been implemented to ensure that when the GAN template is generated, there is a review by 2 separate staff members to ensure all required elements on the G...
View of Responsible Officials NHED concurs with the finding identified in section A. This was an oversight on the part of NHED, and a process has been implemented to ensure that when the GAN template is generated, there is a review by 2 separate staff members to ensure all required elements on the GAN are complete. NHED concurs with the finding identified in Section B. The previous Division Director of Learner Support, without understanding the unintended consequences, required that the IDEA allocations be uploaded in separate installments instead of including the full year award amount. This led to a GAN generation that included only the first installment. This procedure has since been corrected and NHED is now uploading the full year allocation amount in GMS, this will then generate a GAN that reflects the full year grant amount. If a reallocation does occur, there is a review by 2 separate staff members to ensure that the amount is verified and that a new GAN is manually generated to include that verified amount, and then the GAN is reissued to the recipient. Anticipated Completion Date: Already completed Contact Person: Lindsey Labonville
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their develope...
View of Responsible Officials DLS has implemented a procedure across all ESF and ESEA programs to ensure timely and accurate reporting. DLS has also partnered with GSA to resolve issues within the FSRS (FFATA) system, however, there seems to be many technical issues on their end that their developers are currently working through. At the time of this finding, the technical issue on GSA?s side hasn?t been resolved. The procedure includes a flow chart, PowerPoint presentation, FAQ document, and process. Additionally, there have been numerous training opportunities both in person and online across the Division to train as many stakeholders as possible in the reporting and monitoring of FFATA to ensure timeliness and accuracy. In-person and online trainings were held on 01/04/23, 01/26/23, and 02/06/23. The United States Department of Education also recently held a FFATA webinar on 01/18/2023, which all ESF and ESEA program personnel involved in FFATA reporting where required to attend. Anticipated Completion Date: 02/06/2023 Contact Person: Jessica Lescarbeau, Bureau Administrator and Lindsey Labonville, Compliance Administrator
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 200.332(a). Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other st...
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 200.332(a). Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies and entities recognized as component units of state government such as the NH Business Finance Authority; noting agreements between state agencies would not require such compliance. Accordingly, the Department will review existing policies and procedures related to subawarding and subrecipient monitoring to ensure agreements with component units of state government are properly considered. Additionally, the Department will amend the existing agreement to ensure required award information is communicated and ensure all other subrecipient monitoring protocols are applied to the subaward. Anticipated Completion Date: June 30, 2023 Contact Person: Taylor Caswell
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR 170. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies an...
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR 170. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies and entities recognized as component units of state government such as the NH Business Finance Authority; noting FFATA reporting would not apply to agreements between state agencies. Accordingly, the Department will review existing policies and procedures related to FFATA reporting to ensure agreements with component units of state government are properly considered and reported. Anticipated Completion Date: June 30, 2023 Contact Person: Taylor Caswell
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 180. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state ag...
View of Responsible Officials The Department acknowledges the misinterpretation of the agreement as a subaward has led to a failure to comply with 2 CFR section 180. Underlying this misinterpretation was the Department?s failure to differentiate between entering into agreements with other state agencies and entities recognized as component units of state government such as the NH Business Finance Authority; noting suspension and debarment policies and procedures do not apply to agreements between state agencies. Accordingly, the Department will review existing policies and procedures related to suspension and debarment certifications to ensure agreements with component units of state government are properly considered. Anticipated Completion Date: June 30, 2023 Contact Person: Taylor Caswell
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