Corrective Action Plans

Finding 59410 (2022-009)

Material Weakness 2022

NH

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

View of Responsible Officials The State concurs. The State will review and strengthen existing policies and procedures related to suspension and debarment to improve compliance. Anticipated Completion Date: December 2023 Contact Person: Chase Hagaman and Steven Giovinelli

View Audit 49723

Finding 59409 (2022-008)

Significant Deficiency 2022

State of New Hampshire

NH

Subrecipient Monitoring § 200.251 § 200.303 § 200.332 § 200.414 § 200.521

View of Responsible Officials The State largely concurs with the findings and recommendations and has either implemented procedures to address the identified conditions already or will do so. With regard to condition A(a) and (b), although the State illustrated that it includes clauses related to al...

View of Responsible Officials The State largely concurs with the findings and recommendations and has either implemented procedures to address the identified conditions already or will do so. With regard to condition A(a) and (b), although the State illustrated that it includes clauses related to allowed costs in its subawards, including direct and indirect costs, it will work to ensure that agencies entering into such agreements clearly indicate the terms required by Uniform Guidance, including permitted indirect cost rates and whether the award is for R&D. With regard to condition B, the State agrees that risk assessments should have been completed and has since implemented a framework to help ensure that agencies are more consistently conducting and documenting subrecipient risk assessments. With regard to condition C, the State concurs and has already implemented an agency-wide framework to help ensure procedures and policies are in place concerning Uniform Guidance Report review and the issuance of any necessary management decision letters, to the extent required. It is worth noting that the State in most cases has timely conducted risk assessments of subrecipients and reviewed relevant Uniform Guidance Reports, but its corrective actions will result in better documentation and more consistent and timelier follow through. Anticipated Completion Date: The corrective actions indicated above relative to conditions B and C have already been implemented as of the date of this response. The State will work to address Condition A before the end of the current Fiscal Year. Contact Person: Chase Hagaman and Steve Giovinelli

View Audit 49723

Finding 59407 (2022-007)

Material Weakness 2022

State of New Hampshire

NH

Subrecipient Monitoring § 200.251 § 200.303 § 200.332 § 200.521

View of Responsible Officials The State concurs in part with the findings and recommended action. The State?s HAF program fully launched in March 2022 of the Fiscal Year under review, which ended June 30, 2022. On the whole, a more robust subrecipient monitoring framework and process is being implem...

View of Responsible Officials The State concurs in part with the findings and recommended action. The State?s HAF program fully launched in March 2022 of the Fiscal Year under review, which ended June 30, 2022. On the whole, a more robust subrecipient monitoring framework and process is being implemented during the current Fiscal Year for this program. However, the State has engaged in thorough monitoring of its subrecipient, receiving and reviewing recurring biweekly and quarterly reports. As noted, discussion of those reports takes place during weekly conversations with the subrecipient. However, the State has acknowledged that it needs to more formally memorialize the substance of such conversations to demonstrate such review. This change in protocol and procedure has already been implemented during this Fiscal Year. The State has also engaged in a subrecipient risk assessment and review of audited financials for the purposes of uniform guidance report review. However, its process and protocols will be revised to better demonstrate when such reviews/assessments take place moving forward. Moreover, the State relies on its subrecipient to facilitate the State?s HAF program, which includes collecting and processing data, as outlined in the program?s policy guide manual. A key feature of that process is a detailed quality control protocol. Additionally, during this Fiscal Year, the State engaged in a robust, on-site review of the subrecipient?s quality control protocols and methods, including applicant file review, and found them satisfactory and reliable. The State also works closely with its subrecipient during the quarterly and annual U.S. Treasury reporting processes, which involves reviewing and analyzing data provided by the subrecipient for reporting purposes. This review and the resulting communications can result in corrections to data prior to submission to U.S. Treasury. Corrective Action and Anticipated Completion Date: As of this response, the State has already implemented several corrective actions that align with the recommendations above, including documentation of report review during weekly calls with the subrecipient, timestamping procedures for uniform guidance report review, and on site, detailed review of quality control protocols that involved applicant file review. The State will further ensure that such updated protocols and procedures are memorialized in the Programs? transaction processing memo during its Q1 2023 update, including any protocols necessary to ensure timely issuance of any required management decisions relative to the subrecipient. Contact Person: Chase Hagaman, Lisa Cota-Robles, and Michele Zangri-Crean

View Audit 49723

Finding 59406 (2022-006)

Material Weakness 2022

State of New Hampshire

NH

Cash Management Subrecipient Monitoring § 200.303 § 200.305

View of Responsible Officials The State concurs in part with the premise of the findings identified, but it does not concur with the characterization of the Governor?s Office for Emergency Relief and Recovery (GOFERR), the process for authorizing the relevant subaward and relevant amendments, the na...

View of Responsible Officials The State concurs in part with the premise of the findings identified, but it does not concur with the characterization of the Governor?s Office for Emergency Relief and Recovery (GOFERR), the process for authorizing the relevant subaward and relevant amendments, the nature of the subaward and amendments, or the recommended corrective action. Moreover, the full $49,250,000 identified in the finding was not provided to the subrecipient in one lump sum. The State was allocated $50,000,000 from U.S. Treasury for the purposes of designing and facilitating the State?s HAF program. The State received $5,000,000 from U.S. Treasury up front and received the remainder after approval of the State?s planned program. As a result, the State?s subrecipient received an initial subaward for administrative and planning purposes from within the initial $5,000,000 delivered to the State. The subrecipient was advanced only a portion of those initial funds and then was provided the remainder upon request and justification. A subsequent amendment to that subaward provided additional funds to the subrecipient as needed for the same purpose and as part of the U.S. Treasury required process of designing and then attaining approval for the State?s HAF program. The State ultimately received approval from U.S. Treasury for the State?s HAF program plan, which is a complex multi-faceted program that provides various forms of assistance to homeowners, and then received approval from State officials to launch the program. The State?s program is run entirely through a single subrecipient, New Hampshire Housing Finance Authority, which is the only entity of its kind as a statewide housing authority. This subrecipient facilitates a variety of larger-scale, federally funded housing programs. While developing the State?s HAF program and as it neared the launch date, the State began receiving preapplications through its subrecipient. Additionally, during this time, the State was facilitating its Emergency Rental Assistance (ERA) program, which has provided assistance to renters as opposed to homeowners and is facilitated by the same subrecipient of the State. Within the context of having received nearly 200 preapplications for the HAF program and witnessing a heavy and increasing demand in the rental assistance program, the decision was made to advance the remainder of the State?s HAF allocation ($45,000,000) to its subrecipient in order to provide prompt and adequate assistance, believing the program would experience high demand at the outset and funding shortfalls would be problematic for its success. Moreover, the amount of funds provided to the subrecipient was consistent with past advances to the same subrecipient under the ERA program, and as with prior delivery of funds, the subrecipient placed the funds in an appropriate account. However, demand for assistance did not unfold as anticipated due to the features of the program and the areas of need ultimately demonstrated by applicants after review and processing of initial applications. As part of the State?s monitoring protocols, and in part because of a lower initial expenditure rate than expected, the subrecipient began providing biweekly reports on the usage of funds, which the State has used as a measure of cash on hand. Moreover, the State also engages in standing, calendared, weekly calls with the subrecipient to discuss these reports. The State has provided documentation to support the process outlined above as well. Finally, as a result of the State?s remaining HAF allocation having already been provided to the subrecipient, the recommended corrective action is not feasible. However, the State acknowledges the need to more formally memorialize its review of the subrecipient?s cash on hand. As a result, the biweekly reports received and reviewed by the State will now include a specific section providing such information; review and discussion of that data will be incorporated into the weekly calls with the subrecipient, and the process and protocols will be documented in the State?s transaction processing memo for the program. Corrective Action Incorporation of cash on hand related data in biweekly reports received and reviewed by the State, documentation of that review as part of the weekly calls with subrecipient, and memorialization of the process and protocols in the State?s transaction processing memo for its HAF program. Anticipated Completion Date: Cash on hand data into biweekly reports and documentation of review said data as part of weekly calls with the subrecipient is being is actively being incorporated as of this response. The State will ensure that the transaction processing memo is updated with the requisite processes and protocols during the next update before the end of Q1 2023. Contact Persons: Chase Hagman, Lisa Cota-Robles, and Michele Zangri-Crean

View Audit 49723

Finding 59405 (2022-005)

Material Weakness 2022

State of New Hampshire

NH

Subrecipient Monitoring Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Quarterly Reporting The State concurs in part with the condition and recommendation. A unique challenge with ERA reporting has been changes in the U.S. Treasury portal for that program, which have impacted the State?s ability to download and provide copies of past reports that have been submitted. I...

Quarterly Reporting The State concurs in part with the condition and recommendation. A unique challenge with ERA reporting has been changes in the U.S. Treasury portal for that program, which have impacted the State?s ability to download and provide copies of past reports that have been submitted. In addition, this issue in the reporting portal has been inconsistent, as some previously submitted reports were made accessible by Treasury, while others were not, which resulted in the State being able to access some requisite materials but not others. The State did not have documented procedures to ?pull down? copies of reports it had submitted to Treasury because the State has otherwise been able to rely on access to its previously submitted reports within reporting portals in order to enable the testing required during audit for the relevant periods. Meaning, in the State?s experience with COVID-19 related federal funds reporting, it has been able to access and download past reports for purposes of audit. However, also noted above is that the Treasury portal was recently revised and updated to allow for accessing previously submitted ERA reports that were not otherwise available (the communication from Treasury acknowledging this change was provided by the State). However, the reporting portal change did not take place in time for the State?s auditors to reasonably conduct the necessary testing. The State did provide the data and materials it reported to Treasury for the relevant periods, but auditors were unable to test and validate that data because the State could not access and provide a copy of what was actually uploaded into the portal. Nevertheless, to avoid any such potential issues in the future, the State has already implemented a procedure that involves downloading copies of reports as soon as they are submitted and taking screenshots of portions of the portal where perceived necessary to support what the State has submitted to Treasury. This updated procedure will be memorialized in the program?s transaction processing memo during its next update. Monthly Reporting The State concurs in part but has already implemented related corrective action in line with the recommendation above. The State would also like to note that as part of the ERA reallocation process U.S. Treasury has relied on both quarterly and monthly reporting, and that the State has continued to engage in thorough monitoring of its subrecipient and receives regular reports from that subrecipient, including weekly, biweekly, and quarterly data, which also includes quality control reports. This is inclusive of the monthly reports that were required by U.S. Treasury at one time but no longer are. The State reviews and then discusses reports received at standing, calendared, weekly meetings with the subrecipient and often engages in e-mail correspondence concerning those reports, especially if any questions concerning the data provided arise. However, the State has acknowledged that its documentation of those weekly conversations needed to be more formally memorialized. During the current fiscal year, the State began providing agendas and summaries of topics discussed during the weekly check-ins and will ensure that the program?s transaction processing memo adequately documents this requirement and procedure. The very nature of this program and U.S. Treasury?s facilitation of it has required the State and its subrecipient to stay in close contact, make regular decisions on strategies and policies within the program, and closely consider data relative to it. Anticipated Completion Date Quarterly reporting - Corrective action relative to acquisition of submitted federal reports has already been implemented and this revised procedure will be memorialized in the transaction processing memo for the program during its next update in Q1 2023. Monthly Repotting - Corrective action relative to documentation of weekly meetings was already complete as of the State?s response to this finding, and the State will ensure that the transaction processing memo for the program reflects these measures during its next update in Q1 2023. Contact Person Chase Hagaman, Lisa Cota-Robles, and Emily Larson

View Audit 49723

Finding 59404 (2022-004)

Significant Deficiency 2022

State of New Hampshire

NH

Subrecipient Monitoring § 200.251 § 200.303 § 200.331 § 200.332 § 200.521

View of Responsible Officials The State concurs in part with the findings and concurs in part with the recommendations. Given that CARES Act CRF is a funding source that is no longer eligible for use because program obligations were required to be entered into by December 31, 2021, and program expe...

View of Responsible Officials The State concurs in part with the findings and concurs in part with the recommendations. Given that CARES Act CRF is a funding source that is no longer eligible for use because program obligations were required to be entered into by December 31, 2021, and program expenditures complete by September 30, 2022, there are no ongoing CRF funded projects or programs. As a result, any corrective actions would relate to ensuring any other federal funding sources are achieving compliance requirements. With regard to condition A, the State partially concurs. Federal guidance concerning CARES Act CRF did not allow for charging indirect costs. That guidance indicated ?Payments from the Fund are not administered as part of a traditional grant program and the provisions of the Uniform Guidance, 2 CFR part 200, that are applicable to indirect costs do not apply. Recipients may not apply their indirect costs rates to payments received from the Fund.? Thus, awardees and recipients of funds were not permitted to charge indirect costs against CARES Act CRF. However, the state acknowledges inclusion of language specifically acknowledging the disallowance of indirect costs could have been included in the agreements. With regard to condition B, the State concurs. The four identified subrecipients were awardees of a program that was facilitated at the very end of CARES Act CRF eligibility for the period of performance. This program was run due to updated guidance by U.S. Treasury on December 14, 2021, that extended the deadline for expenditure of funds so long as obligations were entered into by December 31, 2021. That program largely resulted in direct beneficiary awards, but due to the nature of some expenditures awarded some entities received a subaward. Those subawards identified a brief timeline for project completion, between December 2021 and September 2022. Most projects were completed in February and March, with two of the subrecipients finalizing projects in September. Given the nature and timing of the program, those subawardees were closely monitored and regularly interacted with the State in order to receive reimbursement for eligible expenses and complete projects. The State can provide documentation of that monitoring and expense review. However, formal risk assessments were not initially done for those entities. Since then, the State has implemented policies and procedures that help ensure risk assessments are completed for all subrecipients, regardless of the nature of the program. With regard to condition C, the State concurs and has already implemented corrective actions to ensure procedures and policies are in place concerning Uniform Guidance Report review and the issuance of any necessary management decision letters to the extent required and where this deficiency could impact any other sources of federal funding. It is worth noting that the State in most cases has timely conducted risk assessments of subrecipients and reviewed relevant Uniform Guidance Reports, but its corrective action will result in better documentation of that process and protocol. Anticipated Completion Date: The corrective actions indicated above have already been implemented as of the date of this response. Contact Person: Steve Giovinelli and Chase Hagaman

View Audit 49723

Finding 59399 (2022-002)

Significant Deficiency 2022

State of New Hampshire

NH

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.303 § 200.502 § 200.510

Views of Responsible Officials The Department of Administrative Services (DAS) concurs. Financial management of individual federal awards is decentralized throughout state agencies which centralizes annually in the culmination of the State?s SEFA. During this process, each agency is required to com...

Views of Responsible Officials The Department of Administrative Services (DAS) concurs. Financial management of individual federal awards is decentralized throughout state agencies which centralizes annually in the culmination of the State?s SEFA. During this process, each agency is required to complete a standardized SEFA analysis and reconciliation tool for review by the DAS prior to the incorporation of the data into the State?s SEFA. This process also includes an annual Single Audit training and update session organized by the DAS. Additionally, the DAS notes all contracts, including subawards, entered by state agencies over a designated threshold are required to be authorized by the State?s Legislative Fiscal Committee and the Governor and Executive Council. The DAS will examine each of these processes to identify additional control activities to improve the accuracy and completeness of the pass through element of the SEFA. Anticipated Completion Date: April 30, 2024 Contact: Steven Giovinelli, Federal Grants and Cost Allocation Administrator, Department of Administrative Services

View Audit 49723

Finding 59387 (2022-002)

Material Weakness 2022

National Trail Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management

When the project started, the National Trail Local School District was not fully aware of all needed requirements when using federal grant dollars. At that time, the information and directions had not been clearly issued by the State of Ohio and the District was learning about the uses and regulati...

When the project started, the National Trail Local School District was not fully aware of all needed requirements when using federal grant dollars. At that time, the information and directions had not been clearly issued by the State of Ohio and the District was learning about the uses and regulations when it came to COVID dollars. However, once we were aware we immediately made the needed changes. In the future, the District will put controls in place to address this issue to ensure we properly follow the guidelines when using federal grant dollars.

View Audit 55078

Finding 59364 (2022-004)

Material Weakness 2022

School Town of Munster

IN

School Nutrition Programs Subrecipient Monitoring Cash Management § 200.302 § 200.303 § 200.327 § 200.328 § 200.329

Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There has been turnover in the finance department and the past employees who would have been respo...

Contact Person Responsible for Corrective Action: Jessica Espinoza Contact Phone Number: (219) 836-9111 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: There has been turnover in the finance department and the past employees who would have been responsible for this are no longer here. There are already internal controls in place to ensure that the monthly sponsor claims submitted match the school?s meal count reports. The Treasurer will continue to ensure that everything is correctly entered before submission. Anticipated Completion Date: March 2023

View Audit 55071

Finding 59349 (2022-002)

Significant Deficiency 2022

Corinth Central School District

NY

School Nutrition Programs Procurement, Suspension & Debarment Eligibility § 200.213

Vendor?s eligibility was reviewed but not formally documented. A spreadsheet will be documented when vendor?s eligibility are reviewed. Babette L. Donlon District Treasurer 1/23

View Audit 53926

Finding 59334 (2022-001)

Significant Deficiency 2022

Faith Housing New Hope Apartments 122-Hd127-Wpd-Np

CA

Questioned Costs HUD Housing Programs Special Tests & Provisions

Name of auditee: Faith Housing New Hope Apartments HUD auditee identification number: 122-HD127-WPD-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Christien Tran Position: Management agent representative Telephone numb...

Name of auditee: Faith Housing New Hope Apartments HUD auditee identification number: 122-HD127-WPD-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Christien Tran Position: Management agent representative Telephone number: 323-838-8556 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition # 2022-001 Comments on Finding and Recommendation: The Corporation's required deposit of $12,057 to the residual receipts account per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Action(s) taken or planned on the finding: Management deposited $12,057 into the residual receipts fund on November 8, 2021.

View Audit 56625 Questioned Costs: $1

Finding 59331 (2022-001)

Significant Deficiency 2022

Silver Lake New Hope Courtyard Apts 122-Hd047-Wpd-Np

CA

Questioned Costs HUD Housing Programs Special Tests & Provisions

Name of auditee: Silver Lake New Hope Courtyard Apartments HUD auditee identification number: 122-HD047-WPD-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Christien Tran Position: Management agent representative Teleph...

Name of auditee: Silver Lake New Hope Courtyard Apartments HUD auditee identification number: 122-HD047-WPD-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2022 CAP prepared by Name: Christien Tran Position: Management agent representative Telephone number: 323-838-8556 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition # 2022-001 Comments on Finding and Recommendation: The Corporation's required deposit of $53,828 to the residual receipts account per the June 30, 2021 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Action(s) taken or planned on the finding: Management deposited $53,828 into the residual receipts fund on November 12, 2021.

View Audit 56624 Questioned Costs: $1

Finding 59328 (2022-002)

Significant Deficiency 2022

Chico State Enterprises

CA

Subrecipient Monitoring Eligibility

Finding 2022-002, Special Tests and Provisions a. Program Information: Foster Grandparent Program ? ALN 94.011, Senior Companion Program ? ALN 94.016 b. Criteria: The NSCHC must be conducted, reviewed, and an eligibility determination made by the grant recipient or subrecipient based on the results ...

Finding 2022-002, Special Tests and Provisions a. Program Information: Foster Grandparent Program ? ALN 94.011, Senior Companion Program ? ALN 94.016 b. Criteria: The NSCHC must be conducted, reviewed, and an eligibility determination made by the grant recipient or subrecipient based on the results of the NSCHC no later than the day before a person begins to work or serve on a NSCHC-required grant. The grant recipient must maintain adequate documentation of individual NSCHC grant records to include evidence that all required components (NSOPW, State(s), and FBI checks) were completed and on file (45 CFR ?2540.206). c. Condition: CSE did not have completed NSOPW documentation on file for two individuals before they began working or serving on the grant. Response: The CSE Director of Human Resources and project management will review and update existing policy as necessary and ensure that all required components of the NSCHC are completed by requiring the NSCHC Documentation Checklist to be: 1) completed at least one day prior to the person working or serving on the grant and 2) retained at the program and/or personnel level as appropriate. Contact person(s) responsible for corrective action: 1. Vance Kelly, Director of Finance and Accounting 2. Michele Flowerdew, Director of Sponsored Programs Administration Anticipated completion date: December 31, 2022

View Audit 56623

Finding 59304 (2022-002)

Significant Deficiency 2022

Tri-County Senior Citizens and Housing, Inc.

CO

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding 2022-002:Section 8 Project-Based Cluster Federal Assistance Number: 14.182 and 14.195 U.S. Department of Housing and Urban Development Compliance Requirements: Cash Management, Eligibility, Reporting Type of finding: Internal Control Over Compliance (significant deficiency) Reco...

Finding 2022-002:Section 8 Project-Based Cluster Federal Assistance Number: 14.182 and 14.195 U.S. Department of Housing and Urban Development Compliance Requirements: Cash Management, Eligibility, Reporting Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of administrative staff allowing the administrator to act in a more supervisory position. Action Taken: This is not a "non-compliance" finding, however, management and the Board understand that internal controls and best management practices need to be strengthened. Management will review job descriptions and evaluate the number of staff needed to strengthen internal controls. Policies and procedures will be reviewed and adopted to segregate duties for best management practices in internal controls given the size of the organization we are. If the U.S. Department of Housing and Urban Development have questions regarding this plan, please call the responsible party at (719) 852-5778. Sincerely yours, Karla Shriver Managing Board Member Tri-County Senior Citizens and Housing, Inc.

View Audit 51940

Finding 59299 (2022-002)

Significant Deficiency 2022

Hannibal-Lagrange University

MO

Subrecipient Monitoring Significant Deficiency

Gramm-Leach -Bliley Act (GLBA) Compliance Planned Corrective Action: In regards to the Gramm-Leach-Bliley Act (GBLA), we concur that Hannibal- LaGrange University (HLGU) has not adequately addressed the requirements of the GBLA. In an effort to rectify this issue, the director of Computer Services,...

Gramm-Leach -Bliley Act (GLBA) Compliance Planned Corrective Action: In regards to the Gramm-Leach-Bliley Act (GBLA), we concur that Hannibal- LaGrange University (HLGU) has not adequately addressed the requirements of the GBLA. In an effort to rectify this issue, the director of Computer Services, Dr. Michelle Todd, is in contact with the security team of the Missouri Research and Education Network (MORENet) and has begun to work through a security assessment, which provides a roadmap for making current and continual improvements in regards to the security of the network. MOREN et is a membership consortium that operates as a department within the University of Missouri System, assisting members with network and security support. This process with MORENet will provide HLGU with guidance to develop a program that would protect the exposure of student information security risks. Person Responsible for Corrective Action Plan: Dr. Michelle Todd, Director of Computer Services Anticipated Date of Completion: Fall 2023

View Audit 51939

Finding 59287 (2022-002)

Significant Deficiency 2022

Synergistic Hawaii Agriculture Council

HI

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.305

The primary recipient of cash advanced under the SCRI program was the USDA Agricultural Research Service (ARS). The USDA-ARS Trust agreement with SHAC allowed for advancement of funds to the Federal agency so they could hire staff under their contracting agreements with the Department of Energy?s OR...

The primary recipient of cash advanced under the SCRI program was the USDA Agricultural Research Service (ARS). The USDA-ARS Trust agreement with SHAC allowed for advancement of funds to the Federal agency so they could hire staff under their contracting agreements with the Department of Energy?s ORISE program. Funds are required up front for ORISE hiring contracts. USDA-ARS manages the risk by portioning out payments to ORISE so funds can be suspended upon unsatisfactory performance. Secondarily, cash advances were also made to the Land Grant University Subawardees for similar hiring and supply procurement reasons at the start of the grant. Due to extreme labor shortages caused by post-pandemic issues with available staffing, some positions remained unfilled for longer than expected, creating a discrepancy in expected expenses. This issue has been resolved. All Subawardee contracts were transitioned to a cost-reimbursement basis in the 2023-24 grant period. SHAC will ensure proper reporting of expenditures in a timely manner from its Subawardees through timely pursuit of invoices from University sponsored program offices. Relevant Personnel details: Mike Miyahira, Accountant, mike@shachawaii.org, Ph 808-987-8438 Suzanne Shriner, Executive Director, suzanne@shachawaii.org, Ph 808-365-9041

View Audit 55006

Finding 59273 (2022-001)

Material Weakness 2022

Spokane Housing Authority

WA

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Spokane Housing Authority January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the Housing Authority for findings reported in this report in accordance with Title 2 U.S. Code of Federal R...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Spokane Housing Authority January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the Housing Authority for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-01 Finding caption: The Housing Authority had inadequate internal controls for ensuring compliance with Housing Quality Standards enforcement requirements of its Housing Voucher Cluster program. Name, address, and telephone of Housing Authority contact person: Kathy Clark, Finance Director 25 W. Nora Avenue Spokane, WA 99205 (509) 252-7109 Corrective action the auditee plans to take in response to the finding: Spokane Housing Authority acknowledges the above reference finding. Although personnel responsible for conducting the HQS inspections and ensuring owners corrected the cited life-threatening deficiencies were trained on policy and procedure, SHA did not establish the internal controls to ensure proper follow-up was made. In September 2022, SHA, established a Housing Support Specialist position, which will log life-threatening HQS deficiencies as documented on the HQS inspector?s reports daily and follow-up with the landlord within the 24-hour timeframe to ensure that repairs have been addressed and completed. If repairs have been made pursuant to the directive given by the inspector, then a letter will be sent to the landlord and tenant indicating that the 24-hour hazards have been fixed. If the landlord fails to comply within the 24-hour timeframe, then the unit fails, and a Notice of Termination of HAP letter will be sent to the landlord and tenant. SHA will work with the tenant to start the process of locating a new unit that passes HQS. The log of deficiencies will be reviewed by the Inspections Coordinator regularly as an additional internal control. Anticipated date to complete the corrective action: January 1, 2023

View Audit 54676

Finding 59224 (2022-001)

Significant Deficiency 2022

Global Communities

MD

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Views of Responsible Officials: While many of the above-listed delays were approved by the donor POCs, there were instances where staffing gaps contributed to delays. To ensure timely reporting, a report tracking system has been created where we are regularly updating the tracker with report deadlin...

Views of Responsible Officials: While many of the above-listed delays were approved by the donor POCs, there were instances where staffing gaps contributed to delays. To ensure timely reporting, a report tracking system has been created where we are regularly updating the tracker with report deadlines. As an added measure ,notifications have been established to remind the responsible individuals. These various measures will help to ensure timely reporting.

View Audit 56152

Finding 59223 (2022-002)

None 2022

Rayne Elderly Housing Corporation Operating As Leisure Lane Apartments

FL

HUD Housing Programs Subrecipient Monitoring Reporting

FINDING No. 2022-002: Section 202 Supportive Housing for the Elderly, CFDA 14.157 Recommendation: The Project should comply with HUD regulations for timely renewal of PRAC contract to ensure no interruption in funding. Action Taken: Staff is going to be trained on the proper procedures to follow for...

FINDING No. 2022-002: Section 202 Supportive Housing for the Elderly, CFDA 14.157 Recommendation: The Project should comply with HUD regulations for timely renewal of PRAC contract to ensure no interruption in funding. Action Taken: Staff is going to be trained on the proper procedures to follow for the PRAC contract renewal process. This will include meeting deadlines for submission to HUD. As of March 2023 Compliance created a spreadsheet of dates when contract renewals are due. Compliance will be monitoring this process and will be making monthly contacts to the Community Manager and Regional Property Manager to ensure deadlines will be met. If the Oversight Agency for Audit has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

View Audit 56151

Finding 59220 (2022-001)

None 2022

Mermentau Elderly Housing Corporation Dba Riverbend Apartments

FL

HUD Housing Programs Subrecipient Monitoring Reporting

Oversight Agency for Audit, Mermentau Elderly Housing Corporation respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201 Coral Springs, Florid...

Oversight Agency for Audit, Mermentau Elderly Housing Corporation respectfully submits the following corrective action plan for the year ended December 31, 2022. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201 Coral Springs, Florida 33067 Audit period: January 1, 2022 through December 31, 2022 The finding from the December 31, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III - FINDINGS AND QUESTIONED COSTS ? MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING NO. 2022-001: Section 202 Supportive Housing for the Elderly, CFDA 14.157 Recommendation: The Project should comply with HUD regulations for timely renewal of the PRAC contract to ensure no interruption in funding and establish procedures to ensure that Project implements approved rent charges on the effective date approved by HUD. Action Taken: All new staff now receives additional training on HUD guidelines. In addition, management is implementing a monitoring software to assist in ensuring timely submissions. If the audit Oversight Agency has questions regarding these plans, please call Christine Harris at 954-835-9200. Sincerely yours, Christine Harris Accounting Manager

View Audit 55077

Finding 59152 (2022-008)

Significant Deficiency 2022

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Subrecipient Monitoring Significant Deficiency

U.S. Department of Education Mississippi Valley State University (MVSU) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The find...

U.S. Department of Education Mississippi Valley State University (MVSU) respectfully submits the following corrective action plan for the year ended June 30, 2022. Audit period: July 1, 2021 ? June 30, 2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS?FEDERAL AWARD PROGRAMS AUDITS 2022-008: Gramm-Leach-Bliley Act (MVSU) Student Financial Assistance cluster - Assistance Listing No. 84.007, 84.033, 84.038, 84.063, 84.268 Recommendation: For those institutions noncompliant with requirements, CLA recommends that the institution needs to complete all areas. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Office of Financial Aid stores all student files in a locked file room. There are only two keys to gain access which is held by the director and the associate director. The file room remains locked at all times unless a request is made by a counselor or if the director or associate director needs to obtain a file. All financial aid personnel have been trained to initiate the following processes - lock computer screens when leaving their area for a short period of time, if gone for an extended time frame the computer is locked and the financial aid representative's office door is locked. Financial aid documents are electronic and exist in the institution's software module. Name of contact person responsible for corrective action: Deborah Banks, Interim Director of Financial Aid Planned completion date for corrective action plan is April 13, 2023. If the Department of Education has questions regarding this plan, please call Deborah Banks at 662-254-3335.

View Audit 49406

Finding 59134 (2022-001)

Material Weakness 2022

Southwest Care Center

NM

Internal Control / Segregation of Duties Subrecipient Monitoring HUD Housing Programs

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended the Organization review internal controls in regard to the determination, recording, and monitoring of the sliding fee process to...

COVID-19: FY 2020 HEALTH CENTERS PROGRAM LOOK-ALIKES: EXPANDING CAPACITY FOR CORONAVIRUS TESTING ? Assistance Listing No. 93.527 Recommendation: Our auditors recommended the Organization review internal controls in regard to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The case management team conducted a comprehensive training in April 2022 including instructions for completing a sliding fee scale and appropriately filing the documentation in the EMR. In May 2022, an internal monthly audit process was implemented that includes a review of slides completed in the prior month to further reduce the error rate. In response to this audit finding, the case management team will conduct a training session highlighting issues identified during the recent audit including the appropriate utilization of sliding fees. The revenue cycle and pharmacy teams have also implemented processes to ensure that sliding fee scales are active on the service date for medical visits and/or prescriptions from the pharmacy. Name(s) of the contact person(s) responsible for corrective action: Jason Sanchez, CFO Planned completion date for corrective action plan: Has been implemented

View Audit 55087

Finding 58997 (2022-002)

Significant Deficiency 2022

Fairview Woods

MN

Subrecipient Monitoring HUD Housing Programs Significant Deficiency

Recommendation: Recommend management put a policy in place to monitor the bank rating quarterly for financial institutions the projects hold funds at. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will...

Recommendation: Recommend management put a policy in place to monitor the bank rating quarterly for financial institutions the projects hold funds at. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review and update their policies and procedures to ensure the bank ratings for the financial institutions where their projects hold assets is monitored on a quarterly basis. Name of the contact person responsible for corrective action: Connie Bednarek, Controller Planned completion date for corrective action plan: March 31, 2023

View Audit 54742

Finding 58942 (2022-007)

Significant Deficiency 2022

Polk County, Florida

FL

Subrecipient Monitoring Reporting § 200.332

U.S. Department of the Treasury 2022-007 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk Coun...

U.S. Department of the Treasury 2022-007 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend an amended subrecipient contract that complies with all guidelines under 2 CFR section 200.332(a) be put into place between Polk County and the identified subrecipient. In addition, we recommend a risk assessment of this subrecipient be performed and depending on the results of the assessment, determine a planned schedule of monitoring that matches frequency and intensity that aligns with the risk assessment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is implementing training and procedures to properly identify and classify subrecipients on the Schedule of Expenditures of Federal Awards and State Financial Assistance, and to ensure that all required subrecipient monitoring is properly performed. Additionally, the contract for a subrecipient identified during the audit is being amended to comply with all applicable requirements. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson Planned completion date for corrective action plan: June 15, 2023. Approval of amended contract expected in August 2023.

View Audit 56341

Finding 58940 (2022-005)

Significant Deficiency 2022

Polk County, Florida

FL

Subrecipient Monitoring Reporting Significant Deficiency

U.S. Department of the Treasury 2022-005 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely r...

U.S. Department of the Treasury 2022-005 Covid-19 Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend corrections to quarterly reports be made in subsequent quarterly reports to ensure obligations match actuality. We recommend timely reconciliation of accounting transactions to allow for accurate reporting of expenditures through the quarter. Additionally, we recommend careful consideration of assignment for type of entity for which the County enters transactions with related to this funding. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The COVID-19 funds were distributed under an emergency declaration due to the worldwide pandemic and had to be administered by staff with limited grant experience. The County is implementing processes and procedures regarding the reconciliation of transactions to ensure accurate reporting of expenditures for each quarter and to make any necessary corrections in subsequent quarterly reports. Processes and procedures are also being implemented to properly identify subrecipients, contractors, and beneficiaries. Staff will review the most recent Federal guidance, training, and webinars as necessary to ensure they are up to date with the most recent information. Name(s) of the contact person(s) responsible for corrective action: Christia Johnson, Budget and Management Services Director Planned completion date for corrective action plan: June 30, 2023

View Audit 56341

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