Corrective Action Plans

Finding 3979 (2022-001)

Significant Deficiency 2022

KS

Subrecipient Monitoring Cash Management Significant Deficiency § 200.305

U.S. DEPARTMENT OF HOMELAND SECURITY KANSAS ADJUANT GENERAL 2022-001: Disaster Grants – Public Assistance CFDA No. 97.036 Grant period: Year Ended December 31, 2022 Condition and Context: The County does not have a complete set of written cash management policies and procedures as required by the U...

U.S. DEPARTMENT OF HOMELAND SECURITY KANSAS ADJUANT GENERAL 2022-001: Disaster Grants – Public Assistance CFDA No. 97.036 Grant period: Year Ended December 31, 2022 Condition and Context: The County does not have a complete set of written cash management policies and procedures as required by the Uniform Guidance. The lack of written procedures did not result in any material noncompliance, fraud or abuse with respect to the major program. Criteria: The Uniform Guidance requires Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, to follow the cash management standards set out at 2 CFR section 200.305. The County must have a complete set of written cash management policies, which conform to applicable Federal statutes and the cash management requirements identified in 2 CFR part 200. Cause: The County was unaware of the written cash management policy requirements required by the Uniform Guidance. Effect: An important component of internal controls is the existence of operating policies and procedures and that they are clearly understood and communicated. Without clear written policies and procedures, there is a higher risk of noncompliance with program requirements. Recommendation: Management should determine the scope of written policies needed for compliance with all federal programs and develop policies and procedures to comply with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and recommendation. The County’s existing policies are currently under review by management and staff to determine what updates/changes are necessary in order to meet the Uniform Guidance requirements. Once any updates/changes are drafted, the policy will be presented to the Governing Body for review and approval.

View Audit 6270

Finding 3872 (2022-003)

None 2022

Camcare Health Corporation

NJ

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.305 § 200.308 § 200.309 § 200.403

Finding Numbers 2022-002 and 2022-003 Planned Corrective Action: To date, management has already started additional training with the team responsible for grants and any communications between them and HRSA. The accounting department has also been advised to insist on more written documentation pri...

Finding Numbers 2022-002 and 2022-003 Planned Corrective Action: To date, management has already started additional training with the team responsible for grants and any communications between them and HRSA. The accounting department has also been advised to insist on more written documentation prior to assigning expenses to grants. Anticipated Completion Date: November 30, 2023 Responsible Contact Persons: Jillian Hudspeth, CEO Christopher Bernardi, CFO

View Audit 6120 Questioned Costs: $1

Finding 3733 (2022-001)

Material Weakness 2022

Coupeville School District No. 204

WA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

It is very unusual for the district to ever complete projects with unrestricted Federal funds and in this case it was in the midst of a national crisis. In the event that there are future projects, that are Federally funded in excess of $2,000, Coupeville School District (CSD) will have adequate co...

It is very unusual for the district to ever complete projects with unrestricted Federal funds and in this case it was in the midst of a national crisis. In the event that there are future projects, that are Federally funded in excess of $2,000, Coupeville School District (CSD) will have adequate controls for ensuring compliance with Davis-Bacon Act (Federal prevailing wage rate) requirements. Additionally, when Federal unrestricted ESF funds are received, CSD will be sure to better substantiate expenditures with journal entries so that the program does not appear to be overcharged on the financials.

View Audit 5892 Questioned Costs: $1

Finding 3639 (2022-009)

Significant Deficiency 2022

Guam Department of Education

GU

Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No.: 2022-009 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425X American Rescue Plan – State Agency Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425X210003 Area: Activities Allowed or Unallowed ...

Finding No.: 2022-009 Federal Agency: U.S. Department of Education AL Program: 84.425 Education Stabilization Fund AL Sub-Program: 84.425X American Rescue Plan – State Agency Educational Agency (Outlying Areas) (ESF-SEA) Federal Award No.: COVID-19 S425X210003 Area: Activities Allowed or Unallowed Questioned Costs: $0 Views of Auditee and Corrective Actions: The GDOE disagrees with the finding. Utilities (power and water) are an allowable cost allowing the maximization for a safe return of students to the classroom, and necessary for continued operation and promoting handwashing techniques to prepare, prevent, and respond to COVID_x0002_19. USEd FAQ B-10 specifically states that "Generally, ESF-SEA or ESF Governor funds may be used to support activities that are necessary to maintain the operation and continuity of services in the SEA or LEA as schools and students recover from the pandemic.” Additionally, GDOE sought grantor approval and USEd approved the allowability of utility expense under the ARP, and more recently deemed the transfer of utility costs from the ARP to ESF as an allowable expense.

View Audit 5640

Finding 3636 (2022-006)

Significant Deficiency 2022

Guam Department of Education

GU

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

Finding No.: 2022-006 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Area: Period of Performance Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE agrees with the finding. In GDOE’s Munis system, if the Human Resou...

Finding No.: 2022-006 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Area: Period of Performance Questioned Costs: $0 Views of Auditee and Corrective Actions: GDOE agrees with the finding. In GDOE’s Munis system, if the Human Resources (HR) pay records are not accurately updated, GDOE payroll will reflect dated pay tables until such time HR makes the appropriate updates based on the project leads request to update accounts to current grant year. GDOE corrected the improperly charged payroll expenditures to the proper grant year via the journal voucher process. Plan of action and completion date: The GDOE Business Office will perform a monthly review of all transactions to ensure charges are recorded in the appropriate grant year. Additionally, Grant Project Managers and Program Coordinators will timely communicate to the Human Resources and Business Office any changes to accounts charged for federally funded payroll expenditures. Plan to monitor and responsible officials: GDOE Comptroller (vacant), will assign an accountant to monitor the expenditures of federal grants and the corresponding periods of performance and liquidation periods. Grant Project Managers, Federal Compliance review team will be responsible for timely communicating any changes in grant year funding to HR.

View Audit 5640

Finding 3632 (2022-004)

Significant Deficiency 2022

Guam Department of Education

GU

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No.: 2022-004 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education – Grants to States Area: Period of Performance Questioned Costs: $1,835 Views of Auditee and Corrective Actions: GDOE agrees with the finding. During the period of performance in question, the TPF...

Finding No.: 2022-004 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education – Grants to States Area: Period of Performance Questioned Costs: $1,835 Views of Auditee and Corrective Actions: GDOE agrees with the finding. During the period of performance in question, the TPFA issued check no. 2012949 to a vendor in February 2022, within the liquidation period. However, the TPFA indicated that the vendor lost the check and the TPFA re-issued payment to the vendor on January 29, 2023. The untimely reissuance of the check resulted in the transaction occurring one day after the liquidation period expired. Plan of action and completion date: As of April 2023, the TPFA has not been issuing checks to vendors, as the responsibility was returned to the GDOE to process all fiscal transactions within the GDOE Munis. The Business Office will closely monitor grant liquidation dates and payments to vendors. SOPs will be reviewed to update the procedures for monitoring grant period of performance. Plan to monitor and responsible officials: The Deputy of Finance and Administrative Services, Joann Camacho, as well as the GDOE Comptroller (vacant), will assign an accountant to monitor the expenditures of federal grants and the corresponding periods of performance and liquidation periods.

View Audit 5640 Questioned Costs: $1

Finding 3630 (2022-003)

None 2022

Lucile Salter Packard Children's Hospital at Stanford

CA

Reporting Subrecipient Monitoring § 200.512

2022-003 – Late Submission of Uniform Guidance Report Cluster: Not applicable Federal Granting Agency: All federal agencies represented on the SEFA Award Name: All awards on the SEFA Award Year: All awards on the SEFA CFDA #: All awards on the SEFA CFDA Title: All awards on the SEFA Pass-through en...

2022-003 – Late Submission of Uniform Guidance Report Cluster: Not applicable Federal Granting Agency: All federal agencies represented on the SEFA Award Name: All awards on the SEFA Award Year: All awards on the SEFA CFDA #: All awards on the SEFA CFDA Title: All awards on the SEFA Pass-through entity: All identified on the SEFA Management’s Response: Management is in agreement with the recommendation as stated above. The audit for this fiscal year was unique and is not indicative of the typical audit process and timeliness of LPCH. Corrective Action Plan: Complete subsequent audits in a timely manner consistent with previous year. Leadership Responsible: Melanie Davidson, Vice President and Controller, who can be reached by email at mdavidson@stanfordchildrens.org

View Audit 5637

Finding 3578 (2022-001)

Significant Deficiency 2022

King Philip Regional School District

MA

Subrecipient Monitoring Internal Control / Segregation of Duties

The District has implemented a grants manual during fiscal year 2023. Additional efforts are expected to ensure grant budgets are amended in an appropriate timeframe. Management will evaluate additional enhancements to policies and procedures. Due to the timing of the current year audit, the Distric...

The District has implemented a grants manual during fiscal year 2023. Additional efforts are expected to ensure grant budgets are amended in an appropriate timeframe. Management will evaluate additional enhancements to policies and procedures. Due to the timing of the current year audit, the District expects implementation overall and implementation with the June 30, 2024 year end.

View Audit 5592

Finding 3557 (2022-001)

Material Weakness 2022

Holt, County of

MO

Reporting Subrecipient Monitoring § 200.510

Beginning in 2023, the Holt County Clerk has implemented a process to obtain award letters from grant writers and documenting the funding details. The Holt County Clerk is looking into software which is able to track projects year over year to make reporting more manageable.

View Audit 5564

Finding 3500 (2022-003)

Significant Deficiency 2022

Barry County, Missouri

MO

Reporting Subrecipient Monitoring

The treasurer will create a spreadsheet to help in the tracking of federal funds. The treasurer is currently working on the spreadsheet and is in the process of looking up all 2023 funds that will be ready for the 2024 budget year.

View Audit 5501

Finding 3436 (2022-002)

Significant Deficiency 2022

Juneau County Housing Authority

WI

Subrecipient Monitoring Internal Control / Segregation of Duties

2022-002 ,I nsufficient Collateral Corrective Action Planned: The Authority will closely monitor all deposits to make sure that the amount of funds on deposit are protected by federal deposit insurance, corporate surety bond, or collateral. Completion Date: December 31, 2023

View Audit 5389

Finding 3431 (2022-002)

Significant Deficiency 2022

West Central Texas Council of Governments

TX

Subrecipient Monitoring Reporting

The Council has employed a CPA with extensive knowledge of grant management and accounting to reconcile and monitor grant awards and ensure proper financial reporting. The Council will reconcile grant receivables and ensure accurate grant accounting on an ongoing basis, particularly at fiscal year e...

The Council has employed a CPA with extensive knowledge of grant management and accounting to reconcile and monitor grant awards and ensure proper financial reporting. The Council will reconcile grant receivables and ensure accurate grant accounting on an ongoing basis, particularly at fiscal year end. As a result, the Council will be prepared to complete their single audit in a timely manner and in accordance with federal guidelines.

View Audit 5378

Finding 3427 (2022-002)

Significant Deficiency 2022

West Central Texas Regional Foundation

TX

Subrecipient Monitoring Reporting

The Foundation has employed a CPA with extensive knowledge of grant management and accounting to reconcile and monitor grant awards and ensure proper financial reporting. The Foundation will reconcile grant receivables and ensure accurate grant accounting on an ongoing basis, particularly at fiscal ...

The Foundation has employed a CPA with extensive knowledge of grant management and accounting to reconcile and monitor grant awards and ensure proper financial reporting. The Foundation will reconcile grant receivables and ensure accurate grant accounting on an ongoing basis, particularly at fiscal yearend. As a result, the Foundation will be prepared to complete their single audit in a timely manner and in accordance with federal guidelines.

View Audit 5376

Finding 3392 (2022-012)

Significant Deficiency 2022

City of Philadelphia

PA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

Assistance Listing 93.558 Temporary Assistance for Needy Families Assistance Listing 93.658 Foster Care – Title IV-E Act 148 Pennsylvania Department of Human Services ...

Assistance Listing 93.558 Temporary Assistance for Needy Families Assistance Listing 93.658 Foster Care – Title IV-E Act 148 Pennsylvania Department of Human Services Views of the Responsible Officials and Corrective Action Plan: Effective 10/13/23, DHS has been preparing FY24 funding allocation letters that will be sent to provider agencies immediately. Going forward, the funding allocation letters will go out at the beginning of the contract fiscal year. Contact Person: Landuleni Shipanga, Controller, Department of Human Services, 215-683-6366.

View Audit 5296

Finding 3391 (2022-011)

Significant Deficiency 2022

City of Philadelphia

PA

Subrecipient Monitoring § 200.332

Assistance Listing 93.558 Temporary Assistance for Needy Families ...

Assistance Listing 93.558 Temporary Assistance for Needy Families Views of the Responsible Officials and Corrective Action Plan: Management agrees with the finding and recommendation. Starting from FY2024, MOCEO will include a Notice of Award document for all subrecipients contracts. This document will contain the necessary OMB required information to clearly identify award details for the subrecipient. Contact Person: Allison Elliott, Director of Finance, Mayor’s Office of Community Empowerment and Opportunity, 215-685-3626

View Audit 5296

Finding 3389 (2022-010)

Material Weakness 2022

City of Philadelphia

PA

Subrecipient Monitoring Reporting

Assistance Listing 93.268 Immunization Cooperative Agreements Assistance Listing 93.940 HIV Prevention Activities Health Department Based ...

Assistance Listing 93.268 Immunization Cooperative Agreements Assistance Listing 93.940 HIV Prevention Activities Health Department Based Views of the Responsible Officials and Corrective Action Plan: The Department of Public Health will strengthen procedures to ensure the accuracy and submission of FFATA reports. The Division of Disease Control (DDC) acknowledges the discrepancy within the submitted FFATA report for Immunization Cooperative Agreements Grant Program (ALN 93.268). DDC will implement appropriate review and preparation for all FFATA reporting by querying the necessary systems to gather and identify all pertinent information regarding contracts and amounts. The Division of HIV Health’s FFATA reports were late due to employee turnover and attempts to obtain information from providers. The Division of HIV Health is researching the fact that expenditure information for the FFATA reports included only six month of awards and not the full twelve months, as well as the fact that a subaward was not included in the source document used in preparation of the FFATA report. Contact Person(s): Ryan Taylor, Chief Operating Officer and Deputy Commissioner, Philadelphia Department of Public Health, 215-686-5207 Kathleen Brady, Director/ Medical Director, Division of HIV Health, Philadelphia Department of Public Health, 215-685-4778

View Audit 5296

Finding 3387 (2022-014)

None 2022

City of Philadelphia

PA

Questioned Costs Subrecipient Monitoring Reporting

Assistance Listing 21.023 Emergency Rental Assistance Program (ERAP) ...

Assistance Listing 21.023 Emergency Rental Assistance Program (ERAP) Views of the Responsible Officials and Corrective Action Plan: We disagree with the finding regarding spending reported to the Commonwealth of Pennsylvania. Prior to April 2022, reporting to the state was generated from a reporting dashboard within the Quickbase database. Internal controls checking these reports against raw data revealed an issue with the programming of the dashboard, and beginning in April 2022, reports were generated using raw data downloaded from the portal. Once this issue was detected and resolved, PHDC and the City sent updated and corrected reporting to the Commonwealth, along with a statement detailing our shift in methodology. This shift, and the corrected reports, were accepted by the Commonwealth, as shown in the email chains that were provided to the Controller’s Office. The data underlying the original ERA1 and ERA2 January 2022 reports cited in the finding cannot be recreated since the errors have now been permanently corrected. Auditor’s Comments on Agency’s Response: Regarding the corrected reports provided via email chains with the Commonwealth to our office, we have the following comment: Only one email chain provided had an attached “updated historical check” for ERAP1, submitted to the Commonwealth in July 2022. The historical check included a line item for the month in question, January 2022, but was still reporting the amounts of $173,807 and $22,042 for the Administrative Paid categories (See Table 6). These amounts remain unsubstantiated per our audit testing. Additionally, no corrected reports or updated historical checks were provided via these email chains to address the discrepancies noted for ERAP2 (See Table 7). Contact Person: Dan Gasiewski, Chief Grants Compliance Officer, Grants Office, Office of the Director of Finance

View Audit 5296 Questioned Costs: $1

Finding 3208 (2022-001)

Material Weakness 2022

Partners in Prevention Education

WA

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Internal Control over Cash Receipts and Disbursements Name of contact person and title: Charlia Messinger, Executive Director Anticipated completion date: 12/31/23 Agency’s response: Concur the organization agrees with this finding and will implement the following:Partners in Prevention Education w...

Internal Control over Cash Receipts and Disbursements Name of contact person and title: Charlia Messinger, Executive Director Anticipated completion date: 12/31/23 Agency’s response: Concur the organization agrees with this finding and will implement the following:Partners in Prevention Education will adopt internal control procedures matching requirements from 2 CFR section 200.303 and other government standards of non-profit financial control. This will be adopted by the Executive Director and Board by December 31, 2023.

View Audit 5229

Finding 3141 (2022-002)

Material Weakness 2022

Pike County

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.308 § 200.309 § 200.403

The County plan has been implemented.

View Audit 5115

Finding 3140 (2022-001)

Material Weakness 2022

Pike County

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

The County plan has been implemented.

View Audit 5115

Finding 3098 (2022-006)

None 2022

City of West Haven, Ct

CT

Subrecipient Monitoring Internal Control / Segregation of Duties

Compliance Finding The Education Department did not obtain and review the certified payrolls from a construction vendor to verify the contractor's compliance with prevailing wage rate requirements. The Education Department will review their procedures to ensure compliance with federal awards vendo...

Compliance Finding The Education Department did not obtain and review the certified payrolls from a construction vendor to verify the contractor's compliance with prevailing wage rate requirements. The Education Department will review their procedures to ensure compliance with federal awards vendor contract request and request the certified payrolls from the contractors or subcontractors The implementation of this recommendation will be monitored by Matthew Cavallaro, Business Manager.

View Audit 5029

Finding 3083 (2022-005)

Material Weakness 2022

City of West Haven, Ct

CT

Allowable Costs / Cost Principles Subrecipient Monitoring

Compliance Finding Funds were embezzled from the City using fictitious vendors established by the City employees who were managing the Coronavirus Relief Fund (CRF) program. The invoices for the fictitious vendors were charged to a line item designated for the CRF program. The grant reporting to th...

Compliance Finding Funds were embezzled from the City using fictitious vendors established by the City employees who were managing the Coronavirus Relief Fund (CRF) program. The invoices for the fictitious vendors were charged to a line item designated for the CRF program. The grant reporting to the State for the CRF program was performed by the Finance Director and not by the Grant Coordinator Department. The original reporting of the specific disbursements for the program included the invoices for the fictitious vendors. The reporting was subsequently revised to remove the fraudulent invoices. Beginning in Fiscal 2023, several policies and procedures were implemented over Grants and all other spending to reduce the risk of embezzlement. These policies include the Vendor Approval process including segregation of duties, the Debarment Check process (federal grant specific), and Finance Director and Treasurer invoice review prior to check printing. All elements were fully implemented in Fiscal 2024.

View Audit 5029

Finding 3031 (2022-002)

None 2022

City of Fall River

MA

Subrecipient Monitoring Reporting Program Income § 200.328

Condition: As of the June 30, 2022 reporting date, the City’s Project and Expenditure Reports overstated expenditures by $274,713 and overstated obligations by $14,045,059. Corrective Action Planned: ARPA Director reviews all expenditures for the quarter with City Auditor to reconcile cumulative ...

Condition: As of the June 30, 2022 reporting date, the City’s Project and Expenditure Reports overstated expenditures by $274,713 and overstated obligations by $14,045,059. Corrective Action Planned: ARPA Director reviews all expenditures for the quarter with City Auditor to reconcile cumulative expenditures and obligations for entry into portal. Anticipated Completion Date: October 31, 2023 Contact: Bridget Almon, Director of Financial Services Kara Humm, ARPA Director Sedryk Sousa, City Auditor

View Audit 4974

Finding 3030 (2022-001)

None 2022

City of Fall River

MA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Condition: During the testing of grant transactions, it was determined that an invoice for security equipment was not part of an approved project. Corrective Action Planned: The City is reimbursing the ARPA grant for the $45,000 through the general fund in FY24. Procedures for ARPA purchasing: A...

Condition: During the testing of grant transactions, it was determined that an invoice for security equipment was not part of an approved project. Corrective Action Planned: The City is reimbursing the ARPA grant for the $45,000 through the general fund in FY24. Procedures for ARPA purchasing: ARPA Director reviews all invoices for ARPA spending, reconciles the contracts and submits to Law Clerk to input for processing. ARPA Director reviews all vendors requested for state and federal procurement compliance. Anticipated Completion Date: Fiscal year 2024 Contact: Bridget Almon, Director of Financial Services Kara Humm, ARPA Director Sedryk Sousa, City Auditor

View Audit 4974 Questioned Costs: $1

Finding 3022 (2022-002)

Significant Deficiency 2022

Monroe County Board of Education

GA

Questioned Costs Procurement, Suspension & Debarment School Nutrition Programs § 200.303 § 200.318 § 200.320

FA 2022-002 Strengthen Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass...

FA 2022-002 Strengthen Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Significant Deficiency Compliance Impact: Nonmaterial Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 10.553 - School Breakfast Program 10.555 - National School Lunch Program Federal Award Number: 225GA324N1199; 225GA324N1199 Questioned Costs: $474 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement procedures were followed. Corrective Action Plans: The School District has returned to following its approved procurement procedures. Estimated Completion Date: July 1, 2023 Contact Person: Chris Johnson, CGFM, Director of Financial Services Telephone: 478-994-2031 Email: chris.johnson@mcschools.org

View Audit 4890 Questioned Costs: $1

Corrective Action Plans

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