Corrective Action Plans

Finding 375831 (2021-001)

Material Weakness 2021

California Asian Pacific Chamber of Commerce

CA

Reporting Subrecipient Monitoring Material Weakness

Description of Finding: Untimely audit submission in accordance with OMB Uniform Guidance Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the seriousness of this deficiency an...

Description of Finding: Untimely audit submission in accordance with OMB Uniform Guidance Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the seriousness of this deficiency and the need for strict adherence to timely audit submissions per the OMB Uniform Guidance. Additional staff have been hired to assist in accounting processes; and an Interim Controller has been hired to review all accounting processes and procedures with the Director of Finance, provide best practice recommendations and month-end closing schedule. Monthly reviews of the financial data, including reconciliations of all accounts will be performed and reviewed by the Controller and Director of Finance. Implementation of these recommendations will help to mitigate the risk of untimely submissions in future years. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: July 2024

View Audit 294918

Finding 375496 (2021-015)

Material Weakness 2021

Okmulgee County

OK

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

Management will work together to design and implement procedures to address county wide controls over federal programs and to ensure compliance with grant agreements.

View Audit 294536

Finding 375420 (2021-004)

Material Weakness 2021

Municipality of Morovis

PR

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.302 § 200.403

We concur with the finding. The pandemic caused by the outbreak of COVID-19 disrupted and delayed many accounting and reporting processes during the fiscal years 2020 and 2021 since the Municipality had to shut down operations for various months. Consequently, several projects and tasks calendarized...

We concur with the finding. The pandemic caused by the outbreak of COVID-19 disrupted and delayed many accounting and reporting processes during the fiscal years 2020 and 2021 since the Municipality had to shut down operations for various months. Consequently, several projects and tasks calendarized were postponed or delayed, including certain reports and controls required by the Federal Regulations. As of the date of this Corrective Action Plan, the transaction detail of the Disaster Grant costs incurred on fiscal year ending on June 30, 2021 was produced, under alternate methods, from the Finance Department’s accounting system and submitted to the external auditor. Expected Implementation Date: The transaction details applicable to financial statements of fiscal periods ended June 30, 2021 were completed. Transactions detail analysis during the following fiscal years were already completed. Responsible Person: Finance Department Director and Federal Program Director.

View Audit 294483

Finding 375419 (2021-003)

Material Weakness 2021

Municipality of Morovis

PR

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.302 § 200.403

We concur with the finding. The pandemic caused by the outbreak of COVID-19 disrupted and delayed many accounting and reporting processes during the fiscal years 2020 and 2021 since the Municipality had to shut down operations for various months. Consequently, several projects and tasks calendarized...

We concur with the finding. The pandemic caused by the outbreak of COVID-19 disrupted and delayed many accounting and reporting processes during the fiscal years 2020 and 2021 since the Municipality had to shut down operations for various months. Consequently, several projects and tasks calendarized were postponed or delayed, including certain reports and controls required by the Federal Regulations. As of the date of this Corrective Action Plan, the transaction detail of CDL costs incurred on fiscal year ending on June 30, 2021 was produced, under alternate methods, from the Finance Department’s accounting system and submitted to the external auditor. Expected Implementation Date: The transaction details applicable to financial statements of fiscal periods ended June 30, 2021 were completed. Transactions detail analysis during the following fiscal years were already completed.Responsible Person: Finance Department Director and Federal Program Director.

View Audit 294483

Finding 375385 (2021-013)

Material Weakness 2021

Cleveland County

OK

Questioned Costs Subrecipient Monitoring § 200.332

2021-013 Lack of Internal Controls and Noncompliance with Subrecipient Monitoring - Emergency Rental Assistance Program The County has met with the Oklahoma State Auditor & Inspector's office m reference to Finding 2021-013 lack of internal controls and noncompliance with sub-recipient monitoring re...

2021-013 Lack of Internal Controls and Noncompliance with Subrecipient Monitoring - Emergency Rental Assistance Program The County has met with the Oklahoma State Auditor & Inspector's office m reference to Finding 2021-013 lack of internal controls and noncompliance with sub-recipient monitoring requirements for the Emergency Rental Assistance Program. We agree with the auditor's recommendation and will take the following corrective actions: I . Design and implement internal controls to ensure compliance with all applicable federal laws, regulations, and grant requirements for current and future ERA grants. This will include: a) Amend written policies and procedures to better included sub-recipient monitoring, including requirements for sub-recipients to provide supporting documents for actual administrative expenditures incurred rather than receiving advance payments. b) Providing annual training to staff on the new sub-recipient monitoring policies and procedures. c) Implementing a documentation and review process to ensure sub-recipients are properly informed of federal requirements related to allowable cots and that expenditures are supported before payment. 2. Strengthen sub-recipient agreements to include clear requirements around supporting documents for administrative costs. 3. Increase monitoring of sub-recipients through periodic desk audits and site visits to review expenditures and supporting documentation. The County takes these findings seriously and will implement robust internal controls and subrecipient monitoring procedures to ensure full compliance with federal grant requirements and prevent any future noncompliance or questioned costs. We appreciate the auditor identifying these issues so they can be properly addressed and corrected. Please let us know if any additional information or documentation is needed regarding the corrective actions. Anticipated Completion Date: November 27,2023 Responsible Contact Person: Rod Cleveland,Chairman BOCC

View Audit 294443 Questioned Costs: $1

Finding 374621 (2021-003)

Significant Deficiency 2021

Saint Charles County, Missouri

MO

Subrecipient Monitoring Reporting Significant Deficiency

FFATA Reporting – Community Development Block Grants U.S. Department of Housing and Urban Development Recommendation: We recommend the agency implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports and training employees...

FFATA Reporting – Community Development Block Grants U.S. Department of Housing and Urban Development Recommendation: We recommend the agency implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports and training employees on the FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will identify all federal awards that FFATA reporting is required. Once all of the requirements are identified, the County will then determine if there are eligible subrecipients or contracts that need to be reported on the FFATA website. Name(s) of the contact person(s) responsible for corrective action: Tracy Bayne Planned completion date for corrective action plan: September 30, 2024

View Audit 294294

Finding 374620 (2021-002)

Significant Deficiency 2021

Saint Charles County, Missouri

MO

Subrecipient Monitoring HUD Housing Programs Reporting

FFATA Reporting - Housing Choice Voucher U.S. Department of Housing and urban Development Recommendation: We recommend the agency implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency ACT (FFATA) reports and training employees on the FFAT...

FFATA Reporting - Housing Choice Voucher U.S. Department of Housing and urban Development Recommendation: We recommend the agency implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency ACT (FFATA) reports and training employees on the FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will identify all federal awards that FFATA reporting is required. Once all of the requirements are identified, the County will then determine if there are eligible subrecipients or contracts that need to be reported on the FFATA website. Name(s) of the contact person(s) responsible for corrective action: Tracy Bayne Planned completion date for corrective action plan: September 30, 2022

View Audit 294294

Finding 371944 (2021-006)

Significant Deficiency 2021

Martin University

IN

Subrecipient Monitoring Reporting

The University failed to complete and file its annual audit and complete its filing with the federal audit clearing house for the June 30, 2021 year end. Corrective action: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual training on SFA federal...

The University failed to complete and file its annual audit and complete its filing with the federal audit clearing house for the June 30, 2021 year end. Corrective action: In 2022, the board of trustees expanded the duties of the Audit and Finance Committee to include annual training on SFA federal and state financial reporting regulations and audit requirements. The University also will provide risk assessment training to all board members and the President’s Cabinet focusing on covering common risk factors of institutions of higher education. The University hired a new CFO in November 2023 and completed its FY2021 audit in December 2023. The University received an extension from the DOE to complete its FY2022 audit by March 2024. Person responsible: E. ZeNai Savage, CPA, CFO and Executive VP of Finance and Administration Anticipated Completion Date: June 30, 2024

View Audit 293212

Finding 371310 (2021-012)

Material Weakness 2021

City of Bethel, Alaska

AK

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

Finding 2021‐012 Expenditure Approval – Activities Allowed and Unallowed, Allowable Costs – Material Weakness in Internal Control over Compliance Corrective Action Plan Management will implement policies and procedures to ensure expenditures are reviewed timely and approved prior to posting. Expecte...

Finding 2021‐012 Expenditure Approval – Activities Allowed and Unallowed, Allowable Costs – Material Weakness in Internal Control over Compliance Corrective Action Plan Management will implement policies and procedures to ensure expenditures are reviewed timely and approved prior to posting. Expected Completion Date Fiscal Year 2025.

View Audit 292985

Finding 371307 (2021-009)

Material Weakness 2021

City of Bethel, Alaska

AK

Subrecipient Monitoring § 200.332 § 200.501

Finding 2021‐009 Monitoring Activities – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are establish...

Finding 2021‐009 Monitoring Activities – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal award information. Expected Completion Date Fiscal Year 2025.

View Audit 292985

Finding 371306 (2021-008)

Material Weakness 2021

City of Bethel, Alaska

AK

Subrecipient Monitoring § 200.332 § 200.501

Finding 2021‐008 Subrecipient Agreements – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are establi...

Finding 2021‐008 Subrecipient Agreements – Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will revise the policies and procedures related to subrecipient monitoring and will ensure that policies are established to ensure subawards contain the required federal award information. Expected Completion Date Fiscal Year 2025.

View Audit 292985

Finding 371302 (2021-005)

Material Weakness 2021

City of Bethel, Alaska

AK

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness § 200.512

Finding 2021‐005 Deadline for Federal Single Audit – Reporting – Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will ensure beginning balance reconciliations and year‐end adjustments will be complete by September, and will work with external...

Finding 2021‐005 Deadline for Federal Single Audit – Reporting – Noncompliance and Material Weakness in Internal Control over Compliance Corrective Action Plan Management will ensure beginning balance reconciliations and year‐end adjustments will be complete by September, and will work with external auditors to have a financial statement draft prior to their fieldwork. Expected Completion Date Fiscal year 2025.

View Audit 292985

Finding 370588 (2021-013)

Material Weakness 2021

Kickapoo Tribe in Kansas

KS

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2021-013 Procurement Individual(s) Responsible: Grace Ross, Tribal Treasurer, Accounting Director, Program Directors Action: Will adhere to Procurement Policy and will check for Debarment for all vendors. Anticipated Completion Date: March 2024

View Audit 292271

Finding 370586 (2021-009)

Material Weakness 2021

Kickapoo Tribe in Kansas

KS

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Finding 2021-009 Reporting Individual(s) Responsible: Grace Ross, Tribal Treasurer, Tribal Administrator Action: Reviewing reporting requirements with department heads and reviewing reports submitted. Anticipated Completion Date: April 2024

View Audit 292271

Finding 370052 (2021-007)

Material Weakness 2021

Delaware County

OK

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

We will work to implement a risk assessment plan. We will implement controls to help make sure we are m compliance with all grant requirements and federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct complian...

We will work to implement a risk assessment plan. We will implement controls to help make sure we are m compliance with all grant requirements and federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compliance supplement to work from.

View Audit 291562

Finding 369779 (2021-002)

Significant Deficiency 2021

Housing Authority of the Birmingham District

AL

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

Recommendation: The Authority should implement additional controls related to monitoring timelines and review and retention of tenant’s inspection. The support of abatement, inspection results should be kept in the tenant file or centralized location. We recommend management should designate one per...

Recommendation: The Authority should implement additional controls related to monitoring timelines and review and retention of tenant’s inspection. The support of abatement, inspection results should be kept in the tenant file or centralized location. We recommend management should designate one person to oversee the inspection process to ensure that all inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response to finding: The Authority will implement additional controls related to monitoring timelines and review and retention of tenant’s inspection. During the year, the Authority faced turnover in the Section 8 department, which caused internal controls to not operate effectively. Name of the contact person responsible for corrective action: Dontrelle Young Foster, Executive Director Planned completion date for corrective action plan: We expect to have the finding resolved by issuance of next year's audit. If the U.S. Department Housing and Urban Development has questions regarding this plan, please call Dontrelle Foster at (205) 521-0623.

View Audit 291312 Questioned Costs: $1

Finding 369484 (2021-003)

Significant Deficiency 2021

Ka Mana O Na Helu

HI

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles

Views of Responsible Officials and Corrective Action - Responsible Party: Director of Operations - KMNH has updated our draft policies and procedures to incorporate §200.318 through §200.327 of the Uniform Guidance procurement standards to ensure compliance with Federal standards. The policies and ...

Views of Responsible Officials and Corrective Action - Responsible Party: Director of Operations - KMNH has updated our draft policies and procedures to incorporate §200.318 through §200.327 of the Uniform Guidance procurement standards to ensure compliance with Federal standards. The policies and procedures will be sent for approval from the KMNH BOD during the next BOD meeting scheduled for April 26, 2024. ESG CV contractors selected were not impacted by the lack on inclusion of the procurement standards in our policies and procedures as KMNH was not responsible for the selection and/or procurement.

View Audit 290718

Finding 369395 (2021-006)

Material Weakness 2021

So Consortium

OH

Subrecipient Monitoring § 200.332

Planned Corrective Action: The Consortium will implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports will be supported by the accoun...

Planned Corrective Action: The Consortium will implement procedures to ensure quarterly reports are filed no later than the tenth calendar day of the second month following the quarter the report represents. In addition, all data reported thru these quarterly reports will be supported by the accounting system of the Fiscal Agent and County Financial Information System (CFIS). Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

View Audit 290596

Finding 369391 (2021-003)

Material Weakness 2021

So Consortium

OH

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.414 § 200.502 § 200.510

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track ...

Planned Corrective Action: The Fiscal Agent and Board Management will review all grant and loan award documents in order to execute policies and procedures which help ensure compliance with grant agreements, including Schedule reporting requirements. The Consortium will implement a system to track all federal expenditures and related information separately from other expenditures and report federal expenditures with proper support including, but not limited to, grant agreements, calculation of the expenditures, and any federal reporting requirements. Anticipated Completion Date: March 31, 2024 Responsible Contact Person: Crystal Keaton

View Audit 290596

Finding 369278 (2021-024)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Subrecipient Monitoring Cash Management

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run throug...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: Primarily the University implemented a robust ERP tool Ellucian Colleague that will assist in the administration and management of Title IV programs. COD processes are run through Colleague's CODE (Common Originators Disbursement Ellucian) system, which is used to send origination requests and disbursement information for Pell and Federal loans to COD. Funds are transmitted to a student's account through a two-part process run between the Financial Aid Office (FAO) and the Business Office. The Finanical Aid Office is responsible for sending loan originations and disbursments to COD within 15 days. The data extraction process will be more consistent using the workflows provided by the new ERP system. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369247 (2021-021)

Material Weakness 2021

Saint Augustine's University

NC

Student Financial Aid Internal Control / Segregation of Duties Special Tests & Provisions

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved as the financial aid department can now track transfer students and any changes to their financial aid ...

Name of Responsible Individual: Denise Hicks-Mial, Director, Office of Financial Aid and Scholarships Corrective Action: With the implementation of Ellucian Colleague this issue has been resolved as the financial aid department can now track transfer students and any changes to their financial aid while informing other institutions of those changes through the National Student Loan Data System (NSLDS). This issue has been resolved with the implementation of Colleague. The Financial Aid Director can now perform transfer monitoring in Colleague to track transfer students and any changes to their financial aid while informing other institutions of those changes. Colleague sends information files to the National Student Loan Data System (NSLDS), which notifies NSLDS of our transfer students and serves as a request to put SAU's transfer students on the NSLDS maintained Transfer Monitoring list. The inform file is also a request for a Financial Aid History file for each student listed. With Colleague, we can determine which students to monitor, send the information to NSLDS, transfer the files, and view students' NSLDS information as necessary. The Financial Aid Director runs transfer monitoring at the beginning of the semester for everyone enrolled and then runs TMXP, which creates a file to monitor those who are newly awarded, Students are run through the process in December for new transfer student can be monitored. With Colleague, the Financial Aid Director/Staff can easily adhere to the "Inform, Monitor, Alert" process since this system can efficiently and effectively run this process. Prior to awarding a transfer for spring the Financial Aid Staff as alternative option review NSLDS and manually add a student to the transfer monitoring file. Anticipated Completion Date: December 31, 2023

View Audit 290538

Finding 369246 (2021-017)

Material Weakness 2021

Saint Augustine's University

NC

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: Given the challenges that current management faced in regard to the lack of proper accounting, document retention and internal controls over financial reporting that took...

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: Given the challenges that current management faced in regard to the lack of proper accounting, document retention and internal controls over financial reporting that took place during fiscal year 2021, there were significant delays in the audit. With the implementation of the new ERP system and new internal policies being put in place this should keep future delays at a minimum. New policies and procedures are being developed to ensure the timeliness of documentation to meet required deadlines. Anticipated Completion Date: June 30, 2024

View Audit 290538

Finding 369245 (2021-016)

Material Weakness 2021

Saint Augustine's University

NC

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: The enhanced internal controls and policies and procedures now in place over the financial reporting process will aid current management in the accurate and timely compl...

Name of Responsible Individual: Dr. Lynda Batiste, Senior Vice President of Finance & Chief Operating Officer Corrective Action: The enhanced internal controls and policies and procedures now in place over the financial reporting process will aid current management in the accurate and timely completion of the Schedule of Expenditures of Federal Awards (SEFA). Additionally, current management has reviewed the reporting requirements for the SEFA and going forward, grant setup procedures will include a checklist that will identify the correct federal grant name (and cluster, if applicable), assistance listing number and total expenditure amount per program to ensure accuracy in reporting on the SEFA. Additionally, further review will be conducted by the Controller and Vice President of Finance to ensure accuracy. Anticipated Completion Date: June 30, 2024

View Audit 290538

Finding 366956 (2021-005)

Material Weakness 2021

Mogadore Local School District

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

The district will verify vendors

View Audit 290138

Finding 366447 (2021-003)

Material Weakness 2021

US Helping Us, People Into Living, Inc.

DC

Procurement, Suspension & Debarment Subrecipient Monitoring

Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they are not in suspension...

Views of Responsible Officials and Corrective Action: Upon recommendation from the Auditor, Us Helping Us began submission of all potential employees, contractors, and consultants to the System for Award Management (SAM) Exclusion and Debarment Search System to ensure that they are not in suspension or debarment. Us Helping Us will maintain documentation of these searches, retain them in vendor files. Screenings will be conducted on an annual basis. Retrospective screenings were conducted as requested during the audit. In addition to access to SAM.gov, Us Helping Us is using the services of Office of Inspector General (OIG) Exclusion Search and Software Company. Services provided include OIG Searches as well as SAM and State Exclusion searches. Us Helping Us staff will be educated about these procedures. The Executive Director and the Deputy Executive Director, Finance and Administration will be responsible for developing, implementing, and maintaining the plan, which will be effective immediately.

View Audit 16114

Corrective Action Plans

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