Corrective Action Plans

Finding 39845 (2022-005)

Material Weakness 2022

Western Heights Independent School District No. I-41

OK

Questioned Costs Equipment & Real Property Management Procurement, Suspension & Debarment § 200.313

2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Recommendation: The auditor recommended that property...

2022-005 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Recommendation: The auditor recommended that property be properly tracked. The auditor also recommended that procedures be put in place to properly identify property transaction and track property acquired with federal funds. Action Taken: District will hire an asset management company, which will complete an initial database of District property and barcode items. Afterwards, District will maintain database. Encumbrance clerk has implemented new procedures to monitoring the coding of items greater than $5,000 with lite longer than a year is properly coded in OCAS. Federal Programs Director will manage budgets and make sure if property/equipment will be purchased it is budgeted and proper approval to be obtained before purchase. Federal Program Director will also monitor during claim process, property items have been identified and tracked on District equipment listing. Anticipated Completion Date: May 2023 Responsible Official: Superintendent

View Audit 45226 Questioned Costs: $1

Finding 39844 (2022-004)

Material Weakness 2022

Western Heights Independent School District No. I-41

OK

Questioned Costs Subrecipient Monitoring § 200.430

2022-004 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Recommendation: The Auditor recommended that The Dist...

2022-004 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Recommendation: The Auditor recommended that The District needs to have time and effort documentation maintained. The District needs to develop procedures to maintain documentation supporting work performed. Action Taken: District was unaware of the time and effort requirement for this program. New Federal Program director is monitoring this time and effort. FY23 the time and effort documentation has been kept for this program. Anticipated Completion Date: May 2023 Responsible Official: Superintendent

View Audit 45226 Questioned Costs: $1

Finding 39815 (2022-004)

Material Weakness 2022

Pueblo County Colorado

CO

Subrecipient Monitoring § 200.303 § 200.331 § 200.332

Recommendation: We recommend that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subr...

Recommendation: We recommend that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will ensure that all subrecipients of American Rescue Plan (APRA) funds are monitored by using appropriate subrecipient monitoring procedures to ensure compliance with the grant awarded throughout the contract period. Name(s) of the contact person(s) responsible for corrective action: Sherri Crow, Interim Director of Budget and Finance Planned completion date for corrective action plan: January 1, 2024

View Audit 34720

Finding 39814 (2022-003)

Material Weakness 2022

Pueblo County Colorado

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.318 § 200.326

Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. A...

Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement new policies and procedures to ensure that all expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Name(s) of the contact person(s) responsible for corrective action: Sherri Crow, Interim Director of Budget and Finance Planned completion date for corrective action plan: January 1, 2024

View Audit 34720

Finding 39800 (2022-001)

Significant Deficiency 2022

Pact, Inc.

DC

Subrecipient Monitoring

Finding No. 2022-001 Program Assistance Listing Number 98.001 USAID Foreign Assistance for Programs Corrective Action Effective April 2023, Management implemented a new process that strengthens the internal controls over the FFATA reporting ...

Finding No. 2022-001 Program Assistance Listing Number 98.001 USAID Foreign Assistance for Programs Corrective Action Effective April 2023, Management implemented a new process that strengthens the internal controls over the FFATA reporting to ensure the required reports are submitted within the required timeframe and records of submitted reports are maintained. Anticipated Completion Date Person Responsible for Implementation September 2023 Kenery Gallagher Sr. Director of Global Ethics & Compliance (202) 466-5666

View Audit 37529

Finding 39796 (2022-002)

None 2022

City of Fort Lauderdale

FL

Questioned Costs Subrecipient Monitoring

View of responsible officials and planned corrective actions: The City identified this issue also during performance of the subrecipient annual monitoring. A monitoring letter was submitted with the noted findings to the agency of Sunserve, with a corrective action plan returned to acknowledge the f...

View of responsible officials and planned corrective actions: The City identified this issue also during performance of the subrecipient annual monitoring. A monitoring letter was submitted with the noted findings to the agency of Sunserve, with a corrective action plan returned to acknowledge the finding. The City scheduled a mandatory training on January 12, 2023, which required a minimum of 2 people per agency to attend, and educated on the proper way to perform income verifications and document within the PE system.

View Audit 37962 Questioned Costs: $1

Finding 39762 (2022-001)

Material Weakness 2022

South Bend School District No. 118

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Equipment & Real Property Management

Corrective action the auditee plans to take in response to the finding: Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements Name, address, and telephone of District contact person: Barbara Cenci, Busi...

Corrective action the auditee plans to take in response to the finding: Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements Name, address, and telephone of District contact person: Barbara Cenci, Business Manager 304 S. Adams St South Bend, WA 98586 (360) 875-6041 Corrective action the auditee plans to take in response to the finding: The district acknowledges the finding and concurs with those details, however the district also would like to point out we have already corrected the issue and implemented the plan below last June, 2022. There have been no issues related to this current finding since the issuing of the previous finding, and internal controls are in place. The district has taken corrective measures to ensure compliance with the Davis-Bacon Act requirements on all contracts moving forward. Specifically, please note the following actions: 1. The district business manager, accounts payable assistant, and Superintendent have each been trained on the Davis-Bacon Act and the required federal requirements related to contracts; 2. All contracts in excess of $2,000 entered into for construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds, will contain the required contract provisions; 3. Contracts utilizing federal funds will be identified as such during the procurement process; 4. The superintendent, prior to approving related contracts, will ensure required contract provisions are included. Anticipated date to complete the corrective action: June 2022

View Audit 46300

Finding 39733 (2022-001)

Material Weakness 2022

Columbiana County

OH

Subrecipient Monitoring Reporting

In response to your findings of incorrect reporting of subrecipients, subawards and over reported expenditures, the Commissioners will be contacting Clark Schaefer Hackett and they have advised they will guide us in the reporting process. When the next report is due they will be contacting Brian Mo...

In response to your findings of incorrect reporting of subrecipients, subawards and over reported expenditures, the Commissioners will be contacting Clark Schaefer Hackett and they have advised they will guide us in the reporting process. When the next report is due they will be contacting Brian Mosier for guidance in reporting the correct way. There has been very little help from the Federal Government with the reporting. We do not like receiving findings, so we will work to correct the situation.

View Audit 44058

Finding 39726 (2022-001)

Material Weakness 2022

Aberdeen School District No. 5

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regu...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Aberdeen School District No. 5 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District 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: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Fiscal Consultant 216 N. G Street, Aberdeen, WA 98520, (360)538-2007 Corrective action the auditee plans to take in response to the finding: The district will issue an RFP annually, with an option to extend the contract. The district will keep records of the cost analysis each time a need is identified and a provider is hired to fill that need. Additionally at the beginning of the year, the district will do a cost analysis based on the responses of the RFP per vendor with the services they are to be contracted. A staff member will also attend Procurement Boot camp training in compliance with OMB Uniform Grant Guidance. Anticipated date to complete the corrective action: July 2023

View Audit 44049

Finding 39698 (2022-006)

Material Weakness 2022

Real Services, Inc. and Affiliates

IN

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking

We concur with the recommendation. Management has remediated the finding. Funding is now separately identified on the Schedule of Expenditures of Federal and Nonfederal Awards. Additionally, Management has allocated additional resources to the Finance and Administration department to properly manage...

We concur with the recommendation. Management has remediated the finding. Funding is now separately identified on the Schedule of Expenditures of Federal and Nonfederal Awards. Additionally, Management has allocated additional resources to the Finance and Administration department to properly manage, track, and report grant awards. A shared SEFA index is maintained and a process for updating the document on an ongoing basis was instituted.

View Audit 36821

Finding 39693 (2022-001)

Significant Deficiency 2022

Building Markets Ltd.

NY

Subrecipient Monitoring Reporting

Views of Responsible Officials and Planned Corrective Actions: We will update our policies and procedures to ensure all first tier subawards in excess of $30,000 are accurately and timely registered. We will ensure any subawards are reported within the required timeframe.

View Audit 37541

Finding 39687 (2022-009)

Significant Deficiency 2022

Cook County, Illinios

IL

Subrecipient Monitoring § 200.208 § 200.332 § 200.338 § 200.425 § 200.501

Finding #2022-009: regarding subrecipient monitoring were not performed on the Health Equity Grant, Award# 11442, CFDA # 93.391 as required by CCH Policy and Federal Regulations. ...

Finding #2022-009: regarding subrecipient monitoring were not performed on the Health Equity Grant, Award# 11442, CFDA # 93.391 as required by CCH Policy and Federal Regulations. Cause: The cause of this finding resulted from subrecipients being identified as vendors in the Grant application. The Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff and/or external consultant to perform subrecipient monitoring. Correction Action: The CCH Director of Grant Accounting will engage an outside consultant to conduct subrecipient monitoring for the grant and collaboratively work to modify the established policy. Anticipated completion of the corrective action will be December 31, 2023.

View Audit 37825

Finding 39686 (2022-008)

Significant Deficiency 2022

Cook County, Illinios

IL

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding #2022-008: not complying with the Federal Funding Accountability and Transparency Act (FFATA) as required in the Health Equity Grant, Award # 11442, CFDA # 93.391, Notice of Award and Federal Regulations. ...

Finding #2022-008: not complying with the Federal Funding Accountability and Transparency Act (FFATA) as required in the Health Equity Grant, Award # 11442, CFDA # 93.391, Notice of Award and Federal Regulations. Cause: The cause of this finding resulted from having subrecipients in the grant application identified as vendors. As a result, staff classified the associated costs as Professional Services instead of Grant Disbursements which is used to identify subrecipient(s) on the Grant. The Program Lead informed Finance late which did not allow sufficient time to mobilize CCH staff to prepare and submit the FFATA reporting. Correction Action: The CCH Director of Grant Accounting will ensure that the FFATA reporting is submitted for all subawards more than the $30K as required by Federal Regulations. Program staff will be retrained to classify subrecipients properly and re-prioritize within the Finance Department?s established procedures. Anticipated completion of the corrective action will be December 31, 2023.

View Audit 37825

Finding 39682 (2022-002)

Significant Deficiency 2022

Cook County, Illinios

IL

Special Tests & Provisions Subrecipient Monitoring Allowable Costs / Cost Principles

Findings 2022 ? 002 Emergency Solutions Grant (ESG) Program, Federal Assistance Listing #14.231 Corrective Action Plan: Last year, the ESG program was monitored by the U.S. Departm...

Findings 2022 ? 002 Emergency Solutions Grant (ESG) Program, Federal Assistance Listing #14.231 Corrective Action Plan: Last year, the ESG program was monitored by the U.S. Department of Housing and Urban Development (HUD) local Office. This year, the ESG-Coronavirus (CV) program will be monitored by HUD. The local HUD office is currently working with DPD staff in various technical assistance workshop to prep for an upcoming session. These meetings have occurred since April 2023. At HUD?s request, DPD rewrote various policies and procedures. We are still awaiting HUD?s final approval on the recommended policies and procedures revisions. DPD will be using the revised policies and procedures to monitoring concerns going forward. ESG has a complicated billing structure which includes five (5) different spending areas from which a subrecipient can choose for payment. Unfortunately, the ESG and ESG-CV program includes one (1) dedicated staff person and support from the Deputy. This complicated billing structure forces DPD, to provide an extensive amount of technical assistance to various subrecipients due to incorrect invoice submissions. Many of the subrecipients are understaffed and lack the capacity to bill properly. On various occasions, DPD staff has spent a considerable amount of time assisting subrecipients with preparing request for reimbursements. The amount of technical assistance dedicated towards these efforts will be reduced as a result of ESG ending in December 2023 and a new grant cycle beginning in January 2024. ESG-CV will close permanently in September 2023. Recommendation/corrective action planning will be taken on future grant awards that may have similar compliance requirements. DPD plans to hire new staff to expedite the payment process as well as to provide technical assistance to our subrecipients. With ESG-CV ending in September 2023 and new staff on board, this should reduce the amount of time for processing payment to DPD subrecipients.

View Audit 37825

Finding 39681 (2022-001)

Significant Deficiency 2022

Cook County, Illinios

IL

Subrecipient Monitoring Procurement, Suspension & Debarment HUD Housing Programs

Findings 2022 - 001 Community Development Block Grant (CDBG)/Entitlement Grants Federal Assistance Listing Number 14.218 Corrective Action Plans: The Department of Planning and Dev...

Findings 2022 - 001 Community Development Block Grant (CDBG)/Entitlement Grants Federal Assistance Listing Number 14.218 Corrective Action Plans: The Department of Planning and Development (DPD) will update the current Policies and Procedures established for complying with Federal Funding Accountability and Transparency Act Subaward Reporting System and update the Sub-Recipients Required Information Form to inform staff of the threshold criteria which requires reporting of each subrecipient receiving $30,000.00 or more of CDBG funding. The updated form will include 1) HUD links identified below that will provide clarification, from archived trainings and 2) the latest regulations to ensure collection of pertinent and full award information. FSRS - Federal Funding Accountability and Transparency Act Subaward Reporting System https://www.hud.gov/program_offices/comm_planning/FSRS https://www.hudexchange.info/trainings/courses/fsrs-reporting-at-hud-cpd-learning-session/ https://files.hudexchange.info/resources/documents/ffata-subaward-reporting-system-webinar-slides.pdf DPD will incorporate a review of these processes during the department?s evaluation of Grant Agreement Execution procedures. Responsible Staff Person ? Deputy Director of Community Development DPD Schedule for Completion ? October 30, 2023 Anticipated Timeline for full Implementation of Corrective Action ? December 30, 2023

View Audit 37825

Finding 39668 (2022-001)

Significant Deficiency 2022

World Vision International and World Vision Inc.

WA

Subrecipient Monitoring Reporting Procurement, Suspension & Debarment

Finding 2022-001 ? Reporting - Late filing of FFATA required reports World Vision implemented an improved control process for collecting required information and trained relevant staff on the strengthened review procedures and the importance of submitting FFATA reports prior to the due date. Contact...

Finding 2022-001 ? Reporting - Late filing of FFATA required reports World Vision implemented an improved control process for collecting required information and trained relevant staff on the strengthened review procedures and the importance of submitting FFATA reports prior to the due date. Contact Person Responsible for Correct Action: Kenneth E. Botka Completion Date: March 11, 2022

View Audit 37786

Finding 39649 (2022-001)

Material Weakness 2022

Little Rock School District

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.439

Finding 2022-001 Allowable Costs/Cost Principles Criteria or Specific requirement: Purchases of equipment and other capital expenditures require the written approval of the Federal awarding agency or pass-through entity, as specified in Office of Management and Budget (OMB) 2 CFR section 200.439. ...

Finding 2022-001 Allowable Costs/Cost Principles Criteria or Specific requirement: Purchases of equipment and other capital expenditures require the written approval of the Federal awarding agency or pass-through entity, as specified in Office of Management and Budget (OMB) 2 CFR section 200.439. Condition: In our test of equipment purchases from the COVID-19 Education Stabilization Fund, we identified the purchase of 447 pieces of equipment with the unit costs greater than the $5,000 threshold for which the District did not obtain prior written approval from the Arkansas Division of Elementary and Secondary Education (DESE). Retroactive approval was subsequently obtained from DESE during the audit fieldwork. LRSD Response: The District will continue to monitor internal controls in regards to use of ESSER funds and ensure all prior approvals are granted by DESE before purchasing of capital assets with a unit value equal to or greater than $5,000. Responsible LRSD Staff: Kelsey Bailey, CDFO, will be responsible for ensuring compliance. Completion Date: Kelsey Bailey has made contact with Jayne Greene at DESE for guidance and retroactive approval was granted from DESE on March 9, 2023. Please let me know if additional information is needed. Respectfully, Kelsey Bailey Chief Deputy Finance & Operations Officer

View Audit 37215 Questioned Costs: $1

Finding 39622 (2022-003)

None 2022

Central Dewitt Community School District

IA

Questioned Costs Subrecipient Monitoring Equipment & Real Property Management § 200.313

The District will review current processes for purchasing equipment within Iowa Department of Education approval amounts or seek amendments when approval cost limits cannot be met. June 30, 2023 Cyndie Johnson

View Audit 46139 Questioned Costs: $1

Finding 39609 (2022-001)

Material Weakness 2022

Crescent School District No. 313

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Ashley Petersen, Business Manager PO Box 20 Joyce, WA 98343 (360) 928-3311 ext 1005 Corre...

Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Name, address, and telephone of District contact person: Ashley Petersen, Business Manager PO Box 20 Joyce, WA 98343 (360) 928-3311 ext 1005 Corrective action the auditee plans to take in response to the finding: The following corrective action has been applied to the finding below: Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clauses in the contracts with two contractors o The Crescent School District contract used for all public works will be updated with the appropriate language. The school is utilizing information from SAO, OSPI, WASBO, and Business Manager peers to compile a contract that complies with state and federal requirements. ? Collect weekly certified payroll reports from the contractors to confirm they paid laborers proper prevailing wages o Crescent School District will use the LNI Contractor Awards Portal for tracking all public works projects. The portal will help track all necessary documents for the project. A checklist provided by OSPI will be referenced for each project and calendar reminders will be set to follow up on weekly prevailing wage for projects as needed. In addition, more training for public works will be strongly encouraged for the Business Office. Anticipated date to complete the corrective action: ASAP

View Audit 44823

Finding 39608 (2022-003)

Material Weakness 2022

Friendly House, Inc.

AZ

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management

2022-003 Cash Management Material Noncompliance Cash Management Material Weakness in Internal Control over Compliance U.S. Department of Health and Human Services Passed-through the Arizona Department of Economic Security Refugee and Entrant Assistance State Administered Federal Financial Assistance...

2022-003 Cash Management Material Noncompliance Cash Management Material Weakness in Internal Control over Compliance U.S. Department of Health and Human Services Passed-through the Arizona Department of Economic Security Refugee and Entrant Assistance State Administered Federal Financial Assistance Listing/CFDA #93.566; ADES18-191650; October 1, 2020 to September 30, 2021 and October 1, 2021 to September 30, 2022 Condition: Eide Bailly LLP (EB) noted that four out of four draw requests did not have adequate support for the class hours included. Management?s Response and Corrective Action Plan: ? Monthly Attendance Report are completed by data specialist using individual teachers? daily rosters. ? The Monthly Attendance Reports are verified by the program manager and corrected if any mistakes are identified. ? Monthly invoices are reviewed, prior to submission, with the Department Manager for additional verification and approval. ? After the student attendance has been reviewed by Program Manager and verified by the Department Manager, a review log is signed off by both the Program Manager and the Department Manager. ? Any changes to either the attendance logs or monthly student attendance will only be made with the authorization of the department manager after data has been verified, with an explanation of why that was needed. ? After the appropriate verifications have taken place, the Program Manager creates the monthly invoice, they will maintain and verify documentation for the student attendance hours reflected on the invoice. ? Management will continue to discuss and explore ways to strengthen our current internal controls, including, purchasing tracking software and/or the creation of a google form/document. ? Management will routinely review and consider any needed modifications to or implementation of new policies and procedures that would strengthen internal controls surrounding the invoicing process, record-keeping, and the management thereof. Contact Person: Jose J. Vaquera, VP of Client Services Anticipated Completion Date: May 15, 2023

View Audit 37105

Finding 39508 (2022-001)

Significant Deficiency 2022

Sanford

SD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213 § 200.303

Finding 2022-001 ? Suspension and Debarment Information on the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Planned corrective actions: As it relates to the reliance on the third-party vendor that conducts suspension and deb...

Finding 2022-001 ? Suspension and Debarment Information on the federal program: Federal Agency: Various Assistance Listing: Various; Research and Development Cluster Award Year: 2022 Planned corrective actions: As it relates to the reliance on the third-party vendor that conducts suspension and debarment -party vendor searches, the third party vendor provides Sanford a SOC (System and Organizational Controls) 2 Type II report annually over the effectiveness of its controls. This is reviewed by Sanford?s compliance department to ensure that there are no findings that would be of concern to Sanford?s reliance on the vendor transaction. Considering the third-party vendor is not relied upon for financial controls, the third-party vendor does not have a SOC 1 (System and Organization Controls) Report and therefore did not provide this level of report to Sanford. To provide context on scale of vendors subject to suspension and debarment, Sanford paid a total of 27,000 vendors in 2022. There were three vendors identified through the vendor setup and monitoring process to be suspended or debarred. None of those vendors were associated with the programs funded with federal funds. Sanford?s preventative and detective controls and operating procedures provide reasonable assurance over the effectiveness of the controls necessary to prevent the risk of federal funds being paid to the vendors that are suspended or debarred. Sanford believes the risk of any material disbursement to suspended and debarred vendor is effectively mitigated through existing preventative and detective internal controls. Sanford will document a periodic validation of the suspension and debarment search results performed by the third-party vendor for vendor searches that yield no suspension and debarment match. In addition, Sanford will enhance its procedural documentation regarding retention of evidence related to reconciliation of vendor list when discrepancies are identified and the suspension and debarment results that is generated through the vendor setup process. Responsible official: Tracy Sattler, Director of Compliance and Melanie Paape, Executive Director of Supply Chain Anticipated completion date: August 31, 2023

View Audit 34025

Finding 39507 (2022-004)

Significant Deficiency 2022

South Lane School District No 45j3

OR

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Prior approval for capital expenditure: We have reviewed our controls over grant expenditures with new staff to ensure that controls over compliance are followed. We have made one modification that includes a review of recorded expenditures recorded in the general ledger prior to year-end to ensure ...

Prior approval for capital expenditure: We have reviewed our controls over grant expenditures with new staff to ensure that controls over compliance are followed. We have made one modification that includes a review of recorded expenditures recorded in the general ledger prior to year-end to ensure that all items recorded have required approval.

View Audit 34125

Finding 39497 (2022-001)

Significant Deficiency 2022

Population Services International

DC

Subrecipient Monitoring § 200.303 § 200.328

2022-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Contact: Marcie Cook, Susan Mukasa Title: Vice Presidents, Global Operations Phone Number: 202 753 7532 / 202 734 7784 Estimated Completion Date ? ongoing ...

2022-001 Internal Control over Compliance and Compliance with the Reporting Compliance Requirement Contact: Marcie Cook, Susan Mukasa Title: Vice Presidents, Global Operations Phone Number: 202 753 7532 / 202 734 7784 Estimated Completion Date ? ongoing Corrective Action PSI will focus on continuous improvements to the reporting tracking system (D-Tracker) that ensures each contract has a clear program and financial reporting deadlines. The Program Management Team will keep working with Project Directors to confirm accuracy of the report deadlines in D-Tracker. Quarterly reports will be run to confirm upcoming reports due in the quarter and be shared with appropriate staff to ensure that deadlines are met or approvals to extend due dates are appropriately documented. Training will be provided throughout the year so that monitoring is part of the standard procedure.

View Audit 46560

Finding 39441 (2022-001)

Significant Deficiency 2022

County of Kent, Michigan

MI

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

2022-001 ? Housing Quality Standards (HQS) Inspections Auditor Description of Condition and Effect: In the prior year single audit, 1 out of 40 tenants selected for testing did not receive an HQS inspection within the two year window as of December 31, 2021. This tenant did not appear on the appro...

2022-001 ? Housing Quality Standards (HQS) Inspections Auditor Description of Condition and Effect: In the prior year single audit, 1 out of 40 tenants selected for testing did not receive an HQS inspection within the two year window as of December 31, 2021. This tenant did not appear on the appropriate reports that would have generated inspection letters to be sent, and so was overlooked in the process. Per management inquiry, as part of current year testing, the County still has a small list of tenants for this program that have not had an HQS inspection during the two year window as of December 31, 2022. Because of this condition there was an increased risk that required inspections would not be completed timely. Auditor Recommendation: The County should update its tracking process for determining which units are due for HQS inspection, so that all units that have not been inspected within the two year window will be considered. Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. Management has reviewed its existing procedures and has already made revisions, as appropriate, to ensure that all applicable requirements are considered in the monitoring process. Responsible Party. Community Action Department staff Date of Planned Corrective Action. September 2023

View Audit 43998

Finding 39439 (2022-002)

None 2022

County of Kent, Michigan

MI

Subrecipient Monitoring Reporting

2022-002 ? Special Reporting for Federal Funding Accountability and Transparency Act Auditor Description of Condition and Effect: Per inquiry of County management, they were not aware of the subaward submission requirements and no one from an outside agency has contacted them to alert them to this ...

2022-002 ? Special Reporting for Federal Funding Accountability and Transparency Act Auditor Description of Condition and Effect: Per inquiry of County management, they were not aware of the subaward submission requirements and no one from an outside agency has contacted them to alert them to this delinquent reporting. Because of this condition the County did not fully comply with all aspects of the above mentioned programs. Auditor Recommendation: The County should update its policies and procedures to assure that all changes in federal award compliance over reporting are captured and applied. Management Assessment. We concur with the audit assessment regarding this matter. Planned Corrective Action. Management has reviewed its existing procedures and has already made revisions, as appropriate, to ensure complicate with Federal Funding Accountability and Transparency Act reporting requirements. Responsible Party. Community Action Department staff Date of Planned Corrective Action. September 2023

View Audit 43998

Corrective Action Plans

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