Corrective Action Plans

Finding 31188 (2022-002)

Significant Deficiency 2022

Alabama Nursing Home Association Education Foundation

AL

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.303 § 200.329

Finding 2022-002 ?Internal Control Over Reporting Status: Completed. Planned Corrective Action: Management will retain documentation of review of reports. Person(s) Responsible: John Matson, Acting Executive Director Completion Date: September 26, 2023

View Audit 25745

Finding 31183 (2022-001)

Material Weakness 2022

Latino Network

OR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.331

March 6, 2023 CORRECTIVE ACTION PLAN Latino Network respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Kern Thompson 1800 SW First Avenue, Suite 410 Portland, Oregon 97201 Audit Period: 07/01/2021 ? 06/3...

March 6, 2023 CORRECTIVE ACTION PLAN Latino Network respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Kern Thompson 1800 SW First Avenue, Suite 410 Portland, Oregon 97201 Audit Period: 07/01/2021 ? 06/30/2022 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding ? 2022-001 Criteria/Requirement: In accordance with 2.CFR?200.331, a pass-through entity must monitor the activities of subrecipients to ensure that federal awards are used for authorized purposes in compliance with laws, regulations, and the provisions of contracts and grants agreements. Condition/Context: Latino Network passed through $85,311 in funding to subrecipients. During our audit, we noted that the Latino Network did not have documented written controls or procedures to ensure compliance with the U.S. Office of Management and Budget?s Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) subrecipient monitoring requirements. Cause: Procedures are not in place to ensure that Latino Network is maintaining adequate monitoring for each federal subrecipient. Effect: Failure to maintain sufficient subrecipient monitoring may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs: $85,311 Recommendation: The Organization should establish written policies and procedures regarding the monitoring of subrecipients, as well as establish monitoring procedures to ensure that such policies and procedures are being followed. Management?s Response: We agree with the auditors' comments, and the following action will be taken to improve the situation. We will create and document the policies and procedures for effective monitoring of federally granted subrecipients by the end of the fiscal year. We will then perform monitoring of all federally granted subrecipients prior to our FY23 financial audit. Revisions to the users' manual will be made as needed to ensure the manual is current at all times. Grants & Contracts Accountants and Accounting Manager will be trained to perform federally granted subrecipient monitoring.

View Audit 26969 Questioned Costs: $1

Finding 31158 (2022-001)

Significant Deficiency 2022

Kleeman Village Housing Corporation, Nfp

IL

Questioned Costs Subrecipient Monitoring Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development Kleeman Village Housing Corporation, NFP respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: MCK CPAs & Advisors, Decatur, Illinois. Audit Period: Year...

U.S. Department of Housing and Urban Development Kleeman Village Housing Corporation, NFP respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: MCK CPAs & Advisors, Decatur, Illinois. Audit Period: Year ended June 30, 2022. The findings from the June 30, 2022 Schedule of Finding and Questioned Costs are discussed below. The findings are number consistently with the number assigned in the schedule. 2022-001 Recommendations: Management agent and sponsor will continue to monitor financial reports and accounting information as correction is not practical. Findings and Questioned Costs - Federal Award Programs Audit: Department of Housing and Urban Development: Supportive Housing for Persons with Disabilities Program (Section 811), Assistance Listing #14.181: See finding 2022-001 Preparation of Financial Statements. If the Department of Housing and Urban Development has questions regarding this plan please call Stephanie Coonce, Kleeman Village Housing Corporation, NFP at (217) 620-9683.

View Audit 33626

Finding 31152 (2022-001)

Significant Deficiency 2022

Mary Lee Flagship

TX

HUD Housing Programs Questioned Costs Subrecipient Monitoring

Reporting Views of Responsible Officials: Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 202 t...

Reporting Views of Responsible Officials: Management agrees with the finding and will begin an independent review of each tenant file to include examination of EIV reports to determine if there are any discrepancies and take corrective measures. Leasing office staff will undergo additional HUD 202 training regarding the initial and recertification process. Additionally, management will utilize an external consultant to review tenant files for compliance with HUD procedures (i.e.. use of authorized consent and verification forms, EIV reports, etc.) and ensure supporting documentation is maintained in each tenant?s file.

View Audit 33620

Finding 31151 (2022-001)

Material Weakness 2022

Federal Hocking Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding Number: 2022-001 Planned Corrective Action: The District will put procedures in place to ensure that all future contracts for federally funded construction projects will include the necessary prevailing wage language. Anticipated Completion Date: June 30, 2023 Responsible Contact Person:...

Finding Number: 2022-001 Planned Corrective Action: The District will put procedures in place to ensure that all future contracts for federally funded construction projects will include the necessary prevailing wage language. Anticipated Completion Date: June 30, 2023 Responsible Contact Person: Bruce Steenrod, Treasurer

View Audit 30857

Finding 31149 (2022-001)

Material Weakness 2022

Lake Chelan School District No. 129

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Questioned Costs

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Lake Chelan School District No. 129 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 US. Code of ...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Lake Chelan School District No. 129 September 1, 2021 through August 31, 2022 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 US. 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's internal controls were inadequate for ensuring compliance with federal requirements for allowable costs and time- and-effort documentation. Name, address, and telephone of District contact person: Bo Charlton, Business Manager PO Box 369 Chelan, WA 98816-0369 (509) 682-3515 Corrective action the auditee plans to take in response to the finding: The Lake Chelan School District has acknowledged and understands the finding being issued and put a multistep plan in place to correct the issue regarding the internal control for time-and-effort documentation. The Lake Chelan School District has implemented standardized time-and-effort documentation forms that each of the certified staff including directors will be using as of the 2022-2023 fiscal year. There will be an internal review process which will require the employee, principals and director to sign off on the appropriate certification date warranted by the need. The Business Manager and the Payroll Director will each do a reconciliation to verify what is being paid in the system matches the hours worked. With this corrective action plan, we aim to address the inadequate internal controls for time-and-effort documentation. Anticipated date to complete the corrective action: 5/30/23

View Audit 27975

Finding 31148 (2022-001)

None 2022

City of San Bernardino

CA

Subrecipient Monitoring Reporting Significant Deficiency

This corrective action plan is in response to the city's single audit report for the fiscal year ended June 30, 2022, prepared by RAMS. Part Ill Federal Award Findings and Questioned Costs #2022-001 Recommendation: It is recommended that the City implement a tracking system to remind staff of the...

This corrective action plan is in response to the city's single audit report for the fiscal year ended June 30, 2022, prepared by RAMS. Part Ill Federal Award Findings and Questioned Costs #2022-001 Recommendation: It is recommended that the City implement a tracking system to remind staff of the various reports due and respective deadlines. Corrective Action: To ensure compliance for future reporting, staff routes all contracts through DocuSign. Any grant related contract routed through DocuSign will forward a fully executed copy to the Grants Division. Grant related contracts at $30,000 or above will be flagged to inform the applicable department Management Analyst to report the contract to the Federal Funding Accountability and Transparency Act (FFATA) Subaward Report System (FSRS) by the end of the following month. A tracking log will be maintained where applicable contracts will be listed, the deadline date to report in the FSRS, and a date to record when it was completed. This tracking log will be housed in the Grants Division folder on the City's shared drive. Person Responsible for Corrective Action: Grants Division Manager: Mary Alvarez-Gomez Department Management Analyst (various) Anticipated Completion Date for Corrective Action: It should be noted that all contracts within the audit reporting period were reported in the FFATA FSRS by 6/13/23. Corrective Action will be immediately implemented in response to the auditors' recommendation.

View Audit 27596

Finding 31116 (2022-001)

Material Weakness 2022

Massena Independent Living Center INC

NY

Internal Control / Segregation of Duties Subrecipient Monitoring

When management performs the risk assessment process , management will share that with the Board for approval

View Audit 26704

Finding 31108 (2022-001)

Material Weakness 2022

Wells County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.303

FINDING 2022-001 Contact Person Responsible for Corrective Action: Lisa McCormick Contact Phone Number: 260-824-6474 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Wording will be included in all bid packets requesting suspended or disbarred status ...

FINDING 2022-001 Contact Person Responsible for Corrective Action: Lisa McCormick Contact Phone Number: 260-824-6474 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Wording will be included in all bid packets requesting suspended or disbarred status from all vendors prior to issuing contracts. Also, wording will be added to bid packets asking vendors to notify Wells County if they become suspended or disbarred during the life of the contract. Anticipated Completion Date: Immediately

View Audit 26503

Finding 31098 (2022-011)

Material Weakness 2022

Gary Community School Corporation

IN

Subrecipient Monitoring Special Tests & Provisions Equipment & Real Property Management § 200.303 § 200.334

FINDING 2022-011 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure proper calculation and ...

FINDING 2022-011 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure proper calculation and supporting documentation of equitable services as it relates to the GEER I application for participation of private school children. Documentation will be retained by the Federal Programs Administrator and reviewed by the Chief Financial Officer for accuracy and completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

View Audit 33474

Finding 31091 (2022-008)

Material Weakness 2022

Gary Community School Corporation

IN

Subrecipient Monitoring Eligibility Material Weakness § 200.303 § 200.77 § 200.78

FINDING 2022-008 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created and implemented to ensure that th...

FINDING 2022-008 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created and implemented to ensure that the documentation required to support a student?s socioeconomic status is reviewed and retained for Eligibility compliance. This information will be reviewed and entered by the Testing department with a final review by the Federal Programs Administrator. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

View Audit 33474

Finding 31089 (2022-006)

Material Weakness 2022

Gary Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2022-006 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure compliance with require...

FINDING 2022-006 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: A policy and procedure will be created to ensure compliance with requirements related to the Special Tests and Provisions- High school graduation rate. Specifically, it will include internal controls for removing students from graduation cohort programs with proper documentation and review. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023.

View Audit 33474

Finding 31072 (2022-003)

Material Weakness 2022

Gary Community School Corporation

IN

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

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will b...

FINDING 2022-003 Contact Person Responsible for Corrective Action: Nicole Wolverton, CFO Contact Phone Number: 219-881-5536 Views of Responsible Official: We concur with the audit finding. Description of Corrective Action Plan: As it relates to reporting of meal claims, a policy and procedure will be created and implemented to ensure that accurate meal counts are recorded and entered CNP web by Sodexo based off reports from Skyward recording daily meal counts, documentation and entry then reviewed by the GCSC Food Service Manager for accuracy prior to submission of claims and then reviewed by the CFO for completeness. Anticipated Completion Date: Gary Community School Corporation will implement this procedure by September 2023. INDIANA STATE

View Audit 33474

Finding 31061 (2022-004)

None 2022

University of Rio Grande

OH

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding Number: 2022-004 Condition: The University disbursed Direct Plus Loans in excess cost of attendance minus other estimated financial assistance for a student. Planned Corrective Action: The University is working closely with the U.S. Department of Education?s Office of Inspector General on th...

Finding Number: 2022-004 Condition: The University disbursed Direct Plus Loans in excess cost of attendance minus other estimated financial assistance for a student. Planned Corrective Action: The University is working closely with the U.S. Department of Education?s Office of Inspector General on this fraudulent activity. The University will continue to monitor student financial aid accounts using the current internal controls which led to the fraud discovery. Contact person responsible for corrective action: Meghann Fraley, CFO Anticipated Completion Date: 12/31/2023

View Audit 31905 Questioned Costs: $1

Finding 31060 (2022-001)

Significant Deficiency 2022

Premier Health Partners

OH

Allowable Costs / Cost Principles Eligibility Subrecipient Monitoring

Corrective Action Plan Federal Award Findings and Questioned Costs For the Year Ended December 31, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility Federal program information: Federal Program: HRSA COVID-19 Claims Reimbursement for...

Corrective Action Plan Federal Award Findings and Questioned Costs For the Year Ended December 31, 2022 Finding 2022-001 ? A. Activities Allowed or Unallowed, B. Allowable Costs/Cost Principles, E. Eligibility Federal program information: Federal Program: HRSA COVID-19 Claims Reimbursement for the Uninsured Program and the COVID-19 Coverage Assistance Fund (93.461) Federal Agency: U.S. Department of Health and Human Services (HHS), Health Resources and Services Administration (HRSA) Locations: Various Award Numbers: Various Award Period: January 1, 2022, through December 31, 2022 Summary of finding: Premier Health Partners and Subsidiaries (the Company) did not appropriately design and execute internal control procedures to review for retroactive insurance that subsequently became effective for the date(s) of service on patient accounts previously billed to and reimbursed by the COVID-19 Uninsured Program. Corrective Action Plan: Premier Health will submit all claims paid by the HRSA COVID-19 Uninsured Program to a third-party vendor to perform a search for any retroactive insurance coverage for these patients for the service dates submitted and paid by this program. Any accounts found to have retroactive insurance coverage for dates submitted will be paid back to the HRSA Uninsured Program by December 31, 2023. Expected Completion Date: December 31, 2023 Responsible Contact Persons: Amanda Ricci-Adkins ? System VP Revenue Cycle, Mike Sims ? System VP & Corporate Controller

View Audit 30529

Finding 31053 (2022-004)

Material Weakness 2022

Independent School District No.786

MN

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Finding 2022-004 Special Tests ? Wage Rate Requirement Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The District did not ensure proper i...

Finding 2022-004 Special Tests ? Wage Rate Requirement Material Noncompliance and Material Weakness in Internal Control over Compliance Finding Summary: Eide Bailly LLP noted that the District did not satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The District did not ensure proper inclusion of prevailing wage rate clauses in two construction contracts and also did not obtain proper support to ensure required certified payrolls were submitted. Responsible Individuals: Eric Koep, Superintendent Corrective Action Plan: The District will establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Anticipated Completion Date: June 30, 2023

View Audit 34792

Finding 31041 (2022-001)

Material Weakness 2022

United Way of Monterey County

CA

Subrecipient Monitoring Cash Management Eligibility

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In March 2021, UWMC began this eme...

The Emergency Rental Assistance Program was developed in response to the pandemic and was implemented swiftly to meet the needs of low-income tenants affected by Covid-19. The program design involves fourteen partner agencies and their varying accounting systems. In March 2021, UWMC began this emergency program with an existing system, the Smart Referral Network (SRN) software, which was adapted in order to quickly launch the program. In March of 2022, the SRN tool was replaced with a software system (Neighborly) more specifically designed to administer and report on ERAP. The new data system facilitates reconciliation to the detailed payment data. Management agrees that the expenditures for the reporting period were overstated and accepts the recommendation along with implementing the following corrective action. UWMC conducted a comprehensive reconciliation of program data to financial expenditure records of its partnering agencies through June 30, 2022. In the current fiscal year, all partnering agencies are required to submit program data through the online Neighborly software along with providing a general ledger report that supports and is reconciled to the data submitted prior to receiving reimbursement. This new procedure was put in place for reimbursements effective January 1, 2023 forward. For reimbursements from July 1, 2022 ? December 31, 2022, we are going to reconcile past reimbursement requests to the partner agency general ledger report retroactively. The UWMC staff member overseeing these reconciliations with support from the UWMC Finance Department is: Kelly DeWolfe, Community Impact Director, Financial Stability kelly.dewolfe@unitedwaymcca.org (831)318-1997

View Audit 33534

Finding 31035 (2022-001)

Significant Deficiency 2022

University of Health Sciences and Pharmacy in St Louis

MO

Student Financial Aid Subrecipient Monitoring Reporting

The underlying cause of the University's internal control system deficiency regarding Enrollment Reporting primarily related to staffing changes as well as an employee performance matter. The Financial Aid Office has addressed the employee performance matter and provided additional training across ...

The underlying cause of the University's internal control system deficiency regarding Enrollment Reporting primarily related to staffing changes as well as an employee performance matter. The Financial Aid Office has addressed the employee performance matter and provided additional training across all team members. In addition, the Financial Aid Office has implemented new oversight, review processes and procedures across internal departments intended to enhance the timely submission of enrollment changes to the NSLDS in accordance with the requirements. These enhanced processes and procedures were implemented during the fiscal year ending June 30, 2023.

View Audit 28000

Finding 31016 (2022-001)

Material Weakness 2022

National University

CA

Reporting Questioned Costs Special Tests & Provisions

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control Condition/Context: A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of t...

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control Condition/Context: A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause: The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students who had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Corrective action plan: NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.

View Audit 26192

Finding 31005 (2022-002)

Material Weakness 2022

Low Rent Housing Agency of Knoxville, Iowa

IA

HUD Housing Programs Subrecipient Monitoring

Finding 2022-002 We agree with the finding. Planned corrective action: I have contacted our local banking institution and inquired if they will insure or collateralize our funds at 100%. They continue to pass me onto different individuals within their organization. If I learn they will not insur...

Finding 2022-002 We agree with the finding. Planned corrective action: I have contacted our local banking institution and inquired if they will insure or collateralize our funds at 100%. They continue to pass me onto different individuals within their organization. If I learn they will not insure or collateralize our funds at 100%, we will move our funds to a bank that will insure them at 100%.

View Audit 25704

Finding 30973 (2022-001)

Significant Deficiency 2022

California Lutheran University

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigati...

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigation, it was determined that the selection criteria for data extraction required adjustment to ensure all students were included in the data extraction and reporting process. Corrective Action Plan: Maria Kohnke, Associate Vice President of Academic Services & Registrar, modified the selection criteria for the data extraction process in the Colleague system to ensure all permanent address changes are extracted and submitted for all students as required. The Associate Registrar is responsible for reviewing and modifying the selection criteria for the data extraction process at the beginning of each year and at each change in criteria. The criterion will be reviewed and approved by the Associate Vice President of Academic Services & Registrar when changes are made. Responsible person: Maria Kohnke. Date of expected correction: September 1, 2022.

View Audit 30198

Finding 30972 (2022-003)

Significant Deficiency 2022

Missouri Housing Development Commission

MO

Questioned Costs Subrecipient Monitoring Reporting

Finding 2022-003 ? Reporting ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: In order to navigate the required Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has imple...

Finding 2022-003 ? Reporting ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: In order to navigate the required Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has implemented many changes to process. To address staffing limitations, the Community Programs Processes Department was created in the fall of 2021 to aid in the reconciliation and financial tracking processes. In the early part of 2022, the Data and Analytics Department was officially formed to expand reporting capacity. New processes, in response to known limitations and timing restraints, have been developed to ensure adequate record keeping. Regular weekly meetings have been established between the Community Programs Processes Department, the Data and Analytics Department, and the Division Director to improve the coordination between all parties prior to the reporting deadlines. Additionally, where exceptions or changes must be made to reporting processes due to technical deficiencies or changes to guidance, processes have been established for clear communication and approval. Finally, as part of the regular coordination meetings, a debriefing of the reporting process occurs post submission so that improvements to the process may take place as needed. Completion Date: The Commission developed new departments and added additional staffing in fall 2021 and early 2022. New processes for report completion, submission, and record keeping were developed in the late spring of 2022 and regular communication and process improvement are ongoing. The Commission expects to complete implementation of procedures and to document ERA report reconciliations with the general ledger during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197

Finding 30971 (2022-002)

Material Weakness 2022

Missouri Housing Development Commission

MO

Allowable Costs / Cost Principles Eligibility Questioned Costs § 200.400 § 200.401

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 202...

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 21.023. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. This includes the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that are responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021 the Commission hired an Internal Compliance Manager and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity has been expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as ?mass denial metrics? and tiered level reviews have been implemented into weekly application processing. Processes will continue to be implemented in response to changes in behavior by ineligible actors and ineligible application submission attempts. Staff has set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative measures demonstrated to be effective in other states. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30968 (2022-001)

Material Weakness 2022

Missouri Housing Development Commission

MO

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.400 § 200.401

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years ...

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 14.231. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, MHDC undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021, reviewed applications to identify potentially fraudulent applications during fiscal year 2022 and expects to conclude its investigation of identified cases during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30967 (2022-001)

Significant Deficiency 2022

Lake Anne Fellowship House, Section I

VA

Subrecipient Monitoring Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development Lake Anne Fellowship House, Section II FHA Project No. 000-005-NI respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly U.S., LLP 1570 Fruitvill...

U.S. Department of Housing and Urban Development Lake Anne Fellowship House, Section II FHA Project No. 000-005-NI respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly U.S., LLP 1570 Fruitville Pike, Lancaster, PA 17601 Audit period: Year Ending June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINANCIAL STATEMENT FINDINGS None Noted FEDERAL AWARD FINDINGS Finding 2022-001 ? Required Monthly Deposits to the Reserve for Replacement Recommendation: The Corporation should have procedures in place to ensure all required monthly deposits are made. Action Taken: $782.00 shortfall of deposits was funded. Going forward, annually management will verify with ownership monthly deposit required. Anticipated Completion Date: September 22, 2022, the date the Corporation made the underfunded deposit. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Christy Zeitz, CEO at (571) 349-0055.

View Audit 36489

Corrective Action Plans

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