Corrective Action Plans

Finding 24183 (2022-004)

Significant Deficiency 2022

SD

Subrecipient Monitoring

"Finding No. 2022-004: Inadequate Controls Over Subrecipient Monitoring of Nutrition Service Providers Corrective Action Plan: DHS LTSS in partnership with Budget and Finance will review and enhance internal controls to ensure adequate policies are in place for subrecipient monitoring of nutrition...

"Finding No. 2022-004: Inadequate Controls Over Subrecipient Monitoring of Nutrition Service Providers Corrective Action Plan: DHS LTSS in partnership with Budget and Finance will review and enhance internal controls to ensure adequate policies are in place for subrecipient monitoring of nutrition service providers. DHS LTSS will ensure that monitoring procedures for nutrition service providers are consistently applied and adequately documented. These procedures will include documentation tying pre-award risk assessments to the monitoring procedures to be performed for all subrecipients, including tribal governments, and properly follow up on any issues identified with subrecipients as a result of monitoring performed. Contact Person: Jeff Overcash, Chief Financial Officer, Heather Krzmarzick, Director of Long-Term Services, and Supports Greg Evans, Audit Manager Anticipated Completion Date: June 30, 2023"

View Audit 20313

Finding 24126 (2022-002)

Significant Deficiency 2022

City of Elk Grove

CA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding Reference Number: SA2022-002 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Awar...

Finding Reference Number: SA2022-002 Suspension and Debarment Documentation for Contracts and Subcontracts Assistance Listing Number: 21.027 Assistance Listing Title: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of the Treasury Federal Award Identification Number: SLFRP2014 ? Name(s) of the contact person: Marsha Ley ? Corrective Action Plan: City Finance Staff will notify all departments which are managing Federal Grants that prior to entering into subawards and contracts with Federal award funds, City?s Departments must verify that recipients/vendors/contractors are not suspended or debarred. All verification support/evidence should be saved for future reference and audit. ? Anticipated Completion Date: June 30, 2023

View Audit 19948

Finding 24119 (2022-008)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Questioned Costs § 200.303 § 200.334

Compliance requirement ? Earmarking Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because all initiatives and expenditures related to the HEERF funds were precisely and strictly used to monitor, suppress the COVID-19 emergency and...

Compliance requirement ? Earmarking Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because all initiatives and expenditures related to the HEERF funds were precisely and strictly used to monitor, suppress the COVID-19 emergency and additionally to outreach students about the opportunity to receive financial aid, (and they indeed received) due to recent unemployment and financial hardship during the pandemic times. Part of this initiatives were documented in our web page and disseminated through e-mails, phone calls, word of mouth among the community. The institution followed the recommended state and federal government guidelines on maintaining an active program to prevent and respond to the COVID-19 emergency. The institution uses HEERF funds to establish and maintain the following preventive and suppressing measures to fight the COVID-19 emergency, among others: a. Screening temperature b. Purchase covid test kits c. Created and posted many warning banners and instructions d. Purchase prevention and protection supplies for students, faculty, visitor and staff a. Hand sanitizer b. Alcohol auto sprayers c. Face Shields d. Thermometers e. Protective plastic shields for the desks e. Implemented remote education a. Habilitated smart educational rooms for remote education i. Smart TV's ii. High quality microphones iii. Acquired "Zoom" platform licenses iv. Laptops for remote education f. Provided student financial aid to support recent unemployment g. Provided counseling and psychology services to assist students to deal and recover from the emergency. h. Supported a clean and sanitary campus environment with hand sanitizers, handwashing stations, cleaning and disinfection. i. Implemented physical distance j. Keep continued communication with students k. Paid for time off to get vaccinated l. Provided sick leave for COVID treatment and to get vaccinated m. Procured additional space for remote education n. Support costs associated with remote education for students providing laptops and remote communication equipment and hardware Actions Taken or Planned: The institution understands that no further action is necessary or required.

View Audit 20027

Finding 24117 (2022-006)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Equipment & Real Property Management § 200.302 § 200.303 § 200.334 § 200.337 § 200.400

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the...

Compliance requirement ? Allowed Cost /Cost Principle Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the referenced transaction was below the "Micro-purchase" threshold and does not require a quotation. The FAR increase the "Micro-purchase" threshold for natural disasters and national emergencies, among others. The invoice amount of $5899 was a continuation of an initial project under this contractor which have the unique security passwords, IT protocols and other IT requirements for the uniform implementation of intelligent classrooms for remote distance education. Accordingly, the institution does not request a quote. The institution followed the referenced guidelines in the determining the allowability of costs. Additionally, an external consultant reviewed the transaction and costs prior to request reimbursement. The 2 CFR Part 200, Appendix XI Compliance Supplement guide, issued April 2022, makes referenced to the FAQ's and Other Guidance containing information pertinent to the compliance requirements described in the document and encouraged auditor to regularly check the HERF Websites for updated FAQ's and other pertinent guidance and reporting information. The institution followed those referenced FAQ's and guidelines, among other sound administration practices, in the use of the grants. The referenced Compliance Supplemental, under "Activities Allowed or Unallowed" states: "Institutions must demonstrate that costs incurred are allowable under the relevant statutory provision and consistent with the purpose of the ESF "to prevent, prepare for, and respond to coronavirus"". The institution used $5,899 paid to the guidelines as indicated to contractor, to continue enhancing the distance learning program in preventing the spread and contamination of the coronavirus among professors and students by enabling remote distance education. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 2. The institution does not concur with the auditor finding because of what is discussed in No 1 above. In the two cases mentioned, the cost quote may not agree with the invoice, because of some additional services requested, but the amount of the invoice was the correct amount paid and actual cost used to draw the HEERF funds. These invoices were for furniture and partitions divisions, to enable the remote distance education, avoiding physical contact of students and professors, to prevent, prepare for and respond to the COVID-19 emergency. Once again, these incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines. 3. The institution does not concur with the auditor finding. The referenced three cases may not have a specific or expressed "acknowledgement of receipt" statement, but the acknowledgement was validated by UTC management and with the signatures when the check was issued. Nevertheless, the costs incurred in these invoices were authorized and incompliance with HEERF program and ESF purpose. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. 4. Institution does not, firmly, concurs with the auditor finding. This should not even be a finding because the institution strictly followed the FAQs published on March 19, 2021 to calculate the lost revenue and using a comparison between FY-20 and FY 21. That guideline described "Loss of Revenue" as "...those revenues and institution of higher education otherwise expected but were reduced or eliminated as a result of the novel coronavirus 2910 (COVID-2019) pandemic. As such, lost revenues can only be estimated". Nerveless, the result would have been relatively the same if we have use FY21 audited financials. Given the many factors and complexities of the unusual process, the institution followed a conservative approach and reduced those revenue items that have an increase between fiscal year from those with a loss of revenue. Therefore, the institution netted the potential amount of lost revenue to claim. Accordingly, the net amount resulted in $280,929.84. The potential loss of revenue amount could be greater but the institution decided to only claim the referenced estimated amount. These calculations and analysis were further discussed and evaluated by an officer of the Department of Education, with no recommendation on claiming a higher amount because the amount claimed was less than the estimated potential. The guideline indicates: "Reimbursement for lost revenue is allowable for the Institutional Portion program...". The institution claimed this loss of revenue amount from their institutional portion, complying with the HEERF guidelines and the authorized use of the funds. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. a. The institution used unaudited figures for FY21 because the audited financial statements were not completed at the time of the calculation. The institution revised the calculations with the audited financial statements, and the results were the same and the claimed estimated amount did not changed. Once again and in accordance with the guidelines, we were estimating the lost revenue with the data available at the moment. b. The institution followed the recommended HEERF guidelines for this complex and novel exercise. The institution considered under the analysis; those revenues otherwise expected but that were reduced as a result of the novel COVID-2019. The contributions as "Support Revenue" from related entities, which were a significant source of revenue for the institution, was not claimed as loss of revenue. The institution specifically claimed those lost revenue items as authorized in the guidelines. Therefore, once again, the UTC was in compliant with the lost revenue referenced guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. c. As explained above, the institution followed a conservative approach and only claimed a net amount of all lost revenue items. The institution only claimed those estimated revenue items, as authorized in the guideline, that suffer a loss between the two fiscal years considered in the evaluation. This was further evaluated by an officer of the DOE. As the guidelines described, since the lost revenues can only be estimated, the institution correctly, analyzed and calculated the best conservative/reasonable estimate of loss revenue with the available data at the moment. Even if we used the auditors' recommended items, the results would have been the same and no revenue item was claim out of the authorized or allowable costs from the guidelines. The direct charges for this transaction to the federal award was for allowable costs under the instructions, federal grant and FAQs guidelines as indicated. Actions Taken or Planned: The institution understands that the incurred and direct charges to the federal award complied with the HEERF objectives and were allowable costs under the authorized uses in the grant award and HEERF guidelines and no further was required.

View Audit 20027

Finding 24115 (2022-010)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Subrecipient Monitoring Questioned Costs Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

Compliance requirement ? Reporting Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the institution strictly followed and used the recommended HEERF methodology and reporting guidelines to prepare the quarterly and annual rep...

Compliance requirement ? Reporting Institutional Comments on Findings and Recommendations: 1. The institution does not concur with the auditor finding because the institution strictly followed and used the recommended HEERF methodology and reporting guidelines to prepare the quarterly and annual reports. Since the institution used the reimbursement method, the drawdown were the actual expenditures/costs incurred and requested for reimbursement. The HEERF reporting requirement does not make any indication nor reference to GAAP. The Institutional aid portion expenditures were supported by the proper invoice or check. The evidence was available to the auditors. 2. The institution concurs with the auditor finding. The institution inadvertently, did not include a line item from one of the quarterly reports. The period to make corrections was closed and we sent an e-mail to the department to amend this annual report. 3. The institution concurs with the auditor finding. The annual report contains detail statistical information that not necessarily is supported by our institutions data base and programs. As the ED expressed, this information was unique and challenging, and accordingly, the institution made some reasonable estimates and derivatives in the information provided. As you may notice in the referenced table by the auditor, the differences were minimal. 4. a. The institution concurs with the auditor finding on the difference in Item #5 of the quarterly report. The institution will accordingly amend the report. b. The institution does not concur with the auditor finding on the timely and accurate reporting in publicly posting the quarterly Student Aid Portion. The four quarterly reports were timely submitted with an e-mail to the HEERF reporting staff and timely posted in the institution web page as required by the HEERF reporting instructions. The reports were further reviewed by an officer of the Department of Education (ED). The ED expressed that this information may be unique and challenging to an audit, and indicated that for these public reporting requirements, the auditors may accept as evidence of compliance, contemporarily produced e-mails, webmaster logs, or other relevant documentation establishing good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements. Copy of the e-mails were available to the auditors as evidence of compliance. ED understands that this information may be unique and challenging to audit, particularly because auditors are asked to verify information posted on a webpage which may not be accessible during audit fieldwork. For these public reporting requirements, auditors may accept as evidence of compliance, contemporarily produced emails, webmaster logs, or other relevant documentation establishing a good-faith indication that the institution posted the required information at approximately the timelines established by the public reporting requirements (HEERF Grant Program Auditing Requirements, General Requirements and Information - All HEERF Grantees). 5. The institution does not concur with the auditor finding because the referenced payment was made in accordance with the Institution's fund distribution and the student financial needs, among other factors, at the time of the evaluation and distribution of the funds. The student financial circumstances may have change after the distribution and payments of the financial aid. Additionally, this is an immaterial amount as compare to the total amount of the funds distributed ant the quantity of students served (1 out of 460). Actions Taken or Planned: The institution understands that no further is needed or required.

View Audit 20027

Finding 24113 (2022-002)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.302 § 200.303 § 200.305 § 200.317 § 200.318

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance...

1. The institution does not agree, nor concurs, with the auditors on this finding because the institution used the reimbursement payment method. This method was the preferred one when the non-federal entity, as our institution, cannot meet the requirements in 2 CFR, section 200.305(b)(1) for advance payment and the federal awarding agency sets a specific condition for use of the reimbursement. Title 2 of the CFR Part 200.305(b)(1), establish among others: "The non-Federal entity must be paid in advance, provided it maintains or demonstrates the willingness to maintain both written procedures that minimize the time elapsing between the transfer of funds and disbursement by the non-Federal entity, and financial management systems that meet the standards for fund control and accountability as established in this part". Furthermore, 2 CFR Part 200.305(b)(3) states: "Reimbursement is the preferred method when the requirements in this paragraph (b) cannot be met, when the Federal awarding agency sets a specific condition per ? 200.208, or when the non-Federal entity requests payment by reimbursement. " Since our institution was not able to meet 2 CFR, section 200.305(b)(1), and the HEERF guidelines has specific condition on how to use the funds; we choose the reimbursement method in the execution of the funds. Our institution adopted all HEERF instructions and guidelines as their policies to comply with the HEERF requirements, in addition to the CFR's regulations. Below some of the guidelines, instructions ad FAQs we adopted followed" a. Higher Education Emergency Relief Fund III, Frequently Asked Questions, American Rescue Plan Act of 2021, Published May 11, 2021, Questions 7 and 11 updated May 24, 2021, Question 36 updated September 30, 2021 b. US Department of Education, Notice of Proposed Institutional Eligibility Criteria, February 25, 2021 c. Federal Register Notice of Interpretation (NOI), regarding Period of Allowable Expenses for Funds Administered under HEERF Program, March 22, 2021 d. HEERF Notice of Interpretation for Period of Allowable HEERF Expenses (March 22, 2021) e. HEERF Lost Revenue FAQs (March 19, 2021) f. HEERF Period of Allowable Expenses Grant Records Notice (March 19, 2021) g. HEERF Grant Program Auditing Requirements (March 8, 2021) h. CRRSAA HEERF II Section 314(a)(1) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) i. CRRSAA HEERF II Section 314(a)(2) Frequently Asked Questions (January 14, 2021) j. CRRSAA HEERF II Section 314(a)(4) Frequently Asked Questions (Published January 14, 2021 and Updated: March 19, 2021) k. HEERF I and HEERF II Comparison Fact Sheet (Published January 14, 2021 and Updated: March 19, 2021) 1. HEERF Lost Revenue FAQ's, Published March 19, 2021 m. HEERF II, Public and Private Nonprofit Institution (a)(2) Programs (CFDAs 84.425K), FAQ's, Published January 14, 2021 n. HEERF II, Proprietary Institution Grant Funds for Students (CFDA 84.425Q) ((a)(4) Program), FAQ's Published January 14, 2021, Updated March 19, 2021. o. HEERF II, Public and Private Nonprofit Institution (a)(1) Programs (CFDA 84.425E and 84.425F), FAQ's Published January 14, 2021, Updated March 19, 2021. p. CAREST Act HEERF Rollup FAQs (issued October 14, 2020 and revised November 20, 2020) q. CARES Act HEERF Round 3 FAQs (Issued October 14, 2020 and revised November 20, 2020) r. CARES Act HEERF Supplemental FAQs (Issued June 30, 2020 and revised September 08, 2020) s. CARES Act HEERF Student FAQ's (Issued May 15, 2020) t. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) u. CARES Act HEERF Emergency Financial Aid Grants to Students under Section 18004(a)(1) and 18004(c) FAQ's, (Issued April 9, 2020) v. CARES Act HEERF Institutional Portion under Section 18004(a)(1) and 18004(c) FAQ's, Issued April 9, 2020 w. COVID-19 FAQ's for Title III, IV, V and VII Grantees, June 16, 2020 x. COVID-19 Letter to HEP Grantees on Flexibilities Available Under CARES Act Section 3518, July 1, 2020 2. The institution does not agree, nor concurs, with the auditors on this finding because, as we mention in number 1 above, the institution adopted and followed the federal award and HEERF guidelines in the execution of the funds. The HEER funds were provided during the special national emergency caused by COVID-19. The DOE and HEERF officials issued many written guidelines, instructions, and FAQ's (Frequently Asked Questions) documents, due to the nature and novel of the national emergency situation. The institution adopted, followed, and relied on the many referenced guidelines and exercise extreme judgment to ensure compliance with the federal requirements and use of the funds. The institution belief this referenced guidelines and instruction were very specific and sufficient to execute the use of the funds. All direct charges to federal awards were for allowable costs under the guidelines and instructions from the Department of Education. Some of the allowable costs were verified and validated by an officer of the Department of Education and reviewed by an independent consultant. 3. The institution concurs with the auditor finding. Actions Taken or Planned: The institution begins in addition to the adopted HEERF guidelines, instructions, and CFRs; to develop additional procurement policies and are in the process of completing those policies. The institution expects to have those completed by May 31, 2023.

View Audit 20027

Finding 24108 (2022-005)

Significant Deficiency 2022

Universidad Teologica Del Caribe, Inc.

PR

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Compliance requirement - Special tests and provisions ? Gramm-Leach Bliley Act- Student Information Security Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding. The Information Security Program Coordinator's functions were not specifie...

Compliance requirement - Special tests and provisions ? Gramm-Leach Bliley Act- Student Information Security Institutional Comments on Findings and Recommendations: (a) The institution agrees with the auditor on this finding. The Information Security Program Coordinator's functions were not specified in a formal written contract, therefore, the consultant does not have a detail for the functions and responsibilities of his designation. (b) The institution agrees with the auditor on this finding. The Institution has yet to comply with, needs to terminate and correct some of the nine elements that are included in the FTC (Federal Trade Commission). Actions Taken or Planned: 1. A contract with the IT Program Coordinator is being finished with a breakdown of the responsibilities expected for the GLBA requirements. We should be starting it in May 2023. 2. There has been progress in the action plan where a set of estimated time of completion is provided. We will keep doing so and monitor every aspect of the risk assessment to cover and safeguard each area found with a document that indicates any advances. 3. The Institution with the IT Coordinator will keep monitoring each step for the progress and any delay with a task report where it will show any advance or delay for the pending findings so that we can track the development closely until finished. 4. Finally, we will continue with the efforts to document and complete the corrections to the risk assessment results.

View Audit 20027

Finding 24106 (2022-003)

Material Weakness 2022

Universidad Teologica Del Caribe, Inc.

PR

Student Financial Aid Subrecipient Monitoring Procurement, Suspension & Debarment

Compliance requirement ? Special test and provisions - Return of Title IV Funds Institutional Comments on Findings and Recommendations: I. Compliance Requirements ? Applicable After a Student Begins Attendance: a. The institution agrees with the auditors on this finding in which there were two (2) ...

Compliance requirement ? Special test and provisions - Return of Title IV Funds Institutional Comments on Findings and Recommendations: I. Compliance Requirements ? Applicable After a Student Begins Attendance: a. The institution agrees with the auditors on this finding in which there were two (2) cases where the auditors noted that the institution failed to determine that the students withdrew within 14 days after the student's last day of attendance. II. Compliance Requirements ? Applicable for a student who does not begin attendance: b. The Institution agrees with the auditors on this finding in which there was one (1) case were the student did not comply with the Incomplete course requirement and an unofficial withdrawal was not performed. Before the audit process was completed, the institution performed a R2T4 calculation and returned to the US Department of Education, the $439.00 associated with this finding. This process was evidenced to the auditors for their records. c. The Institution agrees with the auditors on this finding in which there was one (1) case were the student had stopped attending the enrolled courses without completing at least 60% of the payment period. Before the audit process was completed, the institution had returned to the US Department of Education, the $581.00 associated with this finding. This process was evidenced to the auditors for their records. d. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to determine that the students withdrew within 14 days after the student's last day of attendance. e. The institution agrees with the auditors that in the cases mentioned in item b and c in that it failed to return Title IV funds after the 45 days' time frame. Actions Taken or Planned: The institution is aware of the importance to comply with Return of Title IV funds (R2T4) reporting requirements and deadlines. Also, the relation to students last day of attendance (date of withdrawal) vs date of school's determination that the students withdrew and the date of the return of any Title IV funds resulting from an R2T4 calculation. The issues as related to these findings were identified as ones being an oversight and lack in compliance with some of the academic processes as required by R2T4 and has already been discussed with the Academic Dean of the institution who in turn has revisited these matters with Faculty and administrative staff under her supervision including the Registrar. The already instituted task force that meets every Friday of each week to identify and review cases that could affect the R2T4 procedure and requirement has continued to review and evaluate information received from the faculty through the Academic Dean and from information the Registrar's office receives of students that are not attending classes in order to process all applicable withdrawals to assure that the return of Title IV funds procedures and the return of funds if any, are processed timely within the 14 days requirement of the student's last day of attendance and within the 45 days from the date that the institution determined that the student withdrew. Before the audit process was completed, the institution had returned to the US Department of Education, the $439.00 and $581.00 associated with this finding. This process was evidenced to the auditors for their records.

View Audit 20027

Finding 24104 (2022-001)

Significant Deficiency 2022

San Joaquin Health Centers

CA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

The Organization will continue to implement the following measures to ensure compliance with the sliding fee discount program, and consistently assess patient income and family size. The Organization will continue to provide on-going training to clinic staff who evaluate the sliding fee application ...

The Organization will continue to implement the following measures to ensure compliance with the sliding fee discount program, and consistently assess patient income and family size. The Organization will continue to provide on-going training to clinic staff who evaluate the sliding fee application at its clinic locations. The training consists of reviewing sliding fee program policies and procedures along with all applicable patient forms, sliding fee scale, and patient eligibility. The following quality control measures to ensure compliance will be implemented: 1. Front Desk Peer Review of sliding fee application and verification of patient income and family size. 2. Enhance training materials to support Front Desk Staff with assessing sliding fee applications. 3. Quarterly feedback to Front Desk Staff based on sliding fee applications reviewed. Person Responsible: Kristopher D. Zuniga Position of Responsible Party: Chief Financial Officer Anticipated Completion: April 30, 2023

View Audit 19923

Finding 24103 (2022-001)

None 2022

Alabama Technology Network

AL

Questioned Costs Subrecipient Monitoring Reporting

Corrective Action Plan Manufacturing Extension Partnership Year-Ended September 30, 2022 Finding #2022-001: Type of Finding: Noncompliance Responsible Person Joey Massey, Director of MEP Implementation Date January 30, 2023 Views of responsible officials and planned corrective actions: ATN ...

Corrective Action Plan Manufacturing Extension Partnership Year-Ended September 30, 2022 Finding #2022-001: Type of Finding: Noncompliance Responsible Person Joey Massey, Director of MEP Implementation Date January 30, 2023 Views of responsible officials and planned corrective actions: ATN agrees with the finding and recommendation. As a result, ATN immediately submitted the FY22 Federal Funding Accountability and Transparency Act (FFATA) subawards in the FFATA sub-award reporting system (FSRS). Furthermore, ATN will implement procedures to ensure subawards will be reported in the FSRS system on a timely basis as required hereafter.

View Audit 21132

Finding 24087 (2022-006)

Significant Deficiency 2022

Pacific Islands Bible College

GU

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Anticipated Completion Date: Ma...

Area: Special Tests and Provisions Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will implement monitoring controls over the monthly direct loan reconciliation process performed by the third-party financial aid private consultant. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

View Audit 20750

Finding 24075 (2022-003)

Material Weakness 2022

Pacific Islands Bible College

GU

Cash Management Questioned Costs Student Financial Aid

Area: Cash Management Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will review the requirements of the Uniform Guidance and understand the cash management principal requirements. Once this is done, PIU will implement procedures and update the Business Office Ma...

Area: Cash Management Views of Auditee and Planned Corrective Action: PIU agrees with the finding. PIU will review the requirements of the Uniform Guidance and understand the cash management principal requirements. Once this is done, PIU will implement procedures and update the Business Office Manual. Anticipated Completion Date: May 31, 2023 Name of Contact Person and Title: Celia Atoigue, Director of Finance

View Audit 20750 Questioned Costs: $1

Finding 24047 (2022-004)

Material Weakness 2022

Laporte Community School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: LaPorte Community School Corporation will review the...

FINDING 2022-004 (Auditor Assigned Reference Number) Contact Person Responsible for Corrective Action: Greg Hunt Contact Phone Number: (219) 362-7056 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: LaPorte Community School Corporation will review the Education Stabilization Fund schedule of disbursements more closely prior to submission. Anticipated Completion Date: May 15, 2023

View Audit 20038

Finding 24027 (2022-002)

Material Weakness 2022

Zane Trace Local School District

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

Better documentation has been requested from the 3 purchasing groups that we use for purchasing to provide evidence of proper procurement procedures.

View Audit 19858

Finding 24012 (2022-015)

Significant Deficiency 2022

City of Baltimore, Maryland

MD

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.309

Finding 2022-015 U.S. Department of Health and Human Services AL No. 93.568 Total Low-Income Home Energy Assistance Significant Deficiency over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: The Office of Home and Energy Programs (OHEP) bureau of The Mayors Office...

Finding 2022-015 U.S. Department of Health and Human Services AL No. 93.568 Total Low-Income Home Energy Assistance Significant Deficiency over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: The Office of Home and Energy Programs (OHEP) bureau of The Mayors Office of Children and Family Success (MOCFS) agency has implemented a plan to locate needed files from previous and current fiscal years. The agency has implemented a scanning and uploading Standard Operating Procedure (SOP) that requires each case file to be digitally attached to its application and supporting documents. This will remedy this finding in its totality. Contact Person: OHEP Director ? Rigel Moore Completion Date: March 10, 2023

View Audit 23759 Questioned Costs: $1

Finding 24011 (2022-014)

Significant Deficiency 2022

City of Baltimore, Maryland

MD

Subrecipient Monitoring Questioned Costs Cash Management § 200.303

Finding 2022-014 U.S. Department of Health and Human Services AL No. 93.568 Total Low-Income Home Energy Assistance Significant Deficiency over Eligibility Repeat Finding: No Auditee?s Corrective Action Plan: The Office of Home and Energy Programs (OHEP) bureau of The Mayors Office of Childr...

Finding 2022-014 U.S. Department of Health and Human Services AL No. 93.568 Total Low-Income Home Energy Assistance Significant Deficiency over Eligibility Repeat Finding: No Auditee?s Corrective Action Plan: The Office of Home and Energy Programs (OHEP) bureau of The Mayors Office of Children and Family Success (MOCFS) agency has implemented a plan to locate needed files from previous and current fiscal years. The agency has implemented a scanning and uploading Standard Operating Procedure (SOP) that requires each case file to be digitally attached to its application and supporting documents. This will remedy this finding in its totality. Contact Person: OHEP Director ? Rigel Moore Completion Date: March 10, 2023

View Audit 23759 Questioned Costs: $1

Finding 23979 (2022-018)

Material Weakness 2022

City of Baltimore, Maryland

MD

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.309

Finding 2022-018 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period ...

Finding 2022-018 U.S. Department of Health and Human Services AL No. 93.778 Medical Assistance Program (Medicaid; Title XIX) Material Weakness over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to the correct grant period within the general ledger. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday, and accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

View Audit 23759 Questioned Costs: $1

Finding 23961 (2022-016)

Material Weakness 2022

City of Baltimore, Maryland

MD

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.309

Finding 2022-016 U.S. Department of Health and Human Services AL No. 93.767 Children?s Health Insurance Program (CHIP) Material Weakness Over Compliance and Internal Control over Period of Performance Repeat Finding: Yes Auditee?s Corrective Action Plan: BCHD will implement controls to al...

Finding 2022-016 U.S. Department of Health and Human Services AL No. 93.767 Children?s Health Insurance Program (CHIP) Material Weakness Over Compliance and Internal Control over Period of Performance Repeat Finding: Yes Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to a grant. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday and the accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

View Audit 23759 Questioned Costs: $1

Finding 23949 (2022-002)

Significant Deficiency 2022

Metro Towers, Inc. St. James Place

MO

HUD Housing Programs Questioned Costs Special Tests & Provisions

Finding 2022-002 Responsible Party Name: Fred Gibbs Position: President ? Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207...

Finding 2022-002 Responsible Party Name: Fred Gibbs Position: President ? Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N ? Special Tests and Provisions Finding Type Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will deposit the shortfall of $868 into the reserve for replacement account, as soon as possible. We will also deposit the shortfall for 2019, 2020, and 2021 once funds become available. We will follow our process to deposit and reconcile the reserve for replacement account on a monthly basis. Anticipated Completion Date June 30, 2023

View Audit 19875 Questioned Costs: $1

Finding 23948 (2022-001)

Material Weakness 2022

Metro Towers, Inc. St. James Place

MO

HUD Housing Programs Questioned Costs Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2022 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 ? Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2022 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 ? Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor?s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2022. Finding 2022-001 Responsible Party Name: Fred Gibbs Position: President ? Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N ? Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee?s Comment on Finding We agree with the auditor?s finding. Corrective Action We will follow our policies and procedures to ensure that our accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2023

View Audit 19875

Finding 23925 (2022-024)

Significant Deficiency 2022

City of Baltimore, Maryland

MD

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.309

Finding 2022-024 U.S. Department of Health and Human Services AL No. 93.977 Totally Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Compliance and Internal Control over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: B...

Finding 2022-024 U.S. Department of Health and Human Services AL No. 93.977 Totally Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Compliance and Internal Control over Period of Performance Repeat Finding: No Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to the correct grant period within the general ledger. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday and the accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

View Audit 23759 Questioned Costs: $1

Finding 23923 (2022-006)

None 2022

City of Baltimore, Maryland

MD

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.414 § 200.502 § 200.508 § 200.510

Finding 2022-006 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee?s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistanc...

Finding 2022-006 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee?s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is ?live? as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients? information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. The City has: ? Held weekly meetings for two years with agency grant representatives to design and configure the Workday grant module. ? Uploaded the grant award, sponsor information and grant budget data into a Workday. ? Implemented a ?new grant? request which uses a Workday business process. ? In the process of reviewing and correcting recoverable costs per grant award so it is properly reported. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024

View Audit 23759

Finding 23871 (2022-004)

Significant Deficiency 2022

Northwest Oregon Housing Authority

OR

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

2021-004 Housing Voucher Cluster ? Assistance Listing No. 14.871 Recommendation: The Authority should review their HQS inspection policies to ensure that all repairs are made timely and if not, that the necessary actions are taken by the Authority. Explanation of disagreement with audit finding: The...

2021-004 Housing Voucher Cluster ? Assistance Listing No. 14.871 Recommendation: The Authority should review their HQS inspection policies to ensure that all repairs are made timely and if not, that the necessary actions are taken by the Authority. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: NOHA has reviewed its updated HQS policies, including its HQS enforcement policies. NOHA continues to refine software functionality and reporting to monitor HQS repair due dates, and to take action when necessary. Name(s) of the contact person(s) responsible for corrective action: Sandra Soucie, HCV Manager, HCVManager@nwoha.org Planned completion date for corrective action plan: 3/31/2023

View Audit 19862

Finding 23860 (2022-023)

Significant Deficiency 2022

City of Baltimore, Maryland

MD

Reporting Questioned Costs Subrecipient Monitoring § 200.302 § 200.303

Finding 2022-023 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Significant Deficiency in Compliance and Internal Control Over Reporting Repeat Finding: No Auditee?s Corrective Action Plan: BCHD will implement controls to maint...

Finding 2022-023 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Significant Deficiency in Compliance and Internal Control Over Reporting Repeat Finding: No Auditee?s Corrective Action Plan: BCHD will implement controls to maintain compliance with reporting requirements. BCHD will continue to work with the Department of Finance to ensure parameters for generating reports are the same and there is an agreed upon reconciliation when the parameters for reporting are not the same. Policies and procedures will be updated to ensure what is reported on 440 Reports are reconciled to general ledger details in addition to ensuring all submitted reports have proper approvals documented. Accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

View Audit 23759

Finding 23859 (2022-022)

Material Weakness 2022

City of Baltimore, Maryland

MD

Reporting Questioned Costs Subrecipient Monitoring § 200.303 § 200.309

Finding 2022-022 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness over Period of Performance Repeat Finding: Yes Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the peri...

Finding 2022-022 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Material Weakness over Period of Performance Repeat Finding: Yes Auditee?s Corrective Action Plan: BCHD will implement controls to allow only costs within the period of performance to be charged to a grant. BCHD will ensure that if there are any exceptions that allow for costs to be charged outside the period of performance, the proper supporting documents will be kept. Baltimore City's new financial system, Workday, allows for all supporting documentation to be kept electronically in one system. Policies and procedures for internal controls will be updated to incorporate processes in Workday and the accounting staff will be trained appropriately. Contact Person: Chief Financial Officer ? Unyime Ekpa Completion Date: December 2023

View Audit 23759 Questioned Costs: $1

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