Corrective Action Plans

Finding 21499 (2022-002)

Material Weakness 2022

OR

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

All first-tier subawards will be submitted to FFATA reporting requirements and will be reviewed by the Associate Vice President of Financial and Auxiliary Services, or designee. The corrective action plan will be implemented beginning with the FY23 ACFR preparation on June 30, 2023.

View Audit 24635

Finding 21494 (2022-001)

Significant Deficiency 2022

17th Avenue Redi, A Nonprofit Corporation 101-11198

CO

HUD Housing Programs Questioned Costs Procurement, Suspension & Debarment

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Corporation did not make the required surplus cash deposit computed at March 31, 2021, in the amount of $12,264 within 90 days of fiscal year end. Recommendation: Management should implement a system to ensure the required deposi...

Statement of Condition 2022-001 (Assistance Listing No. 14.155): The Corporation did not make the required surplus cash deposit computed at March 31, 2021, in the amount of $12,264 within 90 days of fiscal year end. Recommendation: Management should implement a system to ensure the required deposit to the residual receipts is made within 90 days of fiscal year end. Action(s) taken or planned on the finding: Agreed. Management concurs with the finding and the auditor's recommendation. The Corporation made the required surplus cash deposit on August 3, 2022.

View Audit 20971 Questioned Costs: $1

Finding 21488 (2022-003)

Significant Deficiency 2022

Rfe/rl, Inc.

DC

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Views of Responsible Officials: RFE/RL Management fully agrees on the need to ensure our policies and procedures demonstrate adherence to the requirements of the Patriot Act. The process for new employee screening will be reviewed and modified to ensure documented compliance. New vendor and contract...

Views of Responsible Officials: RFE/RL Management fully agrees on the need to ensure our policies and procedures demonstrate adherence to the requirements of the Patriot Act. The process for new employee screening will be reviewed and modified to ensure documented compliance. New vendor and contractor screening is conducted and now fully documented during the initial procurement/contracting process in our Prague office. Additionally, RFE/RL has implemented a process for regular, automated Office of Foreign Asset Control (OFAC) screening of all vendors in FY23. A similar process for regular, automated System Award Management (SAM) screening is in process. Once implemented, these systems will ensure that all vendors on RFE/RL?s supplier list will be reviewed annually.

View Audit 19732

Finding 21442 (2022-004)

Significant Deficiency 2022

Solano Community College District

CA

Questioned Costs Student Financial Aid Subrecipient Monitoring § 200.303

U.S. Department of Education 2022-004: Student Financial Assistance Cluster ? 240 Days Outstanding Check ? Assistance Listing Number: Various Recommendation: We recommend the College to update its procedures and procedures for processing and monitoring refund checks to ensure compliance with the Tit...

U.S. Department of Education 2022-004: Student Financial Assistance Cluster ? 240 Days Outstanding Check ? Assistance Listing Number: Various Recommendation: We recommend the College to update its procedures and procedures for processing and monitoring refund checks to ensure compliance with the Title IV requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: During the 2021-22 aid year, the financial aid and fiscal services departments have been working hard together to clean up and streamline the process by which we handle stale-dated ?financial aid checks? (Title-IV funds processed through BankMobile) as well as ?student refund checks? (non-Title IV funds processed through our district office). In our review, we found that three students had Title IV aid incorrectly processed as ?student refund checks? whose initial disbursement date was more than 240 days before the date of discovery. As a result, we reported those checks to the auditors when asked for outstanding Title IV checks. We have taken the following actions in response to this item: ? We have developed a ?Time Out / Reversal? workgroup that includes members of both the financial aid and fiscal services department to ensure that reissuance of checks does not occur automatically (pre-existing, but this workgroup allows us to address this issue). ? We have trained the workgroup members specifically on the importance of the 240 day limit. Implemented by September 2022. ? We continue to improve the communication between the financial aid and fiscal services. department. We currently hold meetings every two weeks to bring up any common issues and solve problems related to the administration. Implemented by September 2022. Name(s) of the contact person(s) responsible for corrective action: Alysa Borelli, Dean of Enrollment and Student Services. Planned completion date for corrective action plan: The corrective action plan was implemented by August of 2022.

View Audit 62600 Questioned Costs: $1

Finding 21414 (2022-005)

Significant Deficiency 2022

School District of the City of St. Louis

MO

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Finding 2022-005 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will schedule a call with the ECF consultant, the Fi...

Finding 2022-005 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will schedule a call with the ECF consultant, the Financial Management Office, and the Fiscal Control Office by July 15, 2023 to discuss all necessary paperwork that will be submitted to the Financial Management and Fiscal Control Offices 30 days prior to the final submission deadline to ensure that all payment requests can be submitted in the allotted time period, and give the Finance Offices understanding of what the reimbursement amount will be. The ECF consultant will copy the Chief Financial Officer, Finance Director, Grants Manager, and Fiscal Control Director on his/her submission.

View Audit 18333

Finding 21413 (2022-004)

Significant Deficiency 2022

School District of the City of St. Louis

MO

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Finding 2022-004 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: During the revise Information Technology reclamation process, students with ECF devices th...

Finding 2022-004 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: During the revise Information Technology reclamation process, students with ECF devices that do not return the device will be noted in SIS to not have returned an ECF device. The device will be locked through the Moysle system and can be traceable, and the student?s profile in SIS will indicate that they are eligible to receive a District only device that is retained at each school site if the student/family doesn?t start a payment plan to pay for the device that was not returned.

View Audit 18333

Finding 21412 (2022-003)

Significant Deficiency 2022

School District of the City of St. Louis

MO

Equipment & Real Property Management Questioned Costs Subrecipient Monitoring

Finding 2022-003 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will revise the Technology Issue and Reclamation Pla...

Finding 2022-003 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will revise the Technology Issue and Reclamation Plan to include two reconciliation periods, one after technology issuance in the summer/fall, and the other after technology reclamation in the spring/summer, to ensure that all contracts and documentation accounted for have the correct corresponding contract in the devices profile in the database where the documents are kept.

View Audit 18333

Finding 21358 (2022-001)

None 2022

Port Angeles School District No. 121

WA

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring

Finding ref number: 2022-001 Finding caption: The District overcharged indirect costs and fringe benefits to the Education Stabilization Fund Program. Name, address, and telephone of District contact person: Kira Acker 905 West 9th Street Port Angeles WA 98363 360-565-3755 Corrective action the a...

Finding ref number: 2022-001 Finding caption: The District overcharged indirect costs and fringe benefits to the Education Stabilization Fund Program. Name, address, and telephone of District contact person: Kira Acker 905 West 9th Street Port Angeles WA 98363 360-565-3755 Corrective action the auditee plans to take in response to the finding: The district has removed all 2022-2023 payroll expenses associated with fringe benefits charged against ESSER III. In addition, the unrestricted indirect percentage rate of 13.17% will be charged against the remaining ESSER III reimbursements. Anticipated date to complete the corrective action: 6/1/2023

View Audit 18481 Questioned Costs: $1

Finding 21344 (2022-002)

Significant Deficiency 2022

City and County of Honolulu

HI

Subrecipient Monitoring HUD Housing Programs

Finding No. 2022-002: Subrecipient Monitoring (Significant Deficiency - Internal Control Over Compliance) Audit Recommendation: Management should create policies and procedures to ensure required monitoring procedures are performed and completed timely. Administration?s Comment: The City will a...

Finding No. 2022-002: Subrecipient Monitoring (Significant Deficiency - Internal Control Over Compliance) Audit Recommendation: Management should create policies and procedures to ensure required monitoring procedures are performed and completed timely. Administration?s Comment: The City will adhere to policies and procedures for the timely performance of required monitoring, including the review and issuance of monitoring reports. The City will prepare a schedule for targeted monitoring and comprehensively track these projects. The City acknowledges that the finding was caused in part by the aforementioned staffing-related issues which the City has attempted to address and will continue to attempt to address by filling the vacant positions responsible for monitoring. Anticipated Completion Date: June 2023 (for the monitoring related issues including issuance of reports). Ongoing (until the Post Development Monitoring Section is fully staffed)

View Audit 17972

Finding 21332 (2022-015)

None 2022

Lafayette Prish School Board

LA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

2022-015 Recommendation: The School Board did not adhere to its policies and procedures regarding purchasing documentation. Supporting documentation relating to receipt of goods was not present for some disbursements. The School Board should adhere to their policies and procedures and ensure that...

2022-015 Recommendation: The School Board did not adhere to its policies and procedures regarding purchasing documentation. Supporting documentation relating to receipt of goods was not present for some disbursements. The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Corrective Action Plan: To ensure that receipt of goods is properly documented prior to invoice payment, the following process will be implemented effective immediately: (1) As of 7/1/2022, inventory received by each school site will be verified for documentation of receipt (signature) by CNS Office Coordinator/ Accounts Payable, (2) Inventory received without documentation of receipt will be verified with computer entry of inventory received by Area Supervisor assigned to that school; receiving date, quantity received, and price will be verified and signature will be obtained, (3) Documentation of receipt for inventory received that has not been processed for payment will be reviewed by Area Supervisor prior to submission to CNS Office Coordinator for payment, (4) School Site Cafeteria Managers and Technicians have received notification of and training on this requirement, (5) Area Supervisors will review all inventory receipts when conducting routine monitoring, and (6) The CNS Office Coordinator will be the final check to ensure that receipt of goods is properly documented.

View Audit 26549 Questioned Costs: $1

Finding 21330 (2022-009)

Material Weakness 2022

Lafayette Prish School Board

LA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

2022-009 Recommendation: The School Board did not adhere to its policies and procedures regarding purchasing documentation. Supporting documentation relating to receipt of goods was not present for some disbursements. The School Board should adhere to their policies and procedures and ensure that...

2022-009 Recommendation: The School Board did not adhere to its policies and procedures regarding purchasing documentation. Supporting documentation relating to receipt of goods was not present for some disbursements. The School Board should adhere to their policies and procedures and ensure that all required documentation is maintained. Corrective Action Plan: To ensure that receipt of goods is properly documented prior to invoice payment, the following process will be implemented effective immediately: (1) As of 7/1/2022, inventory received by each school site will be verified for documentation of receipt (signature) by CNS Office Coordinator/ Accounts Payable, (2) Inventory received without documentation of receipt will be verified with computer entry of inventory received by Area Supervisor assigned to that school; receiving date, quantity received, and price will be verified and signature will be obtained, (3) Documentation of receipt for inventory received that has not been processed for payment will be reviewed by Area Supervisor prior to submission to CNS Office Coordinator for payment, (4) School Site Cafeteria Managers and Technicians have received notification of and training on this requirement, (5) Area Supervisors will review all inventory receipts when conducting routine monitoring, and (6) The CNS Office Coordinator will be the final check to ensure that receipt of goods is properly documented.

View Audit 26549

Finding 21325 (2022-002)

Material Weakness 2022

Grays Harbor County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2022-001 Finding caption: The County?s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of county contact person: Melinda Raihl, Chief Deputy Auditor 100 W Broadway Montesano, WA 98563 (36...

Finding ref number: 2022-001 Finding caption: The County?s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of county contact person: Melinda Raihl, Chief Deputy Auditor 100 W Broadway Montesano, WA 98563 (360-964-1559) Corrective action the auditee plans to take in response to the finding: The County will verify that each contractor identified by the State Auditor has not been suspended, debarred, or otherwise excluded, and will review existing Program-funded contracts to ensure required verification. To ensure that the County verifies future Program-funded contracts, the County?s budget office will distribute to each department and elected office a copy of the Policy, as well as the Office of Management and Budget Compliance Supplement (?Supplement?). Thereafter, each year as the Supplement is updated, the County will distribute the updated Supplement. Anticipated date to complete the corrective action: 10/15/2023

View Audit 27134

Finding 21324 (2022-001)

Significant Deficiency 2022

Destination Marketing Corporation for Otsego County

NY

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

Management Response: We concur with the recommendation and going forward when the Corporation receives federal funding there will be policies in place to appropriately earmark and track federal expenditures.

View Audit 27132

Finding 21322 (2022-003)

Significant Deficiency 2022

Colorado West, INC and Affiliates

CO

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring

FISCAL YEAR OF FINDING: June 30, 2022 AUDITOR FINDING: 2022-003 FINDING: Reporting and Activities Allowed or Unallowed, Allowable Costs/Cost Principles CFDA No. 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution The Organization included direct expenses fro...

FISCAL YEAR OF FINDING: June 30, 2022 AUDITOR FINDING: 2022-003 FINDING: Reporting and Activities Allowed or Unallowed, Allowable Costs/Cost Principles CFDA No. 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution The Organization included direct expenses from 2020 and 2021 that had already been included on reporting Period 1. In addition, there was an audit entry recorded for fiscal year 2021 that had not been updated with the Period 3 report calculations. Direct expenses from 2020 and 2021 should not have been included and overstated the direct expenses applied to PRF funding by $170,246. The audit entry not included in the Period 3 revenues, reduced revenue by $110,000 along with a keying difference between general ledger data and the report of approximately $26,000. CLIENT PLANNED ACTION: Amy Cooper, VP of Operations and Aaron Hancey, Interim CFO will establish quality reviewing and approval processes so proper reporting can be done effectively and timely. CLIENT RESPONSIBLE PARTY: John Sheehan, CEO COMPLETION DATE: September 22, 2023

View Audit 26287 Questioned Costs: $1

Finding 21293 (2022-005)

None 2022

Mecklenburg County

NC

Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

U.S. Department of Treasury Pass-through Entity: N.C. Pandemic Recovery Office Program Name: Emergency Rental Assistance Federal Assistance Listing Number 21.023 ...

U.S. Department of Treasury Pass-through Entity: N.C. Pandemic Recovery Office Program Name: Emergency Rental Assistance Federal Assistance Listing Number 21.023 Eligibility and Reporting Non-Material Non-Compliance Finding 2022-005 Corrective Action Plan: Mecklenburg County Finance has implemented a process in which all Federal Agency reports are reviewed and approved by the Deputy Finance Director prior to submission. Furthermore, documentation of the approval will be retained by the department. Person responsible: David Boyd, Chief Financial Officer Estimated date of completion: June 30, 2023

View Audit 21439

Finding 21290 (2022-004)

None 2022

Mecklenburg County

NC

Questioned Costs Subrecipient Monitoring Eligibility

Department of Agriculture Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Supplemental Nutrition Assistance Program Federal Assistance Listing Number: 10.561 ...

Department of Agriculture Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Supplemental Nutrition Assistance Program Federal Assistance Listing Number: 10.561 Non-Material Non-Compliance - Eligibility Finding 2022-004 Corrective Action Plan: I. Training a. The Quality and Training unit within the Economic Services Division (ESD) will review the findings and create and deliver training to staff that determine SNAP eligibility and their supervisors and managers to address the specific errors identified during this audit, including but not limited to appropriate documentation of the completed and signed DSS-8207 or electronically generated ePASS application. This training will be delivered by the end of the third quarter of fiscal year 2023. b. NC FAST Certification for Core Functions and Level One FNS policy is required by NC DHHS and completed in the NC FAST Learning Gateway for all staff that determine SNAP eligibility. This is a staggered process initiated by NC DHHS. Mecklenburg County began this process in September 2021 with all new hires obtaining NC FAST Certification within 90 days of their hire. Existing staff that determine SNAP eligibility were enrolled in January 2022 and will complete this training within 18 months to meet all state requirements. c. In December 2022 Sr. Quality & Training Specialists were realigned to provide direct policy support to assigned teams. The assignment of specific Sr. Quality and Training Specialists to work directly with certain teams will enhance the relationship between Q&T, Eligibility staff and their Supervisors, with the goal of improving quality and timeliness of work. This realignment will more easily enable Sr. Quality & Training staff to correct errors identified through the second party review process and share those findings with the worker and their Supervisor for learning and accountability purposes. d. Managers will review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans. II. Process Improvement - A new Quality Assurance team will be created to validate the second party review process across all DSS divisions. This process will involve sampling records that have gone through the second party review process at the divisional level to ensure the review was accurate and that any errors were corrected. This team will also align second party review findings to audit findings to determine if training or process improvement strategies may improve quality. The team should be hired and standard operating procedures drafted during the 4th quarter of FY23. Person responsible: Jim Wright, Sr. Social Services Manager Ellese Massey, Social Services Manager Estimated date of completion: June 30, 2023

View Audit 21439

Finding 21285 (2022-002)

Material Weakness 2022

Mecklenburg County

NC

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal A...

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 Material Weakness and Non-Material Non-Compliance - Eligibility Finding 2022-002 Corrective Action Plan: I. Training a. The Quality and Training unit within the Economic Services Division (ESD) will review the findings and create and deliver training to staff that determine Medicaid eligibility and their supervisors and managers to address the specific errors identified during this audit, including but not limited to completing exparte determinations for eligibility when SSA terminates SSI eligibility, sending the 5097 to verify self-attest wages, properly documenting and reacting to IV-D non-cooperation, correct verification and documentation, and performing the required electronic verifications to complete an application or review. This training will be delivered by the end of the third quarter of fiscal year 2023. b. NC FAST Certification for Core Functions and Level One Medicaid policy is required by NC DHHS and completed in the NC FAST Learning Gateway for all staff that determine Medicaid eligibility. This is a staggered process initiated by NC DHHS. Mecklenburg County began this process in September 2021 with all new hires obtaining NC FAST Certification within 90 days of their hire. Existing staff that determine Medicaid eligibility were enrolled in January 2022 and will complete this training within 18 months to meet all state requirements. II. Process Improvement Strategies a. The division is continuing to hire Eligibility Specialist positions that will manage Medicaid cases. These added resources will help alleviate current workload challenges faced by existing staff and allow for a more thorough review of work being completed. b. In December 2022 Sr. Quality & Training Specialists were realigned to provide direct policy support to assigned teams. The assignment of specific Sr. Quality and Training Specialists to work directly with certain teams will enhance the relationship between Q&T, Eligibility staff and their Supervisors, with the goal of improving quality and timeliness of work. This realignment will more easily enable Sr. Quality & Training staff to correct errors identified through the second party review process and share those findings with the worker and their supervisor for learning and accountability purposes. c. A new Quality Assurance team will be created to validate the second party review process across all DSS divisions. This process will involve sampling records that have gone through the second party review process at the divisional level to ensure the review was accurate and that any errors were corrected. This team will also align second party review findings to audit findings to determine if training or process improvement strategies may improve quality. The team should be hired and standard operating procedures drafted by the 4th quarter of FY23. Ill. Quality Sampling and Accountability a. The Quality and Training Unit will complete monthly quality sampling for Medicaid. Error trends will be shared with the managers and their supervisors, who will work collaboratively with Quality & Training staff to coordinate appropriate strategies to train and coach staff to mitigate errors moving forward. b. Supervisors will review specific quality sampling results with their staff. The supervisor will, when necessary and appropriate, address continued errors using an individual Corrective Action Plan with the worker to include refresher training, additional second party review and/or initiating the formal documentation process. c. Managers will review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans. Person responsible: Jim Wright, Sr. Social Services Manager Ellese Massey, Social Services Manager Estimated date of completion: June 30, 2023

View Audit 21439 Questioned Costs: $1

Finding 21281 (2022-003)

Significant Deficiency 2022

Mecklenburg County

NC

Questioned Costs Subrecipient Monitoring Eligibility

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 ...

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Significant Deficiency - Eligibility Finding 2022-003 Corrective Action Plan: I. Quality Sampling and Accountability a. In December 2022 Sr. Quality & Training Specialists were realigned to provide direct policy support to assigned teams. The assignment of specific Sr. Quality and Training Specialists to work directly with certain teams will enhance the relationship between Q&T, Eligibility staff and their Supervisors, with the goal of improving quality and timeliness of work. This realignment will more easily enable Sr. Quality & Training staff to correct errors identified through the second party review process and share those findings with the worker and their Supervisor for learning and accountability purposes. b. The Quality and Training Unit will complete monthly quality sampling for TANF. Error trends will be shared with the managers and their supervisors, who will work collaboratively with Quality & Training staff to coordinate appropriate strategies to train and coach staff to mitigate errors moving forward. c. Supervisors will review specific quality sampling results with their staff. The supervisor will, when necessary and appropriate, address continued errors using an individual Corrective Action Plan with the worker to include refresher training, additional second party review and/or initiating the formal documentation process. d. Managers will review quality sampling results with supervisors quarterly to follow up on errors addressed, trainings completed and progress with individual Corrective Action Plans II. Process Improvement - A new Quality Assurance team will be created to validate the second party review process across all DSS divisions. This process will involve sampling records that have gone through the second party review process at the divisional level to ensure the review was accurate and that any errors were corrected. This team will also align second party review findings to audit findings to determine if training or process improvement strategies may improve quality. The team should be hired and standard operating procedures drafted by 4th quarter of FY23. Person responsible: Jim Wright, Sr. Social Services Manager Ellese Massey, Social Services Manager Estimated date of completion: June 30, 2023

View Audit 21439

Finding 21262 (2022-002)

Material Weakness 2022

Tohono O'Odham Community College

AZ

Reporting Questioned Costs Student Financial Aid

TOCC RESPONSE TO 2022-002 Submission of Single Audit Reports (Material Weakness). We agree with the finding. To improve TOCC?s financial reporting process and ensure timely completion of our annual single report, the TOCC will take the following steps: 1. The Dean of Finance, Controller, and an add...

TOCC RESPONSE TO 2022-002 Submission of Single Audit Reports (Material Weakness). We agree with the finding. To improve TOCC?s financial reporting process and ensure timely completion of our annual single report, the TOCC will take the following steps: 1. The Dean of Finance, Controller, and an additional contracted expert are developing and implementing a project plan that outlines all necessary tasks and timelines for completion. That information will be used by the President and Administrative Council in a report to the Board of Trustees semi-annually; 2. The group will arrange regular check-ins and progress reviews to ensure that all tasks are on track. 3. TOCC will make more use of the Data Management System?s technology and automation tools to streamline the process of financial reporting, reduce the workload, and decrease potential for human error resulting from manual processes; 4. To ensure compliance with the latest financial regulations and requirements, administration will provide finance and accounting staff with needed training and professional development. 5. Additional accounting support has been and will be employed to review procedures and to assist with tasks as the need indicates. 6. TOCC?s adherence to this corrective action plan will ensure that the audit will be completed by the single audit deadline of March 31, 2024.

View Audit 19831

Finding 21259 (2022-001)

Significant Deficiency 2022

St. Clair County Housing Authority

IL

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding 2022-001- Housing Choice Voucher Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance and Significant Deficiency Housing Choice Voucher Program CFDA #14.871 Corrective Action Plan: 1) SCCHA will arrange for a thorough tenant file audit of existing HCVP files to d...

Finding 2022-001- Housing Choice Voucher Tenant Files - Eligibility- Internal Control over Tenant Files - Noncompliance and Significant Deficiency Housing Choice Voucher Program CFDA #14.871 Corrective Action Plan: 1) SCCHA will arrange for a thorough tenant file audit of existing HCVP files to determine whether there is a significant Incident of incorrect income projections and/or tenant rent calculations. The Initial audit will entail 230 HCVP files randomly sampled (approximately 10% of the program.) The file audit process will continue to include more randomly selected files as Indicated by the results of the initial audit. 2) SCCHA will Increase monitoring and review of HCVP files to increase accuracy and ensure compliance with regulatory and statutory requirements related to income projection and rent determinations. 3) Any staff members with rent calculation certifications older than ten years will be required to attend HCVP rent calculation training and pass the corresponding certification exam. Anticipated Completion Date: 1) Within six months; 2) Initiated within 60 days and on-going thereafter; 3) Within twelve months depending on third-party trainer availability Persons Responsible: Larry McLean, Executive Director; Pam Jackson, HCV Program Director; and Shanae Golliday, Program Integrity & Compliance Coordinator

View Audit 23389

Finding 21218 (2022-001)

None 2022

Cooperative for Assistance and Relief Everywhere, Inc. (care)

GA

Subrecipient Monitoring Reporting § 200.170

Corrective Action Plan Finding no 2022-001 CARE USA Federal Funding Accountability and Transparency Act (FFATA) Compliance Background FFATA is a federal law intended to hold the government accountable and reduce wasteful spending. The law, codified under 2 CFR 170, requires that information on fede...

Corrective Action Plan Finding no 2022-001 CARE USA Federal Funding Accountability and Transparency Act (FFATA) Compliance Background FFATA is a federal law intended to hold the government accountable and reduce wasteful spending. The law, codified under 2 CFR 170, requires that information on federal awards, including subaward activities, be made available to the public through a website maintained by the Office of Management and Budget (OMB). Application and Requirements FFATA applies to all US Government (USG) grants, cooperative agreements and contracts managed by CARE as the prime recipient. Under FFATA, CARE must report any subgrant greater than or equal to $30,000 and any subsequent obligation increase through the FSRS.gov website by the end of the month following the month of the subaward. Compliance Issues Identified as part of the FY2022 Audit Based on the finding in the FY21 Single Audit corrective actions were implemented in FY22. The delays identified in the FY22 Single Audit occurred in the first six months of the fiscal year, before planned FY22 corrective actions were fully implemented. Root Causes The root causes for the delay in reporting the partner organizations (i.e., subrecipients) information with whom CARE works with is as follows: ? Failure by the partner organization to timely adhere to the FFATA requirements delineated in the partner funding agreement (PFA). ? Delay in and confusion by the partner about registering the organization in SAM.gov (a USG database) and system difficulties in obtaining a Unique Entity Identifier Number (UEI), through SAM.gov. Recommended Solutions by CARE Management Team by June 30, 2023 1. Award Management Solutions (AMS) team will: a. Issue additional guidance and notification to all CARE business units involved with FFATA compliance. b. Deliver refresher training for all CARE country offices and HQ units involved with FFATA compliance. c. Complete the terms of reference and initiate the development of an award management platform for COs and HQ units to manage the donor compliance reporting and administration across the organization. 2. CARE will implement preventative controls to reduce the risk of future non-compliance, including: a. Ensure that partners are aware of SAM.gov registration at the proposal development stage; require partners to submit the completed FFATA form before full execution of the PFAs and PFA modifications; and include the completed FFATA form in the approval process. b. AMS will review the PFA templates to include partner DUNS/UEIN and assign a field for a PFA reference number. c. SSC to modify the Project ID (PID) set-up form to include a DUNS/UEIN. d. SSC will strictly enforce the submission of the FFATA collection form before setting up a new PID for USG PFAs and for PFA obligation increases. SSC will continuously monitor for compliance and notify the CARE Country Director of non-compliance instances, copying in the Regional Director (HQ Technical Director for non-CARE USA COs), VP IPO (or VP Program Strategy & Impact) the CFO and the AVP AMS. A Key Performance Indicator (KPI) on donor reporting timeliness will be included on the Country Director KPI dashboard. Repeated instances of non-compliance will be considered a personnel performance issue with the CARE Country Director or a contractual performance issue with the non-CARE USA CO. 3. SSC will monitor: (i) first tier partner funding spending against obligation under USG awards to anticipate potential modifications; (ii) USG awards spending and set-up in the system; and (iii) the completeness of USG awards and PFA documents. SSC will provide a monitoring report to AMS. AMS will spot check the report and provide a response to SSC on non-compliance issues identified and recommended corrective actions. AMS will escalate concerns on gaps identified to the CFO. Responsible Contact: ? Jason Zeno, CARE USA, AVP Grants, Contracts & Donor Compliance, email: jason.zeno@care.org

View Audit 17958

Finding 21196 (2022-002)

Significant Deficiency 2022

Maine Maritime Academy

ME

Matching / Level of Effort / Earmarking Questioned Costs Subrecipient Monitoring

Finding 2022-002: Education Stabilization Fund, COVID-19 ? Higher Education Emergency Relief Fund Institutional Portion ? Earmarking Name of Contact Person: Richard Rosen, Vice President for Financial and Institutional Services Corrective Action Plan: The Academy will review the earmarking requ...

Finding 2022-002: Education Stabilization Fund, COVID-19 ? Higher Education Emergency Relief Fund Institutional Portion ? Earmarking Name of Contact Person: Richard Rosen, Vice President for Financial and Institutional Services Corrective Action Plan: The Academy will review the earmarking requirements, document the Academy?s reasoning for allocation of the funds, and follow-up with the U.S. Department of Education to ensure that the Academy is complying with the applicable provisions of the award. Planned Completion Date: September 2023

View Audit 23362

Finding 21167 (2022-001)

Significant Deficiency 2022

Independent School District 701

MN

Internal Control / Segregation of Duties Subrecipient Monitoring

Actions Planned - The school district has implemented a plan to eliminate this finding for federal programs by distributing duties, and adding additional oversite. Program managers are assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers sign off on...

Actions Planned - The school district has implemented a plan to eliminate this finding for federal programs by distributing duties, and adding additional oversite. Program managers are assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers sign off on all receipts and disbursements. Monthly reports will be given to program managers to assist in the oversight. The Special Education Director acts as program manager for special ed funds, a Principal acts as program manager for Title funds, and the Superintendent acts as program manager for all other federal funds. Request for reimbursement and receipting is completed by the Administrative Assistant with oversight by the Business Manager and Superintendent. The key action to eliminate inadequate segregation of duties is developing strong controls over the review and approval of adjusting journal entries. This involves detailed review by the program manager and the Superintendent. Adjusting journal entries are discussed and signed off on each month to timely detect misstatements. Official Responsible - Business Manager and Superintendent of Schools Planned Completion Date - December 30th, 2022 Disagreement with Finding - None - ISD #701 - Hibbing concurs with the finding. Plan to Monitor - The District is aware of the situation and will monitor, as it deems appropriate. Monitoring will include educating program managers to provide additional oversight for the interim and year-end reporting.

View Audit 21664

Finding 21162 (2022-002)

Significant Deficiency 2022

Green County

WI

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding 2022-002 AL No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Department of Treasury Pass-through Agency Not applicable Award Number / Year Not applicable Department Green County Department of Finance Criteria: The Uniform Guidance requ...

Finding 2022-002 AL No. 21.027 COVID-19 Coronavirus State and Local Fiscal Recovery Funds Federal Agency U.S. Department of Treasury Pass-through Agency Not applicable Award Number / Year Not applicable Department Green County Department of Finance Criteria: The Uniform Guidance require that prior to entering into subawards and contracts with award funds, recipients must verify that such contractors and sub recipients are not suspended, debarred or otherwise excluded pursuant to 31 CFR section 19.300. Condition/Context: During testing, it was noted that the County could not provide evidence this verification had been completed for the two vendors tested. The sample was not statistically valid. Cause: The County did not have evidence verification was completed. Questioned Costs: None noted. Effect: The County could conduct business with a vendor who is suspended or barred. Recommendation: We recommend the County create a procedure that includes one of the following ways to complete this verification. 1. checking the System for Award Management Exclusions maintained by the General Services Administration and available at SAM.gov. Note: The OMB guidance at 2 CFR Part 180 and agency implementing regulations still refer to the SAM Exclusions as the Excluded Parties List System, 2. collecting a certification from the entity, or 3. adding a clause or condition to the covered transaction with that entity, 2 CFR section 180.300. Corrective Action Plan: The County has established the process of doing the System for Award Management validation and attaching screen shots of the results to each vendor. Contracts are reviewed by Corporation Counsel and they determine if the clause should be added. Regardless, they are still validated by SAM.

View Audit 23054

Finding 21148 (2022-003)

Significant Deficiency 2022

Pierce County

WA

Subrecipient Monitoring Allowable Costs / Cost Principles

Finding ref number: 2022-003 Finding caption: The County did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring requirements. Name, address, and telephone of Pierce County?s contact person: Thomas Taylor 950 Fawcett Ave., Suite 100 Tacoma, WA 98402 253-7...

Finding ref number: 2022-003 Finding caption: The County did not have adequate internal controls for ensuring compliance with federal subrecipient monitoring requirements. Name, address, and telephone of Pierce County?s contact person: Thomas Taylor 950 Fawcett Ave., Suite 100 Tacoma, WA 98402 253-798-7577 Corrective action the auditee plans to take in response to the finding: Pierce County has taken steps to improve contracting oversight procedures for 2023 so that contracts with subrecipients will contain the required elements. Anticipated date to complete the corrective action: September 1, 2023

View Audit 21681

Corrective Action Plans

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