Corrective Action Plans

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Recommendation: We recommend the County document and, where applicable, implement policies and procedures that are aligned with Uniform Grant Guidance to limit the risk for noncompliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...
Recommendation: We recommend the County document and, where applicable, implement policies and procedures that are aligned with Uniform Grant Guidance to limit the risk for noncompliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County contracted with a private entity for oversight on the distribution of ARPA federal awards. We will continue to get guidance from auditors and other municipalities to ensure uniform guidance is followed. Name(s) of the contact person(s) responsible for corrective action: Director of Budget and Finance Planned completion date for corrective action plan: February 2023
Recommendation: We recommend that the County revise its existing subrecipient agreement to include all of the required data elements under Uniform Guidance section 200.331. Further, we recommend that the County develop and implement the necessary written policies and procedures related to subrecipie...
Recommendation: We recommend that the County revise its existing subrecipient agreement to include all of the required data elements under Uniform Guidance section 200.331. Further, we recommend that the County develop and implement the necessary written policies and procedures related to subrecipient monitoring to provide guidance and a formal process for employees to follow when monitoring subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement all the recommended changes to ensure we conform with all the required data elements under Uniform Guidance section 200.331. Name(s) of the contact person(s) responsible for corrective action: Director of Office of Community Development. Planned completion date for corrective action plan: March 2024
As per the CNMI Department of Finance Procurement regulations 70-30.3-225, sole source procurement indicates that a written justification shall be prepared by the official with expenditure authority. In this instance, the selection process of the three contractors chosen was based on quotations for ...
As per the CNMI Department of Finance Procurement regulations 70-30.3-225, sole source procurement indicates that a written justification shall be prepared by the official with expenditure authority. In this instance, the selection process of the three contractors chosen was based on quotations for the required services in face-to-face meetings, and the knowledge that these were the sole qualified local contractors with highly specialized and technical expertise to fulfill the scope of the project in preventing further damage to endangered species corals from typhoon-related marine debris. There was an admitted failure to document the procedure undertaken to retain these contractors’ services, and corrective measures have since been put in place, with completion date of corrective action effective December 31, 2023 for the ongoing remainder of the project period, as well as all future federal grants as follows: a. Requests for Proposals will be published in local media with following detail:  Project title and overview  Scope of Work  Proposal Requirements  Submission Deadline and Contact Information  Evaluation and Selections  Contractual information b. The selection criteria are based on the Proposal Evaluation Form, attached herewith. MINA Proposal Evaluation Form Proposal Information:  RFP Release Date:  Proposal Submission Deadline  Proposal Submitted By:  Title:  Proposal Number:  Evaluator Name:  Criteria for Evaluation: Scoring System: 1: Poor, 2: Below Average, 3: Average, 4: Above Average, 5: Excellent 1. Compliance with RFP Requirements Score:  Proposal conforms to the RFP instructions and guidelines.  All required documentation and attachments are included.  Proposal was submitted before the deadline. 2. Understanding of Requirements Score:  Demonstrated understanding of the project's scope and objectives.  Clear articulation of how the proposal meets the needs outlined in the RFP. 3. Technical Approach Score:  Clarity and feasibility of the proposed technical approach.  Innovation and creativity in addressing project challenges. 4. Qualifications and Experience Score:  Relevant qualifications and expertise of the proposing organization.  Past experience on similar projects. 5. Cost and Budget Score:  Cost breakdown and justification.  Alignment of proposed budget with the project's scope. 6. References and Client Feedback Score:  Provided references and feedback from previous clients. 7. Timeline and Milestones Score:  Realistic project timeline and milestones.  Clearly defined project phases. 8. Risk Assessment and Mitigation Score:  Identification of potential risks and a plan for risk mitigation. 9. Quality Control and Assurance Score:  Explanation of quality control measures to ensure project qualityOverall Assessment:  Total Score: Summary and Recommendations: Evaluation completed by: Print name and sign Date Sole Source Procurement Policy December 12, 2023 Marana Islands Nature Alliance (MINA), as a non-Federal entity, and pursuant to CNMI Department of Finance Procurement regulations section 70-30.3-225, has established the following sole source procurement procedures for the acquisition of property or services required under a Federal award or subaward: 1. A contract may be awarded for a supply, service, or construction without competition when the Executive Director of MINA or his or her designee determines in writing that there is only one source for the required supply, service or construction item. This section shall be construed to include the purpose of obtaining professional services in highly specialized or technical expertise in compliance with federal regulations and whenever so required by any federal granting agencies or grant requirements. 2. The written determination shall state the unique capabilities required and why they are required and the consideration given to alternative sources. The written determination shall contain the specific unique capabilities required; the specific unique capabilities of the contractor; the availability of funding for such services as certified by the MINA accountant; and a written copy of any applicable federal grant or regulation under which the services are authorized or required. Approved by: Roberta Guerrero
Finding 10562 (2022-017)
Significant Deficiency 2022
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recomme...
Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University implement procedures to ensure that the risk assessment used to determine compliance with the Gramm-Leach-Bliley act is properly reviewed. Action taken in response to finding: The University agrees with the finding and has developed the following corrective action plan. The University is creating a GLBA management program to govern security of GLBA data and ensure compliance with associated requirements. Name(s) of the contact person(s) responsible for corrective action: Heath Hodges, A&M CIO. Planned completion date for corrective action plan: March 2024
Finding 10448 (2022-002)
Material Weakness 2022
Finding ref number: 2022-002 Finding caption: The County did not have adequate internal controls for ensuring compliance with federal reporting requirements. Name, address, and telephone of County contact person: Randy Rydel 322 N. Commercial Street, 4th Floor Bellingham WA, 98226 (360)778-6217 Corr...
Finding ref number: 2022-002 Finding caption: The County did not have adequate internal controls for ensuring compliance with federal reporting requirements. Name, address, and telephone of County contact person: Randy Rydel 322 N. Commercial Street, 4th Floor Bellingham WA, 98226 (360)778-6217 Corrective action the auditee plans to take in response to the finding: Accounting staff identified this issue at the 2022 year's end, before our audit and the finding. At that time, we updated procedures to include copies of all required reporting in the corresponding grant folder and sent them via electronic means whenever possible. This change will help maintain a transmission record for this and other required reporting. Anticipated date to complete the corrective action: 12/31/2022
Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsid...
Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.
Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsid...
Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.
Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsid...
Following the Auditor's recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.
Following the Auditor’s recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsi...
Following the Auditor’s recommendations and as a corrective action, the staff or department in charge locate and document all required reports that were filed according to the requirements of the grant agreement, including the reconciliation thereof with the official Municipality’s accounting subsidiaries. In addition, the Municipality will design, document, establish and provide the necessary and required training, including guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds.
Finding 9988 (2022-001)
Material Weakness 2022
This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Findin...
This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The City’s internal controls were inadequate for ensuring compliance with federal requirements for suspension and debarment. Name, address, and telephone of City contact person: Dale Novobielski, Clerk/Treasurer 115 West Naches Avenue Selah, WA 98942 (509) 698-7334 Corrective action the auditee plans to take in response to the finding: The City will develop written procedures, including a checklist, to ensure contractors hired to perform work on federally funded projects are evaluated through the Sam.gov website to ensure they are not suspended or debarred. Anticipated date to complete the corrective action: January 2024
Finding 9872 (2022-034)
Significant Deficiency 2022
The DCEO filled the position responsible for issuing MDLs in June 2023.
The DCEO filled the position responsible for issuing MDLs in June 2023.
Aging will hire and train staff; this is already in process.
Aging will hire and train staff; this is already in process.
The IDoA will develop and implement procedures to ensure compliance and will have continuity should staff turnover occur.
The IDoA will develop and implement procedures to ensure compliance and will have continuity should staff turnover occur.
IDOT’s Aeronautics Administrative Services Manager had a process in place; however, due to a loss of key staff, the reporting was not done. Aeronautics is trying to gain clearer guidance from FAA regarding what needs to be included in the FFATA reporting (i.e. only State Block Grants or including fu...
IDOT’s Aeronautics Administrative Services Manager had a process in place; however, due to a loss of key staff, the reporting was not done. Aeronautics is trying to gain clearer guidance from FAA regarding what needs to be included in the FFATA reporting (i.e. only State Block Grants or including funds granted to Primary Airports or Non-Primary Airports, which are being channeled through States due to state statutory provisions (so-called channeling)). IDOT is also working on the following items: 1. Gaining secure access into https://www.fsrs.gov/ a. Document and establish procedure of how access was accomplished. 2. Establishing procedures following award of all grants/contracts (primary airports and non-primary airports) greater than $30,000. Procedures will dictate that staff must enter necessary information into fsrs.gov upon award. 3. Communicating/documenting direction as appropriate.
Finding 9846 (2022-028)
Significant Deficiency 2022
The IDES will implement an internal process, which will include a supervisory review.
The IDES will implement an internal process, which will include a supervisory review.
The third-party service provider has provided SOC1 reports that appear to have resolved the internal controls. The service provider will continue to provide SOC 1 reports through Fiscal Year 2024. The IDES will review to ensure that appropriate controls remain in place.
The third-party service provider has provided SOC1 reports that appear to have resolved the internal controls. The service provider will continue to provide SOC 1 reports through Fiscal Year 2024. The IDES will review to ensure that appropriate controls remain in place.
Finding 9827 (2022-024)
Significant Deficiency 2022
ICJIA will review its current site visit policy and adjust to ensure the timing of review and submission of site visit documentation is clearly stated. Upon making any updates, ICJIA will circulate the site visit policy and provide training to grant specialists and program managers.
ICJIA will review its current site visit policy and adjust to ensure the timing of review and submission of site visit documentation is clearly stated. Upon making any updates, ICJIA will circulate the site visit policy and provide training to grant specialists and program managers.
The Victims of Crime Act (VOCA) performance reports have been updated to include the VOCA administration funds for the Federal fiscal year to be used by ICJIA. A policy and procedure guide for the update of the OVC PMT system to include the administration funds will be developed and submitted to the...
The Victims of Crime Act (VOCA) performance reports have been updated to include the VOCA administration funds for the Federal fiscal year to be used by ICJIA. A policy and procedure guide for the update of the OVC PMT system to include the administration funds will be developed and submitted to the DOJ OVC by January 1, 2024. A step has been included in the timeline for the development and the submission of the VOCA annual report to include the review and verification that VOCA administration funds have been included in the report.
In calendar year 2022, ICJIA identified an issue in its procedure in that its grants management system was unable to identify the execution dates of amendments, which resulted in some amendments not being timely entered into the FFATA system or not being entered. After identifying this issue, agency...
In calendar year 2022, ICJIA identified an issue in its procedure in that its grants management system was unable to identify the execution dates of amendments, which resulted in some amendments not being timely entered into the FFATA system or not being entered. After identifying this issue, agency personnel developed a new procedure that allows ICJIA to capture the pertinent amendment information so that it can ensure timely and complete entry into the FFATA system. This new procedure was finalized on October 26, 2022, prior to receipt of this finding. Staff were trained on the new procedure immediately and ICJIA is currently using the new procedure. ICJIA anticipates that the new procedure will limit or eliminate missed FFATA reporting. ICJIA continues to explore automated options to better improve efficiencies and streamline our FFATA processes.
The IDPH’s fiscal staff were notified in November 2021 to add the ALN to the warrant description for each subrecipient disbursement made.
The IDPH’s fiscal staff were notified in November 2021 to add the ALN to the warrant description for each subrecipient disbursement made.
View Audit 13503 Questioned Costs: $1
The IDPH developed a process with our grants management system vendor to generate a file of all Federal awards to subrecipients equal to or more than $30,000. This file is then uploaded monthly to the FFATA Subaward Reporting System (FSRS) by the Grant Accountability & Transparency Specialist. The ...
The IDPH developed a process with our grants management system vendor to generate a file of all Federal awards to subrecipients equal to or more than $30,000. This file is then uploaded monthly to the FFATA Subaward Reporting System (FSRS) by the Grant Accountability & Transparency Specialist. The IDPH has uploaded current award data, as well as historical data back to January 2023 and plans to go back two additional years.
IDHS - Division of Family and Community Services (FCS) The IDHS-FCS’ Bureau of Contract Support and Payment administration staff has reviewed the exceptions and worked to create a process to ensure the proper notification of the ALN at time of disbursement. A plan of action was created whereby in ea...
IDHS - Division of Family and Community Services (FCS) The IDHS-FCS’ Bureau of Contract Support and Payment administration staff has reviewed the exceptions and worked to create a process to ensure the proper notification of the ALN at time of disbursement. A plan of action was created whereby in each fiscal year the IDHS’ Bureau of Program Support and Fiscal Management staff will communicate the appropriate ALN to be utilized. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS-SUPR staff will ensure that all monthly expenditure vouchers have the ALNs listed and will work with IDHS’ fiscal staff to ensure that the ALNs are listed in the notes field for all vouchers processed for payments. Finally, the IDHS-SUPR staff will ensure that the ALNs are listed on all grants and contracts.
View Audit 13503 Questioned Costs: $1
For future consideration of funding, the IDHS will ensure that, in addition to meeting health and safety requirements, the providers will also complete certification and attestation that verifies that they meet the requirements and eligibility of the program.
For future consideration of funding, the IDHS will ensure that, in addition to meeting health and safety requirements, the providers will also complete certification and attestation that verifies that they meet the requirements and eligibility of the program.
View Audit 13503 Questioned Costs: $1
IDHS - Division of Family and Community Services (FCS) The IDHS-FCS staff will meet to determine the need for updated documentation and communication regarding subrecipient programmatic monitoring. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS-SUPR staff will track the ...
IDHS - Division of Family and Community Services (FCS) The IDHS-FCS staff will meet to determine the need for updated documentation and communication regarding subrecipient programmatic monitoring. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS-SUPR staff will track the completion of compliance and monitoring activities and update the Virtual Compliance Review (VCR) Tracking spreadsheet to track additional monitoring activities to ensure compliance processes are achieved in a timely manner. The IDHS will send reminders and conduct follow- up activities with compliance monitors to ensure compliance and monitoring activities are moving forward as planned. Finally, IDHS will update procedures and provide training to compliance monitors to ensure consistent follow-up is conducted when organizations do not meet established deadlines.
View Audit 13503 Questioned Costs: $1
IDHS - Office of Contract Administration (OCA) The OCA has continued to facilitate internal meetings between IDHS-Department of Innovation and Technology staff, Bureau of Federal Reporting staff, and Division of Family and Community Services (FCS) staff to establish automated procedures. These meeti...
IDHS - Office of Contract Administration (OCA) The OCA has continued to facilitate internal meetings between IDHS-Department of Innovation and Technology staff, Bureau of Federal Reporting staff, and Division of Family and Community Services (FCS) staff to establish automated procedures. These meetings will assist the IDHS to identify all awards subject to the FFATA reporting requirements. IDHS - Division of Substance Use, Prevention, and Recovery (SUPR) The IDHS will develop written policies for identifying all grants subject to FFATA for SUPR funded grants and will create detailed procedures for reporting. Furthermore, the IDHS will track the submission of all FFATA reports monthly. Additional IDHS staff will be hired to conduct FFATA reporting.
View Audit 13503 Questioned Costs: $1
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