Corrective Action Plans

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2025-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act, direct recipients of grants or cooperative agreements are required to report fir...
2025-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act, direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: Upon discovery of the issue in November 2025, City staff corrected the noncompliance by submitting the required report to the appropriate reporting system/entity. To prevent recurrence, management has strengthened internal controls over FFATA reporting and Single Audit preparation by (1) adding review and verification steps, (2) communicating expectations with key personnel, and (3) explicitly assigning submission responsibility to a designated submitter who is independent of the individual(s) responsible for monitoring compliance. These control enhancements are expected to identify and prevent similar deficiencies and, based on implementation to date, appear to be operating effectively. Responsible Person: Jason Denton, Controller Anticipated Completion Date: June 30, 2026
The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a re...
The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a recognized framework such as NIST. Based on the results, the College will document identified risks, existing safeguards, and remediation plans. Additionally, the College will formalize and update its Written Information Security Program, including policies addressing vendor management, user access controls, data transmission and destruction, change management, and data inventory. Policies will be reviewed and approved through the College’s governance process. Responsible Party: Kyle Brown, Executive Director of Technology, Jamestown Community College, kylebrown@sunyjcc.edu, 716.338.1118 Anticipated Completion Date: August 31, 2026
FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Defici...
FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Education Georgia Department of Education 84.027 - Special Education Cluster Grant to States 84.173 - Special Education Cluster Preschool Grants H027A230073 (Year: 2024), H027A240073 (Year: 2025), H173A240081 (Year: 2025) $1,283 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Special Education Cluster. Corrective Action Plans: The District concurs with the finding and is committed to strengthening internal controls. While the identified discrepancies were isolated, we recognize the need for enhanced reconciliation during personnel transitions. The Human Resources and Finance departments will enhance our review process. This pre-payroll validation step will ensure that all salary adjustments and position changes align with Board authorized pay documentation prior to disbursement. Estimated Completion Date: 3/31/2026 Contact Person: Julie Wiley, Chief Financial Officer Telephone: 229-316-1878 Email: juliewiley@lowndes.k12.ga.us
Finding 2025-003 See response to finding 2025-001.
Finding 2025-003 See response to finding 2025-001.
Condition: The controls in place to review the final grant packet, including the grant draw-down template and the drawdown invoice detail, prior to final processing of the drawdown were not operating as designed. Planned Corrective Action: Treasury will work with PMM and DCC departments to out-line ...
Condition: The controls in place to review the final grant packet, including the grant draw-down template and the drawdown invoice detail, prior to final processing of the drawdown were not operating as designed. Planned Corrective Action: Treasury will work with PMM and DCC departments to out-line a process to ensure accurate reporting of eligible expenses when invoices are re-viewed for compliance with grant program requirements. The process will be documented and adhered to once agreed by all departments. A review process for the final drawdown submission will also be adopted to ensure costs that are identified as ineligible are appro-priately excluded from the final submission. Contact person responsible for corrective action: Sr. Grants Manager Anticipated Completion Date: 06/30/2026
Since the prior audit period, management has taken steps to review and revise OFB’s procurement policy and procedures, in alignment with federal procurement standards. Finance will continue implementing the corrective actions and establishing the internal controls to ensure adherence to the policy, ...
Since the prior audit period, management has taken steps to review and revise OFB’s procurement policy and procedures, in alignment with federal procurement standards. Finance will continue implementing the corrective actions and establishing the internal controls to ensure adherence to the policy, retaining documentation of the procurement process to demonstrate compliance. These recent and planned improvements will enhance transparency, strengthen accountability, and reduce compliance risk, ensuring a more efficient and well-documented procurement process that supports the organization’s long-term financial integrity and operational effectiveness. The anticipated completion date remains June 30, 2026.
Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staf...
Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staff members during each phase of the grants management lifecycle, as well as implementing procedures and tools to ensure compliance with subrecipient monitoring requirements. These steps involve multiple levels of review for accurate and consistent application of indirect cost rates. Finance will continue implementing the corrective actions necessary to achieve effective controls over compliance with indirect cost rate requirements. Policy and procedures on allowable and allocable costs will be drafted to clearly document how direct and indirect costs will be billed to federal awards. Training will be provided to relevant staff members to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date remains June 30, 2026.
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across dep...
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across departments and teams. Finance will continue implementing the corrective actions necessary to establish an effective and compliant time and effort reporting system, including providing training for employees and regularly monitoring for effective system utilization. These actions will strengthen internal controls and ensure personnel costs are accurately recorded and appropriately allocated. The anticipated completion date remains June 30, 2027.
Corrective Action Plan for Finding 2025-001 We are in receipt of the Finding Required to be reported by the Uniform Guidance regarding the Reporting Compliance Requirement. Management agrees with the finding. The discrepancy in current-year reporting resulted from a computational oversight caused by...
Corrective Action Plan for Finding 2025-001 We are in receipt of the Finding Required to be reported by the Uniform Guidance regarding the Reporting Compliance Requirement. Management agrees with the finding. The discrepancy in current-year reporting resulted from a computational oversight caused by a formula error within the reporting templates. Where possible, we will add automated check figures to the reporting spreadsheets to validate data accuracy and strengthen internal review procedures. Jamie Moore, Accounting Manager, will be responsible for ensuring this is accomplished. The correction action plan will be implemented by September 30, 2026.
Finding 2025-004: Reporting – Owner – Certified Submission Management Response Management agrees with the finding. REAC submission was late because year – end accounting records were not done in time. Corrective Action Plan 1. Establish a Closing Calendar and Compliance Calendar • Year-end data dead...
Finding 2025-004: Reporting – Owner – Certified Submission Management Response Management agrees with the finding. REAC submission was late because year – end accounting records were not done in time. Corrective Action Plan 1. Establish a Closing Calendar and Compliance Calendar • Year-end data deadlines • Dates for draft and final financials • REAC submission due date 2. Coordination with Fee Accountant • Schedule year-end preparation work earlier • Fee Accountant set a deadline for LHA to provide supporting documents IMPLEMENTATION TIMELINE: PRIOR TO NEXT FISCAL YEAR-END.
Contact Person(s): Sandy Fabre, CFO Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective action planned: Management will complete a two-step review process to ensure expenses are being validated...
Contact Person(s): Sandy Fabre, CFO Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement Corrective action planned: Management will complete a two-step review process to ensure expenses are being validated correctly. Additionally, a selective self-audit program will be developed to verify that recordkeeping is complete and effective. Anticipated completion date: 05/01/2026
02/09/2026 Worksystems, Inc respectfully submits the following corrective action plan for the year ending June 30, 2025. Audit: July 01, 2024 – June 30, 2025 The findings from the schedule of findings and questioned cost are discussed below. The findings are numbered with the number assigned in the ...
02/09/2026 Worksystems, Inc respectfully submits the following corrective action plan for the year ending June 30, 2025. Audit: July 01, 2024 – June 30, 2025 The findings from the schedule of findings and questioned cost are discussed below. The findings are numbered with the number assigned in the schedule. FINDING - FEDERAL AWARD PROGRAMS AUDITS U.S. Department Labor (pass through from the Oregon Higher Education Coordinating Commission) 2025-001 WIOA Cluster – Assistance Listing #17.258, 17.259, 17.278 Recommendation: The Organization should establish written policies and procedures regarding monitoring of the maximum earmark percentage allowed. Explanation of disagreement with audit findings: There is no disagreement with the audit finding. Action taken in response to finding: Fiscal management promptly developed a report to monitor WIOA administrative expenditures to ensure compliance with applicable earmarking requirements. It was recently used to confirm compliance during the quarterly FSR reporting cycle. Fiscal management has also incorporated the review of this report into the monthly close process. Action Plan: Fiscal management is currently reviewing and updating existing process documentation, calculation templates, and journal entry import procedures related to cost pool allocations to WIOA funds. These procedures will be revised as necessary and will incorporate the validation report and related control activities. Upon completion, fiscal staff will be retrained on the updated procedures to ensure consistent application and understanding. In addition, fiscal management will perform a review of current program year allocations to WIOA funds to confirm continued compliance with administrative cost limitations. Name(s) of the contact people responsible for correction action: Andrew L Fitch, CFO afitch@worksystems.org 503-478-7357. Plan completion date for corrective action plan: 03/31/2026
During our fiscal year 2025 – the City began requiring vendors to complete and submit a certification form regarding debarment and suspension if funding for the contract or purchase order involved Federal funds. This certification form requires the vendor to certify that they are not debarred, suspe...
During our fiscal year 2025 – the City began requiring vendors to complete and submit a certification form regarding debarment and suspension if funding for the contract or purchase order involved Federal funds. This certification form requires the vendor to certify that they are not debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. The certification form is to be submitted prior to the City issuing contracts and purchase orders. We will review and adjust our internal review processes to ensure the form is submitted and not missed as part of our contract and purchase order issuing process. We will also review open purchase orders that were issued prior to fiscal year 2025 to obtain the debarment and suspension certification from the vendors.
Finding No. 2025-001 – Subrecipient Monitoring – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: UWNYC will implement a formal annual subrecipient audit verification procedure to ensure compliance with 2 CFR 200.332(g). Staff will annually determine and document whet...
Finding No. 2025-001 – Subrecipient Monitoring – Compliance and Internal Control (Significant Deficiency) Corrective Action Plan: UWNYC will implement a formal annual subrecipient audit verification procedure to ensure compliance with 2 CFR 200.332(g). Staff will annually determine and document whether each subrecipient is subject to Single Audit requirements under 2 CFR Part 200, Subpart F. For subrecipients subject to these requirements, staff will obtain and review the final Single Audit report, document the review, and consider any identified audit findings as part of the subrecipient risk assessment to inform the level and nature of ongoing monitoring. These procedures will be documented and incorporated into UWNYC’s subrecipient monitoring internal controls. Anticipated Completion Date: Initial review by September 30, 2026 Person(s) Responsible for Corrective Action: Eichakeem McClary, Chief Legal Officer (212.251.4093) Tanisha McKnight, Chief Operations Officer (212.251.4010)
Contact Person Tonya Hunskor Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2026.
Contact Person Tonya Hunskor Planned Corrective Action The Cooperative will ensure proper subrecipient monitoring is implemented. Planned Completion Date June 30, 2026.
We agree with the finding. In the future, the appropriate language will be included in subaward documentation.
We agree with the finding. In the future, the appropriate language will be included in subaward documentation.
The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Repeat Finding No Action Taken Management has implemented enhanced internal controls to ensure sliding fee discounts are accuratel...
The Center should establish a system of internal controls to ensure that all sliding fee discounts are properly calculated and supported based on family size and income. Repeat Finding No Action Taken Management has implemented enhanced internal controls to ensure sliding fee discounts are accurately calculated and fully supported. The Center standardized income verification procedures, reinforced documentation requirements for family size and income, and updated its sliding fee eligibility checklist to ensure consistency. Supervisory review protocols were established to verify proper calculation and supporting documentation prior to approval. Additionally, staff received refresher training on sliding fee policy requirements to promote ongoing compliance. Management will conduct periodic internal audits to monitor adherence and ensure continued effectiveness of these controls. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Sean Murphy, CFO at 860-610-6387.
Finding: 2025-001 Condition Found: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Frackson Salak, CFO Planned Corrective Action: Christ Community Health Services will perform...
Finding: 2025-001 Condition Found: The Organization has not applied sliding fee discounts to patient charges consistent with its sliding fee discount program. Individual(s) Responsible for Corrective Action: Frackson Salak, CFO Planned Corrective Action: Christ Community Health Services will perform monthly audits on patients who receive a sliding fee discount. The monthly audits will include verifying the correct fee was applied based on documents received during the patients sliding fee enrollment. If any errors are found they will be immediately corrected. Anticipated Completion Date: 06/30/2026
Finding 2025-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and re...
Finding 2025-003 School Nutrition Program Meal Claims 1. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. 2. Actions Planned in Response to Finding The District has already begun evaluating current procedures for accurately monitoring, recording, and reporting the number and type of meals served. 3. Official Responsible Mr. Greg Johnson, Superintendent, is the official responsible for ensuring corrective action. 4. Planned Completion Date The planned completion date is June 30, 2026. 5. Plan to Monitor Completion The Board of Directors will be monitoring this Corrective Action Plan.
Finding 2025-001 – Education Stabilization – Special Tests and Provisions - Wage Rate Requirements Context: For all six vendors sampled, the School Corporation did not include the necessary clauses for the Davis-Bacon federal wage rate requirements in their contracts. For the two larger vendors repr...
Finding 2025-001 – Education Stabilization – Special Tests and Provisions - Wage Rate Requirements Context: For all six vendors sampled, the School Corporation did not include the necessary clauses for the Davis-Bacon federal wage rate requirements in their contracts. For the two larger vendors representing $3,611,973, weekly payroll reports were properly collected. For the remaining four smaller vendors, the School Corporation did not obtain the weekly payroll report certifications for the work performed totaling $148,522 for the entire audit period. Contact Person Responsible for Corrective Action: Katy Dowling Contact Phone Number: 317-869-4364 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Create an internal control process that ensures roles and responsibilities as it relates to the requirements of the David Bacon Act. Anticipated Completion Date: March 15, 2026
Corrective Action: The College will implement a revised withdrawal process that shifts outreach and financial aid counseling to occur before a student completes and submits the withdrawal form, rather than after submission. This change is designed to eliminate delays in withdrawal processing and sup...
Corrective Action: The College will implement a revised withdrawal process that shifts outreach and financial aid counseling to occur before a student completes and submits the withdrawal form, rather than after submission. This change is designed to eliminate delays in withdrawal processing and support timely institutional action. Under the current process, outreach to students occurred after the withdrawal form was submitted, which resulted in delays in routing the form to the Records Office for processing. The revised process will require that outreach and financial aid counseling occur before students complete the withdrawal form. Students who indicate they are receiving financial aid will be encouraged to consult with the Financial Aid Office prior to completing the withdrawal form. During this consultation, students will be informed of the financial implications of withdrawing and be made aware of available institutional resources and services that may assist them in remaining enrolled, when appropriate. The revised withdrawal form will allow students to complete and submit it online directly to the Records Office for immediate processing. Eliminating post-submission outreach requirements will remove prior delays and allow the Records Office to promptly process the withdrawal. Receipt of the completed withdrawal form will serve as the institution’s date of determination. Following submission, the Financial Aid Office will complete the Return to Title IV (R2T4) calculation within the required 45-day timeframe and return any required funds. Timely processing of withdrawals will ensure continued compliance with all R2T4 regulatory requirements. Anticipated Completion Date: The College will implement this revised withdrawal process immediately (March 2026). Responsible Party: Breshawn Skinner, Director of Financial Aid, in coordination with the Records Office
Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient admini...
Name of Responsible Individual: Shane Himes, Director of Financial Aid Corrective Action: The College acknowledges the exceptions identified related to the timeliness of Return of Title IV (R2T4) calculations and the return of unearned federal funds. The errors were the result of insufficient administrative oversight and internal controls over the withdrawal and R2T4 process. To address this finding, the College will strengthen internal controls and oversight to ensure compliance with federal regulations. The corrective actions include: • Implementing a documented secondary review process for all R2T4 calculations prior to finalization to ensure accuracy and compliance with regulatory requirements. • Enhancing procedures to ensure timely identification of withdrawn students and prompt initiation of the R2T4 calculation process. • Establishing standardized monitoring to ensure all required returns of Title IV funds are processed within the regulatory timeframe. • Developing and implementing a tracking system to monitor withdrawal dates, calculation completion, and return deadlines. • Providing additional training to Financial Aid staff on federal R2T4 regulations and institutional procedures. • Conducting periodic internal quality assurance reviews of R2T4 calculations and returned funds to ensure ongoing compliance. Anticipated Completion Date: May 31, 2026
The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing in...
The University had one R2T4 finding that resulted from a unique situation. The Financial Aid Office will conduct a detailed review of the process and incorporate this specific circumstance into its internal audit procedures. By strengthening internal controls within the R2T4 process and enhancing internal audit protocols, the University will further improve overall compliance in this area and maintain its high standard of regulatory compliance.
Finding 2025-003 Program: Grants to States for Medicaid Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of the subaward agreement, the University is required to submit comp...
Finding 2025-003 Program: Grants to States for Medicaid Assistance Listing No.: 93.778 Federal Agency: U.S. Department of Health and Human Services Award Year: FY 2024 – 2025 Compliance Requirement: Consistent with the requirements of the subaward agreement, the University is required to submit compliance reporting to the grantor annually beginning in the year the funds were received. University’s Response: The University was not provided with the required compliance reporting templates at the time the subaward was issued. As a result, the University was unable to submit the required reports during the applicable reporting period. The grantor did not request submission of the reports during this time. Upon becoming aware of the reporting requirement during the Single Audit process, the University requested the appropriate templates and reporting guidance from the grantor. The templates were subsequently provided, and the University is continuing to work with the grantor to ensure accurate completion and submission of the required compliance reporting. The University confirms that grant funds were used in accordance with the terms and allowable activities of the subaward agreement. Corrective Action Plan: The University will continue to seek clarification and guidance from the grantor regarding required compliance reporting and the appropriate format for submission. If sufficient guidance is not provided, the University will submit the required compliance reporting to the best of its ability based on available information, understanding that the submission may be subject to review or revision by the grantor. No additional corrective action is planned at this time. The University will continue to work with the grantor to address reporting requirements as information becomes available. Name of the responsible person: Brian Shollenberger, Vice President for Financial Affairs and University Development Anticipated completion date: May 31, 2026
The Institution implements a formal validation and review process for all Quarterly Progress Reports. As part of this corrective action: • Copies of all checks and/or disbursements included in the report will be attached to each Quarterly Progress Report. • All reported expenditures will be verified...
The Institution implements a formal validation and review process for all Quarterly Progress Reports. As part of this corrective action: • Copies of all checks and/or disbursements included in the report will be attached to each Quarterly Progress Report. • All reported expenditures will be verified against the Institution’s accounting system. • Each Quarterly Progress Report will be reviewed, verified, and certified by the President of the Institution or the Compliance Officer prior to submission to COR3/FEMA. Implementation Plan: • Develop and formalize a written procedure for the preparation, validation, and review of Quarterly Progress Reports. • Designate a responsible official to perform an independent review of the report. • Require supporting documentation, including copies of checks and accounting system reports, as mandatory attachments. • Obtain written certification and signature from the President or Compliance Officer prior to submission. IMPLEMENTATION DATE Immediately RESPONSIBLE PERSON Compliance Officer President of the Institution
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