Corrective Action Plans

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Management implemented corrective actions to strengthen internal controls over the Data Collection Form submission process, including assigning responsibility to a designated individual and monitoring submission deadlines to ensure timely filing in future periods. Name of contact person responsible ...
Management implemented corrective actions to strengthen internal controls over the Data Collection Form submission process, including assigning responsibility to a designated individual and monitoring submission deadlines to ensure timely filing in future periods. Name of contact person responsible for corrective action plan: Renee Moynagh, Chief Financial Officer. Current Status: The finding has been corrected effective December, 2025.
Management acknowledges the missing internal control over the late submission of the updated financial model/plan for the fiscal year end June 30, 2024. Management has maintained an effective internal control tool for many years in the form of a master spreadsheet called the Annual Task Calendar tha...
Management acknowledges the missing internal control over the late submission of the updated financial model/plan for the fiscal year end June 30, 2024. Management has maintained an effective internal control tool for many years in the form of a master spreadsheet called the Annual Task Calendar that the entire Finance staff reviews at every biweekly Finance meeting, but the WIFIA deadlines were errantly not incorporated into that tool until January 2026. While management agrees with the finding, it should be noted that management was not operating without controls. Rather, the deadline being adhered to was just the wrong date. Management submitted updated financial model/plan by January 31, 2025, which was within the month following the close of the calendar year, similarly to the quarterly construction reports that are due 30 days after the end of the preceding quarter. In addition, the data on the annual model reflected current information near the time of release of the report, not June 30, 2024. So, in substance, management provided an even more current, relevant document. Management acknowledges the additional finding language that the June 30, 2025 quarterly construction monitoring report was submitted on day 31 rather than day 30 following the close of the quarter. Finally, management acknowledges that the annual updated financial model/plan for June 30, 2025, will be submitted in January 2026 as the internal control, as mentioned above, was not corrected until January 2026, which will result in the same finding on the Single Audit for June 30, 2026. However, management believes that we have taken the appropriate measures required to avoid ongoing replication. Responsible Official: Matt Zook, Finance Director
The Organization has set up a system to review transfers of federal funding by the Senior Asset Manager and Chief Financial Officer prior to the transfer taking place to ensure it is within the compliance requirements of the grant
The Organization has set up a system to review transfers of federal funding by the Senior Asset Manager and Chief Financial Officer prior to the transfer taking place to ensure it is within the compliance requirements of the grant
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 and Nonmaterial Noncompliance – Child Support Non-Cooperatio...
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 and Nonmaterial Noncompliance – Child Support Non-Cooperation Finding 2025-008 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each sanction for noncooperation. Condition: a) There was one (1) instance out of two (2) sanctions tested where the required form to be sent was dated after the sanction start date. b) There was one (1) instance out of two (2) sanctions tested where the sanction was not properly documented. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: When required sanction notifications are not issued prior to the sanction start date and sanctions are not properly documented, there is an increased risk that clients may not be properly informed of program actions and that the County may not comply with program requirements. Cause: The County did not have adequate procedures in place to ensure that required sanction notifications were issued prior to the sanction start date and that all sanctions were properly documented in accordance with program requirements. Recommendation: The County should implement procedures to ensure all required sanction notifications are issued prior to the sanction start date and that sanctions are properly documented in accordance with program requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this, which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: Collaborate with Child Support Services to improve understanding of their processes and ensure accurate case handling. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist), Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training and Development Manager), Scott Fritz (Social Services Manager), Program Supervisors Training: Non-Cooperation Sanction Training Anticipated Completion Date: To be completed quarterly. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist). Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training and Development) Anticipated Completion Date: Completed by January 2026.
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 Material Weakness and Nonmaterial Noncompliance – Eligibility and Special Tests: In...
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 Material Weakness and Nonmaterial Noncompliance – Eligibility and Special Tests: Income Eligibility and Verification System Finding 2025-007 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination, and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) An OVS inquiry must be completed and agreed to information reported in NC FAST. b) For the month of application, Work First cash assistance payments are prorated from the date of application, with the date of application being day one. c) All Work First applicants must provide a Social Security number or apply for a Social Security number if they do not have one. d) Parents and step-parents who apply for children must be included in the case with the child, unless they are otherwise ineligible. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 25 program participants selected for testing a) There were two instances where the OVS query was not run at the time of the determination. b) There was one instance where a hearing extension was incorrectly prorated. c) There was one instance where the social security number was not verified. d) There was one instance where kinship was not documented. Lastly, the following are the results of 60 program participants tested for control testing: a) There were three instances where the County did not remediate the errors identified within their internal review timely. b) There was one instance where a participant received benefits for one month where they should not have. c) There was one instance where incorrect forms were sent to a participant. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: The Economic Services Division (ESD) Quality and Training Specialist will conduct a 25% sample review of all ongoing cases. Errors identified during these reviews will be documented and communicated to both the Social Services Supervisor and the assigned Eligibility Specialist for correction within a defined timeframe. Failure to comply with correction timelines will result in corrective action. Case Review and Error Notification • ESD Sr. Quality and Training Specialist will review 25% of all ongoing cases. • Errors will be documented on checking sheets and emailed to both the supervisor and the assigned Eligibility Specialist. • Corrections must be completed within 5 business days of notification. Corrective Action • If corrections are not completed within the extended timeframe: o Corrective Action will be initiated in accordance with departmental performance management protocols. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist), Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training & Development Manager), Scott Fritz (Social Services Manager), Program Supervisors Anticipated Completion Date: To be completed monthly. Training: Training Completion Required for the Following Quality Review Errors: • Ensure the OVS inquiry is completed, and that the information aligns with data reported in NC FAST. • Understand that Work First cash assistance payments are prorated from the application date, which is considered Day One. • Confirm that all Work First applicants must provide a valid Social Security number or apply for one if not already obtained. • Review and apply the rules of kinship, specifically regarding parents and stepparents. Additionally, train supervisors and eligibility specialists on the importance of timely resolution of quality sampling errors and how delays can impact audit outcomes. Responsible Individuals: Sr. Quality & Training Specialists, Quality & Training Supervisor, Training & Development Manager. Anticipated Completion Date: An email will be sent by the Staff Development Unit to the Eligibility Specialist with errors by January 2026, and in-person training will be completed by February 2026.
Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Eligibility Finding 2025-005 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective...
Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Eligibility Finding 2025-005 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Questioned Costs: None Effect: Failure to promptly remediate errors identified during internal review increases the risk that program participants may receive benefits or incur costs that do not comply with program requirements, potentially resulting in noncompliance and questioned costs. Cause: The County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: The WIC Sr. Quality and Training Specialist conducts quarterly monitoring by observing staff and completed random chart reviews. However, due to retrospective nature of audits significant time elapses between the occurrence of the error and its identification. Late corrections in the crossroads system will compromise data integrity and disrupt some of the certification processes in crossroads. Crossroads also lacks the ability to alert supervisors of missing documentation which in turn creates a huge administrative burden to monitor missing documentation in real time. WIC program leadership will create a policy that will address documentation standards. WIC staff will be instructed not to alter the original entry, instead a correction addendum will be documented to acknowledge missing data. WIC program will continue to provide policy refreshers every quarter to address these findings and provide staff updated information. WIC supervisors will review the quarterly audits results with their staff and ensure staff follow the standards set by the department leadership. The following the phases of the corrective action plan will be completed by March 31st, 2026. Phase 1: Review of Federal and State Guidelines Phase 2: Creation of Document Standard Policy Phase 3: Implementation of new documentation standards policy. Anticipated Completion Date: March 31st, 2026 Responsible Person(s): Ali Raza, WIC Director
U.S. Department of Agriculture Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Procurement Finding 2025-004 Criteria: Pe...
U.S. Department of Agriculture Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Procurement Finding 2025-004 Criteria: Per Section 200.318 of the Uniform Grant Guidance, a non-federal entity must use documented procurement procedures for the acquisition of services required under a federal or State award. Condition: The County did not properly follow the Uniform Grant Guidance procurement standards for contracted services tested. Specifically: a) There was one (1) contract out of two (2) contracts tested where the County did not retain proper documentation of the original bid process for a contract that was extended into the current year. b) There was one (1) instance out of two (2) contracts tested where the documentation of the rationale for utilizing a State contract was not properly documented. Questioned Costs: None. Effect: By not having the required documentation and rationalization in the files, the County could have improperly contracted with a vendor that was not considered eligible to be paid with grant proceeds. Cause: The County did not ensure all contracts utilized for the grant were properly documented using procurement requirements in accordance with the Uniform Grant Guidance procurement standards. Recommendation: The County should consider utilizing the Uniform Grant Guidance procurement standards for all County contracts to ensure proper documentation for contracts are maintained in the file. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: The County’s procurement policy generally mirrors the Uniform Grant Guidance and procedures have been implemented to provide additional review of new agreements prior to execution to ensure that proper steps were followed in the selection process. In addition, the importance of comprehensive documentation retention in the areas noted above have been communicated to staff and a review of same will be included in the added review process. Anticipated Completion Date: December 31, 2025 Responsible Person: Teresa Rausch, Procurement Director
Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Allowable Costs/Costs Principles Repeat Finding 2025-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must esta...
Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Allowable Costs/Costs Principles Repeat Finding 2025-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There were 3 out of 40 samples tested where clear and consistent documentation of a control over allowable costs and activities was not present. Effect: Without consistent documentation and adherence to departmental policy for approving allowable costs, there is an increased risk that unallowable expenditures may be charged to the program, potentially resulting in noncompliance with federal requirements and questioned costs. Questioned Costs: None. Cause: The departmental policy to approve expenditure documents as an allowable cost for the program was not followed. Recommendation: The County should consistently follow departmental policy by ensuring all expenditure documents for the program are properly reviewed and approved as allowable costs before being approved for payment and maintain clear documentation of controls over program activities to support compliance with federal requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Correction Action Plan: Program leadership will collaborate with the County Finance Team to ensure departmental policy is followed when purchases are made using WIC Federal funds. Internal purchase approval documents will be created to enhance the approval workflow. All purchases will be submitted to the WIC Program Director for approval. The program Director and the Sr. Admin Assistant will review the orders and ensure they are allowable items per the NC State WIC program guidelines. A shared folder will be created to save the purchase order forms, and the invoices to ensure Mecklenburg County Health Department Policy A-13, Retention of Administrative Documents is followed. The following the phases of the corrective action plan will be completed by March 1st, 2026. Phase 1: Review of Federal and State Guidelines Phase 2: Mecklenburg County Procurement Policy Review Phase 3: Creation and Implementation of new internal purchase approval processes. Phase 4: Staff Training Anticipated Completion Date: March 1st, 2026 Responsible Person(s): Ali Raza, WIC Director
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 U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health an...
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 U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Children's Health Insurance Program Federal Assistance Listing Number: 93.767 Material Weakness and Nonmaterial Noncompliance - Eligibility Finding 2025-002 - Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination, and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) Self-attestation wages should be compared to information in NC FAST. b) All countable resources should be confirmed and recalculated and ensure they are computed accurately in NC FAST. c) The caseworker should prepare and submit a DMA-5097 form in the case of incompatible income verification and self-attestation income as described in the Eligibility Review Document. d) Citizenship should be documented within NCFAST. e) Household information should be entered correctly into NCFAST. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 124 program participants selected for testing: a) There were six instances where the participants self-attest wages did not agree to the wages entered into NC FAST. b) There was one instance where the countable resources were inaccurate within NC FAST. c) There were five instances where the income was incompatible between the income verification and self-attestation income but no DMA-5097 was sent. d) There was one instance where the participant's citizenship was not documented in NCFAST. e) There was one instance where the participant's household size was entered incorrectly into NCFAST. Lastly, there were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Context: There were 8 out of 124 unique participants tested with the errors noted above. Questioned Costs: We noted no federal questioned costs for the County as the State of North Carolina makes all benefit payments to participants directly. Due to split eligibility determinations between the Counties and the State of North Carolina for Medicaid, we found $25,105 in benefit payments made by the State of North Carolina to ineligible participants based on an improper eligibility determinations at the County related to three individuals in item "a" above. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: The County has identified specific opportunities to strengthen accuracy and consistency in eligibility case documentation. While overall performance has improved, with total errors reduced from 14 the prior audit period to 8 in the current period, continued focus is necessary to further reduce errors and sustain compliance across case files. The Economic Services Division Strategies are as follows: • Social Services Supervisors will conduct targeted reviews of identified error trends, emphasizing policy application, documentation completeness, and process standardization to ensure consistent eligibility determinations across the program. • The Economic Services Division's Staff Development Unit will continue to quality sample cases to promote accuracy and accountability. • Social Service Supervisors, in coordination with Medicaid Social Services Managers will coach staff based on audit findings, monitor trends and ensure required corrections are completed within 5 business days of notification. • Failure to complete corrections within the approved timeframe will result in corrective action to both the Social Services Supervisor and the assigned Eligibility Specialist in accordance with departmental performance management protocols. • Supervisory staff will ensure all updates to the Quality Sampling Tracking Log are finalized no later than the 20th calendar day of the subsequent month to support timely monitoring, trend analysis, and corrective action. These actions are designed to strengthen internal controls, support staff performance and maintain compliance with applicable state and federal requirements. Responsible lndividual(s): Kim Konior, Lynn Martin (Medicaid Program Managers), Staphon Snelling (Training and Development Manager), Danisa Concepion, Donnie Munson (Quality and Training Supervisors), and Social Services Medicaid Supervisors. Anticipated Completion Date: Ongoing Training: The Economic Services Division's Staff Development Unit will review the Single Audit findings and develop targeted training for staff responsible for determining Medicaid eligibility, as well as their supervisors and managers. This training will specifically address the errors identified in the audit and will be delivered by the end of March 2026. In addition, Staff Development will provide quarterly training to Medicaid eligibility staff, supervisors, and managers based on error trends identified through quality sampling conducted by the unit. To ensure effectiveness, a structured training approach will be used: • A pre-test will assess staffs current understanding of relevant policies. • The County will deliver targeted training materials tailored to address identified gaps. • A post-test will be developed, with a minimum passing score of 90%. This approach will allow the County to: • Measure knowledge gained through the training • Track training completion, identify staff who have or have not completed the training • Ensure consistent understanding and application of policy across the team Staff who do not achieve the required score will receive additional refresher training to reinforce key concepts and ensure compliance. Responsible lndividual(s): Staphon Snelling (Training and Development Manager), Danisa Concepion, and Donnie Munson (Quality and Training Supervisors), and Sr. Quality and Training Specialists (Medicaid). Anticipated Completion Date: March 31, 2026
2025-003 Distance Learning and Telemedicine – ALN No. 10.855 Compliance: Name of contact person – Brandon Studer, Business Manager Recommendation: We recommend management contact the Grantor to determine necessary actions in response to the excessive interest earned on federal funds, including the p...
2025-003 Distance Learning and Telemedicine – ALN No. 10.855 Compliance: Name of contact person – Brandon Studer, Business Manager Recommendation: We recommend management contact the Grantor to determine necessary actions in response to the excessive interest earned on federal funds, including the potential return of earnings to the grant agency. Action Taken: Management agrees with the recommendation and will contact the Rural Utilities Service to determine whether excess interest earned on the funds is due back to the agency. Proposed Completion Date: March 31, 2026
Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.007, 84.033 Recommendation: Recommend that the College design and implement controls to ensure that all safeguards for identified risks required by the Gramm-Leach-Bliley Act (GLBA) are fully documented and updated as necessary. Expla...
Student Financial Aid Cluster – Assistance Listing No. 84.063, 84.007, 84.033 Recommendation: Recommend that the College design and implement controls to ensure that all safeguards for identified risks required by the Gramm-Leach-Bliley Act (GLBA) are fully documented and updated as necessary. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Moraine Park Technical College will take or has already taken the following actions to address the audit finding: 1. Updated existing policies and documentation to fully reflect the controls in place to safeguard identified risks under the Gramm-Leach-Bliley Act. 2. Revised and formalized the following documents to ensure they clearly describe current practices and continuous monitoring activities: • Incident Response document • Risk Assessment document • Written Information Security Plan • IT Vulnerability Management Practices document These updates ensure that all existing controls and processes are fully documented, current, and aligned with GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Larry Plamann, Director of Enterprise Infrastructure Planned completion date for corrective action plan: January 2026
Condition: The Village did not have adequate controls in place to exercise its oversight responsibility of adherence to wage rate requirements that were reviewed by a contractor for the program. The Village also did not have controls in place to exercise oversight over the same contractor's review o...
Condition: The Village did not have adequate controls in place to exercise its oversight responsibility of adherence to wage rate requirements that were reviewed by a contractor for the program. The Village also did not have controls in place to exercise oversight over the same contractor's review of general and subcontractors for suspension and debarment. Planned Corrective Action: The Village has implemented updated procedures as recommended by the auditors. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2025
Finding Summary: The County did not have adequate controls to ensure Special Tests and Provisions requirements were met. The critical information reported did not have the required “Description of Work Performed” included on the reports. Corrective Action Plan: Eureka County will fill in all boxes o...
Finding Summary: The County did not have adequate controls to ensure Special Tests and Provisions requirements were met. The critical information reported did not have the required “Description of Work Performed” included on the reports. Corrective Action Plan: Eureka County will fill in all boxes on the grant report when being submitted to the Nevada Division of Emergency Management. Responsible Individual: Jayme Halpin, Assistant Public Works Director Anticipated Completion Date: Eureka County will amend the past quarterly reports and any future quarterly reports to reflect actual work performed on the report. This will be completed by January 29, 2026.
Completion of Oustanding Reports: All required SF-425 reports for continuing Early Head Start grants have been completed. Policy and Procedure Enhancements: DPFC has updated its financial policies and procedures to formally document federal reporting responsibilities, required timelines, and interna...
Completion of Oustanding Reports: All required SF-425 reports for continuing Early Head Start grants have been completed. Policy and Procedure Enhancements: DPFC has updated its financial policies and procedures to formally document federal reporting responsibilities, required timelines, and internal review protocols. Enhanced Monitoring and Oversight: A standardized monthly compliance claendar has been implemented and is actively monitored by the CFO to ensure upcoming reporting deadlines are identified and met.
Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate con...
Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate controls in place to ensure that credit balances were refunded in a timely manner within the 14-calendar-day requirement. Management has implemented a process to ensure that credit balances are processed within the 14-calendar-day requirement. A workflow hierarchy is in place to ensure adequate staffing and training, preventing processing delays. Any deviations from the normal processing of credit balances will be sent to the relevant department immediately for further action. Anticipated completion date: December 2025
2025-002 - Child and Adult Care Food Program - Subrecipient Monitoring Condition Five providers were found not to have met the review frequency and type requirements. Recommendation We recommend that new staff members undergo both internal and external training relevant to their position, wherever p...
2025-002 - Child and Adult Care Food Program - Subrecipient Monitoring Condition Five providers were found not to have met the review frequency and type requirements. Recommendation We recommend that new staff members undergo both internal and external training relevant to their position, wherever possible. Additionally, we recommend that the Center review its policies and procedures to ensure that compliance requirements are clearly documented and communicated to all relevant staff. Comments on the Finding Recommendation The CACFP at The Russell Child Development Center, acknowledges its recommendation and agrees with the importance of ensuring that staff receive adequate training and that policies and procedures clearly outline compliance requirements. RCDC recognizes that thorough training and clear documentation are essential to maintaining program integrity and supporting staff in carrying out their responsibilities effectively. Action Taken: As of October 31 , 2025, The Russell Child Development Center, has ceased participation in the Child and Adult Care Food Program. During the final grant award year, CACFP staff participated in available internal and external training courses relevant to their roles, including state-provided guidance and technical assistance when available. Program policies and procedures were reviewed to ensure compliance requirements were documented and communicated to staff to the extent applicable during program close-out. All CACFP-related training documentation, policies, and records from the final grant award year will be retained for the required record-keeping timeframe in accordance with federal and state regulations.
Finding 2025.003 - Subrecipient Monitoring - Material Weakness Recommendation We recommend that management review the Uniform Guidance requirements for subrecipient monitoring and update its policies and procedures as appropriate. We recommend that CLC develop and implement a standardized checklist ...
Finding 2025.003 - Subrecipient Monitoring - Material Weakness Recommendation We recommend that management review the Uniform Guidance requirements for subrecipient monitoring and update its policies and procedures as appropriate. We recommend that CLC develop and implement a standardized checklist outlining all required subrecipient monitoring compliance requirements. The checklist should clearly identify the individual responsible for monitoring and the individual responsible for review, and supporting documentation should be retained to evidence that monitoring requirements have been performed. Planned Corrective Action: Management concurs with the finding and will enhance its subrecipient monitoring process. Corrective actions include: • Update the Financial Policies and Procedures Manual and subaward agreement templates to conform to current Uniform Guidance requirements, including all required subaward data elements (such as Assistance Listing Number, UEI, award identification, and applicable compliance requirements). • Develop and implement a standardized subrecipient monitoring checklist that includes (a) pre-award risk assessment, (b) ongoing monitoring of invoices and programmatic reports, (c) verification of allowable costs, (d) confirmation and review of subrecipient audit requirements and Uniform Guidance reports, as applicable, and (e) documented management review. • Ensure required FFATA subaward reporting is completed timely when applicable, and maintain documentation supporting all monitoring activities. Name of Contact Person: Neil Shah, Interim CFO, neilshah@clcstamford.org Anticipated Completion Date: May 31, 2026 If there are any questions regarding this plan, please contact Neil Shah at neilshah@clcstamford.org.
Finding 2025.002 - Reporting - Material Weakness Recommendation We recommend that management establish and formally document comprehensive policies and procedures for the reporting process. These policies and procedures should clearly outline all required reports, filing timelines, and the method fo...
Finding 2025.002 - Reporting - Material Weakness Recommendation We recommend that management establish and formally document comprehensive policies and procedures for the reporting process. These policies and procedures should clearly outline all required reports, filing timelines, and the method for maintaining supporting documentation. We recommend that CLC develop and implement a standardized checklist outlining all required grant compliance requirements. The checklist should clearly identify the individual responsible for preparation and the individual responsible for review. Additionally, both the preparer and reviewer should document their completion of the review to provide evidence that compliance requirements have been appropriately verified. Planned Corrective Action: Management concurs with the finding and will strengthen controls over federal reporting for the Head Start Cluster. Corrective actions include: • Establish and document a grant reporting calendar and compliance checklist covering all required submissions (including SF-425 and FFATA subaward reporting, as applicable), due dates, and responsible parties. • Require all reports to be supported by underlying accounting records and retained with supporting schedules in a centralized repository. • Implement documented preparer and independent reviewer sign-off prior to submission; the reviewer will verify tie-outs to the general ledger and supporting documentation. • Provide training and cross-training to ensure continuity of compliance responsibilities during personnel changes. Name of Contact Person: Neil Shah, Interim CFO, neilshah@clcstamford.org Anticipated Completion Date: March 31, 2026
SECTION 5 – CORRECTIVE ACTION PLAN Finding 2025 – 001: Grant Administration Condition: During our current audit fieldwork, we noted that the Organization does not have adequate procedures in place for tracking and monitoring grant activities. Each grant has unique reporting and compliance requiremen...
SECTION 5 – CORRECTIVE ACTION PLAN Finding 2025 – 001: Grant Administration Condition: During our current audit fieldwork, we noted that the Organization does not have adequate procedures in place for tracking and monitoring grant activities. Each grant has unique reporting and compliance requirements, which is handled inconsistently among the Organization’s departments. Plan: The Executive Director, along with staff, will create better policies and procedures around the tracking and monitoring of grant funding throughout the year. Anticipated Date of Completion: Fiscal Year 2026 Name of Contact Person: Sonia Ivanov, Executive Director Management Response: Northwest Compass Inc is currently in the process of formally putting inn writing the policies and procedures we are currently following in this regard. We anticipate having this completed in the current fiscal year.
Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed ...
Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed subgrant agreements to confirm that the correct Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) appear in the agreement. • This review will exclude Interagency Agreements with City agencies since they are not considered subrecipients, but as the prime recipient, the City of Baltimore. • This review will also exclude any agreements related to projects classified under Expenditure Category (EC) 6.1 in ARPA SLFRF guidance. According to Frequently Asked Questions (FAQs) issued by the U.S. Department of Treasury, this EC does not give rise to a subrecipient relationship, therefore UEI information is not required. • For any subgrant agreements with an incorrect or missing UEI or FAIN, the Recovery Office will submit a single memorandum that presents correct UEIs and FAIN to the Board of Estimates (BOE) to ensure that the official record has correct UEI and FAIN information. We believe there is a direct conflict between Treasury guidance and 2 CFR 200 regarding the requirement for active SAM.gov registration. Treasury does not require subrecipients to maintain an active SAM.gov registration and instead permits the use of alternative screening questions in lieu of an active registration. Treasury does not collect individualized subrecipient data for subawards at or below $50,000. Each of these three awards are at or below that threshold, therefore the SAM.gov information, including the subrecipient UEI, registration, or the alternative screening questions, were not collected. The total amount of funding for the three identified subrecipients combined is $100,000. The Recovery Office will require that all subrecipients fully register in SAM.gov. The Recovery Office will require that agencies provide a 30-day window to allow all subrecipients to fully register or funds will be withheld until the subrecipient can fully register to demonstrate the organization is not suspended or debarred. In those cases where the Recovery Office is unable to withhold disbursements for noncompliant subrecipients, the Recovery Office will issue a Corrective Action Plan or issue a finding in the subrecipient's closeout letter. For any grants that expired, if payments occurred outside the period of performance, and did not have written justification for and approval of an extension to the allowable closeout period, the Recovery Office will require that the agency to take the agreement back to the Board of Estimates for a retroactive extension. In certain cases, such as when extended monitoring or implementation of corrective action items go beyond the period of performance, a payment may be made outside of the allowable closeout period. According to 2 CFR 200.344c, "The recipient must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must liquidate all financial obligations incurred under a subaward no later than 90 calendar days after the conclusion of the period of performance of the subaward (or an earlier date as agreed upon by the pass-through entity and subrecipient). When justified, the Federal agency or pass-through entity may approve extensions for the recipient or subrecipient." In these cases, the Recovery Office will assure there is written justification for the extension on liquidating all financial obligations. Contact Person: Elizabeth Tatum, Director Completion Date: June 30, 2026
Finding 2025-020 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: In FY 2025 BCHD dev...
Finding 2025-020 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheet, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. • Prioritize meetings with programs that have not conducted monitoring in the prior fiscal year to strategize and to ensure monitoring occurs in FY 2026. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026
Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025...
Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026
Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an inte...
Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts unit. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheet, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026
Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed...
Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Subrecipient vs. Contractor determination checklist that are required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Created fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: June 30, 2026
Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengt...
Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengthen internal controls, MOED will establish separate grant worktags for all parts of the grant award to ensure the grant reference number is unique within the Workday award setup. UEI Subaward Validation: As a corrective action, Contracts Specialist training has been updated to require verification and documentation of the sub-recipient’s Unique Entity Identifier (UEI) through SAM.Gov as part of the subaward setup process. MOED will require grant staff to familiarize themselves with Administrative Manual policy 413- 21 Federal Grant Registration and Unique Entity Identifier, which requires UEI verification and identification in the City’s financial system of record for all subrecipients. Subrecipient Monitoring: MOED does maintain a standardized sub-recipient monitoring checklist designed to ensure subawards are administered in compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward as well as relevant supporting documentation. FY2025 subrecipient monitoring was not scheduled in accordance with the monitoring timeframes outlined in the terms and conditions of the grant award. Management acknowledges this oversight and will ensure that all subrecipient monitoring is scheduled and conducted timely in accordance with the monitoring timeframes outlined in the award. Review of Subrecipient Single Audit Report: MOED performs a review of subrecipient Single Audit reports during the technical proposal evaluation and confirms the subrecipient’s inclusion on the State of Maryland’s Eligible Training Provider List (ETPL). Due to document volume size, this documentation has not historically been included in BOE-approved subrecipient agreements or retained within Workday award files. As a corrective action, MOED will formally incorporate ETPL verification into subrecipient agreements. Single Audit reports will be retained separately from the BOE approval package and uploaded to the applicable Grant Award record in Workday to ensure consistent documentation and accessibility. MOED will utilize the GMO’s subrecipient monitoring templates provided on the centralized SharePoint Grants Management platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reports are completed. Additionally, MOED will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOED will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. MOED will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: September 30, 2026
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