Corrective Action Plans

Finding 1203104 (2024-001)

Material Weakness 2024

MA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Housing and Urban Development The Town of Oak Bluffs, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: CBIZ CPAs P.C....

CORRECTIVE ACTION PLAN Oversight Agency for Audit: U.S. Department of Housing and Urban Development The Town of Oak Bluffs, Massachusetts respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: CBIZ CPAs P.C. 53 State Street, 17th Floor Boston, MA 02109 Audit period: July 1, 2023 through June 30, 2024 The finding from the June 30, 2024, schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Financial Statement Finding 2024-001 – Document Policies and Procedures Over Federal Awards Condition: During our audit, we noted that the Town did not have formal policies and procedures in place covering the requirements of Uniform Guidance as specified in 2 CFR Part 200. Certain elements, such as procurement standards, subrecipient monitoring, internal control, and other compliance areas, were not addressed in written policies or documented procedures. Criteria: Uniform Guidance (2 CFR Part 200) requires non-federal entities administering federal awards to establish and maintain written policies and procedures to address all requirements specified in the regulations, including but not limited to internal controls, determination of allowable costs, procurement, subrecipient monitoring, financial management, and reporting. Cause: The Town has not developed comprehensive written policies and procedures to address all compliance requirements under Uniform Guidance. Effect: The absence of written policies and procedures increases the risk of noncompliance with federal requirements, reduces consistency in federal program administration, and limits transparency and accountability. Recommendation The Town should develop and implement comprehensive written policies and procedures that address all major compliance requirements under Uniform Guidance (2 CFR Part 200). Periodic review and updates should be performed to ensure ongoing compliance. Views of Responsible Officials: We have been reviewing existing workflows, and unwritten procedures, relative to our management and oversight of federal awards either received directly from the federal or from another intermediary pass-through agency. Once our review is complete, we will commit those procedures to writing and present them to the Select Boad for approval. The anticipation is that we will have documented policies and procedures, that are compliant with the Uniform Guidance, in time for the FY2026 audit.

View Audit 396313

Finding 1191627 (2024-002)

Material Weakness 2024

Hawkeye Properties and Workforce Innovation, Inc.

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Period of Performance § 200.300

Management has registered with Sam.gov and obtained a Unique Entity ID (UEI) for the submission of the single audit report for the fiscal year ended June 30, 2024. The UEI does not expire and is therefore addressed for future single audits.

View Audit 395484

Finding 1190773 (2024-001)

Material Weakness 2024

CASA/Youth Advocates Inc.

PA

Allowable Costs / Cost Principles Subrecipient Monitoring

Management Responses: We acknowledge that prior to this audit, CASA relied on summary-level expense reports from subrecipients under the PCCD grant and did not consistently verify underlying invoices. The established oversight also included the following efforts: 1) the individual previously respons...

Management Responses: We acknowledge that prior to this audit, CASA relied on summary-level expense reports from subrecipients under the PCCD grant and did not consistently verify underlying invoices. The established oversight also included the following efforts: 1) the individual previously responsible for invoicing did review submissions for reasonableness against the approved budget, 2) subrecipients were advised to maintain detailed back-up for all expenses, and 3) the Coalition Director regularly visited subrecipient sites to observe work being completed and to meet and observe personnel covered by the grant. However, we acknowledge this process did not meet the full requirements of the Uniform Guidance. While prior audits were not performed under Government Auditing Standards , management notes that the agency has received federal funding since 2016 with no history of previous management-related findings. The identified grant in this finding was a pilot project and the first time the agency has managed subrecipients. Corrective Actions Already Taken: CASA has engaged a new contracted accounting firm with a wider breadth of experience and expertise. CASA has completed an internal restructuring to provide increased opportunity for oversight and review of contracted financial services. CASA has adopted a new review protocol requiring verification of all supporting documentation for subrecipient reimbursements. The Operations Manager now performs a detailed review of invoices, approvals, and alignment with allowable costs prior to releasing funds. Planned Actions: Subrecipient Monitoring Policy: CASA will implement a policy immediately that includes: A standardized invoice review checklist (verifying vendor, date, amount, and allowability). Documentation of management approvals and sign-offs. Monitoring visits or virtual reviews for subrecipients by Coalition Director or Operations Director. Communication: CASA will issue written guidance to all subrecipients outlining documentation requirements and timelines.

View Audit 395075

Finding 1190761 (2024-001)

Material Weakness 2024

Scotland County Public Housing Agency

MO

Subrecipient Monitoring Reporting § 200.510

Scotland County’s response for issues found: 1. We will double check to make sure we didn’t miss something for the SEFA report. 2. We will update the 2024 SEFA for the corrected amounts. 3. The Highway Planning and Construction (MODOT Intermodal) included the railroad bridge that no one could tell u...

Scotland County’s response for issues found: 1. We will double check to make sure we didn’t miss something for the SEFA report. 2. We will update the 2024 SEFA for the corrected amounts. 3. The Highway Planning and Construction (MODOT Intermodal) included the railroad bridge that no one could tell us where the money was coming from. This accounted for $1,228,104.64. We will correct this on the SEFA. 4. The ARPA was the interest received in 2024. We didn’t receive any more money from the state in 2024. We will get this added to the SEFA. 5. The HAVA Election Security Grant was missed when we were putting them in the report. We will get this added to the SEFA.

View Audit 395040

Finding 1187296 (2024-002)

Material Weakness 2024

South Texas Development Council

TX

Subrecipient Monitoring § 200.332

Finding 2024-002 | Subrecipient Not Monitored — City of Laredo Across Three Programs Material Weakness in Internal Control over Compliance | Ryan White (93.917) | HOPWA (14.241) | State Services (HHS001317000004) | First-Time Finding Finding Number: 2024-002 Planned Completion Date: June 30, 2025 (r...

Finding 2024-002 | Subrecipient Not Monitored — City of Laredo Across Three Programs Material Weakness in Internal Control over Compliance | Ryan White (93.917) | HOPWA (14.241) | State Services (HHS001317000004) | First-Time Finding Finding Number: 2024-002 Planned Completion Date: June 30, 2025 (retroactive review and system implementation); ongoing thereafter Responsible Official(s): Josafat Saldivar, Finance Director (monitoring schedule and fiscal monitoring); Program Managers — Ryan White, State Services, HOPWA (programmatic coordination); Juan E. Rodriguez, Executive Director (oversight and quarterly review) Agency Response: STDC acknowledges the finding and recognizes the seriousness of the Material Weakness classification. During FY2024, STDC did not conduct the required annual monitoring of the City of Laredo under the Ryan White, State Services, or HOPWA programs. Combined subrecipient expenditures for the City of Laredo across these three programs totaled $1,162,418. STDC concurs that this constitutes a failure to meet the subrecipient monitoring requirements of 2 CFR 200.332 and the applicable contract terms for all three programs. Management acknowledges that the absence of a formal, documented annual monitoring schedule allowed this gap to go undetected. STDC notes that five of six Ryan White and State Services subrecipients and three of four HOPWA subrecipients were monitored during FY2024; the lapse was isolated to the City of Laredo across all three programs. STDC takes seriously its obligation to ensure all subrecipients are monitored on schedule and is committed to implementing a comprehensive corrective action that addresses both the immediate gap and the underlying control deficiency. STDC also notes that subrecipient monitoring policies and procedures were formally developed and adopted as part of the corrective action for Finding 2022-006. The recurrence of a monitoring gap in FY2024 underscores the need for a more structured scheduling and tracking mechanism to ensure those procedures are consistently applied across all programs and subrecipients each grant year. Corrective Actions to Be Implemented: Action 1 (Target: April 30, 2025): Retroactive Monitoring Review — Conduct a desk review of the City of Laredo's FY2024 subrecipient expenditures, financial reports, and compliance documentation under Ryan White (ALN 93.917), State Services (HHS001317000004), and HOPWA (ALN 14.241), using the standardized monitoring tools and checklists established under STDC's existing Subrecipient Monitoring Policy. Document results and retain findings in the City of Laredo subrecipient monitoring files. Action 2 (Target: April 30, 2025): Develop a formal, written Annual Subrecipient Monitoring Schedule at the start of each grant year, covering all active programs and all subrecipients. The schedule will identify: subrecipient name, program(s), subaward amount, assigned monitoring staff, planned monitoring method (desk review or on-site), and planned and actual completion dates. The schedule must be reviewed and approved by the Executive Director. Action 3 (Target: May 15, 2025): Implement a Monitoring Tracking Log consistent with STDC's existing Subrecipient Monitoring Policy to be updated on an ongoing basis and reviewed weekly. The log will track monitoring visit dates, report draft and distribution dates, and status of any corrective actions required of subrecipients. Action 4 (Target: May 31, 2025): Implement a quarterly monitoring progress report to the Executive Director identifying: (a) subrecipients scheduled for monitoring, (b) monitoring completed to date, (c) any past-due monitoring, and (d) findings or corrective actions arising from completed monitoring activities. Action 5 (Target: Ongoing, beginning FY2025): At the start of each grant year, cross-reference the Annual Subrecipient Monitoring Schedule against all active subaward agreements and update the schedule whenever a new subaward is executed or a new subrecipient is added to any program, to ensure no subrecipient is omitted from the monitoring plan. Action 6 (Target: June 30, 2025): Conduct refresher training for all finance and program staff responsible for subrecipient monitoring on the requirements of 2 CFR 200.332, STDC's Subrecipient Monitoring Policy, and the use of the updated annual monitoring schedule and tracking log. Monitoring and Evaluation: Quarterly monitoring progress reports will be submitted to the Executive Director to verify that all subrecipients are monitored according to the annual schedule. The Annual Subrecipient Monitoring Schedule and Monitoring Tracking Log will be maintained in the subrecipient compliance files and available for audit review. Compliance with the Subrecipient Monitoring Policy will be reviewed annually, and any deviations will be addressed through staff corrective action plans as appropriate.

View Audit 394928

Finding 1186590 (2024-002)

Material Weakness 2024

Camcare Health Corporation

NJ

Special Tests & Provisions Subrecipient Monitoring Eligibility

Finding Number 2024-002 Planned Corrective Action: CAMcare has implemented enhanced controls over the financial screening and sliding fee discount application process to ensure compliance with 42 CFR §56.303(g)(2). Prior to the application of any sliding fee discount, financial screening staff are n...

Finding Number 2024-002 Planned Corrective Action: CAMcare has implemented enhanced controls over the financial screening and sliding fee discount application process to ensure compliance with 42 CFR §56.303(g)(2). Prior to the application of any sliding fee discount, financial screening staff are now required to verify that the patient’s application rating (based on income and family size) aligns with the corresponding Federal Poverty Level (FPL) category and discount level configured within the Epic system. Discounts will not be applied unless this validation is completed. To address inconsistencies identified during the audit period, CAMcare has formalized procedures requiring that all updates to the sliding fee discount schedule, including changes to FPL thresholds or discount percentages, are communicated to registration, financial screening, and billing staff prior to implementation. Additionally, system-level updates within Epic must be validated by designated personnel to ensure that the updated fee schedule is accurately reflected before being used in patient billing. Supervisory review controls have also been strengthened. Financial screening supervisors will perform monthly spot checks of a defined sample of patient accounts to verify that sliding fee discounts have been applied correctly and are supported by complete and accurate patient application data. Any discrepancies identified will be documented, corrected, and escalated for follow-up training or process improvement as necessary. In addition, CAMcare will reinforce staff training on financial screening policies and procedures on a periodic basis and maintain documentation of completed training. Management will monitor compliance through ongoing supervisory review and periodic evaluation of screening and billing accuracy to ensure adherence to established policies. These corrective actions are designed to strengthen internal controls over financial screening and billing processes, ensure accurate application of sliding fee discounts, and reduce the risk of noncompliance in future reporting periods. Anticipated Completion Date: January 1st, 2025, with ongoing monthly monitoring and periodic training. Responsible Contact Persons: Eshan Singh, Vice President of Finance, Analytics & Technology

View Audit 394296

Finding 1182298 (2024-005)

Material Weakness 2024

The Order of Fishermen Ministry Head Start Program, Inc.

MI

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

TOFMHS concurs with the finding. The Agency filed both semi annual and annual financial reports for three grants during the fiscal year on a timely basis. The one semi-annual report was inadvertently filed late. However, upon notice by the Payment Management System of it being overdue, it was immedi...

TOFMHS concurs with the finding. The Agency filed both semi annual and annual financial reports for three grants during the fiscal year on a timely basis. The one semi-annual report was inadvertently filed late. However, upon notice by the Payment Management System of it being overdue, it was immediately filed. The Agency will prepare a checklist of required federal reports by the finance department, which will be monitored by the Program Director. Responsible Person: Fiscal Officer/Program Director Completion Date: January 1, 2025

View Audit 393724

Finding 1182297 (2024-004)

Material Weakness 2024

The Order of Fishermen Ministry Head Start Program, Inc.

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

TOFMHS concurs with the finding. There was turnover in the finance department, moving forward TOFMHS will implement adequate and sufficient internal controls to ensure that approvals charged to the grant are reviewed and approved by authorized members of TOFMHS. Responsible Person: Fiscal Officer/Pr...

TOFMHS concurs with the finding. There was turnover in the finance department, moving forward TOFMHS will implement adequate and sufficient internal controls to ensure that approvals charged to the grant are reviewed and approved by authorized members of TOFMHS. Responsible Person: Fiscal Officer/Program Director Completion Date: January 1, 2025

View Audit 393724

Finding 1182294 (2024-003)

Material Weakness 2024

The Order of Fishermen Ministry Head Start Program, Inc.

MI

Subrecipient Monitoring Material Weakness Reporting § 200.501 § 200.512 § 200.514

TOFMHS concurs with the finding. The agency retained new auditors for the June 30,2024 fiscal year, subsequent to the due date for submission of the data collection reports. Corrective Action to be Taken: The Agency will take all reasonable measures to work with the new auditors to complete the audi...

TOFMHS concurs with the finding. The agency retained new auditors for the June 30,2024 fiscal year, subsequent to the due date for submission of the data collection reports. Corrective Action to be Taken: The Agency will take all reasonable measures to work with the new auditors to complete the audit process and submit the data collection report within the required time period. Responsible Person: Fiscal Officer/Program Director Completion Date: January 1, 2025

View Audit 393724

Finding 1182144 (2024-002)

Material Weakness 2024

Lone Pine Unified School District

CA

Subrecipient Monitoring Reporting Significant Deficiency

Moving forward, the District will ensure that all supporting documents are retained for reporting elements related to grants. Additionally, the District will add additional review procedures for any reporting items related to grants.

View Audit 393507

Finding 1181788 (2024-004)

Material Weakness 2024

East Central Iowa Workforce Development Board

IA

Subrecipient Monitoring

Response and Corrective Action Planned – The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: Revision of its ‘Local Oversight & Monitoring Policy’ as approved by the Board of Directors on May 29, 2025, with a subsequent ‘Post-Award Risk Assessment’ co...

Response and Corrective Action Planned – The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: Revision of its ‘Local Oversight & Monitoring Policy’ as approved by the Board of Directors on May 29, 2025, with a subsequent ‘Post-Award Risk Assessment’ completed on September 22, 2025. Both documents have since been provided to Iowa Workforce Development to demonstrate compliance with WIOA and Uniform Guidance, Part 200.332.

View Audit 393072

Finding 1181787 (2024-003)

Material Weakness 2024

East Central Iowa Workforce Development Board

IA

Subrecipient Monitoring

Response and Corrective Action Planned – The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective Ju...

Response and Corrective Action Planned – The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective July 1, 2025, and were subsequently provided to Iowa Workforce Development (IWD) and AOS Senior Auditor Tristan Swiggum.

View Audit 393072

Finding 1181709 (2024-005)

Material Weakness 2024

City of Augusta

ME

Procurement, Suspension & Debarment Subrecipient Monitoring

Management Response/Corrective Action Plan: The city and school will draft formal compliance procedures to ensure Davis-Bacon wages are met. These procedures will start with having our attorney’s construct a contract specific to federally funded projects that contains necessary language for Davis-Ba...

Management Response/Corrective Action Plan: The city and school will draft formal compliance procedures to ensure Davis-Bacon wages are met. These procedures will start with having our attorney’s construct a contract specific to federally funded projects that contains necessary language for Davis-Bacon compliance. The Augusta School Department has maintained consistent compliance with Davis-Bacon Act requirements. These requirements are integrated into their bid process regularly and are fully implemented. Going forward, the formal procedure will include that we are to require a signed copy of the contractor’s payroll be sent to us for each week the contract work is performed.

View Audit 392953

Finding 1181480 (2024-009)

Material Weakness 2024

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Subrecipient Monitoring Material Weakness Reporting § 200.327 § 200.328 § 200.334

U.S. Department of Treasury • Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organiza...

U.S. Department of Treasury • Material Weakness in Internal Control over Compliance Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Condition: During audit testing of financial reporting for the Coronavirus State and Local Fiscal Recovery Funds program, the Organization was unable to locate three of ten financial reports requested for review. As a result, auditors were unable to verify the accuracy, completeness, or timeliness of the reported financial information for those reporting periods. Recommendation: The Organization should strengthen internal controls over financial reporting and record retention by establishing clear procedures to ensure that all required reports are accurately prepared, timely submitted, and retained in accordance with federal requirements. Management should designate responsible personnel and implement monitoring procedures to verify compliance with reporting and documentation standards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will require that all supporting documentation related to financial reporting—including reports, source data, approvals, and correspondence—be retained electronically within Sage Intacct using standardized attachment and naming conventions. Management will implement periodic monitoring procedures, including supervisory review and internal spot checks, to verify that reports are timely submitted and that documentation is properly retained in Sage Intacct in accordance with applicable federal record-retention requirements. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is June 30, 2025.

View Audit 392710

Finding 1181444 (2024-005)

Material Weakness 2024

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles

U.S. Department of Agriculture 2024-005 • Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 1 out of the 21 agencies tested which distributed TEFAP commodit...

U.S. Department of Agriculture 2024-005 • Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 1 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2024. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization developed a schedule to complete monitoring and created a checklist to ensure that all documentation is in the appropriate folder. In addition, the organization began conducting internal audits to ensure the developed processes are being followed. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2026.

View Audit 392710

Finding 1181307 (2024-001)

Material Weakness 2024

FosterHub

OH

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213

2024-001 – The Organization did not have a process to determine if vendors were suspended or debarred from receiving federal funds Auditor’s Recommendation: It is recommended that FosterHub develop and implement a suspension and debarment procedure to review the eligibility of vendors before enterin...

2024-001 – The Organization did not have a process to determine if vendors were suspended or debarred from receiving federal funds Auditor’s Recommendation: It is recommended that FosterHub develop and implement a suspension and debarment procedure to review the eligibility of vendors before entering into contracts. Training should be provided to all relevant staff to ensure awareness and compliance with federal requirements. Additionally, periodic monitoring and internal audits should be conducted to ensure adherence to the established procedures. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding and agrees with the recommendation. FosterHub will develop and implement a formal suspension and debarment procedure within the next three months. Training sessions will be conducted for all procurement staff to ensure understanding and compliance with the new procedure. Furthermore, periodic reviews will be instituted to monitor adherence to these requirements and to prevent the recurrence of this issue.

View Audit 392535

Finding 1179864 (2024-003)

Material Weakness 2024

City of Parma

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

The City will modify its internal accounting systems to ensure that the encumbrance and subsequent expenditure of Coronavirus State and Fiscal Recovery Funds cannot occur without verification of, and inclusion of supporting documentation within, the accounting system that a vendor is not suspended o...

The City will modify its internal accounting systems to ensure that the encumbrance and subsequent expenditure of Coronavirus State and Fiscal Recovery Funds cannot occur without verification of, and inclusion of supporting documentation within, the accounting system that a vendor is not suspended or disbarred or otherwise excluded from receiving these funds. The City will also implement additional detailed senior management review of proposed encumbrance and expenditures for these funds to verify that SAM compliance checks have occurred.

View Audit 392232

Finding 1179563 (2024-006)

Material Weakness 2024

Economic Action Committee of the Gulf Coast

TX

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303 § 200.512

Finding 2024-006 - Late Submission of Data Collection Form Corrective Action Plan: Management will implement a formal compliance calendar to track Uniform Guidance reporting deadlines. Responsibility for submission will be assigned to a specific individual. Audit progress will be monitored regularly...

Finding 2024-006 - Late Submission of Data Collection Form Corrective Action Plan: Management will implement a formal compliance calendar to track Uniform Guidance reporting deadlines. Responsibility for submission will be assigned to a specific individual. Audit progress will be monitored regularly to ensure timely completion and submission of the reporting package and Data Collection Form. Additionally, management will address underlying financial reporting control weaknesses identified in this audit to improve overall audit readiness. Responsible Party: Executive Director, Board of Directors (oversight) Planned Completion Date: Compliance calendar implemented March 11, 2026; ongoing monitoring thereafter.

View Audit 391938

Finding 1179560 (2024-005)

Material Weakness 2024

Economic Action Committee of the Gulf Coast

TX

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.303 § 200.334

Finding 2024-005 - Major Program – Reporting Support and Review Corrective Action Plan: Procedures will be implemented to:  Retain detailed support for all Federal reports, including reconciliations to the general ledger  Require documented supervisory review prior to submission  Maintain documen...

Finding 2024-005 - Major Program – Reporting Support and Review Corrective Action Plan: Procedures will be implemented to:  Retain detailed support for all Federal reports, including reconciliations to the general ledger  Require documented supervisory review prior to submission  Maintain documentation of adjustments occurring after report submission  Establish standardized reporting workpapers for each reporting period Responsible Party: Fiscal Officer (preparation), Executive Director (review and approval) Planned Completion Date: Effective March 11, 2026; procedures implemented for all future reports.

View Audit 391938

Finding 1179528 (2024-004)

Material Weakness 2024

Restoration Christian Ministries

CO

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.302

Finding Number: 2024-004 Finding Title: Incorrect Recording of Expenditures that were Notes Receivable Draws Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program ...

Finding Number: 2024-004 Finding Title: Incorrect Recording of Expenditures that were Notes Receivable Draws Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302); GAAP Questioned Costs: $0 (classification error, not allowability issue) Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization's accountant was unaware that the federal grant payments to the subrecipient were considered draws on a note receivable. Corrections have been made to improve communication with the accountant to ensure the accountant is aware of key grant provisions and to ensure note receivable draws are being properly accounted for in the general ledger. Corrective Action Plan: Corrective Action #1: Grant Communication Protocol • Action: Establish formal process requiring Board members to provide detailed grant term summaries to Contract Accountant for all new federal awards. Create standardized grant summary form identifying key provisions affecting accounting treatment, including repayment terms, loan features, and contingencies. Hold kick-off meetings between Board representatives and Contract Accountant for all awards exceeding $100,000. Board President will maintain grants management file accessible to Contract Accountant. • Responsible Person/Title: Board President and Contract Accountant • Anticipated Completion Date: January 31, 2026 Corrective Action #2: Transaction Classification Review Procedures • Action: Implement review procedures requiring evaluation of all federal program disbursements to determine proper classification (expense vs. loan/note receivable). Contract Accountant will develop decision tree guidance. Require Board Treasurer approval for all disbursements exceeding $50,000 with verification of proper classification. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: February 28, 2026 Corrective Action #3: Chart of Accounts Modification • Action: Create separate general ledger accounts for notes receivable related to federal programs. Establish clear account coding guidelines distinguishing between grant expenditures and note receivable advances. Board Treasurer will review and approve modifications. • Responsible Person/Title: Contract Accountant • Anticipated Completion Date: January 31, 2026 Corrective Action #4: Professional Development • Action: Ensure Contract Accountant receives training on identifying and accounting for various federal program transaction types, including loans, advances, and conditional grants. Consider engaging consultant with federal grants expertise for technical assistance. Provide Board members basic training on federal grant structures to improve communication with Contract Accountant. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: February 28, 2026 Corrective Action #5: Quarterly Account Review • Action: Conduct quarterly reviews of all federal program accounts to verify proper transaction classification. Reconcile notes receivable balances to underlying agreements and repayment schedules. Report findings to full Board quarterly. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: March 31, 2026 (initial); Ongoing quarterly thereafter

View Audit 391915

Finding 1179526 (2024-003)

Material Weakness 2024

Restoration Christian Ministries

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.214 § 200.317 § 200.327 § 200.332

Finding Number: 2024-003 Finding Title: Subrecipient Monitoring Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Speci...

Finding Number: 2024-003 Finding Title: Subrecipient Monitoring Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Subrecipient Monitoring (2 CFR §200.332(d)); Procurement Standards (2 CFR §200.317-200.327); Suspension and Debarment (2 CFR §200.214) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization has partnered with a firm to administer the development of the project and was unaware of its responsibilities to monitor the subrecipient. The Organization is in process of implementing procedures to ensure the subrecipient complies with the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Subrecipient Monitoring Policy Development • Action: Develop and adopt written subrecipient monitoring policies and procedures complying with 2 CFR §200.332. Include specific requirements for reviewing procurement policies, suspension/debarment procedures, and other compliance areas. Define monitoring activities, frequency, and documentation requirements. Board will formally approve policy by resolution. • Responsible Person/Title: Board President with Contract Accountant • Anticipated Completion Date: February 15, 2026 Corrective Action #2: Pre-Award Risk Assessment Process • Action: Implement pre-award risk assessment for all subrecipients. Require subrecipients to provide documentation of procurement policies and debarment procedures prior to executing subaward agreements. Board Treasurer will review and approve subrecipient policies for Uniform Guidance compliance before subaward execution. • Responsible Person/Title: Board President • Anticipated Completion Date: February 28, 2026 (initial); Ongoing for new subawards Corrective Action #3: Ongoing Monitoring Program • Action: Board will designate Board member or engage consultant to conduct annual reviews of subrecipients verifying procurement and suspension/debarment compliance. Require subrecipients to submit documentation of debarment checks for all vendors. Review subrecipient procurement transactions on sample basis. Designated monitor will report findings to full Board quarterly. • Responsible Person/Title: Board-designated monitor • Anticipated Completion Date: March 31, 2026 (initial monitoring); Ongoing annually thereafter Corrective Action #4: Technical Assistance to Subrecipient • Action: Provide training and technical assistance to current subrecipient to develop compliant procurement policies and debarment procedures. Engage consultant if needed. Create guidance materials and templates. Schedule quarterly meetings between Board representative and subrecipient. • Responsible Person/Title: Board President • Anticipated Completion Date: March 31, 2026 Corrective Action #5: Monitoring Documentation System • Action: Maintain comprehensive monitoring files documenting all activities, findings, and corrective actions. Board President will report monitoring results to full Board quarterly. • Responsible Person/Title: Board President • Anticipated Completion Date: March 31, 2026 (system implementation); Ongoing

View Audit 391915

Finding 1179192 (2024-001)

Material Weakness 2024

Food Bank of Delaware, Inc.

DE

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303 § 200.510 § 200.511

Root Cause Management concurs that federal expenditures totaling approximately $5,842,346 under ALN 21.029 were omitted from the initially prepared SEFA, along with an additional $206,139 of other federal programs, for a total of $6,048,485. Additionally, management discovered that $2,786,421 was om...

Root Cause Management concurs that federal expenditures totaling approximately $5,842,346 under ALN 21.029 were omitted from the initially prepared SEFA, along with an additional $206,139 of other federal programs, for a total of $6,048,485. Additionally, management discovered that $2,786,421 was omitted from the June 30, 2024 SEFA. The omission resulted from incomplete grant tracking reports not reconciled to the general ledger and grant agreements; absence of an independent secondary review; and procedures that did not fully capture pass-through and subrecipient activity. Objective Design and implement effective internal controls to ensure the SEFA is complete, accurate, and in compliance with 2 CFR §200.510(b) and §200.303; prevent recurrence of material omissions; and sustain readiness for Single Audit reporting. 1. Comprehensive Reconciliation Process Implement a standardized monthly and year-end reconciliation that ties federal award expenditures (including drawdowns and indirect costs) to the general ledger, award agreements/portals, and program manager reports. Create a SEFA Reconciliation Workbook with crosswalks by ALN, passthrough entity, award number, program, and period of performance. 2. Federal Awards Inventory & Certification Maintain a centralized Federal Awards Inventory listing all awards by ALN, award number, passthrough entity, and funding stream. Require annual certifications from responsible leadership team members confirming completeness and accuracy of reported expenditures and period-of-performance coverage. 3. Formal Review Workflow (Independent of Preparer) Establish a documented two-tier review: (1) VP of Finance prepares SEFA and reconciliation; (2) Leadership Team Members perform independent reviews using a SEFA Checklist covering ALNs, pass-throughs, subrecipient disclosures, notes (basis, indirect cost rate), and period-of-performance matching. Evidence the review via dated sign-offs. 4. Subrecipient & Pass-through Controls The VP of Finance create procedures to identify all pass-through and subrecipient transactions. Maintain subrecipient listings with amounts passed through and ensure required disclosures (ALN, pass-through numbers) are captured in SEFA. Reconcile subrecipient agreements and payment registers to SEFA. Leadership Team Members perform independent reviews for accuracy and completeness. 5. Close Calendar & Training Adopt an annual SEFA close calendar with milestones (pre-close, interim, final). Provide annual training for finance and program staff on Uniform Guidance reporting requirements and the SEFA Checklist; include updates to OMB Compliance Supplement as applicable. 6. Monitoring & Continuous Improvement Quarterly CAP monitoring by VP of Finance with status reports to the Finance Committee. Track metrics (e.g., % variance between GL and SEFA, number of checklist exceptions) and remediate promptly. Conduct a pre-audit SEFA "dry run" at least 60 days before year-end close. Roles & Responsibilities • VP of Finance: CAP owner; oversight, quarterly monitoring, reports to Finance Committee, designs reconciliation and review workflow; ensures adherence to checklist and certifications; prepares SEFA, reconciliation workbook, and supporting schedules. • Responsible Leadership Team Member/Program Managers: Certify award activity and completeness; provide supporting documentation. Timeline & Milestones Immediate (within 30 days): Approve CAP; establish Federal Awards Inventory template; draft SEFA Checklist; schedule training. Short term (within 60-90 days): Implement monthly reconciliation; obtain program certifications; pilot independent review on QI data. By next year-end close: Execute full close calendar; complete pre-audit SEFA dry run; document reviewer sign-offs; present monitoring results to Finance Committee. Compliance References • 2 CFR §200.510(h): SEFA preparation requirements (completeness, ALN, pass-through, etc.). • 2 CFR §200.303: Internal controls over federal awards. Management Statement (for 2 CFR §200.511(c) submission) Management agrees with the finding and has initiated the corrective actions described herein. The CAP will be monitored quarterly by the VP of Finance, with status updates provided to those charged with governance until all actions are fully implemented and operating effectively.

View Audit 391574

Finding 1179128 (2024-002)

Material Weakness 2024

County of Hancock, Maine

ME

Subrecipient Monitoring Material Weakness

Name of contact person: Michael Crooker, County Administrator Corrective Action: The County will develop and implement a subrecipient monitoring program. Proposed implementation date: The corrective action plan will be implemented as soon as possible.

View Audit 391523

Finding 1179099 (2024-002)

Material Weakness 2024

Line Mountain School District

PA

Subrecipient Monitoring Cash Management Reporting § 200.302 § 200.303

The District Office will work directly with the Federal Programs Coordinator to ensure more timely submissions of Reconciliation of Cash on Hand Quarterly Reports and Final Expenditure Reports are prepared accurately and submitted timely in accordance with grant requirements. The Business Manager wi...

The District Office will work directly with the Federal Programs Coordinator to ensure more timely submissions of Reconciliation of Cash on Hand Quarterly Reports and Final Expenditure Reports are prepared accurately and submitted timely in accordance with grant requirements. The Business Manager will do this by creating reminders on the Business Manager’s calendar that include due dates each quarter and reminding the Federal Programs Coordinator when their respective reports are due. The District will implement and form a review and monitoring process and provide any necessary training to staff responsible for grant reporting to ensure ongoing compliance.

View Audit 391507

Finding 1179072 (2024-005)

Material Weakness 2024

City of Lincoln Park, Michigan

MI

Subrecipient Monitoring Material Weakness Reporting § 200.510

The City will ensure that all future awards under this program are in compliance and separately report on the Schedule of Expenditures of Federal Awards. All pass-through expenditures will be reconciled to ensure accuracy going forward.

View Audit 391505

Corrective Action Plans

Filters