Corrective Action Plans

Finding 555732 (2024-001)

Significant Deficiency 2024

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354363

Finding 555731 (2024-001)

Material Weakness 2024

Cheval Court, Inc.

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354361

Finding 555716 (2024-001)

Significant Deficiency 2024

Avondale Park Apartments, INC

MD

HUD Housing Programs Eligibility Subrecipient Monitoring

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as w...

a. Comments on the Finding and Each Recommendation Management agrees that the EIV Income Report for certain selected files were not generated in a timely manner as well as timely recertification, as required by HUD guidelines. We attribute this finding to prior management handling of compliance as well as the delay in software set-up at management transition. b. Action(s) Taken or Planned on the Finding As there has been a change in the Management Agent, the agent will ensure that the EIV Income Report and annual certifications are completed according to HUD guidelines. The site now has updated its file set-up review to make sure reports have been completed within HUD guidelines and new company policy as well as corporate compliance monitoring.

View Audit 354355

Finding 555695 (2024-002)

Significant Deficiency 2024

Wyoming Housing Network, Inc. and Subsidiaries

WY

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Finding #2024-002 Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, the Corporation made three withdrawals from the reserve for replacements account totaling $31,043 without obtaining RD approval. Management should request retroactive approval for the reserve...

Finding #2024-002 Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, the Corporation made three withdrawals from the reserve for replacements account totaling $31,043 without obtaining RD approval. Management should request retroactive approval for the reserve for replacements withdrawals totaling $31,043 and obtain RD approval prior to making withdrawals from the reserve for replacements account in the future. Action(s) taken or planned on the finding: Management concurs with the finding. Management requested and received retroactive approval for the reserve for replacements withdrawals totaling $31,043 and will obtain RD approval prior to making withdrawals from the reserve for replacements account in the future.

View Audit 354311 Questioned Costs: $1

Finding 555692 (2024-001)

Significant Deficiency 2024

Wyoming Housing Network, Inc. and Subsidiaries

WY

HUD Housing Programs Subrecipient Monitoring Eligibility

Finding #2024-001 Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, two of the nine resident files selected for testing under the HUD Consolidated Audit Guide lacked properly executed and documented resident eligibility forms. The Agent should ensure that all...

Finding #2024-001 Comments on the Finding and Each Recommendation: During the year ended September 30, 2024, two of the nine resident files selected for testing under the HUD Consolidated Audit Guide lacked properly executed and documented resident eligibility forms. The Agent should ensure that all resident files are maintained at the site for each resident of the Property, and the Agent should ensure that the resident files include all properly executed and documented resident eligibility forms. Action(s) taken or planned on the finding: The Agent concurs with the finding and recommendation. The resident files noted in the statement of condition were for residents who moved out of the Property during the year ended September 30, 2024. No further action is required related to these residents' files. The Agent intends to review and update, as necessary, the other resident files during the year ended September 30, 2024 to ensure the Property is in compliance with HUD requirements.

View Audit 354311

Finding 555653 (2024-004)

Material Weakness 2024

Link of Hampton Roads, Inc.

VA

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.308 § 200.309 § 200.403

1. Implement pre-approval controls; require date validation for all expenses against the award' s period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitatio...

1. Implement pre-approval controls; require date validation for all expenses against the award' s period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews; monitor compliance quarterly to detect outliers.

View Audit 354255

Finding 555652 (2024-003)

Material Weakness 2024

Link of Hampton Roads, Inc.

VA

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.308 § 200.309 § 200.403

1. Implement pre-submission controls; require Date validation for all expenses against the award's period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitati...

1. Implement pre-submission controls; require Date validation for all expenses against the award's period of performance. Program Director or Executive Director or Accounting Director to review and approve. 2. Conduct training; educating staff on 2 CFR requirements and period-of-performance limitations. 3. Perform periodic reviews; monitor compliance quarterly to detect outliers.

View Audit 354255

Finding 555640 (2024-002)

Significant Deficiency 2024

66th Avenue Apts. Inc. Dba Cardosa Village 136-Hd006

CA

Subrecipient Monitoring HUD Housing Programs

Finding 2024-002: The Property received a score of 49 (out of a possible 100) in a physical inspection of the property performed on June 21, 2024, by a representative of HUD. Scores below 60 may be referred to the Departmental Enforcement Center. By reference, the NSPIRE inspection is included as a ...

Finding 2024-002: The Property received a score of 49 (out of a possible 100) in a physical inspection of the property performed on June 21, 2024, by a representative of HUD. Scores below 60 may be referred to the Departmental Enforcement Center. By reference, the NSPIRE inspection is included as a statement of condition. Comments on the Finding and Each Recommendation: Management should maintain policies and procedures which help to ensure any substandard conditions are identified and corrected expeditiously. Management should continue to conduct routine unit and general property inspections and deficiencies should be corrected in a timely manner. Management should ensure all necessary repairs have been made. Action(s) taken or planned on the finding: Management concurs with the finding and agrees with the auditor's recommendation. Management has responded to HUD in regards to this inspection report and has addressed all exigent health and safety issues. Management will continue to correct all remaining deficiencies noted and will implement a process of self-inspection of units and common areas. Management expects that a new physical inspection will be completed in 2025.

View Audit 354222

Finding 555638 (2024-001)

Significant Deficiency 2024

66th Avenue Apts. Inc. Dba Cardosa Village 136-Hd006

CA

Questioned Costs Cash Management HUD Housing Programs

Finding 2024-001: The Property paid expenses totaling $6,702 on behalf of another property without HUD approval. Comments on the Finding and Each Recommendation: Management should seek reimbursement for these transactions from the other property. Action(s) taken or planned on the finding: Manageme...

Finding 2024-001: The Property paid expenses totaling $6,702 on behalf of another property without HUD approval. Comments on the Finding and Each Recommendation: Management should seek reimbursement for these transactions from the other property. Action(s) taken or planned on the finding: Management concurs with the finding and agrees with the auditor's recommendation. On February 11, 2025, a reimbursement from the other property totaling $6,702 was deposited into the Property's operating account.

View Audit 354222 Questioned Costs: $1

Finding 555623 (2024-002)

Significant Deficiency 2024

Marygrove Non-Profit Housing Corporation II

MI

Subrecipient Monitoring HUD Housing Programs

Finding #2024-002: The replacement reserve balance was not maintained in an interest bearing account during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: Management should move funds to an interest bearing account. Action(s) taken or planned on the finding: Ag...

Finding #2024-002: The replacement reserve balance was not maintained in an interest bearing account during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: Management should move funds to an interest bearing account. Action(s) taken or planned on the finding: Agree. The new management agent has gained access to the replacement reserve account and will move replacement reserve funds to an interest bearing account.

View Audit 354194

Finding 555622 (2024-001)

Significant Deficiency 2024

Marygrove Non-Profit Housing Corporation II

MI

Subrecipient Monitoring HUD Housing Programs

Finding #2024-001: There was not a management entity profile able to be provided in effect for the period January 1, 2024 through June 30, 2024. Comments on the Finding and Each Recommendation: HUD should approve a new board of directors and management agent. Action(s) taken or planned on the find...

Finding #2024-001: There was not a management entity profile able to be provided in effect for the period January 1, 2024 through June 30, 2024. Comments on the Finding and Each Recommendation: HUD should approve a new board of directors and management agent. Action(s) taken or planned on the finding: Agree. The new board of directors and new management agent took over the Property effective July 1, 2024 and have executed a management entity profile with HUD.

View Audit 354194

Finding 555621 (2024-001)

Significant Deficiency 2024

Marygrove Non-Profit Housing Corporation

MI

HUD Housing Programs Procurement, Suspension & Debarment Subrecipient Monitoring

Finding #2024-001: There was not a management entity profile able to be provided in effect for the period January 1, 2024 through June 30, 2024. Comments on the Finding and Each Recommendation: HUD should approve a new board of directors and management agent. Action(s) taken or planned on the findin...

Finding #2024-001: There was not a management entity profile able to be provided in effect for the period January 1, 2024 through June 30, 2024. Comments on the Finding and Each Recommendation: HUD should approve a new board of directors and management agent. Action(s) taken or planned on the finding: Agree. The new board of directors and new management agent took over the Property effective July 1, 2024 and have executed a management entity profile with HUD.

View Audit 354193

Finding 555616 (2024-001)

Significant Deficiency 2024

Lasalle Park Homes Ii, Inc. 073-Ee100-Np-Wah

IN

HUD Housing Programs Subrecipient Monitoring

Finding 2024-001: During the year ended December 31, 2024, one rejection letter selected for testing under the compliance supplement was missing necessary documents required by the PRAC and HUD Handbook 4350.3. Comments on the Finding and Each Recommendation: Management should ensure that all rejec...

Finding 2024-001: During the year ended December 31, 2024, one rejection letter selected for testing under the compliance supplement was missing necessary documents required by the PRAC and HUD Handbook 4350.3. Comments on the Finding and Each Recommendation: Management should ensure that all rejection letters are maintained at the site of the Property in accordance with the HUD Handbook 4350.3. Action(s) taken or planned on the finding: Management agrees with the recommendation and will ensure that rejection letters are retained in accordance with the HUD Handbook 4350.3.

View Audit 354179

Finding 555611 (2024-001)

Significant Deficiency 2024

Van Buren Apartments, Inc.

CA

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Name of auditee: Van Buren Apartments, Inc. HUD auditee identification number: 122-11351 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on ...

Name of auditee: Van Buren Apartments, Inc. HUD auditee identification number: 122-11351 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Statement of condition 2024-001: During the year ended December 31, 2024, the Corporation did not make the required deposits to the reserve for replacements. Comments on the Finding and Each Recommendation: Management should make a deposit to the reserve for replacements for $3,468 for the delinquent deposits. In future periods, management should fund the reserve for replacements on an annual basis as required by the HUD regulatory agreement. Action(s) taken or planned on the finding: Management made a deposit of $3,468 on March 11, 2025 for the delinquent deposits.

View Audit 354161 Questioned Costs: $1

Finding 555608 (2024-002)

Significant Deficiency 2024

Lime House Senior Housing, Inc.

CA

Questioned Costs Cash Management HUD Housing Programs

Name of auditee: Lime House Senior Housing, Inc. HUD auditee identification number: 122-EE136-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current ...

Name of auditee: Lime House Senior Housing, Inc. HUD auditee identification number: 122-EE136-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and RecommendationsFinding 2024-002: The Corporation made a payment to LAHD in the amount of $15,483 and did not obtain the required HUD approval. Comments on the Finding and Each Recommendation: The Corporation should request retroactive HUD approval to make the payment or request reimbursement from the lender. Action(s) taken or planned on the finding: Management has requested approval from HUD. As of the report date, no response has been received.

View Audit 354160 Questioned Costs: $1

Finding 555607 (2024-001)

Significant Deficiency 2024

Lime House Senior Housing, Inc.

CA

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Name of auditee: Lime House Senior Housing, Inc. HUD auditee identification number: 122-EE136-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current ...

Name of auditee: Lime House Senior Housing, Inc. HUD auditee identification number: 122-EE136-WAH-NP Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended December 31, 2024 CAP prepared by Name: Ana Ponce Position: President Telephone number: 323-231-1104 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding 2024-001: The Corporation's required deposit of $30,965 to the residual receipts account per the December 31, 2023 Computation of Surplus Cash, Distributions and Residual Receipts was not deposited within 90 days of the fiscal year end. Comments on the Finding and Each Recommendation: Management should make all required residual receipt deposits per the annual Computation of Surplus Cash, Distributions and Residual Receipts within 90 days after fiscal year end. Action(s) taken or planned on the finding: Management deposited $30,965 into the residual receipts fund on December 20, 2024. No further action is required.

View Audit 354160 Questioned Costs: $1

Finding 555554 (2024-003)

Material Weakness 2024

San Bernardino City Unified School District

CA

Allowable Costs / Cost Principles Reporting Subrecipient Monitoring

When this matter was brought to the District's attention it was too late to adjust for FY 2023-2024 but the District took steps to ensure all ESSER Funds impacted were fully expended and the indirect charges were ultimately balanced out.

View Audit 354064

Finding 555532 (2024-001)

Significant Deficiency 2024

Ffah Citrus Grove, LLC

CA

HUD Housing Programs Subrecipient Monitoring

Statement of condition #2024-001: The Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 was not submitted to the federal audit clearinghouse in the required timeframe. Comments on the Finding and Each Recommendation: The Company should submit the Form SF-SAC Single...

Statement of condition #2024-001: The Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 was not submitted to the federal audit clearinghouse in the required timeframe. Comments on the Finding and Each Recommendation: The Company should submit the Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 as soon as practical. Action(s) taken or planned on the finding: Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 was submitted to the federal audit clearinghouse on May 13, 2024.

View Audit 354063

Finding 555531 (2024-001)

Significant Deficiency 2024

Ffah Carver Gardens, LLC

CA

HUD Housing Programs Subrecipient Monitoring

Statement of condition #2024-001: The Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 was not submitted to the federal audit clearinghouse in the required timeframe. Comments on the Finding and Each Recommendation: The Company should submit the Form SF-SAC Single...

Statement of condition #2024-001: The Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 was not submitted to the federal audit clearinghouse in the required timeframe. Comments on the Finding and Each Recommendation: The Company should submit the Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 as soon as practical. Action(s) taken or planned on the finding: Form SF-SAC Single Audit Data Collection Form for the year ended December 31, 2023 was submitted to the federal audit clearinghouse on May 28, 2024.

View Audit 354062

Finding 555345 (2024-002)

Material Weakness 2024

Newhall School District

CA

Subrecipient Monitoring Material Weakness Reporting

Corrective Action Plan and Views of Responsible Officials Views of Responsible Officials The District acknowledges the audit finding regarding insufficient retention of financial records supporting the annual ESSER expenditure reports submitted to the California Department of Education. We understan...

Corrective Action Plan and Views of Responsible Officials Views of Responsible Officials The District acknowledges the audit finding regarding insufficient retention of financial records supporting the annual ESSER expenditure reports submitted to the California Department of Education. We understand that maintaining accurate and accessible documentation is essential to federal compliance under Title 2, Code of Federal Regulations (CFR) §200.334. The District takes full responsibility for this oversight and is taking immediate steps to strengthen its internal controls and documentation practices. Corrective Action Plan 1. Reason for the Finding: This issue arose due to high turnover in the position responsible for federal reporting. As a result, institutional knowledge and documentation practices were disrupted, making it difficult to locate supporting financial records for the annual ESSER expenditure report. While the quarterly reports submitted throughout the year were accurate and properly supported, the annual report was not fully aligned with available documentation due to incomplete record retention during the staffing transitions. 2. Actions to be Taken to Correct the Issue: Centralized Document Management System: The District will implement a centralized, secure electronic document management system (e.g., Google Drive, SharePoint, or a financial records database) specifically for tracking and retaining federal program documentation. All financial records supporting ESSER and similar federal grants will be stored here and categorized by funding source, fiscal year, and reporting period. Standard Operating Procedure (SOP): A formal SOP for federal grants management will be created and distributed to all relevant departments. This will include clear guidelines for documentation, record retention timelines, and roles/responsibilities for financial reconciliation and audit readiness. Staff Training: District staff responsible for federal program management and reporting will be trained on the new SOP, federal compliance regulations (including CFR §200.334), and the use of the document management system. Refresher trainings will be conducted annually or as needed. Pre-Submission Review: A dual review process will be instituted where both the Business Services and Federal Programs teams confirm the availability and accuracy of supporting documentation before any reports are submitted to oversight agencies. 3. Timeline for Implementation: All corrective actions will be in place within 90 days. The centralized document storage system and SOPs will be finalized and rolled out within 60 days. Staff training will be completed within the following 30 days. Immediate measures to retain ESSER documentation have already been initiated.

View Audit 353992

Finding 555300 (2024-001)

Significant Deficiency 2024

Zero to Five Montana

MT

Subrecipient Monitoring Procurement, Suspension & Debarment Significant Deficiency

Finding Number 2024-001: Monitoring of Funds Passed to Subrecipient Federal Program ALN: 93.575 Corrective Action Plan: Zero to Five Montana has implemented updated policies and procedures to ensure proper execution and documentation of subrecipient contracts and payments. All contracts are now proc...

Finding Number 2024-001: Monitoring of Funds Passed to Subrecipient Federal Program ALN: 93.575 Corrective Action Plan: Zero to Five Montana has implemented updated policies and procedures to ensure proper execution and documentation of subrecipient contracts and payments. All contracts are now processed and signed via an electronic signing service (e.g., DocuSign) by the Executive Director, with copies securely retained. Prior to disbursing funds, subrecipients with executed contracts are set up as vendors in the expense management system. The subrecipient must complete their vendor profiles and submit tax documentation. Payments are supported by an invoice that includes payment details, expense codes, and grant assignments (if applicable), and must be reviewed and approved by the Program and Operations Directors to confirm all documentation and compliance steps are met. Staff will be trained on these procedures by April 14, 2025, and quarterly audits will be conducted to monitor adherence, with findings reported to leadership and the governing board. Contact Person Responsible for Corrective Action: Caitlin Jensen, Executive Director Anticipated Completion Date: April 14, 2025

View Audit 353940

Finding 555196 (2024-002)

Significant Deficiency 2024

Gratz College

PA

Special Tests & Provisions Subrecipient Monitoring Cash Management

Finding 2024-002 Corrective Action Plan The College reassigned the duties within its business office to ensure remittances to students or parent borrowers of credit balances are executed in accordance with the timeline mandated by the U.S. Department of Education. Gratz College notes that this was ...

Finding 2024-002 Corrective Action Plan The College reassigned the duties within its business office to ensure remittances to students or parent borrowers of credit balances are executed in accordance with the timeline mandated by the U.S. Department of Education. Gratz College notes that this was the only instance of noncompliance and resulted from turnover in Gratz College’s business office staff. Anticipated Completion Date The corrective action plan was completed June 1, 2024 Names of Contact People Responsible for Corrective Action Thomas R. Cipriano, Jr. – Manager of Business Operations and Facilities Ross Holgado – Manager of Financial Reporting Karen West – Senior Accounting Associate and Coordinator of Student Billing

View Audit 353822

Finding 555178 (2024-002)

Significant Deficiency 2024

Housing Authority of Somerset County

PA

Subrecipient Monitoring HUD Housing Programs Internal Control / Segregation of Duties

The Housing Authority of Somerset County disagrees with the second finding as per 2 CFR 200.511 part (c) as for the rent amount on the 50058 not matching the monthly rent amount. The reason that the Housing Authority disagrees and didn't put an action plan in place for this finding is because each f...

The Housing Authority of Somerset County disagrees with the second finding as per 2 CFR 200.511 part (c) as for the rent amount on the 50058 not matching the monthly rent amount. The reason that the Housing Authority disagrees and didn't put an action plan in place for this finding is because each file with the discrepancy had a more recent 50058 in the file which reflected the correct monthly rent amount.

View Audit 353786

Finding 555173 (2024-004)

Material Weakness 2024

Miami Children's Health System, Inc. D/b/a Nicklaus Children's Health

FL

Questioned Costs Allowable Costs / Cost Principles Cash Management

Identifying Number: 2024-004 Finding: Material Weakness: Period of Performance Context: Expenditures were included on the 2024 Schedule of Expenditures of Federal Awards, however, the expenditures were incurred prior to the budget period start date. Corrective Actions Taken or Planned: The Director ...

Identifying Number: 2024-004 Finding: Material Weakness: Period of Performance Context: Expenditures were included on the 2024 Schedule of Expenditures of Federal Awards, however, the expenditures were incurred prior to the budget period start date. Corrective Actions Taken or Planned: The Director of the Office of Sponsored Programs and the Manager of Sponsored Programs will develop a standardized document checklist for all high-value expenditures. This checklist will require all Sponsored Programs analysts to submit complete documentation with expense reports and proof of payment and have their respective immediate supervisor/manager review for compliance before final approval by the Director. a. Implementing organizational changes such as updated policies and/or procedures b. Educating the team(s) and/or Department(s) on internal controls, processes and accuracy best practices during the Grant management process c. Oversight of drawdown requests by the Director of Sponsored Programs to ensure accuracy of request Planning Process: Compliance with Regulations: The Director and Manager from Sponsored Programs will ensure the corrective actions align with applicable federal grant regulations and guidelines. We will create: - Implement internal controls, with the Director and Manager from Sponsored Programs developing checks and balances at the end of each month to ensure compliance in all the grant's portfolio. - Oversight of all drawdown requests, ensuring complete and accurate supporting documentation. Communication: The Director and Manager from Sponsored Programs will communicate the corrective action plan to all relevant staff and stakeholders. Follow-up: The Director and Manager from Sponsored Programs will regularly monitor progress and adjust to resolve any inefficiencies. Training: The Director and Manager from Sponsored Programs will work on the development and delivery of mandatory training sessions for all Sponsored Programs relevant staff. This will include (not limted to): - Retrain on updated policies and procedures (OSP team, Departments and stakeholders, if applicable) - Retrain on workflows and system (OSP team, Departments and stakeholders, if applicable) - Retrain on process improvement (OSP team, Departments and stakeholders, if applicable) Policy Updates: Revision of existing policies or creation of new ones to clarify procedures. System Enhacements: Implementing new software/program that improves data accuracy and compliance in all Federal/State and Local Grants throughout Nicklaus Children's Hospital. Monitoring and Oversight: The Director and Manager from the Sponsored Programs will monitor transactions and reporting processed more frequently. Deadline for Implementation: Immediate Action: The Director of Sponsored Programs transitioned the staff member responsible for the findings to an area where their expertise is most valuable. This CAPA will take effect immediately and be fully implemented within six weeks by April 07, 2025, allowing time to create/revise SOPs, Working Practice Guidelines (WPGs), Checklists and training/retraining sessions for stakeholders and OSP team members.

View Audit 353775 Questioned Costs: $1

Finding 555118 (2024-001)

Material Weakness 2024

National Association of Councils on Developmental Disabilities

DC

Subrecipient Monitoring Internal Control / Segregation of Duties HUD Housing Programs

Recommendation: The Association should design and implement procedures to track and verify employees’ time worked on Federal grant programs along with documented reviews and approvals. Views of Responsible Officials and Planned Corrective Actions: NACDD has created an FTE allocation chart for alloc...

Recommendation: The Association should design and implement procedures to track and verify employees’ time worked on Federal grant programs along with documented reviews and approvals. Views of Responsible Officials and Planned Corrective Actions: NACDD has created an FTE allocation chart for allocating set payroll costs for each time period based on estimated time and effort functions of the employee for each grant and for our unrestricted core funding. NACDD also currently uses an online timecard system, Prime Pay Swipe clock for time keeping and payroll functions. We have already added project labels for all grants and sub-awardee grants in the system’s time keeping section and have trained staff on how to properly record their time for each grant they are working on daily. At the end of each semi-monthly pay period, staff must approve their timecards, and then the Operations Director reviews each of them and signs off on staff timecards (with the Executive Director signing off on the Operations Director’s.) The Operations Director has access to staff calendars, including scheduled meetings and other requirements for each grant. Twice a fiscal year, leadership will review grant hours actually logged with employees and decide if the current estimates of time and effort are accurate or need adjusting. If adjustments are needed, set payroll costs based on FTE allocation will be updated with our accountants.

View Audit 353714

Corrective Action Plans

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