Corrective Action Plans

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Finding # 2025-002 Type: Material weakness over procurement Type: Noncompliance over procurement Assisting Listing Number: 43.001 Federal Agency: National Aeronautics and Space Administration Name of Federal Program: Science Finding: The Organization does not have controls or a policy in place to en...
Finding # 2025-002 Type: Material weakness over procurement Type: Noncompliance over procurement Assisting Listing Number: 43.001 Federal Agency: National Aeronautics and Space Administration Name of Federal Program: Science Finding: The Organization does not have controls or a policy in place to ensure compliance with this requirement. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Recommendation: Management should establish a consistent procedure to verify that vendors are not suspended or debarred and implement controls that are documented to support this process. A procurement policy should also be implemented consistent with the aforementioned guidance. Corrective Action: While we did not previously have a standalone, written policy specifically addressing suspension and debarment, key elements of procurement oversight, including suspension and debarment review, were incorporated into existing policies and operational practices. The new procurement policy consolidates and formally documents these requirements to ensure consistency, clarity, and ongoing compliance. In addition, we took the opportunity to review and revise our detailed procedures for setting up new vendors and retaining documentation for all required vendor confirmation. Anticipated Completion Date: December 20, 2025
Finding 2025-001: Comments on the Finding and Each Recommendation All the required monthly reserve for replacements deposits were not made during the year ended September 30, 2025. Management should transfer $5,692 into the reserve for replacements account from the operating cash account as soon as ...
Finding 2025-001: Comments on the Finding and Each Recommendation All the required monthly reserve for replacements deposits were not made during the year ended September 30, 2025. Management should transfer $5,692 into the reserve for replacements account from the operating cash account as soon as possible. Action(s) taken or planned on the finding Management concurs with the finding and agrees with the recommendation and on December 17, 2025 transferred $5,692 from the operating cash account to the reserve for replacements account.
In relation to Family Health Center of San Diego’s annual financial statement audit and the single audit for the year ended June 30, 2025, the Health Center hereby submits a corrective action plan, as required by Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements,...
In relation to Family Health Center of San Diego’s annual financial statement audit and the single audit for the year ended June 30, 2025, the Health Center hereby submits a corrective action plan, as required by Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Section 511 Audit findings follow-up. 2025-001 – Special Tests and Provisions (Sliding Fee Discounts) Information on the Federal Program: Assistance Listing Number(s): 93.224, 93.527 Federal Program Name: Health Center Program Cluster Federal Agency: U.S. Department of Health and Human Services Pass-Through Entity: Direct Program Federal Award Number and Award Year: 5 H80CS00224‐23‐00 – 2023-2024 5 H80CS00224‐24‐00 – 2024-2025 Criteria: In accordance with the Health Resources & Services Administration Health Center Program Compliance Manual, Chapter 9: Sliding Fee Discount Program, health centers must prepare and apply a sliding fee discount schedule so that amounts owed for health center services by eligible patients are adjusted based on the patients’ ability to pay. In accordance with 42 CFR 56.303, health centers must have a schedule of fees or payments for the provision of their health services consistent with locally prevailing rates or charges and designed to cover their reasonable costs of operation. They are also required to have a corresponding schedule of discounts applied and adjusted based on the patient’s ability to pay. The patient’s ability to pay is determined based on the official poverty guidelines, as revised annually by U.S. Department of Health and Human Services (HHS). The schedule of discounts must provide for a full discount to individuals and families with annual incomes at or below those set forth in the most recent poverty income guidelines (except that nominal fee for service may be collected from such individuals and families) and for no discount to individuals and families with annual incomes greater than twice those set forth in such guidelines. Condition and Context: The Health Center determines the sliding fee discount charged to the patients based on their annual gross income and household size. During our testing of sliding fee discount, we noted the following: • Four (4) out of 60 encounters selected were given a sliding fee discount in an amount that did not match the recalculated sliding fee discount based on annual gross income and household size per the sliding fee policy. There was a total of 65,495 encounters and the sample procedures were not statistical. Questioned Costs: None. 2025-001 – Special Tests and Provisions (Sliding Fee Discounts) (Continued) Cause: During a system transition period, monitoring controls were ineffective, resulting in documentation variances and system-related issues. Contributing factors included documentation timing differences, manual data entry variances, and previously identified electronic health record system mapping defects affecting fee calculation and form generation. Effect: Patients were given an improper sliding fee discount based on their income and family size. Indication of Repeat Finding: No. Recommendation: We recommend that the Health Center strengthen documentation practices and monitoring procedures related to the Sliding Fee Discount Program, particularly during periods of system or workflow transition. Views of Responsible Officials and Planned Corrective Actions: Management concurs in part with the finding. While isolated documentation variances were identified in a non-statistical sample, management determined the condition was limited in scope, not systemic, and resulted in no questioned costs. The variances were associated with a temporary system transition period and documentation timing issues, not a deficiency in internal controls. Corrective actions were implemented, system issues were resolved, and results were validated through a full-population review. Management will continue ongoing monitoring to ensure sustained compliance. Contact person responsible for corrective action: Ricardo Roman, Chief Financial Officer Anticipated completion date: June 30, 2026
Action Taken: CCYSB will ensure that all documentation regarding a federal program is properly collected, stored, and verified on a quarterly basis. To verify data reporting accuracy, the Program Director will provide the supporting data to the Grants Manager for review prior to completion of the re...
Action Taken: CCYSB will ensure that all documentation regarding a federal program is properly collected, stored, and verified on a quarterly basis. To verify data reporting accuracy, the Program Director will provide the supporting data to the Grants Manager for review prior to completion of the report. CCYSB will ensure that once verified, the information submitted in any report will not contain any discrepancies from that which was verified and that we have all the necessary supporting documentation to justify the reporting.
FINDING 2025-001 Finding Subject: Annual Report Card, High School Graduation Rate – Special Test and Provisions Contact Person Responsible for Corrective Action: Marilyn Hampton, Supervisor of Student Services Contact Phone Number and Email Address: (219) 933-2461, ext.1048 mehampton@hammond.k12.in....
FINDING 2025-001 Finding Subject: Annual Report Card, High School Graduation Rate – Special Test and Provisions Contact Person Responsible for Corrective Action: Marilyn Hampton, Supervisor of Student Services Contact Phone Number and Email Address: (219) 933-2461, ext.1048 mehampton@hammond.k12.in.us Views of Responsible Officials: We concur with the finding and will implement a corrective action plan. Description of Corrective Action Plan: To ensure compliance with the requirements related to the grant agreement and the Special Test and Provisions Annual Report Card, High School Graduation rate compliance, the School City of Hammond will put into place an effective internal control system. The School City of Hammond will maintain an effective control system for withdrawals from each of the schools within the school system. At the time of withdrawal, a withdrawal form, along with a verified ID will be copied by the school’s registrar or designee. This withdrawal form must include the signatures of a parent and principal. This is the first step in the monitoring process. This system for withdrawals will also include placing a copy of the withdrawal form in the student information system (PowerSchool Attachments). The documentation that needs to be attached to the withdrawal form should include documents that show a Records Request, proof that the student withdrew to attend another school or educational program that results in the awarding of a high school diploma, has immigrated to another country, or is deceased. Upon completion of the withdrawal at the school, a copy of the documentation will be kept at the school, and the original documentation will be placed into the cumulative record. The school will forward a digital copy to Student Services. Upon receipt of the digital copy at Student Services, the administrator will review the file and will sign off to indicate that the record has been reviewed and is complete. To ensure this process is implemented with fidelity, training will take place on a yearly basis with administrators and office staff on the procedures that need to be followed during the withdrawal process. Anticipated Completion Date: 01/31/2026
Corrective Action Plan June 30, 2025 Finding: 2025-001 Name of Responsible Official: Angela Bass Anticipation Completion Date: December 31 , 2025 Mississippi First's Response: 1. Audit Finding Corrective Action Plan The auditor noted that Mississippi First did not submit a FFATA report for a subawar...
Corrective Action Plan June 30, 2025 Finding: 2025-001 Name of Responsible Official: Angela Bass Anticipation Completion Date: December 31 , 2025 Mississippi First's Response: 1. Audit Finding Corrective Action Plan The auditor noted that Mississippi First did not submit a FFATA report for a subaward of $30,000 or more in a timely and accurate manner. 2. Root Cause The delay in submitting the FFATA report was due to a personnel transition during the reporting period. The outgoing Executive Director had been executing FFATA filings, and the incoming Executive Director and was not yet aware of this reporting requirement. Because the requirement was not captured in any written procedures or transition documents, the report was inadvertently missed. This was an isolated incident resulting from the timing of the leadership transition and a gap in knowledge transfer. 3. Corrective Action Taken / Planned A. Formal Policy Development - Mississippi First has drafted a comprehensive FFATA Compliance and Subaward Reporting Policy. B. Assignment of Responsibility - The Director of Operations is designated as the FFATA Reporting Officer. C. FFATA Reporting Checklist - A standardized checklist ensures accuracy for each submission. D. FSRS Standard Operating Procedure (SOP) - A detailed, step-by-step SOP has been developed. E. Deadline Tracking & Automated Reminders - FFATA deadlines will be integrated into the grants management calendar. F. Quarterly Internal Reviews - Quarterly internal audits will verify completeness, accuracy, and timeliness. G. Job Description Updates - Relevant staff job descriptions now include FFATA responsibilities. 4. Timeline for Implementation • Finalize and adopt FFATA Policy- by December 31, 2025 • Assign FFATA Reporting Officer role - Completed • Launch FFATA checklist and SOP - by December 31, 2025 • Implement automated reminders - by December 31, 2025 • Conduct first quarterly compliance review - by December 31, 2025 5. Preventive Measures Mississippi First will require FFATA training, include FFATA in onboarding, review the policy annually, and integrate FFATA compliance into grants management protocols.
Audit Finding 2025-001 - Procurement and Suspension and Debarment Corrective Action Plan The City will revise its procurement policy and procedures to address all relevant requirements under Uniform Guidance, specifically: . Incorporate written standards of conduct covering conflicts of interest for...
Audit Finding 2025-001 - Procurement and Suspension and Debarment Corrective Action Plan The City will revise its procurement policy and procedures to address all relevant requirements under Uniform Guidance, specifically: . Incorporate written standards of conduct covering conflicts of interest for employees involved in procurement, in accordance with 2 CFR 200.318(c)(1). . Include written policies and procedures requiring affirmative steps to solicit and consider participation by small, minority, women-owned, veteran-owned, and labor surplus area businesses, as specified in 2 CFR 200.321(b). . Add explicit provisions to require sufficient and detailed recordkeeping for all procurement transactions funded with federal awards, addressing the requirements of 2 CFR 200.318(i). Persons responsible for corrective action Jamie Rhodes, Administrative Services Manager Branden Dross, City Administrator Corrective action completion date June 30, 2026
Finding Number: 2025-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing co...
Finding Number: 2025-001: ARP Education Stabilization Fund – Wage Rate Requirements Planned Corrective Action: Summary of corrective action to be taken Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Dave Massa, Treasurer As recommended, the School will perform existing controls and establish new controls to ensure that contractors and subcontractors are in compliance with all labor standards by conducting on-site inspections and collecting the required certified payroll documentation in a timely manner. Specifically, the School will add an Affidavit of Compliance Form to the contracts that will be required to be submitted by the grantee before closing. A project will not be considered closed until the School has received an executed copy of the form. Upon notification of construction commencement, the School will immediately begin monitoring for Wage Rate Requirements in the form of both on-site inspections and review and approval of certified payroll reports.
2025 –002 Reporting Program: Homeowner Assistance Fund Assistance Listing Number 21.026 Name of Contact Person: Lisa Coleman, Senior Vice President of Federal Grants Corrective Action: Management will implement procedures to ensure the timely and accurate submission of Homeowner Assistance Fund (HAF...
2025 –002 Reporting Program: Homeowner Assistance Fund Assistance Listing Number 21.026 Name of Contact Person: Lisa Coleman, Senior Vice President of Federal Grants Corrective Action: Management will implement procedures to ensure the timely and accurate submission of Homeowner Assistance Fund (HAF) Quarterly and Annual Performance Reports. Reporting deadlines are tracked on the Corporation’s federal reporting and compliance calendar, with oversight by the AVP of Grants Compliance and Reporting, who actively monitors reporting progress and coordinates reconciliation of financial data between the HAF Program Manager and Accounting. The AVP of Grants Compliance and Reporting reviews each completed report for accuracy and completeness, signs and dates the report, and submits it to the SVP of Federal Grants for final review and approval. The HAF Program Manager provides confirmation of successful submission through the U.S. Treasury portal. These procedures will be incorporated into the HAF Program Manual. Anticipated Completion Date: March 31, 2026
FINDING 2025-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls over Eligibility Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Number...
FINDING 2025-001 Information on the federal program: Subject: Child Nutrition Cluster - Internal Controls over Eligibility Federal Agency: Department of Agriculture Federal Program: School Breakfast Program, National School Lunch Program Assistance Listing Number: 10.553, 10.555 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Finding: Material Weakness Context: During the testing of internal controls over eligibility determinations for free and reduced meals, we noted there was no formal, documented review control in place. There is no documented, secondary review for the applications entered in the food service software which determines eligibility. Additionally, there was no documented review by School Corporation personnel of the Income Eligibility Guidelines used by the food service software which are updated on annual basis Contact Person Responsible for Corrective Action: Amber Swinehart, Food Services Director Contact Phone Number: 765-759-2592 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Food Services Director will provide evidence of review for the eligibility parameters from Titan at least once a year prior to the start of the school year Anticipated Completion Date: 6/30/2026
Finding Number: 2025-005 Federal Program, Assistance Listing Number and Name: ALN 93.914, Department of Health and Human Services (HHS), HIV Relief Project Grants Condition: Original Finding Description: A lack of effective controls resulted in noncompliance with federal payment requirements, specif...
Finding Number: 2025-005 Federal Program, Assistance Listing Number and Name: ALN 93.914, Department of Health and Human Services (HHS), HIV Relief Project Grants Condition: Original Finding Description: A lack of effective controls resulted in noncompliance with federal payment requirements, specifically for payments made to subrecipients. Contact Person Responsible for Corrective Action / Anticipated Completion Date: Denise Fair Razo Regina Greear Terri Daniels Anticipated completion date: March 2026 Planned Corrective Action: The three payments made were paid one to two days after the 30 day reimbursement requirement. The City will review its subrecipient payment terms and implement additional processes to help ensure compliance with federal payment requirements.
Finding Number 2025-004 Federal Program, Assistance Listing Number and Name: ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description: The City lacked adequate controls to ensure annual reviews were conducted in accordance ...
Finding Number 2025-004 Federal Program, Assistance Listing Number and Name: ALN 14.239, Department of Housing and Urban Development, Home Investment Partnerships Program Condition: Original Finding Description: The City lacked adequate controls to ensure annual reviews were conducted in accordance with its policy, limiting its ability to exercise proper oversight of eligibility determinations performed by the program’s contractor. Contact Person Responsible for Corrective Action / Anticipated Completion Date: Julie Schneider Anticipated completion date: July 2025 Planned Corrective Action: This finding is timing related and was resolved by the City during fiscal year. The City reviewed and updated its policies and procedures to help ensure proper segregation of duties and proper oversight of eligibility determination. Additional processes now have independent review of inspections after the program’s contractor to further support program compliance. Review responsibilities were put in place to help ensure determinations receive an independent secondary review by City staff. These changes were in place by year-end. The City will continue to monitor the program and review procedures to ensure continued compliance and to prevent the recurrence of similar timing-related issues. The City will continue to monitor the program and review procedures to ensure continued compliance and to prevent the recurrence of similar timing-related issues.
Finding Number: 2025-003 Federal Program, Assistance Listing Number and Name: ALN 14.239, Department of Housing and Urban Development (HUD), Home Investment Partnerships Program Condition: Original Finding Description: The requirements mandate that units be inspected, deficiencies communicated, and ...
Finding Number: 2025-003 Federal Program, Assistance Listing Number and Name: ALN 14.239, Department of Housing and Urban Development (HUD), Home Investment Partnerships Program Condition: Original Finding Description: The requirements mandate that units be inspected, deficiencies communicated, and corrective actions taken promptly. However, controls over housing quality standards are not effectively designed, reflecting a persistent lack of segregation of duties necessary to ensure compliance. Furthermore, existing controls were insufficient to guarantee that HQS inspection requirements were met and that identified deficiencies were addressed in a timely manner. Contact Person Responsible for Corrective Action / Anticipated Completion Date: Julie Schneider Anticipated completion date: July 2025 Planned Corrective Action: During the fiscal year, the City reviewed and enhanced its internal controls over HQS inspections to strengthen oversight and segregation of duties. Process changes were implemented to ensure that inspections, documentation of deficiencies, follow-up actions, and certifications of completion have independent review and approval. In addition, management implemented monitoring procedures to track inspection schedules to help ensure HQS requirements are met in a timely manner.While corrective actions were initiated during the fiscal year, they were not fully implemented throughout the entire period. By year-end, the controls were in place. The City will continue to monitor these controls to ensure ongoing compliance and to prevent similar issues from recurring.
For all future stipend payments, the Alternative Payment Program Supervisor will review and confirm that all appropriate documentation is submitted along with the request for payment. This documentation will be reviewed by the Early Care and Education Senior Accounting Technician for accuracy and co...
For all future stipend payments, the Alternative Payment Program Supervisor will review and confirm that all appropriate documentation is submitted along with the request for payment. This documentation will be reviewed by the Early Care and Education Senior Accounting Technician for accuracy and completeness before approving the stipend payment. Stipend payments will not be approved for payment until all appropriate documentation has been received and reviewed by the Early Care and Education Financial Services Manager.
Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Staff have been retrained, and additional monitoring procedures have been implemented. The Food Service Director will oversee ongoing compliance. Official Responsi...
Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Staff have been retrained, and additional monitoring procedures have been implemented. The Food Service Director will oversee ongoing compliance. Official Responsible for Ensuring CAP: Dan Anderson, Superintendent, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: June 30, 2026. Plan to Monitor Completion of CAP: The Board of Education will be monitoring this corrective action plan. Dan Anderson Superintendent
The District has revised and resubmitted the Final Expenditure Report for the Title I School Improvement (a) grant and will repay the unallowable costs to DESE. In addition the District will ensure that its procedures and the Uniform Guidance requirements are being followed regarding allowable trave...
The District has revised and resubmitted the Final Expenditure Report for the Title I School Improvement (a) grant and will repay the unallowable costs to DESE. In addition the District will ensure that its procedures and the Uniform Guidance requirements are being followed regarding allowable travel expenses.
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented multiple corrective actions to address this finding: 1. CIF created a new template for Subawar...
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented multiple corrective actions to address this finding: 1. CIF created a new template for Subaward Agreements that includes all elements required under 2 CFR 200.332(b). This template will be used for any future Subaward Agreements into which CIF enters. 2. CIF created an Amendment template for each active Federal award Subaward/Subrecipient Agreement that includes all elements required under 2 CFR 200.332(b), a requirement to submit period financial reports to CIF, and a section on compliance with audit requirements according to 2 CFR 200.332(g) / 2 CFR 200.501. 3. For each Subrecipient of CIF’s grant NR233A750004G045 under ALN #10.937, formerly known as the Partnerships for Climate Smart Commodities grant but now known as the Advancing Markets for Producers (AMP) program, CIF will use that template to execute an Amendment to the Subaward/Subrecipient Agreement following the execution of the Amendment to the Grant Agreement between CIF and the United States Department of Agriculture (USDA). 4. CIF implemented a schedule for reviewing current subrecipients’ FY 25 Audit Reports after they are published in the Federal Audit Clearinghouse in mid-2026, document the impact of any audit findings on the federally funded program, and implement a corrective action plan. 5. CIF made revisions in the FY 26 update to the CIF Subaward Management & Subrecipient Monitoring Policy and Procedures which will apply to any new subawards. The pre-award risk assessment procedures now include dating and ensure that results are documented prior to subaward execution. The monitoring procedures are now explicitly linked to risk assessment results, with greater oversight required for subrecipients without experience managing Federal funds.
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements w...
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements which involves timesheets that record actual time spent on a funding source and are accompanied by supervisory approvals. This system has been formally documented in the FY 26 update to the CIF Financial Policy and includes annual training for staff responsible for managing payroll allocations and Federal reporting. Charges to Federal awards for salaries and wages are now based on records that accurately reflect the work performed. The records are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The records support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
Significant Deficiency Item 2025-006 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 During ...
Significant Deficiency Item 2025-006 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that LBUCC conducted quarterly internal audit reviews of fifty (50) samples self-pay patients to review for sliding fee discount determination. However, we noted that the findings or exceptions identified in the quarterly internal audit review remained uncorrected. Recommendation: We recommend that LBUCC establish a process for communicating, investigating and correcting all internal audit findings or exceptions on a timely manner. Additionally, we recommend that management identify the potential cause of such findings or exceptions and that necessary corrective actions be taken to address such cause. For example, LBUCC may conduct periodic training of all employees involved in the patient intake and screening process. Action Taken: The internal audit process has been redesigned and expanded to include weekly reviews and all exceptions/errors will be corrected and the cause determined. Additional training will be provided with the expectation that the exceptions/errors will reduce going forward. Effectivity Date: This will be fully implemented by 1/31/2026
Material Weakness Item 2025-001 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 Dur...
Material Weakness Item 2025-001 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 During our audit, we noted that there is no evidence that any exclusion search was conducted in 2025 for all sample employees tested. Recommendation: We recommend that LBUCC develop and implement a formal exclusion search policy for employees whose salaries are charged to HHS grants to ensure compliance with federal and state regulations. The policy should include documentation procedures and procedures for investigating and resolving any exceptions found during the search. Action Taken: LBU has subscribed to the software platform Verify Comply which will allow us to upload a list of all employees and vendors in bulk for exclusion monitoring in OIG, SAM and other federal and state exclusion lists. Ongoing monitoring will occur to include all new hires and new vendors. A report will be available to support and validate monitoring. Effectivity Date: Software implementation and training is scheduled for 1/7/2026 with the expectation that all vendors and employees will be monitored by 1/30/2026.
Name of auditee: Bishop (CSI) Non-Profit Housing Corporation HUD auditee identification number: 044-11134 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Anne Sackrison Position: Chief Executive Officer Telephone number: 5...
Name of auditee: Bishop (CSI) Non-Profit Housing Corporation HUD auditee identification number: 044-11134 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Anne Sackrison Position: Chief Executive Officer Telephone number: 586-753-9052 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding #2025-001: Effective May 1, 2025, the required monthly deposit to the reserve for replacements increased from $12,539 to $63,106 based on the capital needs assessment and replacement reserve analysis. The Corporation did not increase the monthly deposits and as of June 30, 2025, the reserve for replacements account is underfunded by $99,135. Comments on the Finding and Each Recommendation: Management should transfer $99,135 from the operating account in order to bring the reserve for replacements account current. Action(s) taken or planned on the finding: Agreed. On July 1, 2025, management transferred $99,135 to the reserve for replacements account.
Finding #2025-002 – Significant Deficiency and Other Noncompliance – Reporting. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.959, Passed through Texas Health and Human Services Commission, All contracts, Contract years: 09/01/23 – 08/31/24 and 09/...
Finding #2025-002 – Significant Deficiency and Other Noncompliance – Reporting. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.959, Passed through Texas Health and Human Services Commission, All contracts, Contract years: 09/01/23 – 08/31/24 and 09/01/24 – 08/31/25. Condition and context: In our testing of a sample of monthly billings and quarterly reports from throughout the fiscal year, we noted that reports were not being submitted within the required timelines for several reporting periods. Management communicated their delays to Texas Health and Human Services Commission (THHS), and their plan to rectify the delays. Phoenix Houses of Texas were able to file all delayed quarterly reports and monthly billings prior to June 30, 2025. THHS has approved all the delayed monthly billings and quarterly reports. Recommendation: Re-emphasize internal controls over timely grant billing and reporting to comply with grant contracts. Planned corrective action: All outstanding billings were subsequently submitted and billings are now current and submitted in accordance with required timelines. Corrective actions implemented include updates to Finance Department policies and procedures to formalize month-end closing and billing timelines and to strengthen oversight and monitoring controls. These changes ensure that billing and reporting are performed on a timely and ongoing basis. Responsible officer: Drew Dutton, CEO and Anunoy Mou, Finance Director. Estimated completion date: Completed September 2025.
Significant Deficiency Finding: 2025-001 Certification of Tenants Criteria and Condition The grant agreement requires ECS to (1) maintain complete tenant files in the San Francisco HMIS ONE System with hard-copy eligibility documents; (2) apply changes to tenant rent portions based on City and Count...
Significant Deficiency Finding: 2025-001 Certification of Tenants Criteria and Condition The grant agreement requires ECS to (1) maintain complete tenant files in the San Francisco HMIS ONE System with hard-copy eligibility documents; (2) apply changes to tenant rent portions based on City and County of San Francisco Department of Homelessness and Supporting Housing (HSH) notifications; and (3) perform required initial, annual, and interim recertifications under the Housing First program model. We noted instances where tenant files did not contain complete eligibility documentation and/or where required recertifications or updates to tenant rent portions were not performed or documented in accordance with the grant requirements. Context ECS provides rental assistance under the program described in Appendix A-2, which requires full documentation of tenant eligibility and strict adherence to rent-portion updates and recertification timelines. Of our 31 selections, we noted 6 instances where homelessness verification was missing, 6 instances where the rent portions based on HSH notifications were incorrect and 10 instances where the recertifications were not completed for the grant period under audit. Questioned Cost There are no questioned costs regarding this finding. Cause The exceptions result from inconsistent file maintenance and monitoring procedures, including insufficient review over documentation completeness and timeliness of recertifications. The issues were centered on tenant files managed by a third-party service provider. Effect Incomplete tenant files and untimely recertifications increase the risk of noncompliance with grant requirements and may result in incorrect tenant rent portions being charged or insufficient support for program eligibility. Repeat Finding This finding is not a repeat finding. Recommendation We recommend that ECS enhance its documentation and monitoring processes with its third-party property managers by implementing a standardized tenant file checklist, conducting periodic supervisory reviews to confirm that all eligibility documents and recertifications are completed and retained, and establishing a tracking process to ensure tenant rent portions are updated promptly based on HSH notifications. View of responsible officials Management agrees with the recommendation. Corrective Action Planned ECS has taken and will continue to take the following steps in the 2026 fiscal year to correct this deficiency. Step 1: Resources ECS began addressing Certificate of Tenancy errors with the hiring an Associate Chief of Real Estate and Asset Management in August, a Director of Property Management in October and a Property Management Compliance Manager in September. Step 2: Best Practices ECS has hired a consulting firm to correct Certificate of Tenancy errors at its one of its sites and will apply the best practices learned to all the affiliate and master lease sites. In addition, ECS has put together policies and procedures and has offered training to both ECS and subcontracted staff on Certificate of Tenancy. ECS will continue to offer compliance training as it takes over property management across all Master Lease sites and the affiliate portfolio. Step 3: Take control of property management Replace outsourced property management with ECS staff to better control Tenant documentation at all master lease and affiliate sites. Step 4: Quality and Compliance ECS has started in a few sites to review Tenant documentation and will expand this review to all sites across its entire portfolio. Implementation Date ECS will fully correct Certificate of Tenancy errors by June 30, 2026. Responsible Personnel The Chief Operating Officer and the Associate Chief of Real Estate and Asset Management.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
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