Corrective Action Plans

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Finding Number: 2025-026 Planned Corrective Action: The Florida Department of Children and Families (DCF) acknowledges the finding regarding subrecipient risk assessment and monitoring requirements. DCF recognizes the requirements set forth in 45 CFR 75.352(b) and (d) and section 402.7305(4), Florid...
Finding Number: 2025-026 Planned Corrective Action: The Florida Department of Children and Families (DCF) acknowledges the finding regarding subrecipient risk assessment and monitoring requirements. DCF recognizes the requirements set forth in 45 CFR 75.352(b) and (d) and section 402.7305(4), Florida Statutes, which require pass-through entities to evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward, and to conduct monitoring activities commensurate with the assessed level of risk. DCF has developed a standardized assessment tool to determine the risk level for each subrecipient. Risk assessments and monitoring activities have begun. And DCF will complete a comprehensive risk assessment of all active contracts using this tool. Based on the results, DCF will develop a risk-based schedule for contract monitoring site visits. DCF continues to evaluate its monitoring processes and allocate resources to strengthen oversight of subawards. While oversight activities occur across a variety of Department offices including financial monitoring, contract manager oversight, and administrative compliance reviews, those activities are not currently documented within a single, clearly defined risk-based monitoring framework aligned with the federal requirements referenced above. The efforts include implementing documented risk assessments and monitoring activities that incorporate administrative, fiscal, and programmatic considerations, as applicable, and support development of risk-informed monitoring schedules and improved documentation of oversight activities. Additionally, DCF is developing a broader monitoring roadmap to assess existing monitoring practices across programs and identify opportunities to enhance consistency, coordination, and documentation of monitoring activities aligned with federal requirements. Anticipated Completion Date: 12/31/2027 Responsible Contact Person: Tami Gonyea, Deputy Assistant Secretary - OCFW
Finding Number: 2025-006 Planned Corrective Action: Effective July 1, 2025, FCOM implemented new processes and procedures to enhance FFATA reporting controls and ensure the accuracy and timeliness of the subaward data reported in the SAM.GOV. Anticipated Completion Date: 7/1/2025 Responsible Contact...
Finding Number: 2025-006 Planned Corrective Action: Effective July 1, 2025, FCOM implemented new processes and procedures to enhance FFATA reporting controls and ensure the accuracy and timeliness of the subaward data reported in the SAM.GOV. Anticipated Completion Date: 7/1/2025 Responsible Contact Person: Tisha Womack
Finding Number: 2025-013 Planned Corrective Action: Effective July 1, 2025, FCOM implemented new processes and procedures to enhance FFATA reporting controls and ensure the accuracy and timeliness of the subaward data reported in the SAM.GOV. Anticipated Completion Date: 7/1/2025 Responsible Contact...
Finding Number: 2025-013 Planned Corrective Action: Effective July 1, 2025, FCOM implemented new processes and procedures to enhance FFATA reporting controls and ensure the accuracy and timeliness of the subaward data reported in the SAM.GOV. Anticipated Completion Date: 7/1/2025 Responsible Contact Person: Tisha Womack
Finding Number: 2025-005 Planned Corrective Action: Effective July 1, 2025, FCOM implemented new processes and procedures to enhance FFATA reporting controls and ensure the accuracy and timeliness of the subaward data reported in the SAM.GOV. Anticipated Completion Date: 7/1/2025 Responsible Contact...
Finding Number: 2025-005 Planned Corrective Action: Effective July 1, 2025, FCOM implemented new processes and procedures to enhance FFATA reporting controls and ensure the accuracy and timeliness of the subaward data reported in the SAM.GOV. Anticipated Completion Date: 7/1/2025 Responsible Contact Person: Tisha Womack
Finding Number: 2025-004 Planned Corrective Action: During training on the new Federal Funding Accountability and Transparency Act (FFATA) reporting system, the department understood federal guidance to require the creation of a new report each month, consistent with the process used in the previous...
Finding Number: 2025-004 Planned Corrective Action: During training on the new Federal Funding Accountability and Transparency Act (FFATA) reporting system, the department understood federal guidance to require the creation of a new report each month, consistent with the process used in the previous system. However, the department later discovered that the new system aggregates amounts cumulatively across reports. As a result, generating new reports each month inadvertently created the appearance of overstated expenditures. The correct procedure is to update the existing report rather than create a new one. This issue was identified and resolved within three months (three reporting periods). Since implementing the corrected process, the department’s reporting has been accurate and compliant. The Department will continue to follow the current procedure, which has proven effective and ensures the integrity of its reporting. Anticipated Completion Date: The department’s new process was implemented June 2025. Responsible Contact Person: Jim Lewandowski, Division of Administration, Chief of Finance and Accounting; Trisha Williams, Assistant Chief of Finance and Accounting
Corrective Action Plan (CAP) Award Information: NOAA Program Office: NOS Integrated Ocean Observations Systems (IOOS) Federal Award Numbers (FAIN): NA21NOS0120097, NA24NOSX012C0024, and NA23NOS0120243 Recipient Organization: Southeast Coastal Ocean Observing Regional Association Recipient UEI: EEL2L...
Corrective Action Plan (CAP) Award Information: NOAA Program Office: NOS Integrated Ocean Observations Systems (IOOS) Federal Award Numbers (FAIN): NA21NOS0120097, NA24NOSX012C0024, and NA23NOS0120243 Recipient Organization: Southeast Coastal Ocean Observing Regional Association Recipient UEI: EEL2LR5E2R85 Project Title: SECOORA: Delivering actionable coastal and ocean information from high-quality science and observations for the Southeast Project Period: 7/1/21-6/30/26 Criteria: During our single audit for the year ended June 30, 2025, we identified that required subawards were not reported in SAM.gov (previously in the FFATA Subaward Reporting System (“FSRS”)) within the 30-day FFATA reporting window, as required by 2 CFR Part 170 and NOAA award terms. This constitutes noncompliance with federal award requirements and may trigger remedies under 2 CFR § 200.339. Cause: The Association was subject to FFATA reporting requirements under its cooperative agreement with the Integrated Ocean Observing System (“IOOS”) Office within the National Oceanic and Atmospheric Administration (“NOAA”). The cause of the FFATA reporting lapses was an interpretation gap of requirements under a cooperative agreement versus a prime grant award, and management has agreed to promptly remediate and implement controls. The noncompliance resulted from a good-faith misunderstanding regarding the applicability of FFATA to cooperative agreements and did not stem from intentional misconduct or an overall deficient control environment. Immediate Corrective Actions Taken: The Association acknowledges lapses in timely reporting of first-tier subawards in the FSRS/SAM.gov and gaps in internal controls, including procedure documentation, tracking of subaward obligation dates, and staff training. The overdue FSRS/SAM.gov reports will be submitted, and NOAA/IOOS will be provided documentation of completion. Long-Term Corrective Actions / Preventive Measures: The Association is in the process of establishing written internal controls, including procedures and tracking mechanisms to ensure timely FFATA reporting, as well as provide training to grants management personnel responsible for FFATA submissions to ensure timely and accurate reporting. Management will continue to use standardized subaward agreements to clearly capture obligation dates and FFATA applicability. Subawards will not be fully executed in the system until the FFATA data fields are completed. There will be a separation of duties for distinct roles for preparer and reviewer/approver. The Association will evidence retention with a central archive of FSRS confirmations, checklists, and supporting documentation and maintain a tracking log with automated reminders for key reporting deadlines. Responsible Personnel: Chief Financial Officer: Megan Lee – Oversees, Reviews, and Approves FFATA reporting compliance and SAM.gov reporting. Ensures required reporting of subaward obligations for FFATA reporting on a monthly basis and ensures timely data submission. Pre/Post Award Grant Specialist– Prepares required reporting of subaward obligations for FFATA reporting on a monthly basis. Timeline for Completion Corrective Action Responsible Party Completion Date Submit overdue FFATA report Chief Financial Officer 06/30/2026 Update written procedures Chief Financial Officer 04/30/2026 Staff online training on FFATA requirements Chief Financial Officer 05/31/2026 Implement dual review of reporting Chief Financial Officer 04/30/2026 Internal Monitoring and Verification: The Association will perform quarterly internal reviews of a sample of subawards to verify: timeliness, data accuracy, documentation, and adherence to reporting process. Finally, the Chief Financial Officer and Pre/Post Award Grant Specialist will report to the Executive Director and escalate any issues identified and implement corrective training as needed. Certification: I certify that the information provided in this Corrective Action Plan is accurate and that the organization is committed to full compliance with the terms and conditions of the NOAA award and the Uniform Guidance (2 CFR Part 200), including remediation of noncompliance consistent with 2 CFR § 200.339.
Finding No.: 2025-003 – Disbursements Reporting Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster – Pell Grant Program and Federal Direct Loan (FDL) Program ALN Number: 84.063, 84.268 Federal Award Year: July 1, 2024 – June 30, 2025 Criteria Institutions...
Finding No.: 2025-003 – Disbursements Reporting Federal Agency: U.S. Department of Education Program Name: Student Financial Assistance Cluster – Pell Grant Program and Federal Direct Loan (FDL) Program ALN Number: 84.063, 84.268 Federal Award Year: July 1, 2024 – June 30, 2025 Criteria Institutions submit Direct Loan, Pell Grant, TEACH Grant, and IASG origination records and disbursement records to the COD system. Origination records can be sent well in advance of any disbursements, as early as the institution chooses to submit them for any student the institution reasonably believes will be eligible for a payment. An institution follows up with a disbursement record for that student no earlier than (1) seven calendar days prior to the disbursement date under the Advance or Heightened Cash Monitoring 1 payment methods, or (2) the date of the disbursement under the Reimbursement or Heightened Cash Monitoring 2 Payment Method. The disbursement record reports the actual disbursement date and the amount of the disbursement. ED processes origination and/or disbursement records and returns acknowledgments to the institution. The acknowledgments identify the processing status of each record: Rejected, Accepted with Corrections, or Accepted. In testing the origination and disbursement data, the auditor should be most concerned with the data ED has categorized as accepted or accepted with corrections. Institutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data. Institutions may do this by reporting once every 15 calendar days, bi-weekly or weekly, or may set up their own system to ensure that changes are reported in a timely manner. Title 2 U.S. Code of Federal Regulations Part 200 (2CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Conditions Found For two (2) out of 69 Pell COD Reports selected for test work, the required Pell student payment data was reported to the Common Origination and Disbursement (COD) website 52 days after disbursement, which exceeds the 15-day timeframe required by federal regulations. For one (1) out of 69 Pell COD Reports selected for test work, the required Pell student payment data was reported to the Common Origination and Disbursement (COD) website 261 days after disbursement, which exceeds the 15-day timeframe required by federal regulations. For four (4) out of 69 Pell COD Reports and three (3) out of 113 FDL COD Reports selected for test work, the Cost of Attendance was misreported to the COD website. There was no follow-up by the University to correct the discrepancies. For ten (10) out of 69 Pell and ten (10) out of 113 FDL COD Reports selected for test work, the transaction number did not agree between the FASFA Submission Summary Form and the COD website. Cause The cause of the conditions found is insufficient review to ensure that accurate disbursement reporting is occurring on a timely basis, all records submitted to COD were accepted, and, for those that were rejected, that corrected data is submitted within the required timeframe. Possible Asserted Effect The possible effect of the condition found is that the University may not be reporting Pell and FDL disbursements to COD completely, accurately, and in a timely manner. Questioned Costs No questioned costs were identified. Statistical Sampling The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding Yes; 2024-002 Views of Responsible Officials Management accepts this finding and notes several issues that affected the submissions including staffing onboarding and training, submission review, and deadline controls. Management continues to fill positions experiencing unexpected turnover and to improve training for current and newly hired staff in order to restore adequate staffing levels and ensure continuity of COD reporting responsibilities. From May through September 2025, management retained Blue Icon Advisors (BIA) to provide dedicated coaching and support for improved onboarding and compliance knowledge, including providing specialized training to the Loan Manager relative to federal regulations and proper loan record management. Management is implementing processes to improve the weekly review and update of Cost of Attendance (COA) information and CPS transaction numbers to further ensure institutional records are aligned with COD data and to reduce the risk of mismatched records. Management has also strengthened internal controls with improvements to processes which enhance the monitoring of submission deadlines, review of file acceptance reports, and identification and correction of electronic records issues prior to submission. These improvements include the increased and more effective utilization of COD-delivered reports (including Pell Reconciliation and Anticipated Disbursement Reports) and institutional and PeopleSoft reports and queries, with reviews conducted on a weekly basis to promptly identify record discrepancies requiring resolution. Anticipated Completion Date March 2026 - completed Responsible Person Nicole Adner, Director of Financial Aid
Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-...
Finding 2025-002 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs - Federal Work-Study Community Service Requirement Not Met and Failure to Report FWS Earnings (significant deficiency): Criteria – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities unless the institution has received an approved waiver from the Department of Education. Per 34 CFR § 675.19(b), institution must maintain fiscal control and accountability over FWS funds and comply with all reporting requirements established by the Secretary. This includes accurately reporting FWS student earnings through required federal systems and maintaining documentation to support reported activity. Condition - Based on documentation provided for the 2024–2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, only $1,057 was identified as wages paid to students employed in community service activities. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from the U.S. Department of Education of not meeting the required 7 percent community service expenditure threshold. Additionally, during review of the institution’s 2024–2025 Federal Work-Study (FWS) activity, it was noted that FWS student earnings were not reported to the Common Origination and Disbursement (COD) System. The institution’s financial aid records and payroll registers indicate that students earned a total of $23,131 in FWS wages during the award year; however, no corresponding COD submissions or COD acknowledgment files were provided for review to demonstrate that these earnings were reported as required. Cause – The infraction appears to have resulted from failure to monitor compliance with the 7 percent FWS community service requirement and inadequate internal controls to ensure timely and accurate reporting of FWS earnings. Effect – The institution did not comply with the statutory community service spending requirement and FWS earnings were not reported through required federal reporting channels, limiting transparency and federal oversight. Questioned Costs - $0 Perspective – The Federal Work-Study Program includes explicit statutory spending and reporting requirements that are considered key compliance controls. In this instance, the institution expended approximately 4 percent of its authorized FWS allocation ($1,057 of $26,649) on community service wages, compared to the required 7 percent, resulting in a 43 percent shortfall from the required threshold. In addition, 100 percent of FWS earnings identified during testing ($23,131) were not reported to the COD System, as no submission or acknowledgment records were available. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen monitoring of community service requirements and establish formal FWS reporting controls and perform periodic internal audits of FWS expenditures and reporting to identify and correct issues prior to year-end and federal reporting deadlines. Management’s Response – Per 34 CFR § 675.18(g), each institution participating in the Federal Work-Study (FWS) Program must use at least 7 percent of its total FWS allocation to compensate students employed in community service activities. Based on documentation provided for the 2024-2025 award year, the institution was authorized a total of $26,649 in Federal Work-Study funds. Of this amount, $1,057 was identified as community service wages. No documentation was provided to demonstrate that additional community service wages were paid or that a waiver from ED was requested or approved
Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. F...
Information on the federal program: Federal Direct Student Loans, FAL No. 84.268, June 30, 2025; Federal Pell Grant Program, FAL No. 84. 063, June 30, 2025; Federal Supplemental Educational Opportunity Grant, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025. Finding 2025-001 - U.S. Department of Education (ED), Title IV Student Financial Aid Programs- Pell Grant Disbursement Reported in Incorrect Award Year (significant deficiency): Criteria – Per 34 CFR § 690.61, institutions must ensure that Pell Grant disbursements are made and reported for the correct award year and in accordance with program requirements. Institutions are required to report Pell Grant disbursements in the correct award year and submit all disbursement records by the published COD closeout deadline for the applicable award year Disbursements not reported by the closeout deadline may not be shifted to a subsequent award year to compensate for missed reporting. Condition - For the 2024–2025 award year, testing revealed that one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 during the 2023–2024 award year. The institution failed to process and report the disbursement in COD prior to the 2023–2024 COD closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024–2025 award year. Cause – The infraction appears to have resulted from failure to monitor and comply with COD Pell Grant closeout deadlines and inadequate controls to ensure disbursements are reported in the correct award year. Effect – Pell Grant disbursement activity was reported inaccurately to the Department of Education. Reporting the disbursement in the incorrect award year compromises the accuracy and integrity of federal Pell reporting. Misreported Pell activity increases the risk of required data corrections and program review findings. Questioned Costs - $204 Perspective – Accurate and timely reporting of Pell Grant disbursements by award year is a key Title IV compliance control, as Pell Grant funding is awarded, monitored, and closed out on an annual basis. In this instance, one (1) out of ten (10) students tested (10%) had a Pell Grant disbursement that was reported in an incorrect award year due to failure to meet the applicable COD closeout deadline. Although the dollar amount involved was limited, the error demonstrates that controls designed to ensure award-year accuracy and timely COD reporting did not operate effectively. Repeat Finding – No Auditor’s Recommendation – We recommend that the institution strengthen closeout monitoring procedures, ensure award-year accuracy, and perform periodic internal reviews. Management’s Response – For the 2024–2025 award year, one (1) out of ten (10) students selected for testing became eligible for a Federal Pell Grant disbursement of $204 in the 2023-2024 award year. The institution failed to process the disbursement in COD prior to the 2023-2024 closeout deadline. To compensate, the institution incorrectly posted the $204 disbursement to the student’s account and reported the payment to COD under the subsequent 2024-2025 award year. Per 34 C.F.R. § 690.61 and the U.S. Department of Education’s Common Origination and Disbursement (COD) system requirements, institutions must report Pell Grant disbursements in the correct award year and by the published COD closeout deadline. A. Agree B. Conditions That Caused the Infraction a. Upon further review of the student’s account ledger, the institution identified that a $204 Pell Grant disbursement was incorrectly reflected for the Fall 2024 term. The student did not attend or enroll in Fall 2024; therefore, no Title IV funds should have been associated with that payment period. b. The Pell award was disbursed but was not properly aligned with the student’s actual enrollment timeline. Although the student attended Summer 2024 and Spring 2025, the institution did not submit a Student Bill Letter (SBL) for Spring 2025 because the student was enrolled in only one course. At the time, institutional practice did not require SBL submission for students enrolled less than half time or in a single course. As a result:  The Pell disbursement was not aligned with the correct payment period.  The $204 Pell award was incorrectly reflected as a Fall 2024 disbursement instead of being applied to the appropriate term.  This created a compliance issue related to Title IV disbursement timing and documentation.  Subsequent guidance from FA Solutions clarified that SBLs must be submitted for all enrolled students, regardless of enrollment intensity, to ensure proper alignment of Title IV funds with the correct payment period. C. The School’s Planned Corrective Action Plan (CAP)- The institution will implement the following corrective actions to address and prevent recurrence of this finding: a. Ledger Correction  The Student Accounts Office will revise the student’s ledger to accurately reflect the $204 Pell Grant disbursement as a Summer 2024 credit/refund, the term in which the student had eligible enrollment.  Any misapplied term references will be removed to ensure alignment with Title IV regulations. b. Policy and Procedure Update  Institutional procedures will be updated to require submission of Student Bill Letters (SBLs) for all enrolled students, including those enrolled in a single course or less than half time, when Title IV funds are involved.  This requirement will be documented in both Financial Aid and Student Accounts procedural manuals. c. Staff Training  Financial Aid and Student Accounts staff will receive training on updated SBL submission requirements and Title IV disbursement alignment.  Training will include review of payment period eligibility, enrollment intensity, and documentation standards. d. Cross Departmental Review Process  Financial Aid and Student Accounts will implement a secondary review process prior to Pell disbursement to confirm:  Enrollment for the applicable term  Presence of a submitted SBL  Correct payment period assignment D. Responsible Officials a. Dr. Gina Garlington, Financial Aid Administrator Responsible for Title IV compliance, staff training, SBL submission, and oversight of Pell disbursement procedures. b. CLA, Third Party Servicer and School’s Student Accounts Office Responsible for ledger corrections, and reconciliation of student accounts. E. Expected Timeline for Implementation a. All timelines have been complete F. Monitoring of Corrective Action Plan a. The CAP will be monitored through the following mechanisms:  Monthly reconciliation reviews between Financial Aid and Student Accounts  Random sampling of Pell disbursements to confirm correct payment period alignment.  Annual internal compliance review of SBL submissions and Title IV disbursements.  Documentation of corrective actions retained for audit and program review purposes.  Any discrepancies identified during monitoring will be addressed immediately and documented. G. Status of CAP Prior to This Finding a. This is the first occurrence of this finding for the institution. b. No prior corrective action plan existed addressing this specific issue. View of Responsible Officials- Officials agree with findings
2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 ...
2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 out of 21 contractor and subcontractor certified payrolls tested were not submitted timely. VOAWW recognizes that timely receipt and review of certified payrolls is essential to ensuring compliance with federal wage requirements. To strengthen internal controls and ensure certified payrolls are consistently obtained, reviewed, and retained, VOAWW will implement the following corrective actions: Implementation of Certified Payroll Submission Controls Before the end of FY26, VOAWW will implement internal controls requiring contractors and subcontractors to submit certified payrolls with each pay application. These controls will include: • A requirement that certified payrolls be submitted prior to payment • A standardized checklist for verifying receipt of certified payrolls • Documentation of the review and approval process • Follow up procedures for missing or incomplete payrolls These steps will ensure certified payrolls are consistently obtained and reviewed before payment is released. Training for Staff on Wage Rate Requirements Beginning in FY26, staff responsible for managing HUD funded construction projects will receive training on: • Davis-Bacon and related wage requirements • Certified payroll documentation standards • Review procedures and red flags • Requirements under 29 CFR Part 5 Contractor Communication and Expectations Before the end of FY26, VOAWW will update contractor communication materials to clearly outline certified payroll requirements, including: • Submission timelines • Required documentation • Consequences for noncompliance • Points of contact for questions or clarifications These expectations will be reinforced during project kick off meetings and throughout the contract period. Centralized Tracking of Certified Payrolls By the end of FY26, VOAWW will implement a centralized tracking log for all certified payroll submissions. This log will document: • Receipt dates • Review dates • Reviewer initials • Any follow up actions taken This will ensure a complete audit trail and consistent monitoring of compliance. These corrective actions will strengthen VOAWW’s internal controls over Wage Rate Requirements, ensure timely receipt and review of certified payrolls, and reduce the risk of noncompliance with federal labor standards. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026
2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA...
2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA rate of 17.2% while moving to the de minimis rate but did not complete the required true-up to 10% for a three-month period prior to the de minimis rate being increased to 15%. VOAWW has reviewed the circumstances that led to this error and determined that it occurred during an unusual and infrequent set of conditions. Transitions between indirect cost methodologies are rare and increases to the federal de minimis rate are also uncommon. As a result, this specific scenario is unlikely to recur. Nonetheless, VOAWW recognizes the importance of strengthening controls around indirect rate changes to ensure accurate application during any future transitions. To address this finding and strengthen controls over indirect cost rate application, VOAWW will implement the following corrective actions: • Formal Rate Transition Procedures – Before the end of FY26, the Finance Department will develop and document a standardized procedure for transitioning between indirect cost rates, including effective dates, interim rate requirements, required true-ups, and approval checkpoints to ensure accurate application during any future rate changes. • Centralized Indirect Rate Tracking – Before the end of FY26, the Finance Department will maintain a centralized indirect rate schedule that includes approval documentation, effective dates, and any required adjustments. This schedule will be referenced during invoice preparation and review to ensure consistent and accurate rate application across all federal awards. • Contract Kick-Off Meetings and Cross-Department Alignment – Before the end of FY26, Finance, Grants, and Contract Compliance will implement contract kick-off meetings for new awards and significant contract amendments to align on billing requirements, approved indirect cost rates, effective dates, and other critical compliance information and ensure consistent communication across departments. • Documentation of Important Communications – Before the end of FY26, VOAWW will implement guidance for documentation of important communications with funders that have a single audit impact. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026
The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budge...
The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budget decision to provide additional Title I funding to Bowling Green Elementary to support after-school programming, without fully accounting for per-pupil allocation. Historically, Bowling Green Elementary has served one of the highest concentrations of students from low-income families in the District, and the additional allocation was intended to ensure continuity of extended learning opportunities for students with significant academic need. While this decision was grounded in student need, the District recognizes that the additional funds were not fully reconciled with updated poverty data and required rank-order calculations. The District has demonstrated compliance with rank and serve requirements in prior years; however, to prevent recurrence, we are strengthening our internal controls. Beginning immediately, the District will implement a structured monthly review of Title I school allocations involving the Title I Program Specialist, the Finance Director, and the Deputy Superintendent to ensure that the 2025-2026 allocations align with current poverty data and PSES calculations. Additionally, the District will seek guidance from the Florida Department of Education Title I Office to confirm that our procedures fully meet all regulatory expectations. The District is confident that these corrective actions will ensure full compliance in 2025-2026 moving forward and will strengthen the integrity of our allocation processes.
Corrective Action Plan Corrective Action Plan – Uniform Guidance Audit Finding Organization: Scripps Health and Affiliates Federal Agency: U.S. Department of Homeland Security Pass-Through Agency: California Governor’s Office of Emergency Services UEI Number: JJRCL53EXL36 Audit Period: Year Ended Se...
Corrective Action Plan Corrective Action Plan – Uniform Guidance Audit Finding Organization: Scripps Health and Affiliates Federal Agency: U.S. Department of Homeland Security Pass-Through Agency: California Governor’s Office of Emergency Services UEI Number: JJRCL53EXL36 Audit Period: Year Ended September 30, 2025 Finding Reference Number: 2025-001 Federal Program: COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Finding Summary: The organization did not employ an adequate internal control review of payroll expenditures to support activities allowed or unallowed and allowable costs/cost principles related to payroll expenditures reimbursed for the project worksheet. Corrective Action Plan: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late fiscal year 2022 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: revised the timekeeping policy to clarify employee and manager responsibilities, modified “failure to comply” provisions, deployed educational programs for both management and staff, reviewed/improved Kronos and UKG Pro Time and Attendance system automated notifications, and training resources have been available to management and staff via our Scripps intranet site. Leadership monitors policy compliance by individual employee and managers via systemwide reporting on a biweekly basis. Responsible Officials & Contact Person: Brett Tande, Executive Vice President & Chief Financial Officer Scripps Health and Affiliates Expected Completion Date: Completed in fiscal year 2022. As the expenditures in the project worksheet were incurred from the beginning of the COVID-19 pandemic, the corrective action plan put in place during 2022 could not previously remediate the project; however, all payroll expenditures incurred after the end of fiscal year 2022 have these corrective actions in place.
Program: Community Development Block Grant Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: B-24-UC-06-0504 and 2025; B-20-UW-06-0504 and 2021 Compliance Requirements: Reporting Type of Finding: Material Weaknes...
Program: Community Development Block Grant Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: B-24-UC-06-0504 and 2025; B-20-UW-06-0504 and 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Criteria: CFR Appendix A to Part 170I(a)(2), Reporting Requirements, states the recipient must report each subaward to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the end of the month following the month in which the subaward was issued. Condition: During our testing of the County’s compliance with reporting requirements, we noted the County did not submit the required subaward data to FSRS. Cause: The department was unaware of this compliance requirement. Effect: Reports were not submitted to FSRS in accordance with the reporting requirements per Appendix A to Part 170I(a)(2). Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling : We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: (Refer to Chart/Table to Finding 2025-003) Repeat Finding from Prior Years: No. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR Appendix A to Part 170I(a)(2). Management Response and Corrective Action Plan: 1. Person Responsible: Francisco Padilla, Community Development Analyst 2. Corrective action plan: Concur. We will adhere to our policies and procedures to ensure reports are submitted to FSRS in accordance with 2 CFR Appendix A to Part 170I(a)(2). 3. Anticipated Implementation date: April 30, 2026
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Pass-Through Entity: California Governor’s Office of Emergency Services Award No. and Year: Multiple Compliance Requirements: Subrecipient Monitoring Typ...
Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Pass-Through Entity: California Governor’s Office of Emergency Services Award No. and Year: Multiple Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR), Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.332, requires that pass-through entities: • Evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. • Verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. • Verify whether the subrecipient is suspended, debarred, or otherwise excluded before entering into a covered transaction. Condition: For two (2) out of two (2) subrecipients selected for testing, the subrecipient risk assessments were not performed by the department and the subrecipient was not checked for suspension or debarment prior to entering into the agreement. For one (1) out of two (2) subrecipients selected for testing, evidence could not be provided to verify the County reviewed the subrecipient’s single audit report to ensure timely corrective action was taken on audit findings, as applicable. Cause: Internal controls were not in place to ensure compliance with subrecipient monitoring requirements. Effect: Ineffective controls over this area of compliance could result in noncompliance occurring for a subrecipient and not being detected. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) subrecipients out of a population of two (2) was selected for testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the department enhance internal controls to ensure compliance with subrecipient monitoring requirements. Management Response and Corrective Action Plan: 1. Person Responsible: Monique Vansuch, Fiscal Administrator 2. Corrective action plan: The Sheriff-Coroner Department will complete and document risk assessments, suspension/debarment status and verify subrecipient’s single audit report is reviewed and corrective actions are implemented prior to subaward issuance. 3. Anticipated Implementation date: June 30, 2026
Program: Block Grants for Community Mental Health Services Federal Financial Assistance Listing Number: 93.958 Federal Grantor: U.S. Department of Health and Human Services Pass Through: California Department of Health Care Services Award No. and Year: 68-0317191 and 2024 Compliance Requirements: Su...
Program: Block Grants for Community Mental Health Services Federal Financial Assistance Listing Number: 93.958 Federal Grantor: U.S. Department of Health and Human Services Pass Through: California Department of Health Care Services Award No. and Year: 68-0317191 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR Part 200.332(a), Requirements for Pass-Through Entities, states that all passthrough entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for three (3) out of five (5) subawards selected for testing from the HCA’s Block Grants for Community Mental Health Services program • Federal Award Identification Number (FAIN) • Federal award date of award to recipient by the Federal Agency • Identification of whether or not the award is R&D • Indirect cost rate for the Federal award (including if the de-minimus rate is charged) Cause: The HCA’s procedures did not consistently ensure that the required award information and applicable requirements were communicated to the subrecipients at the time of subaward. Effect: The County’s control policies were not consistently followed which require compliance with the Subrecipient Monitoring requirements as found in 2 CFR 200.332. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of three (3) of five (5) subrecipients were sampled. The condition noted above was identified during our procedures related to subrecipient monitoring. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Management Response and Corrective Action Plan: 1. Person Responsible: Brittany Davis, HCA Procurement & Contract Services Division Manager 2. Corrective action plan: HCA will coordinate with internal stakeholders on the review of all subrecipient contracts and applicable funding source requirements to ensure that subaward criteria and subrecipient responsibilities are included. Amendments or subrecipient notification letters will be issued, as needed, to notify contractors of subrecipient responsibilities. 3. Anticipated Implementation date: June 30, 2026
The City has commenced the preparation of the FFATA report and is working toward full compliance with reporting requirements. The corrective action is expected to be fully implemented by Fiscal Year 2025/2026. The contact persons for this corrective action are Sabrina Chavez, Director of Public Serv...
The City has commenced the preparation of the FFATA report and is working toward full compliance with reporting requirements. The corrective action is expected to be fully implemented by Fiscal Year 2025/2026. The contact persons for this corrective action are Sabrina Chavez, Director of Public Services, and Martin E. Martinez, Principal Management Analyst, of the City of Perris.
Recommendation We recommend that the Department continue to monitor its monitoring activities over subrecipients, to ensure that they are being performed timely. Management Response Corrective Action The Department acknowledges the corrective action related to the completion of required WIOA monitor...
Recommendation We recommend that the Department continue to monitor its monitoring activities over subrecipients, to ensure that they are being performed timely. Management Response Corrective Action The Department acknowledges the corrective action related to the completion of required WIOA monitoring activities and has taken concrete steps to bring monitoring into compliance. NMDWS has scheduled onsite monitoring reviews and issued formal notification letters to all four subrecipients, as outlined below: • Southwestern Local Workforce Development Board: Notification letter sent January 26, 2026; onsite monitoring scheduled for March 9–13, 2026 • Northern Area Local Workforce Development Board: Notification letter sent January 26, 2026; onsite monitoring scheduled for April 20–24, 2026 • Workforce Connection of Central New Mexico: Notification letter sent January 5, 2026; onsite monitoring scheduled for May 4–11, 2026 • Eastern Area Workforce Development Board: Notification letter sent January 26, 2026; onsite monitoring scheduled for May 18–22, 2026 The Department has completed Program Years 2022, 2023 and 2024. In addition, the Department has also completed a Program Year 2024 risk assessment, which is now incorporated into the grant agreements. The WIOA Monitoring Unit will continue to utilize the Department’s Grant Risk Assessment tool for future grant agreements to ensure consistent and risk-informed monitoring. Finally, the WIOA Monitoring Unit has drafted a comprehensive subrecipient monitoring policy. This policy will establish clear monitoring standards for subrecipients and pass-through entities under WIOA Title I-B and related discretionary awards, including monitoring frequency, scope, and requirements for monitoring letters and reports. These actions are intended to address the identified deficiencies and strengthen the Department’s monitoring framework moving forward. Due Date of Completion: June 30, 2026 Responsible Party(ies): Administrative Services Division Director
Finding No. 2025-008 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that State did not communicate the following award information required under 2 CFR 200.332: • Subrecipient...
Finding No. 2025-008 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that State did not communicate the following award information required under 2 CFR 200.332: • Subrecipient’s unique entity identifier; • Federal Award Date; • Identification of whether the Federal award is for research and development; and • Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with 200.414). Corrective Action Plan DBEDT OPSD will strengthen internal controls over subaward identification and monitoring subrecipients to ensure that subrecipient monitoring requirements are met. The Program will communicate with the subrecipient to record their UEI. Program will supply the subrecipient with the date of the federal award, the indirect cost rate for the Federal award per CFR 200.414, and information on whether the award is for research and development. The Program will continue to supply subrecipient with Period of Performance Start and End Date, Budget Period Start and End Date, and the Assistance Listing number. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026
Finding No. 2025-007 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that the State did not submit FFATA reports for most of the active grant agreements open for the program. C...
Finding No. 2025-007 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that the State did not submit FFATA reports for most of the active grant agreements open for the program. Corrective Action Plan DBEDT OPSD will strengthen internal controls over subaward identification and reporting. This will include hiring and training staff to support federal grant administration and management-level review of all subawards to ensure FFATA reporting is complete and timely. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026
Finding No. 2025-006 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that for various samples, the time between drawdown and disbursement of federal funds was up to 266 days el...
Finding No. 2025-006 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that for various samples, the time between drawdown and disbursement of federal funds was up to 266 days elapsed. Indicating that cash management controls were not operating to minimize the time between transfer and disbursement. Corrective Action Plan OPSD DBEDT will ensure that program personnel are familiar with all federal requirements, including ensuring that funds are disbursed timely. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026
Finding No. 2025-005 ALN No. 10.179 Program Title: Micro-Grants Food Security Program Grant Award No.: AM200100XXXG132 21MGFSPHI1003-00 AM22MGFSPHI1007-04 23MGFSPHI1011-00 24MGFSPHI1016-00 Condition An elapsed time of 583 days between the drawdown and disbursement date of funds for the program and t...
Finding No. 2025-005 ALN No. 10.179 Program Title: Micro-Grants Food Security Program Grant Award No.: AM200100XXXG132 21MGFSPHI1003-00 AM22MGFSPHI1007-04 23MGFSPHI1011-00 24MGFSPHI1016-00 Condition An elapsed time of 583 days between the drawdown and disbursement date of funds for the program and that the check date of 01/24/2025 occurred after the grant period expiration of 09/29/2024. Indicating that cash management controls were not operating to minimize time between transfer and disbursement and that the period of performance was unauthorized to be extended past the budget date. Corrective Action Plan Concur. The Hawaii Department of Agriculture and Biosecurity (DAB) will change administrative procedures for drawdown and disbursement of federal funds under the Micro-Grants Food Security Program. DAB will process the grant contracts and payments in batches of about 100 micro-grants per month, and federal drawdown will not occur until about a batch of 100 contracts have been executed. Additional staff hired for grant processing will expedite the payment process to ensure conformity with the 25-day disbursement timeline. Person Responsible Brendan Akamu, Market Development Branch Manager Anticipated Date of Completion Corrective action plan will be implemented in April 2026.
Earmarking (Material Weakness in Internal Control and Noncompliance) Cluster name: WIOA Cluster Assistance Listings number and program name: 17.258 WIOA Adult Program 17.259 WIOA Youth Program 17.278 WIOA Dislocated Worker Formula Grants Recommendation: The County should strengthen WIOA Youth Activi...
Earmarking (Material Weakness in Internal Control and Noncompliance) Cluster name: WIOA Cluster Assistance Listings number and program name: 17.258 WIOA Adult Program 17.259 WIOA Youth Program 17.278 WIOA Dislocated Worker Formula Grants Recommendation: The County should strengthen WIOA Youth Activities program policies and procedures to ensure no less than the required 20 percent of its monies is spent to provide in-school and out-of-school youth with paid and unpaid work experience, retain qualified in-school and out-of-school youth, and consistently monitor the County's and subrecipients spending throughout the award period. Contact Person(s): Adam Garrard, WIOA Executive Director Anticipated completion date: June 30, 2026 County Discussion: Concur: The County will take corrective actions to strengthen WIOA Youth program policies, procedures, and oversight to ensure compliance with the 20 percent work experience requirement. This includes ongoing monitoring and oversight of sub-recipient expenditures, addressing barriers to work experience opportunities, and increasing engagement and enrollment of both in-school and out-of-school youth. These activities will include the following: 1) include local school counselors and administrators to support recruitment of in-school youth; 2) engage community partners with access to out-of-school youth; and 3) support outreach, enrollment, and retention strategies to attract eligible youth participants.
Condition: Northeastern Illinois University (University) did not report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for the Higher Education Institutional Aid grants. Planned Corrective Action: The University wil...
Condition: Northeastern Illinois University (University) did not report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for the Higher Education Institutional Aid grants. Planned Corrective Action: The University will review applicable guidelines and assign the responsibility to the appropriate office. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026
Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective act...
Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026
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