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Finding 1230073 (2024-029)
Material Weakness 2024
State of Nevada
NV
Subrecipient Monitoring
OAG CORRECTIVE ACTION PLAN Assistance Lis􀆟ng Number (ALN): 21.027 Eide Bailly Finding Number: 2024-029 Contact Person: John Dekoekkoek, Office of the A􀆩orney General Chief Financial Officer Summary of The Finding: The review determined that a risk assessment was not performed and subrecipient monito...
OAG CORRECTIVE ACTION PLAN Assistance Lis􀆟ng Number (ALN): 21.027 Eide Bailly Finding Number: 2024-029 Contact Person: John Dekoekkoek, Office of the A􀆩orney General Chief Financial Officer Summary of The Finding: The review determined that a risk assessment was not performed and subrecipient monitoring was not performed. Office of the Attorney General (OAG) Response: The original intent of the OAG being involved with the subaward to Legal Aid of Southern Nevada was only to be the Fiscal Agent of the award. As only the fiscal agent, we understood that the GFO would be responsible for completing the risk assessments and any required monitoring. However, due to staff changes there appears to have been some miscommunication. If we would have known that we were going held accountable for risk assessments and monitoring, we would have folded this subrecipient into the established grant processes in place at the O􀆯ice of the Attorney General. In 2025 the Nevada Governor’s Office of Federal Assistance (OFA) released the updated Nevada Grant Policy Manual. This manual includes grant policies that are in line with 2CFR Part 200. The OAG follows the policies included in the manual including the Policy 010-004 Pre-Award Risk Assessments and Policy 010-015 Monitoring Subrecipients. Therefore, the OAG considers the Corrective Action Plan, already implemented.
View Audit 411357
Finding 1230070 (2024-026)
Material Weakness 2024
State of Nevada
NV
Subrecipient Monitoring
Audit Finding: 2024-026 COVID-19 Homeowner Assistance Fund, 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Summary: Subrecipient monitoring policies not in place. Subawards and disbursements did not contain all the required information, an evaluation of each sub...
Audit Finding: 2024-026 COVID-19 Homeowner Assistance Fund, 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Summary: Subrecipient monitoring policies not in place. Subawards and disbursements did not contain all the required information, an evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed. Recommendation: Implement internal controls to ensure compliance with subrecipient monitoring requirements. Agency Response: The Division agrees with the finding. Corrective Action: The Division will establish subrecipient monitoring policies. The Division will also establish an internal audit and compliance committee to enhance oversight of existing policies for assessing, monitoring, and sharing best practices across its business. The internal audit and compliance committee will be responsible for reviewing internal controls and policies on an annual basis, following up on any audit findings and ensuring follow-through of corrective action plans. Adoption of Corrective Action: January 2025 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov
View Audit 411357
Finding 1230068 (2024-023)
Material Weakness 2024
State of Nevada
NV
School Nutrition Programs Subrecipient Monitoring Reporting
Finding Number: 2024-023 Summary of finding: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for p...
Finding Number: 2024-023 Summary of finding: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Recommendation: The State agency should implement internal controls to ensure subaward information is submitted in accordance with the FFATA or to seek guidance for applicability towards permanent agreements with annual obligations. CAP Response: We will continue working with the USDA to establish a clear procedure and guidance for reporting FFATA requirements related to meal claims. At this time, the USDA does not consider meal claims to be subawards. We have requested clarification and a procedure regarding FFATA reporting for meal claims but have not yet received a response. Anticipated date of completion: Ongoing.
View Audit 411357
Finding 1230036 (2024-005)
Material Weakness 2024
Valley Health Associates
CA
Subrecipient Monitoring Material Weakness Reporting § 200.512
Planned Corrective Action: Valley Health Associates will ensure accounting methods are consistent and include proper documentation. And, immediately ensure reports are submitted in a timely manner for the Medi-caid program.
Planned Corrective Action: Valley Health Associates will ensure accounting methods are consistent and include proper documentation. And, immediately ensure reports are submitted in a timely manner for the Medi-caid program.
View Audit 411282
Finding 1230035 (2024-004)
Material Weakness 2024
Valley Health Associates
CA
Reporting Subrecipient Monitoring § 200.501
Planned Corrective Action: We understand the severity of the finding and will maintain a Schedule of Expenditure of Federal Awards to be updated at month-end close as well as documented timesheets for all staff included in the expenditures list. This will be accomplished by providing training for pr...
Planned Corrective Action: We understand the severity of the finding and will maintain a Schedule of Expenditure of Federal Awards to be updated at month-end close as well as documented timesheets for all staff included in the expenditures list. This will be accomplished by providing training for procurement, finance, and administrative staff on: . Recognizing when a transaction exceeds the threshold. . Collecting and organizing supporting documentation. Valley Health Associates shall conduct periodic audits to: . Review SEFA report. . ldentify gaps or missing documentation and correct them promptly. . Document findings and corrective actions.
View Audit 411282
Finding 1230032 (2024-004)
Material Weakness 2024
SC UPLIFT COMMUNITY OUTREACH
SC
Subrecipient Monitoring Procurement, Suspension & Debarment
Finding 2024-004 - Section 3 of the Housing Community Development Act (HCDA) Policy and Procedures guide Fiscal Year Finding Initially Occurred: FY 2024 (Initial Finding) Name of Federal Agency: U. S. Department of Housing and Urban Development (HUD) Assistance Federal Listing Award Number Number Pr...
Finding 2024-004 - Section 3 of the Housing Community Development Act (HCDA) Policy and Procedures guide Fiscal Year Finding Initially Occurred: FY 2024 (Initial Finding) Name of Federal Agency: U. S. Department of Housing and Urban Development (HUD) Assistance Federal Listing Award Number Number Program Title 14.218 N/A CDBG - 7308 Pinedale Renovation Project Award Year: 2024 Criteria or specific requirement: According to Section 3 of the HCDA, grantees must establish and maintain documentation to demonstrate that workers on Section 3 projects meet the definition of a Section 3 worker or Targeted Section 3 worker, at the time of hire or the first reporting period. This includes requiring written reports from developers or contractors summarizing the totals for labor hours, including Section 3 worker and Targeted Section 3 worker labor hours, and documentation from employees or employers certifying that the employee met the requirements to receive Section 3 worker status. Any information that a grantee enters in IDIS or DRGR must have supporting documentation demonstrating the accuracy of the data. (24 CFR part 75). Condition: SC UpLift does not have a written, documented Section 3 policy and procedures guide. However, Section 3 is identified in the activities section of the description of work in the contractual agreement with the contractor. SC UpLift did not maintain a formal written Section 3 Policy and Procedures Guide. However, Section 3 requirements were incorporated into the solicitation and executed construction contract Cause of condition: SC UpLift did not prepare a written Section 3 policy and procedures guide. Potential effect of condition: This appears to be an isolated incident because SC UpLift only had one award agreement under this program assistance listing number. This condition results in a noncompliance finding regarding a written Section 3 policy and procedures guide for the period under audit. Recommendation: We recommend SC UpLift’s Management create a written Section 3 Policies and procedures guide when participating in the above referenced program assistance listing number. Response of responsible SC UpLift official: SC UpLift Community Outreach acknowledges the audit finding and understands that a formal written Section 3 Policy and Procedures Guide should have been established for the CDBG-funded project. Although SC UpLift did not maintain a standalone written Section 3 policy during the audit period, the organization did recognize the applicability of Section 3 requirements during the procurement process. Section 3 provisions were incorporated into the project bid documents and executed construction contract to ensure contractors were aware of the federal requirements. Based on the guidance provided during project implementation, management believed these measures adequately addressed the Section 3 requirements for this project. SC UpLift recognizes that HUD requires recipients and subrecipients to maintain a formal written Section 3 Policy and Procedures Guide regardless of whether separate reporting is requested by the pass-through entity. We accept the finding and are committed to strengthening our compliance procedures. Management will develop and adopt a comprehensive Section 3 Policy and Procedures Guide that establishes procedures for: • documenting Section 3 workers and Targeted Section 3 workers; • monitoring contractor compliance with Section 3 requirements; • maintaining required supporting documentation; • retaining labor hour reports and other required records; and • ensuring compliance with 24 CFR Part 75 for all applicable HUD-funded projects. In addition, SC UpLift will incorporate a federal compliance checklist into its grant administration process to ensure all required HUD policies are adopted prior to the commencement of future projects.
View Audit 411275
Finding 1230028 (2024-006)
Material Weakness 2024
SC UPLIFT COMMUNITY OUTREACH
SC
Subrecipient Monitoring Reporting
Criteria: Section 3.5 of the Grant Agreement, Federal Labor Standards Compliance, requires the subrecipient to ensure compliance with all applicable labor standards for federally funded construction activities. Specifically, contracts exceeding $2,000 for construction, alteration, repair, painting, ...
Criteria: Section 3.5 of the Grant Agreement, Federal Labor Standards Compliance, requires the subrecipient to ensure compliance with all applicable labor standards for federally funded construction activities. Specifically, contracts exceeding $2,000 for construction, alteration, repair, painting, or decorating of a public building or public work financed in whole or in part with federal funds must include the labor standards provisions required by 29 CFR Part 5.5, including prevailing wage requirements. Condition: The subrecipient did not ensure that applicable construction contracts contained the required federal labor standards provisions, including prevailing wage requirements and the contract clauses prescribed by 29 CFR Part 5.5. No prevailing wage determinations were obtained or payroll records maintained, Cause: Management did not establish adequate procedures to review federally funded construction contracts for compliance with federal labor standards requirements before execution. Effect: Failure to include the required labor standards provisions may result in noncompliance with federal grant requirements, expose workers to improper wage practices, and increase the risk of questioned costs, repayment of grant funds, or other federal sanctions. Recommendation: We recommend Management implement procedures to identify all federally funded construction contracts subject to prevailing wage requirements and ensure that required labor standards provisions, including those contained in 29 CFR Part 5.5, are incorporated into all applicable contracts before work begins. Management Response: SC UpLift Community Outreach, Inc. acknowledges the audit finding and understands the importance of ensuring compliance with all applicable federal labor standards and grant requirements. At the inception of the Richland County Home Repair Project for Seniors, SC UpLift participated in an orientation conducted by the consulting firm retained by Richland County to administer and oversee the ARPA-funded program. During that orientation, SC UpLift was provided guidance regarding program administration, reporting requirements, and the monthly Subrecipient Reports that were required throughout the grant period. Based on the information and technical assistance provided during program implementation, management believed that prevailing wage requirements were applicable primarily to larger federally funded construction projects and was not aware that prevailing wage monitoring requirements applied to this program. At no time during the grant period was prevailing wage documentation requested or identified as a compliance concern during the monthly reporting process. While this context explains management's understanding, SC UpLift recognizes that ultimate responsibility for complying with all grant requirements rests with the organization. We accept the finding and are committed to strengthening our compliance procedures. To address this finding, SC UpLift will implement the following corrective actions: • Develop written policies and procedures to identify federal labor standards and prevailing wage requirements before the execution of any federally funded construction or rehabilitation contracts. • Review all federal and pass-through award agreements at the beginning of each grant to identify all applicable compliance requirements. • Incorporate a grant compliance checklist that includes prevailing wage determinations, when applicable, before projects are initiated. • Consult with our third-party CPA and grant management professionals, as necessary, to ensure compliance with federal labor standards and other grant requirements. • Provide additional training to management and program staff regarding federal grant compliance requirements, including prevailing wage regulations. Management is committed to strengthening its internal controls and compliance monitoring processes to ensure all applicable federal requirements are identified and implemented for future federally funded projects.
View Audit 411275
Finding 1229781 (2024-003)
Material Weakness 2024
Public Law Center
CA
Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430
PLC transitioned to a new HRIS software in mid-2024, which disrupted our usual process for documenting approval of employee salary/pay rates. PLC’s HR department has incorporated a new procedure for documenting personnel actions that is compatible with our HRIS software.
PLC transitioned to a new HRIS software in mid-2024, which disrupted our usual process for documenting approval of employee salary/pay rates. PLC’s HR department has incorporated a new procedure for documenting personnel actions that is compatible with our HRIS software.
View Audit 411086
Finding 1229724 (2024-001)
Material Weakness 2024
National Association on Drug Abuse Problems (new York State) INC
NY
Procurement, Suspension & Debarment Subrecipient Monitoring
2024-001 Corrective Action Plan NADAP’s Vendor Screening Policy has been updated with additional information regarding screening procedure, assigning specific ownership and documentation practices to each step of the procedure to ensure compliance. The updated policy is included below and will be in...
2024-001 Corrective Action Plan NADAP’s Vendor Screening Policy has been updated with additional information regarding screening procedure, assigning specific ownership and documentation practices to each step of the procedure to ensure compliance. The updated policy is included below and will be incorporated into the Corporate Compliance Manual. Gary Stankowski, Chief Operating Officer and Corporate Compliance Officer, is responsible for oversight of this corrective action. Vendor Screening Policy Purpose of Policy The purpose of this policy is to establish safeguards to prevent NADAP from contracting with individuals or entities that have been excluded from receiving Medicaid or federal funds. Definitions SAM Exclusion List means the Exclusions List available in the U.S. General Services Administration System for Award Management system. LEIE means the U.S. Department of Health and Human Services Office of Inspector General List of Excluded Individuals/Entities. OFAC SDN means the US Department of Treasury’s Office of Foreign Assets Control Specially Designated National & Blocked Persons List. OMIG Exclusion List means the List of Restricted, Terminated or Excluded Individuals or Entities maintained by the New York State Office of Medicaid Inspector General. Statement of Policy NADAP is prohibited from entering into a contract unless the contractor has been subject to screening in accordance with this policy. Exclusion Screening Prior to Contract Execution The employee responsible for negotiating the contract will forward the contractor’s name, address, social security or tax identification number and other appropriate information to the Corporate Compliance Officer (CCO), copying the Executive Assistant to Administration (EA). If the contractor is an entity rather than an individual, the employee will provide the same information for any individuals or entities that own an interest of 10% or more in the contractor. The CCO will promptly screen all potential contractors (and any individuals who own 10% or more of a corporate contractor) against the SAM Exclusion List, LEIE, OFAC SDN, and the OMIG Exclusion List. The exclusions databases are available to search online at the following addresses: SAM Exclusion List - https://sam.gov/EIE - https://exclusions.oig.hhs.gov/OFAC SDN - https://sanctionssearch.ofac.treas.gov/OMIG Exclusion List - https://apps.omig.ny.gov/exclusions/ex_search.aspx The EA will complete the screening and notify the employee responsible for negotiating the contract and the CCO in writing that the screenings were completed. NADAP may choose to retain a vendor to perform this screening on behalf of the Compliance Officer. New vendor screenings will be reported in the appropriate Corporate Compliance Monthly Activity Report. NADAP is prohibited from contracting with any individual or entity that is included on the SAM Exclusions List, LEIE, OFAC SDN, or OMIG Exclusion List at the time the contract is being executed. Ongoing Screening The CCO and EA will screen all existing vendors on a quarterly basis. The EA will export a list of current vendors from NADAP’s accounting system to forward to the Director of Data Services, who will screen the exported list against the SAM Exclusion List, LEIE, OFAC SDN, and OMIG Exclusion list. Results of the screenings will be included in the appropriate Corporate Compliance Monthly Activity Report. If this screening reveals that a contractor is included on the SAM Exclusion List, LEIE, OFAC SDN, or OMIG Exclusion List, NADAP will immediately terminate the contractor’s contract. Upon receipt of notification from the U.S. Department of Health and Human Services Office of Inspector General (the “OIG”) that a contractor has been excluded from a federal health care program, NADAP will terminate the contractor’s contract as soon as is practicable. If any employee notifies the CCO that a contractor is subject to such an exclusion, the CCO, will investigate the matter. Subcontractors A contractor may enter into a subcontract only with the prior approval of the NADAP employee responsible for overseeing the contract. No subcontract will be approved unless (i) the CCO screens the subcontractor against the SAM Exclusions, LEIE, OFAC SDN, and OMIG Exclusion List and determines that the subcontractor is not an excluded person or (ii) obtains a representation in writing from the contractor that it has conducted such screening of the subcontractor and determined that the subcontractor is not an excluded person.
View Audit 410920
Finding 1229712 (2024-028)
Material Weakness 2024
Republic of the Marshall Islands
MH
Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303
Condition 1: ELC Program Leads complete and submit Work Plan Progress Reports through the ELC CAMP as required by the grant. To monitor compliance, ELC will notify the Ministry of Finance of submitted reports and provide MOF with view-only access to relevant files and supporting documentation as nee...
Condition 1: ELC Program Leads complete and submit Work Plan Progress Reports through the ELC CAMP as required by the grant. To monitor compliance, ELC will notify the Ministry of Finance of submitted reports and provide MOF with view-only access to relevant files and supporting documentation as needed. Condition 2: The ELC Program Leads completes the required financial reports in ELC CAMP using information provided by the MOF Fiscal Officer and submits the reports through ELC CAMP and GrantSolutions. ELC will notify MOF of each submission to support compliance monitoring. To strengthen the process, MOF and MOHHS will establish a formal reporting process. MOHHS will maintain a tracking tool with required reports, reporting periods, due dates, and submission status, and share it with MOF. MOF will have access to ELC CAMP and the MOHHS GrantSolutions account to retrieve reports as needed.
View Audit 410889
Finding 1229710 (2024-026)
Material Weakness 2024
Republic of the Marshall Islands
MH
Period of Performance Subrecipient Monitoring § 200.303
The Ministry disagrees with the findings. The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date (last day for obligations) and Closing Date (last day to liquidate enc...
The Ministry disagrees with the findings. The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date (last day for obligations) and Closing Date (last day to liquidate encumbrances) in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements.
View Audit 410889
Finding 1229709 (2024-025)
Material Weakness 2024
Republic of the Marshall Islands
MH
Equipment & Real Property Management Subrecipient Monitoring § 200.303 § 200.313
Conditions 1-5 Repeat Finding, same response for Finding Nos. 2024-007, 2024-012, and 2024-019
Conditions 1-5 Repeat Finding, same response for Finding Nos. 2024-007, 2024-012, and 2024-019
View Audit 410889
Finding 1229697 (2024-019)
Material Weakness 2024
Republic of the Marshall Islands
MH
Equipment & Real Property Management Subrecipient Monitoring § 200.303 § 200.313
Conditions 1-5 Repeat Finding - same response for Finding No. 2027-007, 2024-012, and 2024-025
Conditions 1-5 Repeat Finding - same response for Finding No. 2027-007, 2024-012, and 2024-025
View Audit 410889
Finding 1229696 (2024-018)
Material Weakness 2024
Republic of the Marshall Islands
MH
Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303
Condition 1-1. Due to structural damages to the Payroll office, files were transferred from there to the warehouse for storage. After numerous attempts to recover the files, the payroll staff were not able to do so within the given time period. Effective October 2025, the Payroll team has been attac...
Condition 1-1. Due to structural damages to the Payroll office, files were transferred from there to the warehouse for storage. After numerous attempts to recover the files, the payroll staff were not able to do so within the given time period. Effective October 2025, the Payroll team has been attaching new employee contracts to the payslips in Bisan. PSC's HRMIS already stored the scanned PAFs of employees. The PSS has now acquired the Orange Human Resource Management System, which will also make contracts available electronically. Condition 1-2. PSS Response: PSS Management acknowledges the finding. While leave requests were generally submitted and recorded, we recognize that approved leave forms were not consistently maintained to support all leave hours charged during the audit period. To address this finding, beginning in FY2027, PSS will implement the Orange Human Resource Management System, which will transition the leave request process from a paper-based system to an electronic system. This will create a complete electronic audit trail for all leave requests submitted by PSS employees on islands with internet access. As internet connectivity continues to expand through solar power and Starlink installations, additional schools and offices will transition to the electronic system, with full implementation across all PSS locations targeted by the end of FY2028. In addition, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that leave requests are properly approved, documented, and retained in accordance with PSS policies and applicable grant requirements. Any deficiencies identified during these reviews will be communicated promptly to management so that corrective action can be taken. MOF response: Additionally, effective FY2025, the Ministry of Finance requires all ministries to submit leave forms for all annual and sick leave taken, regardless of the number of hours & days. The Ministry of Finance issued a clarifying memorandum on July 29, 2025. Condition 2. These costs were incurred to cover the retirees' annual leave lump-sum payments. If not in the approved budget narrative, MOF & PSS will ensure prior approval from the grantor is obtained and sufficient supporting calculations are provided before charging excess costs to the grant to ensure allowability and compliance with grant requirements.
View Audit 410889
Finding 1229695 (2024-017)
Material Weakness 2024
Republic of the Marshall Islands
MH
Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303
Condition 1 Public School System management concurs with the finding. While annual performance evaluations were completed for many grant-funded employees, PSS did not consistently maintain sufficient documentation to demonstrate that all required evaluations had been completed in accordance with the...
Condition 1 Public School System management concurs with the finding. While annual performance evaluations were completed for many grant-funded employees, PSS did not consistently maintain sufficient documentation to demonstrate that all required evaluations had been completed in accordance with the grant requirements. Beginning in FY2027, PSS has implemented the Orange HR Management System, which provides an electronic process for completing, approving, and storing employee performance evaluations. This system creates a centralized electronic record and audit trail, making it easier to monitor compliance and retrieve documentation for audit purposes. In addition, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that all required evaluations are completed and properly documented before the close of each fiscal year. Condition 2 FY2024 Appropriation was a continuation of FY2023 and did not reflect the new Compact yet since negotiations were still ongoing at the time. The $2.5million matching was clarified with the US DOI team in March 2026, to be appropriated in FY2027. The MOF has not drawn down against this grant.
View Audit 410889
Finding 1229694 (2024-016)
Material Weakness 2024
Republic of the Marshall Islands
MH
Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303 § 200.305 § 200.332 § 200.521
Condition 1. On July 31, the newly developed pre-award risk assessment tool was rolled out to all subrecipients and ministries with oversight, effective FY2027. Conditions 2-3: On July 29, July 31 and August 5, 2026, training was conducted on Majuro and Ebeye to introduce new and enhanced tools to s...
Condition 1. On July 31, the newly developed pre-award risk assessment tool was rolled out to all subrecipients and ministries with oversight, effective FY2027. Conditions 2-3: On July 29, July 31 and August 5, 2026, training was conducted on Majuro and Ebeye to introduce new and enhanced tools to strengthen subrecipient monitoring. It covered the following topics: 1. Audit findings related to subrecipient arrangements. 2. Grants Management Manual with emphasis on its scope and the Management Decision Letter (MDL). 3. Unique Entity Identifier (UEI), which is mandatory. 4. Memorandum of Agreement and the significance of each section. 5. MOA circulation process. 6. Procurement Code 2023 7. Reporting and Required Supporting Documents: - Pre-award Risk Assessment - Site Visit Checklist - Enhanced SubGrant Forms and Review Checklist (SG1/Subgrant Objectives and Budget Proposal and SG2/Performance and Financial Evaluation) - SG Forms supporting documentation (salaries & wages, fuel purchase, food purchase, vehicle rental, housing allowance, travel, etc.) 8. Conflict of Interest In September 2026, officers from the Compliance and SOE Monitoring Unit will start going out to conduct the pre-award risk assessment. Results of the assessment will determine whether the entity can sign an MOA with the MOF or not as well as the entity's risk rating, which will determine the frequency of site visits to be conducted by Compliance beginning FY2027. Condition 4 Effective 3rd quarter of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment process.
View Audit 410889
Finding 1229693 (2024-015)
Material Weakness 2024
Republic of the Marshall Islands
MH
Reporting Subrecipient Monitoring Cash Management § 200.303
Condition 1. Item 1. A financial reporting tool was recently established to support the timely preparation and submission of reports. Additionally, the Ministry recruited a Senior Financial Analyst in February to oversee the monitoring, preparation, and timely submission of financial reports. Condit...
Condition 1. Item 1. A financial reporting tool was recently established to support the timely preparation and submission of reports. Additionally, the Ministry recruited a Senior Financial Analyst in February to oversee the monitoring, preparation, and timely submission of financial reports. Condition 2-1. Items 1-2 Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management. Condition 2-2. Items 1-21 A financial reporting tool was recently established to support the timely preparation and submission of reports. Additionally, the Ministry recruited a Senior Financial Analyst in February to oversee the monitoring, preparation, and timely submission of financial reports. Condition 2-3. Items 1-2 Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management. However, the Ministry disagrees with the finding on the SF-425 not containing the SPG code since the latter is not a required US field. SPG code is internal to the MOF. Grant number D22AP00180 is also established in the FMIS as part of the setup of SPG 10450101.
View Audit 410889
Finding 1229690 (2024-012)
Material Weakness 2024
Republic of the Marshall Islands
MH
Equipment & Real Property Management Subrecipient Monitoring § 200.303 § 200.313
The MOF recruited a dedicated asset management officer and began a government-wide asset inventory in April 2026. Upon completion, the FMIS asset module will be fully implemented in FY2027 to improve the classification, recording, reporting, and monitoring of capital assets. The MOF also continues t...
The MOF recruited a dedicated asset management officer and began a government-wide asset inventory in April 2026. Upon completion, the FMIS asset module will be fully implemented in FY2027 to improve the classification, recording, reporting, and monitoring of capital assets. The MOF also continues to coordinate with Ministries and Agencies to update and reconcile asset records. Repeated finding: same response on Finding Nos. 2024-007, 2024-019, and 2024-25
View Audit 410889
Finding 1229688 (2024-010)
Material Weakness 2024
Republic of the Marshall Islands
MH
Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303
Condition 1: Effective FY2025, all ministries submit leave forms for all annual and sick leave taken, regardless of the number of days. The Ministry of Finance issued a clarifying memorandum on July 29, 2025. Condition 2: Item 1. MOF to set a policy providing a repatriation allowance of $500 to expa...
Condition 1: Effective FY2025, all ministries submit leave forms for all annual and sick leave taken, regardless of the number of days. The Ministry of Finance issued a clarifying memorandum on July 29, 2025. Condition 2: Item 1. MOF to set a policy providing a repatriation allowance of $500 to expatriates who have completed their employment contracts and exiting for good, and receipt is not required. Item 2-4. During the second year of FMIS implementation, limited staffing and scanning equipment prevented the timely upload of supporting documents. The Ministry has since improved its staffing and equipment, and in FY2025 all supporting documentation is uploaded to FMIS before payment processing. Item 5. The Ministry disagrees with the finding. The per diem and transportation expenses are accounted for in the liquidation supporting documents. The Government accepts acknowledgment receipts as supporting documentation for transportation services provided in neighboring islands due to the vendors' limited resources and inability to issue invoices or printed receipts. Item 6. The Laura Elementary School PDP & Detailed Design contract was an old/completed project originally funded under expired grant D21AF102130 and was subsequently regranted under FY2024 grant D24AF00024 along with three other projects. The payment was supported by a PMU letter identifying the contractor's total outstanding unpaid invoices. Condition 3. Effective 3rd quarter of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment process.
View Audit 410889
Finding 1229554 (2024-004)
Material Weakness 2024
Robonation Inc.
VA
Reporting Subrecipient Monitoring § 200.512
Views of Responsible Officials: Upon assuming financial leadership in 2026, the new VP of Finance inherited the 2023 audit in a state of significant delay. The commencement of the 2023 audit was delayed due to the backlog of incomplete prior year audits that required resolution before the current ye...
Views of Responsible Officials: Upon assuming financial leadership in 2026, the new VP of Finance inherited the 2023 audit in a state of significant delay. The commencement of the 2023 audit was delayed due to the backlog of incomplete prior year audits that required resolution before the current year engagement could begin, RoboNation had also transitioned to a new audit firm for the 2023 audit, the compound effect contributed to extended timelines and completion delays. Management has implemented the following corrective actions: RoboNation has restored its relationship with its previous audit firm, which has enabled more efficient audit execution and improved communication. The 2023 audit was completed in early 2026, and the 2024 audit was completed on an accelerated timeline. Timelines have been discussed and agreed with the auditors and management for the 2025 audit which positions RoboNation to return to compliance with Federal reporting deadlines. The audit is targeted for completion by September 30, 2026, placing the Data Collection Form submission well within the required deadline. Additionally, management is implementing standardized monthly reconciliation procedures, formalized account close processes, and enhanced financial reporting capabilities that will enable future audits to be executed more efficiently. RoboNation is targeting completion of the 2026 audit in Spring 2027, which will establish a sustainable, predictable audit cadence aligned with Federal compliance requirements.
View Audit 410855
Finding 1229417 (2024-002)
Material Weakness 2024
MICHIGAN FOUNDERS FUND
MI
Reporting Subrecipient Monitoring Allowable Costs / Cost Principles
Remediation Steps Completed: MFF will implement the following corrective actions between June 2026 and September 2026 to remediate the finding and address the cause of the finding. • A new contract financial firm and contracted Financial Officer was selected and engaged in February 2025 for regular ...
Remediation Steps Completed: MFF will implement the following corrective actions between June 2026 and September 2026 to remediate the finding and address the cause of the finding. • A new contract financial firm and contracted Financial Officer was selected and engaged in February 2025 for regular and ongoing financial management and oversight. • Michigan Founders Fund has implemented balance sheet reconciliations to be prepared and completed by identified staff/consultants monthly to ensure expenditures are correctly captured in a timely fashion. • Michigan Founders Fund has documented accounting policies and procedures to reflect month-end processes and provide training to staff on current and future policies in coordination with contracted support. Implementation, Monitoring, and Sustainability of the Corrective Action: Michigan Founders Fund has implemented the above corrective actions to remediate the finding and address the cause of the finding. To ensure these controls remain effective beyond initial adoption and specifically prevent recurrence of costs charged outside the approved period of performance, MFF has built the following monitoring controls into its normal operating cycle: • As part of the monthly balance sheet reconciliation, designated staff/contractors will verify that all expenditures charged to the award were both incurred and obligated within the award's approved period of performance before the entry is posted. Any transaction falling outside the eligible period will be flagged, held from posting to the federal award, and routed for review. • The Executive Director will continue to review and approve all monthly journal entries prior to posting to the general ledger, with specific attention to period-of-performance alignment for federally funded transactions. Approval will be evidenced in writing and retained in accordance with the record retention requirements. • In addition to monthly reconciliations, the Financial Officer will perform a quarterly reconciliation of cumulative expenditures against the award's approved budget period and reporting deadlines, confirming that reported costs align with the eligible period of performance. • MFF's documented accounting policies and procedures will include specific cutoff procedures for the close of the period of performance, ensuring costs are not recorded in the wrong period and that any year-end or award-end accruals are properly evaluated. • All staff and contractors involved in processing or approving federally funded transactions will receive training on period-of-performance requirements as part of onboarding and as part of the annual policy review, ensuring the control does not depend on any single individual's institutional knowledge. • The Executive Director, with support from the Financial Officer, is responsible for overall monitoring and execution of these corrective actions. Any identified instance of an out-of period expenditure will be documented, corrected, and reported to the Board (or Finance/Audit Committee) at its next regularly scheduled meeting. Anticipated Completion Date: September 2026 Contact Person: Rishi Moudgil, Executive Director Contact Phone Number: (313) 338-8292
View Audit 410809
Finding 1228920 (2024-013)
Material Weakness 2024
Twin Oaks Juvenile Development, Inc.
FL
Student Financial Aid Subrecipient Monitoring Reporting § 200.303
Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing...
Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing these procedures. Felecia Read will be responsible for making sure these are completed and documented.
View Audit 410428
Finding 1228902 (2024-010)
Material Weakness 2024
Twin Oaks Juvenile Development, Inc.
FL
Allowable Costs / Cost Principles Subrecipient Monitoring Internal Control / Segregation of Duties § 200.1 § 200.303
Twin Oaks will revise procedures to calculate the MTDC in accordance with Uniform Guidance and apply the indirect cost consistently for all programs and to review the indirect cost allocations performed. Again, because of the timing of this audit report, there may be repeat findings for 2025 but sho...
Twin Oaks will revise procedures to calculate the MTDC in accordance with Uniform Guidance and apply the indirect cost consistently for all programs and to review the indirect cost allocations performed. Again, because of the timing of this audit report, there may be repeat findings for 2025 but should be eliminated going forward. Benjie Read and Felecia Read will work together to calculate the current MTDC by October 31, 2026.
View Audit 410428
Finding 1228867 (2024-007)
Material Weakness 2024
Twin Oaks Juvenile Development, Inc.
FL
Reporting Subrecipient Monitoring Material Weakness § 200.303
See 2024-013, This particular finding that relates to the HHS/ORR program will no longer be an issue going forward with the closure of this program.
See 2024-013, This particular finding that relates to the HHS/ORR program will no longer be an issue going forward with the closure of this program.
View Audit 410428
Finding 1228866 (2024-006)
Material Weakness 2024
Twin Oaks Juvenile Development, Inc.
FL
Cash Management Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.305
This problem only applied to the HHS program that was eliminated in December 2023. All other programs that we contract with are paid in arrears and there are no advances. We have proposed a settlement agreement with HHS to eliminate the overpayment and interest. Benjie Read will be responsible for t...
This problem only applied to the HHS program that was eliminated in December 2023. All other programs that we contract with are paid in arrears and there are no advances. We have proposed a settlement agreement with HHS to eliminate the overpayment and interest. Benjie Read will be responsible for the settlement agreement, by October 31, 2026.
View Audit 410428
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