Corrective Action Plans

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Section III - Federal Award Findings and Questioned Costs: U.S. Department of Defense Recommendation: Appropriate written subrecipient monitoring policies and procedures be developed and implemented, including a schedule for various financial reviews to document that subrecipients are complying with...
Section III - Federal Award Findings and Questioned Costs: U.S. Department of Defense Recommendation: Appropriate written subrecipient monitoring policies and procedures be developed and implemented, including a schedule for various financial reviews to document that subrecipients are complying with the Federal regulations and with the terms and conditions of the subaward. Management has taken the following actions with regards to the current finding. • The five subrecipients are as follows: o Chicago Association for Research and Education o Houston Methodist Research Institute o Tufts Medical Center, Inc. o University of Pittsburgh o Vanderbilt University • Verified that all subrecipients are audited and that none are suspended, debarred, or otherwise excluded from receiving Federal Funds. • Obtained most recent Single Audit Report from each subrecipient and determined that there were no audit findings related to the Company. The following was identfied in each audit report: o Chicago Association for Research and Education – Year Ended September 30, 2024 - The Company is not listed in the Single Audit Report – Management is following up with the institution. o Houston Methodist Research Institute - Year Ended December 31, 2023 - Military Medical Research and Development through Liberate Medical, LLC - W81XWH2211123 - 12.420 - $11,107 o Tufts Medical Center, Inc. - Year Ended September 30, 2023 - Military Medical Research and Development Passed Through—Liberate Medical LLC—A Randomized, Sham Controlled, Double-blinded, MulM-center Trial to Evaluate the Efficacy of the VentFree Respiratory Muscle Stmulator to Assist Ventilator Weaning in Critically III Patients - 12.420 - W81XWH2211123 - $14,770 o University of Pittsburgh - Year Ended June 30, 2024 - Liberate Medical, LLC. - 12.420 - PREVENT-LIBERATE – Planning Phase $1,415; Trial Phase $84,087 o Vanderbilt University - Year Ended June 30, 2024 - MILITARY MEDICAL RESEARCH AND DEVELOPMENT - 12.420 - Liberate Medical VUMC108554 -W81XWH2211123 $52,147 • Management is reviewing costs included in the subrecipient’s Single Audit Report noted above and working with the subrecipients to reconcile amounts to the Company’s books and records. For the year ended December 31, 2024, the Company submitted reimbursement voucher requests to the Department of Defense in the amount of $1,766,172. Amounts related to subawards for the same period were $134,695 or 7.6%. In the future management will: • Prepare a standard operating procedure (SOP) for subrecipient monitoring in accordance with CFR Part 200.332 and OMB Compliance Supplement 6-20. • For the current award: o Evaluate each subrecipient’s fraud risk and risk of noncompliance o Develop a subrecipient risk-based monitoring plan sufficient for the Company to comply with federal statues, regulations, and the terms and conditions of the award. o Follow the developed risk-based monitoring plan for the remainder of the award and implement, where appropriate, corrective actions against any noncompliant subrecipients • For future awards, perform subrecipient monitoring in accordance with the SOP described above and in compliance with CFR Part 200.332 and OMB Compliance Supplement 6-20.
The Village of Whitehouse will work with our outside Engineers to ensure that all compliance items are being addressed in all initial meetings for projects using Federal Funds. This will ensure that all policies and procedures are put into place prior to the start of the project. The Village will se...
The Village of Whitehouse will work with our outside Engineers to ensure that all compliance items are being addressed in all initial meetings for projects using Federal Funds. This will ensure that all policies and procedures are put into place prior to the start of the project. The Village will seek out training on federal procurement compliance requirements.
Statement of Condition #2024-003: The Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending March 31, 2024. Recommendation: The annual financial statements should be issued in a timely manner pursuant to the time f...
Statement of Condition #2024-003: The Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending March 31, 2024. Recommendation: The annual financial statements should be issued in a timely manner pursuant to the time frame set forth by HUD. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. The audited financial statements have been submitted to HUD. No further action is required.
Statement of Condition #2024-001: The Form SF-SAC Single Audit Data Collection Form for the year ended March 31, 2024 was not submitted to the federal audit clearinghouse in the required timeframe. Recommendation: The Corporation should submit the Form SF-SAC Single Audit Data Collection Form for th...
Statement of Condition #2024-001: The Form SF-SAC Single Audit Data Collection Form for the year ended March 31, 2024 was not submitted to the federal audit clearinghouse in the required timeframe. Recommendation: The Corporation should submit the Form SF-SAC Single Audit Data Collection Form for the year ended March 31, 2024 as soon as practical. Action(s) taken or planned on the finding: Agreed. The Agent concurs with the finding and recommendation.
Statement of Condition #2024-002: During the year ended March 31, 2024, the Corporation did not make the required deposit to the residual receipts account within 90 days after the end of the fiscal year, resulting in the account being underfunded at year end. Recommendation: The Agent should transfe...
Statement of Condition #2024-002: During the year ended March 31, 2024, the Corporation did not make the required deposit to the residual receipts account within 90 days after the end of the fiscal year, resulting in the account being underfunded at year end. Recommendation: The Agent should transfer $16,431 from the REDI IV operating account to the residual receipts account. The Agent should make all required deposits to the residual receipts account within 90 days after the end of the fiscal year. Action(s) taken or planned on the finding: Agreed. The Agent concurs with the finding and the auditor's recommendation. The Corporation will ensure future deposits to the residual receipt account are made within 90 days after the end of the fiscal year.
The Village prior to contracting with vendors that will be paid with federal funds, will verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
The Village prior to contracting with vendors that will be paid with federal funds, will verify the vendor is not suspended or debarred by checking the SAM exclusions, collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor.
The Cooperative submitted the reimbursement request to the Federal Emergency Management Agency (FEMA) for equipment costs based on a conservative (less cost) approach using actual mileage costs. The hourly data submitted to FEMA was identified as not used for the reimbursement request. This informat...
The Cooperative submitted the reimbursement request to the Federal Emergency Management Agency (FEMA) for equipment costs based on a conservative (less cost) approach using actual mileage costs. The hourly data submitted to FEMA was identified as not used for the reimbursement request. This information was only provided to demonstrate that the mileage-based cost was less than the hourly calculation. The hourly reimbursement data was a draft and it was indicated that the costs for aerial/digger equipment units were not included. FEMA opted to change the request to use the hourly calculation just prior to the submission deadline leaving no time for further discussion or analysis. A fully completed hourly based cost reimbursement request would have resulted in a higher requested amount and the hourly variance identified would have been negligible. Any future submissions will be based on the hourly approach and will be thoroughly reviewed.
Auditee Response and Corrective Action Plan: Management concurs with the finding. The Organization will update its year-end and audit procedures to designate a responsible party for monitoring and completing the FAC submission process. The Organization will also include the due date as part of its a...
Auditee Response and Corrective Action Plan: Management concurs with the finding. The Organization will update its year-end and audit procedures to designate a responsible party for monitoring and completing the FAC submission process. The Organization will also include the due date as part of its audit closing checklist to ensure future submissions are made timely.
Auditee Response and Corrective Action Plan: Management concurs with the finding. The Organization should design and implement a comprehensive review process for all significant general ledger accounts to ensure that they are reconciled to underlying supporting documentation in a continuous and time...
Auditee Response and Corrective Action Plan: Management concurs with the finding. The Organization should design and implement a comprehensive review process for all significant general ledger accounts to ensure that they are reconciled to underlying supporting documentation in a continuous and timely manner throughout the fiscal year.
Finding Number: 2024-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2025 Responsible Contact Person: Pamela Keener, Finance Director
Finding Number: 2024-001 Planned Corrective Action: City of Norton will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: June 2025 Responsible Contact Person: Pamela Keener, Finance Director
Finding: Material weakness in internal control over Schedule of Expenditures of Federal Awards (SEFA) reporting Corrective action: Pacific Forum will ensure all new grants, including pass-through awards, are properly reviewed to ensure they are included in the SEFA, if necessary. The requirement to ...
Finding: Material weakness in internal control over Schedule of Expenditures of Federal Awards (SEFA) reporting Corrective action: Pacific Forum will ensure all new grants, including pass-through awards, are properly reviewed to ensure they are included in the SEFA, if necessary. The requirement to reconcile federal grant expenditures with federal financial reporting and cash draws will be incorporated into PFI financial reporting and cash management policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Significant deficiency in internal control for late submission of data control form and Single Audit report package. Corrective action: Pacific Forum has authorized its outsourced accounting service to take on a larger role in fulfilling auditor requests to ensure the information submitted ...
Finding: Significant deficiency in internal control for late submission of data control form and Single Audit report package. Corrective action: Pacific Forum has authorized its outsourced accounting service to take on a larger role in fulfilling auditor requests to ensure the information submitted is accurate and complete. PFI has also consolidated financial management policies and other required documentation in a secure cloud network. PFI has also adopted more features available through Bill.com, which has enhanced documentation of expenditures and management reviews. Procedures for filing documents and utilizing financial management procedures available through Bill.com will be integrated into PFI financial management policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over documenting supervisory reviews of financial and performance reports prior to submission Corrective action: Pacific Forum has adopted a policy that requires the Executive Director to review performance and financial reports prior to submission to r...
Finding: Material weakness in internal control over documenting supervisory reviews of financial and performance reports prior to submission Corrective action: Pacific Forum has adopted a policy that requires the Executive Director to review performance and financial reports prior to submission to relevant grantor. The Grants Manager has established a suspense system to ensure reports are submitted in a timely manner. These procedures will be incorporated into PFI financial reporting guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over documenting suspension and debarment reviews for vendors receiving federal funds Corrective action: PFI has adopted a policy to document the screening of all vendors receiving federal funds via the suspension and debarment list provided in SAM.gov....
Finding: Material weakness in internal control over documenting suspension and debarment reviews for vendors receiving federal funds Corrective action: PFI has adopted a policy to document the screening of all vendors receiving federal funds via the suspension and debarment list provided in SAM.gov. These procedures will be incorporated into PFI procurement policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over period of performance Corrective action: Pacific Forum will incorporate policies into expense management and financial reporting guidelines to ensure all expenditure is completed within the period of performance and reviews by management are proper...
Finding: Material weakness in internal control over period of performance Corrective action: Pacific Forum will incorporate policies into expense management and financial reporting guidelines to ensure all expenditure is completed within the period of performance and reviews by management are properly documented. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over allowable costs and compliance with requirement for written documentation of transactions review required for federally funded awards Corrective action: PFI has adopted a policy to document transaction reviews. Email approval documentation is requi...
Finding: Material weakness in internal control over allowable costs and compliance with requirement for written documentation of transactions review required for federally funded awards Corrective action: PFI has adopted a policy to document transaction reviews. Email approval documentation is required for all transactions, including initial approval by the Program Director and final approval by the Executive Director. This policy will be incorporated into PFI expense management policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • Prior to issuing the SEFA, a final review and approval process will be implemented which will include: o Confirmation that all active federal program...
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • Prior to issuing the SEFA, a final review and approval process will be implemented which will include: o Confirmation that all active federal programs are included. o Validation of amounts, ALN, and expense classifications. • Responsible personnel will be retrained on the processes and requirements applicable to SEFA preparation, in order to strengthen compliance and accuracy in reporting. • We are currently in the process of drafting the corresponding administrative order, for which a preliminary draft has already been prepared. This document aims to clearly and systematically establish the necessary processes and procedures, including those related to the identified deficiencies, to ensure the implementation of enhanced controls that guarantee regulatory compliance and operational efficiency. • A fiscal section within the Office of Federal Affairs will be established to manage the fiscal process of federal funds. This structure will ensure that all transactions, corrections, and journal entries are recorded in a timely and accurate manner in the federal accounting accounts.. IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Maritza Torres López
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • For the preparation of the SEFA, all accounts related to disaster funds will be included, considering that these accounts were segregated into revenu...
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • For the preparation of the SEFA, all accounts related to disaster funds will be included, considering that these accounts were segregated into revenues and expenses by the Department of the Treasury. Both categories will be properly incorporated into the SEFA preparation process. • Federal reimbursements received will be immediately identified, and the corresponding journal entries will be prepared without delay to accurately reflect the associated expenses. • Journal entries related to the reimbursement received will be prepared, and the expenses will be recorded in the appropriate accounting accounts, ensuring proper classification and compliance with federal requirements. • We are currently in the process of drafting the corresponding administrative order, for which a preliminary draft has already been prepared. This document aims to clearly and systematically establish the necessary processes and procedures, including those related to the identified deficiencies, to ensure the implementation of enhanced controls that guarantee regulatory compliance and operational efficiency. • Responsible personnel will be retrained on the processes and requirements applicable to SEFA preparation, in order to strengthen compliance and accuracy in reporting. • A fiscal section within the Office of Federal Affairs will be established to manage the fiscal process of federal funds. This structure will ensure that all transactions, corrections, and journal entries are recorded in a timely and accurate manner in the federal accounting accounts. IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Maritza Torres López
Finding 1166725 (2024-001)
Material Weakness 2024
Finding ref number: 2024-001 Finding caption: The County did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of the County contact person: Leo Kim, CPA CFO, Mason County Auditor’s Office, Financial Service, PO Bo...
Finding ref number: 2024-001 Finding caption: The County did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of the County contact person: Leo Kim, CPA CFO, Mason County Auditor’s Office, Financial Service, PO Box 400, Shelton, WA 98584 360-429-9670 Ext 472 Corrective action the auditee plans to take in response to the finding: Mason County is committed to maintaining strong internal controls and ensuring compliance with all federal procurement requirements. While County policy already requires suspension and debarment checks, staff training and documentation practices need improvement. Corrective Action: • In 2025, the County revised its purchasing policy to include an attestation form allowing vendors to certify that they are not suspended or debarred. • Staff will be trained on how to perform and document suspension and debarment checks in SAM.gov. • The County is developing a process to conduct suspension and debarment checks when a vendor is first created and annually thereafter for all active vendors. • Compliance with these procedures will be a joint effort between the Budget Office, Auditor’s Financial Services Office, and responsible offices and departments. Mason County believes that enhanced training, consistent documentation, and proactive vendor verification will prevent recurrence of this issue and strengthen accountability across all departments. Anticipated date to complete the corrective action: December 31, 2025
Finding Number: 2024-003 Planned Corrective Action: The Grants Department Manager and Chief Financial Administrator will ensure the County submits quarterly OCJS amounts that match County accounting records each quarter. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Rob ...
Finding Number: 2024-003 Planned Corrective Action: The Grants Department Manager and Chief Financial Administrator will ensure the County submits quarterly OCJS amounts that match County accounting records each quarter. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Rob Grant, Grants Department Manager and Ben Cowdery, Chief Financial Administrator
Finding Number: 2024-005 Planned Corrective Action: The Special Projects Manager will ensure the County does not charge Indirect Costs in excess of the de minimis rate of 10 percent of modified total direct costs. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Philip Scha...
Finding Number: 2024-005 Planned Corrective Action: The Special Projects Manager will ensure the County does not charge Indirect Costs in excess of the de minimis rate of 10 percent of modified total direct costs. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Philip Schaffer, Special Projects Manager
Finding Number: 2024-004 Planned Corrective Action: The Special Projects Manager and Chief Financial Administrator will ensure the County submits Semi-Annual Performance Reports with expenditures that match County accounting records each semi-annual period. Anticipated Completion Date: December 31, ...
Finding Number: 2024-004 Planned Corrective Action: The Special Projects Manager and Chief Financial Administrator will ensure the County submits Semi-Annual Performance Reports with expenditures that match County accounting records each semi-annual period. Anticipated Completion Date: December 31, 2025 Responsible Contact Person: Philip Schaffer, Special Projects Manager and Ben Cowdery, Chief Financial Administrator
Assistance Listing 93.914 HIV Emergency Relief Project Grants Views of the Responsible Officials and Corrective Action Plan: HHS acknowledges the Controller’s finding that management decision letters were not issued for specific subrecipient audit findings under ALN 93.914, as required under 2 CFR 2...
Assistance Listing 93.914 HIV Emergency Relief Project Grants Views of the Responsible Officials and Corrective Action Plan: HHS acknowledges the Controller’s finding that management decision letters were not issued for specific subrecipient audit findings under ALN 93.914, as required under 2 CFR 200.332(e) and 200.521. While the formal letters were not issued, HHS did review the audit findings, obtained and evaluated the subrecipients’ corrective action plans and confirmed that no questioned costs or additional risks remained. These steps ensured that the underlying corrective actions were completed. To strengthen documentation and ensure consistency across all federal programs, HHS will adopt the following corrective measures: 1.Standard management Decision Template •HHS will adopt a simple, uniform management decision template and clear steps for documenting decisions within the required federal timelines. 2.Central Location for Documentation •HHS will store all management decision letters and related materials in one designated shared location to ensure accessibility and consistent record-keeping. 3.Brief Staff Guidance •HHS will provide concise written guidance to staff outlining: oWhen a management decision is required, oHow to complete it using the template, and oWhat documentation must be retained? These corrective actions will ensure consistent compliance with federal requirements while supporting the City’s long-term goal of standardizing financial processes across departments. Contact Person: Landuleni Shipanga, Controller, City of Philadelphia Office of Children and Families, 215-683-6366
Assistance Listing 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Program Views of the Responsible Officials and Corrective Action Plan: The Philadelphia Department of Public Health (PDPH) acknowledges the Office of the City Controller’s finding. PDPH maintains a process to iden...
Assistance Listing 93.323 Epidemiology and Laboratory Capacity for Infectious Diseases Program Views of the Responsible Officials and Corrective Action Plan: The Philadelphia Department of Public Health (PDPH) acknowledges the Office of the City Controller’s finding. PDPH maintains a process to identify subrecipients during the contracting process. Contracts with subrecipients include federal compliance language. The three entities identified in this finding, including Concilio, Urban Affairs Coalition (UAC), and Public Health Management Corporation (PHMC), should have been classified as vendors and not subrecipients. These entities were not responsible for programmatic decision-making. This error has been corrected in subsequent contracts. Despite the misclassification, appropriate vendor monitoring was conducted, including supervision of staff hiring and monitoring and reconciliation of monthly invoice packages. Contact Person: Jessica Caum, Director, Department of Public Health, 215-685-6731 Naomi Mirowitz, Performance and Compliance Officer, Department of Public Health, 215-964-5050
Assistance Listing 93.136 Injury Prevention and Control Research and State/Community Based Programs Views of the Responsible Officials and Corrective Action Plan: The Philadelphia Department of Public Health (PDPH) acknowledges the findings of the Office of the City Controllers. PDPH confirms that r...
Assistance Listing 93.136 Injury Prevention and Control Research and State/Community Based Programs Views of the Responsible Officials and Corrective Action Plan: The Philadelphia Department of Public Health (PDPH) acknowledges the findings of the Office of the City Controllers. PDPH confirms that risk assessments and related monitoring documentation for all subrecipients were not consistently completed or retained during the audit period, primarily due to staff turnover and limited administrative capacity within the grants management function. To address this, the Division of Substance Use Prevention and Harm Reduction (SUPHR) has initiated corrective measures to strengthen compliance with the requirements of 2 CFR 200.332. These measures include implementation of standardized tools and procedures to ensure that subrecipient risk assessments, monitoring activities, and the review of financial and performance reports are conducted in a consistent, timely, and well-documented manner. Implementation of these improvements will enhance internal controls, ensure appropriate oversight of subrecipients, and promote full compliance with federal regulations. The Department anticipates that tools and standard operating procedures will be finalized by December 19, 2025, with full implementation of corrective actions by March 3, 2026. Contact Person: Daniel Teixeira da Silva, Director, Division of Substance Use Prevention and Harm Reduction (SUPHR), 267-760-0307
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