Corrective Action Plans

Finding 499888 (2023-002)

Significant Deficiency 2023

OH

Procurement, Suspension & Debarment § 200.303

LMM will ensure that documentation of the https://sam.gov/content/home Exclusions: Ineligible, Prohibition/Restriction search will be available for review. Each search will be completed as required with the results of the search printed and/or saved electronically for audit review. The report will s...

LMM will ensure that documentation of the https://sam.gov/content/home Exclusions: Ineligible, Prohibition/Restriction search will be available for review. Each search will be completed as required with the results of the search printed and/or saved electronically for audit review. The report will show the entity searched, the result of the search and the date of the search. The CFO will be responsible for maintaining these reports.

View Audit 322823

Finding 499887 (2023-003)

Material Weakness 2023

Noble County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

FINDING 2023-003 Finding Subject: Suspension and Debarment Summary of Finding: Due to the lack of effective internal controls, Suspension and Debarment requirements were not met during the audit period. Contact Person Responsible for Corrective Action: Shelley Mawhorter, County Auditor Contact Phone...

FINDING 2023-003 Finding Subject: Suspension and Debarment Summary of Finding: Due to the lack of effective internal controls, Suspension and Debarment requirements were not met during the audit period. Contact Person Responsible for Corrective Action: Shelley Mawhorter, County Auditor Contact Phone Number and Email Address: (260) 636-2658; shelley.mawhorter@nobleco.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Noble County Auditor’s office will implement effective internal controls in reference to Suspension and Debarment requirements related to subawards and covered transactions to ensure that one of the three allowable methods of verifying that a vendor is not suspended or debarred is completed prior to entering into the contract or transaction. Anticipated Completion Date: We will have the Corrective Action Plan implemented by December 31, 2024.

View Audit 322810

Finding 499883 (2023-002)

Material Weakness 2023

Montgomery County

MS

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Audit Finding: Material Weakness, Noncompliance Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Contact Email Address: mindy.byers@montgomerycou...

FINDING 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Audit Finding: Material Weakness, Noncompliance Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Contact Email Address: mindy.byers@montgomerycounty.in.gov Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Auditor and her Chief Deputy completed the P&E report together. Moving forward, the Auditor will print the report and have the Chief Deputy sign off on the report prior to submission. Anticipated Completion Date: April 1, 2025. If applicable: Document reason issue will NOT be corrected within six months: The 2024 Project & Expenditure report is not due until April 1, 2025.

View Audit 322791

Finding 499882 (2023-001)

Material Weakness 2023

Montgomery County

MS

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Contact Email Address: mi...

FINDING 2023-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Mindy Byers Contact Phone Number: 765-364-6401 Contact Email Address: mindy.byers@montgomerycounty.in.gov Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Because the contracts are outside Auditor control, the Auditor has forwarded to county management to request a policy/internal control be created to be put in place. The County has adopted a Suspension and Debarment Policy in August 2023. A certification will be collected from the vendor in the current audit period. In addition, language regarding obtaining a certification that a vendor is not suspended or debarred has been added to the standard language in the contracts. Anticipated Completion Date: December 31, 2024

View Audit 322791

Finding 499861 (2023-003)

Significant Deficiency 2023

City of Reedsburg

WI

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

Corrective Action Plan: The Utility Commission General Manager or Communications System Supervisor will review the quarterly progress reports prepared by someone else. Section II of the Project Status Report instructions states “Answer each question to the best of your ability.” The work orders do...

Corrective Action Plan: The Utility Commission General Manager or Communications System Supervisor will review the quarterly progress reports prepared by someone else. Section II of the Project Status Report instructions states “Answer each question to the best of your ability.” The work orders do not include all costs related to labor benefits and taxes, and also the electronics and customer premise equipment associated with the projects. These costs are calculated and added in when the project is completed and is being closed out. Estimating these items for the quarterly Project Status Report is providing the project costs spent through the respective quarter to the best of our ability due to the limitations of the work order reporting process. Planned Completion Date for the Corrective Action: On-going Contact Persons Responsible for the Corrective Action Plan: The following Reedsburg Utility staff members are responsible for items outlined above in the Corrective Action Plan: • Brett Schuppner, Reedsburg Utility General Manager • Ken Las, Communications System Supervisor

View Audit 322720

Finding 499853 (2023-003)

Material Weakness 2023

Montana Alliance of Boys & Girls Clubs, Inc.

MT

Subrecipient Monitoring Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303 § 200.332

Individual Responsible for Corrective Action Plan: Alliance Director – Brian Dennis Corrective Action: The Organization will enhance its procedures and internal controls with respect to monitoring over subrecipient activities and reimbursement payments by working with the State of Montana grantor t...

Individual Responsible for Corrective Action Plan: Alliance Director – Brian Dennis Corrective Action: The Organization will enhance its procedures and internal controls with respect to monitoring over subrecipient activities and reimbursement payments by working with the State of Montana grantor to ensure local clubs are using subawards for authorized purposes. Anticipated Completion Date: December 31, 2024

View Audit 322714

Finding 499849 (2023-002)

Significant Deficiency 2023

City of Mishawaka

IN

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Subject: 2023-002 Coronavirus State and Local Fiscal Recovery Funds – Reporting Federal Agency: Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Reporting Audit Finding: Significant Deficiency Rec...

Subject: 2023-002 Coronavirus State and Local Fiscal Recovery Funds – Reporting Federal Agency: Department of the Treasury Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Compliance Requirement: Reporting Audit Finding: Significant Deficiency Recommendation: The Auditor recommends the City implement procedures to ensure reports are being reviewed by an individual or third-party familiar with the grant prior to their submission, including reconciliation of the report to the general ledger system. Planned Corrective Actions: The City made corrections during calendar year 2023 for a corresponding 2022. This current findings is a result of not being able to make edits in the ARPA reporting portal. A 2022 expenditure was overstated, and this 2023 expenditure was understated by the same amount.

View Audit 322710

Finding 499820 (2023-002)

Material Weakness 2023

Port Authority of New York and New Jersey

NJ

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.303 § 200.313

Findings Related to Federal Awards 2023 002 Equipment and real property management Federal Agency: U.S. Department of Transportation Program Name (ALN): Public Transportation Emergency Relief Program (ALN 20.527) Federal Grant Numbers: NJ-44-X004 Contact Person: Fatima Castellanos, Manager, PAT...

Findings Related to Federal Awards 2023 002 Equipment and real property management Federal Agency: U.S. Department of Transportation Program Name (ALN): Public Transportation Emergency Relief Program (ALN 20.527) Federal Grant Numbers: NJ-44-X004 Contact Person: Fatima Castellanos, Manager, PATH Financial Services, PATH Financial Services Division, 201-216-6459. Corrective Action: The Port Authority acknowledges an internal control deficiency in performing a physical equipment inventory of equipment as required under CFR 200 for the Public Transportation Emergency Relief Program 2013 49 U.S.C. 5324 (Grant award NJ-44-X004 PATH-H). PATH successfully performed a physical inventory of equipment in 2018, the first year it was required. In 2020, the performance of a physical inventory coincided with the COVID-19 pandemic which facilitated the retirement of key personnel in PATH who were responsible for performing the physical inventory of the equipment that was federally funded. This staff transition led to a loss of PATH system expertise necessary to pick up the process previously developed, resulting in the inadvertent lapse in performing the physical inventory in 2020 and 2022. To mitigate this deficiency PATH has performed a physical inventory in 2024 and updated its procedures as they relate to performing the physical inventory of equipment and to have staffing redundancies in place to account for staff turnover. In addition, PATH updated its equipment inventory log to reflect the correct serial numbers on the four pieces of equipment that KPMG identified. Anticipated Completion Date: The entry of all FTA Funded assets for the Public Transportation Emergency Relief Program 2013 49 U.S.C. 5324 will be loaded into the Port Authority Asset Management System (PAMS) by December 31, 2024. Entry of these assets will contain details pertaining to the categories (Asset Name, Supplier, PO#, Cost, Grant #, FTA Share, Date Received, Property Number/Serial Number, Useful Life, Date of Last Inventory, Observed Location, Condition, Current Use, Holder of Asset, Disposition Date) required under CFR 200 and updated on a biennial basis. It is important to note, however, that due to PATH’s nature as an operating railroad, equipment is moved frequently across the system as required. Therefore, the location of the equipment will only be accurate as of the date the inventory is performed.

View Audit 322679

Finding 499801 (2023-002)

Material Weakness 2023

Terre Haute Regional Airport Authority

IN

Reporting § 200.303

FINDING 2023-002 Finding Subject: Airport Improvement Program – Reporting Summary of Finding: Noncompliance. The airport was unable to provide the SF-425: Federal Financial Report, a required report, for the AIP54 grant for audit. Contact Person Responsible for Corrective Action: Kelsey Veatch Conta...

FINDING 2023-002 Finding Subject: Airport Improvement Program – Reporting Summary of Finding: Noncompliance. The airport was unable to provide the SF-425: Federal Financial Report, a required report, for the AIP54 grant for audit. Contact Person Responsible for Corrective Action: Kelsey Veatch Contact Phone Number and Email Address: 812-877-2542 kveatch@huf.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The airport has hired a new Director of Operations and a new on-call airport consultant/engineer which both positions will be properly advised on how to complete and retain all documents related to Airport Improvement Program projects. For this process the on-call airport consultant/engineer will prepare the SF-425 and will submit it to the Executive Director and the Director of Operations for their review and signature of approval. The Executive Director and the Director of Operations will then provide their signed approval to the on-call airport consultant/engineer. Upon receiving the signed approval, the on-call airport consultant/engineer will submit the completed SF-425 to the FAA. Once the submission is made, the oncall airport consultant/engineer will provide documented evidence to the airport showing the submission was made. In summary, the on-call airport consultant/engineer will be responsible for preparing, reporting and submitting the SF-425 upon airport staff’s approval. The Executive Director and the Director of Operations will be responsible for reviewing and providing approval of the SF-425 prior to the final submission, verifying the submission was completed, and maintaining records of the submission in the appropriate AIP binder. Anticipated Completion Date: Effective immediately – 9/24/2024

View Audit 322664

Finding 499800 (2023-001)

Material Weakness 2023

Terre Haute Regional Airport Authority

IN

Equipment & Real Property Management Material Weakness Matching / Level of Effort / Earmarking § 200.303 § 200.313

FINDING 2023-001 Finding Subject: Airport Improvement Program – Equipment & Real Property Management Summary of Finding: Material Weakness, Other Matters. The airport does not have a detailed listing of capital assets. Contact Person Responsible for Corrective Action: Kelsey Veatch Contact Phone Num...

FINDING 2023-001 Finding Subject: Airport Improvement Program – Equipment & Real Property Management Summary of Finding: Material Weakness, Other Matters. The airport does not have a detailed listing of capital assets. Contact Person Responsible for Corrective Action: Kelsey Veatch Contact Phone Number and Email Address: 812-877-2542 kveatch@huf.com Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The airport currently has a capital asset listing, but it does not contain all the information that State Board of Accounts (SBOA) would like to have provided in the listing. SBOA has offered to provide a capital asset template that they recommend units use. Using the provided template the airport will work to update their current capital asset listing. The HR/Business Relations Manager will take the lead on ensuring the capital asset listing is updated to the new format and keeping the listing current and accurate. Anticipated Completion Date: Upon receiving the template from SBOA, the airport will work to have the capital asset listing updated to the new format by Dec 31, 2024.

View Audit 322664

Finding 499795 (2023-005)

Material Weakness 2023

Town of Upland

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2023-005 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Reporting Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher@uplandindiana.com Views of R...

FINDING 2023-005 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Reporting Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher@uplandindiana.com Views of Responsible Officials: We concur with the finding Explanation and Reasons for Disagreement: Description of Corrective Action Plan: The Town of Upland will implement an oversight system to review the P&E Report before submission to the Federal Government. Anticipated Completion Date: Upon the submission of our next report due April 30, 2025

View Audit 322658

Finding 499794 (2023-004)

Material Weakness 2023

Town of Upland

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-04 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Suspension and Debarment Summary of Finding: Material Weakness, Noncompliance Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher...

FINDING 2023-04 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Suspension and Debarment Summary of Finding: Material Weakness, Noncompliance Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher@uplandindiana.com Views of Responsible Officials: We concur with this finding Description of Corrective Action Plan: Although we do have a federal grant consultant that does check the suspension and debarment status of contractors, the Town of Upland will adopt a Suspension and Debarment policy to issue that no contractor being paid with Federal funds are Suspended or Debarred. Anticipated Completion Date: 11/15/2024

View Audit 322658

Finding 499793 (2023-003)

Material Weakness 2023

Town of Upland

IN

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Activities Allowed and Unallowed. Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-74...

FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds- Activities Allowed and Unallowed. Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Mary Fletcher Contact Phone Number and Email Address: (765) 998-7439, mfletcher@uplandindiana.com Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Although the funds were transferred to utilities and not paid directly from ARPA Funds, the funds were used to make necessary investments in utility infrastructure during 2023. We have been fully informed of the guidelines for the use of the ARPA funds since this transfer occurred and will use the remaining funds according to the ARPA guidelines. The Clerk-Treasurer has contacted the Department of the Treasury to get guidance on what can be done to rectify our misuse of the funds. Anticipated Completion Date: Unknown- When a resolution is reached with the Federal Government.

View Audit 322658 Questioned Costs: $1

Finding 499792 (2023-002)

Material Weakness 2023

Monroe Fire Protection District

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-002 (Auditor Assigned Reference Number) Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Summary of Finding: Material Weakness, Other Matters – no policy to check for suspension and debarment prior to entering into transactions with vendors C...

FINDING 2023-002 (Auditor Assigned Reference Number) Finding Subject: Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Summary of Finding: Material Weakness, Other Matters – no policy to check for suspension and debarment prior to entering into transactions with vendors Contact Person Responsible for Corrective Action: Dustin Dillard, Chief Contact Phone Number and Email Address: 812-331-1906; ddillard@monroefd.org Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: The District will adopt a policy related to State and Local Fiscal Recovery Funds (SLFRF) suspension and debarment requirements, and develop a system of internal controls that addresses the need to verify suspension, debarment, or other exclusions prior to entering into transactions with vendors who may have transactions equal to or exceeding $25,000 of federal funds in one year. Policy will include verification by checking the Excluded Parties List System (ELPS), collecting a certification from that vendor, or adding a clause or condition to the covered transaction with that vendor. Anticipated Completion Date: December 31, 2024

View Audit 322653

Finding 499789 (2023-002)

Significant Deficiency 2023

Caminar Latino Inc.

GA

Subrecipient Monitoring § 200.303

Condition: We reviewed all four subawards associated with the program during the audit period and noted that sub-award information for all four subrecipients was not submitted to the FSRS by the required submission deadline. Although all other compliance requirements were met, the late submission r...

Condition: We reviewed all four subawards associated with the program during the audit period and noted that sub-award information for all four subrecipients was not submitted to the FSRS by the required submission deadline. Although all other compliance requirements were met, the late submission represents a deficiency in reporting controls. Correction action: FSRS were submitted to the FFATA site. Responsible Person: Interim Co-CEO Anticipated completion date: Complete. Reports were submitted November 2023

View Audit 322640

Finding 499783 (2023-002)

Significant Deficiency 2023

Tri-County Senior Citizens and Housing, Inc.

CO

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

Finding 2023-002: Section 8 Project-Based Cluster Federal Assistance Number: 14.182 and 14.195 U.S. Department of Housing and Urban Development (Repeat of Finding 2022-002) Compliance Requirements: Cash Management, El...

Finding 2023-002: Section 8 Project-Based Cluster Federal Assistance Number: 14.182 and 14.195 U.S. Department of Housing and Urban Development (Repeat of Finding 2022-002) Compliance Requirements: Cash Management, Eligibility, Reporting, Special Tests and Provisions Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of administrative staff allowing the administrator to act in a more supervisory position. Action Taken: The Operation Administrator is overall responsible the operation of Tri-County Senior Center and Housing; working together with the bookkeeping staff and Executive Director as partners to maintain financial records and budgets. The Executive Director will sporadically review tenant eligibility of new certifications and re-certifications, HAP Contracts, samples of monthly HAP Assistance Payment requests, and her presence when auditors are in-house as well any other assistance requested by Administrator. To ensure the health, safety, and well-being of the residents and staff, the Administrator oversees the responsibilities and duties of all other staff in their roles, (Administration Assistant/Program Administrator-Senior Center Activities; Administration Assistant-Membership, monthly newsletters, answer phones and any other duties requested by the Administrator), to guide them in their specific roles so they understand their duties and responsibilities as administrative staff, and ensuring the facility meets all regulatory compliance standards. If there are questions regarding this plan, please call the responsible party at (719) 852-5778. Sincerely yours, Monica Wolfe Executive Director Tri-County Senior Citizens and Housing, Inc.

View Audit 322625

Finding 499753 (2023-004)

Material Weakness 2023

City of Lawrence

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedu...

FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedure to ensure appropriate segregation of duties and reviews, approvals, and oversight are in place for reporting. This policy will require that two staff members from the Controller's Office prepare the quarterly Project and Expenditure report (P&E report). One staff member shall be responsible for preparing the report and the other will complete a review and submission of the report. Anticipated Completion Date: 12/31/2024

View Audit 322579

Finding 499752 (2023-003)

Material Weakness 2023

City of Lawrence

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a pol...

FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedure to ensure compliance with Federal procurement laws. Additionally, our updated policy shall ensure that the City adheres to all procurement procedures outlined in Federal awards received by the City. This policy will ensure that contractors and subrecipients are not suspended, debarred, or otherwise excluded prior to entering any contracts or subawards. Anticipated Completion Date: 12/31/2024

View Audit 322579

Finding 499738 (2023-003)

Significant Deficiency 2023

National Network to End Domestic Violence, Inc.

DC

Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking § 200.303

The process for cash draws has been updated to include preparation by a supervisor at the outsourced accounting firm, review by the manager at the outsourced accounting firm and by an individual at the organization, and draws are made by the manager at the outsourced accounting firm. The federal fin...

The process for cash draws has been updated to include preparation by a supervisor at the outsourced accounting firm, review by the manager at the outsourced accounting firm and by an individual at the organization, and draws are made by the manager at the outsourced accounting firm. The federal financial reports are entered into the system by the manager at the outsourced accounting firm based on a file created by the supervisor at the outsourced accounting firm. Before being submitted they are printed to PDF and sent to the VP of Finance for review. In the absence of a VP of Finance, the partner in charge of the engagement at the outsourced accounting firm will review. The above corrective actions will be taken by the end of this year, December 31, 2024.

View Audit 322559

Finding 499730 (2023-003)

Material Weakness 2023

City of Richmond

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-003 Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2021 Pass-Through Entity: Direct grant Compliance Requirements: Procurement and Suspension and...

FINDING 2023-003 Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2021 Pass-Through Entity: Direct grant Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Condition: The City elected to receive the standard revenue loss allowance, allowing them to claim its total State and Local Fiscal Recovery Funds (SLFRF) allocation as revenue loss to use for government services. As such, all SLFRF program funds were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients’ use of revenue loss funds would not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury’s determination that the revenue loss eligible use category does not give rise to subawards, the City was only required to comply with suspension and debarment requirements related to covered transactions. Context: We noted there was one vendor that the City entered into contract with in the current year that exceeded $25,000 paid from SLFRF funds. This transaction, totaling $364,374 was selected for testing. The City was not able to provide support proving that the City had verified the vendor was not suspended or debarred prior to entering into the contract. Management asserts that this is being done, but support is not maintained. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City will include a suspension and debarment clause into our federal contracts going forward. Responsible Party and Timeline for Completion: The Controller, Deputy Controller and the Director of Strategic Initiatives. The Corrective Action will be implemented in January 2025.

View Audit 322539

Finding 499726 (2023-002)

Significant Deficiency 2023

Nevada Test Site Historical Foundation

NV

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

To ensure that only proper labor costs are included in grant funding requests, the invoice reported to the grant issuing agency is reviewed by the Project Manager and evidenced by his signature. This review includes reviewing the individual labor charges prior to signing the invoice. All individual...

To ensure that only proper labor costs are included in grant funding requests, the invoice reported to the grant issuing agency is reviewed by the Project Manager and evidenced by his signature. This review includes reviewing the individual labor charges prior to signing the invoice. All individuals who support the grant purpose and are funded by a grant will be separately identified and the ratio of allowable time to total time will be determined for each pay period. Allowable cost for each individual will be aggregated to the total labor cost for the period and be included in the invoice requesting fund draws. These procedures will be in effect as of the date of this writing.

View Audit 322531

Finding 499684 (2023-006)

Material Weakness 2023

St. Vincent De Paul Village, Inc.

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Corrective Action: Management will enhance and enforce existing policies and procedures over monitoring of rental reasonableness in compliance with HUD-determined fair market rent requirements. Management and Tenant Services team will perform a thorough review of all tenant files, a task executed in...

Corrective Action: Management will enhance and enforce existing policies and procedures over monitoring of rental reasonableness in compliance with HUD-determined fair market rent requirements. Management and Tenant Services team will perform a thorough review of all tenant files, a task executed in partnership with landlords and property management companies. Perform internal compliance checks with sub-recipients by FJV compliance staff on a quarterly basis. Finally, develop additional oversight procedures for accounting and documentation of tenant rents to guarantee accuracy within our accounting general ledgers. Name of Responsible Individual(s): Jason Brenier, Maria Rafanan, Jesse Casement, Christina Madriles, Ann Wieczorek, and Judy Bokhari Anticipated Completion Date: December 2024

View Audit 322528 Questioned Costs: $1

Finding 499667 (2023-005)

Material Weakness 2023

St. Vincent De Paul Village, Inc.

CA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Corrective Action: Management is in the process of updating its written procedures to ensure that allowable costs and cost principles comply with 2 CFR 200.403. This includes Grants Accounting implementing a manual process that empowers program employees to submit and approve Time & Allocation Exce...

Corrective Action: Management is in the process of updating its written procedures to ensure that allowable costs and cost principles comply with 2 CFR 200.403. This includes Grants Accounting implementing a manual process that empowers program employees to submit and approve Time & Allocation Excel Sheets. These sheets include attestations certifying actual labor costs monthly. This information is then taken to input by the grants accounting team into the Request for Reimbursement (RFR). This measure ensures that labor costs are accurately reflected and compliant with regulatory requirements. In addition, Management will implement policies and procedures regarding regular review of allocations for workers compensation and other similar expenses to ensure accuracy. Name of Responsible Individual(s): Jason Brenier and Judy Bokhari Anticipated Completion Date: December 2024

View Audit 322528

Finding 499659 (2023-004)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303 § 200.430

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is...

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: December 2025

View Audit 322528

Finding 499644 (2023-003)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.430

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, ma...

Corrective Action: Management, in the immediate term, will review its oversight and controls on the manual process Grants Accounting implemented for obtaining Time & Allocation Excel Sheet and calculating payroll and benefits costs accurately onto the Request for Reimbursement (RFR). Furthermore, management plans to collaborate with its Payroll Service Provider to capitalize on software upgrades, aiming to enhance the accuracy of Time & Allocation to grants and reduce errors by designing straight-through-process improvements. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: October 2024 – immediate term and December 2025 - software implementation.

View Audit 322528 Questioned Costs: $1

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