Corrective Action Plans

Finding 1171982 (2023-019)

Material Weakness 2023

MH

Subrecipient Monitoring § 200.303

Condition 1: #1–4, #5–7, #11–13: The MOF requires that all necessary documents, including expenditure and financial reports, be submitted prior to the release of subsequent funding. These reports are reviewed and processed by the Compliance Unit once complete. #8-9, #10, #12: The MOF, through the Co...

Condition 1: #1–4, #5–7, #11–13: The MOF requires that all necessary documents, including expenditure and financial reports, be submitted prior to the release of subsequent funding. These reports are reviewed and processed by the Compliance Unit once complete. #8-9, #10, #12: The MOF, through the Compliance Unit, enforces payment terms strictly in accordance with the relevant memoranda of agreement. Condition 2: The subrecipient monitoring tool will be consolidated and used by the Budget Division, SOEMU, and the Compliance Unit. Once MOAs are drafted, the preparer will update the monitoring tool, which will then be reviewed by the Compliance Unit for completeness and accuracy against the Appropriation Act. Condition 3: The subrecipient monitoring tool will be updated to track the time elapsed between the transfer of Federal funds to the subrecipient and the disbursement of those funds for program purposes.

View Audit 385081

Finding 1171980 (2023-016)

Material Weakness 2023

Republic of the Marshall Islands

MH

Procurement, Suspension & Debarment § 200.214 § 200.303 § 200.317 § 200.323

Conditions 1-3: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Con...

Conditions 1-3: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 4: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.

View Audit 385081

Finding 1171979 (2023-015)

Material Weakness 2023

Republic of the Marshall Islands

MH

Period of Performance Internal Control / Segregation of Duties § 200.303

Condition 1: The new FMIS includes built-in controls to monitor the period of performance, including tracking the last day for encumbrances and payments, ensuring timely and accurate financial management. Condition 2: In FY2025, all invoices with corresponding purchase orders are uploaded into the s...

Condition 1: The new FMIS includes built-in controls to monitor the period of performance, including tracking the last day for encumbrances and payments, ensuring timely and accurate financial management. Condition 2: In FY2025, all invoices with corresponding purchase orders are uploaded into the system by the Procurement & Supply Division. Once uploaded, the Accounting Division reviews and processes payments accordingly. Additionally, Accounting Management reinstated the pre- review of payment request vouchers with corresponding BRVs prior to payment issuance to strengthen controls and ensure compliance. Condition 3: A control process is currently in place whereby each Notice of Award (NOA) is assigned to a single, corresponding SPG account. Condition 4: NOAs and all relevant grant documents are required to be uploaded to Bisan at the time a new SPG account is created.

View Audit 385081

Finding 1171976 (2023-011)

Material Weakness 2023

Republic of the Marshall Islands

MH

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Condition 1: #1 In FY2025, the Accounting Management reinstated the pre- review of payment voucher requests to ensure all payments are properly reviewed prior to issuance. #2 Effective 3rd qtr. of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment ...

Condition 1: #1 In FY2025, the Accounting Management reinstated the pre- review of payment voucher requests to ensure all payments are properly reviewed prior to issuance. #2 Effective 3rd qtr. of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment process. Condition 2: #1 In early June 2025, a memo was issued to all Ministries and Agencies instructing that payroll will not be approved without submission of leave slips. #2 Same response as Condition 1 #2

View Audit 385081

Finding 1171700 (2023-010)

Material Weakness 2023

Osage County

OK

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

Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk's administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to up...

Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk's administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to update procedures and build stronger internal controls, • developing and formalizing policies to ensure full compliance with federal grant requirements, • and improving communication between offices to ensure federal reporting is accurate and timely. Our collective commitment is to put permanent measures in place to prevent these issues from recurring and to uphold the highest level of compliance for all federal programs. County Clerk: I was not the County Clerk in office at this time. The County will comply with all aspects of grant reporting and requirements. The Officials will work together to put policies and procedures in place to ensure more accurate reporting. County Treasurer: The County Officers will work on better communication to more accurately report the SEFA funds.

View Audit 384730

Finding 1171303 (2023-088)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Reporting § 200.303

VITEMA concurs with this finding. VITEMA uses the sub-recipient agreement as the source of documentation for enrollment into FFATA. This agreement is signed by the Director of VITEMA and Sub Recipient. VITEMA's Grant Management staff will upload this information into the FRS/SAMS.GOV system. VITEMA'...

VITEMA concurs with this finding. VITEMA uses the sub-recipient agreement as the source of documentation for enrollment into FFATA. This agreement is signed by the Director of VITEMA and Sub Recipient. VITEMA's Grant Management staff will upload this information into the FRS/SAMS.GOV system. VITEMA's Deputy Director of Grants Management will review the FFTA information and validate that the information is true and correct based on the amount approved by DHS and sub-recipient agreement. This FFTA document will be signed and dated by the Deputy Director of Grants Management within the 30 days of required enrollment.

View Audit 384576

Finding 1171302 (2023-087)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Matching / Level of Effort / Earmarking Reporting § 200.303

VITEMA concurs with this finding. This information is documented in BSIR as part of the submittal process and does not allow for the submittal of reporting if not verified to meet this requirement. VITEMA will also document this information when preparing the SF 425 report by including this informat...

VITEMA concurs with this finding. This information is documented in BSIR as part of the submittal process and does not allow for the submittal of reporting if not verified to meet this requirement. VITEMA will also document this information when preparing the SF 425 report by including this information in the notes section of this report. This will be conducted on a quarterly basis.

View Audit 384576

Finding 1171301 (2023-086)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring § 200.303 § 200.331 § 200.332 § 200.521

The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the recipient, it is the territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient a...

The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the recipient, it is the territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient agreement which outlines the terms and conditions of the program. The Disaster Program Financial Specialist is responsible for obtaining the subrecipient agreement and ensure it has been signed by the Applicant/Subrecipient and Governor's Authorized Rep and later provided to the Territorial Public Assistance Officer (TPAO). As such, no funds will be disbursed until the Subrecipient signs and returns the agreement. These agreements are saved in a centralized location for documentation and audit purposes. In accordance with the 2CFR #200 Subpart F, all Subrecipients must comply with applicable audit requirements because the applicant is in the receipt of federal funding. Under 2CFR #200.500 Subpart F applies to any non-federal entity that expends $750,000 or more in federal awards during a fiscal year. Subrecipients meeting this threshold are required to undergo a single audit or a program specific audit for that fiscal year. The TPAO will review audit requirements during the applicant's briefing and will incorporate these requirements into the Subrecipient Agreement.

View Audit 384576

Finding 1171300 (2023-085)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

In accordance with 2CFR #200.303 federal recipients VITEMA/ODR must create internal controls that provide reasonable assurance that FFATA reporting requirements are met. Currently, internal controls have been established to ensure compliance with the Federal Funding Accountability and Transparency A...

In accordance with 2CFR #200.303 federal recipients VITEMA/ODR must create internal controls that provide reasonable assurance that FFATA reporting requirements are met. Currently, internal controls have been established to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA). On a monthly basis, the Disaster Program Administrative Assistant in responsible for obtaining the P5 report from the Grants Manager and entering all project with obligated funds exceeding $30,000 into the SAM.gov database, formerly FSRS.gov. The report must be submitted by the end of the following month. Once the data is entered, the Territorial Public Assistance Officer reviews the submission and, upon the verification, certifies that the information has been accurately reported in the federal database. The reports and associated certifications will be placed in a centralized database.

View Audit 384576

Finding 1171299 (2023-084)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Eligibility Special Tests & Provisions § 200.303

DHS continues working with a vendor on the implementation of the Provider Enrollment Application (PEA). Beginning in February 2026, the vendor will assume responsibility for enrolling all USVI providers—both in-territory and out-of-territory. Their enrollment process will address the three bulleted ...

DHS continues working with a vendor on the implementation of the Provider Enrollment Application (PEA). Beginning in February 2026, the vendor will assume responsibility for enrolling all USVI providers—both in-territory and out-of-territory. Their enrollment process will address the three bulleted conditions.

View Audit 384576

Finding 1171298 (2023-083)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

The Department understands the importance of System Security and recognizing its weaknesses and vulnerabilities. In lieu of this, we have conducted an overall cybersecurity risk assessment for entire IT infrastructure. The Department’s strategy to become compliant with the VIBES System Security Revi...

The Department understands the importance of System Security and recognizing its weaknesses and vulnerabilities. In lieu of this, we have conducted an overall cybersecurity risk assessment for entire IT infrastructure. The Department’s strategy to become compliant with the VIBES System Security Review includes updating the scope of work with contracted vendor for this system. The scope of work will now include annual Risk Assessments and Security Reviews.

View Audit 384576

Finding 1171297 (2023-082)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Cash Management Internal Control / Segregation of Duties § 200.303

The Department of Human Services intends to shift the responsibility of Cost Reports internally to Fiscal Office, under the supervision of the Director of Audit and Compliance. The first step towards this initiative will require a contract to be executed, and subsequently the utilization of a templa...

The Department of Human Services intends to shift the responsibility of Cost Reports internally to Fiscal Office, under the supervision of the Director of Audit and Compliance. The first step towards this initiative will require a contract to be executed, and subsequently the utilization of a template for quick calculation. We consider this a high-priority initiative that will provide much-needed revenues to the coffers. Once the contract has been executed, goal is to be up-to-date within 6-9 months.

View Audit 384576

Finding 1171296 (2023-081)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The Program Integrity Unit has established SOPPs which identifies the method for identifying fraud cases, investigating cases, and developed procedures in collaborating and cooperating with legal authorities, for referring credible allegations of fraud cases to law enforcement officials.

View Audit 384576

Finding 1171295 (2023-080)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Currently, reports are submitted for review via email. The CMS-64 as well as the CMS-37 is prepared by a consulting firm who submits the copy of the reports for review and approval. Once the Medicaid Director is satisfied, an email is sent approving the report, for further entering into the MBES (CM...

Currently, reports are submitted for review via email. The CMS-64 as well as the CMS-37 is prepared by a consulting firm who submits the copy of the reports for review and approval. Once the Medicaid Director is satisfied, an email is sent approving the report, for further entering into the MBES (CMS system of record) and certification. To ensure access for audit purposes, the Department has implemented a shared folder where copies of approval emails and any time extension requests are stored, since the submission portal does not allow for attachments. Additionally, a Director of Federal Grants has been on-boarded who will assume the role of preparing the reports.

View Audit 384576

Finding 1171294 (2023-079)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

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

The ERP provides an overall expense report, a specific liquidation report has been developed to ensure that matching is completed with each report submission. Additionally, a program specific Federal Grants Financial Analyst with the sole focus on the Supplemental Nutrition Program. Lastly, a Direct...

The ERP provides an overall expense report, a specific liquidation report has been developed to ensure that matching is completed with each report submission. Additionally, a program specific Federal Grants Financial Analyst with the sole focus on the Supplemental Nutrition Program. Lastly, a Director of Audit and Compliance has been onboarded. Once the audit team is developed, support and compliance monitoring will be provided to ensure compliance.

View Audit 384576

Finding 1171293 (2023-078)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Internal Control / Segregation of Duties Eligibility Reporting § 200.303

Currently, a Standard Operating Policies and Procedures (SOPPs) for certification and recertification procedures is being updated. Additionally, DHS hired a Program Integrity Director in August 2023 and Medical Eligibility Quality Control (MEQC) Reviewer in June 2025 also tasked with the responsibil...

Currently, a Standard Operating Policies and Procedures (SOPPs) for certification and recertification procedures is being updated. Additionally, DHS hired a Program Integrity Director in August 2023 and Medical Eligibility Quality Control (MEQC) Reviewer in June 2025 also tasked with the responsibility of reviewing completed case files.

View Audit 384576

Finding 1171292 (2023-077)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Reporting Subrecipient Monitoring § 200.303

DHS is committed to strengthening internal controls and addressing the auditors’ concern related to the reconciliation process and the importance of clear, auditable reconciliation processes that fully support the preparation of the Schedule of Expenditures of Federal Awards (SEFA) and demonstrate c...

DHS is committed to strengthening internal controls and addressing the auditors’ concern related to the reconciliation process and the importance of clear, auditable reconciliation processes that fully support the preparation of the Schedule of Expenditures of Federal Awards (SEFA) and demonstrate compliance with internal control requirements. DHS will continue to collaborate closely with the auditors and other stakeholders in the reconciliation process and SEFA preparation to ensure all affected parties confirm receipt of required documentation so determination of compliance can be readily identified, confirming DHS’s commitment to federal funds stewardship. To achieve this, DHS will streamline communication between all parties through a designated point of contact, the Director of Audit & Compliance who onboarded in August 2025, to make certain that necessary documentation is distributed to all stakeholders involved.

View Audit 384576

Finding 1171278 (2023-076)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Reporting Internal Control / Segregation of Duties § 200.303

DHS remains in collaboration with Federal Partners relative to the required change to reflect a consolidated report in the Payment Management System financial reporting module. All parties are in agreement that one report is required representing the financial expenditure reporting mirroring the cor...

DHS remains in collaboration with Federal Partners relative to the required change to reflect a consolidated report in the Payment Management System financial reporting module. All parties are in agreement that one report is required representing the financial expenditure reporting mirroring the core concept of the consolidation of the various grants. Relative to the pre and post expenditures, reports are submitted through the portal, represented by a submission log. There are no provisions for approval or acceptance by the Federal partners apparent in said portal. While email notices are received acknowledging receipt, a formal acceptance is not received. Conversations are ongoing with the Federal partners relative to receiving a formal notification.

View Audit 384576

Finding 1171277 (2023-075)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Period of Performance Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.344

As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Fiscal Analyst ...

As part of the close-out process, all open purchase orders are now submitted to the Department of Finance for closure. The grant close-out process has been shifted to the OMB to ensure the grant is no longer available for transaction entries or liquidations. Additionally, a dedicated Fiscal Analyst is being integrated into the workflow to ensure compliance.

View Audit 384576

Finding 1171276 (2023-074)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.303 § 200.403 § 200.430

The Department of Human Services (DHS) adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and ...

The Department of Human Services (DHS) adopted the electronic Timeforce (STATS) system for payroll, replacing manual processes. Time and attendance are approved through management levels, with payroll based on Notice of Personnel Action (NOPA) cost centers. Financial Analysts reconcile payroll, and a workflow ensures accurate NOPA listings for payroll purposes. Additionally, in order to ensure that Notice’s of Personnel Actions are updated on a timely basis, ensuring that salaries are charged to the respective account, DHS has implemented the following process: (1) Provisional Payroll Codes are requested prior to the close of the Fiscal Year by the Department of Finance through the Office of Management and Budget through the established process. (2) Once the codes are received, the Division of Human Resources will update the most current Personnel Distribution Sheets to reflect active employees. (3) The sheets will be submitted to Fiscal certification by the CFO, (4) NOPAS are updated with the provisional codes.

View Audit 384576

Finding 1171275 (2023-073)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Eligibility Special Tests & Provisions Subrecipient Monitoring § 200.303

An internal programmatic audit process is actively utilized. Subsidy determinations are cross-checked by different workers according to federally and locally established policies. Additionally, DHS is in the process of developing an internal audit and compliance unit. With the requisite staffing, in...

An internal programmatic audit process is actively utilized. Subsidy determinations are cross-checked by different workers according to federally and locally established policies. Additionally, DHS is in the process of developing an internal audit and compliance unit. With the requisite staffing, internal audits will be conducted to ensure alignment with the Federal mandates in addition to ensuring overall compliance.

View Audit 384576

Finding 1171274 (2023-072)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

An internal programmatic audit process is actively utilized, involving the exchange of caseloads between workers. Eligibility and subsidy determinations are cross-checked by different workers according to federally and locally established policies. Additionally, DHS is in the process of developing a...

An internal programmatic audit process is actively utilized, involving the exchange of caseloads between workers. Eligibility and subsidy determinations are cross-checked by different workers according to federally and locally established policies. Additionally, DHS is in the process of developing an internal audit and compliance unit. With the requisite staffing, internal audits will be conducted to ensure alignment with the Federal mandates in addition to ensuring overall compliance.

View Audit 384576

Finding 1171273 (2023-071)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Subrecipient Monitoring Eligibility § 200.303

DHS remains in compliance with this finding from previous audit years, the untimely submission led to the issue in current year. To address this, a shared file will be established to ensure that the necessary information for each year is readily available for audit purposes.

View Audit 384576

Finding 1171272 (2023-070)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

A Federal Grants Financial Analyst for CCDF program has been hired and is tasked with ensuring the accuracy and submission of financial reports. Internal controls have been established, requiring final review and approval by a supervisor.

View Audit 384576

Finding 1171271 (2023-069)

Material Weakness 2023

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Matching / Level of Effort / Earmarking § 200.303

DHS is in the process of finalizing corrective actions to address the conditions noted and to enhance compliance across all CCDF funding sources: 1. Formalization of Policies and Procedures DHS will develop and document written policies and procedures governing compliance with CCDF administrative co...

DHS is in the process of finalizing corrective actions to address the conditions noted and to enhance compliance across all CCDF funding sources: 1. Formalization of Policies and Procedures DHS will develop and document written policies and procedures governing compliance with CCDF administrative cost caps, quality earmarks, direct services requirements, and level of effort provisions. These procedures will define roles, monitoring responsibilities, documentation standards, and supervisory review requirements. 2. Strengthened Monitoring Throughout the Fiscal Year DHS has already implemented periodic monitoring throughout the fiscal year to track administrative, quality, and direct service expenditures against federal requirements, rather than relying solely on final year reporting. Monitoring includes monthly reconciliation of expenditures to accounting records in addition to reoccurring monthly meetings jointly with Program and Fiscal to align plans with outcomes. 3. Improved Financial Reporting Controls DHS ensures that all required ACF 696 Financial Reporting Forms are prepared accurately, fully reconciled to the general ledger, and retained in accordance with record keeping requirements. Any discrepancies identified during reconciliation are reviewed and resolved prior to final submission. 4. Designation of Compliance Oversight Responsibility DHS has onboarded a Federal Grants Financial Analyst dedicated to the Child Care program in September of 2024. Additionally, in August 2025, a Director of Audit and Compliance was also onboarded. This will allow for a closer collaboration with the external auditors in ensuring compliance with documentation to support audit and federal review. These corrective actions are intended to strengthen DHS’s internal control framework, improve documentation and monitoring processes, and ensure sustained compliance with CCDF matching, level of effort, and earmarking requests.

View Audit 384576

Corrective Action Plans

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