Corrective Action Plans

Finding 403212 (2023-001)

Material Weakness 2023

AL

Questioned Costs Allowable Costs / Cost Principles Special Tests & Provisions § 200.303 § 200.326

Item 2023‐001 – Special Tests and Provisions – Wage Rate Requirements Recommendation: 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federa...

Item 2023‐001 – Special Tests and Provisions – Wage Rate Requirements Recommendation: 2 CFR 200.303 requires the non‐Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non‐Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Kerry Bedsole, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all contractors and subcontractors regarding the wage rate requirements and has implemented additional procedures, effective October 1, 2023, stating that the Chief School Financial Officer, Kerry Bedsole, will review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.

View Audit 310378 Questioned Costs: $1

Finding 403176 (2023-002)

Significant Deficiency 2023

Public Health - Madison and Dane County

WI

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

City of Madison Fire Department will coordinate with the City of Madison, Internal Audit and Grants function of the Finance Department, for an independent person to review the reports before submission to ensure the loss revenue calculation and amounts reported are accurate. This additional internal...

City of Madison Fire Department will coordinate with the City of Madison, Internal Audit and Grants function of the Finance Department, for an independent person to review the reports before submission to ensure the loss revenue calculation and amounts reported are accurate. This additional internal control procedure will ensure there are proper review and approval processes over completeness and accuracy of reports before submissions to federal agencies.

View Audit 310331

Finding 403100 (2023-002)

Material Weakness 2023

Casa Grande Union High School District No. 82

AZ

Questioned Costs Allowable Costs / Cost Principles § 200.303

Finding Number: 2023‐002 Assistance Listing Numbers: 84.010; 84.027; 84.027X; 84.425U Program Names/Assistance Listing Titles: Title I Grants to Local Educational Agencies; Special Education Cluster; COVID‐19 Education Stabilization Fund Contact Person: Glenda Cole, Human Resources Director An...

Finding Number: 2023‐002 Assistance Listing Numbers: 84.010; 84.027; 84.027X; 84.425U Program Names/Assistance Listing Titles: Title I Grants to Local Educational Agencies; Special Education Cluster; COVID‐19 Education Stabilization Fund Contact Person: Glenda Cole, Human Resources Director Anticipated Completion Date: May 30, 2025 Planned Corrective Action: It has been noted that several of the concerns associated with lack of appropriate payroll procedures occurred due to lack of clear communication with HR regarding rates of pay for new and continuing employees. Therefore, procedures have been put in place to address these issues to ensure an effective, transparent process. The following procedures are in place (or are being implemented) to improve performance in the HR/Payroll Department: I. Position Changes for Employees During the School Year: Position Changes for an employee during the school year will be addressed in the following manner: a. The governing board will continue to receive a personnel recommendation form that includes: i. Employee name ii. Position details (such as rate of pay, position title, control code‐if the position is a replacement.) iii. Site relocation (if applicable) iv. Reason for the position change v. Effective date of the change b. Agreements/Contracts will be issued to staff members for their signature. c. Payroll receives the personnel document after board approval. If the position change for the employee is a replacement, payroll uses the control assigned by HR. If the position change is a new position, Finance assigns the control code and sends to HR. II. Agreements/Contracts for Staff Members: a. Agreements/contracts will be created for each staff member to obtain staff member signature after board approval. b. Agreements will be placed in the staff members’ files. c. Agreements will include: i. Employee name ii. New position/title iii. Site relocation (if applicable), iv. Rate of pay v. Effective date. vi. Employee signature and date d. Tracking of these agreements will occur using onboarding and transfer agreement spreadsheets. III. Communications a. Payroll and HR staff will meet weekly to clarify hiring/payroll issues as they arise. b. A documented flow of information; forms initiated by HR will be shared with payroll to ensure clarity of intent. IV. Flexibility and Amendments: a. As the process continues, certain points will be amended or adjusted to improve the efficiency of tracking employee status changes. V. Training a. HR and Payroll Staff received training last year regarding the use of HR and payroll software and will receive updated training in the 2024‐2025 school year. The District will reimplement (it had been used prior to 2022, but was discontinued) a more thorough use of payroll software in spring of 2025 to increase efficiency and accuracy. b. We will hire a consultant to work with staff for the 2024‐25 school year to ensure more transparent and efficient practice of tracking employee status changes in the District.

View Audit 310236 Questioned Costs: $1

Finding 403061 (2023-001)

Significant Deficiency 2023

American Diabetes Association

VA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.308 § 200.403 § 200.430

American Diabetes Association (ADA) is committed to ensuring the appropriate documentation is in place to adhere to federal regulations regarding activities allowed or unallowed and allowable costs. In response to the audit finding, ADA is taking the following corrective actions to address the audit...

American Diabetes Association (ADA) is committed to ensuring the appropriate documentation is in place to adhere to federal regulations regarding activities allowed or unallowed and allowable costs. In response to the audit finding, ADA is taking the following corrective actions to address the audit recommendations: 1) Financial Services will communicate annual reminders of the existing policy relating toweekly completion and manager review of time records to all ADA team members. 2) Federal grant program management will perform weekly monitoring of all time recordsapplicable to federal awards to ensure that time is reviewed and approved by a manager with knowledge of staff activities so that ADA conforms to federal regulations regardingactivities allowed or unallowed and allowable costs. 3) Financial Services will execute a reimbursement request only once all time is reviewed and approved by a manager with knowledge of staff activities.

View Audit 310207

Finding 402908 (2023-005)

Significant Deficiency 2023

Mayo Clinic

MN

Questioned Costs Procurement, Suspension & Debarment § 200.214 § 200.303 § 200.319 § 200.320

Federal Program Information Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Pass-Through Entity: The University of Texas Health (93.853, NS119834) Assistance Listing Nos.: 12.420, 93.310, 93.353, 93.393, an...

Federal Program Information Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of Defense Federal Cluster: Research and Development (R&D) Pass-Through Entity: The University of Texas Health (93.853, NS119834) Assistance Listing Nos.: 12.420, 93.310, 93.353, 93.393, and 93.853 Award Numbers: W81XWH-15-1-0292 (12.420), OD23121 (93.310), CA246568 (93.353), CA259201 (93.393), NS119834 (93.853), NS122096 (93.853) Award Periods: Various Corrective Action Planned Management conducted an education and training session for procurement teams in June 2024 to reinforce procurement requirements and documentation standards. Management will implement an independent sanction and debarment check for suppliers as part of existing quarterly audits over Supplier AP vendor master tables and related changes to those tables. Persons Responsible for Corrective Action Daniel Schmitz, Division Chair - Supply Chain Management Scott Hammer, Director - Supply Chain Management Target Completion Date June 30, 2024

View Audit 310163 Questioned Costs: $1

Finding 402859 (2023-004)

Significant Deficiency 2023

National Fair Housing Alliance

DC

Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.319 § 200.320

Views of Responsible Officials: NFHA will review and update its current Procurement Policies to ensure that they meet all current Federal and Uniform Guidance requirements. This will include documentation of contractor selection and single source vendor criteria. NFHA will provide additional trainin...

Views of Responsible Officials: NFHA will review and update its current Procurement Policies to ensure that they meet all current Federal and Uniform Guidance requirements. This will include documentation of contractor selection and single source vendor criteria. NFHA will provide additional training to all staff on the revised policies and procedures.

View Audit 310063

Finding 402858 (2023-003)

Material Weakness 2023

National Fair Housing Alliance

DC

Procurement, Suspension & Debarment § 200.214 § 200.303

Views of Responsible Officials: NFHA previously had a process in place, but it was not implemented properly during this fiscal year by the person to whom the responsibility was transferred. NFHA has resumed the process to perform checks in SAM.gov as part of the onboarding process for all new vendor...

Views of Responsible Officials: NFHA previously had a process in place, but it was not implemented properly during this fiscal year by the person to whom the responsibility was transferred. NFHA has resumed the process to perform checks in SAM.gov as part of the onboarding process for all new vendors. NFHA will also perform reviews of existing vendors on an annual basis and maintain evidence of these checks with the appropriate vendor files.

View Audit 310063

Finding 402853 (2023-001)

Significant Deficiency 2023

New Jersey Turnpike Authority

NJ

Allowable Costs / Cost Principles Cash Management Eligibility § 200.303 § 200.403 § 200.406 § 200.430

Findings Related to the Financial Statements Reported in Accordance with Government Auditing Standards None Findings Related to Federal Awards 2023-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: U.S. Department of Homeland Security: Passed through the Sta...

Findings Related to the Financial Statements Reported in Accordance with Government Auditing Standards None Findings Related to Federal Awards 2023-001 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Federal Agency: U.S. Department of Homeland Security: Passed through the State of New Jersey, Department of Law and Public Safety Program Titles and Assistance Listing Numbers (ALN): Disaster Grants – Public Assistance (Presidentially Declared Disasters) – ALN 97.036 Federal Grant Numbers: State of New Jersey pass-through number: UH1WX, Project Worksheet #1822 – Award Year 2023 (Application 553330) Contact Person: Donna Wilser, Deputy Executive Director, 732-750-5300 Corrective Action: Management agrees with the finding. We are committed to strengthening our processes to ensure that all physical timesheets related to FEMA-declared disaster events are properly maintained and readily accessible. To achieve this, we will implement enhanced procedures and controls to ensure full compliance with the Uniform Guidance requirements. Anticipated Completion Date: December 1st, 2024

View Audit 310037

Finding 402552 (2023-031)

Significant Deficiency 2023

State of Michigan

MI

Reporting Internal Control / Segregation of Duties § 200.303

Finding 2023-031 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Workfront Change Management Process Management Views DTMB agrees with the finding. Planned Corrective Action DTMB has created an enhancement tracker to track key documentation throughout the change management process...

Finding 2023-031 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Workfront Change Management Process Management Views DTMB agrees with the finding. Planned Corrective Action DTMB has created an enhancement tracker to track key documentation throughout the change management process. This will ensure that DTMB maintains documentation of testing results at all stages and authorization and completion of all change order requests. DTMB has also enhanced documentation for meetings between program management and development teams. Anticipated Completion Date Completed Responsible Individual(s) Jennifer Edmonds, DTMB

View Audit 309982

Finding 402551 (2023-030)

Significant Deficiency 2023

State of Michigan

MI

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Finding 2023-030 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Workfront Security Management and Access Controls Management Views DTMB agrees with the finding. Planned Corrective Action For part a., DTMB has implemented processes and documentation to track user access requests to...

Finding 2023-030 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Workfront Security Management and Access Controls Management Views DTMB agrees with the finding. Planned Corrective Action For part a., DTMB has implemented processes and documentation to track user access requests to support approval of the system role for all Workfront users. For part b., DTMB has updated processes to ensure it maintains documentation to support the review of all privileged Workfront accounts on a semiannual basis. Anticipated Completion Date Completed Responsible Individual(s) Jennifer Edmonds, DTMB

View Audit 309982

Finding 402548 (2023-027)

Significant Deficiency 2023

State of Michigan

MI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Period of Performance § 200.303

Finding 2023-027 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Insufficient Respite Payment Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS began performing weekly reconciliations of the Medical Services Administration Manual Payment Syste...

Finding 2023-027 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Insufficient Respite Payment Controls Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS began performing weekly reconciliations of the Medical Services Administration Manual Payment System (MSAPay) payment details and Home Help beneficiary applications during February 2024, to ensure only approved outstanding applications are paid. In addition, MDHHS implemented additional steps in the MSAPay approval process during May 2024 to prevent duplicate payments, including a review process to verify the beneficiary did not receive previous payments related to the respite grant, prior to creating a new payment voucher. Anticipated Completion Date Completed Responsible Individual(s) Crystal Kline, MDHHS Jessica Bowen, MDHHS Elaina Brown, MDHHS

View Audit 309982

Finding 402547 (2023-026)

Significant Deficiency 2023

State of Michigan

MI

Allowable Costs / Cost Principles Cash Management Eligibility § 200.303

Finding 2023-026 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Grant Reimbursement Approval Procedures Management Views EGLE agrees with the finding. Planned Corrective Action EGLE’s Water Resources Division’s Administration staff reviewed the existing process with staff conducti...

Finding 2023-026 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - Grant Reimbursement Approval Procedures Management Views EGLE agrees with the finding. Planned Corrective Action EGLE’s Water Resources Division’s Administration staff reviewed the existing process with staff conducting the administrative review to ensure the technical review will be completed in advance of making any payment. If Administration staff have received a request for payment without the technical review, Administration staff will forward all documents received to the project manager to obtain the technical review. Once the technical review has been completed, Administration staff will conduct the administrative review and process the payment request. Additionally, EGLE subsequently reviewed the reimbursement request noted in the finding to ensure that the cumulative totals requested have been for projects that are consistent with the grant award. Anticipated Completion Date Completed Responsible Individual(s) Phil Argiroff, EGLE Amy Hicks, EGLE

View Audit 309982

Finding 402528 (2023-024)

Significant Deficiency 2023

State of Michigan

MI

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.306

Finding 2023-024 Fish and Wildlife Cluster, ALN 15.605, 15.611, and 15.626 - Inappropriate Telecommunication Expenditures Management Views DNR agrees with the finding. Planned Corrective Action DNR sent an email communication on May 7, 2024, to the Department Budget Control Team as a reminder to u...

Finding 2023-024 Fish and Wildlife Cluster, ALN 15.605, 15.611, and 15.626 - Inappropriate Telecommunication Expenditures Management Views DNR agrees with the finding. Planned Corrective Action DNR sent an email communication on May 7, 2024, to the Department Budget Control Team as a reminder to use the monthly DTMB telecom billing detail to verify all employees coded to fish and wildlife activities are valid. The monitoring of these charges will continue to occur as part of the interim quarterly assessments. Anticipated Completion Date Completed Responsible Individual(s) Jennifer Houle, DNR

View Audit 309982

Finding 402493 (2023-007)

Significant Deficiency 2023

State of Michigan

MI

Internal Control / Segregation of Duties § 200.303

Finding 2023-007 MDE, Change Management Process Management Views MDE agrees with the finding. Planned Corrective Action MDE and DTMB will work to implement a regular review of DevOps tickets to ensure documentation is maintained at all stages of the process, that change order requests are closed, ...

Finding 2023-007 MDE, Change Management Process Management Views MDE agrees with the finding. Planned Corrective Action MDE and DTMB will work to implement a regular review of DevOps tickets to ensure documentation is maintained at all stages of the process, that change order requests are closed, and the completion is documented in a timely manner. Anticipated Completion Date October 1, 2024 Responsible Individual(s) Monica Butler, MDE Sean Strom, DTMB

View Audit 309982

Finding 402492 (2023-006)

Significant Deficiency 2023

State of Michigan

MI

Subrecipient Monitoring Cash Management Reporting § 200.303

Finding 2023-006 MDE, Security Management and Access Controls Management Views The Michigan Department of Education (MDE) agrees with the finding. Planned Corrective Action For part a., as part of the Michigan Nutrition Data (MiND) 2.0 Implementation Project, MDE will institute a mechanism to capt...

Finding 2023-006 MDE, Security Management and Access Controls Management Views The Michigan Department of Education (MDE) agrees with the finding. Planned Corrective Action For part a., as part of the Michigan Nutrition Data (MiND) 2.0 Implementation Project, MDE will institute a mechanism to capture the person to whom the access has been delegated. MDE will review the policies and procedures with department staff that is responsible for security access controls for the Next Generation Grant, Application and Cash Management System (NexSys) to ensure proper access control policies are followed. For part b., MDE will update policies and procedures to ensure review of all accounts on a semi-annual basis. For parts c. and d., MDE will continue to work with DTMB to find more efficient ways to ensure all non-privileged users are recertified and improve the technical solution to deactivate users after 18 months of inactivity. For part e., as part of the movement of the grants management unit at MDE to a different office, MDE is reviewing the policies around high-risk transactions and will update the policies to meet established standards. Anticipated Completion Date October 1, 2024 Responsible Individual(s) David Judd, MDE

View Audit 309982

Finding 402473 (2023-003)

Significant Deficiency 2023

State of Michigan

MI

Internal Control / Segregation of Duties § 200.303

Finding 2023-003 Bridges Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS updated change control processes on May 18, 2023, requiring documentation of an alternate validation approval following each Bridges Integrated Automated Eligibility D...

Finding 2023-003 Bridges Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS updated change control processes on May 18, 2023, requiring documentation of an alternate validation approval following each Bridges Integrated Automated Eligibility Determination System (Bridges) release that does not have field testers performing post implementation validation. For Bridges releases occurring after May 18, 2023, MDHHS sends a communication within three business days after each release that validates the changes to Bridges were applied as expected and this validation is documented and retained as part of the release close-out process. Each exception identified occurred prior to the implemented corrective action. Anticipated Completion Date Completed Responsible Individual(s) Holly Roderick, MDHHS

View Audit 309982

Finding 402472 (2023-002)

Material Weakness 2023

State of Michigan

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

Finding 2023-002 Bridges Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a., c., and d., MDHHS implemented the Database Security Application (DSA) on October 2, 2023, which includes documenting incompatible role exception ...

Finding 2023-002 Bridges Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a., c., and d., MDHHS implemented the Database Security Application (DSA) on October 2, 2023, which includes documenting incompatible role exception requests and user access request approvals. The DSA also includes semi-annual review of privileged users and annual review for all users. For parts b. and e., MDHHS will revise internal business processes to include an additional level of monitoring and review to ensure compliance with the existing directives related to monitoring and review requirements. Anticipated Completion Date a., c., and d. Completed b. and e. August 2024 Responsible Individual(s) a., c., and d. Deon Nelson, MDHHS b. and e. Veronica Maxson, MDHHS

View Audit 309982

Finding 402469 (2023-001)

Significant Deficiency 2023

Community Loan Fund of New Jersey, Inc.

NJ

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding Related to Federal Awards 2023-001 Procurement – Suspension and Debarment Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Bond Guarantee Program - ALN 21.014 Federal Grant Numbers: 19-BGA-00003 ...

Finding Related to Federal Awards 2023-001 Procurement – Suspension and Debarment Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Bond Guarantee Program - ALN 21.014 Federal Grant Numbers: 19-BGA-00003 Contact Person: Varun Agnihotri, Manager Director, Portfolio Management, 732-640-2061 Corrective Action: A process and checklist will be put in place to ensure the independent status search is performed on recipients when a payment is made. The process and checklist will include a verification by someone other than the person preparing the request. Anticipated Completion Date: September 30, 2024

View Audit 309975

Finding 402467 (2023-011)

Material Weakness 2023

City of Cambridge Massachusetts

MA

Period of Performance Internal Control / Segregation of Duties Material Weakness § 200.303

Cambridge Public Schools' CFO or Grants Coordinator will review and sign-off on all tuition requisitions that will be charged to grants to confirm the grant approval date and compliance with the period of performance.

View Audit 309973

Finding 402465 (2023-010)

Material Weakness 2023

City of Cambridge Massachusetts

MA

Reporting Material Weakness Internal Control / Segregation of Duties § 200.303 § 200.328

The Finance department will document the reconciliation of the City's GL ARPA expenditures and obligations to the Department of Treasury ARPA reporting portal report both quarterly and annually. All reconciling adjustments and GL report documentation will be properly retained.

View Audit 309973

Finding 402463 (2023-009)

Material Weakness 2023

City of Cambridge Massachusetts

MA

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

The City will use a subrecipient audit certification form and a subrecipient risk assessment questionnaire to evaluate a subrecipient's risk/experience with federal funds as well as assess their federal funding threshold for having a single audit.

View Audit 309973

Finding 402461 (2023-008)

Material Weakness 2023

City of Cambridge Massachusetts

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

The City will ensure that subrecipient contracts will include language about suspension and debarment. The City will also download a PDF copy of the subrecipients registration on SAM.GOV showing the subrecipient's Exclusion Summary Status.

View Audit 309973

Finding 402459 (2023-007)

Material Weakness 2023

City of Cambridge Massachusetts

MA

Subrecipient Monitoring HUD Housing Programs Material Weakness § 200.303

The City will work with all HOPWA subrecipients to ensure that a complete and accurate CAPER is completed in the appropriate format as required by HUD. This will include a focus on inputting the correct (eg, actual expended vs. award amount) funding amount.

View Audit 309973

Finding 402457 (2023-006)

Material Weakness 2023

City of Cambridge Massachusetts

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

The City will use the contract start date (7/1) as the Obligation date, and will submit the FFATA report accordingly.

View Audit 309973

Finding 402455 (2023-005)

Material Weakness 2023

City of Cambridge Massachusetts

MA

Subrecipient Monitoring § 200.303 § 200.332

The City will incorporate a more formal review of financial audits of subrecipients in conjunction with new contracts moving forward. These audits, and City staff's verification of assessment will be included in each subrecipient file.

View Audit 309973

Corrective Action Plans

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