Corrective Action Plans

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To Whom it May Concern: The purpose of the Corrective Action Plan (CAP) is to define corrective actions for resolving any non-conformances identified during the single audit for Fiscal Year 2023. Federal Award Findings and Questioned Costs Finding 2023-001 - Material Weakness in Internal Control -...
To Whom it May Concern: The purpose of the Corrective Action Plan (CAP) is to define corrective actions for resolving any non-conformances identified during the single audit for Fiscal Year 2023. Federal Award Findings and Questioned Costs Finding 2023-001 - Material Weakness in Internal Control - Reporting Assistance Listing Number: 93.498 COVID-19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Federal Agency: U.S. Department of Health and Human Services Pass-Through Agency: Not Applicable Award Number/Year: Not Applicable / 2023 Criteria: Non-federal entities in receipt of federal funds must comply with the requirements of 2 CFR 200.303(a), which require an entity to establish and maintain effective internal control over the Federal award to ensure compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Recipients of Provider Relief Funds (PRF) payments must also comply with the reporting requirements described in the PRF terms and conditions and specified in directions issued by the U.S. Department of Health and Human Services. Condition/Context: The Company did not complete the PRF reporting in accordance with the U.S. Department of Health and Human Services guidance. For the one report filed during the award year it was noted to include incorrect lost revenue totals, due to clerical errors and the exclusion of certain affiliates. In addition, the reports tested did not contain a documented review and approval of the reports prior to submission. Effect: The amounts reported to Health Resources and Services Administration (HRSA) were not in accordance with established U.S. Department of Health and Human Services reporting guidance. Total cumulative lost revenue should be $13,893,503. Questioned Costs: None reported. Cause: Lack of management oversight. Recommendation: We recommend that management review and update, as needed, their procedure for completion of the reporting to ensure that a review and approval of such reporting is completed and documented prior to submission. Additionally, we recommend that management revise their lost revenue totals in any future submissions. Views of Responsible Officials: Management will revise policies and update cumulative lost revenue for any future HRSA PRF Reporting Portal submissions and retain documented proof that the reports were reviewed prior to filing. In addition, revised lost revenues of $13,893,503 exceed cumulative PRF payments applied to lost revenues of $1,626,560. Date of anticipated Completion – March 15, 2024 Person/Persons responsible for completion – Jarrod Leo, CFO and Michele Brown, Senior Director of Fiscal Services Sincerely, Jarrod Leo Chief Financial Officer
FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval pr...
FINDING 2023-005 Finding Subject: Child Nutrition Cluster - Eligibility Summary of Finding: Material Weakness Condition and Context There was no evidence that the Direct Certifications were correctly and properly included in the software system, or that there was an oversight, review, or approval process over the Direct Certifications. Contact Person Responsible for Corrective Action: Lori Boyce Contact Phone Number and Email Address: 765-653-3148 lboyce@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service Director will have the Guidance Secretary check and initial that the Food Service Director has completed the Direct Certification correctly. Anticipated Completion Date: 2/2024
FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Material Weakness Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with the grant agreement and the Procu...
FINDING 2023-004 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Summary of Finding: Material Weakness Condition and Context An effective internal control system was not in place at the School Corporation to ensure compliance with the grant agreement and the Procurement and Suspension and Debarment compliance requirement. There was no evidence that there was an oversight, review, or approval process over the Small Purchases. INDIANA STATE BOARD OF ACCOUNTS 30 Contact Person Responsible for Corrective Action: Lori Boyce Contact Phone Number and Email Address: 765-653-3148 lboyce@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Food Service Director will email the Superintendent all quotes. The Food Service Director will then wait for the Superintendent to give approval for the small purchase. Anticipated Completion Date: 2/2024
FINDING 2023-003 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness Condition and Context Reporting The School Corporation had not designed nor implemented a system of internal controls to ensure that the six Elementary and Secondary School Emergency Reli...
FINDING 2023-003 Finding Subject: Education Stabilization Fund - Reporting Summary of Finding: Material Weakness Condition and Context Reporting The School Corporation had not designed nor implemented a system of internal controls to ensure that the six Elementary and Secondary School Emergency Relief (ESSER) annual data reports required to be filed during the audit period were complete and accurate prior to submission. Each of the reports were prepared by one employee without an oversight or review process in place to prevent, or detect and correct errors. Contact Person Responsible for Corrective Action: Hilarie Logan Contact Phone Number and Email Address: 765-653-3119 hlogan@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The school corporation has a new Grants Coordinator who will participate in Internal Controls Training and sign off that they have done so. We will also incorporate dual signatures on documents as an additional means of approval/oversight. Anticipated Completion Date: 3/2024
Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Correcti...
Finding 2023-002 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Eric Speicher Contact Phone Number: 574-598-2768 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school corporation’s management will establish a documented, secondary review of all accounts payable claims to ensure the accuracy of the claims and will ensure underlying support or details of the claims will be included. Anticipated Completion Date: 2/22/2024
FINDING 2023-003 Finding Subject: Emergency Connectivity Fund – Suspension and Debarment Summary of Finding: The School Corporation had not implemented a system of internal controls to ensure procedures were in place to verify that the contracted entity selected for the project was not suspended or ...
FINDING 2023-003 Finding Subject: Emergency Connectivity Fund – Suspension and Debarment Summary of Finding: The School Corporation had not implemented a system of internal controls to ensure procedures were in place to verify that the contracted entity selected for the project was not suspended or debarred. The School Corporation did not include the appropriate provisions for suspension and debarment in the contract, require a certification, or check the EPLS to ensure the entity was not suspended or debarred. Contact Person Responsible for Corrective Action: Derek Coulombe, Director of Technology Contact Phone Number and Email Address: (317) 856-5265; dcoulombe@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will develop procedures, including adding contract language when appropriate, to ensure searches verifying vendors paid from federal funds have not been Suspended or Debarred. Documentation of the searches will be printed off then filed with the contract and submitted with the original purchase request. Anticipated Completion Date: March 1, 2024
FINDING 2023-002 Finding Subject: Emergency Connectivity Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related t...
FINDING 2023-002 Finding Subject: Emergency Connectivity Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance Summary of Finding: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Period of Performance compliance requirements. The School Corporation completed reimbursement requests and submitted them online; however, there was no evidence of an oversight or review process to ensure that the reimbursement requests were for allowable activities, allowable costs, and within the period of performance. Contact Person Responsible for Corrective Action: Derek Coulombe, Director of Technology Contact Phone Number and Email Address: (317) 856-5265; dcoulombe@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will develop procedures to ensure disbursement requests are printed out and a representative from the Business Department documents review of them for allowable activity before final submission. Anticipated Completion Date: March 1, 2024
FINDING 2023-001 Finding Subject: COVID-19 – Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: The School Corporation did not have adequate policies or procedures to ensure that contracts in excess of $2,000 paid from federal grant funds include...
FINDING 2023-001 Finding Subject: COVID-19 – Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: The School Corporation did not have adequate policies or procedures to ensure that contracts in excess of $2,000 paid from federal grant funds included a prevailing wage rate clause. One of two contracts during the audit period was subject to wage rate requirements; however, the contract did not have the required prevailing wage rate clause included in the contract. Certified payrolls were obtained for both contracts, but there was no evidence the unit had a control in place to ensure the certified payrolls are received timely and in compliance with applicable grant requirements. Contact Person Responsible for Corrective Action: Kirk Farmer, Chief Financial Officer Contact Phone Number and Email Address: (317) 856-5265; kfarmer@decaturproud.org Views of Responsible Official: We concur with Audit Finding Description of Corrective Action Plan: The School Corporation will verify all contracts paid for from federal funds include a prevailing wage rate clause. In addition, the Business Department with print off email correspondence to file with future certified payrolls to document receipt and compliance with grant requirements. Anticipated Completion Date: March 1, 2024
Finding 2023-006 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Acti...
Finding 2023-006 – Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the Davis-Bacon Act. We will collect weekly payroll documentation for any constructions projects where Federal Grant money is used. Anticipated Completion Date: February 2024
Finding 2023-005 – Special Education Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Dir...
Finding 2023-005 – Special Education Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Business Affairs & HR will work with the Special Education Coop to ensure compliance with the Procurement and Suspension and Debarment requirement. Anticipated Completion Date: February 2024
Finding 2023-004 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Business Affairs & H...
Finding 2023-004 – Special Education Cluster – Earmarking Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The Director of Business Affairs & HR will work with the Special Education Coop to ensure compliance with the Earmarking requirement. Anticipated Completion Date: February 2024
Finding 2023-003 – Child Nutrition Cluster – Special Tests and Provisions – Verification of Free and Reduced Price Applications Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Descrip...
Finding 2023-003 – Child Nutrition Cluster – Special Tests and Provisions – Verification of Free and Reduced Price Applications Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the process for Verification of Free and Reduced Price Applications. We have now contracted with a Food Service Director through NIESC. They will perform the Verification of Free and Reduced Price Applications and the Director of Business Affairs & HR will review these documents for accuracy. Anticipated Completion Date: FY24 Verification of Free and Reduced Price Application Review Period
Finding 2023-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Food Service...
Finding 2023-002 – Child Nutrition Cluster – Reporting Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-508-0504 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Food Service Manager or Director of Food Service will prepare the reimbursement claim and the Director of Business Affairs and HR or Treasurer will review and initial the claims. This will ensure the accuracy of the reimbursement claim. Anticipated Completion Date: This Corrective Action was put into place in September 2022 following our prior audit. The Claim that was not signed for this Audit was from October 2021.
Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for reviewing funding claims. Action Taken: One City Schools has developed a new process for submission where a second approver, the COO, reviews the claims for accuracy. This process started in December...
Recommendation: One City Schools, Inc. should design and implement appropriate internal controls for reviewing funding claims. Action Taken: One City Schools has developed a new process for submission where a second approver, the COO, reviews the claims for accuracy. This process started in December 2023, however OCS also completed this second approver review retroactively for all claims in July 2023, September 2023, October 2023, and November 2023.
Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved...
Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Action Taken: One City Schools is in the process of identifying a required training program for all staff members involved in the submission, review and/or approval of the schedule of expenditures of federal awards. This includes One City’s Executive Chef, Executive Director of K-8, COO and VP of Government Relations (who oversees compliance). Designated staff will take advantage of all DPI-provided training seminars and resources available, and we will track attendance of relevant staff members. This process will be in place by June, 2024.
Finding 370424 (2023-002)
Significant Deficiency 2023
Pacific University acknowledges the importance of an effective control environment and closely monitors activities of subrecipients under federal awards. Pacific was able to demonstrate that the selected subrecipients had appropriate audits under Subpart F (or were not subject to such audits). Howe...
Pacific University acknowledges the importance of an effective control environment and closely monitors activities of subrecipients under federal awards. Pacific was able to demonstrate that the selected subrecipients had appropriate audits under Subpart F (or were not subject to such audits). However, the University will enhance controls related to tracking such compliance
Finding 370421 (2023-001)
Significant Deficiency 2023
Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The ap...
Pacific University acknowledges the importance of an effective control environment. University policies do require approval of all timesheets. Management will re-emphasize the importance of this key approval control and periodically review supervisor compliance (with follow-up on exceptions). The approval requirement will also be added to Pacific’s mandatory annual compliance training for supervisors.
Finding Number: 2023‐011 Federal Program, Assistance Listing Number and Name: ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program Condition: Original Finding Description: Certain controls in place did not operate effectively specif...
Finding Number: 2023‐011 Federal Program, Assistance Listing Number and Name: ALN 14.905, United States Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program Condition: Original Finding Description: Certain controls in place did not operate effectively specific to eligibility, earmarking, and reporting compliance requirements. Contact Person Responsible for Corrective Action: Julie Schneider (HRD) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional controls and training to ensure the required review of eligibility approval is in place and all supporting documentation is stored and maintained.
Finding Number: 2023‐010 Federal Program, Assistance Listing Number and Name: 14.218, Department of Housing and Urban Development, Community Development Block Grant/Entitlement Grants Cluster, Community Development Block Grant/Entitlement Grants (CDBG) 14.241, Department of Housing and Urban Develop...
Finding Number: 2023‐010 Federal Program, Assistance Listing Number and Name: 14.218, Department of Housing and Urban Development, Community Development Block Grant/Entitlement Grants Cluster, Community Development Block Grant/Entitlement Grants (CDBG) 14.241, Department of Housing and Urban Development, Housing Opportunities for Persons With Aids (HOPWA) 14.905, Department of Housing and Urban Development, Lead Hazard Reduction Demonstration Grant Program (Lead) Condition: Original Finding Description: The City duplicated costs charged to certain grants. Contact Person Responsible for Corrective Action: Regina Greear (ODFS) and Cynthia Saxton (OGA) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional training that includes a review of its journal entry controls and approval processes to ensure journal entries are posted accurately and no duplicates costs.
Finding Number: 2023‐008 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: The controls in place were not adequate...
Finding Number: 2023‐008 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: The controls in place were not adequate to ensure that amounts reported within the CAPER were accurate and complete in relation to activity reported in the general ledger and underlying records of the City. Contact Person Responsible for Corrective Action: Regina Greear (ODFS), Cynthia Saxton (OGA) and Julie Schneider (HRD) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional reporting controls that includes verification of expenditures, retention of supporting documentation and a timely final reconciliation of the CAPER Report to the general ledger.
Finding Number: 2023-007 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: In conjunction with eligibility testing...
Finding Number: 2023-007 Federal Program, Assistance Listing Number and Name: ALN 14.241, Department of Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS (HOPWA) and COVID‐19 HOPWA Condition: Original Finding Description: In conjunction with eligibility testing, instances of noncompliance specific to the rental assistance calculation and distribution of benefits were identified. Contact Person Responsible for Corrective Action: Denise Fair Razo (DHD) and Angelique Tomsic (DHD) Anticipated Completion Date: June 2023 Planned Corrective Action: City of Detroit HOPWA program has a dedicated quality coordinator position. The coordinator will continue to work closely with the HOPWA program team and conduct regular file audits. The HOPWA program team has also implemented additional steps which includes the use of eligibility templates to help ensure accurate rental assistance calculations. In addition, the City will review during the AFCAP process to ensure the required process improvements and procedures are in place for accurate rental assistance calculations.
View Audit 291959 Questioned Costs: $1
Finding Number: 2023‐006 Federal Program, Assistance Listing Number and Name: ALN 21.027, Department of Treasury, COVID‐19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Condition: Original Finding Description: The payroll costs that were reported as incurred on four CSLFRF projects were...
Finding Number: 2023‐006 Federal Program, Assistance Listing Number and Name: ALN 21.027, Department of Treasury, COVID‐19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Condition: Original Finding Description: The payroll costs that were reported as incurred on four CSLFRF projects were incorrect in the performance report submitted for the period October 1, 2022, through December 31, 2022 (Quarter 4). Contact Person Responsible for Corrective Action: Terri Daniels (ODG) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will review during the AFCAP process and implement additional controls to ensure the quarterly Treasury reports align with the expenses as stated on the general ledger.
Finding Number: 2023‐005 Federal Program, Assistance Listing Number and Name: ALN 20.507, Department of Transportation, Federal Transit Cluster, Federal Transit Formula Grants Condition: Original Finding Description: The City did not have adequate controls in place to ensure payroll costs charged to...
Finding Number: 2023‐005 Federal Program, Assistance Listing Number and Name: ALN 20.507, Department of Transportation, Federal Transit Cluster, Federal Transit Formula Grants Condition: Original Finding Description: The City did not have adequate controls in place to ensure payroll costs charged to the program were accurate in relation to underlying payroll records. Contact Person Responsible for Corrective Action: Regina Greear (ODFS), James George (ODFS) Anticipated Completion Date: June 2023 Planned Corrective Action: The City will implement required controls to ensure accurate payroll costs are charged to the program and completeness of the supporting documentation. The City will review during the AFCAP process to ensure policies, procedures and additional trainings are put in place.
Finding Number: 2023‐003 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City did not have adequate controls in place to exercise its ...
Finding Number: 2023‐003 Federal Program, Assistance Listing Number and Name: ALN 10.557, Department of Agriculture, Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Condition: Original Finding Description: The City did not have adequate controls in place to exercise its oversight responsibility of eligibility determinations that were performed by a contractor for the program. Contact Person Responsible for Corrective Action: Denise Fair Razo (DHD) Anticipated Completion Date: Complete May 2023 Planned Corrective Action: The City has implemented controls to ensure that the Health Department provides oversight over the contractors. In May 2023, the Health Department hired a WIC Program Director to monitor participant eligibility compliance and ensure policies and procedures are maintained and followed.
Chafee Education and Training Vouchers Program – Assistance Listing No.93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement wit...
Chafee Education and Training Vouchers Program – Assistance Listing No.93.599 Recommendation: We recommend the Organization put procedures in place to retain documentation of supervisory approval of time and effort reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures and systems will be adjusted to maintain report approval submissions, along with additional reviews to ensure that documentation is maintained. Name(s) of the contact person(s) responsible for corrective action: Drew Erickson, Controller Planned completion date for corrective action plan: 01/31/2024
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