Corrective Action Plans

Finding 124 (2023-001)

Significant Deficiency 2023

OK

Procurement, Suspension & Debarment § 200.303

At the beginning of FY23, the following steps were initiated to ensure board review and approval of all contracts over an annual value of $500,000 per internal financial policy: - The CFO will flag all contracts in excess of the stated threshold and notify the CEO, Executive Assistant, and board Tr...

At the beginning of FY23, the following steps were initiated to ensure board review and approval of all contracts over an annual value of $500,000 per internal financial policy: - The CFO will flag all contracts in excess of the stated threshold and notify the CEO, Executive Assistant, and board Treasurer that an action of the board will be required. - A standing agenda item will be added for the board finance committee to discuss any notable contracts and potential board approval requirements at each meeting. To prevent the case in which a contract is overlooked due to multiple contracts requiring consideration at the same time, the organization will seek out an automated solution such as electronic workflows or contract lifecycle management software to be implemented in FY24 in combination with the previously established actions above.

View Audit 182

Finding 1175571 (2022-009)

Material Weakness 2022

Dewey County

OK

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.317 § 200.318 § 200.327 § 200.84

The County will make sure that all federal documentation is maintained by each district for inspection and will ensure it is accurately reported on the SEFA.

View Audit 389361

Finding 1175570 (2022-008)

Material Weakness 2022

Dewey County

OK

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

The County will include discussion of all required compliance requirements for each federal program presented in our Officers’ meetings.

View Audit 389361

Finding 1174933 (2022-018)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

Eligibility Internal Control / Segregation of Duties HUD Housing Programs § 200.303

Finding 2022-018 Eligibility Individual(s) Responsible: Michelle Cadue, Tribal Treasurer and Jonnah McKinney, KTIK IHS Director. Action:Complete patient files will be maintained to document eligibility in accordance with program requirements. Records will be made available for audit review while mai...

Finding 2022-018 Eligibility Individual(s) Responsible: Michelle Cadue, Tribal Treasurer and Jonnah McKinney, KTIK IHS Director. Action:Complete patient files will be maintained to document eligibility in accordance with program requirements. Records will be made available for audit review while maintaining confidentiality, i.e., HIPPA. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174932 (2022-017)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding 2022-017 Procurement Individual(s) Responsible: Tribal Council; Rona Johnson-Murillo, Accounting Director; Program Directors; Enterprise Managers; and Paula Vann, Grants Compliance Officer. Action: Will adhere to the most active Procurement Policy and will check for Debarment for all vendors...

Finding 2022-017 Procurement Individual(s) Responsible: Tribal Council; Rona Johnson-Murillo, Accounting Director; Program Directors; Enterprise Managers; and Paula Vann, Grants Compliance Officer. Action: Will adhere to the most active Procurement Policy and will check for Debarment for all vendors. Procurement procedures will be updated to clearly define vendor classification and SAM.gov requirements. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174931 (2022-016)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

Allowable Costs / Cost Principles Material Weakness Significant Deficiency § 200.303

Finding 2022-016 Program Income Individual(s) Responsible: Tribal Council; Rona Johnson-Murillo, Accounting Director; Program Directors; Enterprise Managers; and Tyce Martin, HR Generalist. Action: Ensure that documentation is available for every item purchased or run through payroll. Anticipated Co...

Finding 2022-016 Program Income Individual(s) Responsible: Tribal Council; Rona Johnson-Murillo, Accounting Director; Program Directors; Enterprise Managers; and Tyce Martin, HR Generalist. Action: Ensure that documentation is available for every item purchased or run through payroll. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174930 (2022-015)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

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

Finding 2022-015 Allowable Costs and Activities Individual(s) Responsible: Tribal Council; Michelle Thomas, Acting Executive Director; Tyce Martin, HR Generalist; Program Directors; and Enterprise Managers. Action: The current Tribal Council will ensure that all required documentation is maintained ...

Finding 2022-015 Allowable Costs and Activities Individual(s) Responsible: Tribal Council; Michelle Thomas, Acting Executive Director; Tyce Martin, HR Generalist; Program Directors; and Enterprise Managers. Action: The current Tribal Council will ensure that all required documentation is maintained as supporting backup for all purchase requisitions, including proper signatures, prior authorization, and related approvals. In addition, all employees will have appropriate Personnel Action Notices (PANs) on file, and all timesheets will be properly completed and signed by both the employee and their supervisor. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174927 (2022-014)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

Equipment & Real Property Management Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment § 200.303

Finding 2022-014 Special Tests and Provisions Individual(s) Responsible: Michelle Cadue, Tribal Treasurer; Paula Vann, Grants Compliance Officer; and Cheryl DuBois, Head Start Director. Action: Review annual and quarterly reporting to ensure timely filing. Implementation of procedures to ensure all ...

Finding 2022-014 Special Tests and Provisions Individual(s) Responsible: Michelle Cadue, Tribal Treasurer; Paula Vann, Grants Compliance Officer; and Cheryl DuBois, Head Start Director. Action: Review annual and quarterly reporting to ensure timely filing. Implementation of procedures to ensure all required Head Start facilities documentation is obtained, accurately completed, retained, and readily accessible for review. Resources will be allocated to develop, implement, and monitor policies and procedures that support effective operations, timely reporting, and full compliance with Head Start facilities requirements. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174926 (2022-013)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles § 200.303

Finding 2022-013 Reporting Individual(s) Responsible: Michelle Cadue, Tribal Treasurer; Rona Johnson-Murillo, Accounting Director; Paula Vann, Grants Compliance Officer; and Program Directors. Action: Reporting requirements will be reviewed with department heads, and submitted reports will be monito...

Finding 2022-013 Reporting Individual(s) Responsible: Michelle Cadue, Tribal Treasurer; Rona Johnson-Murillo, Accounting Director; Paula Vann, Grants Compliance Officer; and Program Directors. Action: Reporting requirements will be reviewed with department heads, and submitted reports will be monitored for accuracy and timeliness. To strengthen compliance, a Grants Compliance Officer will be hired to oversee reporting obligations and ensure all required reports are submitted on time. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174923 (2022-012)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

Matching / Level of Effort / Earmarking § 200.303

Finding 2022-012 Matching, Level of Effort and Earmarking Individual(s) Responsible: Cheryl DuBois, Head Start Director and Paula Vann, Grants Compliance Officer. Action: Make sure all reporting requirements are met. Maintain enrollment documentation and provide information upon request. Anticipated...

Finding 2022-012 Matching, Level of Effort and Earmarking Individual(s) Responsible: Cheryl DuBois, Head Start Director and Paula Vann, Grants Compliance Officer. Action: Make sure all reporting requirements are met. Maintain enrollment documentation and provide information upon request. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174922 (2022-011)

Material Weakness 2022

Kickapoo Tribe in Kansas

KS

Equipment & Real Property Management § 200.303 § 200.313

Finding 2022-011 Fixed Asset Inventory Individual(s) Responsible: Michelle Cadue, Tribal Treasurer; Michelle Thomas, Acting Executive Director; Program Directors; Enterprise Managers; and Rona Johnson-Murillo, Accounting Director. Action: Compile inventory listing by July 1st of each fiscal year. An...

Finding 2022-011 Fixed Asset Inventory Individual(s) Responsible: Michelle Cadue, Tribal Treasurer; Michelle Thomas, Acting Executive Director; Program Directors; Enterprise Managers; and Rona Johnson-Murillo, Accounting Director. Action: Compile inventory listing by July 1st of each fiscal year. Anticipated Completion Date: March 2026.

View Audit 388523

Finding 1174836 (2022-004)

Material Weakness 2022

Insight Chicago, Inc.

IL

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.303

Finding: The Company was not able to evidence the review and approval of non-payroll expenses incurred in connection with the Coronavirus State and Local Fiscal Recovery Funds grant program. Corrective Actions Taken or Planned: During the testing there was one invoice Insight was not able to documen...

Finding: The Company was not able to evidence the review and approval of non-payroll expenses incurred in connection with the Coronavirus State and Local Fiscal Recovery Funds grant program. Corrective Actions Taken or Planned: During the testing there was one invoice Insight was not able to document that it had been approved by management to pay. During this period of 2022 we were on a manual accounts payable system. Invoices were approved before payment was made by email and the email was to be printed and attached. In September of 2022 we implemented a new ERP system. This system requires electronic approval by management for the invoice to be paid. Ferrick Jones, Controller, is responsible for ensuring this is remediated.

View Audit 388400

Finding 1173238 (2022-003)

Material Weakness 2022

New Space Nexus

NM

Equipment & Real Property Management § 200.303 § 200.313

2022-003—EQUIPMENT MANAGEMENT (EQUIPMENT IDENTIFICATION/TAGGING) Response: Management concurs with the finding. Corrective Action Plan: Management will update written property and equipment procedures to require tagging of all federally funded equipment upon receipt. The Innovation Program Manager w...

2022-003—EQUIPMENT MANAGEMENT (EQUIPMENT IDENTIFICATION/TAGGING) Response: Management concurs with the finding. Corrective Action Plan: Management will update written property and equipment procedures to require tagging of all federally funded equipment upon receipt. The Innovation Program Manager will be responsible for tagging equipment, maintaining property records, and performing at least annual inventory and tagging reviews. All existing federally funded equipment currently in use, including the TVAC machine, will be reviewed and appropriately tagged. Designation of Employee Position Responsible for Meeting Deadline: Innovation Program Manager — by January 31, 2023.

View Audit 386730

Finding 1172718 (2022-003)

Material Weakness 2022

Northwest Indian College

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Recommendation: We recommend the College implement a suspension and debarment policy and corresponding procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College currently follows its internal control ...

Recommendation: We recommend the College implement a suspension and debarment policy and corresponding procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College currently follows its internal control policies to document verification of vendors who may be listed in SAM for suspension and debarment. The College approved an updated procurement policy effective November 7, 2020, to adhere to Uniform Guidance. The College will strengthen (include) the suspension and debarment section to include a policy specific to Debarment and Suspension. Name of the contact person responsible for corrective action: Reatha Tom, Accounts Payable Specialist, and Clarissa Salhus, Finance Manager Planned completion date for corrective action plan: December 31, 2024

View Audit 385956

Finding 1172717 (2022-009)

Material Weakness 2022

Northwest Indian College

WA

Subrecipient Monitoring Cash Management Significant Deficiency § 200.303 § 200.305

Recommendation: We recommend that the College review and update current procedures to ensure subrecipient payments are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Collaborative workflows will be es...

Recommendation: We recommend that the College review and update current procedures to ensure subrecipient payments are paid timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Collaborative workflows will be established between Grant PI's and the Accounts Payable department to ensure that subrecipient payments are submitted and paid timely. These workflows will be included in the Accounts Payable procedures. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Duane VanderGriend, CFO Planned completion date for corrective action plan: Completed as of January 14, 2026

View Audit 385956

Finding 1172706 (2022-008)

Material Weakness 2022

Northwest Indian College

WA

Eligibility Reporting Significant Deficiency § 200.303 § 200.328 § 200.329

Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...

Recommendation: We recommend the College review the reporting requirements and implement procedures to ensure that all required reports are issued/posted in an accurate and timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Collaborative workflow was developed between Grant PI's and IS department personnel to ensure that all reports are posted to the website in a timely manner. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Duane VanderGriend, CFO Planned completion date for corrective action plan: Completed as of January 14, 2026

View Audit 385956

Finding 1172705 (2022-005)

Material Weakness 2022

Northwest Indian College

WA

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

Recommendation: We recommend the College enhance their controls around payroll disbursements to ensure employees are paid properly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has recognized the cha...

Recommendation: We recommend the College enhance their controls around payroll disbursements to ensure employees are paid properly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has recognized the challenge of hiring a Payroll Specialist. In September 2022, the College outsourced “Payroll” to Paycom. We continue to develop and communicate the unique needs of our College Payroll structure and Federal and private funding sources with Paycom and the College Human Resources to ensure that employees are paid properly. As such, the Business Office is undergoing a restructure and we have identified an internal candidate to take the lead on Payroll. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Reatha Tom, Accounts Payable Specialist, Michelle Ferron-Guppy, Director – Human Resources, and Zoy Zamudio-Lane, Human Resources Generalist Planned completion date for corrective action plan: September 30, 2024

View Audit 385956

Finding 1172700 (2022-007)

Material Weakness 2022

Northwest Indian College

WA

Material Weakness Internal Control / Segregation of Duties § 200.303

Recommendation: We recommend the college retain evidence of the review of student accounts prior to disbursement of HEERF funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: No longer disbursing student HEERF fu...

Recommendation: We recommend the college retain evidence of the review of student accounts prior to disbursement of HEERF funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: No longer disbursing student HEERF funds. Discussions have taken place between Financial Aid department and Accounting staff requesting that supporting documentation is retained to show evidence that the College reviewed student accounts and eligibility prior to student disbursements. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Duane VanderGriend, CFO Planned completion date for corrective action plan: Completed as of January 14, 2026

View Audit 385956

Finding 1172693 (2022-004)

Material Weakness 2022

Northwest Indian College

WA

Equipment & Real Property Management § 200.303 § 200.313

Recommendation: We recommend the College implement policies and procedures to ensure all property and equipment purchased with federal funds includes such information in the property records to comply with the requirement, and physical inventory be taken every two years. Explanation of disagreement ...

Recommendation: We recommend the College implement policies and procedures to ensure all property and equipment purchased with federal funds includes such information in the property records to comply with the requirement, and physical inventory be taken every two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College has begun to explore the Asset Module in the Jenzabar platform, with the goal that Procurement is the first stage of our property tracking. Work continues to be a challenge in this area as we are short staffed. The Business Office Staff will continue to work with the Purchasing staff to identify how best to proceed with this requirement. The College currently has Policies that speak to Assets and the recording of such. The College will strengthen the specifics of what an Asset listing is to include. Name of the contact person responsible for corrective action: Clarissa Salhus, Finance Manager, Charles Roberts, Purchasing Manager, and Paul Roberts, Fiscal Technician/Receiving Planned completion date for corrective action plan: March 31, 2025

View Audit 385956

Finding 1171695 (2022-012)

Material Weakness 2022

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 384725

Finding 1168833 (2022-004)

Material Weakness 2022

Snohomish County Food Bank Coalition

WA

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

Corrective Action: Management will implement formal internal control procedures, including independent reviews or other checks and balances, for all significant accounting processes and major federal award program compliance requirements. Anticipated Completion Date: December 31, 2025

View Audit 381040

Finding 1168824 (2022-007)

Material Weakness 2022

Bell County

TX

Allowable Costs / Cost Principles § 200.303

Condition: The District has not adopted formal controls to detect and prevent unallowable costs from being charged to grant programs. Auditor substantively tested 29 expenditures, including indirect costs, across all major programs noting that all items tested were for allowable costs. Criteria: 2 C...

Condition: The District has not adopted formal controls to detect and prevent unallowable costs from being charged to grant programs. Auditor substantively tested 29 expenditures, including indirect costs, across all major programs noting that all items tested were for allowable costs. Criteria: 2 CFR 200.303(a). Cause of Condition: Unfamiliarity with requirements stated in 2 CFR 200 of the Uniform Guidance. Effect of Condition: Effect is a state of noncompliance which may impact future grant awards or failure to identify and reject un-allowed costs charged to grant programs. Questioned Costs: none. Recommendation: Draft and adopt policies and procedures to become compliant with Uniform Guidance.Corrective Action Plan: Agency policies and procedures, including a guidance template will be clearly defined to ensure compliance with Uniform Guidance. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026

View Audit 381011

Finding 1168466 (2022-004)

Material Weakness 2022

Wyola School District No. 29

MT

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

Finding 2022-004: Activities Allowed and Unallowed, Allowable Costs (Compliance; Internal Controls Over Compliance) Response: For the audit period and subsequent audit periods (FY 2022-23 and partial 2023-24) The District will not be in compliance with this finding as duties were completed by one em...

Finding 2022-004: Activities Allowed and Unallowed, Allowable Costs (Compliance; Internal Controls Over Compliance) Response: For the audit period and subsequent audit periods (FY 2022-23 and partial 2023-24) The District will not be in compliance with this finding as duties were completed by one employee (accounts payable, payroll, balancing) and many records are not able to be located. For partial 2023-24 and 2024-25 records are now fully maintained and should be accessible for audit review. Training has been provided by the District’s Financial Consultant (payroll and accounts payable). The District Financial Consultant is reviewing payroll, processing tax and retirement payments, reviewing AP and correcting coding when necessary. The Consultant is also balancing reports and submitting monthly financial reports to the Board of Trustees.

View Audit 380260

Finding 1165299 (2022-002)

Material Weakness 2022

Spatial Informatics Group Natural Assets Laboratory

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303 § 200.328 § 200.400 § 200.430

Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these record...

Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director

View Audit 375849

Finding 1164948 (2022-001)

Material Weakness 2022

Eastern Kentucky PRIDE, Inc.

KY

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

Views of Responsible Officials and Planned Corrective Actions: PRIDE agrees with the finding and recommended procedures will be implemented.

View Audit 374899

Corrective Action Plans

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