Corrective Action Plans

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Responsible Person(s): Ida Witherspoon, Chief Financial Officer; Ousman Kah, Subrecipient Monitoring Coordinator; James Pell, ARMICS Program Manager Corrective Action Planned: As part of the compliance review, an analysis will be conducted to identify divisions and associated service provider agenci...
Responsible Person(s): Ida Witherspoon, Chief Financial Officer; Ousman Kah, Subrecipient Monitoring Coordinator; James Pell, ARMICS Program Manager Corrective Action Planned: As part of the compliance review, an analysis will be conducted to identify divisions and associated service provider agencies that manage substantial fiscal responsibilities under federal or state funding streams. This includes mapping subrecipient institutions and other state agencies such as the Office of Community Services (OCS) that receive federal grant allocations. The objective is to ensure visibility into entities handling large-scale financial transactions, assess their internal controls, and confirm adherence to applicable federal and state requirements. This analysis will serve as the foundation for targeted monitoring and risk mitigation strategies. DSS receives federal funding, which is disbursed to state agencies as a pass-through transaction. These transactions are initiated by various divisions within DSS, based on agreements with subrecipients, and then sent to Finance for review/processing. The subrecipients receiving federal funding must carry out the mission of that specific federal program. Pass-through transactions are required to be summarized and submitted to DOA for year-end financial reporting by agency and ALN (Assistance Listing Number, i.e., 10.561 = SNAP). DSS needs to obtain confirmation that each agency receiving federal funding is using the federal funds appropriately and within the guidelines of the grant award. ARMICS team will work to obtain financial control assurances from identified significant fiscal recipients. Estimated Completion Date: 11/30/2026
Responsible Person(s): Monique Majeus, Economic Assistance and Employment; Christie Bruce, TANF Consultant Corrective Action Planned: Change Request submitted to fix and implement the changes requiring correction in 2025. Estimated Completion Date: 11/25/2025
Responsible Person(s): Monique Majeus, Economic Assistance and Employment; Christie Bruce, TANF Consultant Corrective Action Planned: Change Request submitted to fix and implement the changes requiring correction in 2025. Estimated Completion Date: 11/25/2025
Responsible Person(s): Fernanda Crandol, Chief Financial Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awa...
Responsible Person(s): Fernanda Crandol, Chief Financial Officer Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 5/31/2026
Responsible Person(s): Darin Moore, Deputy Director of Administration and Outreach; Sarah Boggs, Accounting Manager for Planning and Finance; Suzanne Robinson; Tim Springer, Budget Manager for Planning and Finance Corrective Action Planned: Review the current DWR process and determine whether DWR sh...
Responsible Person(s): Darin Moore, Deputy Director of Administration and Outreach; Sarah Boggs, Accounting Manager for Planning and Finance; Suzanne Robinson; Tim Springer, Budget Manager for Planning and Finance Corrective Action Planned: Review the current DWR process and determine whether DWR should petition the Comptroller for an exception to CAPP Topic 20605 or modify the DWR process to the “split coding” method instead. This will include: 1.) Evaluation of grant program guidance to ensure no obstacles exist from the Federal Awarding Agency to changing DWR's current methodology; 2.) Meeting and discussing with other (like) state agencies for policy, procedure, and training examples for split coding grant eligible expenditures; 3.) Scheduling meetings with Department of Accounts and the previous APA Audit Team to discuss DWR's evaluation, decision, and next steps; 4.) Developing and implementing new DWR policies and training to ensure compliance with the approved methodology. (Estimated completion date: July 1, 2026) Update current policies and procedures to conform with CAPP Manual Topic 20405 and to enhance the agency's current supporting documentation for all journal entries. At a minimum, these new policies and procedures will require that Voucher ID/Expense Report IDs that are moved within a journal entry are documented in the journal reference line in the system to improve transparency, will add more detailed explanations to justify coding changes, will upload applicable documents into the system to assist in manager approval, and will maintain all documentation centrally in one location for easier access and review. (Estimated completion date: July 1, 2026) Publish and maintain a sustainable federal drawdown schedule, by: 1.) Evaluating DWR's current federal drawdown schedule in accordance with current policies, procedures, employee workload, cashflow, and Federal Awarding Agency's guidance; 2.) Developing specific controls, and revised job descriptions as needed to ensure the drawdown schedule can be consistently maintained; and 3.) Incorporating both the new schedule and controls into appropriate policies and procedures to ensure accountability. (Estimated completion date: June 1, 2026) Evaluate current policies, procedures, and practices pertaining to how DWR manages and records Program Income. Develop and update policies and procedures to ensure compliance with CAPP 20205. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: June 1, 2026) Review current internal procedures for reporting federal expenses on the SEFA and Attachment 15 and identify training gaps. Enlist training support from Department of Accounts and/or other state agencies to address training gaps. Develop new written policies and procedures, along with new supporting documentation requirements, to conform to SEFA and Attachment 15 guidelines and expectations. Provide training on new policies and procedures to employees within the Planning and Finance Division. (Estimated completion date: July 1, 2026) Review all other written policies and procedures for administering federal grants and contracts, and develop and update as necessary to address insufficient guidance and noncompliance. (Estimated completion date: August 31, 2025) Estimated Completion Date: 7/1/2026
Responsible Person(s): Liz Havenner, IT Administrative Director; Dan Lewis, Chief Technology Officer; Timothy Kelly, Innovation, Architecture and Governance Director; John Vosper, Assistant Director ISRM; James Pell, ARMICS Manager; Paige Elswick, Controller; Ida Witherspoon, Chief Financial Officer...
Responsible Person(s): Liz Havenner, IT Administrative Director; Dan Lewis, Chief Technology Officer; Timothy Kelly, Innovation, Architecture and Governance Director; John Vosper, Assistant Director ISRM; James Pell, ARMICS Manager; Paige Elswick, Controller; Ida Witherspoon, Chief Financial Officer; Michelle Skaggs, General Services Director; Adrienne Childress, Strategic Sourcing Procurement Manager, General Services, Procurement Corrective Action Planned: DSS is working to compile SOCs and train contract administrators through specific SOC related sessions. Procedures, training, questionnaire, and policy completed. DSS Finance and IT Administration has created draft Policy and Procedures for managing SOC 1 reports for third-party service providers, incorporating SOC 1 & SOC 2 requirements. The policy outlines steps for obtaining, reviewing, and documenting SOC reports, including timelines and responsibilities for contract administrators, TSD Business Managers, and the ARMICS program. It also addresses remediation processes for non-compliant or incomplete reports. The policy is designed to ensure compliance with relevant regulations and will be reviewed and updated annually by the DSS ISRM and Finance team. Training is being developed as well on the procedures to be followed for SOC 1 Type 2 review. Estimated Completion Date: 6/30/2026
Responsible Person(s): Office of Information Management and Othello Dixon, Office of Information Security Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 ...
Responsible Person(s): Office of Information Management and Othello Dixon, Office of Information Security Corrective Action Planned: This finding was marked as FOIA Exempt (FOIAE) and as a result, the State Comptroller has determined that the resulting corrective actions are FOIAE under §2.2-3705.2 (9.) of the Code of Virginia. Federal awarding agencies and pass-through entities, please see the Appendix titled “Applicable Management Contacts for Findings and Questioned Costs” to request the corrective action planned from the applicable entity. Estimated Completion Date: 3/2/2026
Recommendation: CLA recommends that the University implement a more effective suspension and debarment policy and establish corresponding controls to ensure vendor eligibility is verified prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagre...
Recommendation: CLA recommends that the University implement a more effective suspension and debarment policy and establish corresponding controls to ensure vendor eligibility is verified prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University concurs with the auditors’ findings and has already updated its purchasing policies, which have been submitted for final approval through the appropriate University governance channels. In addition, Purchasing is currently implementing a new module within its e-procurement system, JAGGAER, to include the Supplier Management module. This module incorporates the Visual Compliance/Descartes screening solution that provides continuous and ongoing compliance monitoring of vendors. Name(s) of the contact person(s) responsible for corrective action: Robert Akhnoukh Planned completion date for corrective action plan: June 2026 If the US Department of Health and Human Services has questions regarding this plan, please call Robert Akhnoukh at (208) 885-6116.
Finding 1177825 (2025-001)
Material Weakness 2025
Condition: Management did not have controls in place to ensure documentation was maintained evidencing the organization's verification that contractors are not suspended or debarred from participating in a federally funded activity. Planned Corrective Action: Management concurs with the finding. We ...
Condition: Management did not have controls in place to ensure documentation was maintained evidencing the organization's verification that contractors are not suspended or debarred from participating in a federally funded activity. Planned Corrective Action: Management concurs with the finding. We acknowledge that, for the awards issued under the Inflation Reduction Act Urban and Community Forestry Program (Assistance Listing Number 10.727), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained by the responsible department. This represents a documentation lapse rather than a deficiency in internal controls as Openlands routinely performs suspension and debarment verifications for all applicable vendors, contractors, and subrecipients receiving federal funds in accordance with 2 CFR 200.214. This requirement applies to entities and individuals awarded federally funded contracts or subawards exceeding the micro-purchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $15,000. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected, and is currently in the processes of executing an update to internal control policies to ensure these checks are maintained prior to entering into a contract by the responsible department as well as updating a clause to all standard vendor contracts requiring a self-certification that they are not excluded, debarred, or suspended from entering into covered transactions with the federal government. Contact person responsible for corrective action: Paul Spector (Director of Finance) Anticipated Completion Date: January 31, 2026
Current Year Finding Number: 2025-003 Federal Program, Assistance Listing Number and Name: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture 10.553, 10.555, and 10.582 Condition: Based on our sample selection of three vendors for testing, we have identified that two of the three...
Current Year Finding Number: 2025-003 Federal Program, Assistance Listing Number and Name: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture 10.553, 10.555, and 10.582 Condition: Based on our sample selection of three vendors for testing, we have identified that two of the three vendors tested did not have adequate verification of suspension and debarment. Upon further testing and discussion, the District does not have internal controls in place to verify suspension and debarment on vendors that are paid greater than or equal to $25,000, as required by 2 CFR 200 for various federal awards. Upon further compliance testing, vendors in our testing were in compliance with the requirement. Without internal controls over compliance, the District may not be able to identify noncompliance with a suspended or debarred vendors in a timely manner and may incur potential questioned costs without knowledge of the noncompliance. Planned Corrective Action: The School District has implemented an internal process to issue verification of suspension and debarment for vendors of federal awards that are paid equal to or greater that $25,000 as of 02/27/2026. Contact person responsible for corrective action: Roger Stinar, Director of Finance Anticipated Completion Date: 06/30/2026
Condition: One (1) of the monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. The November 2024 claim amounts were consistent with participation levels and reimbursement amounts in other months tested. No anomalies or fluctuations were ident...
Condition: One (1) of the monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. The November 2024 claim amounts were consistent with participation levels and reimbursement amounts in other months tested. No anomalies or fluctuations were identified through analytical procedures; however, required supporting documentation was not maintained. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Responsible Person: Dr. Cynthia Levy, Superintendent. Anticipated Completion Date: June 30, 2026
Finding 2025-002 – Education Stabilization – Special Tests and Provisions - Wage Rate Requirements Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace fan coil units and HVAC equipment in the building. Therefor...
Finding 2025-002 – Education Stabilization – Special Tests and Provisions - Wage Rate Requirements Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace fan coil units and HVAC equipment in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $119,190 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-766-2214 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 2025-001 Finding Subject: Summary of Finding: Earmarking for Non-Public proportionate share was improperly calculated based on budgeted percentage. Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number and Email Address: (219) 850-1914 - qvanrys@pces.k12.in....
FINDING 2025-001 Finding Subject: Summary of Finding: Earmarking for Non-Public proportionate share was improperly calculated based on budgeted percentage. Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number and Email Address: (219) 850-1914 - qvanrys@pces.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. Anticipated Completion Date: This finding was corrected in January, 2024.
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement Suspension and Debarment Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: “We concur with the finding.” De...
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement Suspension and Debarment Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: To address this repeat finding, the Business Manager will now review all federal purchase requests before any funds are committed. We will ensure the correct procurement method is used by requiring and filing at least three competitive quotes for any small purchase between $10,000 and $150,000. For any transaction $25,000 or greater, the Business Manager will verify the vendor’s eligibility on SAM.gov and keep a date-stamped screenshot in the file as proof of the search. This centralized oversight and mandatory documentation process will ensure we maintain a proper history of procurement and prevent further noncompliance. Anticipated Completion Date: 02/01/2026
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative oper...
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering a covered transaction. Contact Person Responsible for Corrective Action: Susan Loftain Contact Phone Number and Email Address: (260) 693-2007 loftains@sgcs.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Procurement: All vendors procured through NEISEC we will need to take action to secure bids and quotes and keep copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on NEISEC to check on suspension and debarment Anticipated Completion Date: Immediately
Department will strengthen controls to ensure that the required award information is provided, once available. Certain information such as Federal Award Identification Number and Federal Transit Administration and National Highway Traffic Safety Administration award date are not available at the tim...
Department will strengthen controls to ensure that the required award information is provided, once available. Certain information such as Federal Award Identification Number and Federal Transit Administration and National Highway Traffic Safety Administration award date are not available at the time of contracting CDOT is working on a process to provide this information, once it is available in a publicly available format on CDOT’s website or on a subrecipient facing grant management site. We will add a note to the contract explaining where the information will be posted on our site when it becomes available. The Department will also identify staff requiring additional training on classification and coding for contractors vs. subrecipients.
The Department agrees with the recommendation. The Department will review, assess, and, where necessary, update existing procedures for FFATA reporting relating to the requirement that state subawards for $30,000+ be submitted within 30 days of committed budget. This will include ensuring that the c...
The Department agrees with the recommendation. The Department will review, assess, and, where necessary, update existing procedures for FFATA reporting relating to the requirement that state subawards for $30,000+ be submitted within 30 days of committed budget. This will include ensuring that the confirmation date is documented. This process will be a coordinated effort between the Office Transportation Safety (OTS) and the Center for Accounting. This will include updating our reconciliation process to include additional data, reviewing and updating reconciliation and review procedures as needed, and reconciling Grants awarded in prior fiscal years that are still active and ensuring they have been appropriately reported. The findings related to this recommendation are in part the result of a federal reporting system limitation, and a federal system conversion. The legacy reporting system, FSRS, had a system limitation, which prevented the full amount of the award being reported in the case of three awards. Additionally, this conversion resulted in some data conversion issues impacting one additional award.
The Department agrees with this finding and will provide any training needed to staff members to ensure that all components of the FFATA are completed accurately, timely and with proper reviews. This training will include leadership reviewing NHTSA/Federal guidelines and SAM.Gov training on FFATA re...
The Department agrees with this finding and will provide any training needed to staff members to ensure that all components of the FFATA are completed accurately, timely and with proper reviews. This training will include leadership reviewing NHTSA/Federal guidelines and SAM.Gov training on FFATA reporting and requirements, documenting controls and ensuring the approvers have access to all supporting schedules, forms and systems and that they understand the subawards, and process for late submissions if needed.
The Department agrees with the finding and will ensure that staff follow all internal policies and procedures to maintain accurate and complete FFATA reporting. To achieve this, staff will review existing procedures and make any necessary updates regarding report compilation. Additionally, we will r...
The Department agrees with the finding and will ensure that staff follow all internal policies and procedures to maintain accurate and complete FFATA reporting. To achieve this, staff will review existing procedures and make any necessary updates regarding report compilation. Additionally, we will review control points to ensure they are consistently followed and approved by the team supervisor and team manager.
CDPHE fiscal procedures have been updated to reflect changes to the reporting process, specifically noting the recent federal website change and adding the requirement of a secondary level of review. By July 31, 2026, all outstanding FFATA reports will be filed with the federal government and the mo...
CDPHE fiscal procedures have been updated to reflect changes to the reporting process, specifically noting the recent federal website change and adding the requirement of a secondary level of review. By July 31, 2026, all outstanding FFATA reports will be filed with the federal government and the monthly review process in the updated fiscal procedures will be implemented.
The Department of Local Affairs (Department) agrees with the recommendation to strengthen internal controls over the financial management of federal Coronavirus Capital Projects Fund grant expenditures and the accuracy and completeness of the Exhibit K1, Schedule of Federal Assistance. The Departmen...
The Department of Local Affairs (Department) agrees with the recommendation to strengthen internal controls over the financial management of federal Coronavirus Capital Projects Fund grant expenditures and the accuracy and completeness of the Exhibit K1, Schedule of Federal Assistance. The Department will develop a corrective action plan that includes enhanced procedures for the performance of year-end estimates/accruals. The Department will create and implement staff training for staff that are responsible for preparing and reviewing the estimates/accruals, the Exhibit K1, grant transactions and enhancements.
The Department will strengthen its internal controls over federal reporting by implementing policies and procedures that include a monitoring process to ensure that FFATA reporting occurs as required for subawards of $30,000 or more in SAM.gov by the end of the month following the month the subaward...
The Department will strengthen its internal controls over federal reporting by implementing policies and procedures that include a monitoring process to ensure that FFATA reporting occurs as required for subawards of $30,000 or more in SAM.gov by the end of the month following the month the subawards are made.
The Department will document and implement internal monitoring policies and procedures, including the performance of reconciliations of reports, to ensure that the required PR28 and Quarterly Performance Reports are accurate and complete. This will include maintaining documentation of evidence of th...
The Department will document and implement internal monitoring policies and procedures, including the performance of reconciliations of reports, to ensure that the required PR28 and Quarterly Performance Reports are accurate and complete. This will include maintaining documentation of evidence of the review and approval of each report prior to its submission to the federal government.
The Department will complete and communicate formalized IT procedures to staff and IT service providers for IT general control activities for MyUI+ by April 2026.
The Department will complete and communicate formalized IT procedures to staff and IT service providers for IT general control activities for MyUI+ by April 2026.
The Department will implement Part B of the confidential finding.
The Department will implement Part B of the confidential finding.
The Department will implement Part A of the confidential finding.
The Department will implement Part A of the confidential finding.
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