Corrective Action Plans

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Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management follow their written procurement policies and controls to ensure it maintains documentation of procurement, suspension and debarments checks and that the documentation is available ...
Inclusive Ventures Small Business Program – Assistance Listing No. 59-059 Recommendation: We recommend that management follow their written procurement policies and controls to ensure it maintains documentation of procurement, suspension and debarments checks and that the documentation is available for audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Anne Arundel Economic Development Corporation implemented a Federal Grant Procurement Policy on March 18, 2025. The purpose of this Procurement Policy is to ensure all procurement activities conducted with funds from federal grants are executed in compliance with federal regulations, promote transparency, fairness, and competitiveness and provide the best value for the resources available. Name(s) of the contact person(s) responsible for corrective action: Lisa Grunder, Vice President of Administration Planned completion date for corrective action plan: March 23, 2026.
We will reach out to MTAS to help the Town to write and implements a policy for the Federal Awards Program.
We will reach out to MTAS to help the Town to write and implements a policy for the Federal Awards Program.
Reference Number 2025-002: Corrective Action Plan: Regarding internal controls over the FFATA (Federal Funding Accountability and Transparency Act) reporting, although no formal approval record could be provided, program staff reported that FFATA reports were verbally reviewed through one-on-one dis...
Reference Number 2025-002: Corrective Action Plan: Regarding internal controls over the FFATA (Federal Funding Accountability and Transparency Act) reporting, although no formal approval record could be provided, program staff reported that FFATA reports were verbally reviewed through one-on-one discussions. As recommended, the County will revise its internal FFATA reporting procedures to require that all FFATA submissions undergo a documented review and approval by an individual who is independent of the preparer. The procedures will be updated to require that the reviewer’s name, title, date of review, and confirmation of the reviewer’s approval be maintained in the program’s electronic records. The County will implement a standardized approval workflow—either through a designated electronic form, checklist, or approval routing mechanism—to ensure consistency across departments. Additionally, staff responsible for FFATA preparation and review will receive updated guidance and training on the new documentation requirements, The County will also evaluate opportunities to integrate this control into existing financial reporting and monitoring structures overseen by Housing and Community Development Services (HCDS) teams, to ensure consistent application of the updated approval requirements across reporting cycles. Anticipated Implementation Date: Updated procedures, workflow documentation, and staff training will be completed by June 30, 2026. Person Responsible: KELLY SALMONS, Deputy Director, Housing and Community Development Services
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There...
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend that the College review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: One of the findings was a clerical math error. CSC is moving R2T4 Calculations into COD to ensure proper calculations and reporting. The second finding was a date of determination discrepancy. CSC FA and Registrar to review how the last date of academic activity is determined and reported in Banner. The Financial Aid Director to review the R2T4 Process and create an SOP. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with aud...
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC utilizes National Student Clearinghouse (NSC) for NSLDS Reporting. The Registrar’s office is responsible for Enrollment Reporting. The four students with Reporting discrepancies are correctional students that do not have access to electronic forms. This population of students must submit paper requests and have them physically routed to the Registrar’s office for processing. The Enrollment and Reporting dates were in line; the discrepancy lies in the Program Enrollment date. The Registrar is researching if the student changed programs after their Enrollment dates. For the Enrollment Reporting date discrepancy outside the 60-day requirement, we reported the correct date to NSC. The Registrar has put in a ticket with NSC to see why they reported the Enrollment Date late. Name(s) of the contact person(s) responsible for corrective action: Current Registrar: Tosha Stout and Current Financial Aid Director: Tara Torres Planned completion date for corrective action plan: 6/30/26
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with fede...
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The audit finding was a result of a student enrolling in summer coursework, and their awards were not recalculated. CSC is creating a documented Standard Operating Procedure (SOP) on how to package awards prior to each term to prevent under awarding and a Financial Aid Processing Calendar to ensure awarding occurs each term. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagre...
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College evaluate its procedures and policies around reporting disbursements to COD to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The late reporting was the result of a known FAFSA issue that began occurring with the 24/25 FAFSA Simplification and continues with the 25/26 FAFSA. The exception occurred when the student was not presented with the HS Completion Status question on the application. Students must self-certify they have a HS Diploma or Equivalent to be eligible for Federal Student Aid. CSC exported the origination to COD. COD approved the award, but CSC was unable to post the award to the student’s account because the HS Completion Status was blank. As soon as the student corrected her FAFSA, CSC posted the award and reported it to COD. The CSC FA office now receives a report with missing HS Completion Status each day and deletes federal awards until the issue is resolved preventing late COD Reporting. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: Completed
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% req...
Student Financial Assistance Cluster– Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review current processes for calculating and tracking the students employed in community service activities for its Federal Work Study funds to meet the minimum 7% requirement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: CSC is in a rural area that does not afford many community service opportunities and usually files the FWS Community Service Waiver. Personnel changes caused CSC to miss the 24/25 filing deadline. CSC received the 25/26 Waiver on 06/05/2025. The 26/27 Wavier was requested 01/15/2026. CSC is creating a documented Standard Operating Procedure (SOP) on how to request the waiver and creating a Financial Aid Processing Calendar to ensure the deadline is met each year. Name(s) of the contact person(s) responsible for corrective action: Current Financial Aid Director: Tara Torres OR Current Assistant Financial Aid Director: Tina Ballinger Planned completion date for corrective action plan: 06/30/2026
Higher Education Institutional Aid – Assistance Listing No. 84.031X Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit findi...
Higher Education Institutional Aid – Assistance Listing No. 84.031X Recommendation: We recommend the College review policies and procedures to ensure all personnel on federal grants have documented time and effort reports as stated in federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Grant Project directors have been notified to have their employees track and document the hours spent in support of their grants versus time spent on college duties. Name(s) of the contact person(s) responsible for corrective action: Current Controller: Elizabeth Todd and Current Human Resources Director Nicole Mote Planned completion date for corrective action plan: 06-30-26
Action Plan- The Organization will ensure that a suspension and debarment check is performed for all covered transactions prior to entering into the covered transaction. Completion Date- March 2026 Contact Person- Jim O'Hara
Action Plan- The Organization will ensure that a suspension and debarment check is performed for all covered transactions prior to entering into the covered transaction. Completion Date- March 2026 Contact Person- Jim O'Hara
Condition: Management reviewed expenditure reports prior to submission however, this review did not detect or correct errors in the expenditure report. Plan:Management will not only continue to review expenditure reports, but will correctly evaluate that these reports agree with current accounting r...
Condition: Management reviewed expenditure reports prior to submission however, this review did not detect or correct errors in the expenditure report. Plan:Management will not only continue to review expenditure reports, but will correctly evaluate that these reports agree with current accounting records.Management Response: The corrective action plan was discussed with the superintendent and business manager. After discussion, the plan was approved by the superintendent.
Condition:The District's internal controls did not affectively monitor the grant budget. Plan: When creating the budget, the superintendent will compare budgeted grant expenses to overall budgeted expenses within each function to accurately monitor grant budgeting. Management Response:The corrective...
Condition:The District's internal controls did not affectively monitor the grant budget. Plan: When creating the budget, the superintendent will compare budgeted grant expenses to overall budgeted expenses within each function to accurately monitor grant budgeting. Management Response:The corrective action plan was discussed with the superintendent. After discussion, the plan was approved by the superintendent.
Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal co...
Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent) compares the meal counts in the claim to the SDS daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Management Response: The corrective action plan was discussed with the employee responsible for filing the claim, the business manager, and the superintendent. After discussion, the plan was approved by the superintendent.
The Screven County School System Nutrition Department will submit purchase order requests in YOSS, which is the digital Accounts Payable system utilized by the district. Requests will be reviewed for approval by the Director of Operations. If approved by the Director of Operations, the request will ...
The Screven County School System Nutrition Department will submit purchase order requests in YOSS, which is the digital Accounts Payable system utilized by the district. Requests will be reviewed for approval by the Director of Operations. If approved by the Director of Operations, the request will be sent through YOSS for the Superintendent's approval and then to bookkeeping to be ordered. When the items are received, accounts payable will send the invoice through YOSS for approval for payment to the Superintendent. This will provide a multiple layer to the approval process to ensure that procurement procedures are being followed.
Finding 2025-004: Payroll Processing Control Condition: During control testing over a major federal program, three instances were identified where payroll changes were not entered into the payroll system in a timely manner; however, the Organization subsequently processed appropriate retroactive adj...
Finding 2025-004: Payroll Processing Control Condition: During control testing over a major federal program, three instances were identified where payroll changes were not entered into the payroll system in a timely manner; however, the Organization subsequently processed appropriate retroactive adjustments. Corrective Actions 1. Formalize and strengthen payroll change procedures Create written procedures requiring that all Personnel Action Notices be entered into the payroll system within two business days of approval. Require preparer and reviewer signoffs on each change, documenting both data entry and verification steps. Completion Target: June 30, 2026 2. Implement payroll change review controls Before each payroll run, generate and review a “personnel change report” listing all recent pay rate, position, or status updates. Review to confirm accuracy against approved PANs, with evidence of review retained (e.g., initials and date on report). Completion Target: June 30, 2026 3. Enhance communication between HR and Payroll Require HR to transmit all approved PANs electronically to Payroll within a defined timeframe. Maintain a centralized shared log tracking each PAN’s status (“submitted,” “entered,” “verified”) to prevent omissions. Completion Target: June 30, 2026 4. Provide staff training on new procedures Conduct joint training for HR and Payroll personnel on updated workflows, timeliness expectations, documentation standards, and verification requirements. Include refresher training annually or when procedures are updated. Completion Target: June 30, 2026 5. Implement monitoring and periodic internal review The Payroll Manager will perform quarterly reviews of sample PANs to confirm timely and accurate system entry. Any discrepancies will be corrected immediately and reported to the Finance Director/CFO. Ongoing, beginning July 1, 2026 Responsible Party: HR Manager and Payroll Manager, under oversight of the Finance Director/CFO Monitoring and Verification: Payroll change log maintained and reviewed monthly. Quarterly internal review results documented and retained for audit.
Corrective Action Plan: The College will implement a process to verify the enrollment update changes have taken effect on the NSLDS website. The registrar’s office will verify the student status updates for a sample size of 15% of the overall batch population for any given month’s transmission withi...
Corrective Action Plan: The College will implement a process to verify the enrollment update changes have taken effect on the NSLDS website. The registrar’s office will verify the student status updates for a sample size of 15% of the overall batch population for any given month’s transmission within the 60-day required timeframe. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented in Spring 2026.
2025-005 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Period of Performance Auditor's Recommendation: We recommend that the Organization maintain effective internal controls over period of performance requirements Corrective Action: One City under...
2025-005 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Period of Performance Auditor's Recommendation: We recommend that the Organization maintain effective internal controls over period of performance requirements Corrective Action: One City understand the requirements for expenditure of grant funds in the proper period and will work more closely with the funders to ensure that documentation exists when a no cost extension is needed. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists in the grant management system. Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026
2025--004 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Cash Management Auditor's Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Corrective Action: One City ad...
2025--004 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Cash Management Auditor's Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Corrective Action: One City adopted a new grants management process which requires that all submitted claims are reviewed and signed by two responsible officials. Evidence of approvals will be maintained in the electronic grant files. In addition, One City has developed a training tool so that all staff who have grant claiming authority must participate in the training. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists. Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026
2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 ...
2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 out of 21 contractor and subcontractor certified payrolls tested were not submitted timely. VOAWW recognizes that timely receipt and review of certified payrolls is essential to ensuring compliance with federal wage requirements. To strengthen internal controls and ensure certified payrolls are consistently obtained, reviewed, and retained, VOAWW will implement the following corrective actions: Implementation of Certified Payroll Submission Controls Before the end of FY26, VOAWW will implement internal controls requiring contractors and subcontractors to submit certified payrolls with each pay application. These controls will include: • A requirement that certified payrolls be submitted prior to payment • A standardized checklist for verifying receipt of certified payrolls • Documentation of the review and approval process • Follow up procedures for missing or incomplete payrolls These steps will ensure certified payrolls are consistently obtained and reviewed before payment is released. Training for Staff on Wage Rate Requirements Beginning in FY26, staff responsible for managing HUD funded construction projects will receive training on: • Davis-Bacon and related wage requirements • Certified payroll documentation standards • Review procedures and red flags • Requirements under 29 CFR Part 5 Contractor Communication and Expectations Before the end of FY26, VOAWW will update contractor communication materials to clearly outline certified payroll requirements, including: • Submission timelines • Required documentation • Consequences for noncompliance • Points of contact for questions or clarifications These expectations will be reinforced during project kick off meetings and throughout the contract period. Centralized Tracking of Certified Payrolls By the end of FY26, VOAWW will implement a centralized tracking log for all certified payroll submissions. This log will document: • Receipt dates • Review dates • Reviewer initials • Any follow up actions taken This will ensure a complete audit trail and consistent monitoring of compliance. These corrective actions will strengthen VOAWW’s internal controls over Wage Rate Requirements, ensure timely receipt and review of certified payrolls, and reduce the risk of noncompliance with federal labor standards. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026
2025-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles We acknowledge BDO’s finding regarding an unallowable cost that was initially charged to the Home Investment Partnerships Program. Although the error was able to be rectified, the initial error indicated that internal controls...
2025-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles We acknowledge BDO’s finding regarding an unallowable cost that was initially charged to the Home Investment Partnerships Program. Although the error was able to be rectified, the initial error indicated that internal controls did not prevent or detect the unallowable charge at the time of posting. To strengthen internal controls over allowable costs and ensure expenditures charged to federal programs comply with Uniform Guidance and program-specific requirements, VOAWW will implement the following corrective actions: Strengthened Review of Allowable Costs Before the end of FY26, the Finance Department will enhance its invoice review procedures for all programs. This strengthened review will include verification of: • Allowability under 2 CFR §200 Subpart E • Program specific requirements • Contract terms and approved budgets • Supporting documentation for each cost Review steps will be documented to ensure a clear audit trail. Training for Staff on Federal Allowable Cost Requirements Beginning in FY26, Finance, Grants, and Contract Compliance staff responsible for coding, approving, or reviewing federal expenditures will receive training on: • Allowable cost principles under 2 CFR §200.403–.405 • Program specific cost restrictions • Documentation standards • The importance of internal controls over federal expenditures Before the end of FY26, VOAWW will implement internal controls to ensure that allowability determinations are made internally by trained staff prior to charging costs to federal awards. Centralized Federal Award Compliance Reference By the end of FY26, Contract Compliance will maintain a centralized compliance reference for all federal programs, including allowability rules, program specific restrictions, and documentation requirements. Finance staff will reference this tool during invoice review to ensure consistent application of federal requirements. These corrective actions will strengthen VOAWW’s internal controls over allowable costs, reduce the risk of unallowable expenditures being charged to federal programs, and ensure compliance with Uniform Guidance and HUD program requirements. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026
2025-002 Accounts Payable Cutoff We acknowledge BDO’s inquiry regarding an invoice that appeared to relate to the prior fiscal period. The invoice was received after Accounts Payable closed without advance notification for accrual. BDO noted a similar issue in an additional sample. To strengthen our...
2025-002 Accounts Payable Cutoff We acknowledge BDO’s inquiry regarding an invoice that appeared to relate to the prior fiscal period. The invoice was received after Accounts Payable closed without advance notification for accrual. BDO noted a similar issue in an additional sample. To strengthen our accounts payable cutoff controls and prevent similar issues, we will implement the following improvement measures: • Formalize the Accrual Process – While an accrual process already exists, before the end of FY26, we will document and strengthen the accrual procedures by requiring Program Managers to notify Finance, specifically the AP team inbox, when work from a vendor has been completed, but an invoice has not yet been received, on an annual basis by a given deadline. This will ensure that known obligations are captured in the correct fiscal period. • Strengthen Review of Post-Year-End Invoices – While regular review of invoices is already a part of our regular AP process, Accounts Payable will implement a more stringent review process before the end of FY26 for all invoices received in the first period after fiscal year end, including verification of service dates, contract terms, and deliverables. • Enhanced Communication Expectations – Program Managers will receive training and guidance before the end of FY26 on the importance of timely invoice submission and the need to alert Finance when delays occur. • Documentation of Cutoff Decisions – For invoices received after close, before the end of FY26, Accounts Payable will document the receipt date, supporting details, and rationale for the period in which the expense is recorded to maintain a clear audit trail. These improvements will strengthen our internal controls over AP cutoff, improve the consistency of accrual practices, and reduce the risk of misstatements due to late or ambiguous invoices. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026
Condition: Multiple individuals are responsible for the preparation and submission of the District's quarterly exepnditure reports; however, the expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of t...
Condition: Multiple individuals are responsible for the preparation and submission of the District's quarterly exepnditure reports; however, the expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of the report. Plan: Mannagement will review all expenditure reports. Only expenditures obligated within the grant period will be included on the expenditure report. Any obligations not yet liquidated will be reported as such.
Segregation of Duties Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. ...
Segregation of Duties Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review its staffing and the need for separation of duties as part of an effective internal control system and take appropriate actions.. Name(s) of the contact person(s) responsible for corrective action: Vice President for Enrollment Management Damon Wade, Director of Financial Aid Deniesha Newby, and Controller Will Gibbons Planned completion date for corrective action plan: June 30, 2026
Program: Congressionally Recommended Awards / HOME Investment Partnerships Program / Homeland Security Grant Program / Epidemiology and Laboratory Capacity for Infectious Disease Federal Financial Assistance Listing Number: 16.753 / 14.239 / 97.067 / 93.323 Federal Grantor: U.S. Department of Justic...
Program: Congressionally Recommended Awards / HOME Investment Partnerships Program / Homeland Security Grant Program / Epidemiology and Laboratory Capacity for Infectious Disease Federal Financial Assistance Listing Number: 16.753 / 14.239 / 97.067 / 93.323 Federal Grantor: U.S. Department of Justice / U.S. Department of Housing and Urban Development / U.S. Department of Homeland Security / U.S. Department of Health and Human Services Award No. and Year: Multiple Compliance Requirements: Other – Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of expenditures of Federal awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. §200.331 of the Uniform Guidance states the County is responsible for making case-by-case determinations to determine whether the entity receiving the Federal funds is a subrecipient. In addition, §200.303 of the Uniform Guidance states that the County must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition: During our audit procedures performed over the SEFA we noted the following: • The Sheriff-Coroner Department did not properly identify the amount expended for the Congressionally Recommended Awards, AL No. 16.753. The expenditures reported by the Department were overstated by $2,638,516. • The Orange County Community Resources Department did not properly identify the amount of Federal funding passed through to subrecipients for the HOME Investment Partnerships Program, AL No. 14.239. The amount passed through to subrecipients reported by the Department was overstated by $4,500,624. • The Sheriff-Coroner Department did not properly identify the amounts expended for the Homeland Security Grant Program, AL No. 97.067. The expenditures reported by the Department were overstated by $715,489. • The Orange County Health Care Agency (HCA) did not properly identify the amount expended for the Epidemiology and Laboratory Capacity for Infectious Disease program, AL No. 93.323. The expenditures reported by the Agency were overstated by $486,000. Cause: As a result, the County lacked adequate internal controls to ensure the SEFA is completely and accurately stated. Specifically, the County’s processes for recording and tracking expenditures of Federal awards are not designed so that expenditures are identified when incurred. In addition, the County’s processes for identifying and reporting subrecipients are not designed to ensure appropriate reporting on the SEFA. Effect: Adjustments to the SEFA were required. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used. Program expenditures and amounts passed through to subrecipients were reconciled to the supporting records. Repeat Finding from Prior Years: No. Recommendation: The County, including all its reporting departments, should follow existing policies, procedures and internal controls to ensure all expenditures and amounts passed through to subrecipients are accurately tracked and reported on the SEFA. Personnel knowledgeable of federal expenditures should review amounts coded to federal programs for completeness and accuracy. The SEFA should be prepared and reviewed in a timely manner and reconciled to underlying records as well as the basic financial statements. Management Response and Corrective Action Plan: Health Care Agency: 1. Person Responsible: David Santalahti, HCA Claims & Financial Reporting Manager 2. Corrective action plan: HCA Accounting will review and enhance its procedures and training for analysis and tracking federal award expenditures to ensure expenditures are reported in the appropriate fiscal year period. 3. Anticipated Implementation date: June 30, 2026 Orange County Community Resources: 1. Person Responsible: Bill Malohn, OCCR Accounting Manager 2. Corrective action plan: Concur. OCCR has established policies and internal controls to ensure all expenditures and amounts passed through to subrecipients are accurately tracked and reported on the SEFA. Appropriate personnel review amounts coded to federal programs for completeness and accuracy. We prepare and review the SEFA in a timely manner and reconcile to underlying records as well as the basic financial statements. In this particular situation, we miscategorized one provider as a subrecipient and reported the related funding as such on the SEFA. This oversight had no impact on the total amount we reported on the SEFA. We will be sure to follow our policies and procedures to ensure accurate SEFA reporting. 3. Anticipated Implementation date: February 2, 2026 Sheriff-Coroner: 1. Person Responsible: Monique Vansuch, Fiscal Administrator 2. Corrective action plan: The Sheriff-Coroner Department acknowledges the finding and recognized federal grant expenditure incurred is defined as when expenditures are delivered and/or services are performed rather than when the expenditures are paid. We will strengthen the internal controls to ensure grant expenditures are reported per the Uniform Guidance. 3. Anticipated Implementation date: June 30, 2026
Program: HIV Emergency Relief Project Grants (Ryan White) Federal Financial Assistance Listing Number: 93.914 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 6H89HA00019-32-04; 2024 Compliance Requirements: Activities Allowable or Unallowed and Allowable Costs/Cost ...
Program: HIV Emergency Relief Project Grants (Ryan White) Federal Financial Assistance Listing Number: 93.914 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 6H89HA00019-32-04; 2024 Compliance Requirements: Activities Allowable or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing, for one (1) out of sixty (60) payroll expenditures, we noted the timecard did not contain documented evidence of supervisory approval. Cause: The County’s internal control procedures were not consistently followed to ensure that the review and approval of timecards was documented. Effect: Lack of documented review for personnel hours could lead to an increased risk that unallowable or inaccurate activities and costs to be charged to the Federal program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sampling of sixty (60) timecards were selected for testing out of a population of 5,994. The condition noted above was identified during our procedures related to activities allowed or unallowed and allowable costs/cost principles. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its policies and procedures to ensure that timecards consistently include documented evidence of supervisor approval prior to payroll processing. The County should also establish compensating controls for circumstances where timely supervisory approvals is not possible, and ensure such controls are consistently documented. Management Response and Corrective Action Plan: 1. Person Responsible: Barbara Harano, HCA Disbursements Manager 2. Corrective action plan: HCA Payroll will continue to review the Unapproved Timesheets Report in OC Time and send reminder emails to all supervisors with pending approvals. If supervisory approvals cannot be obtained by the OC Time timesheet upload deadlines, HCA Payroll will ensure documented timesheet approvals are appended through the OC Time amendment process and archived in the Unit’s shared drive. 3. Anticipated Implementation date: January 22, 2026
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