Corrective Action Plans

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Finding 2024-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 Home Investment Partnership Program Significant Deficiency in Internal Controls and Noncompliance over Special Tests – Housing Quality Standards Repeat Finding: Yes; 2023-026 Auditee’s Corrective Action Plan: The A...
Finding 2024-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 Home Investment Partnership Program Significant Deficiency in Internal Controls and Noncompliance over Special Tests – Housing Quality Standards Repeat Finding: Yes; 2023-026 Auditee’s Corrective Action Plan: The Agency continues to appreciate the comprehensive review of this program and concurs with this finding. Of the two selections that lacked evidence of follow up inspection, one of the cited properties did not receive a follow up inspection in the program year, due in part to the transition of the property management staff. The exit and arrival of new property management company led to high staff turnover at the property. These follow up inspections will take place this year. Follow up inspections at another property did take place, but the results of at least one unit still required corrective measures. The results were shared with property staff at the time of inspection, but file documentation was not updated in a manner consistent with our corrective action plan. The 2025 inspections of that property have already begun with more scheduled. For the three selections that we were unable to provide support for verification of inspection for fiscal year 2024, these inspections took place after the fiscal year ended. HOME program compliance inspections are scheduled by calendar year, not fiscal year, so it is possible for annually inspected properties to not have an inspection during a fiscal year. The audit process has made us aware that we were not properly updating rescheduled inspections, inadvertently giving the impression that these inspections took place on their originally scheduled dates. While the outcome of the audit is not ideal, the corrective action plan from last year did go into effect and progress has been made. A new compliance officer was hired to take over the physical inspection portion of HOME compliance. The dedicated employee was able organize and update the physical inspection documentation into our SharePoint file. Several follow up inspections have already taken place. Going forward, we will redouble our efforts to make sure that Inspection Findings and Corrective measures are recorded and followed up making it a point of emphasis at weekly compliance meetings. We will also update our internal tracker so that rescheduled and follow up inspections are reflected accurately. Contact Person: Eugene Greene, Operations Officer, Baltimore City DHCD – Development Division Completion Date: Effective immediately.
Finding 2024-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 Home Investment Partnership Program Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: No Auditee’s Corrective Action Plan: The agency concurs with and accepts these find...
Finding 2024-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 Home Investment Partnership Program Significant Deficiency in Internal Controls and Noncompliance over Eligibility Repeat Finding: No Auditee’s Corrective Action Plan: The agency concurs with and accepts these findings. Our grantees are aware of HOME record keeping requirements and are reminded of these requirements annually in the text of our file inspection compliance notifications. The management of the cited properties will be given a formal letter making them aware of the findings of this audit and reminded of HOME Investment Partnership Program record keeping requirements. We will also add the record keeping reminder to our Annual Desk Review notification. We will ensure that 100% of active HOME properties receive the record keeping requirements reminder, not just properties that receive file inspections. Additionally, the one file missing support documentation will be selected as a part of that property’s annual file inspection in 2025. We will also instruct the property that failed to submit its requested tenant file to continue searching for the file. The file in question is for a former tenant and was maintained by the previous management company. DHCD will reach out to the former management company to see if they can assist in the search. Contact Person: Eugene Greene, Operations Officer, Baltimore City DHCD – Development Division Completion Date: Effective immediately.
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually a...
Finding 2024-007 Programs: All Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes; 2023-006 Auditee’s Corrective Action Plan: The city’s legacy financial system did not collect data required for SEFA. Agencies had to provide most details manually and work between spreadsheets and multiple systems to input and track receipt grant awards and spend on personnel, supplies and services and sub-recipient awards related to grants. The steps to address this legacy finding have been phased and include the technology implementation, staff training and additional oversight. As noted, the City implemented Workday, an Enterprise Resource Planning (ERP) system, across workstreams so that Financial Accounting, Grants, Procurement, Supplier Accounts, Banking, Payroll and Human Resources are all in one system. As with any ERP, an ongoing process of evaluation and updates are needed to continuously align workflow and business processes. This approach has led to continued improvement over the years as the grants management module is fully implemented in Workday. Since implementation, additional enhancements have been adopted and utilized with a robust workflow process for grant approval, grant budget tracking, and invoice scheduling. In addition to the technology adoption, an increase in citywide grants training and oversight has been implemented. The progress is detailed below: • FY 23 represented the first year in the new system. To compile the SEFA, the City used a hybrid approach to leverage Workday and Agency provided data. o There were some data accuracy challenges from data entry errors. To address those data entry challenges the award modification business process was improved post-implementation to add a GMO review and approval step of award modifications. o As of May 2024, all award modifications now require centralized GMO review to verify data accuracy. o Additional process changes in FY 23 included implementation of the requirement as part of the FY 24 budget preparation process that grant worktags must be created and budgeted for during the City’s annual budget process. The grant worktag creation process includes approvals at the agency program and fiscal levels, as well as at the Department of Finance level. • In FY24 further Award Module enhancements were adopted to provide key new data points in Workday. o Each grant award now includes information: Federal Assistance Listing Number (fna CFDA#), Passthrough Agencies & Passthrough Identifier. o Additionally, in FY 24, GMO, in collaboration with BAPS launched the Grants Workstream Training sessions. These monthly citywide virtual live trainings are on a variety of grant management related topics, averaging 60 attendees per session. Attendees are city agency grant managers and city agency fiscal staff. • In FY 24 and FY 25 the topics covered included: o FY 24 Grant Work tag Preparation o FY 24 SEFA Preparation o Grant Accounting Best Practices and Workday Billing o Award Set-up Best Practice & Potential Pitfalls o Extra Features in Workday (including reporting and how to set up award tasks and deadlines) o Subrecipient Monitoring Best Practices o Cost-reimbursable grant invoicing in Workday o FY 25 SEFA preparation o FY 26 Grant Work tag Preparation o Grant Management Roles and Responsibilities o Specific training on the SEFA, including information on understanding the importance of the SEFA, what information is included and how to review SEFA data, was conducted. Citywide training sessions were held in FY 24 and FY 25 to ensure that the reporting is understood by city agencies, with special emphasis on subrecipient payments being reported properly. The training schedule is ongoing and continuous. • To improve SEFA reporting data, in FY 25 there is an emphasis on subrecipient set up and spending to ensure that functionality is refined to improve uniformity in subrecipient set up. GMO, in conjunction with BAPS, the Bureau of Procurement and city agencies will work to refine subrecipient set up, spending and monitoring, including improved reporting. o GMO has hosted three subrecipient monitoring and management–related trainings since December 2024. Additionally, to improve subrecipient managing and monitoring, GMO modified the award setup business process in Workday to include verification of subaward status before final award setup approval. In FY 25, GMO provided training on how to setup subawards accurately in Workday. As discussed above, these trainings will be ongoing. • Additionally, GMO and the BBMR will collaborate on a subaward dashboard to monitor subrecipient spending data in real time. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: FY26 3rd Quarter- • Design and complete a grants management dashboard within Workday • Ongoing and continuous - GMO will continue to conduct trainings on SEFA reporting and subrecipient management and reporting.
Caspian Housing Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan, PC, 2425 E. Grand River Ave., Suite 1, Lansing, MI 48912 Audit period: Year ended December 31, 2024 The findings from December 31, 2024 schedule o...
Caspian Housing Corporation respectfully submits the following corrective action plan for the year ended December 31, 2024. Auditor: Maner Costerisan, PC, 2425 E. Grand River Ave., Suite 1, Lansing, MI 48912 Audit period: Year ended December 31, 2024 The findings from December 31, 2024 schedule of finding and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding Number 2024-001 - Material Weakness in Interal Control Over Major Program Complaince Recommendation: Develop and implement comprehensive written policies and procedures that align with Uniform Guidance requirements. Action Taken: We are in agreement with the recommendations and will work to implement the required policies and procedures in accordance with Uniform Guidance during 2025.
Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second empl...
Condition: During testing, it was noted that although there was a process in place to review eligibility criteria received by program, there was not an independent review or control to ensure eligibility was accurate. Planned Corrective Action: After the initial review for eligibility, a second employee will verify that eligibility was properly determined and provide a signoff to document review. This was implemented in September of 2024. Contact person responsible for corrective action: Lucy Rosenberg and Michelle Estell Anticipated Completion Date: 09/01/2024
Condition: The Township did not have controls in place surrounding the review of annual performance reporting. Planned Corrective Action: The Township has implemented a formal review process within the Finance and Budget Department to ensure the integrity of annual performance reporting. One staff m...
Condition: The Township did not have controls in place surrounding the review of annual performance reporting. Planned Corrective Action: The Township has implemented a formal review process within the Finance and Budget Department to ensure the integrity of annual performance reporting. One staff member has been designated to compile and complete the performance reports,while a separate finance team member is responsible for conducting an independent review prior to submission. To support this process, an internal timeline has been established to allow sufficient time for thorough review and validation of all performance data before final submission. Contact person responsible for corrective action: Wendy Hillman Anticipated Completion Date: 04/15/2025
Cochise County WIC leadership and staff is committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. The County immediately corrected this issue by conducting a mandatory training sessio...
Cochise County WIC leadership and staff is committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. The County immediately corrected this issue by conducting a mandatory training session for all WIC staff regarding the Rights and Obligations policy. During this session, the policy was read aloud and distributed in written form to all attendees. Staff were directed to inform all participants of their rights and responsibilities to include having the rights and responsibilities form signed by the participants, prior to issuing benefits, during the participant’s initial certification, and recertifications for ongoing benefits. Staff received the Rights and Obligations Pledge for review and reference. Procedures for obtaining signatures from participants not physically present in the office were reviewed. Acceptable alternatives include sending the form via email for electronic or physical signature, scheduling a follow-up in-office visit for signature collection. All staff questions were addressed to ensure clarity and consistent understanding. Ongoing reminders have been disseminated through emails and during regular staff “huddles” since the training. In addition to the immediate actions taken to correct the finding, the County also implemented long-term action steps. These steps include annual training of all WIC Staff on the Rights and Obligations policy the 2nd Monday of January. Each employee will sign an attestation confirming their understanding and compliance post-training. This attestation will be stored in the employee’s personnel record. Monthly, the WIC Manager, or designee, will review the WIC Cert. for Audit Report the last Friday of each month to identify and address any instances of missing client signatures. Additionally, the WIC Manager will manually audit 3% of the total WIC members for the month. Continuous actions implemented by County staff to correct this finding includes consistent reinforcement of signature collection protocols and policy reminders during monthly meetings and weekly “huddles”. Of note, a request was submitted to the Arizona WIC Service Desk to determine whether a report could be generated identifying all participants lacking a signed Rights and Obligations form to strengthen monitoring efforts. The response received indicated that generating this type of report is extremely complex, and at this time it is not possible.
View Audit 357695 Questioned Costs: $1
The reconciliation process implemented in Finding 2024-001 includes a formal method of matching drawdowns to allowable expenditures. Each grant will continue to be tracked in a separate cost center and La Casa will document the reconciled expenditures in the general ledger to amounts drawn from eac...
The reconciliation process implemented in Finding 2024-001 includes a formal method of matching drawdowns to allowable expenditures. Each grant will continue to be tracked in a separate cost center and La Casa will document the reconciled expenditures in the general ledger to amounts drawn from each grant. The monthly reconciliation will be reviewed by the CFO to ensure that revenue is recognized in accordance with ASC 958-605 and that federal expenditures reported on the SEFA and financial statements comply with 2 CFR §§200.302, 200.303, and 200.305. The CFO will utilize the reconciliations to prepare the SF-425 filings and confirm that cumulative drawdowns reconcile to allowable costs and recorded revenues. All supporting documentation will be retained electronically and included in monthly close procedures.
Finding 561950 (2024-004)
Significant Deficiency 2024
Corrective Action Plan: The identified conditions relate to students who experienced a change in status code within the Union College system. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database Syste...
Corrective Action Plan: The identified conditions relate to students who experienced a change in status code within the Union College system. This report will be reconciled with student status changes transmitted by the National Student Clearinghouse (NSC) to the National Student Loan Database System (NSLDS), and any necessary corrections will be made immediately. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented in Spring 2025.
Finding 561927 (2024-003)
Material Weakness 2024
Corrective Action Plan: The identified conditions relate to the proper maintenance of detailed records of equipment and other assets acquired for research purposes from federal award funding. As a result of personnel turnover in the Union College finance department, the required bi-annual inventory ...
Corrective Action Plan: The identified conditions relate to the proper maintenance of detailed records of equipment and other assets acquired for research purposes from federal award funding. As a result of personnel turnover in the Union College finance department, the required bi-annual inventory count and reporting was not conducted for fiscal year 2024. The corrective action plan is to conduct this audit at the conclusion of the current fiscal year (2025). Timeline for Implementation of Corrective Action Plan: These corrective action will be completed concurrently with the fiscal year 2025 year end closing and audit procedures. The College will then get back on cycle with a research equipment inventory audit for fiscal year 2026, and then each bi-annual cycle thereafter.
Finding 561904 (2024-002)
Significant Deficiency 2024
Corrective Action Plan: The identified conditions relate to the proper application and calculation of indirect cost rates for federal research grants. Further items relate to the assignment of the proper fringe rate for federal research grants. To mitigate future occurrences of possible incorrect ra...
Corrective Action Plan: The identified conditions relate to the proper application and calculation of indirect cost rates for federal research grants. Further items relate to the assignment of the proper fringe rate for federal research grants. To mitigate future occurrences of possible incorrect rates applied to such contracts, the College has strengthened its internal controls and oversight by reviewing and reperforming calculations. Timeline for Implementation of Corrective Action Plan: These corrective actions were implemented by spring 2025.
View Audit 357554 Questioned Costs: $1
Corrective Action Planned: The accounting records for the federal award revenues and expenditures have been properly maintained for 2025. Person Responsible for Corrective Action: Alisha Middleton, Clerk. Anticipated Completion Date: December 31, 2025.
Corrective Action Planned: The accounting records for the federal award revenues and expenditures have been properly maintained for 2025. Person Responsible for Corrective Action: Alisha Middleton, Clerk. Anticipated Completion Date: December 31, 2025.
Finding 561396 (2024-001)
Significant Deficiency 2024
U.S Department of Treasury 2024-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommended that the organization implement a review and approval process for all quarterly progress report submissions. This should include: •Training staff on...
U.S Department of Treasury 2024-001 Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommended that the organization implement a review and approval process for all quarterly progress report submissions. This should include: •Training staff on the importance of the review and approval process. •Ensuring adequate staffing levels to handle the review process. •Developing clear guidelines and procedures for the review and approvalprocess. •Regularly monitoring and auditing the review process to ensure compliance. Explanation of disagreement with audit finding: Management concurs with the finding. Action taken in response to finding: Additional fiscal staff has been hired to assist with various fiscal tasks including grant compliance and reporting. The guidelines are being updated, the checklist expanded, and documentation of secondary approval of reports is being retained. Grant guidelines, procedures, and checklists will be utilized to ensure compliance is maintained. Name(s) of the contact person(s) responsible for corrective action: Pete Winton Planned completion date for corrective action plan: The above action plan will be implemented in fiscal year 2025.
Item 2024‐001 – Special Tests and Provisions – Wage Rate Requirements (Repeat) Recommendation: 2 CFR 200.303 requires the non-Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non- Federal entity is managing t...
Item 2024‐001 – Special Tests and Provisions – Wage Rate Requirements (Repeat) Recommendation: 2 CFR 200.303 requires the non-Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Linda Harper, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all current contractors and subcontractors regarding the wage rate requirements for contracts in progress and has implemented additional procedures for future projects effective October 1, 2024. These additional procedures include the Chief School Financial Officer (CSFO), Linda Harper, reviewing all proposed construction contracts for inclusion of the prevailing wage rate clause as part of the bid process prior to expenditures being made. The CSFO will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.
View Audit 356950 Questioned Costs: $1
Finding 561271 (2024-001)
Significant Deficiency 2024
Corrective Action Plan Emory University Office of Financial Aid Prepared by John Leach, Assoc Ve Prov/Dir, Univ Fin Aid, Office of Financial Aid Federal Program: Federal Direct Student Loans (ALN 84.268} CFR 200.303/685.300(b)(S0) Federal Award Year: September 1, 2023 to August 31, 2024 Federal Agen...
Corrective Action Plan Emory University Office of Financial Aid Prepared by John Leach, Assoc Ve Prov/Dir, Univ Fin Aid, Office of Financial Aid Federal Program: Federal Direct Student Loans (ALN 84.268} CFR 200.303/685.300(b)(S0) Federal Award Year: September 1, 2023 to August 31, 2024 Federal Agency: U.S. Department of Education Finding 2024-001: Cash Management The reconciliation between ED's records (School Account Statements) and the school's financial and business records were prepared timely throughout the year; however, the differences identified in the reconciliation were not accounted for and no review or segregation of duties was documented as part of that process. Management Response and Corrective Action Plan: The finding was primarily caused by an unforeseen staff shortage. This led to one person being the preparer and reviewer with no segregation of duties. Although the differences were identified, they were not documented on the reconciliation form. To resolve this finding, the Office of Financial Aid {OFA) has hired new employees and implemented a new process. The Financial Operations Team is now fully staffed with two senior accountants and one senior director. As part of our ongoing efforts to strengthen internal controls and ensure the integrity of our processes, we have implemented a segregation of duties framework. This approach will help us clearly define roles and responsibilities, ensuring that critical tasks are divided among different individuals. By doing so, we will meet compliance requirements, reduce errors, and promote accountability within our office. One senior accountant will prepare the monthly reconciliation by the 10th of the following month. The senior director will review the monthly reconciliation by the 15th of the following month. In the absence of the initial preparer/reviewer, the executive director of OFA will take on the reviewer role. We understand that proper documentation is crucial for clarity, tracking, and future troubleshooting. The differences/discrepancies that are identified in the reconciliation process will be accounted for through proper documentation on the reconciliation form, which will be reviewed/investigated by a second reviewer. The Financial Operations Team within the OFA will continue to create timely and accurate monthly Federal Direct Student Loan reconciliations that compare OPUS (Emory), General Ledger (Emory), Student Account Statement-SAS (U.S. Department of Education), and GS (U.S. Department of Education). Anticipated Completion Date The corrective action plan was implemented for FY 24-25 (September 1, 2024). Responsible Department: Office of Financial Aid John B. Leach, Associate Vice Provost for Enrollment and University Financial Aid Suite 300 Boisfeuillet Jones Center 200 Dowman Drive Atlanta, Georgia 30322
The Authority obtained answers from USDA to questions specific to the Authority's operations after the due date of the semiannual report. The Authority will be proactivt to follow up with USDA when questions and information are submitted for preliminary review. Reports will be prepared and submitted...
The Authority obtained answers from USDA to questions specific to the Authority's operations after the due date of the semiannual report. The Authority will be proactivt to follow up with USDA when questions and information are submitted for preliminary review. Reports will be prepared and submitted in a timely manner.
Finding 561264 (2024-003)
Significant Deficiency 2024
SD 2024‐003 SUBRECIPIENT MONITORING Recommendations: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management’s Response: The IRL Council put controls in place to be more effective at subrecipient monitori...
SD 2024‐003 SUBRECIPIENT MONITORING Recommendations: If the most recent subrecipient audit report is not yet available, management should request the prior fiscal year if not already obtained. Management’s Response: The IRL Council put controls in place to be more effective at subrecipient monitoring following the FY 2023 finding which included the following actions: The IRL Council reviewed all projects and activities currently allocated and funded by federal sources to ensure the Uniform Guidance was in place within their respective agreements, and they were amended as needed. All new subrecipient agreements funded by federal sources were not executed until the respective federal award was in place and the Uniform Guidance language was included. The IRL Council did request audit reports from subrecipients and made statements on them, however for the ones who had not completed their FY 2024 audit, a prior year audit report was not immediately requested and statements for those subrecipients had not yet been made. The IRL Council will implement a control to request prior year Financial Statements/audit reports from subrecipients who have not yet completed their report for the year being requested during the Council’s monitoring. Responsible Party: Daniel Kolodny, COO Anticipated Completion Date: June 1, 2025.
Finding 561261 (2024-002)
Significant Deficiency 2024
SD 2024‐002 SUSPENSION AND DEBARMENT Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating i...
SD 2024‐002 SUSPENSION AND DEBARMENT Recommendation: We recommend the Council continue with the controls that were implemented in late 2024 to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. As the control was not in place for the majority of 2024, it is a repeat finding. Management’s Response: The IRL Council amended its Operating Procedures following the FY 2023 finding to include suspension and debarment procedures into procurement methods for activities that are federally funded. The IRL Council Chief Operating Officer, immediately checked all current vendors for compliance within SAM.gov and all new or amended agreements have since been checked in SAM.gov for compliance. As noted by Carr, Riggs, and Ingram there were no instances of exception in their testing. Due to the timing of the FY 2023 finding, FY 2024 would also be considered a finding regardless of any corrective action taken. Anticipated Completion Date: Remedial action completed on December 31, 2024.
Finding 561258 (2024-001)
Material Weakness 2024
MW 2024‐001 REPORTING Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management’s Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from...
MW 2024‐001 REPORTING Recommendation: The Chief Operating Officer should obtain in writing any adjustments or clarifications to the grant awards to ensure the requested reports are prepared and reviewed. Management’s Response: EPA has never requested the SF425 (Federal Financial Reporting Form) from year’s prior and we were told verbally that we were only required to submit them at grant closeout. During a current EPA OIG audit, we were informed that the procedural process we were following was incorrect and that yearly reports were required to be submitted. To bring the IRL Council back into compliance with all federal awards, the Chief Operating Officer completed the FY 2024 forms and submitted them to EPA on March 10, 2025. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: Remedial action completed on March 10, 2025.
Finding 561212 (2024-003)
Significant Deficiency 2024
Federal Agency Name: US Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds CFDA # 21.027 H4HRG23166 and H4HRGP23180, 2024 Finding Summary: The Organization did not have a formal tracking and monitoring process in place to accumulate total matching expenditures inc...
Federal Agency Name: US Department of Treasury Program Name: Coronavirus State and Local Fiscal Recovery Funds CFDA # 21.027 H4HRG23166 and H4HRGP23180, 2024 Finding Summary: The Organization did not have a formal tracking and monitoring process in place to accumulate total matching expenditures incurred toward the requirement for each award. Responsible Individuals: Lara Blair, Finance Manager Corrective Action Plan: The Organization will implement a tracking process by award detail to clearly identify and track qualifying expenditures by award to ensure that all matching requirements are achieved and appropriately documented. Anticipated Completion Date: June 30, 2025
Management response: Warren Easton is reviewing and updating the procurement section of the policy manual to explicitly include procedures for verifying the suspension and debarment status of all vendors and contractors receiving federal funds. Documentation of each vendor's verification will be mai...
Management response: Warren Easton is reviewing and updating the procurement section of the policy manual to explicitly include procedures for verifying the suspension and debarment status of all vendors and contractors receiving federal funds. Documentation of each vendor's verification will be maintained in procurement files. A printed or PDF record from SAM.gov showing the vendor's status will be retained as audit evidence.
2024-002 Student Financial Aid Cluster – Assistance Listing 84.063 and 84.268 Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Explanation of disagreement with audit finding...
2024-002 Student Financial Aid Cluster – Assistance Listing 84.063 and 84.268 Recommendation: The College should evaluate their procedures and review policies surrounding reporting enrollment effective dates and program enrollment effective dates NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Through the review of program reporting and campus reporting, the college will identify the cause for the data error. The college will explore the impact of branch campuses and the potential to shift to a single college reporting model. The following specific steps will be completed. 1. Identify and Analyze the Issues 2. Root Cause Analysis 3. Corrective Measures 4. Automation: Implement automated checks and balances to ensure data integrity before files are processed and sent. Name(s) of the contact person(s) responsible for corrective action: Patricia Munsch, Ph.D. Vice President for Student Affairs Nancy Brewer, College Director for Financial Aid Cheryl Eldredge, College Associate Dean for Registrar and Master Schedule Planned completion date for corrective action plan: December 31, 2026
Finding 2024‐007: Procurement and Suspension and Debarment Federal Agency Name: U.S. Department of Health and Human Services Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Federal Financial Assistance Listing Number: 93.829 Finding Summary: The Organizat...
Finding 2024‐007: Procurement and Suspension and Debarment Federal Agency Name: U.S. Department of Health and Human Services Program Name: Section 223 Demonstration Programs to Improve Community Mental Health Services Federal Financial Assistance Listing Number: 93.829 Finding Summary: The Organization did not have a written procurement policy that was consistent with Federal, State, local, and tribal laws and regulations. In addition, the Organization entered into a contract with a vendor for services without obtaining quotes from other vendors. Responsible Individuals: Joshua Duame, Fractional CFO Corrective Action Plan: Management agrees with the finding. Management will implement a written procurement, suspension and debarment policy that meets Federal, State, local, and tribal laws and regulations. We also recommend that management review this policy regularly to confirm that it meets the requirements and that all transactions follow this policy. Anticipated Completion Date: 6/1/2025
View Audit 356459 Questioned Costs: $1
Name of Auditee: California Community Foundation (CCF) Audit Period: Year Ended June 30, 2024 Finding Reference #: 2024-003 – Reporting Finding Description: The Single Audit report identified a reporting-related finding (2024-003) associated with the Coronavirus State and Local Fiscal Recovery Funds...
Name of Auditee: California Community Foundation (CCF) Audit Period: Year Ended June 30, 2024 Finding Reference #: 2024-003 – Reporting Finding Description: The Single Audit report identified a reporting-related finding (2024-003) associated with the Coronavirus State and Local Fiscal Recovery Funds under the U.S. Department of Treasury. The Foundation overstated expenditures by $203,329 and the corresponding indirect costs by $20,363 in the Schedule of Expenditures of Federal Awards (SEFA). Additionally, discrepancies were noted in the June 30, 2024 Quarterly Performance Report to the County, where advances to vendors were overstated by $120,000 and vendor-incurred expenditures were understated by $519,259. This condition reflects a gap in internal controls that could impact accurate financial reporting. Corrective Action Planned: CCF acknowledges the finding and is implementing corrective measures to strengthen the accuracy and integrity of its financial and programmatic reporting. CCF has enhanced its internal review process and implemented a reconciliation protocol to ensure consistency between internal records and external reports. Finance staff have received additional training, and final reports are now subject to dial validation by both the Compliance and Finance teams prior to submission. Anticipated Completion Date: Corrective action will be implemented by May 15, 2025. Responsible Official(s): Jose Najera, Sr. Compliance & Operations Officer (213) 452-6218 – jnajera@calfund.org Management Comments: CCF remains committed to maintaining robust internal controls and ensuring compliance with all applicable federal requirements. We appreciate the audit team’s observations and will continue enhancing our procedures to prevent future discrepancies and to uphold the highest standards of financial integrity and transparency.
Name of Auditee: California Community Foundation (CCF) Audit Period: Grant Award Period: 9/1/2022 – 8/31/2024 Finding Reference #: 2024-002 – Allowable Costs Finding Description: For one of the 28 invoices reviewed, which includes 25 subrecipient invoices and 3 vendor invoices, representing $76,549 ...
Name of Auditee: California Community Foundation (CCF) Audit Period: Grant Award Period: 9/1/2022 – 8/31/2024 Finding Reference #: 2024-002 – Allowable Costs Finding Description: For one of the 28 invoices reviewed, which includes 25 subrecipient invoices and 3 vendor invoices, representing $76,549 of the $439,088 of underlying invoices reviewed, insufficient documentation was maintained to demonstrate management completed the invoice review process as the review and approval of the invoice was not documented. The Foundation had an agreement with its contractor to pay for services performed according to an agreed payment schedule. While the Foundation reviewed payments made to the contractors, it did not review the underlying invoice detailing the work performed for the payment. Corrective Action Planned: The Foundation acknowledges the finding and will implement corrective measures by updating its invoice review procedures to formally record review dates and approvals in compliance with 2 CFR 200.303. Additionally, we will reinforce staff training and supervisory reviews to ensure that all invoice documentation meets federal standards. Periodic internal reviews and audits will be conducted to verify adherence to these enhanced procedures. Anticipated Completion Date: Corrective action will be implemented by April 1, 2025. Responsible Official(s): Jose Najera, Sr. Compliance & Operations Officer (213) 452-6218 – jnajera@calfund.org Management Comments: The Foundation remains committed to maintaining effective internal controls and ensuring compliance with all applicable federal regulations. While our current process includes a review of invoices, the noted documentation lapse will be addressed through improved procedures and enhanced training. These corrective actions will mitigate the risk of unallowable cost charges and ensure consistent compliance with federal procurement standards.
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