Corrective Action Plans

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The College acknowledges the finding and agrees that Cost of Attendance and Satisfactory Academic Progress determinations must be calculated, documented, and reviewed in accordance with federal requirements. The condition resulted from reliance on manual processes, lack of retained supporting docume...
The College acknowledges the finding and agrees that Cost of Attendance and Satisfactory Academic Progress determinations must be calculated, documented, and reviewed in accordance with federal requirements. The condition resulted from reliance on manual processes, lack of retained supporting documentation, and absence of independent review and approval. The College is in the process of implementing enhanced controls over COA and SAP determinations. Formal policies and procedures will be established to define methodologies, documentation requirements, and responsibilities for preparation and review. The College will work with Information Technology and third-party consultants to enhance system configuration and develop automated processes to support calculation and retention of COA and SAP determinations within a controlled environment. In addition, the College will implement quality control measures, including a COA review committee, systematic validations and documented supervisory review, and will retain sufficient supporting documentation to allow for independent recalculation and verification of eligibility determinations. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that eligibility determinations are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.
The College acknowledges the finding and agrees that formal cash management controls are required to ensure that Title IV funds are drawn only for immediate cash needs and are properly supported and documented. The condition resulted from the absence of documented procedures and inconsistent executi...
The College acknowledges the finding and agrees that formal cash management controls are required to ensure that Title IV funds are drawn only for immediate cash needs and are properly supported and documented. The condition resulted from the absence of documented procedures and inconsistent execution of draw preparation, review, approval, and reconciliation processes. The College is in the process of implementing enhanced controls over cash management. Formal written procedures are being established to govern draw calculations, timing, approvals, supporting documentation, reconciliation requirements, and identification and return of excess cash. A standardized draw file will be maintained for each draw, including supporting student-level disbursement detail, reconciliation to eligible expenditures, and documented supervisory approval. The College will also perform and document monthly reconciliations between student disbursement records and federal cash activity. Cash balances will be monitored to ensure funds are drawn only for immediate needs and that excess cash is identified and returned, as necessary. Implementation of these procedures began in April 2026 and was not in place for the full fiscal year. Fiscal year 2026 represents a transition period during which controls are being implemented and refined. Full implementation is expected for the 2026–2027 award year. These actions are intended to ensure that draw amounts are accurate, properly supported, and compliant with federal requirements, and to prevent recurrence.
Management Response AIHEC concurs with this finding. AIHEC's procurement approval workflow is processed through its Concur system; however, it was not previously communicated to procurement and program staff that sole-source procurements also require a separately signed sole-source justification, in...
Management Response AIHEC concurs with this finding. AIHEC's procurement approval workflow is processed through its Concur system; however, it was not previously communicated to procurement and program staff that sole-source procurements also require a separately signed sole-source justification, in addition to routing approval through Concur. As a result, certain sole-source transactions were approved through the Concur workflow without the required signed justification on file. AIHEC is modifying its sole-source justification form to include the appropriate required signatures and is updating its procurement procedures to clarify that, for any procurement identified as sole-source, the signed sole-source justification form must be completed and retained in the procurement file in addition to Concur approval. AIHEC will also conduct a quarterly internal self-review of a sample of procurement files, including all sole-source transactions, to confirm compliance with this updated policy, and will retrain procurement and finance staff on documentation requirements, including suspension and debarment verification. Estimated Completion Date September 30, 2026 Responsible Party Diane Robertsy, Director of Finance
Finding 2025-010: Reporting – FFATA Subawards Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will establish sufficient procedures or oversight controls to identify first-tier subawards subject to FFATA reporting requireme...
Finding 2025-010: Reporting – FFATA Subawards Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will establish sufficient procedures or oversight controls to identify first-tier subawards subject to FFATA reporting requirements and ensure the required subaward information was submitted timely. Additionally, personnel responsible for grant administration were not sufficiently aware of the applicable FFATA reporting requirements Implementation dates: July 31, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-009: Reporting – Semi-Annual Performance Report Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will establish a formal review and approval procedure requiring independent supervisory review of SAFER performan...
Finding 2025-009: Reporting – Semi-Annual Performance Report Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will establish a formal review and approval procedure requiring independent supervisory review of SAFER performance reports prior to submission. Implementation dates: July 31, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-008: Special Tests and Provisions – Revenue Diversion Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will draft and maintain a formal written policy or documented procedure to ensure airport-generated revenue...
Finding 2025-008: Special Tests and Provisions – Revenue Diversion Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will draft and maintain a formal written policy or documented procedure to ensure airport-generated revenues are used only for allowable airport-related purposes in accordance with federal revenue-use restrictions. Implementation dates: July 31, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-007: Reporting – FAA Form 5100-127 Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will enhance its existing reconciliation and review procedures by requiring documented tie-outs of FAA Form 5100-127 amounts t...
Finding 2025-007: Reporting – FAA Form 5100-127 Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will enhance its existing reconciliation and review procedures by requiring documented tie-outs of FAA Form 5100-127 amounts to the general ledger, retention of supporting documentation for all reported amounts, and evidence of supervisory review prior to submission. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-006: Equipment and Real Property Management Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will maintain property records for equipment acquired with federal funds that include, among other elements, the sour...
Finding 2025-006: Equipment and Real Property Management Airport Improvement Program View of responsible officials: The City agrees with the finding. Corrective action plan: The City will maintain property records for equipment acquired with federal funds that include, among other elements, the source of funding and the percentage of federal participation. The fixed asset ledger will be updated to distinguish assets acquired with federal award funds from assets acquired with other funding sources. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-005: Special Test – Utility Allowance Schedule Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: The City will maintain and update utility allowance schedules based on current date and adequately demonstrate segregation of d...
Finding 2025-005: Special Test – Utility Allowance Schedule Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: The City will maintain and update utility allowance schedules based on current date and adequately demonstrate segregation of duties over preparation and approval of the schedule. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-004: Special Test – Reasonable Rent Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: The City will determine that the rent to owner is reasonable prior to approving the lease and executing the HAP contract. Implementation d...
Finding 2025-004: Special Test – Reasonable Rent Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: The City will determine that the rent to owner is reasonable prior to approving the lease and executing the HAP contract. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-003: Reporting – SEMAP Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: SEMAP certifications must be formally approved by the City’s governing board and signed by appropriate management prior to submission. Implementation d...
Finding 2025-003: Reporting – SEMAP Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: SEMAP certifications must be formally approved by the City’s governing board and signed by appropriate management prior to submission. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Finding 2025-002: Reporting – HUD 50058 Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: Management acknowledges that the filings with HUD were not timely. Staff will work to ensure filings take place within 60 days of the effective dat...
Finding 2025-002: Reporting – HUD 50058 Housing Choice Vouchers View of responsible officials: The City agrees with the finding. Corrective action plan: Management acknowledges that the filings with HUD were not timely. Staff will work to ensure filings take place within 60 days of the effective date. Implementation dates: September 30, 2026 Responsible person: Lola Ogunremi, Chief Financial Officer
Provide funder-led training sessions for management and staff, maintain current budget tracking incorporated federal program compliance into relevant staff performance evaluations, implement a dual-storage documentation methodology combining a shared drive and a document management system (DMS) and ...
Provide funder-led training sessions for management and staff, maintain current budget tracking incorporated federal program compliance into relevant staff performance evaluations, implement a dual-storage documentation methodology combining a shared drive and a document management system (DMS) and update the Finance Manual.
Provide all management staff with annual training on federal grant requirements, perform periodic internal reviews and a final year-end reconciliation, maintainall grant-related records on a shared organizational drive accessible to all responsible staff, provide formal onboarding and off boarding p...
Provide all management staff with annual training on federal grant requirements, perform periodic internal reviews and a final year-end reconciliation, maintainall grant-related records on a shared organizational drive accessible to all responsible staff, provide formal onboarding and off boarding procedures for federal grant management, and update the Finance Manual .
Lynsey Darragh – Administrative Services Director and Lucas Mayo – Grant Administrator will develop procedures to obtain and review certified payrolls for construction projects to ensure compliance with the wage rate requirements. Anticipated completion date is July 31, 2026.
Lynsey Darragh – Administrative Services Director and Lucas Mayo – Grant Administrator will develop procedures to obtain and review certified payrolls for construction projects to ensure compliance with the wage rate requirements. Anticipated completion date is July 31, 2026.
Lynsey Darragh - Administrative Services Director, Lucas Mayo – Grant Administrator and Tony Pumphrey – Finance Director will develop procedures to ensure that all program reports have documented reviews; are submitted timely and that are reconciled to the accounting records before submission. Antic...
Lynsey Darragh - Administrative Services Director, Lucas Mayo – Grant Administrator and Tony Pumphrey – Finance Director will develop procedures to ensure that all program reports have documented reviews; are submitted timely and that are reconciled to the accounting records before submission. Anticipated completion date is July 31, 2026.
Finding 2025-003: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: November 20, 2025 Recommendation: It was recommended the related parties reimburse Cheney Care Commun...
Finding 2025-003: Section 232 Loan – Mortgage Insurance Nursing Homes, Intermediate Care Facilities, Board and Care Homes and Assisted Living Facilities Loan, ALN 14.129 Anticipated Completion Date: November 20, 2025 Recommendation: It was recommended the related parties reimburse Cheney Care Community for the expenditures paid on their behalf. In addition, it was recommended management review the disbursements made during the periods of turnover to confirm there were no other unallowable payments made. It was also recommended management of Cheney Care Community review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the controls are consistently performed going forward. Action Taken: The related parties reimbursed Cheney Care Community for the expenditures paid on their behalf. Since the new accounts payable clerk started in the Summer of 2025, they have been reviewing all of the supporting documentation for disbursements made during the period of turnover, and accumulating any additional corrections that need to be made. They will continue this process for all disbursements from the period of turnover. The Executive Director/Administrator and Accountant will review the process and procedures in place with the new accounts payable clerk, and implement controls to ensure the appropriate facility and general ledger account coding are made going forward. In addition, they will review the review and monitoring controls in place and revise as needed to ensure the proper checks are in place to catch errors.
Finding 2025-004: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 Anticipated Completion Date: June 11, 2026 Recommendation: It was recommended the related parties reimburse Sessions Village 202 for the expenditures paid on their beh...
Finding 2025-004: Section 202 Supportive Housing for the Elderly, Capital Advance and Project Rental Assistance Contract, ALN 14.157 Anticipated Completion Date: June 11, 2026 Recommendation: It was recommended the related parties reimburse Sessions Village 202 for the expenditures paid on their behalf. In addition, it was recommended management review the disbursements made during the periods of turnover to confirm there were no other unallowable payments made. It was also recommended management of Sessions Village 202 review their internal controls over the cash disbursement process with the necessary individuals involved in the process to ensure the controls are consistently performed going forward. Action Taken: The related parties reimbursed Sessions Village 202 for the expenditures paid on their behalf. Since the new accounts payable clerk started in the Summer of 2025, they have been reviewing all of the supporting documentation for disbursements made during the period of turnover, and accumulating any additional corrections that need to be made. They will continue this process for all disbursements from the period of turnover. The Executive Director/Administrator and Accountant at the management agent will review the process and procedures in place with the new accounts payable clerk, and implement controls to ensure the appropriate facility and general ledger account coding are made going forward. In addition, they will review the review and monitoring controls in place and revise as needed to ensure the proper checks are in place to catch errors.
Finding 2025-003 Congressionally Mandated Projects / Suspension and Debarment Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed...
Finding 2025-003 Congressionally Mandated Projects / Suspension and Debarment Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
Finding 2025-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part ...
Finding 2025-002 Congressionally Mandated Projects / Davis-Bacon Act Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
Finding 2025-001 Congressionally Mandated Projects / Reporting Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the...
Finding 2025-001 Congressionally Mandated Projects / Reporting Anticipated Completion Date: June 30, 2026 Views of Responsible Officials and Corrective Action: Management accepts the recommendation. Management is in the process of developing a template checklist that will be completed as part of the RFP and contract process. Any project that meets additional standards requirements, the checklist will be required and will be maintained for the duration of the project with monthly review at the Executive level to ensure compliance is being met. Responsible Official: Andrew Ferris Chief Financial Officer Kansas City Board of Public Utilities
Management will strengthen controls over federal reporting by establishing documented procedures for the preparation, review, certification, and submission of all required federal reports. Responsibility for report preparation and certification will be formally assigned, with designated backup personn...
Management will strengthen controls over federal reporting by establishing documented procedures for the preparation, review, certification, and submission of all required federal reports. Responsibility for report preparation and certification will be formally assigned, with designated backup personnel identified to ensure continuity during staffing transitions. A reporting calendar and tracking system will be maintained to monitor filing deadlines, and all reports will be subject to documented review and approval by an authorized individual prior to submission. Management will periodically review compliance with reporting requirements to ensure reports are submitted accurately and timely.
Please accept this correspondence as the Alfred Saliba Family Services Center, Inc. 's formal corrective action response to Finding 2025-001: Reporting, related to the review and documentation process for Federal Financial Reports, including SF-425 reports. During the prior audit cycle, management b...
Please accept this correspondence as the Alfred Saliba Family Services Center, Inc. 's formal corrective action response to Finding 2025-001: Reporting, related to the review and documentation process for Federal Financial Reports, including SF-425 reports. During the prior audit cycle, management became aware of deficiencies related to the review and documentation process for Federal Financial Reports. While the 2024 audit was occurring and these deficiencies were being identified, the previous Grants Manager was relieved from her position. Following that personnel change, the Alfred Saliba Family Services Center undertook a reorganization of fiscal management responsibilities to strengthen oversight, accountability, and internal controls. As part of this corrective action, the organization reviewed, rewrote, and codified its Fiscal Policies and Procedures, which were formally adopted by the Board of Directors. These revised policies clarified reporting responsibilities, strengthened the review and approval process, and established clearer expectations for documentation, supervisory review, and retention of records related to grant reporting. The revised fiscal policies also include a new Federal Financial Report (SF-425) Review & Approval Form, located in Appendix X of Standard 2 - Fiscal Policies and Procedures, to ensure consistent documentation of management review prior to submission. Since the personnel and fiscal management changes were implemented, SF-425 reports have been prepared and provided to the Executive Director in a timely manner prior to submission. The Executive Director reviews the reports, verifies the information as appropriate, and signs the reports to document management review and approval. This process provides clear evidence that financial reports are revi_ewed before submission and that appropriate oversight is occurring. The Alfred Saliba Family Services Center believes these corrective actions have addressed the condition noted in the finding. The organization will continue to monitor this process as part of its ongoing fiscal management framework to ensure sustained compliance, timely reporting, and proper documentation of management review. Anticipated Completion: Immediately Responsible Party: Jim Hartnett, Executive Director
Finding Number: 2025-004 Condition: During the audit it was identified the Road Commission did not have formal written federal policies and procedures that document the processes and controls used to administer federal awards, including procedures for compliance \with applicable federal program requ...
Finding Number: 2025-004 Condition: During the audit it was identified the Road Commission did not have formal written federal policies and procedures that document the processes and controls used to administer federal awards, including procedures for compliance \with applicable federal program requirements under Uniform Guidance (2 CFR, Part 200.303) Planned Corrective Action: Road Commission is in the process of developing and implementing a written federal policies and procedure addressing the administration of federal awards to ensure compliance with Uniform Guidance (2 CFR, Part 200). The policy will address the following key compliance areas: allowable costs, cash management, procurement, and conflict of interest. The policy shall be reviewed and modified to included all the necessary items outlined in the Uniform Guidance. Contact Person responsible for corrective action: Destain Gingell, Managing Director / CHE, Kathleen Cunningham, Finance Director Anticipated Completion Date: July 30, 2026
Person(s) responsible for corrective action: Justin Parker, Executive Director, Lucy Yanez, Contract Specialist, and Kari Neumeyer, Communications Manager Management’s Response/Corrective Action Plan: The NWIFC has revised its procedure to ensure timely submission of the annual report: • The Communi...
Person(s) responsible for corrective action: Justin Parker, Executive Director, Lucy Yanez, Contract Specialist, and Kari Neumeyer, Communications Manager Management’s Response/Corrective Action Plan: The NWIFC has revised its procedure to ensure timely submission of the annual report: • The Communications Manager completes the annual report before the reporting period deadline. • The Executive Director will review and approve the annual report before the deadline and communicate approval of the annual report to both the Contract Specialist and Communications Manager. • The Contract Specialist will send the annual report to the BIA by the deadline and retain approval forms or records. Anticipated completion date: June 2026.
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