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Finding #2024-030 - Title I Grants to Local Education Agencies, CFDA 84.010 Matching, Level of Effort, and Earmarking - Significant Deficiency in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensur...
Finding #2024-030 - Title I Grants to Local Education Agencies, CFDA 84.010 Matching, Level of Effort, and Earmarking - Significant Deficiency in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure maintenance of effort monitoring is reviewed by a party other than the preparer for accuracy and appropriate review of compliance. NDE Response NDE agrees with this finding. In alignment with efforts under finding 2023-034 regarding maintenance of effort, the Department has developed a comprehensive Policy and Procedure (1.9 Title I ESEA MOE) documenting the process for the development, review, and finalization of the MOE report, as well a Business Rule which clearly crosswalks source data to reporting outcomes and integrates pillars from NDE’s Records Management Program. Corrective Action A checklist detailing the chain of review has been developed and implemented to track the review and approval process of federal reports prior to submission. NDE shall update and implement MOE internal controls and monitoring to require a review by at least 2 individuals. The Office of Division Compliance will collaborate across the Department to ensure adoption and adherence to this update. Responsible Parties and Anticipated Completion Date Student Investment Division, Office of Division Compliance; November 1, 2026. Please reach out to Jenni Hood at sidcompliance@doe.nv.gov with any questions.
Finding #2024-031 - U.S. Department of Education Special Education (IDEA) Cluster; Special Education Grants to States, 84.027; Special Education Preschool Grants, 84.173; Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking - Material Weakness in Internal Control over Compl...
Finding #2024-031 - U.S. Department of Education Special Education (IDEA) Cluster; Special Education Grants to States, 84.027; Special Education Preschool Grants, 84.173; Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking - Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure the amounts used in monitoring the LEA maintenance of effort is accurate and that documentation sounding in the eligibility standard be maintained in accordance with 34 CFR section 300.230(a). NDE Response NDE agrees with this finding. In alignment with efforts under finding 2024-030, the Department has worked to develop policies and procedures, business rules, and consistent data and reporting practices across reports. Corrective Action NDE shall strengthen internal controls over the Special Education Maintenance of Effort (MOE) review process to guarantee accuracy. Specifically, NDE will update the MOE review process from the compliance standard to the eligibility standard; written procedures will be updated accordingly. Additionally, NDE will establish and implement a required secondary review step within the internal control framework. Responsible Parties and Anticipated Completion Date Student Investment Division, Office of Division Compliance; November 1, 2026. Please reach out to Jenni Hood at sidcompliance@doe.nv.gov with any questions.
Management has enhanced controls over FEMA grant compliance by strengthening the formal review process to verify that costs claimed are eligible, adequately supported, and consistent with FEMA program requirements prior to submission, including the removal of any duplicates.
Management has enhanced controls over FEMA grant compliance by strengthening the formal review process to verify that costs claimed are eligible, adequately supported, and consistent with FEMA program requirements prior to submission, including the removal of any duplicates.
Management has strengthened controls over SEFA preparation by implementing procedures to identify federal awards with unique reporting requirements, including FEMA grants. A formal review process and year-end reconciliation of federal expenditures to the SEFA will be performed to ensure expenditures...
Management has strengthened controls over SEFA preparation by implementing procedures to identify federal awards with unique reporting requirements, including FEMA grants. A formal review process and year-end reconciliation of federal expenditures to the SEFA will be performed to ensure expenditures are reported completely and accurately in accordance with Uniform Guidance requirements.
The grant accounting and SEFA preparation process will be refined, improved and documented. Internal resources will be reallocated to ensure sufficient coverage of these processes, and the primary accountability and oversight will shift to System Accounting. Management will ensure that in preparatio...
The grant accounting and SEFA preparation process will be refined, improved and documented. Internal resources will be reallocated to ensure sufficient coverage of these processes, and the primary accountability and oversight will shift to System Accounting. Management will ensure that in preparation of the SEFA, (1) a team member will assemble the initial reconciliation, (2) management will review the initial reconciliation and review the consolidation from all BayCare entities to the combined SEFA, (3) A final review will be conducted by the Director of Accounting. Sign-off from each preparer/reviewer shall be required. Meetings will be conducted as needed with departments outside of Hospital Finance to ensure completeness and accuracy of data.
Condition 1: ELC Program Leads complete and submit Work Plan Progress Reports through the ELC CAMP as required by the grant. To monitor compliance, ELC will notify the Ministry of Finance of submitted reports and provide MOF with view-only access to relevant files and supporting documentation as nee...
Condition 1: ELC Program Leads complete and submit Work Plan Progress Reports through the ELC CAMP as required by the grant. To monitor compliance, ELC will notify the Ministry of Finance of submitted reports and provide MOF with view-only access to relevant files and supporting documentation as needed. Condition 2: The ELC Program Leads completes the required financial reports in ELC CAMP using information provided by the MOF Fiscal Officer and submits the reports through ELC CAMP and GrantSolutions. ELC will notify MOF of each submission to support compliance monitoring. To strengthen the process, MOF and MOHHS will establish a formal reporting process. MOHHS will maintain a tracking tool with required reports, reporting periods, due dates, and submission status, and share it with MOF. MOF will have access to ELC CAMP and the MOHHS GrantSolutions account to retrieve reports as needed.
Condition 1: The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. Al...
Condition 1: The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. All other provisions of the Procurement Code remain in force and continue to govern procurement activities. Furthermore, an amended Procurement Code was endorsed by Cabinet in March 2026 and will be introduced to Parliament during the August session. Upon its adoption, the corresponding Regulation will be formally issued. Condition 2, #1: Except for items #1, #5, #6, #7, #8 & #9, the Ministry of Finance agrees with the finding and will ensure that vendor selection and the justification for the selected vendor are clearly documented in BRVs and TMV to demonstrate compliance with procurement requirements. Condition 2, #2: The Ministry agrees with the finding. Competitive bidding should be undertaken when a multi-year contract expires. Condition 3: At the start of a new fiscal year, the MOF Compliance team will perform an annual screening of all Funder/Client (Supplier) in Bisan against the SAM.gov list of debarred/suspended entities.
The Ministry disagrees with the findings. The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date (last day for obligations) and Closing Date (last day to liquidate enc...
The Ministry disagrees with the findings. The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date (last day for obligations) and Closing Date (last day to liquidate encumbrances) in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements.
Conditions 1-5 Repeat Finding, same response for Finding Nos. 2024-007, 2024-012, and 2024-019
Conditions 1-5 Repeat Finding, same response for Finding Nos. 2024-007, 2024-012, and 2024-019
The fiscal officers of the MOF Budget Division have strengthened their review of expenditures prior to disbursements and started to conduct weekly evaluation and monitoring of draw downs.
The fiscal officers of the MOF Budget Division have strengthened their review of expenditures prior to disbursements and started to conduct weekly evaluation and monitoring of draw downs.
Condition 1 All pay slips claiming OT will include supporting OT approval including justification that are allocable to grants. Condition 2 Item 1. Utilities are paid out of the de minimis rate of 10% for Federal grants. $43,800 for utilities is included in the budget breakdown of the grant. Items #...
Condition 1 All pay slips claiming OT will include supporting OT approval including justification that are allocable to grants. Condition 2 Item 1. Utilities are paid out of the de minimis rate of 10% for Federal grants. $43,800 for utilities is included in the budget breakdown of the grant. Items #1 to#27. Except for items #1, #7 to #27, the Ministry of Finance agrees with the finding and will ensure that all invoices or billings are attached to support payment accuracy and demonstrate compliance with procurement requirements.
Condition 1. The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. Al...
Condition 1. The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. All other provisions of the Procurement Code remained in force and continue to govern procurement activities. Furthermore, an amended Procurement Code was endorsed by Cabinet in March 2026 and will be introduced to Parliament during the August session. Upon its adoption, the corresponding Regulation will be formally issued. Condition 2. Except for items #1 & #8, the Ministry of Finance agrees with the finding and will ensure that vendor selection and the justification for the selected vendor are clearly documented in all TMVs and BRVs to demonstrate compliance with procurement requirements. Condition 3. Same response as Finding No.: 2024-014 - Condition 3
The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with fundi...
The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements. The Ministry acknowledges, however, that the process still requires human input and oversight. As a result, there remains a risk that expenditures may be processed or incurred outside the approved funding period due to human error. The Ministry will reinforce and continue to strengthen its review and monitoring procedures to minimize this risk and ensure expenditures are charged to the appropriate funding period.
PSS response: Management concurs with the finding. At the time of the FY2024 audit, the Public School System (PSS) calculated the Maintenance of State Financial Support (MFS) using the gross salaries of locally funded Special Education administrative staff and teachers. While management believes tha...
PSS response: Management concurs with the finding. At the time of the FY2024 audit, the Public School System (PSS) calculated the Maintenance of State Financial Support (MFS) using the gross salaries of locally funded Special Education administrative staff and teachers. While management believes that only allowable State-funded salary expenditures were included in the calculation, the supporting documentation and reconciliation to the underlying accounting records were not maintained in sufficient detail to fully support the reported MFS amount. The Ministry of Finance has implemented a Special Purpose Grant (SPG) code to improve the identification and reporting of all expenditures. Management will also develop and implement written procedures defining the responsibilities for preparing, reviewing, and approving the annual MFS calculation. These procedures will require the retention of supporting payroll reports, reconciliation to the accounting records, and documentation identifying the employees included in the calculation, their funding sources, and any personnel changes that occurred during the fiscal year. Beginning in FY2027, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that the MFS calculation is adequately supported, reconciled to the accounting records, and prepared in accordance with IDEA requirements before submission. Any deficiencies identified during these reviews will be communicated promptly to management for corrective action. Management expects these corrective actions to be fully implemented by the end of FY2027.
Conditions 1-5 Repeat Finding - same response for Finding No. 2027-007, 2024-012, and 2024-025
Conditions 1-5 Repeat Finding - same response for Finding No. 2027-007, 2024-012, and 2024-025
Condition 1-1. Due to structural damages to the Payroll office, files were transferred from there to the warehouse for storage. After numerous attempts to recover the files, the payroll staff were not able to do so within the given time period. Effective October 2025, the Payroll team has been attac...
Condition 1-1. Due to structural damages to the Payroll office, files were transferred from there to the warehouse for storage. After numerous attempts to recover the files, the payroll staff were not able to do so within the given time period. Effective October 2025, the Payroll team has been attaching new employee contracts to the payslips in Bisan. PSC's HRMIS already stored the scanned PAFs of employees. The PSS has now acquired the Orange Human Resource Management System, which will also make contracts available electronically. Condition 1-2. PSS Response: PSS Management acknowledges the finding. While leave requests were generally submitted and recorded, we recognize that approved leave forms were not consistently maintained to support all leave hours charged during the audit period. To address this finding, beginning in FY2027, PSS will implement the Orange Human Resource Management System, which will transition the leave request process from a paper-based system to an electronic system. This will create a complete electronic audit trail for all leave requests submitted by PSS employees on islands with internet access. As internet connectivity continues to expand through solar power and Starlink installations, additional schools and offices will transition to the electronic system, with full implementation across all PSS locations targeted by the end of FY2028. In addition, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that leave requests are properly approved, documented, and retained in accordance with PSS policies and applicable grant requirements. Any deficiencies identified during these reviews will be communicated promptly to management so that corrective action can be taken. MOF response: Additionally, effective FY2025, the Ministry of Finance requires all ministries to submit leave forms for all annual and sick leave taken, regardless of the number of hours & days. The Ministry of Finance issued a clarifying memorandum on July 29, 2025. Condition 2. These costs were incurred to cover the retirees' annual leave lump-sum payments. If not in the approved budget narrative, MOF & PSS will ensure prior approval from the grantor is obtained and sufficient supporting calculations are provided before charging excess costs to the grant to ensure allowability and compliance with grant requirements.
Condition 1 Public School System management concurs with the finding. While annual performance evaluations were completed for many grant-funded employees, PSS did not consistently maintain sufficient documentation to demonstrate that all required evaluations had been completed in accordance with the...
Condition 1 Public School System management concurs with the finding. While annual performance evaluations were completed for many grant-funded employees, PSS did not consistently maintain sufficient documentation to demonstrate that all required evaluations had been completed in accordance with the grant requirements. Beginning in FY2027, PSS has implemented the Orange HR Management System, which provides an electronic process for completing, approving, and storing employee performance evaluations. This system creates a centralized electronic record and audit trail, making it easier to monitor compliance and retrieve documentation for audit purposes. In addition, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that all required evaluations are completed and properly documented before the close of each fiscal year. Condition 2 FY2024 Appropriation was a continuation of FY2023 and did not reflect the new Compact yet since negotiations were still ongoing at the time. The $2.5million matching was clarified with the US DOI team in March 2026, to be appropriated in FY2027. The MOF has not drawn down against this grant.
Condition 1. On July 31, the newly developed pre-award risk assessment tool was rolled out to all subrecipients and ministries with oversight, effective FY2027. Conditions 2-3: On July 29, July 31 and August 5, 2026, training was conducted on Majuro and Ebeye to introduce new and enhanced tools to s...
Condition 1. On July 31, the newly developed pre-award risk assessment tool was rolled out to all subrecipients and ministries with oversight, effective FY2027. Conditions 2-3: On July 29, July 31 and August 5, 2026, training was conducted on Majuro and Ebeye to introduce new and enhanced tools to strengthen subrecipient monitoring. It covered the following topics: 1. Audit findings related to subrecipient arrangements. 2. Grants Management Manual with emphasis on its scope and the Management Decision Letter (MDL). 3. Unique Entity Identifier (UEI), which is mandatory. 4. Memorandum of Agreement and the significance of each section. 5. MOA circulation process. 6. Procurement Code 2023 7. Reporting and Required Supporting Documents: - Pre-award Risk Assessment - Site Visit Checklist - Enhanced SubGrant Forms and Review Checklist (SG1/Subgrant Objectives and Budget Proposal and SG2/Performance and Financial Evaluation) - SG Forms supporting documentation (salaries & wages, fuel purchase, food purchase, vehicle rental, housing allowance, travel, etc.) 8. Conflict of Interest In September 2026, officers from the Compliance and SOE Monitoring Unit will start going out to conduct the pre-award risk assessment. Results of the assessment will determine whether the entity can sign an MOA with the MOF or not as well as the entity's risk rating, which will determine the frequency of site visits to be conducted by Compliance beginning FY2027. Condition 4 Effective 3rd quarter of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment process.
Condition 1. Item 1. A financial reporting tool was recently established to support the timely preparation and submission of reports. Additionally, the Ministry recruited a Senior Financial Analyst in February to oversee the monitoring, preparation, and timely submission of financial reports. Condit...
Condition 1. Item 1. A financial reporting tool was recently established to support the timely preparation and submission of reports. Additionally, the Ministry recruited a Senior Financial Analyst in February to oversee the monitoring, preparation, and timely submission of financial reports. Condition 2-1. Items 1-2 Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management. Condition 2-2. Items 1-21 A financial reporting tool was recently established to support the timely preparation and submission of reports. Additionally, the Ministry recruited a Senior Financial Analyst in February to oversee the monitoring, preparation, and timely submission of financial reports. Condition 2-3. Items 1-2 Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management. However, the Ministry disagrees with the finding on the SF-425 not containing the SPG code since the latter is not a required US field. SPG code is internal to the MOF. Grant number D22AP00180 is also established in the FMIS as part of the setup of SPG 10450101.
Condition 1. The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. Al...
Condition 1. The Ministry disagrees with this finding. The revised procurement threshold of $25,000 to $50,000 became effective upon adoption of the Procurement Code of 2023 on October 1, 2023, as provided under Section 119(c) Small Purchases. A Regulation is not necessary to support this change. All other provisions of the Procurement Code remained in force and continue to govern procurement activities. Furthermore, an amended Procurement Code was endorsed by Cabinet in March 2026 and will be introduced to Parliament during the August session. Upon its adoption, the corresponding Regulation will be formally issued. Condition 2-1. Items 1-2,7 The Ministry disagrees with the findings. All three purchase orders were supported by the required documentation at the time of review and prior to the issuance of the purchase orders. Items 3-6 The Ministry intends to revisit the existing travel policy and update accordingly. Item 8 The vendor was directly selected as the authorized distributor & service provider for medical equipment & supplies in the Marshall Islands. Going forward, the Ministry will ensure a signed justification letter from the Head of Department is attached to support sole-source procurements. Item 9 The Ministry will return requisitions with insufficient supporting documentation and will conduct a procurement training in October 2026 to reinforce procurement requirements. Condition 2-2 Item 1 The Ministry now requires a Request for Quotation (RFQ) form to be submitted as evidence of compliance with competitive procurement requirements. Items 2-3 The Ministry disagrees with the findings. Supporting documentations can be found on PR 23/00023360 (#2) & PR 23/00001990 (#3) Item 4 Effective in FY2025, the Enewetak/Ujelang Local Government operations were transferred to the Ministry of Finance. As a result, all procurement activities are now processed through the Ministry and are required to comply with the applicable procurement code, established regulations, and the Ministry's internal procurement policies and procedures, thereby strengthening oversight and ensuring compliance. Condition 2-3 1-7 The Ministry now requires a Request for Quotation (RFQ) form to be submitted as evidence of compliance with competitive procurement requirements 8 The Ministry of Finance will require that the PSS Hot Lunch Vendor selection Report (endorsed by the Bid Committee) be submitted with the initial payment to the Hot Lunch Vendors. 9 Once the DLS contract expires, it will be advertised for competitive bidding. Condition 3 At the start of a new fiscal year, the MOF Compliance team will perform an annual screening of all Funder/Client (Supplier) in Bisan against the SAM.gov list of debarred/suspended entities.
The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with fundi...
The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements. The Ministry acknowledges, however, that the process still requires human input and oversight. As a result, there remains a risk that expenditures may be processed or incurred outside the approved funding period due to human error. The Ministry will reinforce and continue to strengthen its review and monitoring procedures to minimize this risk and ensure expenditures are charged to the appropriate funding period.
The MOF recruited a dedicated asset management officer and began a government-wide asset inventory in April 2026. Upon completion, the FMIS asset module will be fully implemented in FY2027 to improve the classification, recording, reporting, and monitoring of capital assets. The MOF also continues t...
The MOF recruited a dedicated asset management officer and began a government-wide asset inventory in April 2026. Upon completion, the FMIS asset module will be fully implemented in FY2027 to improve the classification, recording, reporting, and monitoring of capital assets. The MOF also continues to coordinate with Ministries and Agencies to update and reconcile asset records. Repeated finding: same response on Finding Nos. 2024-007, 2024-019, and 2024-25
Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management.
Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management.
Condition 1: Effective FY2025, all ministries submit leave forms for all annual and sick leave taken, regardless of the number of days. The Ministry of Finance issued a clarifying memorandum on July 29, 2025. Condition 2: Item 1. MOF to set a policy providing a repatriation allowance of $500 to expa...
Condition 1: Effective FY2025, all ministries submit leave forms for all annual and sick leave taken, regardless of the number of days. The Ministry of Finance issued a clarifying memorandum on July 29, 2025. Condition 2: Item 1. MOF to set a policy providing a repatriation allowance of $500 to expatriates who have completed their employment contracts and exiting for good, and receipt is not required. Item 2-4. During the second year of FMIS implementation, limited staffing and scanning equipment prevented the timely upload of supporting documents. The Ministry has since improved its staffing and equipment, and in FY2025 all supporting documentation is uploaded to FMIS before payment processing. Item 5. The Ministry disagrees with the finding. The per diem and transportation expenses are accounted for in the liquidation supporting documents. The Government accepts acknowledgment receipts as supporting documentation for transportation services provided in neighboring islands due to the vendors' limited resources and inability to issue invoices or printed receipts. Item 6. The Laura Elementary School PDP & Detailed Design contract was an old/completed project originally funded under expired grant D21AF102130 and was subsequently regranted under FY2024 grant D24AF00024 along with three other projects. The payment was supported by a PMU letter identifying the contractor's total outstanding unpaid invoices. Condition 3. Effective 3rd quarter of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment process.
Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing...
Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing these procedures. Felecia Read will be responsible for making sure these are completed and documented.
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