Corrective Action Plans

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Recommendation: CLA recommends that the University implement a more effective suspension and debarment policy and establish corresponding controls to ensure vendor eligibility is verified prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagre...
Recommendation: CLA recommends that the University implement a more effective suspension and debarment policy and establish corresponding controls to ensure vendor eligibility is verified prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University concurs with the auditors’ findings and has already updated its purchasing policies, which have been submitted for final approval through the appropriate University governance channels. In addition, Purchasing is currently implementing a new module within its e-procurement system, JAGGAER, to include the Supplier Management module. This module incorporates the Visual Compliance/Descartes screening solution that provides continuous and ongoing compliance monitoring of vendors. Name(s) of the contact person(s) responsible for corrective action: Robert Akhnoukh Planned completion date for corrective action plan: June 2026 If the US Department of Health and Human Services has questions regarding this plan, please call Robert Akhnoukh at (208) 885-6116.
Finding 1177825 (2025-001)
Material Weakness 2025
Condition: Management did not have controls in place to ensure documentation was maintained evidencing the organization's verification that contractors are not suspended or debarred from participating in a federally funded activity. Planned Corrective Action: Management concurs with the finding. We ...
Condition: Management did not have controls in place to ensure documentation was maintained evidencing the organization's verification that contractors are not suspended or debarred from participating in a federally funded activity. Planned Corrective Action: Management concurs with the finding. We acknowledge that, for the awards issued under the Inflation Reduction Act Urban and Community Forestry Program (Assistance Listing Number 10.727), the required suspension and debarment verification was performed; however, the supporting documentation evidencing this verification was not retained by the responsible department. This represents a documentation lapse rather than a deficiency in internal controls as Openlands routinely performs suspension and debarment verifications for all applicable vendors, contractors, and subrecipients receiving federal funds in accordance with 2 CFR 200.214. This requirement applies to entities and individuals awarded federally funded contracts or subawards exceeding the micro-purchase threshold and excludes routine commercial vendors for indirect administrative costs or purchases under $15,000. Management believes this was an isolated documentation lapse prior to the current audit period when the contractor was selected, and is currently in the processes of executing an update to internal control policies to ensure these checks are maintained prior to entering into a contract by the responsible department as well as updating a clause to all standard vendor contracts requiring a self-certification that they are not excluded, debarred, or suspended from entering into covered transactions with the federal government. Contact person responsible for corrective action: Paul Spector (Director of Finance) Anticipated Completion Date: January 31, 2026
Current Year Finding Number: 2025-003 Federal Program, Assistance Listing Number and Name: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture 10.553, 10.555, and 10.582 Condition: Based on our sample selection of three vendors for testing, we have identified that two of the three...
Current Year Finding Number: 2025-003 Federal Program, Assistance Listing Number and Name: Child Nutrition Cluster Federal Agency: U.S. Department of Agriculture 10.553, 10.555, and 10.582 Condition: Based on our sample selection of three vendors for testing, we have identified that two of the three vendors tested did not have adequate verification of suspension and debarment. Upon further testing and discussion, the District does not have internal controls in place to verify suspension and debarment on vendors that are paid greater than or equal to $25,000, as required by 2 CFR 200 for various federal awards. Upon further compliance testing, vendors in our testing were in compliance with the requirement. Without internal controls over compliance, the District may not be able to identify noncompliance with a suspended or debarred vendors in a timely manner and may incur potential questioned costs without knowledge of the noncompliance. Planned Corrective Action: The School District has implemented an internal process to issue verification of suspension and debarment for vendors of federal awards that are paid equal to or greater that $25,000 as of 02/27/2026. Contact person responsible for corrective action: Roger Stinar, Director of Finance Anticipated Completion Date: 06/30/2026
Condition: One (1) of the monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. The November 2024 claim amounts were consistent with participation levels and reimbursement amounts in other months tested. No anomalies or fluctuations were ident...
Condition: One (1) of the monthly claims for reimbursement reported meal counts in excess of those supported by records of the District. The November 2024 claim amounts were consistent with participation levels and reimbursement amounts in other months tested. No anomalies or fluctuations were identified through analytical procedures; however, required supporting documentation was not maintained. Corrective Action Plan: Management will review its policies and procedures and implement changes to strengthen internal control over compliance. Responsible Person: Dr. Cynthia Levy, Superintendent. Anticipated Completion Date: June 30, 2026
Finding 2025-002 – Education Stabilization – Special Tests and Provisions - Wage Rate Requirements Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace fan coil units and HVAC equipment in the building. Therefor...
Finding 2025-002 – Education Stabilization – Special Tests and Provisions - Wage Rate Requirements Context: The School Corporation did not obtain the weekly payroll reports certifications from a company that performed renovations to replace fan coil units and HVAC equipment in the building. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The amount disbursed and reported on the SEFA during the audit period is $119,190 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Kimberly Nieves Contact Phone Number: 219-766-2214 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: As an internal control, the Director of Business Affairs and Human Resources has reviewed the Davis-Bacon Act. We will collect weekly payroll documentation for any constructions projects where Federal Grant money is used. Anticipated Completion Date: February 2024
FINDING 2025-001 Finding Subject: Summary of Finding: Earmarking for Non-Public proportionate share was improperly calculated based on budgeted percentage. Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number and Email Address: (219) 850-1914 - qvanrys@pces.k12.in....
FINDING 2025-001 Finding Subject: Summary of Finding: Earmarking for Non-Public proportionate share was improperly calculated based on budgeted percentage. Contact Person Responsible for Corrective Action: Quinnlyn Van Rys Contact Phone Number and Email Address: (219) 850-1914 - qvanrys@pces.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Provider/Employee will submit payroll records/invoices by student services monthly/bi-monthly to the bookkeeper. Once payroll records or invoices are received, the CFO will prepare a spreadsheet that calculates the time/amounts serviced by the non-public school and member school. Once the total hours are calculated, a percentage based on total hours worked for each member school will be used to allocate the provider/employee time for each member school. This documentation will be attached to each reimbursement request. Anticipated Completion Date: This finding was corrected in January, 2024.
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement Suspension and Debarment Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: “We concur with the finding.” De...
FINDING 2025-001 Finding Subject: Child Nutrition Cluster - Procurement Suspension and Debarment Contact Person Responsible for Corrective Action: Carrie Alford Contact Phone Number and Email Address: 812-254-5536 calford@wcs.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: To address this repeat finding, the Business Manager will now review all federal purchase requests before any funds are committed. We will ensure the correct procurement method is used by requiring and filing at least three competitive quotes for any small purchase between $10,000 and $150,000. For any transaction $25,000 or greater, the Business Manager will verify the vendor’s eligibility on SAM.gov and keep a date-stamped screenshot in the file as proof of the search. This centralized oversight and mandatory documentation process will ensure we maintain a proper history of procurement and prevent further noncompliance. Anticipated Completion Date: 02/01/2026
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative oper...
FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Summary of Finding: The School Corporation is a member of the Northeast Indiana Special Education Cooperative (Cooperative). During fiscal years 2022-2023 and 2023-2024, the Cooperative operated the special education program and spent the federal money on behalf of all its members. As the grant agreement was between the Indiana Department of Education (IDOE) and each member school, the School Corporation was responsible for ensuring and providing oversight of the Cooperative. The School Corporation did not have internal controls in place to ensure that the Cooperative complied with the procurement and the suspension and debarment requirements. The Cooperative did not have adequate procedures in place to ensure that the requirements for the simplified acquisition threshold and for small purchases were met for each applicable procured good or service or to ensure that vendors were not suspended or debarred prior to entering a covered transaction. Contact Person Responsible for Corrective Action: Susan Loftain Contact Phone Number and Email Address: (260) 693-2007 loftains@sgcs.k12.in.us Views of Responsible Officials: Option 1: “We concur with the finding.” Description of Corrective Action Plan: Procurement: All vendors procured through NEISEC we will need to take action to secure bids and quotes and keep copies and make we are within compliance Suspension and Debarment: We will be sure to complete our own verifications and not rely on NEISEC to check on suspension and debarment Anticipated Completion Date: Immediately
Department will strengthen controls to ensure that the required award information is provided, once available. Certain information such as Federal Award Identification Number and Federal Transit Administration and National Highway Traffic Safety Administration award date are not available at the tim...
Department will strengthen controls to ensure that the required award information is provided, once available. Certain information such as Federal Award Identification Number and Federal Transit Administration and National Highway Traffic Safety Administration award date are not available at the time of contracting CDOT is working on a process to provide this information, once it is available in a publicly available format on CDOT’s website or on a subrecipient facing grant management site. We will add a note to the contract explaining where the information will be posted on our site when it becomes available. The Department will also identify staff requiring additional training on classification and coding for contractors vs. subrecipients.
The Department agrees with the recommendation. The Department will review, assess, and, where necessary, update existing procedures for FFATA reporting relating to the requirement that state subawards for $30,000+ be submitted within 30 days of committed budget. This will include ensuring that the c...
The Department agrees with the recommendation. The Department will review, assess, and, where necessary, update existing procedures for FFATA reporting relating to the requirement that state subawards for $30,000+ be submitted within 30 days of committed budget. This will include ensuring that the confirmation date is documented. This process will be a coordinated effort between the Office Transportation Safety (OTS) and the Center for Accounting. This will include updating our reconciliation process to include additional data, reviewing and updating reconciliation and review procedures as needed, and reconciling Grants awarded in prior fiscal years that are still active and ensuring they have been appropriately reported. The findings related to this recommendation are in part the result of a federal reporting system limitation, and a federal system conversion. The legacy reporting system, FSRS, had a system limitation, which prevented the full amount of the award being reported in the case of three awards. Additionally, this conversion resulted in some data conversion issues impacting one additional award.
The Department agrees with this finding and will provide any training needed to staff members to ensure that all components of the FFATA are completed accurately, timely and with proper reviews. This training will include leadership reviewing NHTSA/Federal guidelines and SAM.Gov training on FFATA re...
The Department agrees with this finding and will provide any training needed to staff members to ensure that all components of the FFATA are completed accurately, timely and with proper reviews. This training will include leadership reviewing NHTSA/Federal guidelines and SAM.Gov training on FFATA reporting and requirements, documenting controls and ensuring the approvers have access to all supporting schedules, forms and systems and that they understand the subawards, and process for late submissions if needed.
The Department agrees with the finding and will ensure that staff follow all internal policies and procedures to maintain accurate and complete FFATA reporting. To achieve this, staff will review existing procedures and make any necessary updates regarding report compilation. Additionally, we will r...
The Department agrees with the finding and will ensure that staff follow all internal policies and procedures to maintain accurate and complete FFATA reporting. To achieve this, staff will review existing procedures and make any necessary updates regarding report compilation. Additionally, we will review control points to ensure they are consistently followed and approved by the team supervisor and team manager.
CDPHE fiscal procedures have been updated to reflect changes to the reporting process, specifically noting the recent federal website change and adding the requirement of a secondary level of review. By July 31, 2026, all outstanding FFATA reports will be filed with the federal government and the mo...
CDPHE fiscal procedures have been updated to reflect changes to the reporting process, specifically noting the recent federal website change and adding the requirement of a secondary level of review. By July 31, 2026, all outstanding FFATA reports will be filed with the federal government and the monthly review process in the updated fiscal procedures will be implemented.
The Department of Local Affairs (Department) agrees with the recommendation to strengthen internal controls over the financial management of federal Coronavirus Capital Projects Fund grant expenditures and the accuracy and completeness of the Exhibit K1, Schedule of Federal Assistance. The Departmen...
The Department of Local Affairs (Department) agrees with the recommendation to strengthen internal controls over the financial management of federal Coronavirus Capital Projects Fund grant expenditures and the accuracy and completeness of the Exhibit K1, Schedule of Federal Assistance. The Department will develop a corrective action plan that includes enhanced procedures for the performance of year-end estimates/accruals. The Department will create and implement staff training for staff that are responsible for preparing and reviewing the estimates/accruals, the Exhibit K1, grant transactions and enhancements.
The Department will strengthen its internal controls over federal reporting by implementing policies and procedures that include a monitoring process to ensure that FFATA reporting occurs as required for subawards of $30,000 or more in SAM.gov by the end of the month following the month the subaward...
The Department will strengthen its internal controls over federal reporting by implementing policies and procedures that include a monitoring process to ensure that FFATA reporting occurs as required for subawards of $30,000 or more in SAM.gov by the end of the month following the month the subawards are made.
The Department will document and implement internal monitoring policies and procedures, including the performance of reconciliations of reports, to ensure that the required PR28 and Quarterly Performance Reports are accurate and complete. This will include maintaining documentation of evidence of th...
The Department will document and implement internal monitoring policies and procedures, including the performance of reconciliations of reports, to ensure that the required PR28 and Quarterly Performance Reports are accurate and complete. This will include maintaining documentation of evidence of the review and approval of each report prior to its submission to the federal government.
The Department will complete and communicate formalized IT procedures to staff and IT service providers for IT general control activities for MyUI+ by April 2026.
The Department will complete and communicate formalized IT procedures to staff and IT service providers for IT general control activities for MyUI+ by April 2026.
The Department will implement Part B of the confidential finding.
The Department will implement Part B of the confidential finding.
The Department will implement Part A of the confidential finding.
The Department will implement Part A of the confidential finding.
The Department will implement Part B of the confidential finding.
The Department will implement Part B of the confidential finding.
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: 812-847-6020 ext. 1007 katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description o...
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Eligibility Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: 812-847-6020 ext. 1007 katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Eligibility - Income guidelines will be entered by the Director of Food Services and reviewed by the Director of School Finance to ensure accuracy. Review by the Director of School Finance will be noted on the July monthly checklist completed by the Director of School Finance. Direct certification - The direct certification process will be completed on a weekly basis by the Director of Food Services and will be reviewed and signed off via email by the Director of School Finance. Review of Applications - The Food Service Management provider reviews and approves or denies online applications. The applications are printed monthly and maintained in the office of the Director of Food Service. The Director of Food Service will review a sample of applications each month to verify proper approvals and denials. The Director of Food Service will provide verified applications to the Director of School Finance for review. Anticipated Completion Date: This Corrective Action Plan will be put in effect February 2026.
FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of C...
FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Katie Elliott Contact Phone Number and Email Address: katieelliott@lssc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the School Corporation completed the required Time and Effort logs, a time study was not completed and documented to justify the allocation of costs related to the compensation and fringe benefits of the food service director. The School Corporation Food Service Director is now documenting the hours spent each day completing food service activities. Anticipated Completion Date: This Corrective Action Plan will be put in effect January 2026.
Corrective Actions Taken or Planned: Management concurs with the auditor’s assessment that this was a control oversight and a breakdown in the internal control system for payroll documentation, rather than intentional noncompliance. As part of our federal grant closeout efforts, we have taken the fo...
Corrective Actions Taken or Planned: Management concurs with the auditor’s assessment that this was a control oversight and a breakdown in the internal control system for payroll documentation, rather than intentional noncompliance. As part of our federal grant closeout efforts, we have taken the following steps to address the deficiency: •After-the-Fact Certifications: As of this response, WETA has obtained ten after-the-factemployee certifications confirming that the payroll allocations for FY 2025 accurately reflectthe effort performed. These certifications are on file and available for review. •Managerial Oversight Confirmation: The Director of Production Operations has provided writtenconfirmation that monthly allocation decisions were discussed with project managers andreflected in payroll actions, though these reviews were not formally documented at the time. •Policy Review and Update: Management is currently reviewing and updating internal policiesto ensure that documentation procedures align with operational practices. These updates willrequire contemporaneous certification and documentation of payroll allocations for any futurefederal or restricted awards. •Training and Controls: We are developing additional training to reinforce documentationexpectations and strengthen internal controls among finance and operational staff. Completion Date: January 31, 2026 Contact Person: Dorian Davis Title: Corporate Controller Phone Number: (703) 998-2216
2025-001 – Allowable Activities/Allowable Costs Contact Person Responsible for Corrective Action: Wendy Bradstreet, RSU29 Business Manager Corrective Action: RSU29 has taken the following actions to address finding 2025-001: The district has been implementing new procedures and processes as of Febru...
2025-001 – Allowable Activities/Allowable Costs Contact Person Responsible for Corrective Action: Wendy Bradstreet, RSU29 Business Manager Corrective Action: RSU29 has taken the following actions to address finding 2025-001: The district has been implementing new procedures and processes as of February 1, 2026, to correct the issues in question to comply with CFR(s): 2 CFR 200.303, to make sure we remain in compliance with OMB guidelines. Findings have been shared with the Food Services Director and training has been utilized from guidance and resources provided by the Maine Department of Education Nutrition Services site which include financial training and procurement practices and resources provided by the USDA School Nutrition Program regulations (7 CFR Part 210, 215, 220). Internal approvals have been revised to have not only the Food Service Director approving purchases, but an approval from the district Business Manager prior to payment of invoices to vendors. A copy of the OMB Circulars containing the CFR guidelines have been received and reviewed by the Business Manager and applicable grant managers/coordinators to implement a more stringent internal control process and procedure to ensure all requirements are followed. The Business Manager has updated the district’s Food Service Director and central office staff of applicable guidelines to ensure compliance of all projects that is being paid for by federal and/or state funding. Anticipated Completion Date: June 30, 2026.
Federal Agency / Pass-Through Entity: U.S. Department of Agriculture / Georgia Forestry Commission Program: Inflation Reduction Act Urban & Community Forestry Program (Federal Assistance Number #10.727) 1. Description of Finding During the audit, it was noted for the three performance reports tested...
Federal Agency / Pass-Through Entity: U.S. Department of Agriculture / Georgia Forestry Commission Program: Inflation Reduction Act Urban & Community Forestry Program (Federal Assistance Number #10.727) 1. Description of Finding During the audit, it was noted for the three performance reports tested, there were no documented review procedures or approvals to validate the information reported to the funding agencies, violating 2 CFR §200.303(a). 2. Statement of Agreement The organization agrees with the finding. 3. Corrective Actions Planned Action 1: For all federally-funded awards, the Development team will provide a draft of each performance report to the Chief Operating Officer for review and approval prior to submission. Action 2: The Chief Operating Officer will request any necessary corrections and/or documentation before approving. Action 3: The Chief Operating Officer will document review and approval of the draft via email copying the Grant & Accounting Specialist on the approval notice. Action 4: The Grant & Accounting Specialist will save approval notices to the Federal Grant Management folder of the Finance shared drive. 4. Responsible Official Don Hemrick, Director of Development 5. Planned Completion Date February 28, 2026 6. Monitoring Plan The Contract CFO will review the approval notices quarterly until approval notices are collected for 100% of performance reports in two consecutive quarters. Trees
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