Corrective Action Plans

Finding 567694 (2024-023)

Significant Deficiency 2024

State of Michigan

MI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding 2024-023 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - PTMS Security Management and Access Controls Management Views MDOT agrees with the finding. Planned Corrective Action MDOT EIM and Office of Passenger Transportation will collaborate and provide oversight to ensure ...

Finding 2024-023 Coronavirus State and Local Fiscal Recovery Funds, ALN 21.027 - PTMS Security Management and Access Controls Management Views MDOT agrees with the finding. Planned Corrective Action MDOT EIM and Office of Passenger Transportation will collaborate and provide oversight to ensure that Public Transportation Management System (PTMS) user access is reviewed semiannually for privileged accounts and annually for all other accounts. MDOT will implement an improved process which will include obtaining, verifying, and documenting the written approval for all identified users by the designated System Security Administrators. Access will be modified/removed, as appropriate, based on responses or removed for non-responders prior to the end of each six-month period for privileged users and each fiscal year for all other users. Anticipated Completion Date September 30, 2025 Responsible Individual(s) Sandy Lovell, MDOT Gina Huhn, MDOT Jean Ruestman, MDOT Kyle Nelson, MDOT Andy Esch, MDOT

View Audit 360209

Finding 567688 (2024-022)

Significant Deficiency 2024

State of Michigan

MI

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.303

Finding 2024-022 Highway Planning and Construction, ALN 20.205 - AASHTOWare Security Management and Access Controls Management Views MDOT agrees with the finding. Planned Corrective Action MDOT’s Office of Enterprise Information Management (EIM), Bureau of Field Services-Construction Field Service...

Finding 2024-022 Highway Planning and Construction, ALN 20.205 - AASHTOWare Security Management and Access Controls Management Views MDOT agrees with the finding. Planned Corrective Action MDOT’s Office of Enterprise Information Management (EIM), Bureau of Field Services-Construction Field Services Division, and Bureau of Development-Design Division will collaborate and provide oversight to ensure that user access for the American Association of State Highway and Transportation Officials software (AASHTOWare) Preconstruction and Construction & Materials modules is reviewed semiannually for privileged accounts and annually for all other accounts. MDOT will implement an improved process, which will be facilitated by the designated System Security Administrators, and access will be modified or removed, as appropriate, prior to the end of each six-month period for privileged users and annually for all other users. Anticipated Completion Date January 1, 2026 Responsible Individual(s) Mark Shulick, MDOT Dan Burns, MDOT Kristin Schuster, MDOT Dee Parker, MDOT Lindsey Renner, MDOT Jason Gutting, MDOT Kyle Nelson, MDOT Andy Esch, MDOT

View Audit 360209

Finding 567678 (2024-021)

Significant Deficiency 2024

State of Michigan

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Period of Performance § 200.303 § 200.308

Finding 2024-021 National Guard Military Operations and Maintenance (O&M) Projects, ALN 12.401 - Extension Procedures Management Views DMVA agrees with the finding. Planned Corrective Action DMVA will set annual recurring calendar appointments to review program activities with the program managers...

Finding 2024-021 National Guard Military Operations and Maintenance (O&M) Projects, ALN 12.401 - Extension Procedures Management Views DMVA agrees with the finding. Planned Corrective Action DMVA will set annual recurring calendar appointments to review program activities with the program managers one month before the end of the period of performance to ensure a joint understanding of extension requirements, allowing sufficient time to prepare and submit period of performance extension requests timely, if needed. Anticipated Completion Date September 1, 2025 Responsible Individual(s) Rachelle Breeden, DMVA

View Audit 360209

Finding 567677 (2024-020)

Significant Deficiency 2024

State of Michigan

MI

Cash Management § 200.303

Finding 2024-020 National Guard Military Operations and Maintenance (O&M) Projects, ALN 12.401 - Timeliness of Cash Draws Management Views The Department of Military and Veterans Affairs (DMVA) agrees with the finding. Planned Corrective Action DMVA has communicated the importance of timely compl...

Finding 2024-020 National Guard Military Operations and Maintenance (O&M) Projects, ALN 12.401 - Timeliness of Cash Draws Management Views The Department of Military and Veterans Affairs (DMVA) agrees with the finding. Planned Corrective Action DMVA has communicated the importance of timely completion of cash draws. DMVA will consolidate expenditure reports sent to federal program managers to reduce overall quantity and improve timeliness. Additionally, DMVA will implement a revised document management methodology for expenditure reports returned from federal program managers that are ready for final approval and submission to the United States Property and Fiscal Office. Anticipated Completion Date September 30, 2025 Responsible Individual(s) Rachelle Breeden, DMVA

View Audit 360209

Finding 567676 (2024-010)

Significant Deficiency 2024

State of Michigan

MI

Internal Control / Segregation of Duties § 200.303

Finding 2024-010 MDE, Change Management Process Management Views MDE agrees with the finding. Planned Corrective Action For MiND, the standard change management process requires documenting the test results. However, there are scenarios when the data in question is only in the production environme...

Finding 2024-010 MDE, Change Management Process Management Views MDE agrees with the finding. Planned Corrective Action For MiND, the standard change management process requires documenting the test results. However, there are scenarios when the data in question is only in the production environment; or it might be production specific deployment like changing application settings which does not have relevance to the test environment. In these cases, MDE will maintain documentation in DevOps that the deployment is production specific. MDE will increase the post-review process of MiND related work items from a semi-annual to quarterly basis to ensure all required evidence of testing is recorded appropriately. For NexSys, MDE will review the change management process with DTMB and implement additional steps to ensure tickets are closed in a timely manner and all testing results have been appropriately documented. Anticipated Completion Date September 30, 2025 Responsible Individual(s) Monica Butler, MDE Peter Jones, MDE

View Audit 360209

Finding 567675 (2024-009)

Significant Deficiency 2024

State of Michigan

MI

Subrecipient Monitoring § 200.303

Finding 2024-009 MDE, Security Management and Access Controls Management Views The Michigan Department of Education (MDE) agrees with the finding. Planned Corrective Action For part a., with the release of Michigan Nutrition Data (MiND) 2.0 in November 2024, the system now has the added documentat...

Finding 2024-009 MDE, Security Management and Access Controls Management Views The Michigan Department of Education (MDE) agrees with the finding. Planned Corrective Action For part a., with the release of Michigan Nutrition Data (MiND) 2.0 in November 2024, the system now has the added documentation supporting the individual approved system roles required for this security control. For part b.1., MDE will start reviewing non-privileged internal Grant Electronic Monitoring System/Michigan Administrative Review System accounts on an annual basis and will store documentation of the review. MDE has started writing the policy adjustment for this change. To validate their continued need, MDE will annually review all MiND accounts for appropriate access that have access to SOM proprietary information. For part b.2., MDE has provided input to DTMB on this technical control, and MDE intends to comply with the revised SOM Technical Standard 1340.00.020.01 (Access Control Standard). MDE plans to complete both the policy adjustment and the annual review for 2025 by December 31, 2025. For part c., MDE implemented the process for deactivating users to meet this security requirement in November 2024 when MiND 2.0 was released. The process for deactivating users to meet this security requirement for the Next Generation Grant, Application and Cash Management System (NexSys) was implemented in May 2025. Anticipated Completion Date a. Completed b.1. September 30, 2025 b.2. December 31, 2025 c. Completed Responsible Individual(s) Monica Butler, MDE Joshua Long, MDE Peter Jones, MDE David Judd, MDE

View Audit 360209

Finding 567674 (2024-008)

Significant Deficiency 2024

State of Michigan

MI

Subrecipient Monitoring Cash Management Eligibility § 200.303

Finding 2024-008 MDE, IT General Controls Management Views DTMB agrees it did not fully implement its user access removal and recertification processes when transitioning responsibilities between employees. Planned Corrective Action DTMB corrected the issues noted and the reassigned employee res...

Finding 2024-008 MDE, IT General Controls Management Views DTMB agrees it did not fully implement its user access removal and recertification processes when transitioning responsibilities between employees. Planned Corrective Action DTMB corrected the issues noted and the reassigned employee resumed DTMB’s existing user access removal and recertification processes in November 2024. Anticipated Completion Date Completed Responsible Individual(s) Rex Menold, DTMB Aaron Dupre, DTMB

View Audit 360209

Finding 567666 (2024-019)

Significant Deficiency 2024

State of Michigan

MI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

Finding 2024-019 WIC Special Supplemental Nutrition Program for Women, Infants, and Children, ALN 10.557 - MI-WIC Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS discussed the change management documented requirements with the information t...

Finding 2024-019 WIC Special Supplemental Nutrition Program for Women, Infants, and Children, ALN 10.557 - MI-WIC Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS discussed the change management documented requirements with the information technology (IT) contractor during April 2025 to ensure all testing is documented appropriately. MDHHS has updated the Michigan Women, Infants, and Children Information System (MI-WIC) Change Management Controls process to include a review of each change to ensure it has successfully completed all components of the change management process prior to completion of associated release activities. Anticipated Completion Date Completed Responsible Individual(s) Kristina Brady, MDHHS Bagya Kodur, MDHHS

View Audit 360209

Finding 567665 (2024-018)

Significant Deficiency 2024

State of Michigan

MI

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Finding 2024-018 WIC Special Supplemental Nutrition Program for Women, Infants, and Children, ALN 10.557 - MI-WIC Access Controls Management Views MDHHS and DTMB agree with the finding. Planned Corrective Action DTMB implemented a process in November 2024 to review privileged accounts with direct ...

Finding 2024-018 WIC Special Supplemental Nutrition Program for Women, Infants, and Children, ALN 10.557 - MI-WIC Access Controls Management Views MDHHS and DTMB agree with the finding. Planned Corrective Action DTMB implemented a process in November 2024 to review privileged accounts with direct database access semiannually. Anticipated Completion Date Completed Responsible Individual(s) Nathan Buckwalter, DTMB

View Audit 360209

Finding 567659 (2024-006)

Significant Deficiency 2024

State of Michigan

MI

Special Tests & Provisions Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Finding 2024-006 ADP Security Program Management Views Although MDHHS and DTMB agree annual testing was not conducted for one system and not all necessary updates to the system security plan were completed during the audit period for four systems, MDHHS and DTMB disagree that effective controls wer...

Finding 2024-006 ADP Security Program Management Views Although MDHHS and DTMB agree annual testing was not conducted for one system and not all necessary updates to the system security plan were completed during the audit period for four systems, MDHHS and DTMB disagree that effective controls were not implemented to ensure confidentiality, integrity, and availability of its automated data processing (ADP) information systems. MDHHS and DTMB also disagree that the security of critical systems was at risk by failing to mitigate potential vulnerabilities as described in the effect statement of the finding. MDHHS and DTMB have compensating controls in place to ensure confidentiality, integrity, and availability of its ADP information systems in addition to mitigating potential vulnerabilities. MDHHS and DTMB monitor remediation of Plans of Actions and Milestones for all information systems even after expiration of the authority to operate (ATO). For one system cited, MDHHS is required to audit the system as part of the responsibilities related to the Affordable Care Act and the Medicaid Expansion marketplace. Those audits are conducted to show compliance with federal information security and privacy requirements related to data stored in those systems. The system required to be audited as part of the Affordable Care Act, along with two other systems cited, are reviewed biennially through the Internal Control Evaluation process where control evidence is updated to demonstrate the effectiveness of controls. Each system cited did not have any significant changes and implemented controls are still working as expected. Planned Corrective Action DTMB has hired additional resources to help ensure the timely completion of the required work below. For part a., MDHHS and DTMB will conduct testing of the disaster recovery plan (DRP) by September 30, 2025, and will follow SOM Technical Standards on DRP testing going forward. For part b., MDHHS and DTMB will complete the necessary updates to the system security plans, including updating the risk assessments, and anticipate completion for all cited systems by July 1, 2025. MDHHS and DTMB anticipate that ATO renewals will be attained for all cited systems by August 30, 2025. Anticipated Completion Date a. September 30, 2025 b. August 30, 2025 Responsible Individual(s) Laura Visser, MDHHS Nathan Buckwalter, DTMB Lyndia Deromedi, MDHHS Heather Frick, DTMB Kasi Hunzinger, MDHHS Veronica Maxson, MDHHS Karen Scott, MDHHS Michelle Smith, MDHHS

View Audit 360209

Finding 567657 (2024-004)

Significant Deficiency 2024

State of Michigan

MI

Internal Control / Segregation of Duties § 200.303

Finding 2024-004 Bridges Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS change control processes require a communication to be sent within three business days after each release that validates the changes to Bridges were applied as expect...

Finding 2024-004 Bridges Change Management Process Management Views MDHHS agrees with the finding. Planned Corrective Action MDHHS change control processes require a communication to be sent within three business days after each release that validates the changes to Bridges were applied as expected and this validation is documented and retained as part of the release close-out process. MDHHS added a checklist to immediate releases during April 2025 to help eliminate human error and ensure documentation of all post-implementation approvals is retained for each release. Anticipated Completion Date Completed Responsible Individual(s) Holly Roderick, MDHHS

View Audit 360209

Finding 567656 (2024-003)

Material Weakness 2024

State of Michigan

MI

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

Finding 2024-003 Bridges Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a., b., c., and d., MDHHS implemented the Database Security Application (DSA) on October 2, 2023, which includes documenting incompatible role except...

Finding 2024-003 Bridges Security Management and Access Controls Management Views MDHHS agrees with the finding. Planned Corrective Action For parts a., b., c., and d., MDHHS implemented the Database Security Application (DSA) on October 2, 2023, which includes documenting incompatible role exception requests and user access request approvals, semi-annual review of privileged users, and annual review for all users. Security management and access control processes will continue to be a standing agenda item for ongoing quarterly training sessions with Local Office Security Coordinators (LOSCs). For parts a., c., and d., the Access Management Section began conducting quarterly reconciliations of DSA to the Bridges Integrated Automated Eligibility Determination System (Bridges) during the first quarter of fiscal year 2025. For part b., MDHHS is currently evaluating the feasibility of establishing a quarterly review process to help ensure documentation is maintained for a sample of LOSC monitoring reports. MDHHS anticipates completing the evaluation by September 30, 2025, and will determine an anticipated completion date for implementation, if necessary, at that time. For part e., MDHHS Local Office Directors, District Managers, or designees review a monthly sample of high-risk Bridges transactions to ensure documentation was properly maintained. Beginning September 2024, MDHHS Business Service Centers (BSC) implemented a monitoring process to ensure monthly reviews are completed by the local offices timely and that the documentation is properly maintained. Anticipated Completion Date a., c., d., and e. Completed b. September 30, 2025 Responsible Individual(s) a., b., c., and d. Jim Bowen, MDHHS e. Veronica Maxson, MDHHS

View Audit 360209

Finding 567655 (2024-002)

Significant Deficiency 2024

State of Michigan

MI

Eligibility Significant Deficiency Internal Control / Segregation of Duties § 200.303 § 200.334

Finding 2024-002 Bridges Interface Controls Management Views DTMB disagrees with the condition and the effect of the OAG’s finding. The OAG sampled 85 total files across eight interfaces. Of these, seven appeared to present issues. For five of the sampled files, detailed exception results no longer...

Finding 2024-002 Bridges Interface Controls Management Views DTMB disagrees with the condition and the effect of the OAG’s finding. The OAG sampled 85 total files across eight interfaces. Of these, seven appeared to present issues. For five of the sampled files, detailed exception results no longer existed. DTMB maintains summary tables for 10 years and purges detailed exception records at the beginning of each calendar year for anything older than 12 months. This purge process was communicated to the OAG during the fiscal year 2022 audit, and sampling was performed prior to purging for the fiscal year 2023 audit. When informed that the sample included files for which the detailed exception records had been purged, the OAG requested DTMB run a simulation processing of the original interface file in a testing environment to recreate detailed exception records. DTMB’s technical teams informed the OAG that rerunning in the current test environment would likely differ from the original results due to code changes that occurred in the test environment subsequent to when the original interface files were run in production. The OAG requested DTMB to proceed with rerunning the files in the current test environment. As a result, the OAG identified five instances where the detailed exception records from the simulation in the test environment did not exactly match the summary table from the original production interface results. For the 2 remaining files out of 85 (2.4 percent) that were cited, it should be clarified that the reconciliation being discussed is not data that was lost or misplaced between systems, but reconciliation of two exceptions correctly logged and correctly not counted in a summary report because they were alerts during processing, not errors that would be forwarded for review. These results do not present a significant deficiency in the ability of MDHHS to review the detailed exceptions. Also, these 2 records are insignificant when compared to the 11.6 million records processed in the 85 sampled files (0.000001 percent). Therefore, the current controls are reasonable to ensure that data processed from the source system to the receiving system is processed accurately, completely, and timely. Planned Corrective Action DTMB disagrees with the finding and does not intend to take further action. Anticipated Completion Date Not applicable Responsible Individual(s) Nathan Buckwalter, DTMB

View Audit 360209

Finding 567565 (2024-007)

Significant Deficiency 2024

City of New Haven

CT

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting § 200.303

Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program: Coronavirus State and Local Fiscal Recovery Fund Finding: Per 2 CFR 200.303, recipients are required to establish, document, and maintain effective internal controls that provide...

Finding 2024-007: Reporting – Significant Deficiency over Internal Control over Reporting Assistance Listing Program: Coronavirus State and Local Fiscal Recovery Fund Finding: Per 2 CFR 200.303, recipients are required to establish, document, and maintain effective internal controls that provide reasonable assurance of compliance with Federal statutes, regulations, and award terms. These controls should align with GAO's Standards for Internal Control in the Federal Government and COSO's Internal Control – Integrated Framework. Condition: The City did not maintain documentation supporting the internal control process over the submission of required quarterly reports during fiscal year 2024. Corrective Actions Taken: 1. Establishment of Formal Reporting Controls: The City has developed and implemented a standardized procedure for the preparation, review, and submission of all quarterly reports related to federal awards, including a designated checklist and approval workflow to ensure compliance with reporting deadlines and content accuracy. 2. Documentation and Retention Protocols: All steps in the reporting process are now formally documented, including preparer and reviewer signoffs. Supporting documentation is retained in a centralized location accessible to relevant staff and auditors for verification purposes. 3. Internal Review and Oversight: The Office of Management, Policy, and Grants has assigned responsibility to the Grant Management Team for conducting secondary reviews of quarterly report submissions. This includes validating that internal controls have been followed, and evidence of compliance is documented. 4. Staff Training: Staff involved in federal reporting have received training on the internal control requirements outlined in 2 CFR 200.303, COSO, and GAO Green Book standards to reinforce the importance of documentation and control procedures. 5. Monitoring and Compliance Checks: A quarterly compliance checklist and review process have been instituted to ensure ongoing adherence to federal internal control requirements. Noncompliance will be flagged and reviewed with senior leadership. Contact: Shannon McCue, Director of Management, Policy, and Grant Anticipated Completion Date: January 2026

View Audit 360119

Finding 567399 (2024-007)

Material Weakness 2024

Washington Parks Academy

MI

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. • We have brought on a State and Federal Grants Consultant to ensure all required grant related paperwork is completed and saved in a shared location with the Finance Team.

View Audit 360089

Finding 567397 (2024-005)

Material Weakness 2024

Washington Parks Academy

MI

Subrecipient Monitoring Material Weakness Reporting § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. • We will ensure all reporting is filed on a timely basis.

View Audit 360089

Finding 567396 (2024-004)

Material Weakness 2024

Washington Parks Academy

MI

Cash Management Subrecipient Monitoring Material Weakness § 200.303

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If d...

Although the Academy has internal controls in place for approvals on journal entries, payments, transfers, and other disbursements, we will improve our processes in the following ways: • We will ensure a signature and date are included on all paperwork needing review and approval going forward. If documents are electronic, there must be an electronic signature with a time stamp included. • All Federal draws will have supporting documents that are reviewed, approved, and certified before funds are requested.

View Audit 360089

Finding 567376 (2024-002)

Significant Deficiency 2024

Cottonwood County

MN

Procurement, Suspension & Debarment § 200.303

Finding Number: 2024-002 Finding Title: Suspension and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Nick Klisch, Highway Engineer Corrective Action Planned: Be aware of the County Policy on Suspension...

Finding Number: 2024-002 Finding Title: Suspension and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Nick Klisch, Highway Engineer Corrective Action Planned: Be aware of the County Policy on Suspension and Debarment. Wording has been updated on the current policy by the County Attorney to make the process clearer. Anticipated Completion Date: 06/30/2025

View Audit 360037

Finding 567101 (2024-004)

Significant Deficiency 2024

Anoka County

MN

Eligibility Significant Deficiency Internal Control / Segregation of Duties § 200.303

Finding Number: 2024-004 Finding Title: Eligibility Program: 93.558 Temporary Assistance for Needy Families Name of Contact Person Responsible for Corrective Action: QC Team (Lead ES): Whitney VonDeLinde, Megan Howard, Melissa Hoeft Kellie Tienter, Public Assistance Manager Jessica Leth, Economic A...

Finding Number: 2024-004 Finding Title: Eligibility Program: 93.558 Temporary Assistance for Needy Families Name of Contact Person Responsible for Corrective Action: QC Team (Lead ES): Whitney VonDeLinde, Megan Howard, Melissa Hoeft Kellie Tienter, Public Assistance Manager Jessica Leth, Economic Assistance Director Corrective Action Planned: • Training TANF employees: o Distribution of Lead ES Newsletter – monthly training communication (includes updates to forms, bulletins from the state, policy & procedural changes, and technical tips) o Supervisor’s will review mandatory verifications at unit meetings by the end of Q3 2025. o Child Support Income Budgeting Guide  Includes how to budget, case noting, etc. o Move In Checklist  We have made clarifying updates to this document regarding requesting a case file from a previous county if not already received. o April 2025 PSU News  QC team shared information and tips from what they noticed while going through the audit • MFIP case reviews conducted by supervisors in Q2 and Q3. 15 per ES per year. • Per Hennepin County we were only transferring the last year of case file documents when clients moved from Anoka County to Hennepin County. Beginning in Q2 of 2025 Anoka County began transferring the entire case file to ensure the complete retention of case files. Anticipated Completion Date: • Completion by end of Q3 2025

View Audit 359961

Finding 567100 (2024-003)

Significant Deficiency 2024

Anoka County

MN

Procurement, Suspension & Debarment § 200.303

Finding Number: 2024-003 Finding Title: Suspension and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Lindsey Felgate - Senior Manager, Procurement Corrective Action Planned: The Procurement Unit will c...

Finding Number: 2024-003 Finding Title: Suspension and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Lindsey Felgate - Senior Manager, Procurement Corrective Action Planned: The Procurement Unit will continue to educate county users on required policy & procedures. This would include a refresh to our new stand-alone procurement policy, a new procedure manual explaining in detail how to procure, and supplemental documents including forms and checklists to aid in compliance. We are upgrading SharePoint (internal website) to aid in sharing procurement information. We will continue to educate on process documentation including the federal guidance listed in Title 2 U.S. Code of Federal Regulations. The County has purchased a finance/procurement system set to go live in 1/2026. The system will manage the purchase order process, and we will continue to find a procurement solution for all other procurement activities. These plans will assist by moving the County from a manual environment to a more structured and standardized environment for procurement activities. Anticipated Completion Date: • Policy – 2025, current summer action • Procedures & Supplemental documents (how to’s, forms, checklists) – initial draft end of 2025 with enhancements in 2026 • SharePoint Site Refresh – year end 2025

View Audit 359961

Finding 567097 (2024-002)

Significant Deficiency 2024

Anoka County

MN

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2024-002 Finding Title: Suspension and Debarment Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Name of Contact Person Responsible for Corrective Action: Lindsey Felgate – Senior Manager, Procurement Corrective Action Planned: ...

Finding Number: 2024-002 Finding Title: Suspension and Debarment Program: 10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program Name of Contact Person Responsible for Corrective Action: Lindsey Felgate – Senior Manager, Procurement Corrective Action Planned: The Procurement Unit will continue to educate county users on required policy & procedures. This would include a refresh to our new stand-alone procurement policy, a new procedure manual explaining in detail how to procure, and supplemental documents including forms and checklists to aid in compliance. We are upgrading SharePoint (internal website) to aid in sharing procurement information. We will continue to educate on process documentation including the federal guidance listed in Title 2 U.S. Code of Federal Regulations. The County has purchased a finance/procurement system set to go live in 1/2026. The system will manage the purchase order process and we will continue to find a procurement solution for all other procurement activities. These plans will assist by moving the County from a manual environment to a more structured and standardized environment for procurement activities. Anticipated Completion Date: • Policy – 2025, current summer action • Procedures & Supplemental documents (how to’s, forms, checklists) – initial draft end of 2025 with enhancements in 2026 • SharePoint Site Refresh – year end 2025

View Audit 359961

Finding 567053 (2024-002)

Material Weakness 2024

Community Foundation of Northwest Indiana, Inc.

IN

Procurement, Suspension & Debarment § 200.303 § 200.318

Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 2...

Finding 2024-002 – Procurement, Suspension, and Debarment Federal Grantor: Department of Health and Human Services Assistance Listing No.: Assistance Listing 93.493, Congressional Directives Federal Award Number: CE1HS52357-01-00 Federal Award Period of Performance: September 30, 2023 – September 29, 2026 A material weakness was issued related to internal control over suppliers under the UG audit. CFNI recognizes the need to comply with the procurement standards outlined in 2 CFR §§ 200.318-326, which require written policies addressing competition, conflicts of interest, procurement methods (micro-purchases, small purchases, sealed bids, competitive proposals, and noncompetitive procurement), oversight, efforts to engage small and disadvantaged businesses, and procurement of recovered materials, among others. To address this deficiency, CFNI is committed to enhancing its documented procurement policies for procure-to-pay processes involving federal funds. The audit identified three instances out of 40 sampled where CFNI did not retain documentation verifying that suspension and debarment reviews were conducted during the onboarding of new suppliers. Although CFNI has an established vetting process, it recognizes the need for consistent documentation to evidence compliance. CFNI will implement formalized procedures to ensure all suspension and debarment reviews are documented and retained for audit purposes. CFNI engages a third-party contractor to monitor its supplier list against suspension and debarment databases. While the vendor provided a SOC 1 report, it did not specifically cover the suspension and debarment services provided. Additionally, CFNI did not conduct testing to validate the accuracy of the third-party's results. CFNI will revise its vendor management practices to ensure the SOC 1 reports cover the relevant services, and it will establish testing procedures to confirm the reliability of the vendor's outputs. Although CFNI utilizes two processes to monitor active suppliers against suspension and debarment lists—periodic PeopleSoft program checks and an annual review by a third-party vendor—no reconciliation was documented to confirm that the supplier lists provided to and received from the third party were complete and accurate. Additionally, no testing was conducted to validate the third party’s work. CFNI will implement a reconciliation process to verify the completeness and accuracy of supplier lists before and after third-party reviews. Furthermore, it will establish a sampling and testing procedure to validate the results provided by external vendors. CFNI will develop and implement a robust supplier management policy, incorporating requirements for procurement, suspension, and debarment reviews. Responsible Official: Pamela Pokropinski, VP Finance Status of finding: Completion expected June 2025

View Audit 359944

Finding 567014 (2024-001)

Material Weakness 2024

City of Panama City Beach, Florida

FL

Subrecipient Monitoring Material Weakness Reporting § 200.303

City of Panama City Beach, Florida Management’s Corrective Action Plan For the Fiscal Year Ended September 30, 2024 Finding Numbers: 2024-001 Finding 2024-001 Lack of Documented Review of Annual Project and Expenditure Report The City acknowledges the importance of maintaining strong internal con...

City of Panama City Beach, Florida Management’s Corrective Action Plan For the Fiscal Year Ended September 30, 2024 Finding Numbers: 2024-001 Finding 2024-001 Lack of Documented Review of Annual Project and Expenditure Report The City acknowledges the importance of maintaining strong internal controls. While the report was prepared with diligence and care, we recognize that the absence of documented independent review poses a risk for potential errors and noncompliance with federal requirements. To address this issue, the City has established a formal process to ensure that future reports undergo an independent review before submission. A qualified staff member who is not involved in preparing the report will conduct the review, and both the preparer and the reviewer will sign and date the report to provide evidence of oversight. This documentation will be retained in the grant file for compliance and audit purposes. Staff involved in the reporting process have been informed of these new procedures to ensure consistency moving forward. The revised procedures have been adopted and will be applied to the next reporting cycle. Documentation of the review process will be retained and made available for future audits. The City is committed to maintaining compliance with all applicable federal regulations and improving internal controls to ensure the integrity and accuracy of all grant-related reporting. Anticipated Completion Date: June 2025 Responsible Contact Person: Debra Gibson

View Audit 359923

Finding 565975 (2024-003)

Significant Deficiency 2024

Taylor County, Texas

TX

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding 2024-003 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal cont...

Finding 2024-003 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. Per 31 CFR 19.300, prior to enter in subawards and contracts with award funds, recipients must verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded pursuant to 31 CFR § 19.300. The County did not retain documentation of the verification that 6 vendors were not suspended, debarred, or otherwise excluded prior to entering into a transaction with them. Responsible Individuals: Elijah Anderson, County Auditor Corrective Action Plan: The County performed a review of suspended and debarred vendors in October 2024, prior to the submission of the final SLFRF required report. Going forward, Taylor County will continue retaining documentation of the verification of vendors paid with federal funds against the sam.gov suspension and debarment review tool. Anticipated Completion Date: Completed

View Audit 359630

Finding 565974 (2024-001)

Significant Deficiency 2024

Taylor County, Texas

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.303

Finding 2024-001 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: The County’s quarterly performance reports submitted to the Department of Treasury were not revie...

Finding 2024-001 Federal Agency Name: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Assistance Listing Number: 21.027 Finding Summary: The County’s quarterly performance reports submitted to the Department of Treasury were not reviewed and approved by a separate individual outside of the preparer. Responsible Individuals: Elijah Anderson, County Auditor Corrective Action Plan: Taylor County implemented a control process for the last quarter of fiscal year 2024 to have the County Auditor prepare the performance reports, with a mechanical review of the report performed by an individual within the Auditor’s Office. Anticipated Completion Date: Completed

View Audit 359630

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