Corrective Action Plans

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Finding Number 2023-105 Subject Heading (Financial) or AL no. and program name (Federal) 10.542 - Pandemic EBT – Food Benefits Planned Corrective Action The P-EBT program is no longer issuing benefits. Should a similar program be required in the future, the DHS will ensure internal controls are in p...
Finding Number 2023-105 Subject Heading (Financial) or AL no. and program name (Federal) 10.542 - Pandemic EBT – Food Benefits Planned Corrective Action The P-EBT program is no longer issuing benefits. Should a similar program be required in the future, the DHS will ensure internal controls are in place to avoid duplicate or erroneous payments. Anticipated Completion Date N/A Responsible Contact Person Sondra Shelby
View Audit 367158 Questioned Costs: $1
Corrective Action Plan (CAP) – FY 2023 Single Audit Finding 1: Material Adjustments to Recognize Balances in Accordance with U.S. GAAP Planned Corrective Action / Views of Responsible Officials: Management acknowledges the need for a formalized process to ensure that all general ledger balances are...
Corrective Action Plan (CAP) – FY 2023 Single Audit Finding 1: Material Adjustments to Recognize Balances in Accordance with U.S. GAAP Planned Corrective Action / Views of Responsible Officials: Management acknowledges the need for a formalized process to ensure that all general ledger balances are reviewed and accurate prior to audit. A third-party accounting firm has been engaged to conduct quarterly reviews and reconciliations of the general ledger to ensure proper documentation and recognition in accordance with U.S. GAAP. Management plans to develop and implement a structured internal review process before submitting the General Ledger balance for audit to ensure alignment with U.S. GAAP. We recognize that this may continue as a finding in the FY 2024 audit; however, the corrective action is in place as of this Single Audit in July 2025. Expected Completion Date: In progress with full implementation as of October 2025 or expected prior to commencement of FY 2025 Single Audit. Responsible Official: Amee Ivie, MSW Chief Executive Officer Finding 2: Completeness of SEFA and Data Collection Form Filing Timeliness Planned Corrective Action / Views of Responsible Officials: We recognize the deficiencies in our prior SEFA submission process. As of July 2025, the organization has engaged a third-party accounting firm to conduct quarterly reconciliations of federal grant activity and maintain a rolling SEFA throughout the fiscal year. Management turnover has stabilized, and processes are now in place to maintain an up-to-date general ledger with accuracy to support a complete and timely SEFA. A documented checklist and timeline have been implemented to ensure timely and accurate reporting. Expected Completion Date: In progress, with full implementation expected prior to commencement of FY 2025 Single Audit. Responsible Official: Amee Ivie, MSW Chief Executive Officer Finding 3: Employee Loan Documentation Planned Corrective Action / Views of Responsible Officials: New leadership has implemented a strict no-loan policy. Any loan or advance to staff must now receive prior written approval from the Executive Board. A formal Employee Loan and Advance Policy is being adopted to ensure any future considerations are properly documented, authorized, and compliant with internal controls. Payment-processing staff will be trained to enforce the new policy and ensure all reimbursements and advances meet approval requirements. Expected Completion Date: September 30, 2025 or expected prior to commencement of FY 2025 Single Audit. Responsible Official: Amee Ivie, MSW Chief Executive Officer Finding 4: Internal Controls Over Compliance – Timesheet Approval and Allowable Costs Planned Corrective Action / Views of Responsible Officials: As of April 2024, the organization implemented a new electronic timekeeping system (SwipeClock) in partnership with a third-party payroll provider. This system includes: • Supervisor approval of all time entries. • A final review by a member of the executive team (CEO, Operations Manager, or Accounting Coordinator). This three-tiered approval process ensures accuracy and accountability in payroll allocation to federal grants. Expected Completion Date: Fully implemented as of April 2024 Responsible Official: Amee Ivie, MSW Chief Executive Officer, AmeeI@cssnv.org
As part of the proposal negotiations for the federal program, initial discussions with the sponsoring office of the federal program included a limitation for allowable compensation for employees that were not the Executive Director. Although the limitation was intended to be removed from the final a...
As part of the proposal negotiations for the federal program, initial discussions with the sponsoring office of the federal program included a limitation for allowable compensation for employees that were not the Executive Director. Although the limitation was intended to be removed from the final agreement, the budgeted requested salaries were not updated. We will attempt to have the sponsoring office of the federal program to retroactively amend the Assistance Agreement to remove the compensation limitation. The Assistance Agreement has been modified to remove any such limitation prospectively beginning with Modification 0015 April 2024.
View Audit 363969 Questioned Costs: $1
2023-026 Strengthen Controls to Ensure Compliance with Federal Monitoring Requirements ALN #21.023 We acknowledge the finding. The Mississippi Department of Finance and Administration was not appropriated funds for this program nor was the agency given any authority for the administration for the pr...
2023-026 Strengthen Controls to Ensure Compliance with Federal Monitoring Requirements ALN #21.023 We acknowledge the finding. The Mississippi Department of Finance and Administration was not appropriated funds for this program nor was the agency given any authority for the administration for the program. As such, DFA was not in a position to assess eligibility determinations or perform monitoring. DFA drew down funds on behalf of Mississippi Home Corp in light of an impending federal deadline. Mississippi Home Corporation had eligibility and fraud prevention policies in place for the ARPA programs. These policies included, but are not limited to, contracting with a third-party law firm to review all applications with a three-tier review system, monitoring with random sample selections for every 10% completed, employing an internal, qualitycontrol auditor, and reviewing any applications submitted that were greater than $10,000. As a result of their monitoring, MHC was able to identify suspicious applications and report them to the Mississippi Attorney General for investigation. MHC continues to report all expenditures directly to U.S. Treasury on a quarterly basis. It is also worth noting that the program stopped taking applications in September of 2022 which was prior to the issuance of the 2022 Single Audit Report that was released on July 31, 2023. Thus, policies and controls in place could not be changed for this. DFA is taking the position that corrective action is no longer necessary for these funds. Corrective Action: A. The Mississippi Department of Finance and Administration is taking the position that corrective action is no longer necessary. The program stopped taking applications in September of 2022, which is prior to the current 2023 single audit report dated November 21, 2024. Policies and controls in place could not be changed for this. B. N/A C. N/A D. The Emergency Rental Assistance program stopped taking applications September of 2022.
Finding 2023-003 Condition: The organization did not properly maintain documentation to support the pay rate authorization. Corrective Action Plan: Management will conduct internal audits to randomly select pay statements and verify there are pay rate authorization documents to support the pay r...
Finding 2023-003 Condition: The organization did not properly maintain documentation to support the pay rate authorization. Corrective Action Plan: Management will conduct internal audits to randomly select pay statements and verify there are pay rate authorization documents to support the pay rate in the pay statements. Person responsible: Finance Director and Human Resources Manager Completion date: Starting 4th quarter of 2024 and through 2025 until management is satisfied the problem is resolved.
Historic Hudson Valley will adopt written policies and procedures, and standards of conduct as required by 2 CFR 200, Subparts D and E.
Historic Hudson Valley will adopt written policies and procedures, and standards of conduct as required by 2 CFR 200, Subparts D and E.
Pioneer Works Art Foundation will adopt written policies and procedures, and standards of conduct as required by 2 CFR 200, Subparts D and E.
Pioneer Works Art Foundation will adopt written policies and procedures, and standards of conduct as required by 2 CFR 200, Subparts D and E.
Recommendation: We recommend the Annex Teen Clinic, Inc. document the authorization of expenditures charged to federal awards and ensure documentation is available to support such expenditures. Planned Action: We have implement a new Accounts Payable Automation Sofware called Continia, which will ma...
Recommendation: We recommend the Annex Teen Clinic, Inc. document the authorization of expenditures charged to federal awards and ensure documentation is available to support such expenditures. Planned Action: We have implement a new Accounts Payable Automation Sofware called Continia, which will make reimbursement, invoicing, and credit card submission processes more efficient and advanced. With this new software, we will be able to streamline our accounts payable processes and save a significant amount of time. Continia will allow everyone to submit their expenses and mileage trips on the Continia Expense Portal. It will also automate the approval process.
Condition: A duplicate expense was recorded to the program and expenses were recorded to the program prior to the period of performance. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Ma...
Condition: A duplicate expense was recorded to the program and expenses were recorded to the program prior to the period of performance. Planned Corrective Action: Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management has instituted procedures to provide a review of journal entries to reclass expenses to grant funded programs and promptly record. As well, Finance staff have been added to oversee the accounting function for the grant. Contact person responsible for corrective action: Mary Lawrence, Director of Financial Analysis and Special Initiatives Anticipated Completion Date: 5/15/2024
Finding 2023-005 Lack of Internal Control / Noncompliance over Subrecipient Monitoring Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: HCSD established a Subrecipient Monitoring Checklist as a monitoring tool to ensure that subrecipients are successful and complia...
Finding 2023-005 Lack of Internal Control / Noncompliance over Subrecipient Monitoring Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: HCSD established a Subrecipient Monitoring Checklist as a monitoring tool to ensure that subrecipients are successful and compliant and the subawards are used in accordance with federal statutes, regulations, and the terms and conditions of the federal and state awards. Proposed Completion Date: Fiscal Year 2024
View Audit 305718 Questioned Costs: $1
Federal Award Findings and Questioned Costs Finding 2023-004 Lack of Internal Control / Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Management will ensure that the system o...
Federal Award Findings and Questioned Costs Finding 2023-004 Lack of Internal Control / Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Name of Contact Person: Elena Begojevic, Business Manager Corrective Action Plan: Management will ensure that the system of internal controls over cash disbursements is designed appropriately and operates effectively to ensure all transactions are coded, reviewed, and approved before payment is made. The Business manager and the Superintendent will conduct a review of claims to determine whether they are proper and valid charges. Once reviewed, all transactions will be authorized. DocuSign will be used for electronic signature approval. Accounts payable clerk will ensure that all transactions include copies of receipts for the goods or services purchased. Finally, the Finance department will work with the program directors to ensure that expenses are coded accurately and within reasonable timeframe to allow for timely submission of grant reports. Proposed Completion Date: Fiscal Year 2024
View Audit 305718 Questioned Costs: $1
Finding 395379 (2023-024)
Significant Deficiency 2023
2023-024 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program MANAGEMENT RESPONSE: We agree with this recommendation. The ODHS Office of Facilities Management coordinates care of a 168-building portfolio. Part of this work is coord...
2023-024 Oregon Department of Human Services/Oregon Health Authority Strengthen review over direct costs charged to the program MANAGEMENT RESPONSE: We agree with this recommendation. The ODHS Office of Facilities Management coordinates care of a 168-building portfolio. Part of this work is coordination of furniture reconfiguration, minor and major remodels of office spaces and other building maintenance work. For these projects we rely on program staff with understanding of their funding sources to provide us with accurate coding to support the project related costs. Our office does not work directly with funding source management only coding and billing. To better track who is providing us the coding and maintain a record of payment approval we have revised our workorder form to include who from the program is providing the coding and what authority they have to provide the coding. This will allow us to assure that important details are captured regarding funding application and coding for billing and protect from funds being drawn from sources that do not support and/or are not appropriate for a given project. The questioned costs of $3,849 were corrected and refunded to CMS using document BTCL1485 with a April 17, 2024 effective date. The refund will be reported on the Q3 FFY 2024 CMS 64 which will be submitted by June 30, 2024. Anticipated Completion Date: June 30, 2024 Contact person: Karuna Thompson, Construction and Facilities Maintenance Manager; Travis Labrum, Grant Accounting Manager
View Audit 305129 Questioned Costs: $1
Finding 391617 (2023-006)
Significant Deficiency 2023
Ref. No. Compliance and Internal Control over Compliance Findings 2023-006 Allowable Costs – Significant Deficiency Recommendation We recommend the County follow their internal control process to ensure that adequate documentation supports the accumulation of costs charged to the Program as requ...
Ref. No. Compliance and Internal Control over Compliance Findings 2023-006 Allowable Costs – Significant Deficiency Recommendation We recommend the County follow their internal control process to ensure that adequate documentation supports the accumulation of costs charged to the Program as required by 2 CFR §200 Subpart E. View of Responsible Officials and Planned Corrective Action Management agrees with this finding. The Department of the Prosecuting Attorney’s office has reviewed and agreed a detailed line item report and Payment Request/Approval form did not accompany the respective RFF. The Department has already corrected these deficiencies to ensure each expense has an Expense Approval form with justification and that each RFF is accompanied with a detailed line item report and backup documentation for each expense being requested for reimbursement. Each payroll and non-payroll monthly invoices submitted clearly shows the breakdown. With each invoice submitted, it will state, as an example, “VOCA-SNAP 21-V2-01 Report & Attachments MM/YY”. A sample of this was submitted on March 25, 2024 with response. In short, the necessary back-up requested going forward is and will be available to submit for future audits or reviews. Anticipated Completion Date: 3/27/2024 Responding Person(s): Robert Nadal Grant Management Specialist Phone No. 808-270-7608
Finding 390913 (2023-003)
Significant Deficiency 2023
Dear Mr. Waguespack: The Department of Children and Family Services has reviewed the finding “Noncompliance and Control Weakness Related to Cost Allocation”. The Department concurs with the finding and recommendation. When processing the July 2022 cost allocation statistics, we inadvertently selec...
Dear Mr. Waguespack: The Department of Children and Family Services has reviewed the finding “Noncompliance and Control Weakness Related to Cost Allocation”. The Department concurs with the finding and recommendation. When processing the July 2022 cost allocation statistics, we inadvertently selected the wrong report date for one statistic, which resulted in incorrect percentages being charged to various cost pools. The Cost Allocation Unit has implemented a review process to ensure that supporting data is accurate prior to processing monthly statistics. The Program Consultant will run all reports used by the Cost Allocation Unit each month and submit the reports to the Program Manager for approval. The Program Manager will verify the accuracy of the report dates and supporting documentation, sign the reports, and return them to the Program Consultant for processing monthly stats. The Cost Allocation Unit is updating the Cost Allocation Plan to include the missing cost pool and will submit future amendments promptly when major changes occur. Plan updates will continue to be submitted semi-annually. If you have any questions, please contact Tonja Hayes, Cost Allocation Unit Program Manager. Ms. Hayes can be reached at (225) 342-4859 or Tonja.Hayes.DCFS@LA.GOV
Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. The Division of Childcare and Early Childhood Education (DCCECE) utilized a custom software platform to provide payment files to the State’s accounting software, AASIS, t...
Views of Responsible Officials and Planned Corrective Action: Department of Human Services Response DHS concurs with the finding. The Division of Childcare and Early Childhood Education (DCCECE) utilized a custom software platform to provide payment files to the State’s accounting software, AASIS, to issue payments to recipients. Within this software, the AASIS coding for Sponsor Administrative costs is coded to CNP Block Consolidated (ALN 10.555) instead of CNP CACFP Sponsor Administrative (ALN 10.558) for the questioned costs of $98,474.00. Expense error corrections were not received timely by managerial accounting staff prior to the close out of SFY2023. Effective August 1, 2023, the division formerly known as DCCECE at DHS transitioned to the Arkansas Department of Education (ADE). DHS alerted financial staff with ADE in February 2024 to review the custom software platform to ensure grant expenses are being properly coded now. Due to depleted grant funds in CNP CACFP Cash in Lieu (ALN 10.558), the questioned costs of $38,341.68 in grants funds were manually moved by DHS Managerial Accounting staff into the CNP Block Consolidated grant. Managerial accounting staff have been retrained to ensure adequate federal funds are available prior to drawing. If manual adjustments are required, the division’s CFO, or their designee, must review and approve manual adjustments prior to the managerial accounting staff executing manual adjustments. DHS Office of Finance is developing an internal control documenting the prior approval process. DHS will continue to work in cooperation and coordination with ADE to provide all relevant financial information, documentation, or other items necessary for the administrative functions of DCCECE so as not to disrupt any services. Arkansas Department of Education Response The Arkansas Department of Education, Finance unit monitors federal grant awards by using separate cost centers for each program and award year within. This process provides transparent delineation of expenses and revenues within the State’s accounting system, AASIS. Additionally, ADE Finance owns an established procedure to reconcile federal grant awards for each month, within 90 days of the month’s end. The reconciliation procedure accounts for all activity within the grants and ensures data is aligned from the federal drawdown system to the State’s accounting system, AASIS. Anticipated Completion Date: Department of Human Services Response 3/31/2024 Arkansas Department of Education Response The itemized CNP programs are reconciled using ADE procedures as of August 1,2023. ADE ensures the accuracy of data from August 1, 2023, through January 31, 2024. Contact Person: Name: Misty Eubanks Title: Deputy Secretary for Operations and Budget and Interim Chief Financial Officer Agency: Department of Human Services Address: P.O. Box 1437, Slot S201 City, State, Zip: Little Rock, AR, 72203-1437 Phone Number: 501-320-6327 Email Address: misty.eubanks@dhs.arkansas.gov Name: Amy Thomas Title: Accounting Operations Manager Agency: Arkansas Department of Education Address: Four Capitol Mall, Room 204 City, State, Zip: Little Rock, AR, 72201 Phone Number: 501-682-3636 Email Address: Amy.Thomas@ade.arkansas.gov
View Audit 298801 Questioned Costs: $1
FINDING 2023-007 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425...
FINDING 2023-007 Information on the federal program: Subject: COVID-19 - Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425D Federal Award Numbers and Years (or Other Identifying Numbers): S425D200013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Audit Findings: Material Weakness, Modified Opinion Contact Persons Responsible for Corrective Action: Regin Johnson, Title I Director Chris Akers, Treasurer Adrian Wilkerson, Chief Financial Officer Contact Phone Number and Email Address: (219) 838-1819 rjohnson@lakeridgeschools.net cakers@lakeridgeschools.net awilkerson@lakeridgeschools.net Condition: An effective internal control system was not in place at the School Corporation to ensure compliance with requirements related to the grant agreement and the Activities Allowed or Unallowed and Allowable Costs/Cost Principles compliance requirements. Context: A number of transfer adjustments were made during the audit period from Corporation fund 7923 (ESSER III) to fund 7941 (CARES Ed Stabilization). These transfers were made move payroll disbursement activity for reimbursement. Support for these adjustments was traced to School Corporation’s records to verify the Gross Payroll activity moved for all but one transaction, which totaled $27,824. The supporting documentation for this transaction exceeded the amount of the transaction. Inquiry with School Corporation officials and review of the documentation determined that the amount transferred in this transaction was based on the remaining grant budget amounts in the grant fund 7941. The transaction was not based on actual payroll disbursements as all other transfer adjustments were. The $27,824 without supporting documentation is considered questioned costs. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For future transfers of payroll disbursements, both the Treasurer and Grant Director will ensure that the amount transferred corresponds to actual, documented payroll expenses and not an aggregate salary and/or benefit expenditure. The Chief Financial Officer shall review and approve these transfers to ensure compliance. Anticipated Completion Date: Immediate
View Audit 296034 Questioned Costs: $1
Re: Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Mental Health...
Re: Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-001 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Mental Health America, Northern Kentucky and Southwest Ohio agrees with the audit finding. Corrective Action: Mental Health America, Northern Kentucky and Southwest Ohio will prepare written procedures governing the expenditures of Federal Funds. Name of Contact Person:Elizabeth Atwell, Executive Director eatwell@mhankyswoh.org (513)721-2910 Projected Completion Date: On or before June 30, 2024
February 14, 2024 City of Bellevue, Kentucky Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 Audit Findings Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Conc...
February 14, 2024 City of Bellevue, Kentucky Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 Audit Findings Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: The City of Bellevue, Kentucky agrees with the audit finding. Corrective Action: The City of Bellevue, Kentucky will prepare written procedures governing the expenditures of Federal Funds. : Name of Contact Person Lindy Jenkins City Clerk / Treasurer (859) 431-8888 Projected Completion Date: On or before June 30, 2024
Re: State Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Sanitati...
Re: State Single Audit Corrective Action Plan for the Fiscal Year Ended June 30, 2023 AUDIT FINDINGS Finding Reference Number: 2023-01 Description of Finding: No Written Policies, Procedures, or Standards of Conduct Relative to Federal Awards. Statement of Concurrence or Nonconcurrence: Sanitation District No.1 agrees with the audit finding. Corrective Action: Sanitation District No.1 will prepare written procedures governing the expenditures of Federal Funds. Name of Contact Person:Debbie Vinson, Accounting Manager dvinsonsd1.orq (859) 578-7462 Projected Completion Date: On or before June 30, 2024
Finding 2023-003 – Allowable Costs and Activities, Eligibility – Compliance Federal Award. No. 21.026 Homeowner Assistance Fund – COVID 19 Corrective Action Plan: The Commission was made aware of the sophisticated fraudulent entity through its contacts with the National Council of State Housing Agen...
Finding 2023-003 – Allowable Costs and Activities, Eligibility – Compliance Federal Award. No. 21.026 Homeowner Assistance Fund – COVID 19 Corrective Action Plan: The Commission was made aware of the sophisticated fraudulent entity through its contacts with the National Council of State Housing Agencies (NCSHA). Staff remains active in those groups, participating in weekly and monthly calls and will adopt further preventative measures that have been shown to be effective in other states. Staff has implemented a more rigorous servicer onboarding process, whereby questionable items or documentation deemed to be suspicious or potentially altered will be presented to the program director, finance staff, compliance staff, or other internal staff for further investigation. Staff does not anticipate further issues with falsified information with the enhanced onboarding procedures implemented. In addition, balances owed are verified by loan servicers, and funds are paid directly to the servicer and never to individual homeowners. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2023 and completed its investigation of the identified case. Contact Person: Steve Whitson, Director of Community Programs
View Audit 2908 Questioned Costs: $1
Finding 2023-002 – Allowable Costs and Activities, Eligibility – Compliance and Control Finding Federal Award No. 21.023 Emergency Rental Assistance Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission...
Finding 2023-002 – Allowable Costs and Activities, Eligibility – Compliance and Control Finding Federal Award No. 21.023 Emergency Rental Assistance Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. Past and ongoing measures implemented to ensure eligibility of all funds disbursed include: the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that were responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021, the Commission hired an Internal Compliance Manager and created an Internal Compliance Department who has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity was expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as “mass denial metrics” and tiered level reviews were implemented into weekly application processing. Commission staff set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative or other review measures demonstrated to be effective in other states. As program funds for direct rental and utility assistance have been expended and direct assistance applications no longer accepted, additional internal metrics and compliance review processes are being developed to apply a consistent process for examining any outstanding questioned costs and to make a final determination regarding the eligibility of disbursed funds. Completion Date: The Commission implemented additional compliance review procedures during fiscal years 2021 and 2022 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2024. Contact Person: Steve Whitson, Director of Community Programs
View Audit 2908 Questioned Costs: $1
Finding 2023-001 – Allowable Costs and Activities – Compliance and Control Finding Federal Award No. 14.231 Emergency Solutions Grant Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the ...
Finding 2023-001 – Allowable Costs and Activities – Compliance and Control Finding Federal Award No. 14.231 Emergency Solutions Grant Program – COVID 19 Corrective Action Plan: The Commission administered direct assistance according to the program rules and regulations. The Commission collected the required information and documentation to review and approve applications. Applicants submitted certified applications meeting the requirements of the program. However, the Commission staff discovered through its noncompliance review and identification processes that some program applicants provided false information and fraudulent documentation that continues to be investigated and reported to the proper authorities. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The use of program funds for direct rental assistance under this program was concluded and the final disbursements made in early May 2021. Past and ongoing measures implemented to ensure eligibility of all funds disbursed include: The Commission hiring an Internal Compliance Manager and establishing an internal compliance department in May 2021 who engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, the Commission undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. As program funds for direct rental assistance have been expended, additional internal metrics and compliance review processes are being developed to apply a consistent process for examining any outstanding questioned costs and to make a final determination regarding the eligibility of disbursed funds. Completion Date: The Commission implemented additional compliance review procedures during fiscal years 2021 and 2022, reviewed applications to identify potentially fraudulent applications during fiscal years 2022 and 2023 and expects to conclude its investigation of identified cases during fiscal year 2024. Contact Person: Steve Whitson, Director of Community Programs
View Audit 2908 Questioned Costs: $1
Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these record...
Planned Corrective Action(s): SIG-NAL will enhance internal controls by implementing formal review and approval processes for payroll, expenses, and financial reporting. The organization will require documented evidence (digital or written) of all reviews and approvals and will maintain these records in a standardized, centralized system. The Finance Team will ensure that all controls are performed and documented in accordance with 2 CFR Part 200 requirements. Updated internal control policies and procedures adopted in 2025 address these requirements and are being fully implemented. Anticipated Completion Date ● March 2026 Responsible Party ● Director of Operations, with support from the Finance Team and Executive Director
2022‐008 Grant Expenditures (Material Weakness) Recommendation: The Organization’s accounting system should be modified to accommodate expense tracking by individual grant and policies and procedures should be implemented to require direct expenses be assigned to specific grants. A method should be ...
2022‐008 Grant Expenditures (Material Weakness) Recommendation: The Organization’s accounting system should be modified to accommodate expense tracking by individual grant and policies and procedures should be implemented to require direct expenses be assigned to specific grants. A method should be established to allocate indirect costs in accordance with federal regulations. Policies and procedures are also needed to provide appropriate oversight of all grant accounting including reporting. Action Taken (Unaudited): Management has updated its control procedures to include proper written policies for the internal control over financial reporting to ensure conformity with U.S. GAAP. Dan Watkins is responsible for this corrective action. A review process and coding within the accounting system was completed in January 2025. All invoices and staff time are evaluated for the level of effort towards each grant.
ALLOWABLE ACTIVITIES AND ALLOWABLE COSTS - SIGNIFICANT DEFICIENCY Federal Program Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause During 2022 payments of rental and utility assistance were entered as batches within the financial accounting software. A se...
ALLOWABLE ACTIVITIES AND ALLOWABLE COSTS - SIGNIFICANT DEFICIENCY Federal Program Emergency Rental Assistance ALN 21.023; passed through the County of Berks Condition/Cause During 2022 payments of rental and utility assistance were entered as batches within the financial accounting software. A separate spreadsheet was utilized to track individual payments included within the batches. The original spreadsheet provided contained data entry errors. After revising for corrections, the detail provided by the Authority outlining individual payments was $472,226 lower than expenses reported in the financial reporting software and could not be reconciled by management. For 6 out of 60 cases tested, the amount paid for rent did not agree to a lease agreement or bills on file for the following reasons: (1) clerical errors, (2) duplicate payments due to multiple staff working on the same file, or (3) failure to request support before payment was made. The Authority did not have controls in place to detect the noncompliance prior to issuing payments. Recommendation We recommend the Authority revisit and strengthen internal controls over tracking individual payments for transactions entered as batches, particularly when related to federal awards. We encourage the Authority to continue working to identify the individual transactions making up the remainder of the federal expenditures under this program. We also recommend the Authority revisit and strengthen internal controls over allowable activities and allowable costs related to grant programs. Management Response The Authority launched the Emergency Rental Assistance Program (ERAP) with little administrative guidance from the U.S. Treasury. The Authority contracted with the Berks Coalition to End Homelessness (BCEH) to undertake various aspects of the Emergency Rental Assistance Program and in the late fall of 2021, the Authority began reviewing all case documentation provided by BCEH. This review eliminated the vast majority of the errors noted. The Authority also updated case documentation checklists as well as provided training for staff involved with ERAP.
View Audit 355767 Questioned Costs: $1
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