Corrective Action Plans

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Corrective Action Planned: The Organization has implemented revised procedures to strengthen controls over the allocation of payroll costs charged to federal awards. Effective January 1, 2026, payroll costs charged to grants are calculated directly from employee labor hours recorded in the Organizat...
Corrective Action Planned: The Organization has implemented revised procedures to strengthen controls over the allocation of payroll costs charged to federal awards. Effective January 1, 2026, payroll costs charged to grants are calculated directly from employee labor hours recorded in the Organization's timekeeping system and are allocated using each employee's applicable rate of pay. Under the revised process, payroll allocations are prepared using detailed labor reports that support the hours charged to each grant. Supporting documentation is maintained for each grant allocation and is reviewed monthly prior to invoicing or charging costs to the grant. The review process includes verification that labor hours charged to the grant agree to timekeeping records and that payroll costs are calculated using approved pay rates. Management believes these revised procedures provide a consistent and documented methodology for allocating payroll costs and will help ensure payroll expenditures charged to federal awards are adequately supported, accurately calculated, and in compliance with applicable grant requirements. Anticipated Completion Date: Implemented as of January 2026. Name of Contact Person Responsible: Shelley Riser, President and Chief Executive Officer (717) 761-6443
Recommendation: The Center should develop policies and procedures to help ensure pay rates are consistent with supporting employee agreements or other management-approved documentation. Corrective Action Taken: 1. Immediate Review and Correction Upon identification of the finding, the Center conduct...
Recommendation: The Center should develop policies and procedures to help ensure pay rates are consistent with supporting employee agreements or other management-approved documentation. Corrective Action Taken: 1. Immediate Review and Correction Upon identification of the finding, the Center conducted a comprehensive internal audit of pay rates for all employees hired from January 1, 2025, to the present. Any discrepancies identified during this review were promptly corrected to ensure alignment with approved documentation. 2. Staff Training Targeted training will be provided to all Human Resources and Payroll staff. This training will emphasize: The importance of accuracy in data entry and the use of self-review as a quality control tool; Accountability at both the individual and team levels for maintaining complete and accurate payroll data; and Proper preparation and retention of documentation supporting initial payroll entries and any subsequent changes. 3. Policy and Procedure Review The Center has performed a comprehensive review of its internal policies and procedures to: Ensure clear delineation of roles and responsibilities across hiring, onboarding, and payroll processes; and Provide detailed guidance on required documentation to support each step in these processes. 4. Double-Verification Process Management has reinforced a culture of shared accountability by implementing a doubleverification process. This includes: Requiring staff to review and confirm the accuracy of their own work prior to submission; and Requiring receiving staff to independently verify information and resolve any discrepancies before proceeding with further processing. 5. Continued Monitoring In addition to standard bi-weekly payroll reviews conducted by management, the Center will implement quarterly payroll system audits. These audits will verify that all payroll changes are accurate, properly documented, and supported by appropriate approvals.
Recommendation: We recommend that the City review and update internal controls to ensure that supporting documentation for allowable time charges to grant programs is properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...
Recommendation: We recommend that the City review and update internal controls to ensure that supporting documentation for allowable time charges to grant programs is properly maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management continues to reinforce the policy that requires employees funded by federal grants to document the actual time and effort spent working on those grant activities. Staff continues with the updated timekeeping method for individuals charging partial time to the Housing Choice Voucher (Section 8) program to track actual hours dedicated to the program rather than through budget allocation, and a quarterly certification form is prepared for employees that charge 100% to the Housing Choice Voucher (Section 8) program. Supervisor approvals are documented through the financial system’s electronic workflow. Reports are generated to demonstrate completion. New staff receive training on the payroll approval process to ensure consistent implementation and compliance with procedures. Name(s) of the contact person(s) responsible for corrective action: Imelda Delgado, Housing Manager Planned completion date for corrective action plan: January 2026
FA 2025-002 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass- Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Costs/Cost Pri...
FA 2025-002 Strengthen Controls over Expenditures Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass- Through Entity: Assistance Listing Numbers and Titles: Federal Award Number: Questioned Costs: Activities Allowed or Unallowed Allowable Costs/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Agriculture Georgia Department of Education 10.553 - School Breakfast Program 10.555 - National School Lunch Program 255GA324N1199 (Year: 2025) $36,927 Description: A review of employee compensation expenditures and journal entries related to the Child Nutrition Cluster revealed that the School District’s internal control procedures were not operating appropriately to ensure that employee compensation and journal entries were appropriately reviewed, approved, and documented. Corrective Action Plans: The School District will strengthen internal controls to ensure that employee compensation and journal entries charged to the Child Nutrition Cluster are properly reviewed, approved, supported, and documented. • Review and document procedures for processing and allocating employee compensation charged to the Child Nutrition Cluster. • Require appropriate supervisory review and approval of employee compensation, including time and effort documentation, payroll allocations, and related supporting documentation. • Establish a documented review and approval process for journal entries affecting Child Nutrition funds, including verification of account codes, amounts, supporting documentation, and proper authorization. • Provide training to Finance and Child Nutrition personnel on payroll documentation, allowable costs, journal entries, and federal grant requirements. • Conduct periodic reviews of payroll expenditures and journal entries to ensure required approvals and supporting documentation are maintained and any errors are identified and corrected timely. Estimated Completion Date: June 30, 2027 Contact Person: Kimberly Harrison Telephone: 912-427-1000 Email: kharrison@wayne.k12.ga.us
Finding Number: 2025-028 Finding Name: Inadequate Process to Communicate Award Information to Subrecipients Finding Condition(s): The Illinois Board of Higher Education (IBHE) does not have an adequate process in place to ensure required award information is accurately communicated to subrecipients ...
Finding Number: 2025-028 Finding Name: Inadequate Process to Communicate Award Information to Subrecipients Finding Condition(s): The Illinois Board of Higher Education (IBHE) does not have an adequate process in place to ensure required award information is accurately communicated to subrecipients of the Child Care and Development Fund (CCDF) Cluster (CCDF Cluster) program. Name of Contact Person(s): • Rebecca Heath, Assistance Chief Accountant - Illinois Board of Higher Education • Bill McCarty, Chief Financial Officer - Illinois Board of Higher Education Corrective Action(s): The IBHE is updating its grant procedure manual, adding a provision to ensure that the IBHE has an adequate process in place to ensure required information is accurately communicated to subrecipients of federal grant programs. Proposed Completion Date: September 30, 2026 – Complete
Finding Number: 2025-024 Finding Name: Failure to Provide Supporting Documentation for Payroll and Related Costs Finding Condition(s): The Illinois Department of Children and Family Services (DCFS) could not provide adequate supporting documentation to substantiate payroll and related costs claimed ...
Finding Number: 2025-024 Finding Name: Failure to Provide Supporting Documentation for Payroll and Related Costs Finding Condition(s): The Illinois Department of Children and Family Services (DCFS) could not provide adequate supporting documentation to substantiate payroll and related costs claimed for federal reimbursement under the Foster Care – Title IV-E (Foster Care), Adoption Assistance, and Temporary Assistance for Needy Families (TANF) programs. Additionally, the auditors noted that the controls to ensure required documentation is obtained to support payroll and related costs and maintained to evidence management approval of payroll information were not operating effectively. Finally, the auditors also noted that adequate internal controls have not been established to ensure the data included in the timekeeping system and used to allocate personal services expenditures to Foster Care, Adoption Assistance, TANF, and other programs operated by the DCFS is consistent with the hours reported on manual timesheets prepared by the employees and approved by supervisor. Name of Contact Person(s): • David Riley, Payroll Administrator – Illinois Department of Children and Family Services • Sarah Tucker, Associated Chief Fiscal Officer – Illinois Department of Children and Family Services • Kiersten Neswick, Chief Fiscal Officer – Illinois Department of Children and Family Services Corrective Action(s): The new quality controls, introduced in October 2024, have helped to identify and correct errors, but system modernization is needed to be fully implemented. The DCFS is working with the Illinois Department of Innovation and Technology (DoIT) and the Illinois Department of Central Management Services (CMS) to implement the systems to shift to electronic timesheets. The DCFS intends to begin using the CMS’ Central Payroll System with eTime. Proposed Completion Date: June 30, 2027
Audit Finding Reference: 2025-001 Maintain Documentation Supporting Employee Pay Rates Planned Corrective Action: We will maintain a current Memorandum of Understanding supporting the hourly pay rate charge to the program for employee pay rates. Planned Implementation Date of Corrective Action: Nove...
Audit Finding Reference: 2025-001 Maintain Documentation Supporting Employee Pay Rates Planned Corrective Action: We will maintain a current Memorandum of Understanding supporting the hourly pay rate charge to the program for employee pay rates. Planned Implementation Date of Corrective Action: November 2026 Person Responsible for Corrective Action: Valerie L. Williams
Finding 2025-002 Lack of Internal Control Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness Name of Contact Person: President, Nora Tom; Tribal Coordinator, Jacinta Martin Corrective Action Plan: The Stebbins Community Association will strengthen its internal...
Finding 2025-002 Lack of Internal Control Over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness Name of Contact Person: President, Nora Tom; Tribal Coordinator, Jacinta Martin Corrective Action Plan: The Stebbins Community Association will strengthen its internal controls over program expenditures by establishing and implementing written procedures to ensure that all costs charged to federally funded and other restricted programs are properly reviewed, supported, approved, and allowable. Management will implement the following corrective actions: 1. Written Policies and Procedures The Association will establish written procedures for reviewing expenditures to determine whether costs are allowable under applicable federal requirements, grant agreements, funding restrictions, and Association policies. 2. Pre-Approval of Expenditures Program expenditures will be reviewed and approved by authorized personnel before payment whenever practical. The reviewer will verify that the expenditure is related to an approved program activity and is necessary to accomplish the program's objectives. 3. Allowability and Cost Principles Review Before costs are charged to a federal award, designated accounting or management personnel will review the expenditure for: • Reasonableness; • Allowability; • Allocability to the applicable program or award; • Proper accounting treatment; • Consistency with applicable cost principles; • Compliance with grant or award restrictions; and • Adequate supporting documentation. 4. Supporting Documentation All expenditures will be supported by appropriate documentation, including invoices, receipts, purchase orders, contracts, timesheets, travel documentation, approval records, or other documentation demonstrating the purpose and allowability of the expenditure. 5. Program/Grant Coding Accounting personnel will ensure that expenditures are charged to the correct program, grant, funding source, and account code. Costs will not be charged to a federal award merely because funds are available. 6. Review of Unallowable Costs Management will establish procedures for identifying costs that are specifically prohibited or otherwise unallowable under applicable laws, regulations, grant agreements, or cost principles. Unallowable costs will not be charged to federal awards and, if identified after recording, will be promptly reclassified or otherwise corrected. 7. Periodic Expenditure Review Management will conduct periodic reviews of expenditures charged to federal and restricted programs. The review will include testing supporting documentation and determining whether expenditures were incurred for authorized program purposes. 8. Correcting Improper Charges If an expenditure is determined to be unallowable or improperly charged to a program, the Association will make the necessary accounting correction and, when applicable, reimburse or return funds to the appropriate funding source. 9. Employee and Management Training Employees and management personnel responsible for purchasing, accounts payable, grant administration, and financial reporting will receive training regarding allowable and unallowable costs, applicable cost principles, grant requirements, documentation requirements, and expenditure approval procedures. 10. Management Oversight The Executive Director and designated financial personnel will be responsible for monitoring compliance with these procedures and ensuring that appropriate corrective action is taken when deficiencies are identified. Proposed Completion Date: The corrective action will be implemented immediately and incorporated into the Association's ongoing purchasing, accounts payable, grant administration, and financial reporting procedures.
Warwick Public Schools has implemented several procedures to strengthen grant management, improve the accuracy and timeliness of required reporting, and ensure appropriate coordination between the Grants and Business Offices. 1. Grants Management Calendar: A shared Grants Management Calendar has bee...
Warwick Public Schools has implemented several procedures to strengthen grant management, improve the accuracy and timeliness of required reporting, and ensure appropriate coordination between the Grants and Business Offices. 1. Grants Management Calendar: A shared Grants Management Calendar has been created and is actively used by the Grants and Business Offices to monitor reporting deadlines and ensure required reports are completed and submitted on time. The calendar identifies the individual responsible for each reporting requirement and is managed by the Director of Federal Programs & Grants, Paul Heatherton. 2. Grant Tracker: A centralized Grant Tracker has been implemented to document key grant information, including the Grant Award Notification (GAN), approved budget, grant-funded positions, and grant end dates. This tracker is shared with the Grants and Business Offices and, when applicable, Human Resources. It supports coordination across departments, particularly for positions funded through grants with defined end dates, such as the Coronavirus State and Local Fiscal Recovery Funds. This process helps the district identify upcoming grant expirations and plan for the continuation or transition of funding for grant-funded positions. 3. Annual Grant Position and Funding Notifications: The Grants Office has established an annual process for providing Human Resources with a transaction notice identifying grant-funded positions and their associated grant fund numbers. This procedure strengthens communication regarding grant-funded staffing and helps ensure that positions are accurately associated with the appropriate funding sources. 4. Federal Grants Management Procedural Guide: Warwick Public Schools intends to develop a Warwick Public Schools Federal Grants Management – Procedural Guide by April 2027. This working guide will include both programmatic and financial procedures to promote consistent grant administration and ensure compliance with applicable federal, state, and grant-specific requirements. The guide will establish clear expectations for grant oversight, reporting deadlines, financial documentation, expenditure monitoring, and coordination among the Grants Office, Business Office, and other relevant departments. It will serve as a reference for staff responsible for administering and monitoring grant-funded programs and expenditures. The Grants Management Calendar, Grant Tracker, and annual grant position and funding notification procedures were implemented as of September 30, 2026. Completion of the Federal Grants Management Procedural Guide by April 2027 will serve as an additional step toward strengthening internal controls, standardizing grant administration, and supporting ongoing compliance.
Finding 1240713 (2025-004)
Material Weakness 2025
Activities Allowed or Unallowed; Allowable Costs/Cost Principles Management Response: Management acknowledges this finding. The audit identified deficiencies in payroll authorization and labor-cost allocation, including missing supervisory approval and insufficient documentation supporting the alloc...
Activities Allowed or Unallowed; Allowable Costs/Cost Principles Management Response: Management acknowledges this finding. The audit identified deficiencies in payroll authorization and labor-cost allocation, including missing supervisory approval and insufficient documentation supporting the allocation of payroll costs among federal programs. The finding resulted in $84,685 of questioned costs. Corrective Action: Nevadaworks will review and strengthen its existing payroll authorization and labor distribution procedures to ensure compliance. 1. All employees will complete time and activity records that accurately reflect work performed. 2. Employees charging time to federal programs will identify the appropriate grant/program allocation. 3. Supervisors will review and approve employee time records before payroll is processed. 4. Payroll allocations will be based on documented and supportable methodologies consistent with the employee’s actual work performed and approved cost allocation plan. 5. Finance will reconcile payroll charges to approved time/activity records on a monthly basis. 6. Any allocation changes or corrections will be documented and approved. 7. Finance will perform periodic reviews of payroll allocations for reasonableness and consistency with grant requirements. 8. Management will evaluate the questioned costs identified by the audit and coordinate with the applicable funding agency regarding any required repayment, adjustment, or other resolution. Responsible Party: Finance Manager/Controller with Program Management oversight. Target Completion: The revised payroll approval and allocation procedures will be implemented immediately and maintained on an ongoing basis. Monitoring: Finance will perform monthly payroll allocation reviews and quarterly compliance testing. Results and corrective actions will be documented and retained.
FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding No. 2025-002: Payroll Costs Charged to Federal Awards Were Not Supported by Actual Time and Effort Documentation - Material Weakness Condition and Context During testing of payroll expenditures charged to the Education Innovation and Research Progr...
FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding No. 2025-002: Payroll Costs Charged to Federal Awards Were Not Supported by Actual Time and Effort Documentation - Material Weakness Condition and Context During testing of payroll expenditures charged to the Education Innovation and Research Program (ALN 84.411), exceptions were identified where payroll costs allocated among funding sources were not supported by documentation reflecting actual time and effort performed. Specifically, 12 exceptions totaling approximately $6,600 were identified within a sample of payroll transactions tested. As a result, certain payroll costs charged to federal awards were not supported in accordance with Uniform Guidance requirements applicable to compensation for personal services. Recommendation We recommend that the Organization strengthen policies and procedures governing payroll costs charged to federal awards. Such procedures should require adequate documentation supporting actual work performed, management review and approval of payroll allocations, periodic reconciliations between payroll records and expenditures charged to federal programs, and training for employees responsible for grant administration and payroll processing. Views of Responsible Officials and Planned Corrective Actions Arts for Learning Maryland has existing procedures for allocating payroll costs to federal and non-federal funding sources. However, the Organization acknowledges the need to enhance documentation and monitoring procedures to ensure compliance with Uniform Guidance requirements. The Organization will formally document payroll allocation policies and procedures, including requirements for contemporaneous support demonstrating actual work performed by employees whose compensation is charged to multiple funding sources. Management will implement enhanced review and approval procedures for payroll allocations and will perform periodic reconciliations between payroll records and expenditures charged to federal awards. In addition, the Organization will provide training to employees involved in payroll processing, financial reporting, and grant administration regarding applicable Uniform Guidance requirements. Management will also perform periodic internal reviews to identify and address compliance issues on a timely basis. These improvements will be implemented during fiscal year 2026 to strengthen compliance with federal award requirements and prevent recurrence of similar findings.
8. 2025-008 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined...
8. 2025-008 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects. The University is developing and formalizing procedures to ensure personnel expenses are appropriately authorized, supported by institutional records, accurately allocated to benefiting activities, and periodically reviewed for consistency with federal award requirements. The planned process will establish clear roles and responsibilities among Sponsored Programs, Grant Accounting, Principal Investigators, supervisors, Payroll, Academic Affairs, and other appropriate offices involved in the administration of grant-funded personnel expenses. As part of this work, the University plans to strengthen controls surrounding payroll reconciliation, personnel and funding allocation changes, documentation of work performed, monitoring of payroll distributions, and review of salary cost transfers. Procedures will establish appropriate review and approval requirements, documentation standards, monitoring checkpoints, and processes for identifying and correcting discrepancies. The University is also evaluating its time and effort documentation and certification process to ensure it appropriately supports compensation charged to federal awards and is practical, consistent, and sustainable across the institution. As part of this review, the University is assessing faculty contract and workload structures for faculty who also manage or perform work on sponsored programs to ensure instructional, administrative, and grant-funded responsibilities are appropriately identified and supported. This assessment will include collaboration among Academic Affairs, Sponsored Programs, Human Resources, Payroll, and the Business Office to better align faculty workload, contractual responsibilities, and grant-funded activity. The recently established Office of Sponsored Programs provides additional capacity and centralized oversight for this work. The Director of Sponsored Programs, Compliance & Strategic Initiatives, in collaboration with the Business Office and other affected departments, will lead the development and documentation of these procedures, provide training and guidance to responsible employees, and establish ongoing monitoring practices to assess compliance. Final procedures, responsibilities, review frequencies, and documentation requirements will be established as the University completes its review of current processes and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress
7. 2025-007 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined...
7. 2025-007 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Planned corrective actions: Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects. The University is developing and formalizing procedures to ensure personnel expenses are appropriately authorized, supported by institutional records, accurately allocated to benefiting activities, and periodically reviewed for consistency with federal award requirements. The planned process will establish clear roles and responsibilities among Sponsored Programs, Grant Accounting, Principal Investigators, supervisors, Payroll, Academic Affairs, and other appropriate offices involved in the administration of grant-funded personnel expenses. As part of this work, the University plans to strengthen controls surrounding payroll reconciliation, personnel and funding allocation changes, documentation of work performed, monitoring of payroll distributions, and review of salary cost transfers. Procedures will establish appropriate review and approval requirements, documentation standards, monitoring checkpoints, and processes for identifying and correcting discrepancies. The University is also evaluating its time and effort documentation and certification process to ensure it appropriately supports compensation charged to federal awards and is practical, consistent, and sustainable across the institution. As part of this review, the University is assessing faculty contract and workload structures for faculty who also manage or perform work on sponsored programs to ensure instructional, administrative, and grant-funded responsibilities are appropriately identified and supported. This assessment will include collaboration among Academic Affairs, Sponsored Programs, Human Resources, Payroll, and the Business Office to better align faculty workload, contractual responsibilities, and grant-funded activity. The recently established Office of Sponsored Programs provides additional capacity and centralized oversight for this work. The Director of Sponsored Programs, Compliance & Strategic Initiatives, in collaboration with the Business Office and other affected departments, will lead the development and documentation of these procedures, provide training and guidance to responsible employees, and establish ongoing monitoring practices to assess compliance. Final procedures, responsibilities, review frequencies, and documentation requirements will be established as the University completes its review of current processes and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress
2. 2025-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined...
2. 2025-002 – Activities Allowed or Unallowed and Allowable Costs/Cost Principles – Material Weakness in Internal Controls over Compliance and Instance of Noncompliance Recommendation: The auditors recommend the University implement an internal control policy that satisfies the requirements outlined in 2 CFR section 200.430(g). Planned Corrective Action: Heritage University agrees with the recommendation and is strengthening its internal controls over personnel expenses charged to federal awards and sponsored projects. The University is developing and formalizing procedures to ensure personnel expenses are appropriately authorized, supported by institutional records, accurately allocated to benefiting activities, and periodically reviewed for consistency with federal award requirements. The planned process will establish clear roles and responsibilities among Sponsored Programs, Grant Accounting, Principal Investigators, supervisors, Payroll, Academic Affairs, and other appropriate offices involved in the administration of grant-funded personnel expenses. As part of this work, the University plans to strengthen controls surrounding payroll reconciliation, personnel and funding allocation changes, documentation of work performed, monitoring of payroll distributions, and review of salary cost transfers. Procedures will establish appropriate review and approval requirements, documentation standards, monitoring checkpoints, and processes for identifying and correcting discrepancies. The University is also evaluating its time and effort documentation and certification process to ensure it appropriately supports compensation charged to federal awards and is practical, consistent, and sustainable across the institution. As part of this review, the University is assessing faculty contract and workload structures for faculty who also manage or perform work on sponsored programs to ensure instructional, administrative, and grant-funded responsibilities are appropriately identified and supported. This assessment will include collaboration among Academic Affairs, Sponsored Programs, Human Resources, Payroll, and the Business Office to better align faculty workload, contractual responsibilities, and grant-funded activity. The recently established Office of Sponsored Programs provides additional capacity and centralized oversight for this work. The Director of Sponsored Programs, Compliance & Strategic Initiatives, in collaboration with the Business Office and other affected departments, will lead the development and documentation of these procedures, provide training and guidance to responsible employees, and establish ongoing monitoring practices to assess compliance. Final procedures, responsibilities, review frequencies, and documentation requirements will be established as the University completes its review of current processes and applicable federal requirements. Name of Responsible Party: • Director of Sponsored Programs • Grant Accountant Anticipated Completion Date: In Progress
Federal Program / Assistance Listing Number (ALN) 84.031 Finding Reference Number 2025-005 1. Finding Summary The auditor noted exceptions in payroll cost allocations and time and effort reporting in testing over the Title III program. 2. Management's Position Management agrees with the finding. Man...
Federal Program / Assistance Listing Number (ALN) 84.031 Finding Reference Number 2025-005 1. Finding Summary The auditor noted exceptions in payroll cost allocations and time and effort reporting in testing over the Title III program. 2. Management's Position Management agrees with the finding. Management Explanation Management agrees with the finding and acknowledges that the exceptions related to two (2) Title III employees who need additional training on how to properly complete the relevant forms. 3. Root Cause Analysis The root cause was a gap in understanding of how the time and effort form should be completed and how the payroll cost allocation change should be documented on the personnel action form. 4. Corrective Action(s) Management will offer training on the completion of time and effort reports as well as work with Human Resources to ensure all payroll allocations are actually reflected on hiring documents. Description of Corrective Actions To address this finding and prevent recurrence, the University will strengthen procedures to ensure payroll allocations are supported by approved personnel records and reconciled to certified time and effort documentation. These procedures and reporting controls will be routinely evaluated and reinforced through staff training and management oversight to support sustained compliance and accurate federal reporting. 5. Risk Mitigation (Required - Even if Disagreeing) The University institution recognizes the importance of accurate documentation to support payroll allocations. Accordingly, the corrective actions described above are designed to ensure adequate training and review to ensure compliance and accurate reporting. 6. Responsible Party • Office/Department: Title III Office • Title of Responsible Official: Interim Title III Director • Name (optional): ____________ _ 7. Implementation Timeline • Corrective action implemented: D Yes ~ No • If not fully implemented, expected completion date: December 31, 2026 8. Status of Corrective Action (For Prior-Year or Repeat Findings) D Fully implemented D Partially implemented D Not yet implemented Evidence of Implementation In progress, evidence is not yet available. 9. Monitoring and Sustainability The University will monitor compliance through ongoing supervisory review of payroll allocations and time and effort reports. Review procedures will be routinely evaluated and reinforced through staff training and management oversight to support sustained compliance and accurate federal reporting.
The findings from the December 31, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2025-001 – Allowable Costs/Cost Principles – U.S. De...
The findings from the December 31, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2025-001 – Allowable Costs/Cost Principles – U.S. Department of Labor (Assistance Listing Number: WIOA Cluster - 17.258, 17.259, 17.278) Passed through New York City Department of Youth and Community Development (Contract# 9060060), Workforce Development Corporation (Contract# 2025WDC005) – (Material Weakness) Material Weakness Recommendation We recommend that management implement policies, controls, and procedures to ensure that time and effort is recorded based on actual effort and approval by appropriate individuals is documented at least monthly to comply with applicable cost principles. Action Taken The New Jewish Home has implemented policies and procedures to ensure that employee time and effort charged to federally funded and other restricted programs is supported by contemporaneous documentation reflecting the actual effort performed. Employee time is recorded through the organization’s established timekeeping process and is reviewed and approved by the employee’s immediate supervisor on a payroll-period basis. This control is performed every pay period and therefore occurs more frequently than the minimum monthly review and approval standard referenced in the finding. Supervisory approval is intended to provide reasonable assurance that recorded time and effort is accurate, supported, and consistent with the employee’s actual work performed and the applicable funding requirements. Management will continue to monitor compliance with these procedures and will reinforce the requirement that time and effort records be accurately maintained and appropriately approved in accordance with organizational policies and applicable federal cost principles. The New Jewish Home will also retain the applicable timekeeping and approval documentation as evidence of the control’s operation. Completion Date: October 5, 2026
Federal Agency Name: Department of Veterans Affairs Assistance Listing Number: 64.003 Program Name: VA Supportive Services for Veteran Families Program Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: In our sample of expenditures selected ...
Federal Agency Name: Department of Veterans Affairs Assistance Listing Number: 64.003 Program Name: VA Supportive Services for Veteran Families Program Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Finding Summary: In our sample of expenditures selected for testing, we noted the following items: a) Calculation errors for payroll expenses allocated to the grant based upon review of supporting timesheets, payroll documentation and management’s true-up calculations to allocate actual costs rather than budgeted costs (5 instances). b) Identification of benefits not being allocated in a similar manner as salaries and wages (1 employee impacted). c) Grant was overcharged as it relates to a travel reimbursement (1 instance). Corrective Action Plan: Management staff will conduct a secondary review of all payroll and travel related allocations to ensure accuracy. Responsible Individuals: Teena Conrad, SSVF Program Manager, Lysa Allison, Executive Director, and Christina Thoelke, Business Manager Anticipated Completion Date: September 2026
Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition As part of our audit procedures, we selected a sample of 60 payroll transactions for review. Our testing incl...
Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition As part of our audit procedures, we selected a sample of 60 payroll transactions for review. Our testing included examining employee human resource files, including signed W-4 and I-9 forms, approved pay rates, timesheets with supervisory approval, and related payroll reports. We recalculated hours and compensation based on approved pay rates and compared the results to the payroll reports. During our review, we noted that management did not record and compensate all employee hours in the appropriate period based on the time and effort performed. Specifically, two employees were not properly compensated for one day of personal time off and 1.12 hours of overtime related to the administration of the CBS Food Program. These amounts were subsequently adjusted and paid in a later period. Recommendation We recommend that management strengthen its payroll review controls to ensure that employee compensation, including personal time off and overtime, is accurately calculated, reviewed, approved, and paid in the appropriate period. The review should include comparing approved timesheets, pay rates, payroll reports, and any leave or overtime documentation before payroll is finalized. Management should also document its review and establish a follow-up process to identify and correct payroll discrepancies timely. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: CBS Food Program will revise its compensation plan to include formal payroll processing procedures. These procedures will require an independent review of timesheets against payroll records before payroll is issued and will establish criteria and timelines for promptly investigating and correcting any discrepancies. Name of the contact person responsible for corrective action: Jonathan Shahar, CEO Jonathan@cbsfoodprogram.com Planned completion date for corrective action plan: June 30, 2026
Corrective Action: UVNR is strengthening its time-and-effort reporting procedures through the use of Timesheets.com as its primary time-and-effort reporting system. Program-specific account codes have been added to allow employees to record actual hours worked by program or cost objective when check...
Corrective Action: UVNR is strengthening its time-and-effort reporting procedures through the use of Timesheets.com as its primary time-and-effort reporting system. Program-specific account codes have been added to allow employees to record actual hours worked by program or cost objective when checking in and out. Airtable is being utilized as a supplemental tool to document employee work performance and programlevel activities. These records are reviewed during monthly supervision meetings to assess alignment between reported activities, program responsibilities, and personnel allocations. UVNR will formalize documented supervisory review and approval of employee timesheets and establish monthly reconciliation of actual hours recorded in Timesheets.com against payroll distributions and funding allocations. Any discrepancies between budgeted allocations and actual time worked will be documented and corrected accordingly. Management will periodically monitor compliance and retain supporting documentation for personnel costs charged to federal awards. Due Date of Completion: December 31, 2026 (ongoing monthly reconciliation and monitoring thereafter). Responsible Parties: Executive Director.
Responsible contact(s): Agnes, Controller, and Laura, CFO. Program Directors, Program Managers/Supervisors are accountable for approval of actual work performed. Participating staff: Steve is the allocation preparer; AP Staff Accountant after training; Trina for reconciliation; employees, supervisor...
Responsible contact(s): Agnes, Controller, and Laura, CFO. Program Directors, Program Managers/Supervisors are accountable for approval of actual work performed. Participating staff: Steve is the allocation preparer; AP Staff Accountant after training; Trina for reconciliation; employees, supervisors, and payroll support. Effective Jan 2026, AEA has replaced unsupported flat budget-based salary charges with documented allocations reflecting actual work performed. During the 1st half of 2026, allocation entries were not done monthly; starting in July 2026, the allocations entries have been done monthly. 1. Document actual activity. Employees are recording actual work by award/project and administrative or other non-Federal activity for each pay period in Salesforce. Supervisors and/or Program Managers with direct knowledge review accuracy, program benefit, and grant/category coding. A Paycom (payroll platform) check register report supplies gross pay, compensated absence, and benefit records. Payroll records cover total compensation activity. 2. Reconcile before charging awards. Steve prepares the payroll-to-award allocation. Laura has been reconciling allocations against the grant budgets, and program staff has approved the expenses before invoicing. Starting Q4, 2026, Steve will reconcile allocations to payroll and the ledger, Agnes/Trina will review and post the allocation entries; and the program staff will continue to approve before billing. 3. Control fringe and exceptions. Finance will support fringe and leave treatment under a written, consistently applied method and applicable award terms; it will not use an unsupported flat fringe percentage. Supervisors will resolve missing or changed activity records promptly. Unsupported amounts will be excluded from Federal claims pending resolution, without withholding employees earned pay. 4. Train and monitor jointly. The Salesforce support team has provided training for the employees for entering and for approval. Laura has trained the Finance, and payroll support on activity documentation, allocation changes, and deadlines. Steve will retain the approved allocation with each relevant billing package. Anticipated completion: For awards ending, Sept 30, 2026, historical review will be completed by October 15, 2026. Update written method: October 30, 2026. Anticipated completion after operating-effectiveness review: January 29, 2027.
We concur with the findingrelated to deficiencies in our approval process and thresholds set bycompany policies. We have documented our approval policies accordingly and implemented anew approval system using email starting in the fourth quarter of fiscal year 2026. This systemis designed to accurat...
We concur with the findingrelated to deficiencies in our approval process and thresholds set bycompany policies. We have documented our approval policies accordingly and implemented anew approval system using email starting in the fourth quarter of fiscal year 2026. This systemis designed to accurately capture approvals and expenses by project/grant. Comprehensivetraining sessions will be conducted forall affected employees to ensurethey are proficient in using the new system. We will also research other possible technologies to assist with thedocumentation of approvals.
Finding 1239496 (2025-001)
Material Weakness 2025
Audit period: For the Year Ended December 31, 2025 The findings for the Year Ended December 31, 2025, from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARDS SIGNIFICANT DEFICIE...
Audit period: For the Year Ended December 31, 2025 The findings for the Year Ended December 31, 2025, from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS – FEDERAL AWARDS SIGNIFICANT DEFICIENCY 2025-001 No process is in place to compare or revise budgeted amounts to allocate time to Federal programs vs. actual time recorded on manual timesheets. [repeat finding 2023-005] Recommendation: Management should establish procedures to ensure payroll costs charged to federal awards are supported by records that accurately reflect the work performed. This should include reviewing available project-level labor data, reconciling payroll allocations to supporting time and effort records, and updating allocations as necessary for each pay period to ensure costs are charged to the appropriate programs and funding sources based on actual activity here. Action Taken: We agree with the findings. During 2025, JVS implemented enhancements within Paylocity that allow employees to electronically review and update their labor allocations, strengthening internal controls over payroll cost allocation. Management has also enhanced its review and monitoring procedures surrounding labor allocation changes. While these improvements have significantly reduced the risk of misallocations, remediation efforts remain ongoing, including implementing a new payroll software in September 2026. JVS continues to refine its processes to ensure labor costs are accurately recorded and that any necessary allocation corrections are identified and addressed through timely review and adjustment procedures. Name of responsible persons: Yashica Ansberry Director of People & Culture Fahim Hakami Senior Accountant Anticipated completion date: Q4 2026
Corrective Action Planned: Management acknowledges the finding related to the lack of formal documentation maintained evidencing a hindsight review of employee working hours to verify alignment between actual hours. The Effort Reporting requirement is now met with a revamped process that includes an...
Corrective Action Planned: Management acknowledges the finding related to the lack of formal documentation maintained evidencing a hindsight review of employee working hours to verify alignment between actual hours. The Effort Reporting requirement is now met with a revamped process that includes an updated institutional effort reporting policy and development of a newly developed effort reporting workflow that aligned with the relatively recent (April 2024) implementation of new ERP system Oracle. This new process applies to those team members who have effort either charged, in-kind or cost-shared, to a grant funded project. The new Effort Reporting workflow formally went live institution wide on October 1, 2025, with a pilot implementation done in September 2025. Effort reporting is conducted monthly and requires a preview of all team members with effort allocated to grants from an automated report. Each report is reviewed for accuracy and then each line item is entered into a Smartsheet format for automated delivery of an individual effort report to each team member. A mid-month report is automated to flag and identify upcoming end dates of grant funding in preparation of the next month effort report. This mid-month review is necessary to adjust for any edits needed in preparation for the next month effort report workflow. In addition, the new process allows for follow up with escalation if individual effort report(s) are not signed by respective team member(s) within the prescribed monthly due date. Name(s) of Contact Person(s) Responsible for Corrective Action: Director Office for Sponsored Programs Anticipated Completion Date: Completion September 30, 2025, active as of October 1, 2025
The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implement policies and procedures to ensure all pay rate change letters or forms are retained in personnel file. Explanation of di...
The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implement policies and procedures to ensure all pay rate change letters or forms are retained in personnel file. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented systems and software where all pay rate changes will be documented and maintained. Name(s) of the contact person(s) responsible for corrective action: Sharon Brown, CEO Planned completion date for corrective action plan: September 30, 2026
The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implements policies and procedures to ensure appropriate allocation calculation is used and retains support for calculation. Expla...
The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implements policies and procedures to ensure appropriate allocation calculation is used and retains support for calculation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will implement procedures to ensure appropriate allocation calculations are used and documentation related to the allocation is retained. Name(s) of the contact person(s) responsible for corrective action: Sharon Brown, CEO Planned completion date for corrective action plan: December 31, 2026
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