Corrective Action Plans

Finding 2025-001 Significant deficiency in internal control in internal control over compliance with allowable costs/cost principles requirements. Contact Person(s): Nicholas Lee, Chief Financial Officer Corrective action planned: Management has enhanced internal controls within the expense reporting platform by adding additional key trigger words designed to flag potentially unallowable costs. These automated alerts prompt users to review and validate whether a charge is allowable or unallowable prior to submission. In addition, the Finance Department will implement mandatory annual training sessions for managers and above to reinforce allowable costs principles and expense documentation requirements. Updated reference materials included written guidance will be published on the Finance Department intranet for ongoing access by staff. These actions are intended to strengthen preventative controls, improve user awareness, and reduce the risk of unallowable costs being charged to federal and other restricted funding sources. Anticipated completion date: August 31, 2026

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing and Section 8 Vouchers Programs to ensure that established internal control policies are being followed on a timely basis. Bart Cook, Executive Director, is responsible for implementing this corrective action by September 30, 2025.

View of Responsible Officials and Corrective Actions: The Authority has recognized the deficiencies related to payroll and will implement internal control procedures that will ensure compliance with the Authority's internal control policies and personnel policy. Julio Marenco, Interim Executive Director, will be responsible to implement this corrective action by June 30, 2025.

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management partially disagrees with the characterization of the finding. The Organization had an established cost allocation methodology in place and provided documentation outlining the allocation basis and percentages applied to shared nonpayroll costs. The allocation methodology was reasonable, consistently applied, and based on operational usage. The matter identified during audit testing relates to a difference in interpretation regarding the allocation percentage applied to certain costs. The federal project expected 100% allocation of specific costs directly to the program, whereas the Organization allocated costs proportionally based on a documented cost allocation methodology. The variance was not due to a lack of methodology, but rather a disagreement regarding the appropriate allocation basis under the specific award expectations. While management maintains that the allocation approach was reasonable and consistently applied, we acknowledge the auditor’s interpretation and will revise our documentation and review procedures to ensure alignment with the awarding agency’s expectations going forward. The Organization will accept the adjustment and strengthen formal documentation to eliminate ambiguity in future allocations.Status: Corrective Action Taken Corrective action planned: Management has organized their general ledger to allow for better matching and coding to better identify unallowable costs during the billing process. Additionally, necessary staff were trained on the tracking and approving expenditure on federal cost principles. Reviews will be made on quarterly baises, and all necessary documentation is collected and reviewed. • Develop and formally adopt a written Cost Allocation Plan identifying allocation methodologies. • Implement pre-charge review controls for all federal expenditures. • Establish general ledger coding for unallowable costs. • Provide cost principles training to approving staff. • Conduct periodic allocation consistency reviews. Anticipated completion date: April 2026

For every program that Twin Oaks operates, there is an approved budget by the grantor agency that includes incentives for modifications and awards for youth behavior. Twin Oaks will strictly go by these approved budgets and better document the purpose. In addition, Benjie Read CFO and Felecia Read Staff Accountant, will educate financial staff on using proper allocation schedules and proper supporting documentation. Expense allocation schedules will be updated periodically whenever program additions or deletions occur with a minimum of twice per year. Twin Oaks has already replaced expense reproting software that was inadequately providing backup documentation with a new system which has greatly improved our accuracy and documentation. Also, our systems have greatly improved since we started with quarterly reporting to our CBCs, especially NWF Health Network, who have greatly assisted in our correct allocation of expenses. This education process will be completed within 90 days of completion of audit.

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook, Executive Director, is responsible for implementing this corrective action by September 30, 2024.

Contact Person: Susie Novak Boelter, Executive Director Corrective Action Plan: The Food Bank will review their procedures for allocating expenses to grants to ensure only allowable expenses are charged to the grant and all expenses are properly approved and the approval documentation is maintained. Completion Date: Immediately

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook, Executive Director, is responsible for implementing this corrective action by September 30, 2023.