Corrective Action Plans

Program: AL 20.509 – Formula Grants for Rural Areas – Allowability & Subrecipient Monitoring Corrective Action Plan: • NDOT will continue to enhance its financial review procedures to ensure that all subrecipients provide adequate supporting documentation for expenditures, including personnel charges and cost allocations. • Training sessions will continue to be conducted for subrecipients to reinforce compliance requirements related to allowable costs, proper documentation, and cost allocation methods. • Revised internal procedures will clarify expectations for travel costs, fuel charges, personnel reimbursements, and revenue reporting to prevent improper charges to the grant. • Assigning audit staff to conduct periodic sampling throughout the year enhances our ability to ensure costs are properly supported, adapt to necessary changes, and effectively communicate updates to our subrecipients. Contact: Jodi Gibson Anticipated Completion Date: NDOT appreciates the audit’s recommendations and remains committed to ensuring compliance with Federal requirements through strengthened internal controls and enhanced subrecipient oversight. This will be an ongoing and continual effort to address anticipated compliance requirements and evolving state and federal regulations.

The organization knows and understands what are the allowable and unallowable cost and the SVOG, as well as the for documentation under 2CFR Part 200. It took tremendous effort to maintain internal controls during the pandemic closure, but with all departments informed and aligned, board of directors and leadership have re-examined organizational practices to see if there is a way to improve internal controls. The organization has designated individuals that are responsible for the compliance with all requirements under the grants, as well as the requirements for each Assistance Listing Number. In addition, the organization has engaged an external professional firm with knowledge and experience in federal awards for accounting services.

Audit testing identified that the Foundation’s detail of expenditures reimbursed under its Shuttered Venue Operators Grant (SVOG) award included fundraising expenses. After being made aware of these unallowable costs, the Foundation was able to identify additional allowable costs which could be substituted for the unallowable costs initially claimed for reimbursement. Therefore, there was no adjustment or refund needed for the SVOG awards claimed by the Foundation. Recommendation - It was recommended the Foundation ensure that personnel who are responsible for administering and overseeing new federal award activity be sufficiently knowledgeable about such federal programs, including reading the allowable costs principles referred to in the grant agreements and reviewing for subsequent guidance released by awarding agencies. Foundation’s Corrective Action Plan - To ensure compliance moving forward with federal grant opportunities, the Foundation will require staff responsible for compliance, to review all program requirements and monitor for subsequently released guidance issued by the awarding agencies.