Corrective Action Plans

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A review and training of the award set up process is being conducted to ensure all team members in Office of Sponsored Programs (OSP) follow the correct procedures for moving an advance fund number into a fully executed award. Implementation of a new electronic research administration system, Novelu...
A review and training of the award set up process is being conducted to ensure all team members in Office of Sponsored Programs (OSP) follow the correct procedures for moving an advance fund number into a fully executed award. Implementation of a new electronic research administration system, Novelution, is currently underway. Internal controls will be incorporated into this system to track advance awards and their conversion into fully executed awards. This control will improve tracking and communication via systems to avoid the duplication of fund numbers for the same award. On a quarterly basis, Research Accounting Services (RAS) will send reports of advance funds to OSP to follow up on the status. RAS is also incorporating additional reviews during the SEFA preparation process. They will review advance funds to check with OSP to see if the fully executed agreements have been received from the sponsor and if any updates are needed. Novelution will also be a more robust system that will provide full grants management for agreements in order to provide more transparency across central units that will minimize these types of errors from occurring in the future. This is expected to be completed prior to the close of FY2025.
Views of Responsible Officials: Management concurs with the recommendation. Following discussions with our Grants Director, we became aware, after submitting the SEFA to the auditors, that the pass-through federal grants in place during FY2024 needed to be added to the SEFA. To ensure proper reporti...
Views of Responsible Officials: Management concurs with the recommendation. Following discussions with our Grants Director, we became aware, after submitting the SEFA to the auditors, that the pass-through federal grants in place during FY2024 needed to be added to the SEFA. To ensure proper reporting moving forward, Sage Intacct was rolled out on July 1, 2024, as CSWE’s new accounting system. This update will help our grants and finance teams better track and report these pass-through grants on the SEFA.
Finding 514316 (2024-003)
Material Weakness 2024
2024-003 – Material Weakness – Internal Control Material Weakness in Internal Control: The following errors were noted and corrected as a result of auditing procedures on the SEFA: • CRA program federal expenditures (CFDA #14.228) were understated by $23,893. • ACL Independent Living State Grants f...
2024-003 – Material Weakness – Internal Control Material Weakness in Internal Control: The following errors were noted and corrected as a result of auditing procedures on the SEFA: • CRA program federal expenditures (CFDA #14.228) were understated by $23,893. • ACL Independent Living State Grants federal expenditures (CFDA #93.369) were overstated by $21,856 due to errors in SEFA preparation. • Several presentational errors including incorrect identifying numbers listed, incorrect award terms listed, and incorrect CFDA #’s listed for multiple awards. Recommendation: Management should continue to seek additional training for the fiscal department on preparation of the SEFA and reporting standards. In addition, review processes over the SEFA and supporting reports should be strengthened. Both the preparer and reviewer should have a clear understanding of the required minimum elements and instructions. As part of the review, all required minimum elements should be vouched to original source documents including copies of awards, grant reporting, and the trial balance profit and loss reports. Steps should be taken to prevent further adjustment of supporting profit and loss reports once reconciled without the express review and approval of the Fiscal Director. Review of the standards for supporting grant reports should be strengthened to prevent errors in reporting leading to errors on the SEFA. Any inconsistencies should be resolved before beginning the audit. Management has taken steps to identify and seek training in areas they have identified as needing improvement. Responsible Person for Corrective Action: Thomas Newman, Executive Director Corrective Action to be Taken: Management acknowledges the audit findings and the material weakness related to the preparation of the Schedule of Expenditures of Federal Awards (SEFA). The errors identified stemmed from insufficient internal controls over the preparation and review process. Additionally, there were inconsistencies in how the SEFA was prepared in previous years, compounded by a quick turnover to a new controller at year-end, which disrupted continuity and contributed to the lack of clear guidance in the SEFA preparation process. To address these challenges, management has implemented immediate corrective actions, including enhanced training for all staff involved in the SEFA preparation to ensure a thorough understanding of federal reporting standards and the required minimum elements. Furthermore, all SEFA components will be reconciled with original source documents, such as grant awards and trial balances, prior to submission for audit. Management believes that, with the new internal control measures and training in place, these errors are not expected to occur in future years. The anticipated completion date for this corrective action is 6/30/2025.
Planned Corrective Action: Management will develop internal controls and oversight over the schedule of expenditures of Federal awards. Contact Person: Name: Brianne Hoelschen Title: Controller Phone: (617) 209-5222 Email: bhoelschen@maloneyproperties.com Anticipated Completion Date:...
Planned Corrective Action: Management will develop internal controls and oversight over the schedule of expenditures of Federal awards. Contact Person: Name: Brianne Hoelschen Title: Controller Phone: (617) 209-5222 Email: bhoelschen@maloneyproperties.com Anticipated Completion Date: June 30, 2025
RECOMMENDATION: Marshall Jones recommends that the School establish a process to track the expenditures of federal awards during the year, including awards for which purchases are made on the School’s behalf by the passthrough grantor. This will better enable the School to timely prepare a complete ...
RECOMMENDATION: Marshall Jones recommends that the School establish a process to track the expenditures of federal awards during the year, including awards for which purchases are made on the School’s behalf by the passthrough grantor. This will better enable the School to timely prepare a complete and accurate SEFA. RESPONSE: DeKalb Preparatory Academy intends to hire a Chief Financial Officer (CFO) to oversee financial operations. The CFO will be responsible for ensuring accurate tracking and management of all revenues and expenditures, including those from state, local, and federal sources.
Carl Biber Chief Financial Officer 317 Western Boulevard Jacksonville, North Carolina 28546 Anticipated Completion Date: June 30, 2025 Annually, the Authority will perform additional verifications of the completeness of the Schedule of Expenditures of Federal awards by confirming directly with th...
Carl Biber Chief Financial Officer 317 Western Boulevard Jacksonville, North Carolina 28546 Anticipated Completion Date: June 30, 2025 Annually, the Authority will perform additional verifications of the completeness of the Schedule of Expenditures of Federal awards by confirming directly with the mortgagee the balance as of year-end and activity for the year then ended.
2CFR 200.510(b) requires organizations to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total of federal awards as determined in accordance with 2 CFR 200.502. The original SEFA prepared by the School...
2CFR 200.510(b) requires organizations to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total of federal awards as determined in accordance with 2 CFR 200.502. The original SEFA prepared by the School District was not complete and accurate. The School District will implement a procedure to ensure that accounting records are closed timely, internal accounts are reconciled, and appropriate workpapers are prepared to support SEFA balances. The School District will implement these procedures for the 2025 fiscal year end.
Finding Number: 2023-007 Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: Reports in Workday along with new reconciliation workpapers will be utilized to ensure a complete and accurate SEFA in FY2025. ...
Finding Number: 2023-007 Condition: Controls in place were not adequate to ensure the schedule of federal expenditures was complete and accurate. Planned Corrective Action: Reports in Workday along with new reconciliation workpapers will be utilized to ensure a complete and accurate SEFA in FY2025. Contact person responsible for corrective action: Laura Randall Anticipated Completion Date: 06/30/2025
Finding Number 2023-005 Condition: The FEMA expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Planned Corrective Action: Seek training from our auditors on the proper recording of obligated expenditures. Contact person...
Finding Number 2023-005 Condition: The FEMA expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Planned Corrective Action: Seek training from our auditors on the proper recording of obligated expenditures. Contact person responsible for corrective action: Laura Randall Anticipated Completion Date: 06/14/2024
Corrective Action Plan 2023 – 007 FINDING 2023-007 Contact Person Responsible for Corrective Action: Kevin Beaver, Clerk – Treasurer Contact Phone Number and Email Address: Ph. 812-533-1053 Kevin.Beaver@westterrehautein.gov Views of Responsible Officials: We Concur with the SBOA Findings Finding Sub...
Corrective Action Plan 2023 – 007 FINDING 2023-007 Contact Person Responsible for Corrective Action: Kevin Beaver, Clerk – Treasurer Contact Phone Number and Email Address: Ph. 812-533-1053 Kevin.Beaver@westterrehautein.gov Views of Responsible Officials: We Concur with the SBOA Findings Finding Subject: Scope Limitation Corrective Action Plan 1. Establish Formal SEFA Preparation Procedures The Clerk-Treasurer will develop and implement written procedures for the preparation and review of the Schedule of Expenditures of Federal Awards. Procedures will require: • Identification of all federal awards received during the year. • Verification of applicable Assistance Listing Numbers (ALNs). • Documentation supporting all reported expenditures. • Completion of a SEFA preparation checklist before submission. 2. Create and Maintain a Federal Awards Inventory The Town will establish a centralized listing of all federal awards received. The inventory will include: • Federal agency • Program name • Assistance Listing Number (ALN) • Grant period • Award amount • Annual expenditures • Pass-through entity information, when applicable The inventory will be reviewed and updated monthly. 3. Implement Reconciliation Procedures for Federal Expenditures Prior to preparation of the AFR and SEFA, federal expenditures will be reconciled to: • General ledger accounts • Grant reimbursement requests • Supporting grant documentation • Cash drawdowns and receipts Any discrepancies identified during the reconciliation process will be investigated and resolved before submission. 4. Implement Independent Review Controls An independent review of the SEFA will be performed before submission. The review will verify: • Completeness of all federal programs. • Accuracy of reported expenditures. • Correct Assistance Listing Numbers. • Agreement of reported amounts to support records and reconciliations. Evidence of review will be documented through a monthly signed and dated review checklist. 5. Strengthen Grant Documentation and Record Retention The Town will maintain separate grant files for each federal program containing: • Award agreements • Amendments • Reimbursement requests • Financial reports • Supporting expenditure documentation • Correspondence with grantor agencies Records will be maintained in accordance with federal and state retention requirements. 6. Establish Ongoing Monitoring Procedures The Town will perform monthly reviews of federal grant activity to ensure expenditures are properly recorded and reported. Monitoring procedures will include: • Review of grant expenditures by program. • Verification of ALN assignments. • Review of grant balances and reimbursement activity. • Follow-up and correction of identified issues. Results of quarterly reviews will be documented and retained. Quarterly monitoring reports Responsible Party: Clerk – Treasurer and Town Council President. Completion Date: immediate first steps, March 3, 2027, for full implementation. _____________________________ Kevin Beaver, Clerk – Treasurer
Finding 1239044 (2023-002)
Material Weakness 2023
Upmc
PA
Federal agency: U.S. Department of Health and Human Services Assistance Listing No.: 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) Condition: Ryan White, Part C requires the use of program income under the additive method, which req...
Federal agency: U.S. Department of Health and Human Services Assistance Listing No.: 93.918, Grants to Provide Outpatient Early Intervention Services with Respect to HIV Disease (Ryan White, Part C) Condition: Ryan White, Part C requires the use of program income under the additive method, which requires program income earned from a federally funded program is added to the federal award amount and used to further program objectives. Under the method, allowable expenditures of program income are included on the SEFA. UPMC’s SEFA did not include expenditures related to program income, which were allowable. As a result, the expenditures in the SEFA for the Ryan White, Part C, were understated which resulted in the improper identification of major federal programs and, therefore, required the restatement of the previously issued Uniform Guidance report to include Ryan White, Part C as a major federal program. Corrective Action Plan: UPMC has remediated the control deficiency for the period ending December 31, 2025, by restating the 2023 Uniform Guidance report and including expenditures of program income in the SEFA for years ending on and after December 31, 2023. Completion: September 2026
Actions Planned – The City has strengthened internal controls over grant management by implementing enhanced processes and oversight. Duties have been assigned to staff that include maintaining a comprehensive and up to date list of all City grants. This individual is responsible for managing a cent...
Actions Planned – The City has strengthened internal controls over grant management by implementing enhanced processes and oversight. Duties have been assigned to staff that include maintaining a comprehensive and up to date list of all City grants. This individual is responsible for managing a centralized spreadsheet that includes grant documents, funding amounts, key requirements, and other supporting information. Grant documents are reviewed including for indication of federal funding. Minutes of the City Council and Economic Development Authority are reviewed and tied to the spreadsheet. Bank deposits are reviewed daily to identify any grant-related receipts. The spreadsheet is reviewed and updated frequently to ensure accuracy and completeness. These actions bolster the City’s ability to track grant activity, ensure compliance, and prevent future occurrences related to the audit finding. Official Responsible – Jason Zimmerman, Finance Director Planned Completion Date – June 30, 2025 Disagreement With or Explanation of Finding – The City agrees with this finding. Plan to Monitor – The City’s grant spreadsheet is reviewed quarterly and used as a workpaper to bring together information for the annual financial audit. Grant documents are reviewed by Finance for terms including federal ALN numbers, or any indication of the City being a subrecipient. Daily bank receipts are reconciled to the bank and tied out on a daily report.
Finding 1229908 (2023-003)
Material Weakness 2023
RAP INC
DC
U.S. Department of Housing and Urban Development 2023-003 Material Weakness in Internal Control over Compliance 14.218 – Community Development Block Grant District of Columbia, Department of Housing and Community Development Contract Number: 2019-009 and 2010-38 Condition: The $200,000 predevelopmen...
U.S. Department of Housing and Urban Development 2023-003 Material Weakness in Internal Control over Compliance 14.218 – Community Development Block Grant District of Columbia, Department of Housing and Community Development Contract Number: 2019-009 and 2010-38 Condition: The $200,000 predevelopment and $3,800,000 construction loans from the District of Columbia Department of Housing and Community Development were financed with federal funding. Management and the prior auditors were not previously aware of the federal funding source, and the loan had not been evaluated for applicable federal compliance requirements under OMB Circular A-133 or the Uniform Guidance since the inception of the agreement. Recommendation: We recommend that management implement a formal process to review all loan, grant, and financing agreements to determine whether funding is derived from federal sources and whether the arrangement is subject to federal compliance or single audit requirements. This review should be performed at inception of each agreement and updated at least annually, with documentation maintained in the Organization’s debt and contract repository and reviewed by personnel responsible for compliance and financial reporting. Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: In addition to the steps mentioned in the related finding above (2023-002), management has also engaged CliftonLarsonAllen LLP to catch up with any official disclosures related to this issue including single audit compliance and any related or resulting compliance disclosures remaining to be completed. Name of the contact person responsible for corrective action: Dr. Deja Gilbert, PhD, MBA, FACHE, LPC, LMHC, President and CEO - dgilbert@gaudenzia.org Planned completion date for corrective action plan: December 31, 2026
August 20, 2026 To: Clausell & Associates, P.C. From: Mary Harrison, Executive Director of CSRA Economic Opportunity Authority, Inc. Below is the Authority’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2023, Single Audit Act audit. Comment #2023-001 ...
August 20, 2026 To: Clausell & Associates, P.C. From: Mary Harrison, Executive Director of CSRA Economic Opportunity Authority, Inc. Below is the Authority’s corrective action plan as it relates to the findings for the fiscal year ending September 30, 2023, Single Audit Act audit. Comment #2023-001 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED GENERAL Views of Responsible Officials and Planned Corrective Actions: We concur with this finding. Management is in the process of assessing the organizational structure and capacity to provide adequate financial reporting. With Board review and approval of the Authority’s financial funding sources, the Authority will require additional specialize training for fiscal staff and improve in the segregation of duties to ensure adequate internal controls are fully implemented. The Executive Director will have the overall responsibility of properly reconciling and closing out the accounting system and grant activity each month in an efficient and timely manner to eliminate the risk of significant errors occurring. Budget-to-actual schedules will be an integral part of the grant accountant analyst’s basic responsibilities. The fiscal policies and procedures will be updated with the enhancements implemented within the fiscal department. Staff will be trained on revised policies and procedures and Uniform Guidance regulations. The Executive Director will take the lead in financial reporting to ensure that all reporting meet GAAP and GAS requirements and to provide informative reports for Board and Management. All enhancements will be implemented by September 30, 2026. Concerning the preparation of external reports required by various funding sources (i.e., SF-425, DHS’s reports for LIHEAP, etc.), the Authority will ensure adequate training is performed to improve the skills and knowledge of key personnel. Policies and procedures will also be revised to support external reporting. Implementation Date: The plan correction date will be completed no later than September 30, 2026 Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action. Comment #2023-002 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION, GRANT CLOSE-OUT, AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED HEAD START AND SUPPORTIVE SERVICES FOR VETERAN FAMILIES PROGRAM FAL # 93.600 AND 64.003 (Questioned Costs - None) Views of Responsible Officials and Planned Corrective Actions: We concur with the finding. Management and staff are in the process of assessing and updating the policies and procedures over the accounting and reporting of federal and state grants and contracts. In connection with training staff on grant accounting, we are providing ongoing training on the requirements of the Uniform Guidance and the specific requirements for each individual grant award as outlined in each applicable Compliance Supplement issued by Office of Management and Budget (OMB). We are currently reconciling all cash accounts and completing and amending, where necessary, all SF-425 reports and other external reports required by each funding source (state and federal). We anticipate completing this corrective action by September 30, 2026. See also the response to Comment #2023-001. Implementation Date: The plan correction date will be completed no later than September 30, 2026. Responsible Person: Mary Harrison, Executive Director, will be responsible for the corrective action.
Condition: Management lacked adequate controls at the transaction level to ensure compliance with activities allowed or unallowed, allowable cost principles, and period of performance, which resulted in the improper inclusion of duplicate costs and costs from a prior fiscal period. Further, a lack o...
Condition: Management lacked adequate controls at the transaction level to ensure compliance with activities allowed or unallowed, allowable cost principles, and period of performance, which resulted in the improper inclusion of duplicate costs and costs from a prior fiscal period. Further, a lack of effective controls over financial reporting and over preparation of the SEFA resulted in management reporting activity on a cash basis, inconsistent with the basis of reporting established in Note 1 and with requirements established by the passthrough funding agency. Planned Corrective Action: Management will implement a new review, reconciliation and oversight process to ensure that compliance with activities allowed or unallowed, allowable cost principles, and period of performance standards are followed for future grant submissions. Contact person responsible for corrective action: Louise Arzu, Vice President, Finance Anticipated Completion Date: 9/30/2024
The County has implemented a process of internal controls where expenditures are tracked in a manner that will coincide with reporting requirements for state expenditures for SEFA reporting.
The County has implemented a process of internal controls where expenditures are tracked in a manner that will coincide with reporting requirements for state expenditures for SEFA reporting.
Finding No: 2023 001 Federal Agency: U.S. Department of Homeland Security Federal Emergency Management Agency Assistance Listing Number: 97.036 Program: COVID 19 – Disaster Grants Public Assistance (Presidentially Declared Disasters) Award Year: July 1, 2022 to June 30, 2023 Compliance Requirement: ...
Finding No: 2023 001 Federal Agency: U.S. Department of Homeland Security Federal Emergency Management Agency Assistance Listing Number: 97.036 Program: COVID 19 – Disaster Grants Public Assistance (Presidentially Declared Disasters) Award Year: July 1, 2022 to June 30, 2023 Compliance Requirement: Other – Inaccurate reporting of the Schedule of Expenditures of Federal Awards Criteria According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of federal awards (SEFA) for the period covered by the entity’s financial statements which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.303 requires non federal entities receiving federal awards to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Effective internal control should include procedures to ensure federal expenditures are accurately and completely reported on the SEFA. Conditions Found The System did not have adequate controls related to the identification and reporting of federal expenditures for the COVID 19 – Disaster Grants Public Assistance (Presidentially Declared Disasters) program on the SEFA. Specifically, the System lacked controls to ensure expenditures incurred for COVID 19 Disaster Grants Public Assistance (Presidentially Declared Disasters) program were recognized on the SEFA when obligated. As a result, $16,310,090 of FEMA expenditures were omitted from the June 30, 2023 SEFA. Cause Management did not perform appropriate risk assessment procedures related to federal awards that have unique recognition criteria such as FEMA. Specifically, there was not a control in place to ensure FEMA expenditures were recognized on the SEFA based on when the FEMA award was both obligated and expenditures were incurred. Effect Failure to establish effective internal controls over the preparation of the SEFA may prevent the System from reporting accurate program information and completing an audit in accordance with the Uniform Guidance. Questioned Cost Not applicable Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding in the Prior Year Not a repeat finding. Recommendation We recommend that the System strengthen its processes and internal controls over ensuring that proper recognition of expenditures have been reported completely and accurately on SEFA. View of Responsible Official Wellstar Health System, Inc. has implemented a control and process to ensure that expenditures are properly reflected on the SEFA. Corrective Action Plan Wellstar Health System, Inc. has implemented a control and process to ensure that expenditures are properly reflected on the SEFA at time of obligation. Anticipated Completion Date: Wellstar Health System, Inc has already implemented the corrective action. Name of Contact Person for Corrective Action: Beth Loudermilk, VP Financial Planning & Analysis
Finding 2023-001: Preparation of the Schedule of Expenditures of Federal Awards - Significant Deficiency in Internal Control Over Compliance Program: U.S. Department of Health and Human Services – Medicaid Cluster Response and Corrective Action Plan: Management agrees with finding and will develop a...
Finding 2023-001: Preparation of the Schedule of Expenditures of Federal Awards - Significant Deficiency in Internal Control Over Compliance Program: U.S. Department of Health and Human Services – Medicaid Cluster Response and Corrective Action Plan: Management agrees with finding and will develop a written policy and procedure for managing the existence of federal assistance within all contracts. Anticipated Completion Date: by June 30, 2026 Responsible Person: Virginia Lui VP, Controller
2023 006 Other – Inaccurate Reporting of the Schedule of Expenditures of Federal Awards Federal Agency: U.S. Department of Homeland Security - Pass Through – SNJ Office of Emergency Management Program Titles and ALN: Disaster Grants - Public Assistance (Presidentially Declared Disasters) (ALN 97.036...
2023 006 Other – Inaccurate Reporting of the Schedule of Expenditures of Federal Awards Federal Agency: U.S. Department of Homeland Security - Pass Through – SNJ Office of Emergency Management Program Titles and ALN: Disaster Grants - Public Assistance (Presidentially Declared Disasters) (ALN 97.036) Grant Number: Grant #4488 Proj F#2105 and Grant #4614 Proj F#690 Contact Person: Erin Cuomo, Interim Vice President IP&O Business Services; 848-932-4981 Corrective Action: The Office for Research, through its Research Administration leadership in collaboration with Institutional Planning & Operations and University Finance will develop and implement a formal Standard Operating Procedure (SOP) to establish a consistent institutional framework for the administration and oversight of federally funded capital projects, emergency recovery programs, and other non-traditional sponsored funding mechanisms. The SOP will define roles and responsibilities, establish compliance requirements, and standardize processes to ensure alignment with applicable federal regulations and institutional policies The Senior Vice President for Research, the Interim Senior Vice President & Chief Operating Officer, and the University Controller will serve as the responsible executives for oversight, approval and implementation of this SOP. Anticipated Completion Date: Completed
Recommendation: We recommend the County implement a countywide system to allow for a more automated system of tracking federal expenditures, that may include updated processes to be developed to set up new organization codes which would require grant managers to provide the required information need...
Recommendation: We recommend the County implement a countywide system to allow for a more automated system of tracking federal expenditures, that may include updated processes to be developed to set up new organization codes which would require grant managers to provide the required information needed for accurate SEFA preparation. Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has implemented new process to ensure accurate preparation of their SEFA’s.
We will reconcile the reports submitted to the federal awarding agency to the expenditures recorded in the accounting records and SEFA to ensure accurate reports going forward.
We will reconcile the reports submitted to the federal awarding agency to the expenditures recorded in the accounting records and SEFA to ensure accurate reports going forward.
Root Cause Management concurs that federal expenditures totaling approximately $5,842,346 under ALN 21.029 were omitted from the initially prepared SEFA, along with an additional $206,139 of other federal programs, for a total of $6,048,485. The omission resulted from incomplete grant tracking repor...
Root Cause Management concurs that federal expenditures totaling approximately $5,842,346 under ALN 21.029 were omitted from the initially prepared SEFA, along with an additional $206,139 of other federal programs, for a total of $6,048,485. The omission resulted from incomplete grant tracking reports not reconciled to the general ledger and grant agreements; absence of an independent secondary review; and procedures that did not fully capture pass-through and subrecipient activity. Objective Design and implement effective internal controls to ensure the SEFA is complete, accurate, and in compliance with 2 CFR §200.510(b) and §200.303; prevent recurrence of material omissions; and sustain readiness for Single Audit reporting. 1. Comprehensive Reconciliation Process Implement a standardized monthly and year-end reconciliation that ties federal award expenditures (including drawdowns and indirect costs) to the general ledger, award agreements/portals, and program manager reports. Create a SEFA Reconciliation Workbook with crosswalks by ALN, passthrough entity, award number, program, and period of performance. 2. Federal Awards Inventory & Certification Maintain a centralized Federal Awards Inventory listing all awards by ALN, award number, passthrough entity, and funding stream. Require annual certifications from responsible leadership team members confirming completeness and accuracy of reported expenditures and period-of-performance coverage. 3. Formal Review Workflow (Independent of Preparer) Establish a documented two-tier review: (1) VP of Finance prepares SEFA and reconciliation; (2) Leadership Team Members perform independent reviews using a SEFA Checklist covering ALNs, pass-throughs, subrecipient disclosures, notes (basis, indirect cost rate), and period-of-performance matching. Evidence the review via dated sign-offs. 4. Subrecipient & Pass-through Controls The VP of Finance create procedures to identify all pass-through and subrecipient transactions. Maintain subrecipient listings with amounts passed through and ensure required disclosures (ALN, pass-through numbers) are captured in SEFA. Reconcile subrecipient agreements and payment registers to SEFA. Leadership Team Members perform independent reviews for accuracy and completeness. 5. Close Calendar & Training Adopt an annual SEFA close calendar with milestones (pre-close, interim, final). Provide annual training for finance and program staff on Uniform Guidance reporting requirements and the SEFA Checklist; include updates to OMB Compliance Supplement as applicable. 6. Monitoring & Continuous Improvement Quarterly CAP monitoring by VP of Finance with status reports to the Finance Committee. Track metrics (e.g., % variance between GL and SEFA, number of checklist exceptions) and remediate promptly. Conduct a pre-audit SEFA "dry run" at least 60 days before year-end close. Roles & Responsibilities • VP of Finance: CAP owner; oversight, quarterly monitoring, reports to Finance Committee, designs reconciliation and review workflow; ensures adherence to checklist and certifications; prepares SEFA, reconciliation workbook, and supporting schedules. • Responsible Leadership Team Member/Program Managers: Certify award activity and completeness; provide supporting documentation. Timeline & Milestones Immediate (within 30 days): Approve CAP; establish Federal Awards Inventory template; draft SEFA Checklist; schedule training. Short term (within 60-90 days): Implement monthly reconciliation; obtain program certifications; pilot independent review on QI data. By next year-end close: Execute full close calendar; complete pre-audit SEFA dry run; document reviewer sign-offs; present monitoring results to Finance Committee. Compliance References • 2 CFR §200.510(h): SEFA preparation requirements (completeness, ALN, pass-through, etc.). • 2 CFR §200.303: Internal controls over federal awards. Management Statement (for 2 CFR §200.511(c) submission) Management agrees with the finding and has initiated the corrective actions described herein. The CAP will be monitored quarterly by the VP of Finance, with status updates provided to those charged with governance until all actions are fully implemented and operating effectively.
Corrective Action Plan Action Item Responsible Party Monitoring Require the SEFA to be reconciled to grant expense schedules and underlying accounting records prior to submission. CFO Documented reconciliation Implement supervisory review procedures to verify the accuracy and completeness of amounts...
Corrective Action Plan Action Item Responsible Party Monitoring Require the SEFA to be reconciled to grant expense schedules and underlying accounting records prior to submission. CFO Documented reconciliation Implement supervisory review procedures to verify the accuracy and completeness of amounts reported on the SEFA. CFO / Finance Management Review prior to submission Ensure supporting documentation for all federal expenditures reported on the SEFA is maintained in accordance with record-retention policies. CFO / Accounting Staff Periodic internal review Strengthen internal controls over federal grant reporting to improve the reliability of SEFA preparation and reduce the risk of recurrence. CFO / Board Finance Committee Annual oversight review ________________________________________ Management Response In FY 2026, management implemented updated and comprehensive policies and procedures designed to strengthen internal controls and promote consistent accounting and administrative practices. These updates establish clearer documentation requirements, defined responsibilities, and improved oversight to support compliance with applicable regulations and safeguard organizational records and financial information. In FY 2026, management also established a separate grant bank account to strengthen the segregation and monitoring of federal award funds, improving the tracking, accountability, and reconciliation of federal expenditures. In addition, management will update the organization’s Federal Financial Reporting Policy to formally include procedures for the preparation, reconciliation, and review of the Schedule of Expenditures of Federal Awards (SEFA) to ensure accuracy, consistency, and compliance with federal reporting requirements. ________________________________________ Responsible Official: Chief Financial Officer Expected Completion Date: FY 2026
2023 – 006: Reporting - Preparation of the Schedule of Expenditures of Federal Awards (SEFA) (Repeat Finding: 2021-007 and 2022-006) Condition: During fiscal year 2023, the Organization did not have adequate controls in place to ensure the SEFA accurately reflected each award's federal agency and as...
2023 – 006: Reporting - Preparation of the Schedule of Expenditures of Federal Awards (SEFA) (Repeat Finding: 2021-007 and 2022-006) Condition: During fiscal year 2023, the Organization did not have adequate controls in place to ensure the SEFA accurately reflected each award's federal agency and assistance listing number. There were differences between the SEFA and the grant agreements/compliance supplements, requiring adjustments to the SEFA. Corrective Action Plan: As of October 1, 2024, the start of FY25 QuickBooks has been the only software used, and Revenue and Disbursements are being classed by Fund. General ledgers are now reconciled monthly. Each grant will have its own folder and required information to assure an accurate SEFA can be completed will be included. Management will reconcile SEFA amounts to the general ledger and review federal agency names and assistance listing numbers against grant documentation.
2023 - 007: Reporting: Preparation of the Schedule of Expenditures and Federal Awards (SEFA) (Repeat Finding:2019-007 and 2020-007, 2021-006 and 2022-008) Condition: During fiscal year 2023, the Governmental Department did not have sufficient controls to ensure the SEFA accurately reflected each awa...
2023 - 007: Reporting: Preparation of the Schedule of Expenditures and Federal Awards (SEFA) (Repeat Finding:2019-007 and 2020-007, 2021-006 and 2022-008) Condition: During fiscal year 2023, the Governmental Department did not have sufficient controls to ensure the SEFA accurately reflected each award’s federal expenditures. There were differences noted in reconciling expenditures from the original SEFA to the trial balance. These errors were corrected through adjustments proposed as part of the audit, and the final version of the SEFA reconciles to the Governmental Department’s general ledger. Corrective Action Plan: Management of the Tribe realizes the importance of the SEFA and will be sure that the SEFA matches the general ledger and accurately reflects each awards federal expenses. With moving reconciliation processes to monthly from annual this will greatly increase the accuracy of the SEFA.
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