Corrective Action Plans

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Management agrees with the finding and plans to reinforce eligibility review procedures, provide additional staff training, and perform periodic supervisory reviews to ensure eligibility determinations are properly supported before benefits are authorized.
Management agrees with the finding and plans to reinforce eligibility review procedures, provide additional staff training, and perform periodic supervisory reviews to ensure eligibility determinations are properly supported before benefits are authorized.
Management's Response: The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure tha...
Management's Response: The Program will develop an internal procurement policy with reference to the appropriate Federal, State, and local laws, regulations, and standards. The documented policy will be used when initiating and approving purchases under Federal grant programs, so they can ensure that they are in compliance with Uniform Guidance. Until it is written, procurement standards will be reviewed and followed. Completion Date: Discussion is ongoing regarding the plan.
Management will enhance its review of grant reimbursement requests by comparing billed amounts to supporting expense detail before submission and resolving any differences timely. Additional billing review training has been implemented, and management will continue working with the funding agency to...
Management will enhance its review of grant reimbursement requests by comparing billed amounts to supporting expense detail before submission and resolving any differences timely. Additional billing review training has been implemented, and management will continue working with the funding agency to resolve the overpayment.
The County will enhance its internal controls over reporting and review federal guidance for reporting under the Coronavirus State and Local Fiscal Recovery Funds.
The County will enhance its internal controls over reporting and review federal guidance for reporting under the Coronavirus State and Local Fiscal Recovery Funds.
See response to finding 2025-010
See response to finding 2025-010
The Commission will implement policies and procedures to ensure that the audit is completed and submitted in a timely manner.
The Commission will implement policies and procedures to ensure that the audit is completed and submitted in a timely manner.
Finding 2025-010: Noncompliance and Significant Deficiency – Allowable Activities and Allowable Costs Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will establish written cost-allocation procedures to ensure that expenditures are charged only to...
Finding 2025-010: Noncompliance and Significant Deficiency – Allowable Activities and Allowable Costs Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will establish written cost-allocation procedures to ensure that expenditures are charged only to the program receiving the benefit and that all allocations are reasonable, equitable, consistently applied, and adequately supported. The Agency will take the following actions: Cost-Allocation Procedures • Review all methodologies used to allocate shared costs among the Public Housing, Housing Choice Voucher, and other Agency programs. • Establish written procedures identifying allowable costs, allocation methods, required supporting documentation, and approval responsibilities. • Ensure costs directly benefiting one program are charged entirely to that program. • Allocate shared costs using a reasonable and documereplacented basis that reflects the benefit received by each program. • Review and update allocation methodologies whenever programs, staffing, services, or operating conditions change. Property Insurance and Prior Allocations • Review property insurance expenses to ensure costs associated with Public Housing properties are not charged to the Housing Choice Voucher Program. • Verify and correct the $14,202.98 property insurance allocation identified during fiscal year 2025. • Review the approximately $24,964.76 in similar allocation errors identified during the two preceding fiscal years. • Record all necessary correcting entries in accordance with applicable accounting requirements and guidance from the Agency’s auditor. • Retain documentation supporting the review, calculations, correcting entries, and final disposition of the prior-period amounts. Documentation and Supervisory Review • Require invoices, allocation calculations, and supporting documentation to be reviewed before expenditures are charged to a federal program. • Implement a supervisory approval process for shared costs and expenditures affecting multiple programs. • Document the allocation basis, calculation, programs charged, reviewer, and date of approval. • Periodically review significant expense accounts to identify allocation errors and ensure corrections are made promptly. • Reconcile financial reports and general-ledger activity to supporting invoices and allocation documentation. Training and Ongoing Monitoring • Provide training to accounting and administrative personnel regarding federal cost principles, allowable costs, and allocability requirements. • Ensure staff understand that federal program funds may only be used for costs that benefit that program. • Conduct periodic internal reviews of expenditures charged to the Housing Choice Voucher Program. • Report the results of monitoring activities and any unresolved allocation issues to the Executive Director and Board of Commissioners. • Provide additional training or corrective guidance when errors or inconsistencies are identified. Management will periodically evaluate compliance with the cost-allocation procedures and report the results and any unresolved deficiencies to the Board of Commissioners. Estimated Completion Date: Written cost-allocation procedures and supervisory review requirements will be implemented by October 31, 2026. The review and correction of the fiscal year 2025 property insurance allocation and prior-year allocation errors will be completed by December 31, 2026, with quarterly monitoring thereafter. Responsible Parties: Executive Director, financial and accounting personnel, applicable program staff, contracted accounting professionals, and Board of Commissioners.
Finding 2025-009: Noncompliance – Special Tests and Provisions Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will establish written procedures and a compliance calendar addressing waiting-list administration, annual utility allowance reviews, an...
Finding 2025-009: Noncompliance – Special Tests and Provisions Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will establish written procedures and a compliance calendar addressing waiting-list administration, annual utility allowance reviews, and required inspection quality-control reviews. The Agency will take the following actions: Waiting-List Administration • Review existing waiting-list records and procedures. • Maintain documentation supporting applications, preferences, applicant selections, withdrawals, removals, updates, and offers of assistance. • Ensure applicants are selected in accordance with the Administrative Plan and documented waiting-list order. • Restrict and monitor access to waiting-list records. • Periodically reconcile system-generated waiting-list reports to supporting documentation. • Conduct and document periodic waiting-list purges in accordance with the Administrative Plan. Utility Allowances • Complete and document an annual review of the Voucher program’s utility allowance schedules. • Retain utility rates, consumption information, calculations, conclusions, and supporting documentation. • Present revisions to the Board for approval when an adjustment is warranted. • Document the review even when no change to the utility allowance schedule is required. Inspection Quality Control • Establish procedures for selecting and completing the required number of quality-control inspections. • Ensure the quality-control sample is selected in accordance with applicable HUD requirements. • Use a qualified individual other than the original inspector to perform the quality-control review. • Document the units reviewed, deficiencies identified, comparison to the original inspection, and corrective action taken. • Apply the HUD inspection standard in effect for the Voucher program at the time of the inspection. • Use quality-control results to identify training needs and improve inspection consistency. Management will review compliance with these requirements periodically and report the results and any unresolved deficiencies to the Board of Commissioners. Estimated Completion Date: Written procedures and the compliance calendar will be implemented by October 31, 2026. The outstanding utility allowance review and initial inspection quality-control review will be completed by December 31, 2026, with annual and periodic monitoring thereafter. Responsible Parties: Executive Director, Housing Choice Voucher program staff, designated inspection personnel, and Board of Commissioners.
Finding 2025-008: Material Weakness in Internal Control Over Compliance – Housing Choice Voucher Program Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will develop and implement a comprehensive system of written internal controls and compliance ...
Finding 2025-008: Material Weakness in Internal Control Over Compliance – Housing Choice Voucher Program Agreement or Disagreement: The Agency agrees with the finding. Planned Corrective Action: The Agency will develop and implement a comprehensive system of written internal controls and compliance procedures for the Housing Choice Voucher Program. The Agency will also: • Develop standardized tenant-file checklists covering eligibility, income, assets, deductions, citizenship or eligible immigration status, Social Security numbers, EIV documentation, rent reasonableness, inspections, leases, HAP contracts, annual and interim reexaminations, portability, and other applicable requirements. • Require the checklist to be completed and maintained in each participant file. • Establish and document supervisory or quality-control reviews of an appropriate sample of applicant and participant files. • Correct deficiencies identified during supervisory reviews and document the corrective action taken. • Update the Administrative Plan to incorporate applicable HOTMA provisions and current HUD guidance. • Establish procedures for reviewing HUD notices, regulations, handbooks, and other program guidance. • Provide regular training to employees responsible for administering the Voucher program. • Clearly assign program responsibilities and develop written procedures to reduce dependence on the knowledge of individual employees. • Maintain a compliance calendar for recurring program responsibilities and reporting deadlines. • Provide the Board with periodic reports regarding compliance reviews, deficiencies identified, and corrective actions completed. Estimated Completion Date: Checklists and supervisory-review procedures will be implemented by October 31, 2026. Written procedures, policy updates, and initial staff training will be completed by December 31, 2026, with ongoing monitoring thereafter. Responsible Parties: Executive Director, Housing Choice Voucher program staff, designated supervisory staff, and Board of Commissioners.
Material Weakness Finding No. 2025-006: Cash Management Views of Responsible Officials and Planned Corrective Action The Organization acknowledges the importance of compliance with 2 CFR §200.305, rules for federal payments; and understood and concurred with the prior year finding (2024-006) and cur...
Material Weakness Finding No. 2025-006: Cash Management Views of Responsible Officials and Planned Corrective Action The Organization acknowledges the importance of compliance with 2 CFR §200.305, rules for federal payments; and understood and concurred with the prior year finding (2024-006) and current year renumbered recommendation (2025-006). A. U.S. Department of Health and Human Services (HHS) Substance Abuse and Mental Health Services Federal Assistance Listing Number 93.243. The Organization received this award from the HHS, Substance Abuse and Mental Health Services Administration (SAMHSA), via the State of Hawaii, Department of Health (DOH). In other words, SAMHSA awarded federal dollars to the DOH, who then sub-awarded federal dollars to the Organization. The Organization further sub-awarded to eligible community-based organizations (CBOs), for the purpose of SAMHSA emergency response grants (SERG), as a result of the impacts of the Lahaina wildfires in August 2023. Payments from the DOH, is based on the Organization’s meeting the billing parameters as established by the DOH at the time of contracting. Actual billing by the Organization to the DOH, includes the aggregation of eligible expenditures incurred by sub-recipient CBOs, that are subject to reimbursement from the Organization via the DOH reimbursement. Sub-recipient CBO invoices are reviewed and validated by the Organization’s program staff prior to submission for the Organization’s aggregation and invoicing to DOH. 1. The Organization notes the following process in place as of the June 30, 2025 fiscal year end: Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls includes the review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds. This monthly process and review controls functioned to mitigate any internal control non-compliance. 2. The Organization also notes the following processes implemented after the June 30, 2025 fiscal year end: Internal Control Environment Policy – July 2025, Updated August 2026. Established and updated the following policies: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; and Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. Effective September 2026, the Organization will implement an internal control review of the federal funds to ensure compliance with 2 CFR §200.305 for Federal Assistance Listing Number 93.243. B. U.S. Department of Health and Human Services (HHS) Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. This federal award is referred to as either Public Health Services (PHS) or the Native Hawaiian Healthcare Improvement Act (Act) federal dollars. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: 1. System, Process & Review Controls In Practice. a. System Controls. Continued to operate in an environment in which system, process & review controls of the United States Department of Health and Human Services (HHS) are practiced in processing cash (draw) transactions in both the Electronic Handbook (EHB) and Payment Management System (PMS) systems, operated by HHS. Only the director of administrative operations and the CEO have system access to the EHB and PMS systems. b. Process & Review Controls – Finance Committee & Full Board. The Organization’s monthly Board process and review controls includes the review of the Organization’s: Statement of Financial Position, Statement of Revenues and Expenditures, Statement of Revenues and Expenditures – Net Income/(Loss) by Fund, Fund Details – Additional Information and Statistics, Active Subcontract Summary, Active Subcontract Listing Related to Funds, and Native Hawaiian Health Program (Fund 007V), and Native Hawaiian Health Scholarship Program (Fund 017V). This monthly process and review controls functioned to mitigate any internal control non-compliance. c. HHS Drawdown Restriction. The Organization remained on HHS imposed drawdown restriction as of June 30, 2024 and June 30, 2025. The restriction was removed by HHS in July 2026. 2. The Organization also notes the following processes implemented after the June 30, 2025 fiscal year end: a. Internal Control Environment Policy – July 2025, Updated August 2026. Implemented and updated the following policies: Internal Control Environment; Implementation of Significant Accounting Policies; Revenue Recognition Policy, Including Federal Draws; and Implementation of Health Resources & Services Administration (HRSA) Related Policies, including cash management processes and procedures. b. Additional Process & Review Controls – EHB & PMS. Effective March 1, 2026, the Organization implemented, federal draws, process and review of internal controls implemented, via the chief of staff’s review of the director of administrative operations cash management analyses, federal grant receivable composition, reconciliation and related federal grant revenue computations, prior to any director of administrative operations and chief executive officer action in EHB and PMS, respectively. Finding No. 2025-006: Cash Management Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.
Material Weakness Finding No. 2025-005: Document Retention Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Feder...
Material Weakness Finding No. 2025-005: Document Retention Views of Responsible Officials and Planned Corrective Action The Organization understands the criteria cited re: Title 2, Subtitle A Chapter II, Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (the Uniform Guidance), §200.334, requiring “Financial records, supporting documents, statistical records, and all other non-Federal records must be retained for a period of three years from the date of submission of the final expenditure report…”, and recommendation made. The Organization further refers to the corrective action plan of Finding No. 2025-002: Subrecipient Monitoring, which describes the Organization’s implemented changes re: Subrecipient Monitoring and Management, Retroactive Subrecipient Portfolio Risk Assessment and Correction(s), and Subrecipient Policies and Procedures. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work by the Organization: A. Contractor Performance Collection and Substantiation – November 2024. Incorporated specific review procedures to ensure the timely collection and substantiation of contractor performance deliverables (e.g., products, goods, services, activities, reports), consistent with the terms and conditions of the contract. B. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. C. Discussed with respective program director(s), the implementation of initiation, consideration, decision, documentation and monitoring phased activities. D. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. E. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date. Finding No. 2025-005: Document Retention Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D. Chief of Staff.
Significant Deficiency Finding No. 2025-004: Reporting Views of Responsible Officials and Planned Corrective Action The Organization concurred with the prior year (2024-004) and current year renumbered recommendation (2025-004), acknowledging that the unexpected resignation of the former independent...
Significant Deficiency Finding No. 2025-004: Reporting Views of Responsible Officials and Planned Corrective Action The Organization concurred with the prior year (2024-004) and current year renumbered recommendation (2025-004), acknowledging that the unexpected resignation of the former independent auditor (January 2023), and the domino effect of a delay in securing a new independent auditor (April 2023) and completion of single audits continued to challenge the Organization through the fiscal year ended June 30, 2025. The Organization notes the following: A. Status and Progress of Single Audits 1. Single Audit as of fiscal year ended (FYE) June 30, 2022, filed in the Federal Audit Clearinghouse (FAC) on February 20, 2025. 2. Single Audit as of FYE June 30, 2023, filed in the FAC on March 9, 2026. 3. Single Audit as of FYE June 30, 2024, filed in the FAC on June 20, 2026. 4. Single Audit as of FYE June 30, 2025, projected for filing in the FAC no later than September 30, 2026. Note: Once the FYE June 30, 2025, single audit is filed, the Organization will no longer be delinquent in filing its single audit in the FAC. 5. Single Audit as of FYE June 30, 2026, engagement letter signed with scheduled field work to commence after the June 30, 2025, FAC filing (e.g., November 2026); with a projected on-time FAC filing no later than March 31, 2027, in compliance with 2 CFR §200.514 – Standards and scope of audit; and 2 CFR §200.512 – Report submission via Form SF-SAC: Data Collection Form, nine months after year end of the audit period. B. Policy, Process and Communications re: Single Audits, the Organization implemented the following policy, process and communications practices: 1. Financial Policies: Internal Control Environment Policy, Implementation of Significant Accounting Policies. 2. Process: Review and Approve Audit Report, including Financial Statements. 3. Communication of the status of the single audit(s) via Memo to the Board occurred in February, March, May, June and August 2026; and as a continuing practice will be completed for each Board meeting.Finding No. 2025-004: Reporting Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations and Sylvia Hussey, Ed.D., Chief of Staff.
Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h). Th...
Finding No. 2025-003: Procurement Policies Views of Responsible Officials and Corrective Action The Organization acknowledges incorporation of the procurement standards of the Uniform Guidance to its policies and procedures to ensure compliance with Federal standards, including 2 CFR §200.318(h). The Organization concurs with the prior year (2024-003) and current year renumbered recommendation (2025-003),and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Financial Policies – May 2025. Completed financial policies related to: implementation of significant accounting policies, internal control environment, cash and banking, cash disbursements and check issuance, payroll processes, procure to pay and revenue recognition policies, processes and procedures. In addition, when applicable, documenting procurement circumstances, processes, decisions and CEO approval was implemented via memo(s) to the procurement file (MTPF). B. Procurement Related Processes – May 2025. Initiated use of MTPF, and process implementation of Request(s) for Professional Services Qualifications, Request(s) for Professional Services, Request(s) for Proposal. C. HRSA Policies – July 2025. Developed HRSA related policies re: implementation of HRSA policies; executive performance evaluation, non-executive performance evaluation, executive compensation, non-executive compensation, timesheets, suspension & debarment procedure, financial management system, legislative mandates, legislative mandates process & procedure and cash management for federal draws and return of funds. D. Board Policy Provision & Awareness – August 2025. Informed the Board about the progress of the Organization’s policy framework, including the above policies. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work by the Organization: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the application of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). E. Updated procurement processes for emergency disaster recovery and support of community needs, including MTF documentation. Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date Finding No. 2025-003: Procurement Policies Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations, and Sylvia Hussey, Ed.D., Chief of Staff.
Material Weakness Finding No. 2025-002: Subrecipient Monitoring Views of Responsible Officials and Planned Corrective Action The Organization acknowledges 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, and its subrecipient monitoring and management provisions emphasizing accountability a...
Material Weakness Finding No. 2025-002: Subrecipient Monitoring Views of Responsible Officials and Planned Corrective Action The Organization acknowledges 2 CFR§ 200.331 and 2 CFR §200.332 of the Uniform Guidance, and its subrecipient monitoring and management provisions emphasizing accountability and compliance in managing federal funds and subrecipients. The Organization concurs with the prior year (2024-002) and current year renumbered recommendation (2025-002) and highlights its ongoing progressive and corrective implementation of policy and process actions. For context, the Organization’s progressive and corrective actions as of the fiscal year ended (FYE) June 30, 2024 report included the following: A. Subrecipient Monitoring and Management. Implemented internal process changes, effective November 1, 2024, specifically, prospectively, and consistently the: 1. Use of a checklist, to comprehensively assess risk of determining subrecipient or contractor classification, before entering into any subrecipient agreement; 2. Provision of identification details such as CFDA number, amount of federal funds obligated, and the award period for determined subrecipient awards; 3. Submission of programmatic and financial reports as specified in the subrecipient agreement; 4. Review of a single audit in accordance with 2 CFR Part 200, Subpart F for subrecipients that expend $750,000 or more in federal funds during a fiscal year, if applicable; and 5. Review of their audit report(s) and addressing any finding(s) related to their federal award(s), including the related appropriate corrective actions, when applicable. B. Retroactive Subrecipient Portfolio Risk Assessment and Correction(s). Performed a risk assessment of the existing subrecipient portfolio to identify risks, for the audit periods July 1, 2022 – June 30, 2023, and July 1, 2023 – June 30, 2024. The objective of this risk assessment was to identify, evaluate, and prioritize risks that could adversely impact the Organization’s ability to achieve its strategic, operational, compliance and quality assurance goals. The completion of the Organization’s portfolio risk assessment resulted in correction of identified non-compliant subrecipient agreement(s). C. Subrecipient Policies and Procedures. Updated, by December 31, 2024, the implemented financial policies and procedures aligned to the subrecipient monitoring and management provision of 2 CFR §200.331 and 2 CFR §200.332 of the Uniform Guidance, including checklists, flowcharts, samples, data sheets, data sharing agreements, etc. For the year ended June 30, 2025, to the period of the audit report date, the Organization continued the prospective implementation of the above policies and processes, including the following reflective contract review work: A. Reviewed all contracts executed between July 1, 2024 to June 30, 2025. B. Discussed with respective program director(s), the implementation of initiation, consideration, decision, documentation and monitoring phased activities. C. Worked with respective program director(s) to document in memorandum(s) to file (MTF), the basis for decision and documentation on a contract-by-contract basis. D. Initiated work with respective program contract monitors to implement and document consistent Organization wide contract monitoring processes and activities (e.g., contract, term, billing, deliverables, eligible expenditures, data input, frequency). Although as of June 30, 2025 the implementation of the resolution was not completed, the implementation continues and is expected to be fully implemented by the next audit report date. Finding No. 2025-002: Subrecipient Monitoring Contact Person(s) Responsible for Corrective Action: Sheri Daniels, Ed.D., Chief Executive Officer, Marisa Wilson, Director of Administrative Operations and Sylvia Hussey, Ed.D., Chief of Staff.
Franklin County will work to document current procedures and redevelop internal control procedures as appropriate for the management of federal funds.
Franklin County will work to document current procedures and redevelop internal control procedures as appropriate for the management of federal funds.
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Allowable Costs, Payroll Disbursements - AB Recommendation: We recommend the Commission implement procedures to ensure payroll costs charged to the Housing Voucher Cluster are properly supported, accurately allocated, and reconciled to payroll rec...
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Allowable Costs, Payroll Disbursements - AB Recommendation: We recommend the Commission implement procedures to ensure payroll costs charged to the Housing Voucher Cluster are properly supported, accurately allocated, and reconciled to payroll records. Management should review and approve payroll allocations and investigate any variances to ensure compliance with 2 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. This error was caused by HCHC’s timekeeping and payroll system, ADP. The error resulted in overtime hours for certain employees being paid twice in one pay period. ADP has admitted to the error and reimbursed HCHC for the costs. In order to ensure that this type of error does not occur again, HCHC is taking a number of steps. Payroll and Overtime Reconciliation: Human Resources will print and review the overtime report for each payroll cycle and reconcile the overtime hours reflected on the report against the applicable employees’ payroll records/pay stubs. Any discrepancies identified during this review will be researched and addressed promptly. Time and Attendance System: The Commission is transitioning to a new time and attendance system that is better aligned with the Commission’s operational and payroll needs. The goal of this transition is to strengthen timekeeping controls, improve the accuracy of payroll information, and provide clearer documentation to support payroll processing and allocation. Employee Payroll Review and Reporting Procedures: The Commission is updating the Employee Handbook to provide employees with clear guidance on reviewing their pay and reporting potential payroll discrepancies. The updated guidance will outline the process employees should follow if they believe they have been overpaid, underpaid, or identify another discrepancy with their compensation. Name(s) of the contact person(s) responsible for corrective action: Ikea Smith, HR Manager and Bei Hua, CFO Planned completion date for corrective action plan: January 1, 2027.
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Failed Inspections - N Recommendation: We recommend that the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of d...
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Failed Inspections - N Recommendation: We recommend that the Commission review their abatement procedures to ensure any unit that has not met the HQS standards is properly abated as well as review their procedures for enforcing correction of deficiencies to tenants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC believes that this finding was caused by the previous inspection company failing to properly communicate the results of its inspections. The new inspection companies are required to use the Commission’s Yardi software to schedule, perform and enter results. This will enhance the speed and accuracy of inspection reporting. In addition, the inspection companies are required to provide weekly reports that will be discussed and reviewed with the voucher team. Based on the results of the inspection the voucher team will be able to send abatement letters, warning letters, and/or proposed termination letters to ensure compliance with the inspection and abatement process. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: All corrections should be reflected by December 2026.
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Inspections - N Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that it utilizes for these inspections to ensure all inspections ...
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – HQS Inspections - N Recommendation: We recommend the Commission review its HQS inspection policies and procedures and discuss these standards with the third-party inspection company that it utilizes for these inspections to ensure all inspections are performed timely and that all necessary documentation is maintained for each inspection. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC’s third-part inspection company was not able to meet the terms of its contract or the HCVP requirements, partly due to staff turnover. As a result, HCHC terminated the contract as of the end of June, 2026, and hired two new contractors. HCHC has a third inspection company under contract to fill in when needed. Staff is providing the new contractors with a detailed SOP to ensure a mutual understanding of all necessary inspection actions. HCHC staff will meet with the inspection companies weekly to discuss progress, results and issues that arise during inspections. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: in progress all correction should be reflected by December 2026.
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Eligibility - E Recommendation: We recommend that the Commission review its process for collecting third party income support to ensure that accurate data is used as part of the rent and HAP calculation. Explanation of disagreement with audit find...
Housing Voucher Cluster – FALN No. 14.871 & 14.879 – Eligibility - E Recommendation: We recommend that the Commission review its process for collecting third party income support to ensure that accurate data is used as part of the rent and HAP calculation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HCHC staff attended a NAHRO training that provided an in-depth review of programmatic changes. In the training the HUD hierarchy of collecting documents was reviewed while also referencing the Commission’s Administrative Plan. The voucher team meets at least monthly to discuss HCVP issues, tools, and solutions that both meet the needs of the participants and comply with HUD regulations. Name(s) of the contact person(s) responsible for corrective action: Crystal Gorham, Director of Rental Assistance Planned completion date for corrective action plan: September 2026.
Corrective Action Plan: Finding 2025 – 004 corrective action is addressed in the corrective action plan for Finding 2025 – 003 as the questioned costs in 2025 – 004 relate to that finding. Management has transitioned reporting and compliance responsibilities to the Grant Manager and implemented over...
Corrective Action Plan: Finding 2025 – 004 corrective action is addressed in the corrective action plan for Finding 2025 – 003 as the questioned costs in 2025 – 004 relate to that finding. Management has transitioned reporting and compliance responsibilities to the Grant Manager and implemented oversight procedures performed by the Chief Operating Officer to ensure required reporting is completed accurately and submitted timely. Responsible Party: Michael Galea, Grant Manager Karen Johnson, Chief Operating Officer Melinda Asbury, Chief Executive Officer
Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Action Taken Upon review, it was determined that the configuration of the Sliding Fee Discount Program within our Practice Management System had been set up ...
Recommendation The Center should establish a system of internal controls to ensure that all patients receive the correct sliding fee discount. Action Taken Upon review, it was determined that the configuration of the Sliding Fee Discount Program within our Practice Management System had been set up incorrectly. Specifically, the "Slide After Insurance Method" setting was configured as CHGAMT rather than BALANCE. The Sliding Fee Maintenance settings were corrected in the system on May 27, 2026, to ensure the Sliding Fee Discount Program is applied appropriately following insurance adjudication. In addition, ConnextCare conducted a comprehensive audit of all 2026 dates of service for patients actively enrolled in the Sliding Fee Discount Program. No additional occurrences of this issue were identified. If the Cognizant or Oversight Agency for Audit has questions regarding this plan, please call: Tracy Wimmer, CFO at (315) 264-0991. Sincerely yours, Tracy Wimmer Sr. VP/Chief Financial Officer
We will correct our reporting issues with the next required report.
We will correct our reporting issues with the next required report.
Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted ...
Finding 2025-003 No Written Conflict of Interest Policy Finding: The Town does not have a written conflict of interest policy as required by 2 CFR § 200.318(c)(1). Corrective Action The Town of St. Matthews concurs with the finding. The Town recognizes the importance of maintaining formally adopted written standards of conduct governing actual, potential, and perceived conflicts of interest involving employees and governing body members who participate in the selection, award, or administration of contracts supported by federal funds. To address the finding, the Town will develop a written conflict of interest policy that complies with applicable federal requirements, including 2 CFR § 200.318(c)(1). At a minimum, the policy will: 1. Define actual, potential, and perceived conflicts of interest and prohibited conduct; 2. Identify the employees, officials, and governing body members subject to the policy; 3. Require prompt written disclosure of relevant financial interests and other potential conflicts; 4. Establish procedures for reviewing, documenting, and resolving disclosed conflicts; 5. Require affected individuals to refrain from participating in matters in which a conflict exists; 6. Establish appropriate disciplinary or corrective measures for violations; 7. Require periodic written conflict-of-interest acknowledgments and disclosures; and 8. Address the retention of acknowledgments, disclosures, determinations, and related compliance documentation. The proposed policy will be presented to the Town Council for formal consideration and adoption. Following adoption, the Town will distribute the policy to applicable employees and governing body members and provide appropriate training or written guidance regarding their responsibilities. The Town will retain completed acknowledgments, disclosures, and documentation of any conflict determinations in accordance with its applicable record-retention requirements. Management will periodically review the policy and related procedures to help ensure continued compliance with federal award requirements. Responsible Official Town Administrator Anticipated Completion Date December 31, 2026. Current Status The Town currently does not have a written conflict of interest policy.
Finding 2025-002 Federal Audit Clearinghouse Reporting Finding: The single audit reporting package and data collection form were not submitted to the Federal Audit Clearinghouse within the required timeframe established by the Uniform Guidance. Corrective Action The Town will implement procedures to...
Finding 2025-002 Federal Audit Clearinghouse Reporting Finding: The single audit reporting package and data collection form were not submitted to the Federal Audit Clearinghouse within the required timeframe established by the Uniform Guidance. Corrective Action The Town will implement procedures to ensure timely completion of audits, and submission of future Single Audit reporting requirements by: 1. Assigning responsibility for monitoring federal reporting deadlines to the Town Administrator. 2. Utilizing the services of the Town's contracted CPA to assist management in monitoring audit progress and ensuring all required reports are submitted within the timeframe required by 2 CFR §200.512. 3. Providing periodic updates to Town Council regarding the status of federal compliance requirements and reporting deadlines. Responsible Official Town Administrator Anticipated Completion Date Immediately implemented and fully operational by December 31, 2026. Current Status The Town has retained a third-party Certified Public Accountant to assist with bookkeeping, compliance monitoring, and timely submission of required reports to the Federal Audit Clearinghouse.
Finding 2025-001 Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding: Management does not internally prepare a complete SEFA and currently relies on significant assistance from the external auditor. Corrective Action We relied on our auditor to produce the SEFA. Our accounting d...
Finding 2025-001 Preparation of Schedule of Expenditures of Federal Awards (SEFA) Finding: Management does not internally prepare a complete SEFA and currently relies on significant assistance from the external auditor. Corrective Action We relied on our auditor to produce the SEFA. Our accounting department is small, and consists of one contracted individual, which makes it difficult. We will continue to evaluate our ability to produce our SEFA, with related footnotes when audits are required. Responsible Official Town Administrator Anticipated Completion Date December 31, 2026, and ongoing for all future audits. Current Status The Town does not currently have personnel with the ability to prepare the SEFA.
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