Corrective Action Plans

Finding 501119 (2023-002)

Material Weakness 2023

IL

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303 § 200.332

Corrective Action Plan: Trillium Place will update the sub-award contracts to include all required elements, including: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Contact Person(s): Ann C...

Corrective Action Plan: Trillium Place will update the sub-award contracts to include all required elements, including: FAIN, ALN number and title, name of the federal awarding agency, UEI, indirect cost rate, Single Audit requirements, and a suspension and debarment clause. Contact Person(s): Ann Campen Anticipated Completion Date: 12/31/2024

View Audit 323383

Finding 501115 (2023-001)

Material Weakness 2023

The Carle Foundation

IL

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.430

Corrective Action Plan: SOR II grant leadership evaluated its process for preparing and reviewing time tracking for this award and implemented procedures to ensure appropriate documentation of personnel costs is complete and accurate. The prior year's finding was corrected with the pay period ending...

Corrective Action Plan: SOR II grant leadership evaluated its process for preparing and reviewing time tracking for this award and implemented procedures to ensure appropriate documentation of personnel costs is complete and accurate. The prior year's finding was corrected with the pay period ending 9/23/2023, which resulted in this repeat finding for the year ended 12/31/2023. Hourly staff are clocking into the appropriate cost center and salaried staff are submitting hours to payroll to ensure the proper tracking of time. Contact Person(s): Heather Hintz/Kathy Dams Anticipated Completion Date: 10/1/2023

View Audit 323383

Finding 501096 (2023-001)

Material Weakness 2023

Triple Bottom Line Foundation

CO

Subrecipient Monitoring Reporting

The 2023 SEFA was based on the 2022 audited SEFA schedule, updating it for the new 2023 federal programs. Since most of ICAST contracts are with state government agencies, in some instances it is not clear or apparent to ICAST staff, whether the source of funds are Federal for those state contracts...

The 2023 SEFA was based on the 2022 audited SEFA schedule, updating it for the new 2023 federal programs. Since most of ICAST contracts are with state government agencies, in some instances it is not clear or apparent to ICAST staff, whether the source of funds are Federal for those state contracts. The initial SEFA submission was identified as preliminary and was subsequently updated as ICAST learned more about the source of the state funds. The accrual figures were subject to ongoing deliberations with the state and federal agencies that led to delays in addressing the final reconciliation. ICAST is experiencing delays as long as six months for approval and payment of its invoices by both the state and the federal agencies monitoring its program funds. ICAST has addressed this finding in the following manner: 1. Management and staff will be taking refresher training on the Uniform Guidance requirements. New staff will be trained on it. 2. ICAST has begun to clarify upfront the source of funds for all contracts with its funders. Also ICAST is consolidating all contracts into a central location, with clear indication of the source of funds, to ensure complete and accurate records are available to management and staff when assessing programs for inclusion/exclusion on the SEFA. 3. ICAST continues to hire and train additional financial/accounting staff and management to ensure financial records are reviewed every month and items are followed up and resolved in a timely manner. 4. ICAST is reorganizing its accounting recordkeeping process, to ensure program information is more transparent and readily available.

View Audit 323382

Finding 501093 (2023-001)

None 2023

Neighbor Network of Northern Nevada

NV

Cash Management

Views of Responsible Officials and Planned Corrective Action: Management acknowledges the terminations. The Board of Directors of the Neighbor Network of Northern Nevada determined not to seek an appeal of the Department’s decision. No corrective action was requested, required, or deemed necessary.

View Audit 323378

Finding 501092 (2023-006)

Significant Deficiency 2023

Brighter Tomorrows, Inc.

NY

Allowable Costs / Cost Principles

2023-006. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: An allocation for costs within the administrative components of the budget was not maintained. A percentage of the total administrative budget was requ...

2023-006. Allowable Costs/Cost Principles United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: An allocation for costs within the administrative components of the budget was not maintained. A percentage of the total administrative budget was requested for reimbursement based on an estimate of costs expended. Recommendation: The Organization should implement procedures to ensure that administrative related charges to the program are documented by an allocation calculation. Corrective Action: The Organization will implement procedures to ensure an allocation for administrative related expenses is performed and documented. Responsible Contact Person(s): Dolores Kordon, Executive Director, will be responsible for resolving this matter. Anticipated Completion Date: December 31, 2024. Contact Information: Dolores Kordon, Executive Director Brighter Tomorrows, Inc. P.O. Box 706 Shirley, New York 11967

View Audit 323358

Finding 501091 (2023-005)

Significant Deficiency 2023

Brighter Tomorrows, Inc.

NY

Allowable Costs / Cost Principles Cash Management Matching / Level of Effort / Earmarking

2023-005. Match Source Documentation United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: Source documentation was not maintained to support costs applied to the match. Recommendation: The Organization should maintain an accounting for all funds ...

2023-005. Match Source Documentation United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: Source documentation was not maintained to support costs applied to the match. Recommendation: The Organization should maintain an accounting for all funds expended attributed to meeting the match requirement, as well as the source documentation. Corrective Action: The Organization will implement procedures to ensure accounting for funds expended, as well as source documentation, is maintained for costs attributed to meeting the match requirement. Responsible Contact Person(s): Dolores Kordon, Executive Director, will be responsible for resolving this matter. Anticipated Completion Date: December 31, 2024.

View Audit 323358

Finding 501090 (2023-004)

Significant Deficiency 2023

Brighter Tomorrows, Inc.

NY

Special Tests & Provisions HUD Housing Programs

2023-004. Special Tests and Provisions United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: There were instances in which comparable rents for the area were not documented and maintained in tenant files. Recommendation: The Organization should im...

2023-004. Special Tests and Provisions United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: There were instances in which comparable rents for the area were not documented and maintained in tenant files. Recommendation: The Organization should implement procedures for supervisory review of documentation and approval for all tenant files to ensure reasonable rent is charged. Corrective Action: The Organization will ensure written documentation is maintained in tenant files, to support that the grant funds to pay rent were used for reasonable rent in relation to comparable rent in the area. Responsible Contact Person(s): Dolores Kordon, Executive Director, will be responsible for resolving this matter. Anticipated Completion Date: December 31, 2024.

View Audit 323358

Finding 501089 (2023-003)

Significant Deficiency 2023

Brighter Tomorrows, Inc.

NY

Cash Management Special Tests & Provisions

2023-003. Written Intake Procedures United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: The Organization was unable to provide written policies and procedures with respect to intake and the calculation of rent. Recommendation: The Organization s...

2023-003. Written Intake Procedures United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: The Organization was unable to provide written policies and procedures with respect to intake and the calculation of rent. Recommendation: The Organization should complete the written policies and procedures to comply with the written intake documentation and rent calculation. Corrective Action: The Organization will maintain the written intake policies and procedures, as well as rent calculations. Responsible Contact Person(s): Dolores Kordon, Executive Director, will be responsible for resolving this matter. Anticipated Completion Date: December 31, 2024.

View Audit 323358

Finding 501086 (2023-002)

Significant Deficiency 2023

Brighter Tomorrows, Inc.

NY

Allowable Costs / Cost Principles § 200.430

2023-002. Allowable Costs/Cost Principles United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: The Organization cha...

2023-002. Allowable Costs/Cost Principles United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: The Organization charged costs for staff time without source documentation that complied with Uniform Guidance. Recommendation: The Organization should maintain Personnel Activity Reports (PAR) or equivalent documentation. This reporting of time will allow each employee to accurately reflect the time work is performed, for compensation which is funded by a federal award. Corrective Action: The Organization will modify procedures to have time records reflect actual time worked by employees on PAR equivalent documentation, which will serve as support for personnel expenses funded by a federal award. Responsible Contact Person(s): Dolores Kordon, Executive Director, will be responsible for resolving this matter. Anticipated Completion Date: December 31, 2024.

View Audit 323358

Finding 501085 (2023-001)

Significant Deficiency 2023

Brighter Tomorrows, Inc.

NY

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.317

2023-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: The Organization did not have writt...

2023-001. Written Policies United States Department of Justice, Passed through New York State, Office of Victims Services Crime Victim Assistance ALN: 16.575 United States Department of Housing and Urban Development Continuum of Care Program ALN: 14.267 Condition: The Organization did not have written policies referencing these requirements. Recommendation: The Organization should update their policies and procedures manual to ensure compliance with the procurement requirements at 2 CFR 200.317-327, and the impact of 24 CFR 578.103(c). Corrective Action: The Organization will update the written policies and procedures to comply with the Uniform Guidance requirements. Responsible Contact Person(s): Dolores Kordon, Executive Director, will be responsible for resolving this matter. Anticipated Completion Date: December 31, 2024.

View Audit 323358

Finding 501084 (2023-003)

Significant Deficiency 2023

Pembina County Housing Authority

ND

HUD Housing Programs Significant Deficiency

Contact Person Derek Johnson, Managing Agent Corrective Action Plan The Authority’s management recognizes the deficiency and will corroborate with its financial institution to remediate the finding. Planned Completion Date for CAP Immediately.

View Audit 323357

Finding 501083 (2023-002)

Material Weakness 2023

Pembina County Housing Authority

ND

HUD Housing Programs Eligibility Material Weakness

Contact Person Derek Johnson, Managing Agent Corrective Action Plan The Authority’s management company has hired a Deputy Director who completes quality control audits on all tenant files periodically. The Deputy Director holds monthly meetings with all eligibility staff workers to ensure compliance...

Contact Person Derek Johnson, Managing Agent Corrective Action Plan The Authority’s management company has hired a Deputy Director who completes quality control audits on all tenant files periodically. The Deputy Director holds monthly meetings with all eligibility staff workers to ensure compliance with policies and procedures. Planned Completion Date for CAP Immediately.

View Audit 323357

Finding 501076 (2023-006)

Significant Deficiency 2023

Jvs Socal

CA

Eligibility Subrecipient Monitoring

We have created an eligibility checklist for the WIOA programs that lists all required documentation. Additional training will be provided to the WIOA intake team on required documentation. No later than November 1, 2024, AJCC Associate Directors will implement period spot checks to ensure all neces...

We have created an eligibility checklist for the WIOA programs that lists all required documentation. Additional training will be provided to the WIOA intake team on required documentation. No later than November 1, 2024, AJCC Associate Directors will implement period spot checks to ensure all necessary documents for eligibility are completed.

View Audit 323354

Finding 501075 (2023-005)

Significant Deficiency 2023

Jvs Socal

CA

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

JVS will implement a process before December 31, 2024, whereby each payroll period, a JVS Payroll department employee will 1) independently review all employee timesheet allocations, as approved by their supervisor and 2) make necessary modifications to the budgeted allocations reflected in its payr...

JVS will implement a process before December 31, 2024, whereby each payroll period, a JVS Payroll department employee will 1) independently review all employee timesheet allocations, as approved by their supervisor and 2) make necessary modifications to the budgeted allocations reflected in its payroll ERP module (Paylocity). In this manner, program labor distributions and resulting cost allocations will align to actual time incurred and permit accurate reporting for billing purposes. JVS is also researching a technological solution that will reduce the amount of time required from the above laborious effort.

View Audit 323354

Finding 501074 (2023-004)

Significant Deficiency 2023

Jvs Socal

CA

Allowable Costs / Cost Principles § 200.403

Apart from the audit observation that the work from home environment has impacted existing processes and retention of information, the issues with staff retention and turnover have presented multiples challenges in relation to continuity of knowledge base and consistent work routines. A key vacancy...

Apart from the audit observation that the work from home environment has impacted existing processes and retention of information, the issues with staff retention and turnover have presented multiples challenges in relation to continuity of knowledge base and consistent work routines. A key vacancy in the Budget & Compliance area is impacting the ability to move forward on several planned initiatives including i) develop a comprehensive key-data repository, easily accessible to parties requiring this information, ii) centralized accounting records i.e., journal entries, directly related to Federal contracts tracking and bookkeeping and iii) digitalization of underlying legal grant contracts, documents and files, as well as other important data. We are targeting full staffing no later than March 31, 2025, and these items will form part of this new hire’s cri􀆟cal path in the first 90 days at JVS.

View Audit 323354

Finding 501073 (2023-003)

Significant Deficiency 2023

Conejos County, Colorado

CO

Allowable Costs / Cost Principles Significant Deficiency

Finding 2023-003: Forest Service Schools and Roads Cluster, Federal Assistance Listing No. 10.665 U.S. Department of Agriculture Passed through Colorado Department of Treasury Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Grant No.: Title land III Type off...

Finding 2023-003: Forest Service Schools and Roads Cluster, Federal Assistance Listing No. 10.665 U.S. Department of Agriculture Passed through Colorado Department of Treasury Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Grant No.: Title land III Type offinding: Internal Control (signicant deficiency) and Compliance (noncompliance) Recommendation: The County should strengthen its internal controls with adopted policies and procedures to ensure compliance with the authorized uses portion of the Title III — County Funds Code. Action Taken: Policies and procedures will be compiled to ensure compliance with the authorized uses of the Title III funds. If there are questions regarding this plan, please call the responsible party listed below. Sincerely yours, Tressesa Martinez County Administrator Conejos County, Colorado

View Audit 323338

Finding 501070 (2023-001)

Material Weakness 2023

Young Women's Christian Association of Metropoliatan St. Louis

MO

Reporting Subrecipient Monitoring Material Weakness

Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with...

Management is committed to ensuring we are in compliance with all Head Start Reporting required by the Department of Health and Human Services and other regulatory bodies. Management has thoroughly reviewed all the terms and conditions of its grant awards with internal management and externally with the Department of Health and Human Services and other regulatory bodies to ensure the proper completion of subaward reports in FSRS, the SF429 and other required reporting. The above noted issue was discovered during the course of the 2022 audit, but after the reporting deadlines for the 2023 year. Upon discovery of the requirement, Management took the above noted steps to become compliant with both 2022 and 2023. The finding repeated in 2023 solely due to the timing of the discover of the issue. Effective to date, all FSRS and applicable SF429 reports have been filed correctly and timely.

View Audit 323329

Finding 501065 (2023-001)

None 2023

Foundation for Puerto Rico, Inc.

PR

Reporting Internal Control / Segregation of Duties § 200.512

Management Response: This finding was identified for the submission of the 2021 Data Collection Form, and by the time the Organization established procedures to ensure that the Data Collection Form and Single Audit report are submitted within the established due date, the due date of the 2022 audit ...

Management Response: This finding was identified for the submission of the 2021 Data Collection Form, and by the time the Organization established procedures to ensure that the Data Collection Form and Single Audit report are submitted within the established due date, the due date of the 2022 audit already passed. However, the procedures will be in place for the next year’s audit to avoid the recurrence of this finding.

View Audit 323328

Finding 501064 (2023-003)

Significant Deficiency 2023

Virginia University of Integrative Medicine

VA

The University has implemented a policy to process all refunds via ACH, eliminating the risk of outstanding checks being lost in the mail. Additionally, any uncleared funds will be returned to the Secretary.

View Audit 323327

Finding 501063 (2023-002)

None 2023

Virginia University of Integrative Medicine

VA

The University will implement a policy to issue refunds within 13 days. This proactive measure ensures that any unforeseen circumstances that may arise will not impede the timely processing of refunds within the 14-day timefr ame.

View Audit 323327

Finding 501062 (2023-001)

None 2023

Virginia University of Integrative Medicine

VA

Reporting

The University has already addressed the Corrective Action Plan for this issue: • The 3rd Party Processor was contacted and they confirmed VUIM will need to provide information about 100% of the VUIM student body to Campus Ivy. • VUIM met with Campus IVY, Populi, as well as a 3rd party software dev...

The University has already addressed the Corrective Action Plan for this issue: • The 3rd Party Processor was contacted and they confirmed VUIM will need to provide information about 100% of the VUIM student body to Campus Ivy. • VUIM met with Campus IVY, Populi, as well as a 3rd party software developer to build a technology solution for aggregating the student data Campus Ivy requires but Populi could not produce, out of the box. Now, all information about all students are reported accurately and timely, by running the newly built report process and uploading it to Campus IVY every 45 days - well within the 60 day timeline required.

View Audit 323327

Finding 501059 (2023-002)

None 2023

Transtimulation Inc.

OK

Prior to commencing the initial audit the Company engaged the assistance of an outside consultant to develop a formal policy and procedure document for financial and business management systems. The document was completed prior to the completion of the audit and was provided to the auditors for revi...

Prior to commencing the initial audit the Company engaged the assistance of an outside consultant to develop a formal policy and procedure document for financial and business management systems. The document was completed prior to the completion of the audit and was provided to the auditors for review and acceptance. The auditors reviewed the document and accepted it.

View Audit 323322

Finding 501056 (2023-002)

Significant Deficiency 2023

Petersburg Redevelopment and Housing Authority

VA

HUD Housing Programs Eligibility Significant Deficiency

1.The inspector has attended an outsourced training from a reputable company that meetsthe HUD requirements and certification criteria. HQS includes requirements for allhousing types, including single and multi-family dwelling units, as well as specificrequirements for special housing types such as ...

1.The inspector has attended an outsourced training from a reputable company that meetsthe HUD requirements and certification criteria. HQS includes requirements for allhousing types, including single and multi-family dwelling units, as well as specificrequirements for special housing types such as manufactured homes. 2.The Housing Authority HCV supervisor will implement greater oversight over theHousing Quality Standards by reinforcing the quality controls and monitoring failedinspection to improve on the standards mandated by HUD regarding biannual inspectionsand failed inspections.

View Audit 323315

Finding 501055 (2023-001)

Significant Deficiency 2023

Petersburg Redevelopment and Housing Authority

VA

HUD Housing Programs Allowable Costs / Cost Principles Significant Deficiency

The Authority concurs with the findings in that PRHA’s Housing Choice Voucher program didn’t provide the EIV Income Report within 120 days for at least one tenant and the PRHA’s HCVP failed to document the biannual Housing Quality Standards (HQS) inspections for two units in accordance with the PHA’...

The Authority concurs with the findings in that PRHA’s Housing Choice Voucher program didn’t provide the EIV Income Report within 120 days for at least one tenant and the PRHA’s HCVP failed to document the biannual Housing Quality Standards (HQS) inspections for two units in accordance with the PHA’S Administrative Plan. The following corrective actions are for the EIV Income Report findings: 1.The HCV staff reviewed the tenant’s files. 2.The EIV policy and procedure has been reiterated to each staff member. 3.Internal controls have been discussed and assigned to ensure the EIV Income Reportswill be run within 120 days of the tenant’s lease date.

View Audit 323315

Finding 501051 (2023-005)

Significant Deficiency 2023

Forum for Cultural Engagement, Inc.

NY

Cash Management Reporting Significant Deficiency § 200.303

Views of Responsible Officials and Action Taken: FCE implemented new internal controls in the fourth quarter of 2023 and has continued to document all draw down requests, review thereof, and approvals.

View Audit 323314

Corrective Action Plans

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