Corrective Action Plans

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Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: Decem...
Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: December 31, 2023 The findings from the December 31, 2023 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2023-001: Community Development Financial Institutions Fund – Assistance Listing No. 21.024, Rapid Response Program, Restatement of Schedule of Expenditures of Federal Awards, Material Weakness Criteria and Condition: Recipients of federal funds are required to prepare a complete and accurate Schedule of Expenditures of Federal Awards. Additionally, recipients must establish and maintain effective internal controls over federal awards to provide reasonable assurance of accurate financial reporting Context: The Company restated the 2023 Schedule of Expenditures of Federal Awards by a material amount a result of misinterpretation of reporting requirements for loan loss reserves and allocations of other allowable purposes. Cause: The omission occurred due to a misinterpretation of reporting requirements involving the treatment of grant expenditures for the purpose of loan loss reserve funds, which differs in nature from general program expenditures. Management identified the issue and determined a change in reporting was needed to simplify tracking and reporting of federal grants, and to ensure compliance with the technical definition of expenditures in the guidance. Effect: Loan loss reserves allocated in the wrong period resulted in an understatement of total federal expenditures on the Schedule of Expenditures of Federal Awards. Recommendation: We recommend that the Company implement a formalized review process to ensure all applicable expenditures, including loan loss reserves, are properly recorded in the period in which assigned. Views of Responsible Officials and Planned Corrective Actions: We agree with the finding and have established a process to ensure all expenditures are properly included in the SEFA. Name of Contact Person: Donna Gambrell, President and Chief Executive Officer Signature of Contact Person:
The audit report was due to be received by the State of New Jersey no later than March 31, 2023. As a result, the audit was not submitted timely. Recommendation: The School should alert the auditor about new funding received during the year to give ample time to research and prepare. Action Taken: T...
The audit report was due to be received by the State of New Jersey no later than March 31, 2023. As a result, the audit was not submitted timely. Recommendation: The School should alert the auditor about new funding received during the year to give ample time to research and prepare. Action Taken: The administrator will monitor the School’s funding that they receive throughout the year and will alert the auditor as soon as they receive funding from a new program. As such, the required corrective actions have been implemented. Implementation Date: Corrective Action Plan has been implemented as of April 3, 2024. Person Responsible for Implementation: Mr. Rother, the Administrator, is the responsible party for implementation of the CAP. Telephone Number: (732)-722-5511.
Finding 560112 (2023-004)
Significant Deficiency 2023
We will reconcile all of 2024 accounts to ensure accuracy. Expenditure and reimbursement of all federal funds will be recorded timely and accurately.
We will reconcile all of 2024 accounts to ensure accuracy. Expenditure and reimbursement of all federal funds will be recorded timely and accurately.
Finding 560111 (2023-003)
Significant Deficiency 2023
We will implement more internal training with the Accounts Payable department to ensure manifests are signed.
We will implement more internal training with the Accounts Payable department to ensure manifests are signed.
Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expendit...
Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expenditures to determine single audit status, and file corresponding reports in a timely manner. Expected Completion Date June 30, 2025
Finding 560093 (2023-003)
Significant Deficiency 2023
Finding Number: 2023-003 Finding Title: Special Tests and Provisions – Davis‐Bacon Act Name of Contact Person Responsible for Corrective Action: Heidi E. Winter, County Auditor-Treasurer Corrective Action Planned: County staff will obtain and properly review the certified payrolls received from a...
Finding Number: 2023-003 Finding Title: Special Tests and Provisions – Davis‐Bacon Act Name of Contact Person Responsible for Corrective Action: Heidi E. Winter, County Auditor-Treasurer Corrective Action Planned: County staff will obtain and properly review the certified payrolls received from all contractors and subcontractors for compliance with the Davis‐Bacon Act and Title 29 U.S. Code of Federal Regulations Part 5 and ensure documentation exists to support monitoring of and compliance with this requirement. Anticipated Completion Date: December 31, 2024
Finding 560078 (2023-002)
Significant Deficiency 2023
Suspension and Debarment over COVID-19 America Rescue Plan Act Recommendation: We recommend that the Town design controls to ensure an adequate review process in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: The...
Suspension and Debarment over COVID-19 America Rescue Plan Act Recommendation: We recommend that the Town design controls to ensure an adequate review process in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town has a system in place to review contractors. A written process will be prepared to record and maintain appropriate documentation. Name of the contact person responsible for corrective action: Town Manager and Finance Director Planned completion date for corrective action plan: Since this report is overdue, the estimated date is before the start of the FY 24 audit.
Recommendation: Controls should be implemented to ensure timely filing of the audit package to the Federal Audit Clearinghouse. Views of Responsible Officials: The Organization agrees with the auditors' recommendation.
Recommendation: Controls should be implemented to ensure timely filing of the audit package to the Federal Audit Clearinghouse. Views of Responsible Officials: The Organization agrees with the auditors' recommendation.
The Business Manager will change the procedure in place for tracking assets to include a method that will identify which assets are federally connected.
The Business Manager will change the procedure in place for tracking assets to include a method that will identify which assets are federally connected.
Finding No 2023-005 “ALN #21.027 Reporting” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Corrective Action: CPA agrees with the finding. CPA has subsequently made corrections to the reports. Pro...
Finding No 2023-005 “ALN #21.027 Reporting” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Corrective Action: CPA agrees with the finding. CPA has subsequently made corrections to the reports. Proposed Completion Date: April 30, 2025
Finding No 2023-004 “ALN #20.106 Special Tests and Provisions – Revenue Diversion” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Corrective Action: CPA disagrees with this finding. Condition 1: A...
Finding No 2023-004 “ALN #20.106 Special Tests and Provisions – Revenue Diversion” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Corrective Action: CPA disagrees with this finding. Condition 1: All costs incurred by the Seaport paid initially by the Airport are reimbursed in a timely manner. For purposes of efficiency, this method is used as to reduce the number of payments to vendors being made. The Airport Division has been fully reimbursed. CPA will be seeking grantor approval for the use of this method even though this practice of recordkeeping has been in place for more than 20 years. Condition 2: CPA believes that the costs incurred pertain to the operational costs of the airport. Per the Federal Register / Vol. 64, No. 30, “Operating costs for an airport may be both direct and indirect and may include all of the expenses and costs that are recognized under the generally accepted accounting principles and practices that apply to the airport enterprise funds of state and local government entities.” Proposed Completion Date: June 30, 2025
Finding No 2023-003 “ALN #20.106 Equipment and Real Property Management” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Alex Tudela, Procurement Officer Corrective Action: CPA agrees with this fin...
Finding No 2023-003 “ALN #20.106 Equipment and Real Property Management” Name of Contact Person(s): Sheryl Sizemore, Comptroller Ida S. De Brum, Accounting Manager Zack A. Diaz, Internal Auditor Alex Tudela, Procurement Officer Corrective Action: CPA agrees with this finding. CPA has implemented Equipment Management Standard Operating Procedures (SOPs) in June 2022 and trained staff involved in Equipment Management in August 2022. Because trainings on the newly developed SOPs were first conducted in August 2022, CPA noted and FAA acknowledged that repeat findings may be found in this audit report. CPA emphasizes that SOP trainings are continuing and mandatory for all of CPA Management, and CPA expects that the SOPs and related training will resolve this issue moving forward. Equipment SOP trainings occur twice per year and will continue indefinitely. In July 2023, CPA issued the inventory and property records to all CPA Department Heads to review, verify and confirm details of each fixed asset and provide additional identifying information for entry. These updates will be submitted to the Procurement Division in August 2023 for verification and entry into the Equipment Management System. Condition 1: CPA will ensure that count sheets are dated to reflect timing of the approval of fixed asset inventory performed. Condition 2: The fixed asset schedule provided to the auditors included a column that listed all contributed fixed assets as funded by the Federal Aviation Administration (FAA). The FAA column was mistakenly entered into the schedule. CPA Accounting verified that the details of all assets that were identified as non-FAA assets indicate funding through other federal or local programs. The fixed asset schedule will go through verification by the Accounting Manager and Comptroller to ensure that only the program assets requested are listed. Condition 3a: CPA will write off the asset from its fixed asset system. Condition 3b: CPA will write off assets 000015, 000040, 000047 as they have been already replaced with an existing asset. For assets 000091, 000589, and 000791: we will create maintenance logs for these assets as well as all assets that require maintenance in the fixed asset system. Condition 3c: CPA will write off the asset from its fixed asset system. Condition 3d: CPA will write off the asset from its fixed asset system and adjust and reclassify for any remaining depreciation still left on the books. CPA has developed the following corrective action plan for this finding: 1. Establish Standard Operating Procedures (SOP) for Equipment Management CPA has established Equipment Management SOPs that were implemented and effective on June 30, 2022. The SOPs detail the equipment management requirements, details, and responsibilities. In addition, the SOPs include an annual mandatory schedule for inventory, disposals, and reconciliation. The Department Heads are reviewing their equipment listings to verify the accuracy of equipment details, provide additional identifying information and confirm existence of all assets listed. The Department Heads will be providing monthly updates to the Procurement Department for entry into the Equipment Management System. 2. Implement Standard Equipment Management Forms Standard procurement forms have been developed to establish additional controls and reviews for all equipment. These standard forms include requirements such as identifying details for all fixed assets. 3. Develop a Training Plan for Equipment Management Procedures CPA developed an Equipment Management training plan that was implemented on June 17, 2022. The training plan includes annual requirements for training on equipment management and compliance requirements. The training is based on the established SOPs and best practices and is mandatory for all staff involved in equipment management. 4. Internal Auditor Position An internal auditor position was created on May 16, 2022 and hired on August 29, 2022. Part of the internal auditor’s responsibilities include reviewing inventory records and equipment management files for compliance. The internal auditor reports directly to the CPA Board of Director and provides monthly reports. The internal auditor monthly reports are used as a tool to identify areas of equipment management non-compliance for immediate correction. Proposed Completion Date: June 30, 2025
Finding 560049 (2023-001)
Significant Deficiency 2023
Significant Deficiency over Preparation of Schedule of Federal Expenditures (SEFA) The Organization did not identify all federal awards and significant adjustments were required to the SEFA prepared by management. Corrective Action: The Organization agrees with the auditor’s recommendation. At the...
Significant Deficiency over Preparation of Schedule of Federal Expenditures (SEFA) The Organization did not identify all federal awards and significant adjustments were required to the SEFA prepared by management. Corrective Action: The Organization agrees with the auditor’s recommendation. At the time of this audit’s publishing, the Organization has implemented additional procedures and controls to identify and report all federal award activity. Anticipated Completion Date: May 2025
Comments on findings and recommendations Management should implement a process to evaluate and allocate expenses on a regular basis. Actions taken or planned Management implemented a process to evaluate and allocate expenses based on employee estimates of time spent by function and proportion of th...
Comments on findings and recommendations Management should implement a process to evaluate and allocate expenses on a regular basis. Actions taken or planned Management implemented a process to evaluate and allocate expenses based on employee estimates of time spent by function and proportion of the association’s floor space utilized by each employee during the year. Anticipated completion date July 1, 2023
Recommendation: The City should implement controls for filing federal financial reports in a timely manner. Action Taken: In the past few years, the city has experienced turnover in management from the City Clerk, Finance Director, and the HR Director along with being significantly understaffed. Wit...
Recommendation: The City should implement controls for filing federal financial reports in a timely manner. Action Taken: In the past few years, the city has experienced turnover in management from the City Clerk, Finance Director, and the HR Director along with being significantly understaffed. With the stabilization of appropriate staffing levels along with appropriate procedures, and clear job duties this should no longer be an issue. The Mayor and City clerk have sent out instructions to all department heads that the documentation for all grants must be sent to the Admin Department. With the completion of the FY 2024 audit and the continued support of leadership this should no longer be an issue.
Finding 560005 (2023-003)
Significant Deficiency 2023
Finding; Reference Number: 2023-003 Description of Finding: The audit and reporting package were not submitted by the due date April 30, 2024. Finding is a significant deficiency. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will ensu...
Finding; Reference Number: 2023-003 Description of Finding: The audit and reporting package were not submitted by the due date April 30, 2024. Finding is a significant deficiency. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management will ensure that there is an adequate level of appropriately trained and experienced personnel and that internal controls over financial reporting will function properly to submit the audit and reporting package timely. Name of Contact Person: Kimalee Williams, CEO - Faith Asset Management, LLC, (860) 528-5000, kimalee@faithassetmgt.com Projected Completion Date: July 31, 2026
Finding 560003 (2023-002)
Significant Deficiency 2023
Finding Reference Number: 2023-002 Description of Finding: The security deposits, residual receipts, and replacement reserve were not properly established in separate bank accounts, and the required monthly deposits to the replacement reserve were not made. Statement of Concurrence or Nonconcurrence...
Finding Reference Number: 2023-002 Description of Finding: The security deposits, residual receipts, and replacement reserve were not properly established in separate bank accounts, and the required monthly deposits to the replacement reserve were not made. Statement of Concurrence or Nonconcurrence: Management agrees with this finding. Corrective Action: Management has set up separate bank accounts and continues to make the required deposits. Name of Contact Person: Kimalee Williams, CEO - Faith Asset Management, LLC, (860) 528-5000, kimalee@faithassetmgt.com Projected Completion Date: December 15, 2024
COVID-1 9 Coronavirus State and Local Fiscal Recovery Funds — Assistance Listing No. 21 .027 Recommendation: We recommend the District design controls to ensure an adequate review process over the invoices recorded and presented on the schedule of expenditures of federal awards to determine complian...
COVID-1 9 Coronavirus State and Local Fiscal Recovery Funds — Assistance Listing No. 21 .027 Recommendation: We recommend the District design controls to ensure an adequate review process over the invoices recorded and presented on the schedule of expenditures of federal awards to determine compliance with the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District’s policies will be updated and approved if needed to conform to federal guidance. Name(s) of the contact person(s) responsible for corrective action: Ron McEachern, General Manager or Delia Stoor, Accounting Manger Planned completion date for corrective action plan: September 30, 2024
COVID-19 Coronavirus State and Local Fiscal Recovery Funds —Assistance Listing No. 21.027 Recommendation: We recommend the District design controls to ensure an adequate review process is in place to review potential contractors to determine compliance with the Uniform Guidance procurement rules and...
COVID-19 Coronavirus State and Local Fiscal Recovery Funds —Assistance Listing No. 21.027 Recommendation: We recommend the District design controls to ensure an adequate review process is in place to review potential contractors to determine compliance with the Uniform Guidance procurement rules and procedures. Procedures for approval of the vendor contracts, and verification documents to ensure the vendor was not on the suspended or debarred vendor list maintained by the General Services Administration, should be reviewed and retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District’s policies will be updated and approved if needed to confirm to federal guidance. Name(s) of the contact person(s) responsible for corrective action: Ron McEachern, General Manager, or Delia Stoor, Accounting Manager Planned completion date for corrective action plan: September 30, 2024
• Finding 2023-005 – Compliance and Significant Deficiency in Internal Control over compliance with Allowable Costs: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with the audit finding. o Corrective Action Plan: MHA updated internal procedures to assure the Assista...
• Finding 2023-005 – Compliance and Significant Deficiency in Internal Control over compliance with Allowable Costs: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with the audit finding. o Corrective Action Plan: MHA updated internal procedures to assure the Assistant Director of Housing is reviewing rent calculations to assure there are not data entry issues, when there are questions in the program about what should qualify as “income” an internal discussion is held with the Director of Corporate Compliance and the Clinical Director of Behavioral Health Services. The Assistant Director of Housing and Care Coordination will notify all staff responsible for administering HUD programs of the policy changes and train those staff accordingly. All trainings are expected to be completed by May 2025. o Person Responsible: Director of Corporate Compliance o Expected Date of Completion: May 15, 2025
• Finding 2023-004 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: The utility calculation is updated annually ...
• Finding 2023-004 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions: o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: The utility calculation is updated annually by the Director of Corporate Compliance using the new tables provided by Pathstones which is received at the end of each year. This was implemented for 2024. The agency has developed, revised and implemented internal controls in the form of written program policies and procedures to ensure that the agency is in compliance with changes to regulatory requirements. Utility calculation is updated annually and verified by the Director of Corporate Compliance to reflect the current utility allowances within 30-days of publication. The Assistant Director of Housing and Care Coordination will notify all staff responsible for administering HUD programs of the policy changes and train those staff accordingly by May 2025. o Person Responsible: Director of Corporate Compliance o Expected Date of Completion: May 15, 2025
• Finding 2023-003 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: MHA uses the official HUD COC Rent Determinat...
• Finding 2023-003 – Compliance and Significant Deficiency in Internal Control over compliance with Special Tests and Provisions o U.S. Department of Housing and Urban Development o Agency Response: Concurs with audit findings. o Corrective Action Plan: MHA uses the official HUD COC Rent Determination worksheets, as well as an external vendor (Affordable Housing Network) to establish that reasonable rents are charged for comparable apartments. Worksheets are now updated annually and verified by the Director of Corporate Compliance. The Assistant Director of Housing and Care Coordination will notify all staff responsible for administering HUD programs of the changes and train those staff accordingly. The external contract was established in mid-2024, and is still being used. o Person Responsible: Director of Corporate Compliance. o Date of Completion: June 10, 2024.
Finding 2023-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Kaylee Reierson, Finance Officer Corrective Action: Neither current City Administrator or Finance Officer was employed with the City during this time period. Moving forward, all reporting will be...
Finding 2023-005 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Kaylee Reierson, Finance Officer Corrective Action: Neither current City Administrator or Finance Officer was employed with the City during this time period. Moving forward, all reporting will be done in a timely manner. Proposed Completion Date: Already implemented when the new administration was hired.
Management agrees with the finding and will ensure that the required deadline is met in the future.
Management agrees with the finding and will ensure that the required deadline is met in the future.
Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: Currently, the Authority is tracking all utility consumption for future OpFund application.Proposed Completion Date: Immediately
Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: Currently, the Authority is tracking all utility consumption for future OpFund application.Proposed Completion Date: Immediately
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