Corrective Action Plans

Finding 559944 (2023-006)

Material Weakness 2023

NC

HUD Housing Programs

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action:KMHA's Board has approved new written Tenant policies and procedures, to include a new ACOP (CFR 960), and are in place now.Appropriate staff have begun taking proper safeguards to ensure a waiting list is in place...

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action:KMHA's Board has approved new written Tenant policies and procedures, to include a new ACOP (CFR 960), and are in place now.Appropriate staff have begun taking proper safeguards to ensure a waiting list is in place and utilized, each tenant application is filed and proper action taken and tenant files are properly maintained and complete. A checklist is placed inside each tenant file to assist in completeness.Proposed Completion Date: Immediately

View Audit 355868

Finding 559943 (2023-005)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Cash Management HUD Housing Programs Procurement, Suspension & Debarment

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This in...

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This includes the oversight of processing payments of CFP expenditures, which includes the following procedures for: 1) payment of invoices; 2) requisition of funds; 3) monitoring; and 4) reporting of CFP funds.payment of InvoicesAll CFP invoices will be reviewed and clearly marked as approved and documented to show that the source of funds for payment are CFP grant funds by the Executive Director prior to payment. The Executive Director will specify the general ledger code, including the BLI account to be used for payment processing on the invoice before providing the invoice to the accounts payable clerk.Under no circumstances will a payment be made if KMHA has not drawdown and received the respective CFP funds.With the exception of funds associated with BLI 1406 “Operations”, PHAs have three (3) business days to issue and mail the check once the CFP funds are received.The Executive Director/accounts payable clerk will specify the BLI account and CFP grant year on the check voucher prior to sending the check voucher to the fee accountant for financial statement processing.Requisition of FundsFor each drawdown, the Executive Director will print the associated eLOCCS Voucher Payment form from the eLOCCS system.The Executive Director will document the check number(s) and vendor(s) associated with each CFP draw (i.e., the eLOCCS Voucher Payment form). In addition, each individual draw shall be numbered for reference purposes.A copy of each draw shall be submitted to the fee accountant to ensure proper reporting of the grant drawdown.With the exception of funds associated with BLI 1406 “Operations”, in no case shall a draw be made without the proper approved invoices.MonitoringThe fee accountant's monthly financial statements will include a CFP report for each grant which will be reviewed by the Executive Director for proper coding and accuracy.Folder has been created to track all required information in the management of a CFP grant to include correspondence to and from HUD, expenses, grant reimbursements, budgets, closeout documentation and EPIC management.Proposed Completion Date: Immediately

View Audit 355868

Finding 559942 (2023-004)

Material Weakness 2023

Kings Mountain Housing Authority

NC

HUD Housing Programs Internal Control / Segregation of Duties

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: A budget for FYE 9/30/25 was approved by the Board in their October 2024 meeting.Proposed Completion Date: Immediately

View Audit 355868

Finding 559941 (2023-003)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KMHA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for deposits and bank reconciliations to ensure proper accountability. Bank ...

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KMHA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for deposits and bank reconciliations to ensure proper accountability. Bank statements will be provided directly to the Fee Accountant monthly. The reconciliation of all bank accounts in a timely manner is a key component of good controls over cash. The reconciliation of the bank balance with the book balance (i.e., general ledger) is necessary to ensure that:All receipts and disbursements are recorded, which is an essential process for ensuring complete and accurate monthly financial statements;Checks are clearing the bank in a reasonable timeframe;Items reconciled are appropriate and are being recorded;Fraudulent claims can be discovered and investigated; andReconciled cash balance agrees to the general ledger cash balance.Each bank account will be reconciled by the fee accountant returned.This documentation will be made available to the Authority’s auditorProposed Completion Date: Immediately

View Audit 355868

Finding 559940 (2023-002)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: Internal actions have been taken to prevent this from happening again.Proposed Completion Date: Immediately

View Audit 355868

Finding 559939 (2023-001)

Material Weakness 2023

Kings Mountain Housing Authority

NC

Procurement, Suspension & Debarment § 200.320

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for purchasing and procurement actions to ensure proper accountability. The ...

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for purchasing and procurement actions to ensure proper accountability. The new policy addresses the three types of procurement under CFR 200.320 informal and formal procurement and noncompetitive procurement. Thresholds have been set for Micro purchases and thus simplified procurement under informal practices. Formal methods include Sealed bids and Proposals when sealed bids are not appropriate.All checks are handled in accordance with the new check writing policy and have the necessary documentation to support the purchase and is filed in such a manner to be available for future reviews. This documentation will be made available to the Authority's fee accountant.All procurement actions will be handled in accordance with the new procurement policy and CFR 200.Proposed Completion Date: Immediately

View Audit 355868

Finding 559920 (2023-001)

Material Weakness 2023

People's Emergency Center and Subsidiaries

PA

Material Weakness Reporting § 200.512

Finding 2023-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2023, management was unable to provide timely year end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately refle...

Finding 2023-001 – Material Weakness – Accounting Recordkeeping All Programs Other Condition During the year ended June 30, 2023, management was unable to provide timely year end trial balances in accordance with U.S. GAAP without significant adjusting journal entries required to accurately reflect the underlying accounting transactions. Recommendation We recommend that individuals overseeing the accounting and finance department continue to review the Organization's current accounting policies and update existing policies or implement new policies, as needed, to ensure that the trial balances are accurately maintained throughout the year, reconciliations are completed and reviewed monthly or quarterly, as appropriate, and the trial balances and related supporting schedules are prepared and reviewed timely after year-end. Management’s Corrective Action Plan Management has implemented a structured monthly closing process to ensure timely and accurate recording of transactions. All balance sheet accounts will be reconciled by the 15th day of the following month. We will develop and implement a month-end and year-end closing checklist based on U.S. GAAP and, as necessary, any city, state, or federal reporting requirements. We are also evaluating current staffing levels to determine if there is a need to hire additional personnel or retain external accounting support during the year-end closing process. We will conduct a pre-closing review in the 4th quarter to identify and resolve discrepancies prior to year-end. We will also prepare a preliminary trial balance and draft financial statements by July 31 to allow sufficient time for audit fieldwork. The Finance Committee of the HopePHL Board of Directors will receive quarterly updates on the status of the monthly financial closing process. Contact Person: Kathy Desmond, President and CEO Anticipated Completion Date: June 30, 2025

View Audit 355861

Finding 559904 (2023-003)

Material Weakness 2023

Organized Parents Make A Difference, Inc.

CT

Allowable Costs / Cost Principles

The Organization implemented procedures to ensure invoices and payroll are approved including the use of bill.com and a cash report approval of all payments. Payroll is prepared by the CFO and is reviewed by the Executive Director. It is then entered into Quickbooks by our outsourced accountants.

View Audit 355829

Finding 559858 (2023-002)

Material Weakness 2023

Washington County

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.208 § 200.328

Finding Number: 2023-002 Planned Corrective Action: The Chief Financial Administrator will ensure all ARPA expenditures are included on the Project and Expenditure Reports. Anticipated Completion Date: March 31, 2025 Responsible Contact Person: Ben Cowdery, Chief Financial Administrator

View Audit 355799

Finding 559810 (2023-001)

Significant Deficiency 2023

Opportunities Credit Union

VT

Reporting Significant Deficiency

Identifying Number: Finding 2023-001 Finding: Late Issuance of 2023 Single Audit Package Condition: The submission of the 2023 Single Audit reporting package was not submitted by the September 30, 2024 deadline. Corrective Actions Taken or Planned: Management agrees with the finding that the Single ...

Identifying Number: Finding 2023-001 Finding: Late Issuance of 2023 Single Audit Package Condition: The submission of the 2023 Single Audit reporting package was not submitted by the September 30, 2024 deadline. Corrective Actions Taken or Planned: Management agrees with the finding that the Single Audit report was not filed timely. This report will be filed once the Single Audit is issued. The delay in filing was due to personnel constraints. Management will take steps to hire the necessary personnel to ensure all audit work can be performed in a timely manner going forward. Completion Date: April 30, 2025 Responsible for the Corrective Action Plan: Erin Metivier, Chief Financial Officer

View Audit 355770

Finding 559783 (2023-003)

Significant Deficiency 2023

Portland Community Reinvestment Initiatives, Inc.

OR

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.502 § 200.510

While PCRI does have systems in place to adequately track federal expenditures, the preparation of the schedule of federal expenditures was delayed in large part due to the deficiencies outlined in Finding 2023-001, which led to delays in accurately compiling the information required for the schedul...

While PCRI does have systems in place to adequately track federal expenditures, the preparation of the schedule of federal expenditures was delayed in large part due to the deficiencies outlined in Finding 2023-001, which led to delays in accurately compiling the information required for the schedule of federal expenditures, and that the transition of relevant accounting processes to the outsourced accounting firm will resolve this deficiency going forward. The timeline for full transition of relevant accounting processes to the outsourced accounting firm which started in January of 2025 is approximately seven months due to the complexities of PCRI’s operations. PCRI anticipates this transition being complete in July of 2025.

View Audit 355753

Finding 559782 (2023-002)

Significant Deficiency 2023

Portland Community Reinvestment Initiatives, Inc.

OR

Reporting § 200.512

The delay in submission of the December 31, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the due date is a direct result of the delays in completion of the December 31, 2023 audit which were caused by the deficiencies outlined in Finding 2023-001. Management believes tha...

The delay in submission of the December 31, 2023 Single Audit reporting package to the Federal Audit Clearinghouse by the due date is a direct result of the delays in completion of the December 31, 2023 audit which were caused by the deficiencies outlined in Finding 2023-001. Management believes that the outsourcing of critical accounting functions will help ensure that PCRI’s records are reconciled in a timely manner which will allow for the Single Audit to be submitted by the due date going forward. The timeline for full transition of relevant accounting processes to the outsourced accounting firm which started in January of 2025 is approximately seven months due to the complexities of PCRI’s operations. PCRI anticipates this transition being complete in July of 2025.

View Audit 355753

Finding 559682 (2023-002)

Significant Deficiency 2023

Muslim Youth for Positive Impact

CO

Reporting

The Organization agrees with this finding and will implement a corrective action plan based on this recommendation.

View Audit 355577

Finding 559681 (2023-001)

Material Weakness 2023

Muslim Youth for Positive Impact

CO

Reporting Internal Control / Segregation of Duties

Management acknowledges that adjustments to deferred revenue, receivables, and revenue were required.

View Audit 355577

Finding 559675 (2023-001)

None 2023

Great River Energy

MN

4/24/2025 ...

4/24/2025 Deloitte & Touche LLP 50 South Sixth Street Suite 2800 Minneapolis, MN 55402 We are providing the below corrective action plan in response to Finding 2023-001 identified during the program-specific audit of the Schedule of Expenditures of Federal Awards for the Federal Emergency Management Agency (FEMA) Public Assistance Disaster Grants (ALN 97.036) Program from the United States Department of Homeland Security (the “DHS”), which was passed through Minnesota Homeland Security and Emergency (HSEM), collectively known as the “FEMA program” of Great River Energy (GRE), (the “Company”) for the year ended December 31, 2023, and your program-specific audit of the compliance requirements of the FEMA program. Finding 2023-001 Noncompliance with Uniform Guidance (UG) – Timing of Compliance Audit Corrective Action – The need for a compliance audit for fiscal year 2023 was identified and requested as part of Management’s preparation for an audit during fiscal year 2024. As part of the corrective action that has been put in place, the Company will submit future required compliance audit reports to the FAC within the required timeline. All FEMA expenditures to date will have now been reported in the Federal Audit Clearinghouse (FAC) Site. Corrective Action Anticipated Completion Date – April 30, 2025 Responsible Party – Jesse P. Huber, Director, Financial Reporting, Rates & Analysis

View Audit 355555

Finding 559271 (2023-002)

Significant Deficiency 2023

Foundation for Democratic Development

DC

Reporting

2022-003 Reporting Federal Program – All federal programs Criteria – The data collection form must be completed and submitted within nine months of the Organization’s fiscal year end. Condition and Context – As a result of a conversion to a new accounting system, the impact of COVID-19, and reco...

2022-003 Reporting Federal Program – All federal programs Criteria – The data collection form must be completed and submitted within nine months of the Organization’s fiscal year end. Condition and Context – As a result of a conversion to a new accounting system, the impact of COVID-19, and reconciliation differences, the data collection form was not timely submitted for the year ended December 31, 2023. Questioned Costs – None. Effect – The Organization was not in compliance with the Uniform Guidance reporting requirements. Cause – With the conversion to a new accounting system, combined with the COVID-19, new accounting staff and reconciliation differences, the data collection form could not be timely completed and submitted. Recommendation – The financial records of the Organization should be reconciled and closed shortly after year-end, which will permit the timely submission of the data collection form. Views of Responsible Officials and Planned Corrective Actions Management agrees with this finding. We will anticipate being able to comply with this requirement effective with the FY2024 audit. Anticipated Completion Date: The financial records for the year ended December 31, 2024, will be reconciled and closed, permitting the audited financial statements, financial reporting package and data collection form to be filed timely by September 30, 2025. Contact Person: Natalia Arno, President, 916-849-3057

View Audit 355515

Finding 559265 (2023-002)

Significant Deficiency 2023

Oklahoma City Innovation District, Inc.

OK

Eligibility Reporting Matching / Level of Effort / Earmarking § 200.512

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays e...

Recommendation: We recommend that management implement processes to ensure timely completion and submission of the Single Audit report in future years. This could include setting internal deadlines, increasing oversight, and coordinating with the audit firm to identify and address potential delays earlier in the audit process. Action Taken: Management agrees with the finding and will take steps to improve the timeliness of the audit process. Anticipated completion date: June 30, 2025 Name of contact person and title: Jeffrey Seymour, President / CEO

View Audit 355490

Finding 559264 (2023-001)

Significant Deficiency 2023

Oklahoma City Innovation District, Inc.

OK

Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.305

Identifying Number: 2023-001; Lack of Written Policies and Procedures Recommendation: The Organization should develop and implement comprehensive written policies and procedures in accordance with the requirements of the Uniform Guidance. Action Taken: In response to the finding, management will t...

Identifying Number: 2023-001; Lack of Written Policies and Procedures Recommendation: The Organization should develop and implement comprehensive written policies and procedures in accordance with the requirements of the Uniform Guidance. Action Taken: In response to the finding, management will take action to develop and implement the necessary written policies and procedures. Comprehensive training will be provided to all relevant staff to ensure compliance with federal requirements. Anticipated completion date: June 30, 2025 Name of contact person and title: Jeffrey Seymour, President / CEO

View Audit 355490

Finding 559174 (2023-002)

Significant Deficiency 2023

Ocab Community Action Agency, INC

SC

Reporting Matching / Level of Effort / Earmarking Special Tests & Provisions

Management is actively working on retaining and recruiting knowledgeable personnel in the finance and account department to enhance the department's effectiveness and efficiency. OCAB has established agreements with account professionals to improve the training and efficiency of staff in the fiscal...

Management is actively working on retaining and recruiting knowledgeable personnel in the finance and account department to enhance the department's effectiveness and efficiency. OCAB has established agreements with account professionals to improve the training and efficiency of staff in the fiscal office, focusing on areas such as financial compliance, daily fiscal responsibilities month end closing and budget analysis. OCAB as slso hired 2 fiscal personnel in this department. We believe significant progress has been made since the last reorting period. A wage and benefits was completed and utilized in the process. OCAB believes that the measures taken will ensure compliance with all department of Health & Human Services regulations.

View Audit 355410

Finding 559163 (2023-003)

Significant Deficiency 2023

Ozarks Regional YMCA

MO

Allowable Costs / Cost Principles Cash Management § 200.302

Management agrees with the finding and has developed and implemented the appropriate policies and procedures effective September 2024.

View Audit 355391

Finding 559162 (2023-002)

Material Weakness 2023

Hamilton County Hospital District

TX

Reporting Internal Control / Segregation of Duties

orrective Action Plan for Finding 2023-002 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to e...

orrective Action Plan for Finding 2023-002 We are in receipt of the finding required to be reported by Uniform Guidance, regarding other instance of noncompliance with respect to Reporting. Management agrees with the finding. Policies and procedures over federal grant reporting will be modified to ensure reports are prepared using complete and accurate information. We will increase compensating controls for introducing additional oversight and review for future COVID-19 Provider Relief Fund reporting. Tammy Schreiber, CFO, will be responsible to ensure this is accomplished. The District had enough lost revenues during Period 4 that the error determined in Finding 2023-002 will not result in a conflict with funding received. The Corrective Action Plan will be implemented by September 30, 2025.

View Audit 355389

Finding 559143 (2023-002)

Significant Deficiency 2023

The Enola Group, Inc.

NC

Reporting Allowable Costs / Cost Principles

Name of Contact Person: Terri Brown, Director of Finance Corrective Action: Due to the extreme turnover within the Finance Director position in FY 22-23, there were more than normal accounting errors that were corrected by journal entries in the FY22 audit. The Executive Director addressed the turno...

Name of Contact Person: Terri Brown, Director of Finance Corrective Action: Due to the extreme turnover within the Finance Director position in FY 22-23, there were more than normal accounting errors that were corrected by journal entries in the FY22 audit. The Executive Director addressed the turnover by hiring a Finance Director with extensive non-profit finance and operation experience. In addition, training was provided on the accounting software. The Finance Director role has been occupied by one individual for multiple years. A Bookkeeping position was also created and filled which now allows for more separation of duties. A system of checks and balances have been established between the Bookkeeper, Administrative Assistant, Finance Director and Executive Director. This system includes the enhancement of protocols such as cash receipts, disbursements process and journal vouchers, monthly one on one in depth review of financials with Program Directors and Finance Director, and monthly Finance Director and Executive Director meetings. In addition, the Executive Director, Finance Director and Bookkeeper are now using the secured server to file digital copies of most financial documents. The Finance Director has monthly finance meetings with each Program Director to review their monthly actuals against budget. In addition, the accounting system is now remote which allows for access based on role for the Bookkeeper and Executive Director. The organization has created a third position, Accounts Receivable Coordinator to process all AR related duties. Proposed Completion Date: Immediately.

View Audit 355382

Finding 559071 (2023-002)

Material Weakness 2023

Manhattan Housing Authoirty

KS

Questioned Costs HUD Housing Programs Special Tests & Provisions

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Aaron Estabroo...

Authority Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies are being followed on a timely basis. Aaron Estabrook, Executive Director, is responsible for implementing this corrective action by December 31, 2024.

View Audit 355357 Questioned Costs: $1

Finding 559067 (2023-002)

None 2023

Illuminate Colorado

CO

Subrecipient Monitoring Reporting

Illuminate Colorado has developed a new process for initiating federal grants that includes a review of Terms and Conditions by multiple individuals to ensure all required Terms and Conditions are identified and implemented. This process includes documentation of compliance with requirements for sub...

Illuminate Colorado has developed a new process for initiating federal grants that includes a review of Terms and Conditions by multiple individuals to ensure all required Terms and Conditions are identified and implemented. This process includes documentation of compliance with requirements for subrecipients. This process will be documented through a Standard Operating Procedure to ensure consistent implementation of the expectations. Standard Operating Procedure will include:  Process to accept federal awards including review of Notice of Award by at least two individuals  Process to identify standard terms and conditions, including requirements related to: o Compliance with Federal Laws o Debarment and Suspension o Federal Funding Accountability and Transparency Act  Process to identify and monitor vendors paid with Federal Funds, including vendor type (contractor, subrecipient), procurement method, and associated requirements  Development of a Face Sheet for subrecipients that includes required information such as Assistance Listing Number, Federal Award Information Number, Unique Entity Identifier, etc.  Process to identify any new or different terms and conditions

View Audit 355335

Finding 559065 (2023-001)

None 2023

Illuminate Colorado

CO

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.305

In alignment with this audit finding, Illuminate Colorado has implemented processes to improve working capital and address cash flow challenges, including:  improved invoicing procedures to ensure timely submission of invoices to minimize time elapsed between submission of invoices to funders and r...

In alignment with this audit finding, Illuminate Colorado has implemented processes to improve working capital and address cash flow challenges, including:  improved invoicing procedures to ensure timely submission of invoices to minimize time elapsed between submission of invoices to funders and reimbursement of those invoices, and  seeking increased working capital via a larger line of credit or other source (foundation, corporate, or individual donations) In addition, Illuminate Colorado is in process of developing a Standard Operating Procedure to ensure consistent identification of vendors utilized for direct Federal assistance programs in order to prioritize payment of those vendors with federal drawdown receipts. Standard Operating Procedure will include:  Process to identify vendors paid with federal funds  Process to monitor invoice timelines of vendors paid with federal funds  Process to prioritize payments of vendors paid with federal funds following federal drawdowns  Process for internal review of payment timelines

View Audit 355335

Corrective Action Plans

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