Corrective Action Plans

Finding 499754 (2023-002)

Significant Deficiency 2023

DC

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.332 § 200.341

Views of Responsible Officials: Management acknowledges a noncompliance with FFATA Reporting requirements and a need to establish and document a policy and procedure. FFATA reporting was subsequently completed for one of the two subawards requiring FFATA reporting in 2023 and the other is in process...

Views of Responsible Officials: Management acknowledges a noncompliance with FFATA Reporting requirements and a need to establish and document a policy and procedure. FFATA reporting was subsequently completed for one of the two subawards requiring FFATA reporting in 2023 and the other is in process. The Global Center has updated its “Subaward Methodology and Guidelines” to include FFATA reporting requirements and is distributing those guidelines to all project managers, finance, and other staff to ensure FFATA reporting is completed when required by the end of the month following the month in which any subcontract greater than $30,000 is awarded. Responsible Officials: Jason Ipe, Chief of Operations Anticipated Completion Date: September 27, 2024

View Audit 322582

Finding 499753 (2023-004)

Material Weakness 2023

City of Lawrence

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedu...

FINDING 2023-004 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedure to ensure appropriate segregation of duties and reviews, approvals, and oversight are in place for reporting. This policy will require that two staff members from the Controller's Office prepare the quarterly Project and Expenditure report (P&E report). One staff member shall be responsible for preparing the report and the other will complete a review and submission of the report. Anticipated Completion Date: 12/31/2024

View Audit 322579

Finding 499752 (2023-003)

Material Weakness 2023

City of Lawrence

IN

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a pol...

FINDING 2023-003 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Humphrey Nagila Contact Phone Number: 317-542-4554 Views of Responsible Official: We agree with this finding. The City will create a policy and procedure to ensure compliance with Federal procurement laws. Additionally, our updated policy shall ensure that the City adheres to all procurement procedures outlined in Federal awards received by the City. This policy will ensure that contractors and subrecipients are not suspended, debarred, or otherwise excluded prior to entering any contracts or subawards. Anticipated Completion Date: 12/31/2024

View Audit 322579

Finding 499751 (2023-001)

Significant Deficiency 2023

Father Flanagan's Boys' Home Dba Boys Town

NE

Allowable Costs / Cost Principles § 200.430

The certification process for the year ended December 31, 2023, is expected to be completed by October 31, 2024. For the period from January 1, 2024, through September 30, 2024, the certification process is expected to be completed by November 15, 2024. Communication has been disseminated to employe...

The certification process for the year ended December 31, 2023, is expected to be completed by October 31, 2024. For the period from January 1, 2024, through September 30, 2024, the certification process is expected to be completed by November 15, 2024. Communication has been disseminated to employees that certifcations will occur in accordance with the policy for the remainder of 2024 and beyond. Any material differences identified in the allocation of salaries and fringes will be corrected for the year ended December 31, 2024. Cheri Sash, Director of Grants & Financial Contract Compliance Compliance will oversee the certification process.

View Audit 322569

Finding 499750 (2023-004)

Significant Deficiency 2023

Clark County

IN

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.332 § 200.501

Finding 2023-004 – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Danny Yost Contact Phone Number: 812-285-6221 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The County will obtain all subrecipient audit reports an...

Finding 2023-004 – Subrecipient Monitoring Contact Person Responsible for Corrective Action: Danny Yost Contact Phone Number: 812-285-6221 Views of Responsible Official: We concur with the finding Description of Corrective Action Plan: The County will obtain all subrecipient audit reports and formally document their review of each subrecipient’s audit report. Anticipated Completion Date: October 2024.

View Audit 322568

Finding 499739 (2023-003)

Significant Deficiency 2023

Five Towns Community Center INC

NY

Questioned Costs Allowable Costs / Cost Principles

FTCC concurs with this finding and will make every attempt to create time studies to support salary allocations in the future.

View Audit 322561 Questioned Costs: $1

Finding 499738 (2023-003)

Significant Deficiency 2023

National Network to End Domestic Violence, Inc.

DC

Internal Control / Segregation of Duties Reporting Matching / Level of Effort / Earmarking § 200.303

The process for cash draws has been updated to include preparation by a supervisor at the outsourced accounting firm, review by the manager at the outsourced accounting firm and by an individual at the organization, and draws are made by the manager at the outsourced accounting firm. The federal fin...

The process for cash draws has been updated to include preparation by a supervisor at the outsourced accounting firm, review by the manager at the outsourced accounting firm and by an individual at the organization, and draws are made by the manager at the outsourced accounting firm. The federal financial reports are entered into the system by the manager at the outsourced accounting firm based on a file created by the supervisor at the outsourced accounting firm. Before being submitted they are printed to PDF and sent to the VP of Finance for review. In the absence of a VP of Finance, the partner in charge of the engagement at the outsourced accounting firm will review. The above corrective actions will be taken by the end of this year, December 31, 2024.

View Audit 322559

Finding 499737 (2023-002)

Significant Deficiency 2023

National Network to End Domestic Violence, Inc.

DC

Procurement, Suspension & Debarment § 200.320

Management is looking into systems to track the spending on contractors so they can ensure to request price quotes when the contracted amount rises over the micro-purchase threshold. Management is also retraining Program and Grants Management staff on procurement standards and requirements. The res...

Management is looking into systems to track the spending on contractors so they can ensure to request price quotes when the contracted amount rises over the micro-purchase threshold. Management is also retraining Program and Grants Management staff on procurement standards and requirements. The responsibility for this will be handled by the VP of Finance, or in the absence of the VP of Finance, it will be the responsibility of the Director of Development. The above corrective actions will be taken by the end of this year, December 31, 2024.

View Audit 322559

Finding 499735 (2023-001)

Material Weakness 2023

Family Advocates, Inc.

WI

Finding #2023-001 – Material Audit Adjustments Condition: Material audit adjustments were required to adjust noncash contributions and related expenses and various accounts related to the construction of the new building at year-end. Effect: Financial statements generated by the accounting system...

Finding #2023-001 – Material Audit Adjustments Condition: Material audit adjustments were required to adjust noncash contributions and related expenses and various accounts related to the construction of the new building at year-end. Effect: Financial statements generated by the accounting system may not provide an accurate reflection of the Organization’s financial position and activities. Cause: Significant noncash contributions not recorded throughout the year and new building project spanning over multiple years. Criteria: Month-end and year-end closing processes should be in place to ensure that records are correct, reliable, and properly reconciled. Recommendation: We recommend that the Organization improve their month-end and year-end closing processes to include reviewing annual audit entries and posting any applicable entries prior to the audit. Management should then review the financial information on a timely basis. Response: The Organization will review the month-end and year-end closing processes. The Organization will review the annual audit entries as part of the closing processes and post any applicable entries prior to future audits. Contact Person: Darlene Masters Anticipated Completion: December 31, 2024

View Audit 322558

Finding 499734 (2023-001)

Significant Deficiency 2023

Community Action Wayne/medina

OH

Eligibility

Finding Number: 2023-001 Planned Corrective Action: The ERA program was a temporary program as part of the American Rescue Plan Act and there will not be expenditures for this program going forward therefore corrective action is not necessary. Anticipated Completion Date: 9/23/24 Responsible Conta...

Finding Number: 2023-001 Planned Corrective Action: The ERA program was a temporary program as part of the American Rescue Plan Act and there will not be expenditures for this program going forward therefore corrective action is not necessary. Anticipated Completion Date: 9/23/24 Responsible Contact Person: N/A

View Audit 322554

Finding 499733 (2023-001)

Significant Deficiency 2023

Distilled Spirits Council of the United States, Inc.

DC

Procurement, Suspension & Debarment § 200.318 § 200.327

The Distilled Spirits Council of the U.S. recognizes the importance of implementing a procurement process in accordance with 2 CFR 200.318(a). The International Team (with feedback from the Finance Team), will adopt an updated procurement process with procedures to address various methods of procure...

The Distilled Spirits Council of the U.S. recognizes the importance of implementing a procurement process in accordance with 2 CFR 200.318(a). The International Team (with feedback from the Finance Team), will adopt an updated procurement process with procedures to address various methods of procurement and ensure all vendors entered a covered transaction are not debarred, suspended,or otherwise excluded. The procurement policy was updated; however, it did not take effect until the 2024 fiscal year due to the finalization of the 2022 audit, which occurred near the end of the 2023

View Audit 322549

Finding 499732 (2023-002)

Significant Deficiency 2023

Madison County Housing Authority

IL

HUD Housing Programs Reporting Significant Deficiency

Finding No. 2023-002 Significant Deficiency Personnel Responsible for Section 8 Director Corrective Action: Anticipated Completion Date: January 31, 2025 Corrective Action Plan: We take the proper review and documentation of review of our Housing Quality Standards (HQS) inspections prior ...

Finding No. 2023-002 Significant Deficiency Personnel Responsible for Section 8 Director Corrective Action: Anticipated Completion Date: January 31, 2025 Corrective Action Plan: We take the proper review and documentation of review of our Housing Quality Standards (HQS) inspections prior to their timely submission to the Public and Indian Housing Information Center (PIC) very seriously. We acknowledge the importance of this process and the need for consistent implementation. To address this finding, we will implement the following measures: 1. Documentation: A new documentation protocol will be established to provide clear proof that this process is occurring regularly. This will include date-stamped review logs and signatures from responsible staff members. We will institute a monthly review of 3 to 5 initial failed inspections. This review will: • Determine if repairs have occurred in a timely manner • Assess whether abatement letters should be sent • Be documented and included in our regular reporting 2. Training: We will conduct refresher training for all relevant staff to ensure they understand the importance of this process and their role in maintaining it. 3. Automated Reminders: We will implement an automated reminder system to alert staff when reviews and submissions are due. 4. Internal Review: Internal quarterly reviews will be conducted to ensure compliance with this process and to identify any potential issues early.

View Audit 322548

Finding 499731 (2023-001)

Significant Deficiency 2023

Madison County Housing Authority

IL

HUD Housing Programs Reporting Significant Deficiency

Finding No. 2023-001 – Significant Deficiency Personnel Responsible for Section 8 Director Corrective Action: Anticipated Completion Date: January 31, 2025 Corrective Action Plan: We acknowledge that while reviews of moved-out individuals are occurring, there was insufficient documentation...

Finding No. 2023-001 – Significant Deficiency Personnel Responsible for Section 8 Director Corrective Action: Anticipated Completion Date: January 31, 2025 Corrective Action Plan: We acknowledge that while reviews of moved-out individuals are occurring, there was insufficient documentation to support this process. We understand the importance of maintaining clear and accessible records to demonstrate our compliance and due diligence. To address this finding and implement the best practice recommendations, we will take the following steps: 1. Documentation Protocol: • Implement a standardized documentation process for move-out reviews. • Create a digital log that records the date of review, the reviewer's name, and the outcome of each review. • Ensure all documentation is easily accessible for future audits and internal reviews. 2. Monthly Landlord Verification: • Establish a monthly process to contact a sample of 3-5 landlords. • Provide these landlords with a current tenant listing for their properties. • Request verification of occupancy status for each listed tenant. • Document all responses and follow up on any discrepancies identified. 3. Move-Out Tracking: • Strengthen our move-out tracking procedures to ensure timely submission of Form HUD-50058. • Implement a system of alerts or reminders to prompt staff when 50058 submissions are due. • Conduct regular internal audits to verify the timeliness of 50058 submissions. 4. Training: • Provide comprehensive training to all relevant staff on the new documentation and verification processes. • Emphasize the importance of timely 50058 submissions and accurate move-out tracking.

View Audit 322548

Finding 499730 (2023-003)

Material Weakness 2023

City of Richmond

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-003 Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2021 Pass-Through Entity: Direct grant Compliance Requirements: Procurement and Suspension and...

FINDING 2023-003 Subject: Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Federal Agency: U.S. Department of Treasury Assistance Listing Number: 21.027 Federal Award Number: FY 2021 Pass-Through Entity: Direct grant Compliance Requirements: Procurement and Suspension and Debarment Audit Findings: Material Weakness Condition: The City elected to receive the standard revenue loss allowance, allowing them to claim its total State and Local Fiscal Recovery Funds (SLFRF) allocation as revenue loss to use for government services. As such, all SLFRF program funds were expended under the revenue loss eligible use category. The U.S. Department of the Treasury (Treasury) determined that there are no subawards under this eligible use category, and that recipients’ use of revenue loss funds would not give rise to subrecipient relationships given that there is no federal program or purpose to carry out in the case of the revenue loss portion of the award. Prior to entering into subawards and covered transactions with SLFRF award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. “Covered transactions” include, but are not limited to contracts for goods and services awarded under a non-procurement transaction (i.e. grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Due to the Treasury’s determination that the revenue loss eligible use category does not give rise to subawards, the City was only required to comply with suspension and debarment requirements related to covered transactions. Context: We noted there was one vendor that the City entered into contract with in the current year that exceeded $25,000 paid from SLFRF funds. This transaction, totaling $364,374 was selected for testing. The City was not able to provide support proving that the City had verified the vendor was not suspended or debarred prior to entering into the contract. Management asserts that this is being done, but support is not maintained. Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The City will include a suspension and debarment clause into our federal contracts going forward. Responsible Party and Timeline for Completion: The Controller, Deputy Controller and the Director of Strategic Initiatives. The Corrective Action will be implemented in January 2025.

View Audit 322539

Finding 499729 (2023-003)

Significant Deficiency 2023

Meadville Area Sewer Authority

PA

Cash Management Period of Performance

An internal procedure was created, in addition to former procedures that shows a more detailed approach of ensuring every invoice involved with each drawdown are accounted for and paid on a timely basis to each vendor. The Authority believes this instance was a one-time item that will be corrected.

View Audit 322538

Finding 499728 (2023-005)

Significant Deficiency 2023

Township of Little Egg Harbor

NJ

Reporting

Recommendation: That the Township implement controls to ensure reports are submitted on time in accordance with grant compliance requirements. View of responsible official: The responsible official agrees with this finding and will address the matter as part of their corrective action plan.

View Audit 322533

Finding 499727 (2023-001)

Material Weakness 2023

Village of Cassville

WI

Internal Control / Segregation of Duties HUD Housing Programs

Finding #2023-001- Limited Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintenti...

Finding #2023-001- Limited Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Criteria: Segregation of duties is an aspect of internal control intended to prevent or decrease opportunities of intentional and unintentional errors and fraud. Duties and responsibilities are properly segregated if no single individual either has control over all phases of a transaction or can both make and conceal an error, whether such error is intentional or unintentional. Cause: Limited number of personnel. Effect: Errors or intentional fraud could occur and not be detected timely by other employees in the normal course of their responsibilities because of the lack of segregation of duties. Recommendation: We recommend that the Village consider the benefits of implementing additional policies and procedures to address key controls related to its significant transaction cycles as noted. Response: We agree with the finding but do not believe it is cost-effective to increase the office staff in an attempt to bring about a more effective segregation of duties. Contact Person: Molly Roskams, Clerk/Treasurer Anticipated Completion: Not applicable

View Audit 322532

Finding 499726 (2023-002)

Significant Deficiency 2023

Nevada Test Site Historical Foundation

NV

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

To ensure that only proper labor costs are included in grant funding requests, the invoice reported to the grant issuing agency is reviewed by the Project Manager and evidenced by his signature. This review includes reviewing the individual labor charges prior to signing the invoice. All individual...

To ensure that only proper labor costs are included in grant funding requests, the invoice reported to the grant issuing agency is reviewed by the Project Manager and evidenced by his signature. This review includes reviewing the individual labor charges prior to signing the invoice. All individuals who support the grant purpose and are funded by a grant will be separately identified and the ratio of allowable time to total time will be determined for each pay period. Allowable cost for each individual will be aggregated to the total labor cost for the period and be included in the invoice requesting fund draws. These procedures will be in effect as of the date of this writing.

View Audit 322531

Finding 499725 (2023-001)

Significant Deficiency 2023

Nevada Test Site Historical Foundation

NV

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.317 § 200.318

Written procurement procedures have been written for the Nevada Test Site Historical Foundation to ensure that procurements will be processed in conformity with 2 CFR 200.317 to 327. These procedures will be followed for procurements related to grants awarded to the entity. The dollar amount of the ...

Written procurement procedures have been written for the Nevada Test Site Historical Foundation to ensure that procurements will be processed in conformity with 2 CFR 200.317 to 327. These procedures will be followed for procurements related to grants awarded to the entity. The dollar amount of the grant will determine the process to follow to be in compliance. Implementation of these procedures will begin as of the date of this writing.

View Audit 322531

Finding 499720 (2023-009)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

Subrecipient Monitoring

Corrective Action: Management has experienced turnover in recent years which has made agency report submissions challenging for proper review due to limited user access. Management added additional users to agency filing websites and will continue to enforce evidence of review and approver for all r...

Corrective Action: Management has experienced turnover in recent years which has made agency report submissions challenging for proper review due to limited user access. Management added additional users to agency filing websites and will continue to enforce evidence of review and approver for all reports prior to submission. Name of Responsible Individual(s): Jason Brenier, Ann Wieczorek, Christina Madriles, and Judy Bokhari Anticipated Completion Date: October 2024

View Audit 322528

Finding 499708 (2023-008)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

Period of Performance Subrecipient Monitoring Allowable Costs / Cost Principles

Corrective Action: Management will update written procedures and train the Grants Accounting team regarding period of performance to ensure all requests are made within the proper period based on the period of performance. The procedures and training will include grant period close, cost allowabilit...

Corrective Action: Management will update written procedures and train the Grants Accounting team regarding period of performance to ensure all requests are made within the proper period based on the period of performance. The procedures and training will include grant period close, cost allowability, requirements for documentation, and review of charges prior to requests. In addition, Grants Accounting has initiated monthly meetings with grantors to closely monitor grant spenddown, address any processing issues, and ensure proper cut-off. These meetings will be instrumental in tracking progress and oversight in our grant management process. Name of Responsible Individual(s): Jason Brenier, Shelly Courtois, and Judy Bokhari Anticipated Completion Date: April 2024

View Audit 322528

Finding 499696 (2023-007)

Material Weakness 2023

St. Vincent De Paul Village, Inc.

CA

Questioned Costs Subrecipient Monitoring Cash Management § 200.344

Corrective Action: Management will update written procedures and train the Grants Accounting team regarding period of performance to ensure all requests are made within the proper period based on the period of performance. The procedures and training will include grant period close, cost allowabilit...

Corrective Action: Management will update written procedures and train the Grants Accounting team regarding period of performance to ensure all requests are made within the proper period based on the period of performance. The procedures and training will include grant period close, cost allowability, requirements for documentation, and review of charges prior to requests. In addition, Grants Accounting has initiated monthly meetings with grantors to closely monitor grant spenddown, address any processing issues, and ensure proper cut-off. These meetings will be instrumental in tracking progress and oversight in our grant management process. Name of Responsible Individual(s): Jason Brenier, Shelly Courtois, and Judy Bokhari Anticipated Completion Date: April 2024

View Audit 322528 Questioned Costs: $1

Finding 499684 (2023-006)

Material Weakness 2023

St. Vincent De Paul Village, Inc.

CA

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Corrective Action: Management will enhance and enforce existing policies and procedures over monitoring of rental reasonableness in compliance with HUD-determined fair market rent requirements. Management and Tenant Services team will perform a thorough review of all tenant files, a task executed in...

Corrective Action: Management will enhance and enforce existing policies and procedures over monitoring of rental reasonableness in compliance with HUD-determined fair market rent requirements. Management and Tenant Services team will perform a thorough review of all tenant files, a task executed in partnership with landlords and property management companies. Perform internal compliance checks with sub-recipients by FJV compliance staff on a quarterly basis. Finally, develop additional oversight procedures for accounting and documentation of tenant rents to guarantee accuracy within our accounting general ledgers. Name of Responsible Individual(s): Jason Brenier, Maria Rafanan, Jesse Casement, Christina Madriles, Ann Wieczorek, and Judy Bokhari Anticipated Completion Date: December 2024

View Audit 322528 Questioned Costs: $1

Finding 499667 (2023-005)

Material Weakness 2023

St. Vincent De Paul Village, Inc.

CA

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

Corrective Action: Management is in the process of updating its written procedures to ensure that allowable costs and cost principles comply with 2 CFR 200.403. This includes Grants Accounting implementing a manual process that empowers program employees to submit and approve Time & Allocation Exce...

Corrective Action: Management is in the process of updating its written procedures to ensure that allowable costs and cost principles comply with 2 CFR 200.403. This includes Grants Accounting implementing a manual process that empowers program employees to submit and approve Time & Allocation Excel Sheets. These sheets include attestations certifying actual labor costs monthly. This information is then taken to input by the grants accounting team into the Request for Reimbursement (RFR). This measure ensures that labor costs are accurately reflected and compliant with regulatory requirements. In addition, Management will implement policies and procedures regarding regular review of allocations for workers compensation and other similar expenses to ensure accuracy. Name of Responsible Individual(s): Jason Brenier and Judy Bokhari Anticipated Completion Date: December 2024

View Audit 322528

Finding 499659 (2023-004)

Significant Deficiency 2023

St. Vincent De Paul Village, Inc.

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.303 § 200.430

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is...

Corrective Action: Management will review all cost allocations and implement documented policies and procedures to ensure sufficient support of any allocations of costs is maintained as required by 2 CFR §200.403. In addition, Management has developed a cost allocation worksheet and framework and is in the process of implementing a new procedure to ensure it is reviewed by accounting and grant managers to ensure accurate reporting. Name of Responsible Individual(s): Jason Brenier, Judy Bokhari, and Luz Gonzales-Toscano Anticipated Completion Date: December 2025

View Audit 322528

Corrective Action Plans

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