Corrective Action Plans

Finding 498968 (2023-003)

Material Weakness 2023

AL

Procurement, Suspension & Debarment § 200.303 § 200.319 § 200.320 § 200.326

Finding 2023-003 – Procurement Non-Compliance (Material Weakness) Federal Program Title: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Assistance Listing Number: Various Action taken in response t...

Finding 2023-003 – Procurement Non-Compliance (Material Weakness) Federal Program Title: U.S. Department of Treasury – ALN 21.027, Covid-19 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), and Research and Development Cluster Assistance Listing Number: Various Action taken in response to finding: We have taken steps to identify all active federal awards that are subject to Federal procurement requirements under 2 CFR Part 200; these actions will ensure that all purchase orders and other subcontract arrangements under existing federal awards are subject to our purchasing system policies and procedures for Federal awards. Southern Research’s existing purchasing policies and procedures for Federal awards were reviewed and deemed acceptable in 2017 by the Defense Contract Management Agency (DCMA) Huntsville, AL. Contracts appropriately classified as Federal awards will be subject to purchasing policies and procedures that are compliant with Federal regulations. As part of the business process review, we will implement processes to ensure that all new Federal awards are classified correctly, and that Southern Research’s Federal purchasing system policies and procedures are applied to all Federal awards. Name of Person Responsible for the Corrective Action Plan: David A. Rutledge, Sr. Advisor - Finance Planned Completion Date for Corrective Action Plan: We anticipate that new process recommendations from the business process review related to purchasing will be implemented no later than December 31, 2024.

View Audit 321789

Finding 498967 (2023-006)

Significant Deficiency 2023

City of Sheboygan

WI

Reporting

Management agrees with the comment. The City will work closely with the Water Utility to receive quarterly updates on actual expenditures incurred for the project going forward.

View Audit 321788

Finding 498965 (2023-001)

Significant Deficiency 2023

Sealaska Heritage Institute

AK

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

September 24, 2024 To whom it may concern: Sealaska Heritage Institute (SHI) respectfully submits the following corrective action plan for the year ending December 31, 2023. Our independent single federal audit was performed by Kendall, Prebola and Jones, LLC 133 Mann Street, PO Box 259, Bedford PA...

September 24, 2024 To whom it may concern: Sealaska Heritage Institute (SHI) respectfully submits the following corrective action plan for the year ending December 31, 2023. Our independent single federal audit was performed by Kendall, Prebola and Jones, LLC 133 Mann Street, PO Box 259, Bedford PA 15522. The following finding was discovered, and a corrective plan has been implemented: ALN Number 84.356A ALN Title Alaska Native Educational Programs Federal Award Years: 10/01/22 – 09/30/23 09/30/23 – 09/29/24 Type of Finding: Significant Deficiency in Internal Control over Compliance Condition and Context: SHI is engaged in a construction project, and it is partially funded by federal funds. While SHI primarily oversees educational programs and their reporting requirements, SHI was aware that Federal prevailing wage requirements apply to construction projects funded with Federal monies, and had conveyed this to its prime contractor for the construction project. SHI concurs with the auditor finding that SHI did not have timely submittal and review of the certified payrolls as required. Upon late review of the certified payrolls furnished to SHI by the design-build contractor and its subcontractors employed on this project, SHI confirmed that all wages paid met or exceed the prevailing wage rates for Juneau, Alaska. In order to ensure timely tracking and compliance with Federal prevailing wage requirements for this project, SHI has committed to the following corrective action plan. Corrective Action: • SHI’s design-build (prime) contractor for this project has been informed that it must provide certified payrolls to SHI for all workers on this project employed by itself or its subcontractors with contracts valued at $2,000 or more within seven (7) days of the end of each weekly pay period. Contractor will provide these either by e-mailing them to SHI’s Project Manager and/or by posting them on Procore, the construction management application it uses and to which SHI’s Project Manager has access. • SHI’s Project Manager will log and review the certified payrolls weekly, comparing them against the prevailing wage rates indicated in General Decision Number AK20240001 or any preceding or superseding document, and will maintain a record of said payrolls. • Should any construction project happen in the future, SHI will ensure an experienced federal audit consultant provides proper training in the particulars of construction project compliance requirements to the Project Manager and Finance Staff before the start of the project. • Prior to the start of any future construction project, SHI will develop a reporting requirement calendar that is checked/implemented during the course of the project. Completion Dates: Grant Award Compliance Review.……………………………………….. 06/24 Development of Compliance corrective action…………………….. 07/24 Implementation of Compliance corrective action………………… 07/24 Project Manager review/training in reporting requirements.. 06/24 SHI, the COO, and their contracted financial firm have discussed the corrective action plan and are working cooperatively to ensure that all deadlines are met for construction compliance and reporting purposes. Lee A. Kadinger Chief Operating Officer

View Audit 321781

Finding 498964 (2023-001)

Material Weakness 2023

Choose New Jersey, Inc.

NJ

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.213

Planned Corrective Action: Choose New Jersey (“CNJ”) understands the findings outlined in the audit report. CNJ has updated its procurement procedures for the federal grant to align with 2 CFR section 200.213 and 2 CFR section 180.300. To ensure that vendors supporting efforts on the federal grant a...

Planned Corrective Action: Choose New Jersey (“CNJ”) understands the findings outlined in the audit report. CNJ has updated its procurement procedures for the federal grant to align with 2 CFR section 200.213 and 2 CFR section 180.300. To ensure that vendors supporting efforts on the federal grant are not suspended or debarred from doing business with the federal government, CNJ has added a task in our Procurement Summary (procurement checklist) that specifically requires the project manager and CAO to verify the vendor’s eligibility in the System for Award Management ("SAM") maintained by the General Services Administration ("GSA") (available at SAM.gov). In addition to the verification that the vendor is NOT prohibited (debarred or suspended) from providing services to or contracting with the United States government, CNJ will retain a copy of the verification for the procurement file. This action will be completed during the vendor evaluation stage of the procurement and before contract is awarded to the vendor. It should be noted that the vendors selected for testing for 2023 were found to be in good standing. Corrective Action incorporation has already begun and will be fully implemented by 10/15/2024. Name of Contact Person: Jen Lenhardt, CAO, Choose New Jersey, Inc. One Gateway Center 11-43 Raymond Plaza West – Suite 1420 Newark, NJ 07102 609.293.1423 jlenhardt@choosenj.com

View Audit 321779

Finding 498960 (2023-002)

Material Weakness 2023

County of Armstrong

PA

Subrecipient Monitoring

Finding 2023-002 Subrecipient Monitoring AL 93.778 and Medical Assistance Program and DHS Medical Assistance Transportation Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program’s vendor. These monit...

Finding 2023-002 Subrecipient Monitoring AL 93.778 and Medical Assistance Program and DHS Medical Assistance Transportation Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program’s vendor. These monitoring procedures include documenting the procedures performed and the results of those procedures along with documenting the risk assessment associated with the selected procedures. Condition: During the audit, it was noted that the County was not performing subrecipient monitoring over the Program’s vendor. Cause: The County does not have adequate controls in place or the expertise to ensure proper subrecipient monitoring procedures. Effect: The Program’s vendor may be using grant funding inappropriately. This is a repeat finding from the prior year – Finding 2022- 002. Questioned Costs: The amount of questioned costs, if any, is undeterminable. Recommendation: The County should implement internal control procedures that ensure the vendor is being properly monitored and document those procedures and results of procedures. Management Response: Management is working to implement and document proper subrecipient monitoring internal controls. Anticipate Completion Date: Immediate

View Audit 321776

Finding 498959 (2023-003)

Material Weakness 2023

County of Armstrong

PA

Subrecipient Monitoring

Finding 2022-003 Subrecipient Monitoring AL 14.231 Emergency Solutions Grant Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program’s vendor. These monitoring procedures include documenting the procedu...

Finding 2022-003 Subrecipient Monitoring AL 14.231 Emergency Solutions Grant Program Criteria: Internal control procedures require the County to perform subrecipient monitoring procedures over the funding disbursed to the Program’s vendor. These monitoring procedures include documenting the procedures performed and the results of those procedures along with documenting the risk assessment associated with the selected procedures. Condition: During the audit, it was noted that the County was not performing subrecipient monitoring over the Program’s vendor. Cause: The County does not have adequate controls in place or the expertise to ensure proper subrecipient monitoring procedures. Effect: The Program’s vendor may be using grant funding inappropriately. Questioned Costs: The amount of questioned costs, if any, is undeterminable. Recommendation: The County should implement internal control procedures that ensure the vendor is being properly monitored and document those procedures and results of procedures. Management Response: Management is working to implement and document proper subrecipient monitoring internal controls. Anticipate Completion Date: Immediate

View Audit 321776

Finding 498958 (2023-003)

Significant Deficiency 2023

City of Rohnert Park

CA

Reporting Subrecipient Monitoring § 200.328

Finding 2023-003 Reporting – Internal Control and Compliance over Reporting Information on the Federal Program: Assistance Listing Number: 21.027 Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Federal Agency: Department of Treasury Pass-Through Entity: N/A ...

Finding 2023-003 Reporting – Internal Control and Compliance over Reporting Information on the Federal Program: Assistance Listing Number: 21.027 Federal Program Name: Coronavirus State and Local Fiscal Recovery Fund Federal Agency: Department of Treasury Pass-Through Entity: N/A Federal Award Number and Award Year: N/A - FY22-23 Criteria: Title 2 - Grants and Agreements. Subtitle A - Office of Management and Budget Guidance for Grants and Agreements. Chapter II - Office of Management and Budget Guidance. Part 200 - Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Subpart D - Post Federal Award Requirements. Performance and Financial Monitoring and Reporting. §200.328 – Financial Reporting (2 CFR 200.328): Unless otherwise approved by OMB, the Federal awarding agency must solicit only the OMB-approved governmentwide data elements for collection of financial information (at time of publication the Federal Financial Report or such future, OMB-approved, governmentwide data elements available from the OMB-designated standards lead. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting. The Federal awarding agency must use OMB-approved common information collections, as applicable, when providing financial and performance reporting information. Title 31 – Money and Finance: Treasury. Subtitle A – Office of the Secretary of the Treasury. Part 35 – Pandemic Relief Programs. Subpart A – Coronavirus State and Local Fiscal Recovery Funds. § 35.4 Reservation of authority, reporting. (c) Reporting and requests for other information. During the period of performance, recipients shall provide to the Secretary periodic reports providing detailed accounting of the uses of funds, modifications to a State or Territory’s tax revenue sources, and such other information as the Secretary may require for the administration of this section. In addition to regular reporting requirements, the Secretary may request other additional information as may be necessary or appropriate, including as may be necessary to prevent evasions of the requirements of this subpart. False statements or claims made to the Secretary may result in criminal, civil, or administrative sanctions, including fines, imprisonment, civil damages and penalties, debarment from participating in Federal awards or contracts, and/or any other remedy available by law. Condition: For the Coronavirus State and Local Fiscal Recovery Funds (SLFRF), the City did not submit the reports within the required deadline: Report Type Report Type Period Date Due Date Submitted Project and Expenditure Report Performance Report 1/1/23-3/31/23 4/30/2023 5/3/2023 Project and Expenditure Report Performance Report 4/1/23-6/30/23 7/31/2023 8/25/2023 Four (4) performance reports were tested and two (2) of the reports tested were not submitted by the required deadline. In addition, expenditure information reported on the Project and Expenditure Reports were not supported by the City’s accounting records and did not match expenditures reported on the SEFA. This was due to the City not reporting the Revenue Replacement project expenditures of $4,821,936. The City’s Corrective Action Plan: The City concurs with the auditors’ finding. The City will take steps to improve identification and monitoring of required grantor reporting deadlines. Contact person responsible for corrective action: Betsy Howze, Interim Finance Director Anticipated completion date: June 30, 2024

View Audit 321774

Finding 498957 (2023-006)

Material Weakness 2023

City of Bluffton

IN

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

FINDING 2023-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Of...

FINDING 2023-006 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Material Weakness Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All persons involved in the internal control; preparer, reviewer, etc. will be documented on the P&E Report document or with a checklist to show that we actually completed the internal controls we have in our policy. Anticipated Completion Date: immediately

View Audit 321762

Finding 498956 (2023-005)

Material Weakness 2023

City of Bluffton

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2023-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindia...

FINDING 2023-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All bids going out will include a Suspension and Debarment declaration that all bidders will need to fill out and sign, and the bid packets, including completed declaration, will be reviewed and approved by governance and management. Anticipated Completion Date: immediately

View Audit 321762

Finding 498955 (2023-004)

Material Weakness 2023

City of Bluffton

IN

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

FINDING 2023-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: Material Weakness, Other Matters. Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindi...

FINDING 2023-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Summary of Finding: Material Weakness, Other Matters. Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: All bids going out will include a Suspension and Debarment declaration that all bidders will need to fill out and sign, and the bid packets, including completed declaration, will be reviewed and approved by governance and management. Anticipated Completion Date: immediately

View Audit 321762

Finding 498954 (2023-003)

Material Weakness 2023

City of Bluffton

IN

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.300 § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Bri Lau...

FINDING 2023-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Activities Allowed or Unallowed, Allowable Costs / Cost Principles, Period of Performance Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Bri Lautzenheiser Contact Phone Number and Email Address: bri@blufftonindiana.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Any transfers that happen, will be reviewed, and will have better documentation of what claims made the transfer happen and make sure supporting documentation is attached to the claim to prove the use of the transferred funds. Anticipated Completion Date: Immediately

View Audit 321762 Questioned Costs: $1

Finding 498921 (2023-001)

Significant Deficiency 2023

Adventist Health System Sunbelt Healthcare Corporation

FL

Procurement, Suspension & Debarment Subrecipient Monitoring Period of Performance § 200.303

Corrective Action Plan December 31, 2023 Federal Award Findings and Questioned Costs – For the Year Ended December 31, 2023 Finding 2023-001 Information on the federal program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No...

Corrective Action Plan December 31, 2023 Federal Award Findings and Questioned Costs – For the Year Ended December 31, 2023 Finding 2023-001 Information on the federal program: Federal Grantor: United States Department of Health and Human Services and Department of Defense Assistance Listing No.: Various; Research and Development Cluster Period of Performance: January 1, 2023 – December 31, 2023 Views of responsible officials and planned corrective actions: Management agrees with the finding. Management plans to add controls to validate the accuracy of the suspension and debarment search results performed by the third-party service provider when the search results in no match. In addition, management plans to implement a process over the reconciliation of the vendor and supplier list to the third-party service provider list to ensure completeness of the suspension and debarment checks performed. Responsible official: Stacey Wilson, Director Grants Management Anticipated completion date: December 31, 2024

View Audit 321761

Finding 498920 (2023-001)

Significant Deficiency 2023

Regent at Maplewood, LLC Dba: the Seasons at Maplewood

MN

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to maintain tenant security deposits in a separate bank account in an amount adequate to cover the security deposit liability. The security deposit bank account balance was not adequate to cover the security depos...

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to maintain tenant security deposits in a separate bank account in an amount adequate to cover the security deposit liability. The security deposit bank account balance was not adequate to cover the security deposit liability. Recommendation: Recommend management fund the security deposit account in an amount that is adequate to cover the security deposit liability. There is no disagreement with the audit finding. Action taken in response to finding: We have funded the security deposit account in an amount adequate to cover the security deposit liability. Name of the contact person responsible for corrective action: Cassandra Johnson Planned completion date for corrective action plan: July 2024

View Audit 321756

Finding 498919 (2023-005)

Material Weakness 2023

Forth

OR

Procurement, Suspension & Debarment Material Weakness Internal Control / Segregation of Duties § 200.318 § 200.326

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should follow established written policies and procedures regarding procurement and properly document the process for each procurement made. Explanation of disagreement with audit findings: th...

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should follow established written policies and procedures regarding procurement and properly document the process for each procurement made. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and the following actions have been taken to improve the situation. We hired a Contracts & Compliance Manager in 2024 who is now responsible for ensuring the procurement process is properly documented for each procurement made. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: September 30, 2024

View Audit 321749

Finding 498918 (2023-004)

Material Weakness 2023

Forth

OR

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

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding allocation processes, including ensuring internal controls are in place. It would also be beneficial to eliminate or reduce the amoun...

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding allocation processes, including ensuring internal controls are in place. It would also be beneficial to eliminate or reduce the amount of manual inputs into the allocation process. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments, and the following action will be taken to improve the situation. We will establish written policies and procedures regarding allocation processes, including ensuring internal controls are in place by November 30, 2024. Simultaneously, we will also consider options to eliminate or reduce the amount of manual inputs into the allocation process. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Ronald Tran, Senior Finance Manager Plan completion date for corrective action plan: November 30, 2024

View Audit 321749

Finding 498917 (2023-003)

Material Weakness 2023

Forth

OR

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding firsttier subawards including tracking and proper internal control procedures. Explanation of disagreement with audit findings: there...

Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding firsttier subawards including tracking and proper internal control procedures. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and the following actions have been taken to improve the situation. We hired a Contracts & Compliance Manager in 2024 who is now responsible for reporting first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) by the reporting due date. Additionally, we established written policies and procedures regarding first-tier subawards including tracking and proper internal control procedures. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: September 30, 2024

View Audit 321749

Finding 498916 (2023-002)

Material Weakness 2023

Forth

OR

Cash Management Internal Control / Segregation of Duties Material Weakness § 200.303

Conservation Research and Development Program – Assistance Listing #81.086 Plan completion date for corrective action plan: October 31, 2024 Recommendation: The Organization should establish written policies and procedures regarding invoicing for cost- reimbursement related to federal grants which i...

Conservation Research and Development Program – Assistance Listing #81.086 Plan completion date for corrective action plan: October 31, 2024 Recommendation: The Organization should establish written policies and procedures regarding invoicing for cost- reimbursement related to federal grants which include proper segregation of duties. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments, and the following actions have been or will be taken to improve the situation. We hired a Grants Accountant in 2024 to take over the responsibility of preparing invoices for cost-reimbursement. This allows for the additional control of the Senior Finance Manager reviewing the invoices. This review is now being documented in writing. Additionally, there are procedures in place to ensure if the Senior Finance Manager prepares the invoice, the Director of Finance & Operations reviews and documents approval of the invoice. We will establish written policies and procedures to document this process by October 31, 2024. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Ronald Tran, Senior Finance Manager

View Audit 321749

Finding 498915 (2023-001)

Significant Deficiency 2023

Forth

OR

Subrecipient Monitoring § 200.303 § 200.332

2023-001 Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish or...

2023-001 Conservation Research and Development Program – Assistance Listing #81.086 Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies and procedures are being followed. Explanation of disagreement with audit findings: there is no disagreement with the audit findings. Action Plan: We agree with the auditor’s comments and will implement the following action steps to improve the situation. We will create and document a procedure which ensures we obtain audits on an annual basis from our subrecipients. This procedure will be implemented by October 31, 2024. Name(s) of the contact people responsible for correction action: Gina Avalos-Limardo, Director of Finance & Operations and Cho Heide, Contracts & Compliance Manager Plan completion date for corrective action plan: October 31, 2024

View Audit 321749

Finding 498907 (2023-002)

None 2023

City of Middletown

NY

Reporting

The City Treasurer will file the Single Audit before September 30th, 2024.

View Audit 321724

Finding 498902 (2023-001)

Significant Deficiency 2023

The Rogosin Institute, Inc.

NY

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Information on the federal program: Grantor: U.S Department of Defense, U.S. Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No. / FAIN / Pass-Through Entity (if applicable) / Pass-Through Entity Identifying Number (if applicable): 12.420 ...

Information on the federal program: Grantor: U.S Department of Defense, U.S. Department of Health and Human Services Program Name: Research and Development Cluster Assistance Listing No. / FAIN / Pass-Through Entity (if applicable) / Pass-Through Entity Identifying Number (if applicable): 12.420 / W81XWH2110945 / Royal Institution for the Advancement of Learning / McGill University / PT89891 93.847 / RC2DK125960 93.847 / UC2DK126021 / MDI Biological Laboratory / UC2DK126021-04/ROGOSIN 93.847 / U01DK123786 / University of Washington / UWSC11731 Views of responsible officials and planned corrective actions: Management concurs with this audit finding and will further enhance the suspension and debarment process and controls to meet the requirements of 2 CFR part 200. Name of responsible official: Name – Lauren Everson Title – Director of Finance, NYP Phone: (212-297-3325) Email: jrh9009@nyp.org Projected completion date: December 31, 2024

View Audit 321719

Finding 498901 (2023-002)

Significant Deficiency 2023

City of Charleston, South Carolina

SC

HUD Housing Programs Period of Performance Reporting

The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

View Audit 321709

Finding 498900 (2023-001)

Significant Deficiency 2023

City of Charleston, South Carolina

SC

Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management

The City of Charleston will implement internal controls and procedures to ensure all required reports are prepared, reviewed, and submitted within the program’s required timeframes, and with the correct amounts.

View Audit 321709

Finding 498897 (2023-004)

Material Weakness 2023

Clifford W. Beers and Subsidiaries

CT

Material Weakness Internal Control / Segregation of Duties

Department of Education Education Stabilization Fund – Assistance Listing No. 84.425 Recommendation: We recommend that internal policies and procedures be reviewed and updated to ensure underlying supporting documentation for payroll expenditures is fully retained going forward for this program. E...

Department of Education Education Stabilization Fund – Assistance Listing No. 84.425 Recommendation: We recommend that internal policies and procedures be reviewed and updated to ensure underlying supporting documentation for payroll expenditures is fully retained going forward for this program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The organization has enhanced its internal policies and procedures to ensure underlying supporting documentation is fully retained and maintained.Name of the contact person responsible for corrective action: Shaina Rodriguez, Vice President of Human Resources and Managed Services. Planned completion date for corrective action plan: June 30, 2024

View Audit 321699

Finding 498891 (2023-003)

Significant Deficiency 2023

Clifford W. Beers and Subsidiaries

CT

Procurement, Suspension & Debarment Significant Deficiency § 200.318 § 200.326

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR se...

Department of the Treasury Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend that the Organization review its procurement policy and conflict of interest policy and make necessary changes to comply with the criteria as set out in 2 CFR sections 200.318 and 200.326. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization will review and modify the procurement policy and conflict of interest policy and make all necessary changes for compliance. Name of the contact person responsible for corrective action: Michael Riso, CFO Planned completion date for corrective action plan: June 30, 2024

View Audit 321699

Finding 498888 (2023-001)

Significant Deficiency 2023

Confederated Tribes of Coos, Lower Umpqua & Siuslaw Indians

OR

Procurement, Suspension & Debarment

Person(s) Responsible for Corrective Action: Donald Moos, CFO 1245 Fulton Avenue Coos Bay, OR 97420 Estimated Completion Date: ___July 2024_____ In July 2024, we reviewed our active vendors and documented debarment reports within each file. Workflows were updated to require all new vendors to have d...

Person(s) Responsible for Corrective Action: Donald Moos, CFO 1245 Fulton Avenue Coos Bay, OR 97420 Estimated Completion Date: ___July 2024_____ In July 2024, we reviewed our active vendors and documented debarment reports within each file. Workflows were updated to require all new vendors to have documentation included in their vendor file. An annual workflow has been initiated to review all vendors in January each year to update debarment statements to vendor file.

View Audit 321688

Corrective Action Plans

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