Corrective Action Plans

Finding 496636 (2023-012)

Significant Deficiency 2023

City of Boston

MA

Procurement, Suspension & Debarment Eligibility Significant Deficiency § 200.303

Boston Public Schools (BPS) has revised their tracking and documentation for special education expenses. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496635 (2023-011)

Material Weakness 2023

City of Boston

MA

Allowable Costs / Cost Principles § 200.303 § 200.308 § 200.309 § 200.403 § 200.430

Boston Public Schools (BPS) has updated its’ training and guidance for timekeepers. Timekeepers participated in enhanced trainings during August of 2024 in preparation of the new school year. Anticipated Completion Date: August 31, 2024 Responsible Contact Person: Colin Musto, Assistant City Audit...

Boston Public Schools (BPS) has updated its’ training and guidance for timekeepers. Timekeepers participated in enhanced trainings during August of 2024 in preparation of the new school year. Anticipated Completion Date: August 31, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496634 (2023-010)

Material Weakness 2023

City of Boston

MA

Material Weakness Internal Control / Segregation of Duties § 200.303

Boston Public Schools (BPS) is continuously reinforcing its protocols with school leaders to ensure they are promptly school certifications. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496633 (2023-009)

Material Weakness 2023

City of Boston

MA

HUD Housing Programs Material Weakness Reporting § 200.303

Boston Public Schools (BPS) has updated training for school leaders to review school leader certification of withdrawals. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496632 (2023-008)

Material Weakness 2023

City of Boston

MA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Material Weakness § 200.303 § 200.64 § 200.67

Boston Public Schools (BPS) has revised its’ consultation process to ensure it happens with fidelity and that records are properly stored. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496631 (2023-007)

Material Weakness 2023

City of Boston

MA

Subrecipient Monitoring Material Weakness Reporting § 200.303

Boston Public Schools (BPS) is continuously working with DESE to ensure they are meeting compliance with FR-1 deadlines. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496630 (2023-006)

Material Weakness 2023

City of Boston

MA

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.430

Boston Public Schools (BPS) has updated its’ training and guidance for timekeepers. Timekeepers participated in enhanced trainings during August of 2024 in preparation of the new school year. Anticipated Completion Date: August 31, 2024 Responsible Contact Person: Colin Musto, Assistant City Audit...

Boston Public Schools (BPS) has updated its’ training and guidance for timekeepers. Timekeepers participated in enhanced trainings during August of 2024 in preparation of the new school year. Anticipated Completion Date: August 31, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431 Questioned Costs: $1

Finding 496629 (2023-005)

Material Weakness 2023

City of Boston

MA

Subrecipient Monitoring § 200.303 § 200.331

Mayor’s Office of Housing (MOH) has implemented control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Gran...

Mayor’s Office of Housing (MOH) has implemented control procedures to ensure that each subrecipient is evaluated for risk of noncompliance to ensure appropriate subrecipient monitoring. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496627 (2023-004)

Significant Deficiency 2023

City of Boston

MA

School Nutrition Programs Cash Management Significant Deficiency § 200.303

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented advanced policies including additional segregation of duties to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto...

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented advanced policies including additional segregation of duties to ensure that all deposits made have clear and accurate cash receipt forms. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431

Finding 496626 (2023-003)

Material Weakness 2023

City of Boston

MA

Questioned Costs School Nutrition Programs Cash Management § 200.303

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented various procedures in order to accurately report meal counts and claims. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@bos...

Boston Public Schools (BPS) Food and Nutrition Services (FNS) has implemented various procedures in order to accurately report meal counts and claims. Anticipated Completion Date: June 30, 2024 Responsible Contact Person: Colin Musto, Assistant City Auditor, Grants Monitoring Unit colin.musto@boston.gov

View Audit 319431 Questioned Costs: $1

Finding 496623 (2023-001)

Material Weakness 2023

American Institute for Foreign Study Foundation, Inc.

CT

Allowable Costs / Cost Principles

2023-001 Professional and Cultural Exchange Programs - Citizen Exchanges – Assistance Listing No. 19.415 Recommendation: American Institute For Foreign Study Foundation, Inc. should formalize review over allocations to the award to ensure that allocations are based on actual time and effort. Expla...

2023-001 Professional and Cultural Exchange Programs - Citizen Exchanges – Assistance Listing No. 19.415 Recommendation: American Institute For Foreign Study Foundation, Inc. should formalize review over allocations to the award to ensure that allocations are based on actual time and effort. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure only actual salary is charged to the awards. Name of the contact person responsible for corrective action: James Mahoney, CFO Planned completion date for corrective action plan: August 31, 2024 If the U.S. Department of State has questions regarding this plan, please call James Mahoney at 203-399-5143.

View Audit 319423

Finding 496612 (2023-002)

Significant Deficiency 2023

True Access Capital Corporation

DE

Reporting Matching / Level of Effort / Earmarking

Corrective Action Plan: TAC will create a comprehensive spreadsheet to consolidate all federal reporting deadlines. This spreadsheet will delineate the appropriate staff accountable for each report and facilitate efficient tracking of completion and submission dates. Responsible Person: Vandell Hamp...

Corrective Action Plan: TAC will create a comprehensive spreadsheet to consolidate all federal reporting deadlines. This spreadsheet will delineate the appropriate staff accountable for each report and facilitate efficient tracking of completion and submission dates. Responsible Person: Vandell Hampton, Jr., President & CEO Anticipated Completion Date: September 30, 2024

View Audit 319411

Finding 496611 (2023-005)

Significant Deficiency 2023

Hendry County Bocc

FL

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

The County will implement necessary internal controls to ensure that expenditures included as allowable costs are in compliance with the requirements of the program and the Uniform Guidance. Additionally, the County will ensure that relevant personnel are properly trained to perform procedures to ac...

The County will implement necessary internal controls to ensure that expenditures included as allowable costs are in compliance with the requirements of the program and the Uniform Guidance. Additionally, the County will ensure that relevant personnel are properly trained to perform procedures to accurately report expenditures.

View Audit 319410

Finding 496610 (2023-004)

Material Weakness 2023

Hendry County Bocc

FL

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303

The County will implement necessary internal controls to ensure that expenditures included as allowable costs are in compliance with the requirements of the program and the Uniform Guidance. Additionally, the County will ensure that relevant personnel are properly trained to perform procedures to ac...

The County will implement necessary internal controls to ensure that expenditures included as allowable costs are in compliance with the requirements of the program and the Uniform Guidance. Additionally, the County will ensure that relevant personnel are properly trained to perform procedures to accurately report expenditures.

View Audit 319410

Finding 496484 (2023-004)

Significant Deficiency 2023

City of New Haven

CT

Reporting § 200.512

Finding 2023-004: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2023 and 2022 Single Audit Reporting Packages. Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of feder...

Finding 2023-004: Significant Deficiency and Noncompliance Finding, Late Issuance of the 2023 and 2022 Single Audit Reporting Packages. Applicable to all assistance listing numbers (ALN’s) and federal agencies (and passthrough entities) included on the accompanying schedule of expenditures of federal awards for the years ended June 30, 2023, and June 30, 2022. Finding: Uniform Guidance 2 CFR 200.512(a) requires that each organization’s audit must be completed, and the data collection form and reporting package should be submitted within the earlier of 30 days after receipt of the auditor’s report or nine months after the end of the audit period. The City failed to meet the required filing deadlines for its Single Audit packages for the fiscal years ending June 30, 2022, and June 30, 2023. Corrective Actions Taken: 1. Improved Reporting Processes: Steps have been taken to streamline the audit reporting process, including enhanced coordination with auditors and improvements to internal procedures. Contact: Dr. Kristi Samperi, Controller. Anticipated Completion Date: 12/24 2. Resource and Training Enhancements: During the last few audits, the City was without a Controller, requiring the Budget Director to manage two roles. The City has hired a new Controller in 2024 and is implementing additional resources and training to ensure timely completion of audit reports. Contact: Dr. Kristi Samperi, Controller. Anticipated Completion Date: 12/24

View Audit 319406

Finding 496483 (2023-003)

Significant Deficiency 2023

City of New Haven

CT

Subrecipient Monitoring HUD Housing Programs Reporting

Finding 2023-003: Significant Deficiency and Noncompliance Finding, Reporting-Annual Assistance Finding: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ...

Finding 2023-003: Significant Deficiency and Noncompliance Finding, Reporting-Annual Assistance Finding: Under the Lead-Based Paint Hazard Reduction Grant Program Terms and Conditions issued by the U.S. Department of Housing and Urban Development, Cities were required to submit an annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2021, to June 30, 2022, by January 10, 2023. The City failed to submit the required annual race and ethnic data reporting form HUD-27061 covering the period from July 1, 2021, to June 30, 2022, by the January 10, 2023, deadline, as mandated under the Lead-Based Paint Hazard Reduction Grant Program by the U.S. Department of Housing and Urban Development. Corrective Actions Taken: 1. Centralized Compliance Tracking: The City has implemented a centralized system for monitoring grant reporting deadlines to prevent missed submissions. Contact: Maritza Bond, Health Director. Anticipated Completion Date: 12/24 2. Dedicated Compliance Oversight: A dedicated compliance officer now oversees all grant-related activities to ensure adherence to reporting requirements. Contact: Shannon McCue, Budget Director & Maritza Bond, Health Director. Anticipated Completion Date: 10/24

View Audit 319406

Finding 496481 (2023-003)

Significant Deficiency 2023

City of Warwick, Rhode Island

RI

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

Special Education - Preschool Grants (IDEA Preschool) – Assistance Listing # 84.173 Recommendation: We recommend the Department develop and document internal controls to provide proper support and approval over the allocation of salaries. Explanation of disagreement with audit finding: There is no...

Special Education - Preschool Grants (IDEA Preschool) – Assistance Listing # 84.173 Recommendation: We recommend the Department develop and document internal controls to provide proper support and approval over the allocation of salaries. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Finance will routinely review salary allocations to IDEA and compare to grant budget. Adjustments to allocations should be documented with support. WPS is implementing a new financial reporting system that includes a grant reporting module – this will help resolve issues with internal controls related to grants moving forward. Name(s) of the contact person(s) responsible for corrective action: Brandon Bohl - Director of Finance Warwick Public Schools Planned completion date for corrective action plan: June 30, 2025

View Audit 319403

Finding 496471 (2023-002)

Significant Deficiency 2023

City of Warwick, Rhode Island

RI

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Education Stabilization Fund – Assistance Listing # 84.425D Recommendation: We recommend the City reviews and enhances internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Explanation of disagreement with audit ...

Education Stabilization Fund – Assistance Listing # 84.425D Recommendation: We recommend the City reviews and enhances internal controls and procedures to ensure that all reports are prepared and reviewed for accuracy and supporting documentation maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WPS is implementing a new financial reporting system that includes a grant reporting module – this will help resolve issues with internal controls related to grants moving forward. Name(s) of the contact person(s) responsible for corrective action: Brandon Bohl - Director of Finance Warwick Public Schools Planned completion date for corrective action plan: June 30, 2025

View Audit 319403

Finding 496464 (2023-002)

Material Weakness 2023

City of Federal Way

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2023-002 Finding caption: The City’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Steve Groom, Finance Director 33325 8th Ave S Federal Way, WA 98003 253-835-...

Finding ref number: 2023-002 Finding caption: The City’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Steve Groom, Finance Director 33325 8th Ave S Federal Way, WA 98003 253-835-2520 Corrective action the auditee plans to take in response to the finding: The City concurs that maintaining strong internal controls is appropriate. Management is committed to taking corrective action to ensure compliance with federal requirements and in fact did so immediately. Since the enactment of the SLFRF, city staff made significant efforts to keep up with the multiple and evolving guidelines rules and FAQs issued by Treasury, and attended numerous trainings. The initial lack of guideline clarity resulted in information-sharing webinars hosted by reputable state-wide and nation-wide associations such as AWC and GFOA. City staff, management and governing body exercised initial restraint in approving projects for spending of SLFRF funding in order to avoid inadvertently violating a rule issued subsequently. One example is that exemption from Federal supplanting rules came out in later guidance and the City then proceeded relying on that explicit clarification. This is the second finding for the same issue because the timing of requirement awareness spanned two years. The rule in question was clarified in 2023, after the City’s opportunity to comply in 2022 and part of 2023 had passed, and the City acted to correct immediately. The City remains dedicated to ensuring Federal funds are spent in compliance with all governing laws and regulations. The City’s immediate change being implemented was to eliminate recipients that cannot 1) register on SAM.gov, 2) contractually attest compliance or 3) provide self-attestation. The City believes that adequate controls and procedures are in place and that internal training and communication are the appropriate corrective steps. Anticipated date to complete the corrective action: 01/01/2024

View Audit 319390

Finding 496463 (2023-005)

Material Weakness 2023

Washington Parks Academy

MI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Even though the Academy transferred $3,345,325 of ESSER funds to LKAYA based on the intergovernmental agreement that was in place during that time, the Academy itself did incur ESSER eligible costs that could have been applied against these ESSER dollars if they had remained within the Academy. The ...

Even though the Academy transferred $3,345,325 of ESSER funds to LKAYA based on the intergovernmental agreement that was in place during that time, the Academy itself did incur ESSER eligible costs that could have been applied against these ESSER dollars if they had remained within the Academy. The costs incurred involved improvements to technology, maintaining and increasing additional staff, curriculum materials, instructional supplies, and staff training to name a few.

View Audit 319381 Questioned Costs: $1

Finding 496462 (2023-004)

Material Weakness 2023

Washington Parks Academy

MI

Cash Management Material Weakness

Management will ensure experienced staff is recruited, retained, and trained to support grant revenues. This includes recording the grants correctly in the G/L and also pulling the correct draws from the State website accurately and timely.

View Audit 319381

Finding 496461 (2023-003)

Material Weakness 2023

Washington Parks Academy

MI

Material Weakness

The necessary review and analysis of GL accounts will be completed according to the established month end and annual close procedure check lists. Audit engagement will begin no later than August for FY 2024. Any new, as well as current staff, will receive periodic in-service centered around the MI P...

The necessary review and analysis of GL accounts will be completed according to the established month end and annual close procedure check lists. Audit engagement will begin no later than August for FY 2024. Any new, as well as current staff, will receive periodic in-service centered around the MI Public School Accounting manual to ensure thorough understanding of the expectations and processes for school fund accounting

View Audit 319381

Finding 496460 (2023-002)

Material Weakness 2023

Washington Parks Academy

MI

Subrecipient Monitoring Material Weakness

The Finance Director will review staffing resources and make appropriate adjustments to ensure that adequate levels of staffing and quality staff are recruited and retained. New ERP software has now been put in place to facilitate input, reporting, and analysis of fund accounting and accurate GL cla...

The Finance Director will review staffing resources and make appropriate adjustments to ensure that adequate levels of staffing and quality staff are recruited and retained. New ERP software has now been put in place to facilitate input, reporting, and analysis of fund accounting and accurate GL classification

View Audit 319381

Finding 496459 (2023-001)

Material Weakness 2023

Washington Parks Academy

MI

Material Weakness Internal Control / Segregation of Duties

The Accounting Team will adhere to the established monthly checklist and physically check off items as they are completed, including the date of completion. Management will review the monthly close procedural checklist to ensure established processes have been followed and completed and sign off on...

The Accounting Team will adhere to the established monthly checklist and physically check off items as they are completed, including the date of completion. Management will review the monthly close procedural checklist to ensure established processes have been followed and completed and sign off on each month after completion/close is verified.

View Audit 319381

Finding 496458 (2023-004)

None 2023

Saint John's Program for Real Change

CA

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

2023-004— REPORTING Jose Dominguez, Interim CEO, jdominguez@saintjohnsprogram.org Corrective Action Planned: Saint John's Program for Real. Change is dedicated to the meticulous implementation of a system for preserving financial records, supporting documents, statistical records, and all other non-...

2023-004— REPORTING Jose Dominguez, Interim CEO, jdominguez@saintjohnsprogram.org Corrective Action Planned: Saint John's Program for Real. Change is dedicated to the meticulous implementation of a system for preserving financial records, supporting documents, statistical records, and all other non-Federal entity records relevant to a Federal award. The electronic versions of these documents will be consistently stored in the Sharepoint cloud on a monthly basis for permanent retention. Furthermore, the organization will produce paper copies of these documents and securely maintain them in an archive accessible exclusively to authorized personnel. The paper copies will be systematically arranged by year and alphabetical order to facilitate efficient retrieval upon request by auditors or reviewing entities. A comprehensive schedule delineating the stipulated retention period for each document type will be generated in accordance with the pertinent Uniform Guidance record retention guidelines. In addition, all supporting documentation pertaining to a program funded by a Federal Grant, whether comprising an intake form or client information, will be stored in both digital and paper formats, and will be maintained in compliance with the record retention guidelines outlined in the Uniform Guidance. AlL records wilt undergo an annual review prior to filing to ensure the presence of all necessary documents and uniform adherence to regulatory requirements. Anticipated Completion Date: 8/30/2024

View Audit 319380

Corrective Action Plans

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