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Finding 485117 (2023-003)
Significant Deficiency 2023
2023-003 SUSPENSION AND DEBARMENT Recommendations: CRI recommends the IRL Council implement controls to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. CRI suggests the Cou...
2023-003 SUSPENSION AND DEBARMENT Recommendations: CRI recommends the IRL Council implement controls to ensure the Council does not enter a subaward or other covered transaction with a party that is suspended, debarred or otherwise excluded from participating in federal awards. CRI suggests the Council include a clause in the subrecipient contracts stating the contractor is not suspended or debarred. This clause would need to be included in any modifications to the contracts that provide for additional funding. For other covered transactions, the Council should document their verification of the vendor’s status on the System for Award Management (SAM) Exclusions website. Management’s Response: The IRL Council will establish the following policies and controls to monitor and ensure compliance with SAM.gov requirements. • The IRL Council’s procurement process for federally funded projects will include an af􀏔idavit where applicants attach their SAM.gov proof at the time of proposal submission. • The IRL Council staff will review all proposal submissions to include SAM.gov review and provide screenshots of when the information was checked. These screenshots will be saved in the procurement file. • Current vendors and/or recipients of federal funds will be checked for SAM.gov compliance on an annual basis. The annual checks will be screenshot and uploaded into the vendor files. Vendor files will be updated accordingly with the date of the Sam.gov check by Finance. The annual compliance check will be a standard part of the end-of fiscal year closeout process. • Current vendors working on federally funded projects will be checked for SAM.gov compliance at the time of any change order, amendment, or contract adjustment that is requested. At the time of the change order, amendment or contract adjustment Sam.gov compliance will be checked and a Sam.gov screenshot will be uploaded into the vendor files. Responsible Party: Daniel Kolodny, Chief Operating Officer Anticipated Completion Date: December 31, 2024.
Finding 485116 (2023-002)
Significant Deficiency 2023
PROCUREMENT 2023-002 PROCUREMENT Recommendation: The IRL Council should review all procurements for compliance with award terms, Uniform Guidance, and Federal Acquisition Regulations prior to submitting issuing the purchase order or subrecipient contract. Management’s Response: The IRL Council Op...
PROCUREMENT 2023-002 PROCUREMENT Recommendation: The IRL Council should review all procurements for compliance with award terms, Uniform Guidance, and Federal Acquisition Regulations prior to submitting issuing the purchase order or subrecipient contract. Management’s Response: The IRL Council Operating Procedures Manual lists 14 days as the minimum response time for competitive procurement of services. However, during an EPA review of IRL Council procurement practices, a single instance was found to be less than 30 days per federal procurement standards. In a letter to EPA dated May 3, 2024, the IRL Council proposed a corrective action that would replace the contractor that had been procured less than the 30-day response time with one that had been procured consistent with federal policy and defer revenues to FY 2024 for the new project. The Corrective action was approved by EPA by issuance of Award 4T-02D39922 modification 3 on June 16, 2024. The IRL Council will amend its Operating Procedures Manual to ensure that all future procurements, whether federally funded or otherwise, require a minimum 30-day response time. Responsible Parties: Daniel Kolodny, Chief Operating Officer and Duane De Freese, Executive Director Anticipated Completion: November 15, 2024
Finding 485115 (2023-001)
Material Weakness 2023
2023-001 CASH MANAGEMENT Recommendation: The IRL Council should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings. Management’s Response: Initial discussions with EPA staff regarding fiscal management of the funds...
2023-001 CASH MANAGEMENT Recommendation: The IRL Council should obtain clarification in writing from the grantor on guidance outside of the established procedures to prevent future misunderstandings. Management’s Response: Initial discussions with EPA staff regarding fiscal management of the funds from the Bipartisan Infrastructure Law (BIL) suggested that management of the cash for the BIL award was different than the Section 320 grant award. During these discussions, cash flow was brought up as a possible concern by IRL Council staff. EPA staff initially indicated that the grant funds were not reimbursable and that all funds would be available as soon as an award was made. The Council was not made aware that the RAIN polices would be in effect for BIL funds. The Council interpreted EPA correspondences as authorization to withdraw funds immediately upon receiving the award. Upon making the draw, EPA provided the IRL Council with clarifying information with regards to the RAIN policy. The IRL Council responded quickly to this new information and the appropriate amount of funds were returned in a timely manner. The EPA was satis􀀁ied with the corrective response and outcome. The IRL Council will continue to manage all EPA federal grants as a reimbursable grant award to ensure the RAIN policy is followed correctly. For any other Federal agency grants that may be awarded, strict adherence to that agency’s policies for treasury draws will be made. Responsible Party: Daniel Kolodny, Chief Operating Officer
Finding 485110 (2023-002)
Significant Deficiency 2023
U.S. DEPARTMENT OF TREASURY Suspension and Debarment Recommendation: We recommend following the requirements for suspension and debarment per the Uniform Guidance, including the date performed and retain required documentation. Explanation of disagreement with audit finding: There is no disagreement...
U.S. DEPARTMENT OF TREASURY Suspension and Debarment Recommendation: We recommend following the requirements for suspension and debarment per the Uniform Guidance, including the date performed and retain required documentation. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will continue to place procedures in place which ensure the policies are followed. Name(s) of the contact person(s) responsible for corrective action: Larry Baugh, Board Chairman Planned completion date for corrective action plan: November 30, 2024
Status: Corrective action in progress Corrective Action: We agree with the recommendation. Regarding award number 08CH010552, we will update our internal procedures for reporting FFATA amounts in the period of obligation rather than when the expense was incurred. For 08HE000797 award, the grant acco...
Status: Corrective action in progress Corrective Action: We agree with the recommendation. Regarding award number 08CH010552, we will update our internal procedures for reporting FFATA amounts in the period of obligation rather than when the expense was incurred. For 08HE000797 award, the grant accountant that managed this award unexpectedly left the city. Given that other Coronavirus State and Local Fiscal Recovery Funds were exempt from the reporting and that he filed the FFATA for the main Head Start grant, we believe he misunderstood the guidance that this funding was also exempt. For all future Federal funding awards, we will ensure the grant accountant has a thorough understanding of the FFATA reporting requirements. Person(s) Responsible for Implementing: Accounting Services Implementation Date: July 2024
Status: Completed Corrective Action: The City disagrees with the finding. BDO’s review of the ERA2 administration costs should consider the timing of the static report submission. The report was prior to monthly close/reconciliation for March 2023 administrative expenses, which occurs the following ...
Status: Completed Corrective Action: The City disagrees with the finding. BDO’s review of the ERA2 administration costs should consider the timing of the static report submission. The report was prior to monthly close/reconciliation for March 2023 administrative expenses, which occurs the following month. The correct administration costs for Q2 is $40,484.26. We make every attempt to coincide the grant reporting requirements however, if there are updates/changes needed we make those adjustments in future reports. Person(s) Responsible for Implementing: Melissa Thate, HOST HSHR Director Implementation Date: N/A- the City disagrees with the finding
Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will implement additional trainings and guidance for contract monitoring including invoice review and encourage a standard template in Excel to avoid calculation errors. The City is also currently implem...
Status: Corrective action in progress Corrective Action: The City agrees with the finding. DDPHE will implement additional trainings and guidance for contract monitoring including invoice review and encourage a standard template in Excel to avoid calculation errors. The City is also currently implementing a city-wide grants management system and we hope to include invoice review and tracking in this new system by 2025. Person(s) Responsible for Implementing: DDPHE – Paige Cheney Implementation Date: September 2024 and potentially January 2025
View Audit 317890 Questioned Costs: $1
Status: Corrective action in progress Corrective Action: The City agrees with the finding. HOST makes every effort to comply with all federal requirements. Starting with our 2020 ESG Award, HOST entered into 3-year contracts with our subrecipient providers within the outlined periods of performance ...
Status: Corrective action in progress Corrective Action: The City agrees with the finding. HOST makes every effort to comply with all federal requirements. Starting with our 2020 ESG Award, HOST entered into 3-year contracts with our subrecipient providers within the outlined periods of performance (POP): E-20-MC-08-0005/AWD-00001006 (06/26/2020 – 06/25/2022) E-21-MC-08-0005/AWD-00001212 (07/26/2021 – 07/25/2023) E-22-MC-08-0005/AWD-00001376 (11/04/2022 – 11/03/2024) While the annual Federal awards indicated a 24-month POP from the date of the contract execution/IDIS obligation date, the subrecipient contracts were encumbered and executed within a calendar year POP and amended as necessary upon receipt of the annual award. As such, there was overlap in the eligibility dates. The $2,426.75 under SI-00629712 was for EMERGENCY Essential Services for August case management. SI-00629712 was for eligible expenses in August 2023. The expenses should have been expensed under the E22 award based on the Federal POP. Executing multiple-year contracts for annual grant awards was a pilot project with the goal of improving the process. HOST has determined that annual subrecipient awards accordant to our Federal award timeline is more supportive of our internal grant policies and procedures. The Division of Operations and Impact has established policies and procedures that guarantee appropriate internal controls are in place to ensure that eligible expenditures are within a grant’s period of performance. A non-exhaustive list of the established policies that illustrate this are listed below: ٠Managing the AP Inbox & Data Entry into Salesforce ٠HOST Accounts Payable Voucher Processing Aid ٠HOST Contract Invoice Process Map Person(s) Responsible for Implementing: Ami Webb, HOST Division of Operations & Impact Finance Director Implementation Date: Complete
Status: Completed Corrective Action: The City agrees with the finding. After receiving 2022-007, DDPHE has consulted with the City’s Federal Grants Manager, other agencies that typically have subrecipients for Federal awards, and the City Attorney’s Office to review the current standard contract pro...
Status: Completed Corrective Action: The City agrees with the finding. After receiving 2022-007, DDPHE has consulted with the City’s Federal Grants Manager, other agencies that typically have subrecipients for Federal awards, and the City Attorney’s Office to review the current standard contract provisions to ensure they cover all required provisions and has modified those provisions accordingly. DDPHE has a new template for Scope of Work that includes the missing information that was identified by BDO. DDPHE also included a step to verify the recording of the SAM.gov in the scope of work. This will be implemented in any Federally funded contracts going forward and we will be trained on this during Contracts & Grants training on a regular basis. Person(s) Responsible for Implementing: DDPHE – Paige Cheney Implementation Date: October 2023
Status: Completed Corrective Action: The City agrees with the finding. Remediation began with 2022-006. HOST makes every effort to comply with not only federal requirements but also City Charter requirements for timely payment. Occasionally there are exceptional circumstances where there is a need t...
Status: Completed Corrective Action: The City agrees with the finding. Remediation began with 2022-006. HOST makes every effort to comply with not only federal requirements but also City Charter requirements for timely payment. Occasionally there are exceptional circumstances where there is a need to update the City financial system Workday, for budget modifications or the like that could result in a delay of payment. In an effort to determine these items ahead of time we’ve updated our internal policies to require finance budget review prior to contract execution. Likewise, HOST is engaged in an application upgrade with Salesforce which is in the final User Acceptance Testing (UAT) phase to incorporate changes that now include status tracking for vendor invoice submissions and reimbursement payments. This will support a more comprehensive and accurate accounting of any legitimate postponed payments due to waiting on more required information from vendors, budget modifications, contract amendments, etc. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: Q1-2024
Status: Complete Corrective Action: This matter has been remediated, however, per the assessment this issue is a carryover into 2023 sub-awards based on the contract timeframes. The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to addres...
Status: Complete Corrective Action: This matter has been remediated, however, per the assessment this issue is a carryover into 2023 sub-awards based on the contract timeframes. The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to address the finding prior to December 31, 2022.To remediate prior findings 2022-008 and 2021-011, HOST updated the agency’s Contract & Performance Management Policies under Section VII. Procedure Process Map, Step 1 to include the requirement to verify Suspension and Debarment for all subgrantees utilizing federal funding. This policy was modified and completed in July 2023, and a copy of this was provided to BDO on August 16, 2023, in response to the finding. This issue has been remediated, however, per the assessment, this issue is a carryover into 2023 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST – Jon Luper Implementation Date: July 2023
Status: Complete Corrective Action: This matter has been remediated, however, per the assessment this issue is a carryover into 2023 sub-awards based on the contract timeframes. The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to addres...
Status: Complete Corrective Action: This matter has been remediated, however, per the assessment this issue is a carryover into 2023 sub-awards based on the contract timeframes. The City agrees with the finding. However, based on when the finding was identified, there was insufficient time to address the finding prior to December 31, 2023. To remediate prior findings 2022-005 and 2021-010, HOST updated the agency’s Grant Administrator Policies & Procedures, and our Contract & Performance Management Policies that now include language to ensure obligation of funding within the required deadlines. These policies were modified complete in June 2022 and July 2023. HOST’s current Notice of Funding Availability (NOFA) cycle for ESG funding will apply to subrecipient programs awarded beginning 01/01/2024, with anticipated contract executions in Q4 2023. Copies of both policies were provided to BDO on August 16, 2023, in response to the finding. This matter has been remediated, however, per the assessment this issue is a carryover into 2022 sub-awards based on the contract timeframes. Person(s) Responsible for Implementing: HOST Operations Division Directors Implementation Date: July 2023
a. Contact person responsible for corrective action: Susan Cothren, Business Manager. b. Description of corrective action to be taken: The District will submit the required Annual Project Performance Activity Report to the grantor agency by the indicated timelines in the future. c. Anticipated...
a. Contact person responsible for corrective action: Susan Cothren, Business Manager. b. Description of corrective action to be taken: The District will submit the required Annual Project Performance Activity Report to the grantor agency by the indicated timelines in the future. c. Anticipated completion date of corrective action: The report was submitted in June 2024.
Finding 485090 (2023-001)
Significant Deficiency 2023
FGI had reviewed the published guidance on FFATA reporting on sub-awards, based on our reading we determined the agreement with UK was exempt. We also consulted with our attorney and received similar advice that the agreement was exempt from reporting requirements. Thus, the cause is not a result of...
FGI had reviewed the published guidance on FFATA reporting on sub-awards, based on our reading we determined the agreement with UK was exempt. We also consulted with our attorney and received similar advice that the agreement was exempt from reporting requirements. Thus, the cause is not a result of insufficient controls but a different interpretation of the requirements. Context: Part 170—Reporting Subaward and Executive Compensation Information Section 170.110(b) Exceptions. (1) None of the requirements in this part apply to an individual who applies for or receives a Federal award as a natural person (i.e., unrelated to any business or nonprofit organization he or she may own or operate in his or her name). (2) None of the requirements regarding reporting names and total compensation of a non-Federal entity's five most highly compensated executives apply unless in the non-Federal entity's preceding fiscal year, it received— (i) 80 percent or more of its annual gross revenue in Federal procurement contracts (and subcontracts) and (ii) $25,000,000 or more in annual gross revenue from Federal procurement contracts (and subcontracts) and Federal financial assistance awards subject to the Transparency Act, as defined at § 170.320; and (3) The public does not have access to information about the compensation of senior executives, unless otherwise publicly available, through periodic reports led under section 13(a) or 15(d) of the Securities Exchange Act of 1934 (15 U.S.C. 78m(a), 78o(d)) or section 6104 of the Internal Revenue Code of 1986. Additionally, Appendix A to Part 170—Award Term Reporting Subawards and Executive Compensation e.4. Subaward ii. “The term does not include your procurement of property and services needed to carry out the project or program.” The requirements for this award required a collaboration between a nonprofit entity and a university. The subaward with UK is required to carry out the project or program, further limiting the requirement to report. HRSA Guidance: HRSA also has a PowerPoint that addresses FFATA and their responsibility in communicating with organizations receiving an award through HRSA. In this presentation HRSA defines how applicants and awardees are informed of the FFATA requirements. • The Notice of Funding Opportunity will include reference to the FFATA requirement. • The Notice of Award (NOA) will include reference to FFATA • HRSA website will include information • Published on Electronic Handbook (EHB) • Technical assistance calls, workshops, webinars, etc. There was no reference in our NOA to the requirement to file an FFATA with UK, which was clearly described in our proposal and the budget justification. The EHB does not include a reference to completing this task. Thus, based on our reading of the requirements, and the lack of guidance from HRSA, we determined that we did not need to report UK sub-award on the FFATA. Ongoing Practice: We subsequently filed the report indicated by FFATA protocol for UK. We will seek additional clarification from HRSA regarding agreements that need reporting for any other sub-agreement award that we establish going forward.
Management agrees with the finding. In 2023, shortly after management was made aware procedures were put into place to properly oversee the timely submission of the SF-425 financial reports.
Management agrees with the finding. In 2023, shortly after management was made aware procedures were put into place to properly oversee the timely submission of the SF-425 financial reports.
Finding 485087 (2023-005)
Significant Deficiency 2023
Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are revi...
Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are reviewed, bi-weekly, by payroll and adjusted to reflect actual hours as they relate to a specific activity. The City was able to hire a permanent accountant hiring who will provide additional oversight of these processes ensuring that hours worked are both reported correctly on the timesheets and are following the funding allocations that are approved by the grant.
View Audit 317869 Questioned Costs: $1
2023-002 Missing Eligibility Information - ALN# 14.181 Section 811 Supportive Housing for Persons with Disabilities – Year Ended June 30, 2023 Condition Found During the eligibility testing of the audit, the following deficiencies were identified – certain tenant files are not kept on file within...
2023-002 Missing Eligibility Information - ALN# 14.181 Section 811 Supportive Housing for Persons with Disabilities – Year Ended June 30, 2023 Condition Found During the eligibility testing of the audit, the following deficiencies were identified – certain tenant files are not kept on file within the required compliance timeframe. We consider this finding to be a material weakness with the Eligibility Compliance Requirement. Corrective Action Plan A new Finance Department position will be created that is responsible for working with residents and programmatic staff in order to ensure that tenant files are kept on file within the required compliance timeframe. Responsible Person for Corrective Action Plan Lore Baker, President & CEO Implementation Date of Corrective Action Plan September 2024
One important aspect of the internal control structure is the segregation of duties among employees to prevent an individual employee from handling duties which are incompatible. We noted one individual has control over portions of one or more of the following areas for the District relating to majo...
One important aspect of the internal control structure is the segregation of duties among employees to prevent an individual employee from handling duties which are incompatible. We noted one individual has control over portions of one or more of the following areas for the District relating to major federal programs; cash, inventories, receipts, disbursements, financial reporting, journal entries and the school lunch program. See finding 2023-001.
The District will continue to seek ways to strengthen internal controls even with limited staff.
The District will continue to seek ways to strengthen internal controls even with limited staff.
Management will implement an internal procedure to ensure proper filing within 30 days of quarter end to be in reporting compliance.
Management will implement an internal procedure to ensure proper filing within 30 days of quarter end to be in reporting compliance.
Management will implement an internal procedure to ensure proper documentation is retained for all grant expenses.
Management will implement an internal procedure to ensure proper documentation is retained for all grant expenses.
View Audit 317854 Questioned Costs: $1
Finding 485073 (2023-003)
Significant Deficiency 2023
FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Significant Deficiency Contact Person Responsible for Corrective Action: Ann Hathaway Contact Phone Number and Email Address: 317-852-1126 ahathaway@brownsburg.org Views of Re...
FINDING 2023-003 Finding Subject: COVID-19 Coronavirus State and Local Fiscal Recovery Funds - Reporting Summary of Finding: Significant Deficiency Contact Person Responsible for Corrective Action: Ann Hathaway Contact Phone Number and Email Address: 317-852-1126 ahathaway@brownsburg.org Views of Responsible Officials: We concur with the finding that there was not a review in place prior to submitting the report for 3/31/2023. The rules, dates and requirements were quickly changing for the reporting of the Coronavirus State and Local Fiscal Recovery Funds. With there being only one project and a relatively small amount spent, the report was filed with no errors. Description of Corrective Action Plan: The 3/31/2024 report was reviewed and further reports will be going forward. Anticipated Completion Date: Immediately
FINDING 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317...
FINDING 2023-002 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Summary of Finding: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317-852-1120 akaytar@brownsburg.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: In 2023 a Purchasing Policy was implemented for all departments to follow. It states: 1. For Purchases Under $50,000 a. Purchases or Contracts of $1,000 or Less i. Shall be reviewed and approved by the designated Purchasing Agent. ii. The Department Head, Procurement Manager and Town Manager reserve the right to deny any Purchase. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. b. Purchases or Contract between $1,000 and $10,000 i. Shall be reviewed and approved via a Requisition Form by the Purchasing Agent/Department Head. ii. The Procurement Manager and Town Manager reserve the right to deny any Purchase. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. c. Purchases or Contracts between $10,000 and $50,000 i. Shall be reviewed and approved via a Requisition Form by the Department Head, Procurement Manager and Town Manager. ii. Should have (3) formal quotes from different vendors. iii. The Procurement Manager and Town Manager reserve the right to deny any Purchase. iv. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. v. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. d. Purchases of at Least $50,000 and Less Than $150,000 i. Shall be reviewed and approved by the Department Head, Procurement Manager, Town Manager and Town Council. ii. The information shall be presented to Town Council and should contain (3) formal quotes from different vendors. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. e. Purchases of $150,000 or More i. Shall be submitted via a formal bidding process. ii. Shall be reviewed by Department Heads, Procurement Manager, Town Manager and Town Council. iii. Contracts should be submitted to the Clerk-Treasurer’s Office for retention. iv. Any new purchase that meets the asset requirement ($5,000 or more) MUST be reported to the Clerk-Treasurer’s Office. 2. To provide services to the Town of Brownsburg, you must not be debarred, suspended, or otherwise be excluded from or ineligible for participation in federally assisted programs under Executive Order 12549. Anticipated Completion Date: Policy change 2023. Purchase order change 8/31/2024.
Finding 485069 (2023-002)
Significant Deficiency 2023
Management’s Response/Corrective Action Plan: Staff is aware of the reporting deadlines. The Grant in question provides guidance that invoices submitted for payment are required to error-free and have all necessary supporting documents. It further states that invoices and the Monthly Financial Rep...
Management’s Response/Corrective Action Plan: Staff is aware of the reporting deadlines. The Grant in question provides guidance that invoices submitted for payment are required to error-free and have all necessary supporting documents. It further states that invoices and the Monthly Financial Report “should” be filed by the 15th but “must” be filed no later than 45 days from the end of the month. Staff relied on this guidance, along with discussions with other industry professionals, to prepare and file the reports. The 45-day window was relied upon if supporting documentation was lacking or staffing/scheduling issues arose. All reports and invoices were filed within the 45-day window. The Director of the Public Health and Community Services Department will ensure that all grant managers are made aware that the 15th should be used as the reporting deadline for future reporting.
Finding 485062 (2023-004)
Significant Deficiency 2023
Management’s Response/Corrective Action Plan: City and School contracts have the original Request for Proposals attached as “part of the contract”. These Requests for Proposals contain the required Davis-Bacon Wage requirements, when needed, so the concern that contractors may be unaware of the requ...
Management’s Response/Corrective Action Plan: City and School contracts have the original Request for Proposals attached as “part of the contract”. These Requests for Proposals contain the required Davis-Bacon Wage requirements, when needed, so the concern that contractors may be unaware of the requirements is extremely remote. This has been a long-standing practice across all Departments utilizing Federal funding and has not been identified as an issue previously. To address this finding the City and School will modify their Construction contracts to contain the Wage Requirement language in both the main body of the contract as well as continuing to be within the attached contract documents.
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