Corrective Action Plans

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Material Weakness and Noncompliance: See Finding 2025-003. Recommendation: Management should implement a grant review and approval acceptance process, grant reporting calendar and review process that reconciles reporting periods to the Credit Union's fiscal year, assigns preparer and reviewer respon...
Material Weakness and Noncompliance: See Finding 2025-003. Recommendation: Management should implement a grant review and approval acceptance process, grant reporting calendar and review process that reconciles reporting periods to the Credit Union's fiscal year, assigns preparer and reviewer responsibilities, documents review, and reconciles reported categories to the general ledger and supporting records before submission. Action Taken: Prior to this finding, but subsequent to the audit period, the Credit Union established a formal grant management policy that defines roles, documentation standards, tracking procedures, reporting reconciliations, record retention, review and approval requirements, and periodic monitoring. The Credit Union considers all relevant requirements of Uniform Guidance, as well as specific requirements set forth in grant agreements and contracts. The Credit Union will maintain grant tracking records and reconcile grant activity to the general ledger and required award reports. Completion Date: July 28, 2026
Material Weakness: See Finding 2025-002. Recommendation: Management should establish a formal grant management policy defining roles, documentation standards, tracking procedures, report reconciliations, record retention, review and approval requirements, and periodic monitoring. The policy and asso...
Material Weakness: See Finding 2025-002. Recommendation: Management should establish a formal grant management policy defining roles, documentation standards, tracking procedures, report reconciliations, record retention, review and approval requirements, and periodic monitoring. The policy and associated procedures should consider all relevant requirements of Uniform Guidance, as well as specific requirements set forth in grant agreements and contracts. Action Taken: Prior to this finding, but subsequent to the audit period, the Credit Union established a formal grant management policy that defines roles, documentation standards, tracking procedures, reporting reconciliations, record retention, review and approval requirements, and periodic monitoring. The Credit Union considers all relevant requirements of Uniform Guidance, as well as specific requirements set forth in grant agreements and contracts. The Credit Union will maintain grant tracking records and reconcile grant activity to the general ledger and required award reports. Completion Date: July 28, 2026
The District will strengthen its procedures for documenting time and effort for employees whose salaries or benefits are charged to federal or other restricted funding sources. Employees will be required to complete the appropriate time and effort documentation in a timely manner and in accordance w...
The District will strengthen its procedures for documenting time and effort for employees whose salaries or benefits are charged to federal or other restricted funding sources. Employees will be required to complete the appropriate time and effort documentation in a timely manner and in accordance with applicable grant requirements and District procedures. Financial Services, in coordination with the grant administrator and supervisors, will establish a process to monitor the submission and completion of time and effort records. Supervisors will review documentation for completeness and accuracy, and Financial Services will follow up on missing or late records. The District will provide guidance to employees and supervisors regarding time and effort requirements, including when documentation is required, who is responsible for completing and approving it, and the importance of submitting records timely. Documentation will be retained in an organized manner and made available for audit or monitoring purposes. Responsible Party: Financial Services Manager, Grant Administrator, and Supervisors Monitoring: Financial Services will periodically review time and effort records to ensure required documentation has been submitted, approved, and retained. Missing or untimely documentation will be followed up on and corrective action taken as necessary.
By addressing the recommendations described in Findings 2025-001 and 2025-002 as soon as practical, we will have additional staff resources and procedures documented to allow for a more regimented closing of the books, which will permit timely submission to the FAC.
By addressing the recommendations described in Findings 2025-001 and 2025-002 as soon as practical, we will have additional staff resources and procedures documented to allow for a more regimented closing of the books, which will permit timely submission to the FAC.
In response to this finding, management has taken the following actions. 1. Policies and Procedures – Management has developed and updated written policies and procedures governing subrecipient monitoring activities. These policies outline roles and responsibilities, documentation requirements, and ...
In response to this finding, management has taken the following actions. 1. Policies and Procedures – Management has developed and updated written policies and procedures governing subrecipient monitoring activities. These policies outline roles and responsibilities, documentation requirements, and monitoring standards in accordance with 2 CFR Part 200 (as applicable). 2. Monitoring Schedule – A subrecipient monitoring schedule has been established to ensure that all subrecipients are reviewed on a consistent and risk-based basis through the program year. The schedule includes desk reviews and when warranted, on-site monitoring visits. 3. Management Oversight: The Controller's Office will establish a periodic review process to ensure all City Departments are conducting Subrecipient Monitoring.
In response to this finding, management will take the following actions. 1. Establish a process to review significant or uncertain compliance recommendations with the grantor and document the guidance received before implementation or reimbursement submission, as applicable. 2. Train applicable City...
In response to this finding, management will take the following actions. 1. Establish a process to review significant or uncertain compliance recommendations with the grantor and document the guidance received before implementation or reimbursement submission, as applicable. 2. Train applicable City personnel on grant requirements and revised compliance procedures.
In response to this finding, management will take the following actions. 1. Adoption of the De Minimis Rate: The City will apply the 15% de minimis indirect cost rate, as permitted under Uniform Guidance, to applicable federal awards where a federally negotiated indirect cost rate agreement is not i...
In response to this finding, management will take the following actions. 1. Adoption of the De Minimis Rate: The City will apply the 15% de minimis indirect cost rate, as permitted under Uniform Guidance, to applicable federal awards where a federally negotiated indirect cost rate agreement is not in place. This approach will provide consistency in the recovery of indirect costs and ensure compliance with federal requirements. 2. Formalize Procedures: The Controller's Office will develop and document procedures governing the application of indirect cost rates, including guidance on when the de minimis rate may be used, calculation methodologies, required documentation, and approval requirements. 3. Training: Training will be provided to grants management, accounting, and program staff responsible for grant budgeting, financial reporting, and reimbursement requests to ensure a clear understanding of indirect cost rate requirements and the application of the minimis rate. 4. Management Oversight: The Controller's Office will establish a periodic review process to ensure the de minimis indirect cost rate is applied consistently, calculations are accurate, and adequate supporting documentation is maintained. Any discrepancies identified during the review process will be addressed timely to ensure compliance with Uniform Guidance requirements related to Indirect Cost Recovery.
As part of the closeout process for the City's remaining CARES Act grants, the Department of Grants and Community Development (DGCD) will work with HUD to ensure that Section 15011 reporting obligations are met and submitted prior to grant closeout. Additionally, DGCD has implemented amended interna...
As part of the closeout process for the City's remaining CARES Act grants, the Department of Grants and Community Development (DGCD) will work with HUD to ensure that Section 15011 reporting obligations are met and submitted prior to grant closeout. Additionally, DGCD has implemented amended internal controls that include Section 15011 requirements. To prevent similar issues from occurring with future federal awards, DGCD Program and Fiscal Operations managers will track reporting deadlines and maintain documentation evidencing submission, while the Compliance Division managers will perform periodic reviews to verify compliance with any nonstandard federal reporting requirements. These corrective actions will strengthen oversight of federal reporting requirements and ensure future grants are administered in accordance with all applicable federal regulations and award conditions.
The City of Atlanta’s Department of Grants and Community Development (DGCD) will establish and implement internal controls to ensure all relevant first-tier subawards are reported timely and accurately in accordance with FFATA requirements. Effective immediately, FFATA applicability will be evaluate...
The City of Atlanta’s Department of Grants and Community Development (DGCD) will establish and implement internal controls to ensure all relevant first-tier subawards are reported timely and accurately in accordance with FFATA requirements. Effective immediately, FFATA applicability will be evaluated during DGCD’s subrecipient contracting process. After the final action legislation but prior to contract execution, DGCD Program and Fiscal Operations staff will review all subawards to determine if FFATA reporting thresholds are applicable and document applicability in subaward files. DGCD staff will complete required FFATA submissions through SAM.gov by the end of the month following the month in which the subaward contract is executed. Additionally, DGCD Program and Fiscal Operations managers will conduct quarterly reviews of all active subrecipient agreements to verify compliance with FFATA requirements. Supporting documentation will be properly maintained in subrecipient files. DGCD will document reporting status, due dates, and completion dates in a standardized FFATA tracking log and checklist. DGCD’s Compliance Division will perform periodic oversight reviews to verify adherence to FFATA requirements and ensure corrective action is taken promptly if reporting deficiencies are identified. Additionally, the Controller’s Office will establish a periodic review process to ensure all City Departments are adhering to FFATA requirements.
To: EisnerAmper LLP Date: October 29, 2026 Subject: Response to Management Letter Commend for the Fiscal Year Ended 6/30/2025 Thank you for your management letter dated 10/12/2026 and for your valuable insights and recommendations regarding our financial processes and controls. Areas of improvement ...
To: EisnerAmper LLP Date: October 29, 2026 Subject: Response to Management Letter Commend for the Fiscal Year Ended 6/30/2025 Thank you for your management letter dated 10/12/2026 and for your valuable insights and recommendations regarding our financial processes and controls. Areas of improvement identified by the audit team are acknowledged. CUCS is committed to addressing the points raised. For each recommendation we have taken corrective actions as outlined below. Response to comment#1: CUCS experienced delays in producing final audit schedules due to staffing transitions, including the unanticipated resignation of the Chief Financial Officer (CFO) and other key executive members. While various members of the fiscal team are responsible for preparing audit schedules, the CFO has historically overseen the initiation and finalization of the financial statements and served as the primary liaison with EisnerAmper during the audit process. We appreciate the opportunity to respond to the internal control deficiencies identified during your audit for fiscal year 2025. We acknowledge your finding that our current internal control processes may not consistently detect and correct material misstatements in a timely manner. This concern has been noted and taken seriously by management. Corrective Actions: Staffing and Leadership Stabilization • A Part-time Chief Financial Officer Consultant has been hired to provide leadership, oversight, and stability within the Finance Department while CUCS continues to recruit for a permanent CFO. • Internal resources are being strengthened to reduce reliance on external accounting services. Process and Calendar Improvements • An annual financial reporting and audit preparation calendar has been developed and implemented to improve planning and accountability for deliverables. • Key deadlines for closing entries, reconciliations are now documented and monitored quarterly. • Enhance our review procedures by implementing an additional layer of financial oversight. All required financial reports and key reconciliation’s will be conducted monthly. Capacity Building and Training • Cross-training of finance staff is underway to reduce dependency on single individuals and improve team resilience. Monitoring and Follow-Up • Regular updates to the Executive Team and Audit Committee. Response to comment#2: We acknowledge the auditor’s observation regarding the presence of former employees remaining listed as authorized signers on CUCS bank accounts. We agree that maintaining accurate and up-to-date signer authorizations is critical to safeguarding the organization’s financial assets. In response to this finding, CUCS has taken the following corrective actions: Immediate Review and Removal of Former Employees All bank accounts have been reviewed, and individuals who are no longer employed by CUCS have been removed from signer authority. This process was completed promptly upon identification of the issue. Ongoing Monitoring and Annual Review We are instituting an annual review of all authorized bank signers to ensure that records are current and appropriately reflect active personnel with approval authority. This review will be documented and conducted under the direction of the new part-time CFO consultant. CUCS is committed to maintaining effective internal controls over its financial operations, and we appreciate the auditor’s recommendation in helping us strengthen this process.
2025-006: WAGE RATE COMPLIANCE The School District will strengthen controls over federally funded construction projects to ensure applicable wage rate requirements are met prior to any work being completed by making sure all grant agreements, regulations and guidelines are followed before bid issuan...
2025-006: WAGE RATE COMPLIANCE The School District will strengthen controls over federally funded construction projects to ensure applicable wage rate requirements are met prior to any work being completed by making sure all grant agreements, regulations and guidelines are followed before bid issuance and making sure wage-rate requirements are in the bid and contract documents. The people responsible for this will be the Board, Superintendent, and District Clerk.
Finding #2025-3 Planned Corrective Action and Status Update CLBL agrees with the finding regarding records retention and documentation controls. However, CLBL does not agree with the refence to a missing “Federal grant agreement.” The documentation in question consisted of two amendments associated ...
Finding #2025-3 Planned Corrective Action and Status Update CLBL agrees with the finding regarding records retention and documentation controls. However, CLBL does not agree with the refence to a missing “Federal grant agreement.” The documentation in question consisted of two amendments associated with staff changes at USDA and did not materially affect the grant funding, allowable costs, or expenditures. CLBL will strengthen its records retention procedures by maintaining centralized electronic copies of grant agreements, amendments, and supporting documentation. As full system migration was completed in December 2025, supporting documentation is fully intact for future audits. a) Anticipated completion date: December 31, 2026; ongoing thereafter b) Responsible Contact Person: IsaMarie McIntyre
The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit...
The Organization has begun implementing the above-mentioned recommendations. The Organization will ensure that it has a working compliance calendar to assist in meeting the reporting deadline. Additionally, the Organization has engaged the audit firm for their upcoming fiscal year-end, and the audit firm has put it on its calendar to begin the audit process well in advance. The Organization’s board of directors has agreed to oversee the auditing and reporting processes to a greater extent. With these actions, the Organization expects to comply with the Uniform Guidance for single audits deadline for the fiscal year end June 30, 2025. Mr. Benjamin Klein, executive director, has been designated to monitor the plan of corrective action for this finding. He can be reached at 845-354-9500.
Finding: 2025-002 - Special Tests and Provisions: Uniform Relocation Act Condition Reported by the Auditor: OCGDLC did not assess whether the relocation provisions of 49 CFR Part 24 applied to the occupants of the property acquired with federal award funds, did not identify the occupants or retain o...
Finding: 2025-002 - Special Tests and Provisions: Uniform Relocation Act Condition Reported by the Auditor: OCGDLC did not assess whether the relocation provisions of 49 CFR Part 24 applied to the occupants of the property acquired with federal award funds, did not identify the occupants or retain occupancy records, and did not issue any notice required by 49 CFR 24.203. Corrective Action Planned: Ossining Community Garden of Dreams Legacy Center Inc. (OCGDLC) recognizes the importance of compliance with the Uniform Relocation Act (URA) and acknowledges the documentation and procedural concerns identified during the audit. The federally assisted property acquisition was completed on April 15, 2025. While the prescribed HUD relocation-related form was not utilized during the acquisition process, OCGDLC maintains that communication concerning the property's occupancy circumstances was conveyed to the seller, as reflected in the available transaction documentation. These communications demonstrate that occupancy considerations were addressed during the acquisition process, notwithstanding the absence of the specific form. Furthermore, to the best of OCGDLC management's knowledge and based on the information available, no displacement occurred as a result of the acquisition. OCGDLC has provided HUD with available documentation concerning the completed acquisition and occupancy circumstances. OCGDLC remains committed to ensuring that the documentation and communications surrounding the transaction are appropriately reflected in its federal grant records. OCGDLC will implement the following corrective measures: 1. Documentation of the Completed Acquisition: OCGDLC has maintained the existing acquisition records, including correspondence and documentation reflecting communications with the seller regarding occupancy, together with the supporting materials previously submitted to HUD. These records are maintained as part of OCGDLC's federal grant documentation. 2. Advance Confirmation of Federal Compliance Requirements: For any future federally assisted real property acquisition, OCGDLC will proactively request written guidance from HUD or the applicable federal awarding agency identifying all required forms, notices, certifications, supporting documentation, and applicable submission deadlines. OCGDLC will seek clarification regarding when each requirement must be completed, including any actions necessary before acquisition, during the transaction, or following closing. This process will supplement OCGDLC's internal compliance review and promote clear communication and coordination regarding federal requirements. These measures reflect OCGDLC's commitment to federal compliance while recognizing the distinction between the absence of a prescribed form and the documented communications that occurred during the acquisition. OCGDLC will continue to strengthen its compliance practices through advance clarification of applicable requirements and maintenance of supporting documentation. Anticipated Completion Date: Completed: Existing acquisition documentation, occupancy-related correspondence, and supporting materials have been maintained on file and provided to HUD. Effective Immediately: OCGDLC will proactively request written confirmation of applicable federal forms, notices, documentation requirements, and submission deadlines in advance of any future federally assisted real property acquisition. Name and Title of Responsible Official: Diana E. Lemon Chief Executive Officer & Co-Founder Ossining Community Garden of Dreams Legacy Center Inc.
Finding: 2025-001 - Equipment and Real Property Management Condition Reported by the Auditor: No property, hazard, or general liability insurance coverage was in force with respect to the real property acquired with federal award funds during the year ended December 31, 2025. Corrective Action Plann...
Finding: 2025-001 - Equipment and Real Property Management Condition Reported by the Auditor: No property, hazard, or general liability insurance coverage was in force with respect to the real property acquired with federal award funds during the year ended December 31, 2025. Corrective Action Planned: Ossining Community Garden of Dreams Legacy Center Inc. (OCGDLC) acknowledges the auditor's finding and has taken proactive steps to address the insurance coverage deficiency identified during the audit period. OCGDLC previously engaged insurance brokers and relied upon third-party professionals to facilitate coverage for the federally funded property. Despite ongoing efforts and awareness among management and the Board of Directors, OCGDLC subsequently determined that coverage had not been formally bound. To remedy this matter, OCGDLC has engaged two additional insurance brokers to secure appropriate property, hazard, and general liability coverage. One broker has obtained an insurance quotation, and additional underwriting information requested by the carrier was submitted on October 9, 2026. OCGDLC continues to actively pursue coverage and obtain written confirmation that the policies have been bound. OCGDLC will implement the following corrective measures: 1. Insurance Verification: Require written confirmation that insurance coverage has been formally bound, including appropriate policy documentation, before considering coverage effective. This verification will ensure that OCGDLC does not rely solely on broker communications or assurances without confirmation that coverage is in force. 2. Insurance Procurement Escalation Protocol: Establish a formal escalation procedure for insurance procurement delays. If coverage cannot be secured within 60 days of initiating the procurement process, management and the Board of Directors will review the barriers and assess alternative options. If coverage remains unresolved within 90 days, OCGDLC will pursue additional qualified brokers, carriers, or other appropriate insurance solutions. These timelines represent escalation thresholds and do not delay ongoing efforts to secure coverage. 3. Annual Insurance Compliance Review: OCGDLC has secured property insurance, commercial general liability insurance, and professional liability insurance through Donn Gerelli Associates Insurance Agency, Inc., with coverage effective October 16, 2026, through October 16, 2027. Certificates of insurance were issued on October 23, 2026, confirming that coverage is in force. To ensure continued compliance with applicable federal award requirements, OCGDLC will conduct an annual review of insurance coverage, policy limits, exclusions, renewal dates, and applicable federal requirements. This review will begin at least 90 days before policy expiration to allow sufficient time for renewal, necessary coverage adjustments, or alternative insurance arrangements. OCGDLC will maintain documentation of active coverage, renewal confirmations, and communications with its insurance broker as part of its compliance records. These corrective measures address the previously identified insurance deficiency and strengthen OCGDLC's internal oversight through documented insurance verification, defined procurement escalation procedures, and proactive renewal monitoring. Anticipated Completion Date: October 16, 2026 - Completed: OCGDLC successfully secured and bound property, commercial general liability, and professional liability insurance coverage for the October 16, 2026, through October 16, 2027, policy period. October 23, 2026 - Completed: OCGDLC received certificates of insurance confirming active coverage for the insured property and organizational operations. Ongoing: OCGDLC will maintain continuous insurance compliance monitoring, with the next annual renewal review beginning no later than July 16, 2027. Name and Title of Responsible Official: Diana E. Lemon Chief Executive Officer & Co-Founder Ossining Community Garden of Dreams Legacy Center Inc.
FINDING NUMBER 2025-005 AUDITOR’S DESCRIPTION WIC/SENIORS FARMERS’ NUTRITION PROGRAMS: REPORTING CONDITION The Data Collection Form and related reporting package for the fiscal year ended June 30, 2025, were not submitted to the Federal Audit Clearinghouse within the timeframe required by 2 CFR Part...
FINDING NUMBER 2025-005 AUDITOR’S DESCRIPTION WIC/SENIORS FARMERS’ NUTRITION PROGRAMS: REPORTING CONDITION The Data Collection Form and related reporting package for the fiscal year ended June 30, 2025, were not submitted to the Federal Audit Clearinghouse within the timeframe required by 2 CFR Part 200.512. This matter represents a repeat finding from the prior year. AUDITOR’S RECOMENDATION We recommend that AEDA establish a formal Single Audit reporting calendar and designate responsible personnel to coordinate the audit process before year-end. Management should establish deadlines for closing the accounting records, completing subsidiary ledgers and reconciliations, preparing the Schedule of Expenditures of Federal Awards and supporting schedules, responding to auditor requests, and reviewing and submitting the Data Collection Form and reporting package within the federal deadline. CORRECTIVE ACTION PLAN AEDA has implemented a new accounting system and is reorganizing its personnel structure to ensure that all accounting information is complete, accurate, and available on a timely basis, enabling the organization to successfully complete future Single Audits within established deadlines. LEADS PERSONS ACCOUNTABLE FOR ACTIONS ITEM COMPLETION Elmer Perez, Administrator of AEDA, and Yimaries Méndez, Finance Director of AEDA. DELIVERABLE June 30, 2025 EVIDENCE INCLUDED YES/NO NO TARGET COMPLETION DATE Finding 2025-005 should be corrected for the Single Audit pertaining to the State fiscal year ending on 6/30/2027.
2025-001 Program/Department: Diesel Emission Reduction Act (DERA) National Grants and Energy Efficiency and Renewable Energy Information Dissemination, Outreach, Training and Technical Analysis/Assistance Federal Agency: Environmental Protection Agency and Department of Energy AL #: 66.039 and 81.11...
2025-001 Program/Department: Diesel Emission Reduction Act (DERA) National Grants and Energy Efficiency and Renewable Energy Information Dissemination, Outreach, Training and Technical Analysis/Assistance Federal Agency: Environmental Protection Agency and Department of Energy AL #: 66.039 and 81.117 Federal Award Identification Number and Year: Various – See SEFA Pass-through Entity: Various – See SEFA Type of Finding: Other Matters Internal Control Impact: N/A Finding: Management did not provide all of the necessary supporting documentation to complete the audit and submit the reporting package to the Federal Audit Clearinghouse by the due date. Status: Our December 31, 2025 financial statements and Independent Auditor’s Reports were finalized and available for issuance on October 29, 2026. Corrective Action Plan: The Auditor will initiate the Federal Audit Clearinghouse submission, and management will complete it on or before November 6, 2026. Metropolitan Energy Center management will conduct trainings and will ensure any single audit reporting package for FY26 and subsequent years, if required, are completed prior to August 31. Person Responsible for Implementation: Kelly Gilbert, Executive Director, kelly.gilbert@metroenergy.org, (816) 812-9772.
During review of Coronavirus State and Local Fiscal Recovery Fund (SLFRF) expenditures, the County identified and corrected certain reporting classifications. No expenditure was added to or removed from the program. The County will perform additional review procedures for future submissions. Name of...
During review of Coronavirus State and Local Fiscal Recovery Fund (SLFRF) expenditures, the County identified and corrected certain reporting classifications. No expenditure was added to or removed from the program. The County will perform additional review procedures for future submissions. Name of Responsible Person: Board of Supervisors of Forrest County, Mississippi Expected Date of Completion: Implemented for the corrected SLFRF reporting.
Finding 1241627 (2025-003)
Material Weakness 2025
Finding 2025-003 AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Federal award or contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 202955 Questioned costs: None Torch Technology Solutions, a subsidiary of CrossPurpose, and charged amounts to the FFY 2026 SNA...
Finding 2025-003 AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Federal award or contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 202955 Questioned costs: None Torch Technology Solutions, a subsidiary of CrossPurpose, and charged amounts to the FFY 2026 SNAP Employment and Training Program for compliance and reporting, finance and cost allocation, program delivery, technology infrastructure, and participant-support functions. The Organization did not retain sufficient documentation to demonstrate that the amounts billed represented actual costs incurred during the applicable periods, were necessary and reasonable for the federal award, were directly attributable to program administration or participant services, or were allocated using a reasonable and documented methodology. Torch Technology Solutions also lacked sufficient documentation for certain subcontractor and service-provider expenditures. Available records did not adequately demonstrate the services provided, when they were performed, the benefit to the federal program, or the allocation methodology. Certain gift card payments also lacked documentation showing participant need, redemption, and allowable program-related use. The Colorado Department of Human Services identified similar concerns in its fiscal management evaluation. Management recorded a liability for the repayment obligation, reversed the related program revenue, and excluded the associated costs from the Schedule of Expenditures of Federal Awards. The Organization subsequently terminated its Employment First Program contract with Torch Technology Solutions, terminated the staff, and ceased operations. The Organization returned $283,425 requested in connection with the State's findings. Corrective Action Plan Management agrees with the finding. CrossPurpose has developed a process to review any future reimbursement requests submitted by subsidiaries and require supporting documentation showing that the costs are allocable, reasonable, necessary, and connected to benefits provided to eligible participants. For Torch Technology Solutions, all employees were terminated effective May 15, 2026, and the Organization terminated the subsidiary's contract with the Department. The Organization fulfilled the Department's requests arising from the fiscal management evaluation, returned $283,425, and ceased all operations of the subsidiary.The closure of Torch Technology Solutions is disclosed as a subsequent event in the notes to the financial statements. As of now, there are no existing grant awards held by subsidiaries. Anticipated completion date: May 15, 2026
Finding 1241626 (2025-002)
Material Weakness 2025
Finding 2025-002 AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Federal award or contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 206885 Questioned costs: $412,100 The Department-approved Employment First Program Operator Plan incorporated into Contract No....
Finding 2025-002 AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Federal award or contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 206885 Questioned costs: $412,100 The Department-approved Employment First Program Operator Plan incorporated into Contract No. 26 IHGA 201182 included a Launch licensing materials cost of $2,600 per participant. The plan described the participantbased fee and related services, and the executed contract incorporated the methodology. Related budget documents also contemplated billing at established component rates rather than reimbursement based solely on actual costs incurred. The Organization billed $412,100 under the participant-based licensing methodology. Based on the approved plan, supporting budget schedules, and executed contract, management believed the methodology was approved by the Department, was reasonable and necessary, and complied with program requirements.After the program began, the Organization engaged with a reputable independent firm to perform a transferpricing and fair value study to evaluate and support the methodology and contribute the technology to a separate legal entity. The Colorado Department of Human Services later questioned whether the retained documentation adequately supported the participant-based fee and the allocation of charges to the federal program. The Department had approved invoices and reimbursed these costs before raising concerns during its fiscal management evaluation. Management recorded a liability for the amounts identified by the State pending final resolution. Corrective Action Plan Management has established a separate legal entity to hold the technology associated with these charges. On May 4, 2026, before the fiscal management evaluation, management engaged an accounting firm to benchmark the fee and independently evaluate the participant-based pricing methodology. Management is also working to value the developed technology for contribution to the separate legal entity. Although documentation was retained, management has developed a plan to enhance the documentation supporting the methodology under federal cost principles. The enhanced records will describe the basis for the participant fee, the supporting assumptions and analyses, and the benefit received by the federal program. Anticipated completion date: October 30, 2026
Finding 1241625 (2025-001)
Material Weakness 2025
Finding 2025-001 AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Federal award or contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 206885 Questioned costs: $155,141 During the audit, the Organization reported $155,141 of contractual expenditures under the FF...
Finding 2025-001 AL number: 10.561 AL title: Supplemental Nutrition Assistance Program Federal award or contract: FFY 2026 SNAP Employment and Training Contract No. 26 IHGA 206885 Questioned costs: $155,141 During the audit, the Organization reported $155,141 of contractual expenditures under the FFY 2026 SNAP Employment and Training Program. The expenditures primarily related to technology, outsourced IT support, operations, consulting, and other program support provided by third-party service providers and contractors. The Organization retained invoices and supporting records, but the documentation did not provide enough detail to demonstrate how certain contractual costs were allocated to eligible participants of the federal program, and whether time-and-effort records, utilization metrics, or other records supported the charges. Management submitted an Employment First Program Operator Plan to the Department at the beginning of the contract including the estimated contractual costs, but did not retain documentation showing whether the selected contractors were communicated to or approved by the Department as modifications to the approved plan. The Department had approved invoices and reimbursed these costs before raising concerns during its fiscal management evaluation. Management recorded a liability for the amounts identified by the State pending final resolution. Corrective Action Plan CrossPurpose has implemented a revised cost allocation plan consistent with federal cost principles. Because the Organization serves people throughout Denver neighborhoods regardless of eligibility for government benefits, certain shared costs cannot always be tied directly to eligible participants. The revised plan pools those costs and allocates them based on eligible participants as a proportion of total participants served, using participant data the Organization already tracks. CrossPurpose has also implemented a process to review contractors whose costs are charged to grants and confirm that each contractor has completed the applicable approval process required by the grant before reimbursement requests are submitted. Anticipated completion date: August 1, 2026
The District agrees with the finding and the business manager has resumed taking on responsibility for submitting quarterly reports in a timely manner. The District maintains a listing of due dates for reports to assist in monitoring when reports are due to external agencies. The business manager an...
The District agrees with the finding and the business manager has resumed taking on responsibility for submitting quarterly reports in a timely manner. The District maintains a listing of due dates for reports to assist in monitoring when reports are due to external agencies. The business manager and staff are developing and implementing procedures to correct past mistakes, establish efficient processes and ensure all transactions are correctly posted to the proper period, fund, function and account.
Upon OSAI's recommendations, we are putting into place protocols in an official policy and procedures manual specific to all federal grants. With their guidance, future federal grants will be better documented and monitoed in accordance with this policy.
Upon OSAI's recommendations, we are putting into place protocols in an official policy and procedures manual specific to all federal grants. With their guidance, future federal grants will be better documented and monitoed in accordance with this policy.
The Clerk will ensure all reports are accurately submitted
The Clerk will ensure all reports are accurately submitted
Upon OSAI's recommendations, we are putting into place protocols in an official policy and procedures manual specific to all federal grants. With their guidance, future federal grants will be better documented and monitoed in accordance with this policy.
Upon OSAI's recommendations, we are putting into place protocols in an official policy and procedures manual specific to all federal grants. With their guidance, future federal grants will be better documented and monitoed in accordance with this policy.
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