Corrective Action Plans

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Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Administrator will review with staff agency Administrative Plan in accordance to CFR 982.2(b) in regards to policies and procedures for application documentation of preferences.
Finding 395036 (2023-001)
Significant Deficiency 2023
Due to insufficient operating funds to repair costs, an EMERGENCY Replacement Reserve authorization request of $4,000 was attempted on December 29, 2023 via email. Due to holiday closures, that attempt failed. A subsequent post holiday response was received on January 2, 2024 recommending submissio...
Due to insufficient operating funds to repair costs, an EMERGENCY Replacement Reserve authorization request of $4,000 was attempted on December 29, 2023 via email. Due to holiday closures, that attempt failed. A subsequent post holiday response was received on January 2, 2024 recommending submission of HUD-9250. Upon submission of the HUD-9250, approval was obtained on January 8, 2024. The Project will comply with HUD regulations in reference to obtaining proper approval prior to use of replacement of reserve funds.
This finding is related to activities on our Legal Services Corporation Basic Field Grant. For each new employee added to our organization, our onboarding process includes a requirement of a signed priority statement be placed in our employee’s personnel file. FRLS has also implemented a checklist o...
This finding is related to activities on our Legal Services Corporation Basic Field Grant. For each new employee added to our organization, our onboarding process includes a requirement of a signed priority statement be placed in our employee’s personnel file. FRLS has also implemented a checklist of required documentation before every case closure to be reviewed by the Regional Managing Attorneys and Advocacy Director. This includes the required priority statement Upon closure of a case file, the assigned advocate and Regional Managing Attorney will then attest that a case file contains all necessary documentation for compliance. A review of the checklist and case files will be done by the Advocacy Director on a regular basis to ensure compliance. FRLS will undertake a review of this process to ensure that we are in compliance with priority statements for employees involved with cases or other matters. This review will be completed within the next 90 days.
This finding is related to activities on our VOCA grants. As was the case in Finding #005, the majority of the exceptions were related to either finding #2 above or were related to the process in place prior to May 2023. Again, in May 2023 FRLS added an electronic transaction approval process via te...
This finding is related to activities on our VOCA grants. As was the case in Finding #005, the majority of the exceptions were related to either finding #2 above or were related to the process in place prior to May 2023. Again, in May 2023 FRLS added an electronic transaction approval process via teams, that documents approvals for all our AP, AR and other transactions initiated by our accounting staff. These are reviewed and approved by the CFO before being posted into the GL. It was also noted that our process of allocating costs from our overhead cost centers to our various grants, was not fully documented. The CFO will undertake a review of this process to ensure that we are in compliance with allowable cost documentation requirements. We will also review and update our documentation of allocations and ensure that each month’s allocation is properly approved. This review will be completed within the next 90 days.
View Audit 304969 Questioned Costs: $1
FRLS shared that as part of the corrective action plan, improved PAI services by changing pro bono coordinators from paralegals to attorneys to better work with private attorneys and respective bar associations throughout our service areas. FRLS has also reestablished connections with our respective...
FRLS shared that as part of the corrective action plan, improved PAI services by changing pro bono coordinators from paralegals to attorneys to better work with private attorneys and respective bar associations throughout our service areas. FRLS has also reestablished connections with our respective service partners throughout the pandemic, rebuilding and providing excellent services through our pro bono partners. PAI remains one of our top priorities in expanding our program services. Our program improvements, including pro bono assistance via virtual and courthouse clinics have resulted in more PAI services to our client communities. We have increased attendance at our annual bench and bar events to raise PAI awareness in our service communities. FRLS is in the process of creating a “low bono” program to expand our network of private attorneys and meet our required 12.5% spending requirement. FRLS will continue to evaluate its policies and procedures surrounding monitoring of PAI compliance to ensure that only allowable pro bono cases are accepted. This will be completed by December 31, 2024.
Upon review, FRLS had retainer agreements for both of the exceptions listed, but they were not readily available for review. FRLS has implemented a checklist of required documentation before every case closure to be reviewed by the Regional Managing Attorneys and Advocacy Director. Upon closure of a...
Upon review, FRLS had retainer agreements for both of the exceptions listed, but they were not readily available for review. FRLS has implemented a checklist of required documentation before every case closure to be reviewed by the Regional Managing Attorneys and Advocacy Director. Upon closure of a case file, the assigned advocate and Regional Managing Attorney will then attest that a case file contains all necessary documentation for compliance. A review of the checklist and case files will be done by the Advocacy Director on a regular basis to ensure compliance.
This finding is related to activities on our VOCA grants. As was the case in Finding #004, the majority of the exceptions were related to either finding #2 above or were related to the process in place prior to May 2023. Again, in May 2023 FRLS added an electronic transaction approval process via te...
This finding is related to activities on our VOCA grants. As was the case in Finding #004, the majority of the exceptions were related to either finding #2 above or were related to the process in place prior to May 2023. Again, in May 2023 FRLS added an electronic transaction approval process via teams, that documents approvals for all our AP, AR and other transactions initiated by our accounting staff. These are reviewed and approved by the CFO before being posted into the GL. It was also noted that our process of allocating costs from our overhead cost centers to our various grants, was not fully documented. The CFO will undertake a review of this process to ensure that we are in compliance with allowable cost documentation requirements. We will also review and update our documentation of allocations and ensure that each month’s allocation is properly approved. This review will be completed within the next 90 days.
This finding is related to activities in our Legal Services Basic Field Grant. In reviewing the testing for this finding, the majority of the exceptions were related to either finding #2 above or were related to the process in place prior to May 2023. Again, in May 2023 FRLS added an electronic tran...
This finding is related to activities in our Legal Services Basic Field Grant. In reviewing the testing for this finding, the majority of the exceptions were related to either finding #2 above or were related to the process in place prior to May 2023. Again, in May 2023 FRLS added an electronic transaction approval process via teams, that documents approvals for all our AP, AR and other transactions initiated by our accounting staff. These are reviewed and approved by the CFO before being posted into the GL. The CFO will undertake a review of this process to ensure that we are in compliance with allowable cost documentation requirements. This review will be completed within the next 90 days.
View Audit 304969 Questioned Costs: $1
Procedures should be established and implemented where the Organization segregates duties in the receipts and expenditures cycles and implements additional controls over the accounting and recording functions. Involvement by the Board of Directors can help mitigate the risk of error or fraud. The Bo...
Procedures should be established and implemented where the Organization segregates duties in the receipts and expenditures cycles and implements additional controls over the accounting and recording functions. Involvement by the Board of Directors can help mitigate the risk of error or fraud. The Board of Directors should remain involved in the financial affairs of the Organization with oversight and independent review of internal control functions.
Prior to 2018, obtaining the simple agreement, when required by LSC regulations, was the responsibility of the managing attorney for the unit or office. In 2018, this responsibility was transferred to the Human Resources Administrator to ensure this document and others were timely obtained and place...
Prior to 2018, obtaining the simple agreement, when required by LSC regulations, was the responsibility of the managing attorney for the unit or office. In 2018, this responsibility was transferred to the Human Resources Administrator to ensure this document and others were timely obtained and placed in the employee’s personal file. Based on these findings, all current employees, for whom a simple agreement was not in the personnel file, were required to sign the agreement or submit a copy of the agreement they previously signed. All current employees, required to sign the simple agreement, have one on file. Human Resources will continue to obtain the agreements as part of the new employee onboarding process.
One of the two meeting minutes noted, January 30, 2023, was approved at the March 3, 2023 board meeting and submitted to LSC on May 9, 2023. The minutes of the May 22, 2023 meeting have not been approved and should not have been submitted on September 7, 2023. The minutes for the May 22, 2023 meetin...
One of the two meeting minutes noted, January 30, 2023, was approved at the March 3, 2023 board meeting and submitted to LSC on May 9, 2023. The minutes of the May 22, 2023 meeting have not been approved and should not have been submitted on September 7, 2023. The minutes for the May 22, 2023 meeting will be placed on the upcoming Executive Committee meeting agenda for review and approval as appropriate. Upon approval, the May 22, 2023 meeting minutes will be re‐submitted to LSC. CLS recently implemented a new process. If there is not a quorum at a full board meeting, the minutes that were on that meeting’s agenda for approval will be placed on the next scheduled Executive Committee meeting for review and approval. For example, if there is no quorum at the January full board meeting, all meeting minutes that were scheduled for review and approval at that meeting will be placed on the agenda for the Executive Committee meeting later that month for approval and reported out to the full board at its next regularly scheduled meeting in March. This will ensure timely review, approval and submission of minutes for board and committee meetings.
2023-007 Timely Submission of Quarterly Financial Status Reports The Director of Finance will ensure Financial Status Reports are filed timely. The deadlines will be added to a calendar that tracks deadlines, maintained by the Director of Finance.
2023-007 Timely Submission of Quarterly Financial Status Reports The Director of Finance will ensure Financial Status Reports are filed timely. The deadlines will be added to a calendar that tracks deadlines, maintained by the Director of Finance.
2023-006 Timely Submission of Quarterly Financial Status Reports The Director of Finance will ensure Financial Status Reports are filed timely. The deadlines will be added to a calendar that tracks deadlines, maintained by the Director of Finance.
2023-006 Timely Submission of Quarterly Financial Status Reports The Director of Finance will ensure Financial Status Reports are filed timely. The deadlines will be added to a calendar that tracks deadlines, maintained by the Director of Finance.
2023-005 Internal Control over Compliance - Review of Reports Submitted The Executive Director will review all federal reports being submitted to the government system (SAM). This will include a review of expenses being reported.
2023-005 Internal Control over Compliance - Review of Reports Submitted The Executive Director will review all federal reports being submitted to the government system (SAM). This will include a review of expenses being reported.
2023-004 Proper Approval of Expenditures We have implemented a new electronic timesheet system. Our Director of Finance will review system reports monthly to ensure proper supervisory review and sign-offs have occurred.
2023-004 Proper Approval of Expenditures We have implemented a new electronic timesheet system. Our Director of Finance will review system reports monthly to ensure proper supervisory review and sign-offs have occurred.
2023-003 Federal Grant Policies and Procedures We will develop formal policies and procedures over federal funding administration. This will include processes and controls over the preparation and approval of the SEFA. We will present the policies and procedures to our Board of Directors for approva...
2023-003 Federal Grant Policies and Procedures We will develop formal policies and procedures over federal funding administration. This will include processes and controls over the preparation and approval of the SEFA. We will present the policies and procedures to our Board of Directors for approval.
Finding Number: 2023-001 Condition: The Corporation was unable to provide sufficient documentation to verify that one of the participants selected for admission was selected in the appropriate order based on their position on the waiting list. Planned Corrective Action: Management has taken measur...
Finding Number: 2023-001 Condition: The Corporation was unable to provide sufficient documentation to verify that one of the participants selected for admission was selected in the appropriate order based on their position on the waiting list. Planned Corrective Action: Management has taken measures to improve their documentation process surrounding the selection of applicants from the waiting list. Contact person responsible for corrective action: Jill Kolb, Vice President – Housing Accounting Anticipated Completion Date: December 31, 2023
The Executive Director is currently working with senior management to review and update the Organization's accounting procedures manual to align it to the LSC Financial Guide.
The Executive Director is currently working with senior management to review and update the Organization's accounting procedures manual to align it to the LSC Financial Guide.
The Executive Director will reinforce the importance of obtaining executed retainer agreements with all paralegals and attorneys.
The Executive Director will reinforce the importance of obtaining executed retainer agreements with all paralegals and attorneys.
The Executive Director will reinforce the importance of timely completion and review of timecards with all employees.
The Executive Director will reinforce the importance of timely completion and review of timecards with all employees.
Finding 2023-003 Department of Housing and Urban Development Housing Voucher Cluster - ALN Number 14.871 Recommendation: We recommend that the Authority implement procedures to ensure that the appropriate procedures are followed when housing quality inspection deficiencies are not resolved in the ...
Finding 2023-003 Department of Housing and Urban Development Housing Voucher Cluster - ALN Number 14.871 Recommendation: We recommend that the Authority implement procedures to ensure that the appropriate procedures are followed when housing quality inspection deficiencies are not resolved in the required timeframe, as required by HUD (24 CFR 882.516) and the Uniform Guidance. Action taken: Using the newly implemented process for setting and updating google calendars with reminders.
View Audit 304912 Questioned Costs: $1
Finding 2023-002 Department of Housing and Urban Development Housing Voucher Cluster - ALN Number 14.871 Recommendation: We recommend that the Authority implement procedures to ensure that all housing quality inspections are being performed throughout the year, as required by HUD and the Uniform G...
Finding 2023-002 Department of Housing and Urban Development Housing Voucher Cluster - ALN Number 14.871 Recommendation: We recommend that the Authority implement procedures to ensure that all housing quality inspections are being performed throughout the year, as required by HUD and the Uniform Guidance. Action taken: The Section 8 Coordinator will print an updated calendar of the upcoming inspection schedule for comparison to the Inspector's calendar and continue to update the google calendar and set daily reminders.
View Audit 304912 Questioned Costs: $1
Department of Housing and Urban Development Housing Voucher Cluster - ALN Number 14.871 Recommendation: We recommend that the Authority implement procedures to ensure all required Income verification and other supporting documentation is obtained when completing the HUD-50058 forms, and to the exte...
Department of Housing and Urban Development Housing Voucher Cluster - ALN Number 14.871 Recommendation: We recommend that the Authority implement procedures to ensure all required Income verification and other supporting documentation is obtained when completing the HUD-50058 forms, and to the extent they are not, that action be taken to resolve any issues, and that this action be documented Action taken: Updated "How To" and the file guides. The entire file will be reviewed at all Interims and Re certifications. The Operations Manager/Compliance Officer will review each file for quality control. I have attended training provided by Nelrod and will continue to do so.
View Audit 304912 Questioned Costs: $1
Finding 394997 (2023-001)
Significant Deficiency 2023
Views of responsible officials and planned corrective action: City Management takes grant compliance very seriously and corrective action has been taken. The City has created a checklist encompassing all grant-related tasks, and an Environmental Review Record (ERR) is part of that checklist and will...
Views of responsible officials and planned corrective action: City Management takes grant compliance very seriously and corrective action has been taken. The City has created a checklist encompassing all grant-related tasks, and an Environmental Review Record (ERR) is part of that checklist and will be completed for every property and program.
Any amendments to the approved Food Service Management Company's contract be approved by Board resolution and submitted to the State for approval as required.
Any amendments to the approved Food Service Management Company's contract be approved by Board resolution and submitted to the State for approval as required.
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