Corrective Action Plans

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Condition: The Organization lacked adequate controls to ensure the SEFA was complete and accurate. Planned Corrective Action: 1. Federal Award Classification Review: Federal versus non-federal classification will be reviewed by the program manager, Director of Internal Control, and CFO based on the ...
Condition: The Organization lacked adequate controls to ensure the SEFA was complete and accurate. Planned Corrective Action: 1. Federal Award Classification Review: Federal versus non-federal classification will be reviewed by the program manager, Director of Internal Control, and CFO based on the executed agreement. Any reclassification will require documented CFO approval. 2. Annual Cross-System Reconciliation: An annual reconciliation between the contract management system and the general ledger will be performed to ensure all federal awards are captured for SEFA reporting. 3. SEFA Format Standardization: The SEFA preparation schedule will be reverted to a prior-year rollover format that retains carryforward data and enables year-over-year comparison to improve completeness review and anomaly detection. 4. General Ledger Tagging Controls: General ledger dimensional tagging has been enhanced so federally funded activity is automatically identified and included in the preliminary SEFA. 5. Independent SEFA Review: The SEFA will undergo documented independent review and approval by the CFO prior to auditor submission, consistent with 2 CFR 200.303. Contact person responsible for corrective action: Ian Kile (Director of Internal Controls and Analysis) Chiyoko Yokota (Chief Financial Officer) Anticipated Completion Date: Fully Corrected
2025-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act, direct recipients of grants or cooperative agreements are required to report fir...
2025-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act, direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: Upon discovery of the issue in November 2025, City staff corrected the noncompliance by submitting the required report to the appropriate reporting system/entity. To prevent recurrence, management has strengthened internal controls over FFATA reporting and Single Audit preparation by (1) adding review and verification steps, (2) communicating expectations with key personnel, and (3) explicitly assigning submission responsibility to a designated submitter who is independent of the individual(s) responsible for monitoring compliance. These control enhancements are expected to identify and prevent similar deficiencies and, based on implementation to date, appear to be operating effectively. Responsible Person: Jason Denton, Controller Anticipated Completion Date: June 30, 2026
The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a re...
The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a recognized framework such as NIST. Based on the results, the College will document identified risks, existing safeguards, and remediation plans. Additionally, the College will formalize and update its Written Information Security Program, including policies addressing vendor management, user access controls, data transmission and destruction, change management, and data inventory. Policies will be reviewed and approved through the College’s governance process. Responsible Party: Kyle Brown, Executive Director of Technology, Jamestown Community College, kylebrown@sunyjcc.edu, 716.338.1118 Anticipated Completion Date: August 31, 2026
FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Defici...
FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Education Georgia Department of Education 84.027 - Special Education Cluster Grant to States 84.173 - Special Education Cluster Preschool Grants H027A230073 (Year: 2024), H027A240073 (Year: 2025), H173A240081 (Year: 2025) $1,283 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Special Education Cluster. Corrective Action Plans: The District concurs with the finding and is committed to strengthening internal controls. While the identified discrepancies were isolated, we recognize the need for enhanced reconciliation during personnel transitions. The Human Resources and Finance departments will enhance our review process. This pre-payroll validation step will ensure that all salary adjustments and position changes align with Board authorized pay documentation prior to disbursement. Estimated Completion Date: 3/31/2026 Contact Person: Julie Wiley, Chief Financial Officer Telephone: 229-316-1878 Email: juliewiley@lowndes.k12.ga.us
Management takes its responsibility to maintain effective internal control over the federal award that provides reasonable assurance that the agency is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award seriously and gave significan...
Management takes its responsibility to maintain effective internal control over the federal award that provides reasonable assurance that the agency is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award seriously and gave significant consideration to what additional controls would be effective to ensure the proper amount of indirect costs are charged to all federal grants. To prevent another occurrence, the organization will: On the final report to HS, the agency refunded the indirect costs that were overbilled in error. Continue its current policy that no individual who prepares bill/draw should review their own calculation of the draw/billing. Another individual will review and approve costs allowable for the draw/billing and recalculate the indirect costs. Continue its current policy that the Director of Grants Management complete a detailed review of each grant reconciliation monthly, to ensure all costs charged to the grant are reasonable and necessary for the performance of the award. This review will include appropriate tests of indirect costs including ensuring the appropriate indirect cost base is used, all items required to be excluded from the indirect cost base are excluded, and the appropriate indirect cost rate is applied to the indirect cost base. Add additional step whereby the monthly grant reconciliations will be reviewed by the Controller or Chief Financial Officer.
Recommendation The Municipality must establish and implement a documented reconciliation process between the MIP and ORACLE accounting systems to ensure the accuracy and reliability of financial information used for federal compliance purposes. In addition, implement oversight procedures and periodi...
Recommendation The Municipality must establish and implement a documented reconciliation process between the MIP and ORACLE accounting systems to ensure the accuracy and reliability of financial information used for federal compliance purposes. In addition, implement oversight procedures and periodic monitoring to review and verify the WIOA expenditures to ensure they comply with the earmarking percentage limitations. View of responsible officials Management concurs with the findings as presented and notes that all corrective measures are already substantially implemented. The Municipality remains fully committed to maintaining strong internal controls and continuous improvement in federal grant administration. Responsible official Ana Maria Delgado WIOA Program Fiscal Agent Estimated completion date June 30, 2026
The City has separated duties to the extent possible and has implemented compensating controls to monitor the account activities
The City has separated duties to the extent possible and has implemented compensating controls to monitor the account activities
Finding 2025-003 See response to finding 2025-001.
Finding 2025-003 See response to finding 2025-001.
Condition: The controls in place to review the final grant packet, including the grant draw-down template and the drawdown invoice detail, prior to final processing of the drawdown were not operating as designed. Planned Corrective Action: Treasury will work with PMM and DCC departments to out-line ...
Condition: The controls in place to review the final grant packet, including the grant draw-down template and the drawdown invoice detail, prior to final processing of the drawdown were not operating as designed. Planned Corrective Action: Treasury will work with PMM and DCC departments to out-line a process to ensure accurate reporting of eligible expenses when invoices are re-viewed for compliance with grant program requirements. The process will be documented and adhered to once agreed by all departments. A review process for the final drawdown submission will also be adopted to ensure costs that are identified as ineligible are appro-priately excluded from the final submission. Contact person responsible for corrective action: Sr. Grants Manager Anticipated Completion Date: 06/30/2026
Condition: There were no controls in place for the annual report [FAA Form 5100-126] for the fiscal year ending September 30, 2025 to ensure the report contained accurate infor-mation and was sent timely to the appropriate FAA airports office. Planned Corrective Action: A review of FAA Form 5100-126...
Condition: There were no controls in place for the annual report [FAA Form 5100-126] for the fiscal year ending September 30, 2025 to ensure the report contained accurate infor-mation and was sent timely to the appropriate FAA airports office. Planned Corrective Action: A review of FAA Form 5100-126 will be conducted with ap-propriate personnel, such as the Controller or Vice President, Treasury Management prior to submitting to the FAA. Review and timely submission will be evidenced via time-stamped DocuSign or other electronic means such as an acknowledgment via email. Contact person responsible for corrective action: Sr. Grants Manager Anticipated Completion Date: 03/31/2026
Since the prior audit period, management has taken steps to review and revise OFB’s procurement policy and procedures, in alignment with federal procurement standards. Finance will continue implementing the corrective actions and establishing the internal controls to ensure adherence to the policy, ...
Since the prior audit period, management has taken steps to review and revise OFB’s procurement policy and procedures, in alignment with federal procurement standards. Finance will continue implementing the corrective actions and establishing the internal controls to ensure adherence to the policy, retaining documentation of the procurement process to demonstrate compliance. These recent and planned improvements will enhance transparency, strengthen accountability, and reduce compliance risk, ensuring a more efficient and well-documented procurement process that supports the organization’s long-term financial integrity and operational effectiveness. The anticipated completion date remains June 30, 2026.
Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staf...
Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staff members during each phase of the grants management lifecycle, as well as implementing procedures and tools to ensure compliance with subrecipient monitoring requirements. These steps involve multiple levels of review for accurate and consistent application of indirect cost rates. Finance will continue implementing the corrective actions necessary to achieve effective controls over compliance with indirect cost rate requirements. Policy and procedures on allowable and allocable costs will be drafted to clearly document how direct and indirect costs will be billed to federal awards. Training will be provided to relevant staff members to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date remains June 30, 2026.
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across dep...
Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across departments and teams. Finance will continue implementing the corrective actions necessary to establish an effective and compliant time and effort reporting system, including providing training for employees and regularly monitoring for effective system utilization. These actions will strengthen internal controls and ensure personnel costs are accurately recorded and appropriately allocated. The anticipated completion date remains June 30, 2027.
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all exp...
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all expenses claimed are for expenses paid during the year. Managements Response: The District will take the necessary steps to only claim allowable expenses on future expenditure reports.
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all exp...
Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all expenses claimed are for expenses paid during the year. Managements Response: The District will take the necessary steps to only claim allowable expenses on future expenditure reports.
Condition: Quarterly expenditure reports for the Special Education Cluster were not filed timely. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Managements response - The Distr...
Condition: Quarterly expenditure reports for the Special Education Cluster were not filed timely. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Managements response - The District will take the necessary steps to file all quarterly expenditure reports on time in the future.
U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U U.S. Department of Education Herron High School, Inc. d/b/a Herron Classical Schools and its Wholly-Owned Subsidiaries (the Organization) respec...
U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Charter Schools – AL #84.282 Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U U.S. Department of Education Herron High School, Inc. d/b/a Herron Classical Schools and its Wholly-Owned Subsidiaries (the Organization) respectively submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 Audit period: Year ended June 30, 2025 The findings from the schedule of findings and questioned costs for the year ended June 30, 2025, are discussed below. The findings are numbered consistently with the numbers assigned in the Schedule. FEDERAL AWARD FINDINGS AND QUESTIONED COSTS U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Education Stabilization Fund – AL #84.425C, 84.425D & 84.425U 2025-001 Equipment and Real Property Management (Repeat Finding 2024-002) Significant Deficiency Recommendation: The Auditor recommended the Organization develop a system of internal controls aligned with the applicable compliance requirements to properly track equipment acquisitions in the accounting records and to ensure a physical inventory is appropriately documented when completed. Planned Corrective Action: The Organization has begun to notate and identify equipment and property purchased with federal funds in accounting records by using appropriate coding methods. These items will be visible on the fixed asset register. Regular annual inventory measures will be conducted for compliance and reporting. Michelle Krauter, VP, Chief Financial Officer, will oversee the ongoing implementation of this process to ensure adherence to all compliance requirements and this process has already begun as of the finalization of this audit. Will be completed within fiscal year.
U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Title I, Part A – AL #84.010 2025-002 Maintenance of Effort Significant Deficiency Recommendation: The auditor recommends the Organization develop internal controls to ensure expenses are properly reported on the Form 9 report in line ...
U.S. DEPARTMENT OF EDUCATION AND INDIANA DEPARTMENT OF EDUCATION Title I, Part A – AL #84.010 2025-002 Maintenance of Effort Significant Deficiency Recommendation: The auditor recommends the Organization develop internal controls to ensure expenses are properly reported on the Form 9 report in line with guidelines. Planned Corrective Action: The Organization has begun to use an outside vendor skilled in the preparation of Form 9 reporting and up-to-date on standards and compliance. An error in documents provided to this vendor lead to the misrepresentation of information on the report. Moving forward, all employees of the Organization are aware that any changes made that will impact the Form 9 after finalization of the period need to be conveyed to our Form 9 preparer. The Organization has provided modifications to the opening balances to the DOE in order to correct this error. Michelle Krauter, VP, Chief Financial Officer, will work with outside vendor to ensure all records are accurate. This process has already begun as of the date of this report and will be completed within the fiscal year. If the U.S. Department of Education has questions regarding this plan, please call Michelle Krauter, Vice President, Chief Financial Officer at 317.231.0010 Sincerely yours, Michelle Krauter, Vice President, Chief Financial Officer Herron High School, Inc. d/b/a Herron Classical Schools and its Wholly-Owned Subsidiaries
The District will reevaluate its control structure to ensure there is adequate review to verify the every recipient has a signed and dated consent form on file prior to billing Medicaid.
The District will reevaluate its control structure to ensure there is adequate review to verify the every recipient has a signed and dated consent form on file prior to billing Medicaid.
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Dr. Derek Etheridge, Executive Director of Business Services Anticipated Completion Date: March 1, 2026 Planned Corrective Action: Reimbursements for federal...
Finding Number: 2025‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Contact Person: Dr. Derek Etheridge, Executive Director of Business Services Anticipated Completion Date: March 1, 2026 Planned Corrective Action: Reimbursements for federal grant expenditures will be verified and signed by two individuals, including the person responsible for the reimbursement request and a member of the management team.
Finding 1176268 (2025-004)
Material Weakness 2025
Views of Responsible Officials and Planned Corrective Action FAC accepted the County’s data collection form on April 19, 2025, Report ID 2024-06-GSAFAC-0000364488. Due to the lateness of the FY 2023, this finding will be cleared in FY 2026, as it has already been filed and accepted. Finding resoluti...
Views of Responsible Officials and Planned Corrective Action FAC accepted the County’s data collection form on April 19, 2025, Report ID 2024-06-GSAFAC-0000364488. Due to the lateness of the FY 2023, this finding will be cleared in FY 2026, as it has already been filed and accepted. Finding resolution timeline: Resolved as of 04/19/2025. Designation of employee position responsible for meeting this deadline: Andrea Montoya, Deputy County Manager
Finding 1176249 (2025-003)
Material Weakness 2025
Views of Responsible Officials and Planned Corrective Action The County fully implemented a grant software program in FY 2026 to provide accurate and complete tracking and reporting of federal award expenditures. Finding resolution timeline: This has been resolved as of 12/4/2025. Designation of emp...
Views of Responsible Officials and Planned Corrective Action The County fully implemented a grant software program in FY 2026 to provide accurate and complete tracking and reporting of federal award expenditures. Finding resolution timeline: This has been resolved as of 12/4/2025. Designation of employee position responsible for meeting this deadline: Andrea Montoya (Deputy County Manager), Gabriella (Betty) Orosco (Assistant Finance Director) and Francine Mondello( Grant Administrator)
2025-007: Internal Control and Compliance over Special Tests – Medicaid Cluster Corrective Action: The District has asked CESA 10 to send the Medicaid claims prior to submission to the District for approval. The District will have a staff member review the salary and fringe information provided to C...
2025-007: Internal Control and Compliance over Special Tests – Medicaid Cluster Corrective Action: The District has asked CESA 10 to send the Medicaid claims prior to submission to the District for approval. The District will have a staff member review the salary and fringe information provided to CESA 10. Responsible Person: Danielle Mittermeyer Anticipated Completion Date: Ongoing
2025-006: Internal Control over Reporting – Medicaid Cluster Corrective Action: The District has asked CESA 10 to send the Medicaid claims prior to submission to the District for approval. The District will have a staff member review the salary and fringe information provided to CESA 10. Responsible...
2025-006: Internal Control over Reporting – Medicaid Cluster Corrective Action: The District has asked CESA 10 to send the Medicaid claims prior to submission to the District for approval. The District will have a staff member review the salary and fringe information provided to CESA 10. Responsible Person: Danielle Mittermeyer Anticipated Completion Date: Ongoing
2025-005: Internal Control over Reporting – COVID-19: Education Stabilization Fund Corrective Action: Due to its size, it is not cost effective to hire additional staff to complete necessary reporting. Reviews and checks have been put into place prior to claim submissions with existing staff members...
2025-005: Internal Control over Reporting – COVID-19: Education Stabilization Fund Corrective Action: Due to its size, it is not cost effective to hire additional staff to complete necessary reporting. Reviews and checks have been put into place prior to claim submissions with existing staff members. Responsible Person: Danielle Mittermeyer Anticipated Completion Date: Ongoing
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