Corrective Action Plans

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Finding: Significant deficiency in internal control for late submission of data control form and Single Audit report package. Corrective action: Pacific Forum has authorized its outsourced accounting service to take on a larger role in fulfilling auditor requests to ensure the information submitted ...
Finding: Significant deficiency in internal control for late submission of data control form and Single Audit report package. Corrective action: Pacific Forum has authorized its outsourced accounting service to take on a larger role in fulfilling auditor requests to ensure the information submitted is accurate and complete. PFI has also consolidated financial management policies and other required documentation in a secure cloud network. PFI has also adopted more features available through Bill.com, which has enhanced documentation of expenditures and management reviews. Procedures for filing documents and utilizing financial management procedures available through Bill.com will be integrated into PFI financial management policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over documenting supervisory reviews of financial and performance reports prior to submission Corrective action: Pacific Forum has adopted a policy that requires the Executive Director to review performance and financial reports prior to submission to r...
Finding: Material weakness in internal control over documenting supervisory reviews of financial and performance reports prior to submission Corrective action: Pacific Forum has adopted a policy that requires the Executive Director to review performance and financial reports prior to submission to relevant grantor. The Grants Manager has established a suspense system to ensure reports are submitted in a timely manner. These procedures will be incorporated into PFI financial reporting guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over documenting suspension and debarment reviews for vendors receiving federal funds Corrective action: PFI has adopted a policy to document the screening of all vendors receiving federal funds via the suspension and debarment list provided in SAM.gov....
Finding: Material weakness in internal control over documenting suspension and debarment reviews for vendors receiving federal funds Corrective action: PFI has adopted a policy to document the screening of all vendors receiving federal funds via the suspension and debarment list provided in SAM.gov. These procedures will be incorporated into PFI procurement policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over procurement policies Questioned costs: ALN 81:113 ($31,120) ALN 19.901 ($15,000) Corrective action: While PFI accepts the finding and the rationale for identifying questioned costs based on Uniformed Guidance (UG) requirements for documentation reg...
Finding: Material weakness in internal control over procurement policies Questioned costs: ALN 81:113 ($31,120) ALN 19.901 ($15,000) Corrective action: While PFI accepts the finding and the rationale for identifying questioned costs based on Uniformed Guidance (UG) requirements for documentation regarding competitive bidding and contract types, it believes there is adequate documentation to justify incurred costs. PFI will update its procurement policy guidelines to reflect current UG requirements to include acquisition thresholds and competitive bidding procedures. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Significant deficiency in internal control over federal cash drawdowns Corrective action: Pacific Forum has adopted new financial controls policies to ensure federal cash drawdowns are completed in a timely manner and reviewed by management. The Director of Development prepares a financial ...
Finding: Significant deficiency in internal control over federal cash drawdowns Corrective action: Pacific Forum has adopted new financial controls policies to ensure federal cash drawdowns are completed in a timely manner and reviewed by management. The Director of Development prepares a financial report that shows the amount that can be invoiced/drawn down from federal funds based on actual expenditures. The Executive Director approves the request for funds prior to submission to the funding organization. These procedures will be incorporated into PFI cash management policy guidelines. Completion Date: February 1, 2026. Responsible Individual: Executive Director
Finding: Material weakness in internal control over period of performance Corrective action: Pacific Forum will incorporate policies into expense management and financial reporting guidelines to ensure all expenditure is completed within the period of performance and reviews by management are proper...
Finding: Material weakness in internal control over period of performance Corrective action: Pacific Forum will incorporate policies into expense management and financial reporting guidelines to ensure all expenditure is completed within the period of performance and reviews by management are properly documented. Completion Date: February 1, 2026 Responsible Individual: Executive Director
Finding: Material weakness in internal control over allowable costs and compliance with requirement for written documentation of transactions review required for federally funded awards Corrective action: PFI has adopted a policy to document transaction reviews. Email approval documentation is requi...
Finding: Material weakness in internal control over allowable costs and compliance with requirement for written documentation of transactions review required for federally funded awards Corrective action: PFI has adopted a policy to document transaction reviews. Email approval documentation is required for all transactions, including initial approval by the Program Director and final approval by the Executive Director. This policy will be incorporated into PFI expense management policy guidelines. Completion Date: February 1, 2026 Responsible Individual: Executive Director
The District’s Business Manager will obtain quotes/bids when necessary.
The District’s Business Manager will obtain quotes/bids when necessary.
Management will complete the audit filing with the federal audit clearinghouse by the deadline going forward.
Management will complete the audit filing with the federal audit clearinghouse by the deadline going forward.
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • We are currently in the process of drafting the corresponding administrative order, for which a preliminary draft has already been prepared. This doc...
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • We are currently in the process of drafting the corresponding administrative order, for which a preliminary draft has already been prepared. This document aims to clearly and systematically establish the necessary processes and procedures, including those related to the identified deficiencies, to ensure the implementation of enhanced controls that guarantee regulatory compliance and operational efficiency. • A fiscal section within the Office of Federal Affairs will be established to manage the fiscal process of federal funds. This structure will ensure that all transactions, corrections, and journal entries are recorded in a timely and accurate manner in the federal accounting accounts. IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Maritza Torres López
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • Prior to issuing the SEFA, a final review and approval process will be implemented which will include: o Confirmation that all active federal program...
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • Prior to issuing the SEFA, a final review and approval process will be implemented which will include: o Confirmation that all active federal programs are included. o Validation of amounts, ALN, and expense classifications. • Responsible personnel will be retrained on the processes and requirements applicable to SEFA preparation, in order to strengthen compliance and accuracy in reporting. • We are currently in the process of drafting the corresponding administrative order, for which a preliminary draft has already been prepared. This document aims to clearly and systematically establish the necessary processes and procedures, including those related to the identified deficiencies, to ensure the implementation of enhanced controls that guarantee regulatory compliance and operational efficiency. • A fiscal section within the Office of Federal Affairs will be established to manage the fiscal process of federal funds. This structure will ensure that all transactions, corrections, and journal entries are recorded in a timely and accurate manner in the federal accounting accounts.. IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Maritza Torres López
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • For the preparation of the SEFA, all accounts related to disaster funds will be included, considering that these accounts were segregated into revenu...
VIEWS OF RESPONSIBLE OFFICIALS As part of the Corrective Action Plan to address the identified findings, the following measures will be implemented: • For the preparation of the SEFA, all accounts related to disaster funds will be included, considering that these accounts were segregated into revenues and expenses by the Department of the Treasury. Both categories will be properly incorporated into the SEFA preparation process. • Federal reimbursements received will be immediately identified, and the corresponding journal entries will be prepared without delay to accurately reflect the associated expenses. • Journal entries related to the reimbursement received will be prepared, and the expenses will be recorded in the appropriate accounting accounts, ensuring proper classification and compliance with federal requirements. • We are currently in the process of drafting the corresponding administrative order, for which a preliminary draft has already been prepared. This document aims to clearly and systematically establish the necessary processes and procedures, including those related to the identified deficiencies, to ensure the implementation of enhanced controls that guarantee regulatory compliance and operational efficiency. • Responsible personnel will be retrained on the processes and requirements applicable to SEFA preparation, in order to strengthen compliance and accuracy in reporting. • A fiscal section within the Office of Federal Affairs will be established to manage the fiscal process of federal funds. This structure will ensure that all transactions, corrections, and journal entries are recorded in a timely and accurate manner in the federal accounting accounts. IMPLEMENTATION DATE Fiscal Year 2025-2026 RESPONSIBLE PERSON Maritza Torres López
Corrective Action Plan Fiscal Year 2024 Audit AYUDA, INC. Introduction AYUDA, INC. has prepared this Corrective Action Plan in response to observations identified during the Fiscal Year 2024 audit. This plan outlines management’s actions to further strengthen internal processes, enhance coordination...
Corrective Action Plan Fiscal Year 2024 Audit AYUDA, INC. Introduction AYUDA, INC. has prepared this Corrective Action Plan in response to observations identified during the Fiscal Year 2024 audit. This plan outlines management’s actions to further strengthen internal processes, enhance coordination, and support continued compliance with applicable financial and reporting requirements. The organization maintains established financial and governance practices and views the audit process as an opportunity to reinforce existing controls, clarify responsibilities, and formalize procedures that support efficiency and timeliness. The corrective actions described below are intended to enhance consistency and scalability as organizational operations continue to evolve. Finding 2: Single Audit Report Submission Timeline Condition The audit noted that the Single Audit report submission occurred later than the initially established timeframe. Contributing Factors Factors influencing this observation include: • Opportunities to initiate audit planning earlier within the fiscal cycle. • The need for more clearly defined internal timelines supporting audit coordination. • Increased audit scope and complexity requiring enhanced documentation readiness and cross-functional coordination. Corrective Action Plan 1. Early Audit Planning Management will initiate audit planning earlier in the fiscal year, including confirmation of audit timelines, documentation requirements, and key deliverables. Responsible Party: Sr. Accountant 2. Pre-Audit Readiness Procedures Standardized pre-audit preparation procedures will be followed, including advance completion of reconciliations, schedules, and supporting documentation. Responsible Party: Finance Department 3. Defined Internal Audit Timeline A formal internal audit timeline with clearly defined milestones will be established and monitored throughout the audit cycle. Responsible Party: Sr. Accountant and Executive Director 4. Ongoing Communication with Auditors Regular status check-ins with external auditors will be scheduled to monitor progress, address issues proactively, and support timely completion. Responsible Party: Finance Department 5. Resource and Capacity Planning Management will periodically assess staffing levels and workload distribution related to audit preparation to ensure adequate capacity during critical audit periods. Responsible Party: Finance Department Certification This Corrective Action Plan has been reviewed and approved by management of AYUDA, INC. Name: Miguel Chacon Title: Executive Director Date: 10/18/2025 Name: Paul Rivera Title: Sr. Accountant Date: 10/18/2025
In October 2024, immediately after the above-referenced fraud was committed, SELF created a new policy with tighter internal controls in regard to ACH payments. The new policy requires multiple staff members to verify any banking information (in multiple ways) before any such payment can be initiate...
In October 2024, immediately after the above-referenced fraud was committed, SELF created a new policy with tighter internal controls in regard to ACH payments. The new policy requires multiple staff members to verify any banking information (in multiple ways) before any such payment can be initiated. The new policy was approved shortly thereafter by the organization’s board. SELF also contracted with a digital security company to train all employees about digital threat awareness including fraud and phishing attempts, specifically via email. As part of these new practices, all employees are required to participate in monthly training.
09.744060 Basic Field Grant Grant Period: 1/1/2024 – 12/31/2024 Contract Number: 744060 U.S Department of Justice 16.575 Victims of Crime Act Grant Periods: 10/1/23-9/30/24 and 10/1/24 – 9/30/25 Contract Number: 4055104; 4055105 Supreme Court of Texas Basic Civil Legal Services Program Grant Period:...
09.744060 Basic Field Grant Grant Period: 1/1/2024 – 12/31/2024 Contract Number: 744060 U.S Department of Justice 16.575 Victims of Crime Act Grant Periods: 10/1/23-9/30/24 and 10/1/24 – 9/30/25 Contract Number: 4055104; 4055105 Supreme Court of Texas Basic Civil Legal Services Program Grant Period: 9/1/2023 – 8/31/2025 Contract Number: 26030 2024-003 Internal Controls and Compliance over Allowable Costs and Activities – Payroll (Material Weakness and Material Noncompliance) Recommendation: We recommend the Organization review its timekeeping policies and procedures and provide additional training to employees to ensure time sheets are retained for all payroll transactions to support the allocation of compensation. We also recommend the Organization review and refine its policies to reconcile the percentage of hours charged on the time sheets to the budget estimates used to bill Federal and State grantors. This should be done in conjunction with monthly or quarterly billings (or other determined regular interval), at fiscal year end, and at the end of the grant year (if different from the Organization’s fiscal year). Corrective Action: AVDA implemented a formal Timekeeping and Payroll Compliance Policy in June 2025. All employees funded by Federal or State grants are now required to complete bi-weekly electronic functional time sheets that identify time spent on tasks by budgeted grant(s). Supervisors must review and approve all time sheets prior to submission. The Director of Finance will reconcile budget estimates to actual hours monthly, and quarterly reviews will ensure accuracy in allocations. Training on grant timekeeping standards (2 CFR §200.430) was provided to all program directors and staff in July 2025. Responsible Parties: - Lisa Mikosh, Director of Finance - Marcello Gonzales, Bookkeeper - Maisha Colter, CEO (policy approval and oversight) Date Corrected: August 15, 2025
To whom it may concern: We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals w...
To whom it may concern: We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals with adequate training and subject matter knowledge to perform assigned functions in accordance with appropriate standards and expectations. We are always receptive to positive constructive criticism in our effort to improve upon compliance and financial reporting. Sincerely yours, Rufus Wofford– Acting Chief Executive Officer
To whom it may concern: We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals w...
To whom it may concern: We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals with adequate training and subject matter knowledge to perform assigned functions in accordance with appropriate standards and expectations. We are always receptive to positive constructive criticism in our effort to improve upon compliance and financial reporting. Sincerely yours, Rufus Wofford– Acting Chief Executive Officer
To whom it may concern: We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals w...
To whom it may concern: We have reviewed the comments provided herein and are in agreement with the comments and will remediate the findings as follows: We are reviewing the staffing of our finance department in an effort to ensure that on a go forward basis we reduce turnover and have individuals with adequate training and subject matter knowledge to perform assigned functions in accordance with appropriate standards and expectations. We are always receptive to positive constructive criticism in our effort to improve upon compliance and financial reporting. Sincerely yours, Rufus Wofford– Acting Chief Executive Officer
To improve the timeliness and accuracy of our quarterly and semi-annual reporting, Cayuga Centers has aligned reporting deadlines with internal reconciliation schedules. A reporting coordinator will be appointed to oversee submissions and ensure accuracy. Monthly reconciliations of qualifying costs ...
To improve the timeliness and accuracy of our quarterly and semi-annual reporting, Cayuga Centers has aligned reporting deadlines with internal reconciliation schedules. A reporting coordinator will be appointed to oversee submissions and ensure accuracy. Monthly reconciliations of qualifying costs and cash draws will support this process, and a reporting calendar with automated reminders will be implemented to keep all stakeholders on track.
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs ...
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs against program requirements and other relevant background documentation. For finding 2024-012, Cayuga will review relevant lease terms and program requirements. If, upon full evaluation, Cayuga Centers concurs that such costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. For steps to resolve the underlying control deficiency asserted or implied in this finding, please see Cayuga Centers’ response to Findings 2024-001 through 006 above.
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs ...
Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs against program requirements and other relevant background documentation. For finding 2024-012, Cayuga will review relevant lease terms and program requirements. If, upon full evaluation, Cayuga Centers concurs that such costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. For steps to resolve the underlying control deficiency asserted or implied in this finding, please see Cayuga Centers’ response to Findings 2024-001 through 006 above.
As discussed above Cayuga Centers has engaged grants management advisors who will assist in evaluating this specific finding. To the extent that the finding merely asserts that indirect cost bases were improperly calculated in prior periods, please see Cayuga Centers’ response and actions steps with...
As discussed above Cayuga Centers has engaged grants management advisors who will assist in evaluating this specific finding. To the extent that the finding merely asserts that indirect cost bases were improperly calculated in prior periods, please see Cayuga Centers’ response and actions steps with respect to findings 2024-001 through 006. If, upon full evaluation, Cayuga Centers concurs that indirect costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs.
Cayuga Centers does not fully understand the scope of this asserted finding. It will, however, work with its auditors to fully assess this finding. As discussed above, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted findings. To the exte...
Cayuga Centers does not fully understand the scope of this asserted finding. It will, however, work with its auditors to fully assess this finding. As discussed above, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted findings. To the extent that the costs referenced in this finding are unallowable, Cayuga Centers will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. To the extent this finding asserts control failures, please see Cayuga Centers’ response to Findings 2024-005 and 006 above.
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the...
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the drawdown process generally, Cayuga Centers has established a review protocol requiring that draws include only qualified expenditures incurred or expected within three business days. All draw requests require dual approval from both finance and program staff. A centralized draw request log is being maintained, including supporting documentation and reconciliation records. With respect to Finding 2024-008, Cayuga Centers does not entirely agree with the auditors’ assertion that accrued vacation expense was improperly included in draw requests. Under certain circumstances, costs of paid time off may be treated as incurred based on PTO earned, rather than PTO-paid. See 2 C.F.R. § 200.431(b). Cayuga Centers will further evaluate this asserted finding with the grants management advisors described above. To the extent there may be any compliance discrepancy, Cayuga Centers will take further appropriate action.
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the...
Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the drawdown process generally, Cayuga Centers has established a review protocol requiring that draws include only qualified expenditures incurred or expected within three business days. All draw requests require dual approval from both finance and program staff. A centralized draw request log is being maintained, including supporting documentation and reconciliation records. With respect to Finding 2024-008, Cayuga Centers does not entirely agree with the auditors’ assertion that accrued vacation expense was improperly included in draw requests. Under certain circumstances, costs of paid time off may be treated as incurred based on PTO earned, rather than PTO-paid. See 2 C.F.R. § 200.431(b). Cayuga Centers will further evaluate this asserted finding with the grants management advisors described above. To the extent there may be any compliance discrepancy, Cayuga Centers will take further appropriate action.
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