Corrective Action Plans

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Finding 2023-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education
Finding 2023-001: Procurement Federal Agency: U.S. Department of Education Pass-through agency: Pennsylvania Department of Education
Assistance Listing Number: 84.425 Education Stabilization Fund Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal ...
Assistance Listing Number: 84.425 Education Stabilization Fund Criteria: The Uniform Guidance requires that non-federal entities must have and use documented procurement procedures consistent with laws and regulations and the standards for the acquisition of property or services under a federal award or subaward in accordance with 2 CFR 200.318. Furthermore, the non-federal entity is required to follow formal procurement methods when the value of the procurement for property or service under a federal financial assistance award exceeds the simplified acquisition threshold in accordance with 2 CFR 200.320.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance.
Condition: The District did not follow the appropriate procedures to comply with Uniform Grant Guidance.
Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local governme...
Context: During testing, it was noted that the District had entered into a lease agreement in 2017 to acquire computer equipment. The equipment was acquired through COSTARS, a cooperative purchasing program. While purchases through COSTARS meet the cooperative purchase requirement for local government purchasing under 62 Pa.C.S. section 1902, they do not meet the more stringent requirements of the Uniform Grant Guidance. Subsequently, the District decided to budget for and pay for this lease agreement in the 2021-2022 school year under the Education Stabilization Fund. In using federal funds to pay for the lease agreement, the District inadvertently did not follow its procurement policy. While the school district developed a plan to correct these procedures, it was not fully implemented until the 2023-2024 school year.
Cause: When the District initially entered into the lease agreement, they were unaware that the future cost of the lease would be paid for with federal funding.
Cause: When the District initially entered into the lease agreement, they were unaware that the future cost of the lease would be paid for with federal funding.
Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance.
Effect: The District did not follow its procurement policy and ultimately did not comply with the standards of the Uniform Grant Guidance.
Identification of Repeat Finding: No
Identification of Repeat Finding: No
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement stan...
Recommendation: We recommend that when the District decides to utilize cooperative purchasing programs and use federal funds for those purchases that a review of compliance with the procurement policy occurs. The District should then document its process and how it complies with the procurement standards.
View of Responsible Officials: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Grant Guidance Fede...
View of Responsible Officials: The District has reviewed the applicable Uniform Guidance from the Federal Office of Management and Budget and has developed administrative procedures to aid with ensuring that all procurements financed with federal funding fully comply with Uniform Grant Guidance Federal acquisition thresholds and requirements. On June 15, 2023, business office representatives met with staff members potentially involved with procurements that may be federally funded. The business manager reviewed the newly established protocol developed to assist with compliance with all in attendance. The protocol was officially deployed on July 1, 2023, but unfortunately was not in place during the 22-23 FY. It is noted that one-half of the 22-23 FY was already over at the time the district received notification of this initial finding.
Person Responsible: Oslwen C. Anderson, Jr., Business Manager OCA
Person Responsible: Oslwen C. Anderson, Jr., Business Manager OCA
Completion Date: June 30, 2023
Completion Date: June 30, 2023
Action taken in response to finding:  The Financial Aid Office (FAO) has implemented, another line of communication with the Registrar’s office to ensure that all complete withdrawals are sent to the financial aid office by forwarding them to a designated email box. The Financial Aid Office is also...
Action taken in response to finding:  The Financial Aid Office (FAO) has implemented, another line of communication with the Registrar’s office to ensure that all complete withdrawals are sent to the financial aid office by forwarding them to a designated email box. The Financial Aid Office is also working with IT services to develop a report that can be pulled to capture and compare all withdrawal students, with the Registrar’s office to make sure none are overlooked.  The Financial Aid Office is working with our 3rd Party Servicer, Ellucian, to identity the issues with our rules that do not capture the correct data elements, so that loans are not disbursed after a student has completely withdrawn.
View Audit 15077 Questioned Costs: $1
2023-002: Special Tests and Provisions – Wage Rate Requirements Condition: The District did not have sufficient controls in place to ensure that all construction contracts in excess of $2,000 financed by federal assistance funds included verbiage to ensure that all laborers and mechanics employed by...
2023-002: Special Tests and Provisions – Wage Rate Requirements Condition: The District did not have sufficient controls in place to ensure that all construction contracts in excess of $2,000 financed by federal assistance funds included verbiage to ensure that all laborers and mechanics employed by the contractors or subcontractors were paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (40 USC 3141-3144, 3146, and 3147) Recommendation: Management implement internal control procedures to review all construction contracts and ensure prevailing wage requirements are met Action Taken: We concur with the recommendation and a procedure has been defined and implemented to ensure all construction contracts include prevailing wage requirements prior to signature. If the Pennsylvania Department of Education has questions regarding this corrective action plan, please call Gary Levin at 717-244-4021 x 4245.
Condition: One vendor was awarded a contract without a procurement process. Corrective Action Planned: The Town followed Massachusetts procurement laws instead of Federal procurement laws. Upon discovery, the Town took immediate action to rectify and has updated its Federal procurement guideline...
Condition: One vendor was awarded a contract without a procurement process. Corrective Action Planned: The Town followed Massachusetts procurement laws instead of Federal procurement laws. Upon discovery, the Town took immediate action to rectify and has updated its Federal procurement guidelines and re-distributed the information to employees. Anticipated Completion Date: Completed September 2023 Contact: Jodi Cuneo, Finance Director/Town Accountant
View Audit 15065 Questioned Costs: $1
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Eagle Court Apartments respectfully submits the following corrective action plan for the year ended September 30, 2023. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 554...
DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Eagle Court Apartments respectfully submits the following corrective action plan for the year ended September 30, 2023. Name and address of independent public accounting firm: Hinrichs & Associates, Ltd. 1000 Shelard Parkway, Suite 110 Minneapolis, MN 55426 Audit Period: September 30, 2023 The finding from the September 30, 2023 schedule of findings and questioned costs are discussed below. The finding is numbered consistently with the numbers assigned in the schedule. Section A of the schedule, Summary of Audit Results, does not include findings and is not addressed. FINDINGS - FINANCIAL STATEMENT AUDIT - NONE, FINDINGS - FEDERAL AWARD PROGRAMS AUDIT - DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING 2023-001: SECTION 202, Assistance Listing Number 14.157 Condition: One of the tenant files tested contained a mathematical error in computing household income in the process of computing the tenant share of monthly rent. Recommendation: The Project should recompute the HUD subsidy and tenant rent for this tenant and adjust a future monthly billing. Project managers should be aware of the importance of computing the tenant's household income correctly. Action taken: The Project agrees with the finding. Tenant rent was recomputed in December 2023 and management will adjust the January 2024 HUD billing. If the Department of Housing and Urban Development has questions regarding this plan, please call Craig Ritter at 320-584-2423.
View Audit 15039 Questioned Costs: $1
Finding 11248 (2023-004)
Significant Deficiency 2023
Identifying Number: 2023-004 Finding: While the College does have a program that addresses information security, the College did not have a readily accessible program document to address the required safeguards for the nine required elements under the implementing regulations of the Gramm-Leach Bl...
Identifying Number: 2023-004 Finding: While the College does have a program that addresses information security, the College did not have a readily accessible program document to address the required safeguards for the nine required elements under the implementing regulations of the Gramm-Leach Bliley Act (GLBA) known as the “Safeguards Rule” by June 9, 2023. Corrective Action Taken or Planned: The College will create a readily accessible written information security program document outlining all standards to meet and maintain compliance with the GLBA. While the College has not yet formally adopted an information security program, they have demonstrated substantial compliance with the required elements under the Gramm-Leach Bliley Act, including: • Development and implementation of risk assessment frameworks that include penetration testing (16 C.F.R. 314.4(b)); • Adoption of a cybersecurity roadmap and various College policies based on internationally recognized NIST standards (16 C.F.R. 314.4(c)); • Regular testing and monitoring of the effectiveness of the safeguards currently implemented (16 C.F.R. 314.4(d)); • Implementation of policies and procedures to ensure personnel can enact safeguards that should be formally included in the information security program (16 C.F.R. 314.4(e)); • Adoption of procedures and policies for the evaluating and adjusting the safeguards that have been implemented, including monthly vulnerability scans accompanied by a remediation plan for any vulnerabilities identified (16 C.F.R. 314.4(g)); • Creation of a Cybersecurity Incident Response Plan (16 C.F.R. 314.4(h)); and • Annual training and reporting for the College’s Board of Trustees on cybersecurity safeguards (16 C.F.R. 314.4(i)). The Director of Cybersecurity and the Chief Information Officer are designated as the responsible parties for oversight and implementation of the program. Anticipated Completion Date: June 30, 2024 Responsible Person: Allison Porterfield-Woods, Chief Information Officer
View Audit 15031 Questioned Costs: $1
Finding 11245 (2023-003)
Significant Deficiency 2023
Identifying Number: 2023-003 Finding: For 2 out of 17 (11.7%) expenditures tested, portions of the expenditures had service periods that extended beyond the grant’s period of performance and were charged to the grant for reimbursement. Corrective Action Taken or Planned: To prevent a recurrence...
Identifying Number: 2023-003 Finding: For 2 out of 17 (11.7%) expenditures tested, portions of the expenditures had service periods that extended beyond the grant’s period of performance and were charged to the grant for reimbursement. Corrective Action Taken or Planned: To prevent a recurrence, grants transactions will be reviewed by the Principal Investigator/Program Director, the Strategic Advancement unit, and the Finance Office for allowability and alignment with the grant’s performance period. Anticipated Completion Date: This process has already been implemented by the College. Responsible Persons: Nick Branson, Assistant Vice President for Strategic Advancement Jean Stephan, Controller
View Audit 15031 Questioned Costs: $1
Finding 11244 (2023-002)
Significant Deficiency 2023
Identifying Number: 2023-002 Finding: The College did not publicly post a certain required report timely. The following instance of noncompliance was identified: • HEERF Institutional Portion and MSI: The College posted a report to their website on October 23, 2023, for the period of April 1, 2...
Identifying Number: 2023-002 Finding: The College did not publicly post a certain required report timely. The following instance of noncompliance was identified: • HEERF Institutional Portion and MSI: The College posted a report to their website on October 23, 2023, for the period of April 1, 2023 – June 30, 2023, which was 110 days after the required deadline of July 10, 2023. Corrective Action Taken or Planned: The FY2023 Q2 report was completed by the College and posted on the website. Due to transition in personnel overseeing the quarterly reporting deadline, the initial due date for this report passed before the College completed its report. The College completed its reporting and public posting before the HEERF closeout deadline as specified in the Department of Education’s Closeout Liquidation Letter. Anticipated Completion Date: This process has already been implemented by the College Responsible Person: Nick Branson, Assistant Vice President Strategic Advancement Jean Stephan, Controller
Recommendation – We encourage the Board of Directors and management to strengthen internal controls or implement mitigating controls where possible. Management’s Response – In 2023, the Organization implemented a new accounting information system at Adoray, as well as reviewing job responsibilities ...
Recommendation – We encourage the Board of Directors and management to strengthen internal controls or implement mitigating controls where possible. Management’s Response – In 2023, the Organization implemented a new accounting information system at Adoray, as well as reviewing job responsibilities and duties, to create opportunities for segregation of duties and separation of incompatible functions in the future. Management plans to continue this process and review and provide additional updates in 2024.
Federal Award Finding. Department of Health and Human Services, Temporary Assitance for Needy Families. Assistance listing number 93.558. Passed through various counties and Minnesota DEED. Significant Deficiency: See Finding 2023-002. Recommendation: That management review internal controls and imp...
Federal Award Finding. Department of Health and Human Services, Temporary Assitance for Needy Families. Assistance listing number 93.558. Passed through various counties and Minnesota DEED. Significant Deficiency: See Finding 2023-002. Recommendation: That management review internal controls and implement procedures to ensure all entries are independently reviewed and approved and supported by adequate supporting documentation. Action Taken: We concur with the recommendation, and it was implemented immediately 1/22/2024. The Accounting Manager will no longer create and approve the same adjusting journal entry. When the Accounting Manager, Bill MacFarlane creates an adjusting journal entry, it will be approved by the IT Manager, Dave Schumacher, or the Executive Director, Tina Jaster. When Accounting Specialist, Angie Hanson, makes any adjusting journal entries, they will be approved by the Accounting Manager going forward.
Finding 2023-002 Federal Agency Name: Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Fund CFDA #21.027 Finding Summary: The original project and expenditure reports provided to the auditors did not include all expenditures made during the reporting peri...
Finding 2023-002 Federal Agency Name: Department of the Treasury Program Name: COVID-19 Coronavirus State and Local Fiscal Recovery Fund CFDA #21.027 Finding Summary: The original project and expenditure reports provided to the auditors did not include all expenditures made during the reporting periods they selected for testing. Responsible Individuals: Aaron Price Corrective Action Plan: This is the result of an end of year timing issue wherein the reporting deadline to the Federal Government occurred prior to year-end close, resulting in a reconciling item being accurately reported within the City’s fiscal year despite being reported to the Federal Government in a subsequent quarter, but still accurately within the Federal Government’s fiscal year. Moving forward, greater efforts will be used to reconcile year end grant transactions prior to federal reporting, however, this is considered to be a non-recurring issue given the nature of the grant. Anticipated Completion Date: December 2023
The College experienced a transition in a key management position, Controller, at the end of fiscal year 2023. The new appointed Controller will revise the month-end, and year-end, closing activities to include detailed procedures, the roles of those responsible on the Financial Services team, and d...
The College experienced a transition in a key management position, Controller, at the end of fiscal year 2023. The new appointed Controller will revise the month-end, and year-end, closing activities to include detailed procedures, the roles of those responsible on the Financial Services team, and deadlines that support timely financial reporting. The Financial Services team will maintain regularly scheduled progress meetings to ensure the audit remains on track for timely submission and uphold the responsibility for ensuring that the audit commences on a timely basis. A quarterly progress review will be conducted with the Vice President of Financial Services and Operations. Additionally, the Controller will submit a request to fill vacant Financial Services positions to the Senior Team for approval and will submit a recommendation to the Senior Team to fire additional resources with appropriate accounting experience and knowledge.
Recommendation – We recommend that all accounts be reconciled and adjustments be posted to the accounting records on a quarterly basis, at a minimum. Management’s Response – The Hospital will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the ...
Recommendation – We recommend that all accounts be reconciled and adjustments be posted to the accounting records on a quarterly basis, at a minimum. Management’s Response – The Hospital will work to establish policies and procedures to reduce the number of adjusting journal entries proposed by the auditors.
Recommendation – We recommend management and those charged with governance continue to evaluate whether to accept the degree of risk associated with this condition because of cost or other considerations. Management’s Response – The Hospital does not have the resources available to increase staff si...
Recommendation – We recommend management and those charged with governance continue to evaluate whether to accept the degree of risk associated with this condition because of cost or other considerations. Management’s Response – The Hospital does not have the resources available to increase staff size and address this internal control deficiency. The Board of Directors and management are aware of the incompatible duties and will continue to provide oversight and monitor the Hospital’s operations
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