Corrective Action Plans

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Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have ...
Management agrees with the findings and has implemented the policies below and will continue to train and connect our team members with the in-house HUD Compliance Specialist for support. 1. Move in EIV’s – All move in files will be sent to our in-house compliance department and Franklin Group have an EIV specialist how follows and tracks all moves for accuracy for all move files and the EIV specialist also sends out the 90-day reminders for all move in. 2. Existing Tenant EIV – It is the policy that all existing tenant EIV & 120-day reports are run per the 4350 guidelines. The Community Manager for Renaissance Gardens has been provided the HUD Trainings and have noted on her daily task reminder from One Site to pull all reports as required. The Regional Manager is required during monthly visits to spot check at least 5 existing tenants.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will gain prior approval for replacement reserve withdraw in accordance with HUD going forward.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will gain prior approval for replacement reserve withdraw in accordance with HUD going forward.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations and has implemented reviews of the financial statements by senior management prior to approving transfers to ensure accuracy of information.
Management agrees with the findings and recommendations and has implemented reviews of the financial statements by senior management prior to approving transfers to ensure accuracy of information.
Management agrees with the finding and is working with ownership on reimbursement to the property. Management will collect in accordance with HUD going forward.
Management agrees with the finding and is working with ownership on reimbursement to the property. Management will collect in accordance with HUD going forward.
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance wi...
FG Companies has a procedure in place that requires all tenant files to be reviewed by the compliance team that is in line with the community’s tenant selection plan that outlines the tenant eligibility requirements. All annual certifications are submitted and reviewed by compliance in accordance with the requirements of the HUD Handbook4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. FG Companies has also implemented a bi-weekly file audit system that will continue to be completed by the Regional Manager. This system is to ensure all files are current with certifications and all required state and local forms are completed and filed accordingly.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will collect in accordance with HUD going forward.
Management agrees with the findings and recommendation is working with ownership on reimbursement to property. Management will collect in accordance with HUD going forward.
Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.
Management agrees with the findings and recommendations, however due to insufficient funds at the property, we will collaborate with HUD to secure appropriate funding.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
Management agrees with the findings and recommendations, will transfer the replacement reserve funds. Monthly deposits will be completed in accordance with HUD going forward to ensure all terms and conditions are met.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certific...
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CAPITALIZATION GRANTS FOR CLEAN WATER STATE REVOLVING FUNDS ASSISTANCE LISTING No. 66.458 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2026.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, HAZARD MITIGATION GRANT PROGRAM, ASSISTANCE LISTING No. 97.039 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required ent...
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, HAZARD MITIGATION GRANT PROGRAM, ASSISTANCE LISTING No. 97.039 Name of Contact Person: Loni Hanson Corrective Action: The city appreciates the clarification regarding the required compliance certifications for all required entities receiving federal funds. In this case, the documentation collected by our contactors for subcontractor and supplier compliance was not available to the city at the time of audit. In the future, the city will request this documentation from our prime contractors in a more timely fashion to ensure its availability at the time of audit. The city will work with its engineering contractor to update processes to correct the identified deficiency. Proposed Completion Date: April 1, 2026.
Management concurs with Audit Finding 2025-004 and will strengthen controls over USDA commodity receiving documentation and related reporting to ensure compliance with Food Distribution Cluster special tests and provisions and reporting requirements. Management will implement the following correctiv...
Management concurs with Audit Finding 2025-004 and will strengthen controls over USDA commodity receiving documentation and related reporting to ensure compliance with Food Distribution Cluster special tests and provisions and reporting requirements. Management will implement the following corrective actions: 1. Required Receiving Worksheets for USDA Commodity Receipts Management will reinforce the requirement that a completed receiving worksheet be prepared for all TDA USDA commodity receipts. Each receiving worksheet will be signed or initialed by the receiving employee at the time of receipt to evidence verification of quantities received. 2. Reconciliation of Receiving Documentation to CERES Management will implement a formal reconciliation process to ensure all USDA receiving documentation is reconciled to CERES inventory entries prior to submission of monthly TEFAP reports. Any discrepancies will be promptly investigated, resolved, and documented. 3. Supervisory Review and Approval Supervisory personnel will perform periodic documented reviews to verify that: o All USDA commodity receipts are supported by completed and signed receiving worksheets; and o Receiving activity is accurately and completely recorded in CERES. Evidence of supervisory review will be retained. 4. Documentation Retention and Standardization All receiving worksheets and supporting documentation will be retained in accordance with Food Distribution Cluster record retention requirements. Management will standardize receiving forms and procedures to promote consistency and completeness. 5. Training and Ongoing Monitoring Management will provide refresher training to warehouse and inventory staff on USDA receiving requirements and the importance of timely, accurate documentation. Management will periodically monitor compliance with these procedures to ensure controls are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)
Management concurs with Audit Finding 2025-003 and will strengthen controls over USDA Food Distribution Cluster reporting to ensure accuracy, completeness, and compliance with federal and State requirements. Management will implement the following corrective actions: 1. Monthly USDA Reporting Reconc...
Management concurs with Audit Finding 2025-003 and will strengthen controls over USDA Food Distribution Cluster reporting to ensure accuracy, completeness, and compliance with federal and State requirements. Management will implement the following corrective actions: 1. Monthly USDA Reporting Reconciliation Process Management will implement a formal monthly reconciliation process that includes: o Reviewing confirmed USDA receipts and reconciling them to internal inventory records in CERES; and o Reconciling all TEFAP distribution reports submitted to the States to CERES data prior to submission. All reconciliations will be documented, reviewed, and retained. 2. Documentation of Shortages and Inventory Adjustments Shortages noted on signed agency invoices will be promptly documented and resolved through credit memos or inventory adjustments in CERES. Supporting documentation will be retained to substantiate all adjustments. 3. 48-Hour Receipt Confirmation Tracking Management will establish a tracking mechanism (e.g., log or checklist) to monitor submission of all required 48-hour receipt confirmations. The tracking tool will document submission dates and ensure confirmations are submitted timely and retained in accordance with record retention requirements. 4. Assignment of Reporting Responsibility Management will formally assign primary responsibility for preparation and submission of Food Distribution Cluster reports to a designated individual. Roles and responsibilities will be clearly documented. 5. Supervisory Review and Oversight A supervisory reviewer will perform documented reviews of reconciliations, supporting documentation, and reports prior to submission. Supervisory review will confirm that: o Reconciliations are completed. o Differences are investigated and resolved; and o Reports comply with applicable federal and State requirements. 6. Monitoring and Training Management will periodically monitor compliance with these procedures and provide refresher training to staff involved in inventory, distribution, and reporting to ensure consistent application of controls. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)
Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following co...
Management concurs with Audit Finding 2025-002 and will reinforce controls over USDA food distribution documentation to ensure all distributions are properly acknowledged and supported in accordance with Food Distribution Cluster recordkeeping requirements. Management will implement the following corrective actions: 1. Required Agency Acknowledgment at Delivery Management will reinforce procedures requiring recipient agency signatures or equivalent acknowledgment on all USDA food distribution invoices at the time of delivery. Distribution staff and drivers will be reminded that unsigned delivery documentation is considered incomplete. 2. Post-Delivery Follow-Up Control Management will implement a follow-up control, such as a delivery log or checklist, to track all USDA distributions recorded at the time of delivery. The log will include verification that a signed receipt has been obtained and returned for each transaction. 3. Reconciliation of Distributions to Signed Documentation On a periodic basis, management will reconcile USDA distribution activity to signed agency invoices to identify any missing acknowledgments. Missing signatures will be promptly investigated and resolved, with documentation of follow-up retained. 4. Supervisory Review and Oversight Supervisory personnel will perform periodic documented reviews of distribution documentation to verify that signed agency receipts are obtained, complete, and retained. Evidence of review will be maintained. 5. Training and Awareness Management will provide refresher training to distribution staff and drivers on USDA documentation requirements and the importance of obtaining signed acknowledgment to support program accountability and reporting accuracy. Expected Completion Date: Within 60-90 days Responsible Parties: Andrelle Bowen, Transportation Manager, (901-373-0402)
Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will i...
Management concurs with Audit Finding 2025-001 and will implement enhanced internal controls over inventory adjustments to ensure accurate accounting for the receipt, distribution, and disposition of all USDA commodities in compliance with Special Tests and Provisions requirements. Management will implement the following corrective actions: 1. Formal Approval and Authorization of Inventory Adjustments Management will establish a formal policy requiring documented supervisory review and approval for all manual positive and negative inventory adjustments recorded in the general ledger and the CERES inventory system. Approval will be obtained prior to posting adjustments, and access to record adjustments will be restricted to authorized personnel. 2. Standardized Documentation for Adjustments Each inventory adjustment will be supported by standardized documentation clearly explaining the nature, reason, and calculation of the adjustment, along with applicable supporting records (e.g., receiving documents, distribution records, shortage documentation). All documentation will be retained in accordance with USDA record retention requirements. 3. Reconciliation of Inventory Activity Management will implement a periodic (at least monthly) reconciliation of inventory receipts, distributions, and adjustments to CERES and the general ledger. Reconciling items will be investigated, resolved, and documented timely. 4. Monitoring of USDA Program Inventory Management will perform periodic reviews of inventory activity related to donated inventory and Tennessee and Mississippi USDA programs to ensure that adjustments are appropriate, approved, and accurately recorded. 5. Training and Ongoing Oversight Management will provide targeted training to staff involved in inventory and accounting processes regarding USDA Special Tests and Provisions requirements and the new approval and documentation procedures. Management will monitor compliance with these controls to ensure they are operating effectively. Expected Completion Date: Within 60–90 days Responsible Parties: Donavann Brooks, Inventory Control Manager (901-527-0422)
2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these control...
2025-004. SEGREGATION OF DUTIES Name of Contact Person: Roger Heimbigner Corrective Action: The duties will be separated as much as possible and alternative controls will be used to compensate for lack of separation. The governing board will continue to be involved in providing some of these controls. Proposed Completion Date: The governing board will implement the above procedure immediately.
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.
Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Man...
Condition: The amounts used to record expenditures on the quarterly expenditure reports should match the general ledger accounts where the expenditures are recorded. Recommendation: We recommend reviewing the general ledger to the expenditure reports before submittin for more accurate reporting. Management response: The District will review the general ledger to the expenditure reports before submitting.
Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Man...
Condition: The District's general ledgers totals are inconsistent with the ISBE reports due to timing errors, resultig in certain expenses being claimed late on the IDEA Flow Through. Recommendation: We recommend reconciling the general ledger totals to the expenditure reports before sumbitting. Management Response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports ...
Condtion: The District's general ledger totals are inconsistent with the ISBE reports due to the timing erros, resulting in certain expenses being claimed in grants in the current year and the prior year. Recommendations: We recommend reconciling the general ledger totals to the expenditure reports before submitting. Management response: The District will add a vertification process to reconcile the general ledger totals to the expenditure reports before submitting.
Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if...
Finding 2025-001: Subrecipient monitoring Name of contact person: Shavone Smith, Vice President of Finance, (404) 653-0790 Recommendation: The Foundation should ensure that established policies and procedures that are in place to ensure proper subrecipient monitoring activities are adhered to and if there are delays in performing certain key tasks that a plan with a timeline be developed to address when missed tasks will be completed. Corrective action: The Foundation acknowledges that it did not obtain internal control surveys and audit certification forms for a portion of fiscal year 2025 due to reductions in force and other organizational changes which temporarily limited staff capacity to complete all monitoring activities. Internal control surveys and audit certification fully resumed in October 2025. At that time, we also went back to the period May-October 2025 to perform the procedures that were paused and completed monitoring for all subrecipient agreements that were still active. The procedures we performed retroactively did not indicate any heightened risks for the applicable subrecipients. Additionally, all current subrecipient agreements with end dates beyond October of 2025 have had monitoring completed or are scheduled to be completed (due to more recent start dates). To prevent recurrence, the Foundation has implemented procedural safeguards to ensure continuity of compliance monitoring (specifically internal control survey administration, audit certification and an audit review and follow-up) during periods of staffing or operational disruption. These safeguards include (1) reaffirming formal assignment of responsibility for internal control survey administration and audit certification/foll-up to designated roles rather than individual staff, (2) cross-training of additional personnel to perform these functions as needed, and (3) increased management review to confirm completion and timeliness of monitoring. The Foundation will proactively assess the potential impact of anticipated and unanticipated staffing changes on subrecipient monitoring and compliance activities. Management will identify critical functions (including internal controls surveys and audit certification collection) and will ensure appropriate coverage, cross-training, or alternative resources are in place to maintain compliance with federal requirements. These controls were designed to ensure continuity of compliance activities during periods of staffing transition or operational disruption. Management will monitor compliance with this process on an ongoing basis to ensure monitoring is consistently performed in accordance with policy. Proposed completion date: October 2025
Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the U...
Finding 2025-001 - Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Equipment and Real Property Context: During testing, we noted the Unit spent $160,847 on flooring upgrades which exceeded the $5,000 federal equipment and real property threshold. However, the Unit did not perform any of the required federal compliance steps related to the flooring purchase (getting approval before making the purchase, adding the flooring purchase to the capital asset listing, and performing an inventory of the flooring). The Unit believed the flooring purchase did not require approval because it does not meet the criteria of a major renovation under Head Start guidelines. However, as noted in the criteria above, the flooring still qualifies as an equipment and real property purchase. Contact Person Responsible for Corrective Action: Brenda Overton Contact Phone Number: 574.393.5866 Views of Responsible Official: The Consortium management disagrees with the finding. Description of Corrective Action Plan: The Consortium plans to discuss this matter with ACF/HHS to determine if the finding is out of compliance. Anticipated Completion Date: June 30, 2026
Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Actio...
Finding Description: 2 CFR Part 200.302(b)(7) requires the financial management system to include written procedures for determining the allowability of costs. The City has not developed written procedures for determining the allowability of costs for departments outside of transit. Corrective Action: Management will incorporate written procedures for determining the allowability of costs into the City's Financial Plan document, which already includes a section for City-wide policies related to grant administration. The Finance Director and City Manager are responsible for updating the Financial Plan, and the policy updates will be incorporated along with the adoption of the City's fiscal year 2026-2027 budget prior to June 30, 2026.
Recommendation: We recommend the Town evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the data collection form. Management’s Response:: The Town will implement internal ...
Recommendation: We recommend the Town evaluate the process and design of internal controls over financial reporting, including the SEFA and SESA, in order to ensure readiness for the audit and to avoid late filing of the data collection form. Management’s Response:: The Town will implement internal controls to ensure the filing deadline is met. Jason Vieira of the Towns Finance Department is responsible for the corrective action plan.
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