Corrective Action Plans

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Management concurs with the noted deficiencies and has implemented, or is in the process of implementing, corrective actions to strengthen compliance with HRSA Sliding Fee Discount Program requirements. Actions include the immediate use of standardized eligibility checklists, enhanced documentation ...
Management concurs with the noted deficiencies and has implemented, or is in the process of implementing, corrective actions to strengthen compliance with HRSA Sliding Fee Discount Program requirements. Actions include the immediate use of standardized eligibility checklists, enhanced documentation requirements, and monthly compliance reviews of approved applications. A secondary review process for eligibility determinations will be implemented, along with formalized staff training programs to be completed within established timelines. Additionally, management will establish a quarterly internal audit process to monitor ongoing compliance, with results reported to appropriate oversight personnel. These measures are designed to improve accuracy, consistency, and oversight, and management will continue to monitor compliance through recurring reviews and annual policy assessments.
Implement procedures to ensure the reports filed are in agreement with the County's financial accounting records and be clerically accurate.
Implement procedures to ensure the reports filed are in agreement with the County's financial accounting records and be clerically accurate.
Corrective Action: The District will establish a formal Federal Grant Compliance Reporting Calendar and Review Process. The corrective action will include: 1. Development and maintenance of a comprehensive federal reporting calendar identifying: o Grant/program; o Required report; o Reporting freque...
Corrective Action: The District will establish a formal Federal Grant Compliance Reporting Calendar and Review Process. The corrective action will include: 1. Development and maintenance of a comprehensive federal reporting calendar identifying: o Grant/program; o Required report; o Reporting frequency; o Federal or grantor due date; o Responsible preparer; o Supervisory reviewer; o Backup personnel; o Date prepared; o Date reviewed; and o Date submitted. 2. Establishment of internal deadlines sufficiently in advance of federal reporting deadlines to allow for supervisory review and correction. 3. Documented supervisory review before submission of federal reports. 4. Assignment of backup personnel for critical federal reporting responsibilities. 5. Periodic management review of upcoming reporting deadlines. 6. An escalation procedure for reports approaching their deadline without completion. 7. Retention of evidence demonstrating report preparation, review, submission, and acceptance when available. 8. Quarterly review of the federal reporting calendar to identify changes in grant requirements, personnel responsibilities, or reporting deadlines. 9. Coordination of the federal reporting calendar with the year-end close and Single Audit timetable. 10. Upon execution and implementation of the ICA, applicable grant accounting and financial reporting procedures will be coordinated with the County Auditor's Office to the extent those functions are included within the shared services established under the Agreement. Measure of Completion: The District will have the formal federal reporting calendar, assigned responsibilities, backup assignments, supervisory review procedures, and escalation procedures implemented by October 31, 2026. All federal reports will thereafter be submitted by their applicable deadlines. Management will retain documentation demonstrating timely preparation, supervisory review, and submission. Any missed deadline will be documented, investigated, and addressed through appropriate corrective action. Target Completion Date: October 31, 2026, for development and implementation; ongoing thereafter. District Management Contact: Tomiko Fisher, Chief Operating Officer
Corrective Action: The District will establish a formal Federal Award Period-of-Performance and Payroll Cutoff Procedure as a component of its year-end closing and grant reporting processes. The corrective action will include: 1. Identification of all payroll periods crossing the September 30 fiscal...
Corrective Action: The District will establish a formal Federal Award Period-of-Performance and Payroll Cutoff Procedure as a component of its year-end closing and grant reporting processes. The corrective action will include: 1. Identification of all payroll periods crossing the September 30 fiscal year-end. 2. Calculation and documentation of payroll and related benefits attributable to each fiscal year. 3. Procedures to ensure federal award expenditures reported on the SEFA are recorded in the appropriate fiscal period. 4. Documented spot checks of payroll and nonpayroll federal expenditures around fiscal year-end. 5. Coordination between Payroll, Accounting, and Grant Accounting regarding fiscal-year cutoff. 6. Supervisory review of year-end federal award cutoff calculations before preparation of the SEFA. 7. Training for accounting, payroll, and grant personnel regarding period-of-performance and fiscal-year cutoff requirements. 8. Upon execution and implementation of the ICA, applicable grant accounting, payroll cutoff, and financial reporting procedures will be coordinated with the County Auditor's Office to the extent those functions are included within the shared services established under the Agreement. Measure of Completion: The District will have the formal federal award period-of-performance and payroll cutoff procedures implemented by October 31, 2026. The procedures will thereafter be incorporated into the annual year-end close process. All federal award payroll and applicable nonpayroll expenditures crossing fiscal year-end will be reviewed and documented. The FY2026 SEFA will receive a specific period-of-performance and cutoff review before submission to the independent auditors. Target Completion Date: October 31, 2026, for development and implementation; ongoing thereafter. District Management Contact: Tomiko Fisher, Chief Operating Officer
2025-009 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation ...
2025-009 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance with reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University reviewed its awarding and reconciliation processes following the identified discrepancy between COD and the institutional ledger, which resulted from packaging based on an earlier ISIR transaction without confirming the most recent ISIR data. To address this, the University has partnered with FA Solutions and implemented enhanced controls within Regent, including system checks to flag updated ISIR information and require confirmation of the most current transaction prior to packaging.Additionally, reconciliations and related reporting provided by FA Solutions will be reviewed for accuracy and completeness. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026
2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are bei...
2025-008 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University should implement formal review procedures to document that the Cash Management reconciliation and drawdown reviews are being performed to correct errors in a timely manner and to minimize the likelihood of errors going undetected. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University performs cash management reconciliation and drawdown reviews; however, formal documentation of these reviews has not been consistently maintained. To address this, the University is implementing formal review procedures that include documented evidence of reconciliation and drawdown review activities. As part of this process, reconciliations and drawdowns prepared by FA Solutions will be reviewed by the Financial Aid Office for accuracy and completeness prior to submission and reporting. These procedures will be formalized within a standardized SOP, which will outline review timelines, responsibilities, and required documentation to ensure errors are identified and resolved in a timely manner and to reduce the risk of discrepancies going undetected. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 4/30/2026
2025-007 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance over stale checks that need to be returne...
2025-007 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University design controls to ensure an adequate review process is in place to ensure compliance over stale checks that need to be returned to the Department of Education after 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is implementing enhanced controls to ensure compliance with stale-dated Title IV credit balance checks. This includes establishing a monthly review process in coordination with Accounts Payable, Accounts Receivable, and the Financial Aid Office to identify any outstanding checks approaching or exceeding the 240-day threshold. As part of this process, a tracking mechanism will be maintained to monitor the status and issuance dates of all Title IV credit balance checks. The University will make reasonable efforts to contact students and reissue checks, as appropriate, to ensure funds are received. Any checks that remain uncashed and meet the stale-dated threshold will be voided and returned to the U.S. Department of Education in accordance with federal requirements. These procedures will be formalized within a standardized SOP to ensure consistent and timely compliance moving forward. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid, Accounts Receivable Clerk, and Accounts Payable Clerk Planned completion date for corrective action plan: 4/30/2026
2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are award...
2025-006 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review its current procedures for awarding Title IV funds and implement any changes necessary to ensure federal funds are awarded and disbursed in accordance with federal regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has conducted a review of its procedures for awarding Title IV funds, with particular attention to the awarding of Summer Pell. Through this review, we identified that Summer Pell was not awarded to eligible students during the applicable period, due in part to a misunderstanding of awarding requirements during a transition in third-party processing support. Urshan has since partnered with FA Solutions to strengthen oversight and ensure alignment with federal awarding requirements. Updated procedures have been implemented to ensure all eligible students are properly evaluated for Title IV aid, including Summer Pell, across all applicable terms. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 8/31/2026
2025-005 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit ...
2025-005 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has completed a comprehensive review and revision of its Written Information Security Program (WISP) to ensure alignment with all applicable requirements under the Gramm-Leach-Bliley Act (GLBA). While these updates were finalized after the end of FY25, the revised WISP now includes all required elements. The University has also received confirmation from the U.S. Department of Education’s Cybersecurity Compliance team that the updated program meets minimum GLBA compliance requirements. Moving forward, the University will maintain and periodically review its WISP to ensure ongoing compliance with federal standards. Name(s) of the contact person(s) responsible for corrective action: Dewayne Presson & Keith Braswell | Urshan IT Department Planned completion date for corrective action plan: 3/31/2026
2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation o...
2025-004 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend that the University review policies and procedures related to R2T4 calculations to ensure calculations are performed accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan has partnered with FA Solutions, an experienced third-party processor. Through this partnership, we have strengthened our processes and implemented additional checks and balances to ensure that R2T4 determinations are identified, calculated, and processed in a timely and compliant manner. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 3/31/2026
U.S. Department of Education 2025-003 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are...
U.S. Department of Education 2025-003 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal Pell Grant Program – Assistance Listing No. 84.063 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Urshan is currently in the onboarding process to partner with the National Student Clearinghouse, which will improve the timeliness and accuracy of our enrollment reporting to NSLDS. In addition, we are developing and implementing a standardized SOP that establishes defined reporting schedules (at least every 60 days), clearly outlines roles and responsibilities, and includes reconciliation procedures to ensure data accuracy. Name(s) of the contact person(s) responsible for corrective action: Levi Powell, Director of Financial Aid Planned completion date for corrective action plan: 7/31/2026
Finding 2025-003 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct...
Finding 2025-003 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct Grant Compliance Requirement: Special Tests and Provisions - Underwriting Requirements Audit Findings: Significant Deficiency Condition: The Consortium did not have a documented review control in place to ensure the underwriting calculation was prepared and calculated accurately. There was no documented proof of segregation of duties. Context: In a sample of two, one selection was noted where the underwriting calculation did not have evidence of preparer or reviewer. The selected underwriting calculation was prepared in April 2025. The Consortium implemented a control process in September 2025. The second sample tested had proper review and was completed in September 2025. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a system of internal controls to ensure the required underwriting calculations are prepared, reviewed, and maintained. Responsible Party and Timeline for Completion: The Consortium Director (or their designee) and the Federal Grant Administrator are responsible for implementation. The Consortium has implemented additional controls effective September 2025.
Finding 2025-002 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct...
Finding 2025-002 Information on the federal program: Subject: Home Investment Partnerships Program – Internal Controls Federal Agency: Department of Housing and Urban Development Federal Program: Home Investment Partnerships Program Assistance Listing Number: 14.239 Pass-Through Entity: N/A - Direct Grant Compliance Requirement: Special Tests and Provisions – Maximum Per Unit Subsidy Audit Findings: Material Weakness Condition: The Consortium did not have a documented review control in place to ensure the per-unit subsidy calculation was prepared and calculated accurately. There was no documented proof of segregation of duties. Context: In a sample of two, the following instances were noted: • For the first selection, the per-unit subsidy information was entered into the HUD system (IDIS) during the project close out. There is no evidence of segregation of duties over the preparation and review of IDIS inputs. • For the second selection, the calculation was prepared by a former employee in 2025 and did not have sign off by the preparer or reviewer. A secondary review with evidence of sign off was performed subsequent to the audit period in 2026. Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will implement a system of internal controls to ensure the required per unit subsidy calculations are prepared, reviewed, and maintained. Responsible Party and Timeline for Completion: The Consortium Director (or their designee) and the Federal Grant Administrator are responsible for implementation. The Consortium has implemented additional controls effective September 2026.
Planned Corrective Action: Management acknowledges the finding. The Council currently maintains comprehensive fiscal policies and procedures governing its financial operations and internal controls. Management will review its existing policies against the applicable Uniform Guidance requirements ide...
Planned Corrective Action: Management acknowledges the finding. The Council currently maintains comprehensive fiscal policies and procedures governing its financial operations and internal controls. Management will review its existing policies against the applicable Uniform Guidance requirements identified during the audit and, where necessary, supplement or clarify existing policies to expressly document federal award requirements. Any necessary revisions will be incorporated into the Council’s existing fiscal policy framework. The Council will review its existing fiscal policies and procedures against applicable Uniform Guidance requirements. Existing policies will be supplemented or clarified, where necessary, to expressly address federal award administration requirements identified during the audit, including allowable costs, cash management, procurement, and conflicts of interest. The Council will incorporate any necessary revisions into its existing fiscal policy framework and maintain the policies as part of its ongoing compliance processes. Anticipated Completion Date: December 31, 2026
Federal Award Agency: Department of Housing and Urban Development Name of Contact Person: Jennifer Carter, Voucher Programs Director Corrective Action: In order to ensure all units are properly scheduled for inspection within the required period; Vancouver Housing Authority will continue to pull mon...
Federal Award Agency: Department of Housing and Urban Development Name of Contact Person: Jennifer Carter, Voucher Programs Director Corrective Action: In order to ensure all units are properly scheduled for inspection within the required period; Vancouver Housing Authority will continue to pull monthly reports for inspections due. VHA will continue to schedule inspections for tenant-based voucher households every 18 months to ensure we meet the two-year period and will continue to run reports for “missed” inspections that do not have a completed inspection within the expected time period. VHA staff have implemented additional reporting to review the assigned inspection schedule on active units at least annually. VHA has updated internal compliance process to review inspection and unit specific requirements during a PBV to tenant-based property conversion. Date of Planned Corrective Action: The above process has been completed.
FINDING 2025-003 – LATE REPORTING Due to turnover in the CFO and CEO roles, there was delay in the compiling of records related to the audit. CPH has strengthened internal controls by hiring a contract CFO and controller as well as a senior accountant on staff. These roles will ensure compliance wit...
FINDING 2025-003 – LATE REPORTING Due to turnover in the CFO and CEO roles, there was delay in the compiling of records related to the audit. CPH has strengthened internal controls by hiring a contract CFO and controller as well as a senior accountant on staff. These roles will ensure compliance with Uniform Guidance audit reporting by implementing procedures to track submission deadlines, assigning responsibility for timely filing of the audit report and FAC Data Collection Form, and establishing management review processes to ensure compliance with Uniform Guidance reporting requirements.
FINDING 2025-002 – SLIDING SCALE FEES CPH is implementing more robust review process for information that is input into the billing system. This will include new, simplified forms for patients to complete for the sliding fee scale application and an enhanced review process including review of each a...
FINDING 2025-002 – SLIDING SCALE FEES CPH is implementing more robust review process for information that is input into the billing system. This will include new, simplified forms for patients to complete for the sliding fee scale application and an enhanced review process including review of each application within the first 30 days of initial application. Crystal Wolf, Revenue Cycle Director, will oversee this effort. The implementation of the new forms and the training to correct the finding is scheduled to be completed by December 31, 2026.
Finding 1229202 (2025-003)
Material Weakness 2025
The County Clerk has implemented a program to ensure knowledge and awareness of all federal monies being expended. The County Treasurer will set up accounts within our financial software to account for all transactions.
The County Clerk has implemented a program to ensure knowledge and awareness of all federal monies being expended. The County Treasurer will set up accounts within our financial software to account for all transactions.
Finding 2025-004 – Noncompliance – Reasonable rent rates documentation Name of Contact Person: George Czerwionka, Director of Finance Corrective Action: Management will maintain documentation for all rental agreements along with an analysis of its evaluation of the reasonableness of rental rates in ...
Finding 2025-004 – Noncompliance – Reasonable rent rates documentation Name of Contact Person: George Czerwionka, Director of Finance Corrective Action: Management will maintain documentation for all rental agreements along with an analysis of its evaluation of the reasonableness of rental rates in accordance with the Uniform Guidance. Proposed Completion Date: October 1, 2026
Finding 2025-003 – Noncompliance – Reporting (Repeat) Name of Contact Person: George Czerwionka, Director of Finance Corrective Action: Management understands the data collection was not submitted within nine months of June 30 year-end. Procedures will be implemented to make sure the audit is comple...
Finding 2025-003 – Noncompliance – Reporting (Repeat) Name of Contact Person: George Czerwionka, Director of Finance Corrective Action: Management understands the data collection was not submitted within nine months of June 30 year-end. Procedures will be implemented to make sure the audit is completed before the nine-month deadline. Data collections will then be uploaded to the federal clearing hours before the ninemonth deadline or within 30 days of the audit report being issued. Proposed Completion Date: March 31, 2027
Before reviewing and updating it Fiscal Policies, including its purchasing and procurement policies, All Nations Finance Director and CEO will ensure that finance staff, the Audit and Finance Committee, and its accounting partner know how to adhere to and have a thorough understanding of the importa...
Before reviewing and updating it Fiscal Policies, including its purchasing and procurement policies, All Nations Finance Director and CEO will ensure that finance staff, the Audit and Finance Committee, and its accounting partner know how to adhere to and have a thorough understanding of the importance of complying with its purchasing and procurement policies.
All Nations Health Center will identify appropriate resources and implement procedures needed for timely submission of the Single Audit report in the future.
All Nations Health Center will identify appropriate resources and implement procedures needed for timely submission of the Single Audit report in the future.
Policies and procedures for review of quarterly financial and performance reports will be followed on a consistent basis.
Policies and procedures for review of quarterly financial and performance reports will be followed on a consistent basis.
Policies and procedures for review of payroll will be followed on a consistent basis.
Policies and procedures for review of payroll will be followed on a consistent basis.
The findings from the December 31, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2025-001 - Cash Management - U.S. Department of Agri...
The findings from the December 31, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. FINDINGS - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS Finding 2025-001 - Cash Management - U.S. Department of Agriculture ({Assistance Listing Number 10.557, WIC Special Supplemental Nutrition Program for Women, Infants, and Children} Passed Through New York State Department of Health, Contract Number C38291GG - (Significant Deficiency) SJGNFICANT DEFICIENCY During our audit, we noted that there is no evidence of review of WIC vouchers submitted for payments. Recommendation We recommend that the Center implement a policy that requires all WIC voucher and supporting records to be reviewed and that such review be documented. Action Taken WIC vouchers and supporting documentation were reviewed and approved in accordance with BSFHC's established policy. However, the reviews were not documented, resulting in insufficient evidence to demonstrate that the required review had been performed. Going forward, Management will ensure that all WIC vouchers and supporting documentation are reviewed and that the review is documented through the reviewer's signature or initials. Management will monitor compliance with this requirement to ensure that documentation ofthe review is consistently maintained.
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