Corrective Action Plans

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Finding 1168825 (2022-008)
Material Weakness 2022
Condition: The District has not retained transaction support for all expenditures related to federal programs. Auditor substantively tested 29 expenditures across all major programs noting that 10 items did not have proper supporting documentation. Criteria: 2 CFR 200.334. Cause of Condition: Record...
Condition: The District has not retained transaction support for all expenditures related to federal programs. Auditor substantively tested 29 expenditures across all major programs noting that 10 items did not have proper supporting documentation. Criteria: 2 CFR 200.334. Cause of Condition: Records retention procedures were not sufficient to ensure fiscal year 2022 transactions were retained through October 2025. Effect of Condition: Records supporting expenditures of federal awards were not located. Consequently, the auditors could not adequately test these items. Questioned Cost: $ 35,017.55 Recommendation: Draft and adopt policies and procedures to ensure compliance with record retention requirements. Corrective Action Plan: The District will adopt updated record retention policies. Procedures will require all supporting documentation for federal expenditures to be retained for a minimum of five years after final closeout, in both electronic and hard-copy form. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Finding 1168824 (2022-007)
Material Weakness 2022
Condition: The District has not adopted formal controls to detect and prevent unallowable costs from being charged to grant programs. Auditor substantively tested 29 expenditures, including indirect costs, across all major programs noting that all items tested were for allowable costs. Criteria: 2 C...
Condition: The District has not adopted formal controls to detect and prevent unallowable costs from being charged to grant programs. Auditor substantively tested 29 expenditures, including indirect costs, across all major programs noting that all items tested were for allowable costs. Criteria: 2 CFR 200.303(a). Cause of Condition: Unfamiliarity with requirements stated in 2 CFR 200 of the Uniform Guidance. Effect of Condition: Effect is a state of noncompliance which may impact future grant awards or failure to identify and reject un-allowed costs charged to grant programs. Questioned Costs: none. Recommendation: Draft and adopt policies and procedures to become compliant with Uniform Guidance.Corrective Action Plan: Agency policies and procedures, including a guidance template will be clearly defined to ensure compliance with Uniform Guidance. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Finding 1168823 (2022-006)
Material Weakness 2022
Condition: The District has not adopted written policies or procedures regarding procurements or the determination of allowable costs in accordance with the Uniform Guidance. Criteria: 2 CFR 200.302(b)(7), 2 CFR 200.318(a), and 2 CFR 200.319(d). Cause of Condition: Unfamiliarity with requirements st...
Condition: The District has not adopted written policies or procedures regarding procurements or the determination of allowable costs in accordance with the Uniform Guidance. Criteria: 2 CFR 200.302(b)(7), 2 CFR 200.318(a), and 2 CFR 200.319(d). Cause of Condition: Unfamiliarity with requirements stated in 2 CFR 200 of the Uniform Guidance.Effect of Condition: Effect is a state of noncompliance which may impact future grant awards or failure to identify and reject un-allowed costs charged to grant programs. Questioned Costs: none. Recommendation: Draft and adopt policies and procedures to become compliant with Uniform Guidance. Corrective Action Plan: Agency policies and procedures, including a guidance template will be clearly defined to ensure compliance with Uniform Guidance. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Finding 1168822 (2022-005)
Material Weakness 2022
Condition: 1- Gross payroll calculations could not be supported for several employees tested due to missing pay rate support. 2- Gross payroll calculations could not be supported for several employees tested due to missing timesheets. 3- Classification errors were noted in 2 of 11 periods tested (34...
Condition: 1- Gross payroll calculations could not be supported for several employees tested due to missing pay rate support. 2- Gross payroll calculations could not be supported for several employees tested due to missing timesheets. 3- Classification errors were noted in 2 of 11 periods tested (34 of 86 individuals tested). Criteria: Generally accepted control procedure and 2 CFR 200.302 Cause of Condition: Missing documentation resulted in conditions 1 and 2. The cause of the classification differences between the accounting department’s payroll worksheet and the general ledger postings are unknown. Due to staff turnover, the cause could not be determined. Effect of Condition: Employees may be paid at unapproved rates or for unworked time. Classification errors may result in over/under charging grant programs.Questioned Costs: Condition 1: Known: $ 412.54 Questioned: $ 5,580.24 Condition 2: Known: $ 20,357.31 Questioned: n/a Condition 3: Known: $ 91,593.05 Questioned: n/a Recommendation: We recommend: - Records be retained to support all transactions recorded to the general ledger. - Department managers review and approve all payroll-related source documents (personnel action forms, timesheets, etc.) prior to finalizing the payroll run. - Administrative manager review and approve payroll worksheet prior to finalizing the payroll run and posting to the general ledger. Corrective Action Plan: Beginning January 2025, the District strengthened payroll documentation and review procedures to ensure compliance with 2 CFR 200.302. Personnel Action Forms and timesheets will be required, approved by department managers, and retained electronically for all employees. The Administrative staff reviews and approves payroll worksheets prior to posting to the general ledger. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Finding 1168821 (2022-004)
Material Weakness 2022
Condition: Support for expenditure transactions does not indicate approval from an appropriate manager with authority over the department/program. Auditor tested 57 transactions of which 17 did not include evidence of approval (excluding routine expenditures such as utility bills). Criteria: General...
Condition: Support for expenditure transactions does not indicate approval from an appropriate manager with authority over the department/program. Auditor tested 57 transactions of which 17 did not include evidence of approval (excluding routine expenditures such as utility bills). Criteria: Generally accepted control procedures and 2 CFR 200.302. Cause of Condition: Initiating procurement transactions without proper approval or failing to document that approval was obtained prior to initiating the transaction. Effect of Condition: Unapproved charges, including potential unallowable costs, may be incurred and charged to the District, including federal or state programs. Additionally, the potential exists for fraud or errors to go undiscovered and uncorrected in a timely manner. Questioned Costs: none.Recommendation: We recommend that a purchase order or purchase requisition system be devised to ensure all expenditures, including those paid for by credit cards, are approved by an appropriate manager prior to making the purchase. Corrective Action Plan: Beginning January 2026, all purchases, including credit card transactions, will require Purchase approval by the Program Manager and administration prior to purchase. A Purchase Order tracking process will be implemented in Blackbaud Financial Edge NXT by April 2026 to ensure all expenditures are properly documented. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. The Financial Procedures Manual will be created and updated by June 2026 to include revised procurement approval requirements. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 06/01/2026
Finding 1168820 (2022-003)
Material Weakness 2022
Condition: Bank reconciliations are not always performed in the subsequent month. Bank reconciliations or copies of bank statements are not reviewed by anyone outside the accounting department. Criteria: Generally accepted control procedures. Cause of Condition: Bank reconciliations are not performe...
Condition: Bank reconciliations are not always performed in the subsequent month. Bank reconciliations or copies of bank statements are not reviewed by anyone outside the accounting department. Criteria: Generally accepted control procedures. Cause of Condition: Bank reconciliations are not performed in a timely manner (within subsequent month) and nonaccounting staff are not involved in control procedures surrounding the cash accounts.Effect of Condition: The potential exists for fraud or errors to go undiscovered and uncorrected in a timely manner. Questioned Costs: none. Recommendation: We recommend that bank reconciliations be performed in the subsequent month and also that bank statements (and possibly bank reconciliations) be reviewed by non-accounting staff (District Director and/or Board member). Corrective Action Plan: Beginning January 2026, all bank accounts will be reconciled within 15 business days of month-end. Completed reconciliations and corresponding bank statements will be reviewed and signed by the District Director, with quarterly oversight by the Board. All documentation will be stored electronically for audit verification. The Financial Procedures Manual will be created and updated to reflect these requirements and establish clear timelines and responsibilities for review. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Finding 1168819 (2022-002)
Material Weakness 2022
Condition: Capital assets are not tracked adequately for proper presentation in the financial statements. Criteria: GASB Code section 1400. Cause of Condition: Capital assets, as defined by the District’s capitalization policy, are not adequately tracked for presentation in the government-wide finan...
Condition: Capital assets are not tracked adequately for proper presentation in the financial statements. Criteria: GASB Code section 1400. Cause of Condition: Capital assets, as defined by the District’s capitalization policy, are not adequately tracked for presentation in the government-wide financial statements. Effect of Condition: The potential exists to overstate expenditures and understate capital assets in the government-wide statements. Questioned Costs: none. Recommendation: We recommend contemporaneously adding capital assets to a subledger for tracking which should include assigning a useful life to the asset. Additionally, we recommend scanning relevant expenditure accounts for uncapitalized expenditures. Corrective Action Plan: Capital assets will be added as invoices occur and added to a subledger for tracking which will include assigning a useful life to the asset. Additionally, relevant expenditure accounts for uncapitalized expenditures will be scanned. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
Finding 1168818 (2022-001)
Material Weakness 2022
Condition: The District’s accounts payable process does not have a procedure that clearly documents when and by whom the expenditure was authorized nor does the process include cut-off procedures to apply the expenditure to the proper period. Criteria: Controls should be in place to ensure that expe...
Condition: The District’s accounts payable process does not have a procedure that clearly documents when and by whom the expenditure was authorized nor does the process include cut-off procedures to apply the expenditure to the proper period. Criteria: Controls should be in place to ensure that expenses are recorded in the period in which the expenses are incurred and to ensure that staff with the appropriate level of authority approves the transaction. 2 CFR 200.302. Cause of Condition: Procurement transactions are initiated by several individuals within the District at times without review and approval by a District or program supervisor. Procurement transactions are not entered into the account system with the date the liability was incurred. Effect of Condition: Expenditures could be processed and paid without proper authorization and posted to an improper period. Questioned Costs: none. Recommendation: Develop procedures to ensure purchases are authorized prior to recording and paying the invoice. The procedures may include development of lines of authority whereby an individual is approved to authorize purchases up to a particular dollar threshold and require that all invoices/documentation be signed/initialed by authorized approver. Accounts payable process should include cutoff procedures to ensure expenditure is recorded in period that liability is incurred. Corrective Action Plan: Policies and procedures will be clearly defined both administratively and within each department to ensure purchases are authorized prior to recording and paying the invoice. The procedures will include development of lines of authority for approval and to authorize purchases, including up to a particular dollar threshold where applicable. The procedures will also require that all invoices/documentation, purchase order forms and packing slips be signed/initialed by authorized approver. Accounts payable process will include cutoff procedures to ensure expenditure is recorded in period that liability is incurred. All department managers and administrative staff will attend training and routine follow-up training on purchasing policies and procedures. A sign in sheet will be required for those attending. Contact Person: Grant Accounting Specialist Anticipated Completion Date: 01/31/2026
U.S. Department of Treasury - Coronavirus State and Local Fiscal Recovery Effort Recommendation: We recommend the County review federal guidelines to ensure that reports are identified to allow proper and timely submission. Explanation of disagreement with audit finding: There is no disagreement wit...
U.S. Department of Treasury - Coronavirus State and Local Fiscal Recovery Effort Recommendation: We recommend the County review federal guidelines to ensure that reports are identified to allow proper and timely submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County agrees and is developing a process to ensure reports are prepared and submitted. Name(s) of the contact person(s) responsible for corrective action: Donna Hillis, County Clerk Planned completion date for corrective action plan: December 31, 2025
Finding 2022 – 005: Reporting – Late Data Collection Form Submission Response: For the audit period and subsequent audit periods the District will not be in compliance with this finding until the FY 2022-23, FY 2023-24 and FY 2024-25 audits are completed.
Finding 2022 – 005: Reporting – Late Data Collection Form Submission Response: For the audit period and subsequent audit periods the District will not be in compliance with this finding until the FY 2022-23, FY 2023-24 and FY 2024-25 audits are completed.
Finding 2022-004: Activities Allowed and Unallowed, Allowable Costs (Compliance; Internal Controls Over Compliance) Response: For the audit period and subsequent audit periods (FY 2022-23 and partial 2023-24) The District will not be in compliance with this finding as duties were completed by one em...
Finding 2022-004: Activities Allowed and Unallowed, Allowable Costs (Compliance; Internal Controls Over Compliance) Response: For the audit period and subsequent audit periods (FY 2022-23 and partial 2023-24) The District will not be in compliance with this finding as duties were completed by one employee (accounts payable, payroll, balancing) and many records are not able to be located. For partial 2023-24 and 2024-25 records are now fully maintained and should be accessible for audit review. Training has been provided by the District’s Financial Consultant (payroll and accounts payable). The District Financial Consultant is reviewing payroll, processing tax and retirement payments, reviewing AP and correcting coding when necessary. The Consultant is also balancing reports and submitting monthly financial reports to the Board of Trustees.
Finding 2022 – 003: Reporting: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Response: For the audit period and subsequent audit periods the employee responsible for the SEFA did not prepare the SEFA for the audit. For future audit periods the SEFA will be prepared by the Fina...
Finding 2022 – 003: Reporting: Preparation of the Schedule of Expenditures of Federal Awards (SEFA) Response: For the audit period and subsequent audit periods the employee responsible for the SEFA did not prepare the SEFA for the audit. For future audit periods the SEFA will be prepared by the Financial Consultant.
Views of responsible officials: Before the approval of budget and the contract petition, the Chief Financial Officer will verify if the vendors are excluded as an authorized Federal contractor. The Company will establish a formal procedure to ensure that all vendors for federal funds are verified ag...
Views of responsible officials: Before the approval of budget and the contract petition, the Chief Financial Officer will verify if the vendors are excluded as an authorized Federal contractor. The Company will establish a formal procedure to ensure that all vendors for federal funds are verified against the excluded list at least once a year. This verification process will ensure compliance with federal regulations and avoid engaging with vendors who may be suspended or debarred. Additionally, this procedure will be recommended to be included in the review process for quotes or bidding requirements, further enhancing the Company’s ability to comply with federal regulations and maintain responsible vendor relationships.
Views of responsible officials: The Company will establish a clear and organized calendar for the submission of all required reports. This calendar will serve as a reference to ensure that all deadlines are met, helping to improve overall efficiency. By outlining specific dates for each report will ...
Views of responsible officials: The Company will establish a clear and organized calendar for the submission of all required reports. This calendar will serve as a reference to ensure that all deadlines are met, helping to improve overall efficiency. By outlining specific dates for each report will avoid delays and ensure that all required reports and documentation are submitted on time, contributing to a more effective report delivery process.
The Chief Financial Officer (CFO) is responsible for this task. The overview includes reviewing and submitting the information and data collected during the month. To ensure timely compliance, the CFO has implemented a shared calendar system with the administrative personnel that establishes clear d...
The Chief Financial Officer (CFO) is responsible for this task. The overview includes reviewing and submitting the information and data collected during the month. To ensure timely compliance, the CFO has implemented a shared calendar system with the administrative personnel that establishes clear deadlines and reminders to prevent delays and improve efficiency, ensuring all submissions are received within the required timeframe. In addition to timeliness, the CFO will implement enhanced internal controls and quality assurance measures to guarantee that all data submitted is accurate, complete, and in full compliance with federal reporting requirements. This process will include: • Conducting a pre-submission review of all documents by the finance and compliance team to verify accuracy and consistency. • Establish a checklist of federal regulatory requirements to be applied before final submission of reporting packages. • Assigning a secondary reviewer independent of the preparer to ensure an additional level of oversight. • Documenting all reviews and approvals to create an audit trail that supports transparency and accountability. • Holding monthly coordination meetings with responsible personnel to address potential delays, clarify requirements, and provide corrective guidance in real time. By combining timely submission mechanisms with strengthened review and compliance controls, the CFO ensures that reporting packages meet the highest standards of accuracy, reliability, and federal regulatory compliance.
Corrective action: Management has implemented internal controls over compliance in place to assist with the timely preparation of the SEFA.
Corrective action: Management has implemented internal controls over compliance in place to assist with the timely preparation of the SEFA.
Corrective action: Management understands the due date for single audit reporting package submission to the Federal Audit Clearinghouse and filed as soon as possible
Corrective action: Management understands the due date for single audit reporting package submission to the Federal Audit Clearinghouse and filed as soon as possible
All required PRF reporting has been submitted. Will comply should new or additional reporting requirements be added in the future.
All required PRF reporting has been submitted. Will comply should new or additional reporting requirements be added in the future.
Management will enforce existing internal control procedures and train staff to maintain appropriate documentation.
Management will enforce existing internal control procedures and train staff to maintain appropriate documentation.
The audits are currently in progress sequentially by fiscal year.
The audits are currently in progress sequentially by fiscal year.
Date: 12/11/2025 Re: Corrective Action Plan - Audit Finding 2022-03 - Improve controls and documentation over allowability of costs Planned Corrective Action: The District will strengthen internal controls over allowability by implementing an allowability verification checklist, requiring documented...
Date: 12/11/2025 Re: Corrective Action Plan - Audit Finding 2022-03 - Improve controls and documentation over allowability of costs Planned Corrective Action: The District will strengthen internal controls over allowability by implementing an allowability verification checklist, requiring documented approval for all grant-funded purchases, and maintaining adequate supporting documentation. Time and effort reporting processes will be reinforced. Grant monitoring procedures will include periodic allowability reviews. Planned Implementation Date of Corrective Action: Already following corrective action Person Responsible for Corrective Action: Lisa Gibbons; Director of Finance & Operations ___Lisa Gibbons__________________________ Signature Ms. Emilys Peña Assistant Superintendent Dr. Deanne Galdston Superintendent of Schools Ms. Lisa Gibbons Director of Finance and Operations Dr. Ceronne Daly Director of Diversity, Equity, Inclusion, and Belonging Dr. Kathleen Desmarais Director of Student Services Ms. Amanda Owens Director of Human Resources
Re: Corrective Action Plan - Audit Finding 2022-02 - Improve Controls and Documentation over Payroll Planned Corrective Action: The District will enhance payroll documentation controls by standardizing processes for verifying pay rates, retaining payroll support documents, and documenting/approving ...
Re: Corrective Action Plan - Audit Finding 2022-02 - Improve Controls and Documentation over Payroll Planned Corrective Action: The District will enhance payroll documentation controls by standardizing processes for verifying pay rates, retaining payroll support documents, and documenting/approving transfers and allocations. Cross-department procedures between Payroll, HR, and Business Office will be formalized. Staff involved in payroll and federal grants will receive training. Planned Implementation Date of Corrective Action: Already following corrective action Person Responsible for Corrective Action: Lisa Gibbons; Director of Finance & Operations ___Lisa Gibbons__________________________ Signature Ms. Emilys Peña Assistant Superintendent Dr. Deanne Galdston Superintendent of Schools Ms. Lisa Gibbons Director of Finance and Operations Dr. Ceronne Daly Director of Diversity, Equity, Inclusion, and Belonging Dr. Kathleen Desmarais Director of Student Services Ms. Amanda Owens Director of Human Resources
Re: Corrective Action Plan - Audit Finding 2022-01 -Documentation of Policies and Procedures over Federal Awards Planned Corrective Action: The District will develop and formally adopt comprehensive written policies and procedures compliant with 2 CFR Part 200, including allowability of costs, procu...
Re: Corrective Action Plan - Audit Finding 2022-01 -Documentation of Policies and Procedures over Federal Awards Planned Corrective Action: The District will develop and formally adopt comprehensive written policies and procedures compliant with 2 CFR Part 200, including allowability of costs, procurement, conflicts of interest, cash management, travel, time and effort, inventory management, and record retention. All procedures will be consolidated into a Federal Grants Procedures Manual, approved by leadership, and reviewed annually. Relevant staff will receive training. Planned Implementation Date of Corrective Action: Already following corrective action Person Responsible for Corrective Action: Lisa Gibbons; Director of Finance & Operations ___Lisa Gibbons__________________________ Signature
Re: Corrective Action Plan - Audit Finding 2022-04 - Improve procurement procedures Planned Corrective Action: The District will update procurement procedures to align fully with Uniform Guidance and Massachusetts procurement law. Documentation requirements (quotes, bids, verification,justification ...
Re: Corrective Action Plan - Audit Finding 2022-04 - Improve procurement procedures Planned Corrective Action: The District will update procurement procedures to align fully with Uniform Guidance and Massachusetts procurement law. Documentation requirements (quotes, bids, verification,justification forms) will be standardized and retained. Staff will receive procurement training, and periodic procurement compliance reviews will be instituted. Planned Implementation Date of Corrective Action: Already following corrective action Person Responsible for Corrective Action: Lisa Gibbons; Director of Finance & Operations ___Lisa Gibbons__________________________ Signature Ms. Emilys Peña Assistant Superintendent Dr. Deanne Galdston Superintendent of Schools Ms. Lisa Gibbons Director of Finance and Operations Dr. Ceronne Daly Director of Diversity, Equity, Inclusion, and Belonging Dr. Kathleen Desmarais Director of Student Services Ms. Amanda Owens Director of Human Resources
Due to a disagreement in the balance of taxes owed in 2022, Guardian’s and its payroll processor have been going back and forth to resolve the matter. We have also written to the IRS and are awaiting a response. Our back-and-forth efforts with our payroll processor have provided no resolution and th...
Due to a disagreement in the balance of taxes owed in 2022, Guardian’s and its payroll processor have been going back and forth to resolve the matter. We have also written to the IRS and are awaiting a response. Our back-and-forth efforts with our payroll processor have provided no resolution and they have passed our case to different managers, each of which has to get up to speed about the case. In the meantime, we have set aside an account with the funds to pay the liability, in full, once the issue is resolved.
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