Corrective Action Plans

Finding 1161214 (2022-013)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Questioned Costs Allowable Costs / Cost Principles

Finding No.: 2022-013 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Questioned Costs: $1,828,733 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan:...

Finding No.: 2022-013 AL Program: 15.875 - Economic, Social, and Political Development of the Territories Area: Allowable Costs/Cost Principles Questioned Costs: $1,828,733 Contact Person(s): Epiphanio Cabrera, Jr., Grants Administrator, OGM-SC / Nerissa B. Karakaya, CIP COTR Corrective Action Plan: Condition 1 (E. Cabrera): The Office of Grant Management (OGM) respectfully disagrees with this finding. Due to internal scheduling constraints and the compressed timeline required to complete the FY22 audit, the requested documents were not submitted by the specified deadline, resulting in this finding. However, OGM maintain all relevant supporting documentation and is prepared to provide it upon request from the Grantor. Furthermore, based on our documentation, the Authority to Proceed (ATP) requirement was not fully communicated or operationalized with the relevant agencies until late 2021. During this period, the National Environmental Policy Act (NEPA) compliance processes were nascent for both OGM and the partner agencies, and subsequently required coordination with the U.S. Army Corps of Engineers for proper implementation. Given that these procedural requirements were still in the initial stages of establishment and integration, the CNMI Government should not be deemed liable for noncompliance with obligations that were not yet fully defined or operationalized. Proposed Completion Date: Ongoing Condition 2 (N. Karakaya): We respectfully disagree with this finding. Our office has obtained an Authorization to Proceed (ATP) for all projects funded by the Office of Insular Affairs under the 702 Capital Improvement Project (CIP) grants. It appears that supporting documents may not have been provided to the assigned auditor within the required timeframe; however, our office has maintained all ATPs associated with the projects listed in Condition 2. In addition, the Capital Improvement Program has implemented a process to include the Authorization to Proceed when routing contracts for projects procured through sealed bid procurement and sealed proposals. Corrective Action Plan: 1. Centralized Record Submission: - Designate a staff member responsible for ensuring that all ATP supporting documents are submitted to the auditors during scheduled audits. - Create a checklist to confirm that all required ATP documentation is included in audit packets. 2. Process Improvement: - Incorporate a mandatory step in the contract routing process to attach the Authorization to Proceed for all projects procured through sealed bid procurement and sealed proposals. - Update internal procedures to reflect this requirement. Training & Awareness: - Conduct a briefing for CIP staff on the importance of timely submission of ATP documentation to auditors. - Provide refresher training annually to ensure continued compliance. 4. Timeline for Implementation: - Checklist & Process Update: By October 15, 2025 - Staff Training: By October 31, 2025 Proposed Completion Date: December 31, 2025

View Audit 371187 Questioned Costs: $1

Finding 1161192 (2022-012)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Questioned Costs School Nutrition Programs Matching / Level of Effort / Earmarking

Finding No.: 2022-012 AL Programs: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $58,494 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1 & 2: CNMI NAP respectfully disagrees. Audit finding states that documentation supporting...

Finding No.: 2022-012 AL Programs: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Eligibility Questioned Costs: $58,494 Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: Condition 1 & 2: CNMI NAP respectfully disagrees. Audit finding states that documentation supporting eligibility determinations were not provided. Finding further states that CNMI NAP lacks monitoring control over the listing of validated eligibility roster data that were not uploaded into MAVEN eligibility system due to data entry capacity limitations (sic) were not being maintained; and Distributed coupons were not reconciled to the recorded expenditures for redeemed coupons. The resulting effect being that CNMI NAP is in noncompliance with the applicable eligibility requirements and questioned costs for condition 1. CNMI NAP was informed that this finding had been cleared so we are perplexed as to the re-emergence of this audit finding. CNMI NAP contends that: 1. Eligibility for P-EBT benefits is not determined by CNMI NAP. P-EBT eligibility was determined by identifying children who qualified for free or reduced-price school meals and then correlating that with a reduction of in-person schooling due to COVID-19. Children in households receiving SNAP and young children, under age six, were also eligible, provided their schools or childcare facilities closed or reduced hours for at least five consecutive days due to the pandemic. This data was provided by PSS, as well as the listing of eligible children that corresponded to this data set. 2. There are no “validated eligibility roster data case files” that were not uploaded into MAVEN due to data entry capacity limitations. All rosters provided by PSS were uploaded into MAVEN as this is the only way a case file can be generated in the system. 3. CNMI NAP has reconciled all benefits issued, including the P-EBT benefits for the audit year in question. This is a mandatory, non-negotiable process. Proposed Completion Date: Ongoing

View Audit 371187 Questioned Costs: $1

Finding 1161191 (2022-011)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Subrecipient Monitoring School Nutrition Programs Eligibility § 200.334

Finding No.: 2022-011 AL Program: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Activities Allowed or Unallowed Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: CNMI NAP respectfully disagrees with this finding. The April 2022 Compliance Supplem...

Finding No.: 2022-011 AL Program: 10.542 - Pandemic EBT Food Benefits (P-EBT) Area: Activities Allowed or Unallowed Questioned Costs: $-0- Contact Person(s): Margaret Aldan, NAP Administrator Corrective Action Plan: CNMI NAP respectfully disagrees with this finding. The April 2022 Compliance Supplement referenced by the auditor states: Special Tests and Provisions. 1. Verification of Free and Reduced-Price Applications (NSLP) Compliance Requirements: By November 15th of each school year, the LEA (or state in certain cases) must verify the current free and reduced-price eligibility of households selected from a sample of applications that it has approved for free and reduced-price meals, unless the LEA is otherwise exempt from the verification requirement. The verification sample size is based on the total number of approved applications on file on October 1st. A state agency may, with FNS approval, assume from LEAs under its jurisdiction the responsibility for performing the verifications. If the LEA performs the verification function it must be in accordance with instructions provided by the state agency. The LEA must follow up on children whose eligibility status has changed as the result of verification activities to put them in the correct category. CNMI NAP response: The 2022 Compliance Supplement states that the LEA, in this instance, PSS, is responsible for verifying the current free and reduced-price eligibility of households unless the LEA is exempt from the verification requirement. PSS is not exempt from the verification requirement and the CNMI NAP has never given instructions to PSS for data collection as it is the PSS’ responsibility to supply the data to NAP for P-EBT. NAP’s role is to distribute the benefits only. Similar to the SUN Bucks (S-EBT) program, PSS furnishes the student listing to NAP, after which NAP distributes the benefits according to the listing provided by PSS. Proposed Completion Date: Ongoing

View Audit 371187

Finding 1161190 (2022-010)

Material Weakness 2022

Commonwealth of the Northern Mariana Islands

MP

Procurement, Suspension & Debarment § 200.317

Finding No.: 2022-010 AL Program: 10.539 - CNMI Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: Unknown Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1 (G. Cruz): Th...

Finding No.: 2022-010 AL Program: 10.539 - CNMI Nutrition Assistance Program Area: Procurement and Suspension and Debarment Questioned Costs: Unknown Contact Person(s): Margaret Aldan, NAP Administrator / Geraldine Cruz, Procurement Services Director Corrective Action Plan: Condition 1 (G. Cruz): The Procurement Services Division agrees with this finding on behalf of CNMI NAP. The Division will revise CNMI’s procurement regulations to ensure alignment with federal procurement standards as outlined in 2 CFR Part 200, particularly the small purchase threshold requirements and competitive procurement procedures. Proposed Completion Date: Policy updates drafted by December 31, 2025 and adopted by March 31, 2026. Condition 2 (M. Aldan): The CNMI NAP agrees with this audit finding and that vendors were not being vetted using SAMS.gov. CNMI NAP has created and implemented an internal Standard Operating Procedure (SOP) to address this issue to ensure compliance. The SOP went into effect August 2025. A copy of the SOP can be provided upon request. Proposed Completion Date: Completed

View Audit 371187

Finding 1161131 (2022-005)

Material Weakness 2022

Pease Township

OH

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.302 § 200.303

Will have a policy for FEMA allowable expenditures in the future

View Audit 371132

Finding 1160958 (2022-002)

Material Weakness 2022

City of Easton

PA

Reporting

The City anticipates being able to complete the next audit timely which will lead to a timely submission of the data collection form.

View Audit 370988

Finding 1160584 (2022-002)

Material Weakness 2022

Summitview Child & Family Services

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.302

Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice a...

Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice and Payment Documentation: • All invoices related to the federal program will be promptly reviewed and approved by the appropriate personnel to ensure they reflect allowable costs under the specific terms and conditions of the award. • Management will establish clear procedures for the proper recording and classification of payments, ensuring that they are linked directly to the corresponding federal program expenses. • All supporting documentation (e.g., purchase orders, contracts, receipts) will be retained in electronic formats within the accounting system, in accordance with the Organization’s record retention policy, ensuring availability for future audits or reviews. Retention and Accessibility: • The Organization will maintain a secure, organized filing system for all invoices and payments, ensuring that each record is easily accessible for audit purposes. This system will include electronic records that are stored in a centralized database, with restricted access to authorized personnel. • Retained invoices and payment documentation will be kept for the full duration required by federal regulations, typically for a period of at least seven years after the final expenditure report for the federal award has been submitted, or as otherwise required by the specific federal agency. Periodic Reviews and Monitoring: • To ensure ongoing compliance, Management will perform periodic reviews of federal program expenditures and documentation. This will include random sampling of invoices and payment records to confirm that they are complete, accurate, and in compliance with federal regulations. • In the event of any discrepancies or issues identified during these reviews, Management will take immediate corrective action to address the issue and prevent recurrence. By maintaining thorough records of all invoices and payments, the Organization aims to not only comply with federal audit requirements but also to ensure transparency, accountability, and sound financial management of federal funds.

View Audit 370890 Questioned Costs: $1

Finding 1160576 (2022-002)

Material Weakness 2022

Town of Guilderland

NY

HUD Housing Programs Reporting

Finding Reference: 2022-002 Compliance with Reporting to Housing and Urban Development Description: The financial information submission was not submitted timely. Recommendation: The Town should follow federal guidelines by submitting the audited financial statement to HUD through the REAC submissio...

Finding Reference: 2022-002 Compliance with Reporting to Housing and Urban Development Description: The financial information submission was not submitted timely. Recommendation: The Town should follow federal guidelines by submitting the audited financial statement to HUD through the REAC submission in a timely manner. Corrective Action: The Town of Guilderland Comptroller’s Office suffered significant turnover in key positions during the fiscal years of 2019 and 2021 including the retirement of the Town Comptroller and Fiscal Officer. In addition, the COVID-19 pandemic had significant impact to the Town, particularly during 2020 when remote work was encouraged. This combination and sequence of events made it impossible to meet the required external audit reporting deadlines. Since these events, the Town has filed the vacant positions and has scheduled all remaining audits. The auditors are working as expeditiously as possible to complete the remaining audits. The Town receives an accepted audited REAC submission from HUD each year and has been submitting timely since 2022. Once the audited financial statements are caught up, they will be included in the REAC submission timely. Person(s) Responsible for Corrective Action: Darci Efaw, Comptroller & Jessica Gulliksen, Fiscal Officer Anticipated Completion Date for Corrective Action: The remaining audits that are left to become fully in compliance have been tentatively scheduled with the external auditors since 2022. The Town of Guilderland works as efficiently as possible with the auditors to complete these remaining audits.

View Audit 370881

Finding 1160575 (2022-001)

Material Weakness 2022

Town of Guilderland

NY

Reporting § 200.512 § 200.520

Finding Reference: 2022-001 Compliance with Reporting Under the Uniform Guidance Description: The data collection forms for the years 2019 through 2021 have not been submitted timely. Recommendation: The Town should follow federal guidelines by submitting the data collection form to the FAC in a tim...

Finding Reference: 2022-001 Compliance with Reporting Under the Uniform Guidance Description: The data collection forms for the years 2019 through 2021 have not been submitted timely. Recommendation: The Town should follow federal guidelines by submitting the data collection form to the FAC in a timely manner. Corrective Action: The Town of Guilderland Comptroller’s Office suffered significant turnover in key positions during the fiscal years of 2019 and 2021 including the retirement of the Town Comptroller and Fiscal Officer. The Town also implemented a new accounting software during 2018 that caused significant delays in the monthly and year-end reporting. Lastly, the COVID-19 pandemic had significant impact to the Town, particularly during 2020 when remote work was encouraged. This combination and sequence of events made it impossible to meet the required external audit reporting deadlines. Since these events, the Town has filed the vacant positions and has scheduled all remaining audits. The auditors are working as expeditiously as possible to complete the remaining audits. The required reporting noted in the guidelines above cannot be completed until each prior year audit is finished, therefore causing a delay in each fiscal year’s reporting. Person(s) Responsible for Corrective Action: Darci Efaw, Comptroller & Jessica Gulliksen, Fiscal Officer Anticipated Completion Date for Corrective Action: The data collection forms for years 2018 through 2022 have been filed. The remaining audits that are left to become fully in compliance have been tentatively scheduled with the external auditors since 2022. The Town of Guilderland works as efficiently as possible with the auditors to complete these remaining audits. The remaining data collection forms will be filed upon completion of the audits.

View Audit 370881

Finding 1160272 (2022-003)

Material Weakness 2022

Monroe County Commission

AL

Eligibility Special Tests & Provisions

Response/Views: The County Engineer and Assistant Engineer were declared eligible workers since they performed essential duties during the pandemic, as outlined in the January 2022 Overview of the Final Rule. These employees were discussed in various work sessions; however, they were not properly in...

Response/Views: The County Engineer and Assistant Engineer were declared eligible workers since they performed essential duties during the pandemic, as outlined in the January 2022 Overview of the Final Rule. These employees were discussed in various work sessions; however, they were not properly included in the resolution. Because the County was not a participant in IAC (Investing in Alabama Counties), we did not receive additional guidance. We elected not to pay 8 percent of ARPT funding ($4,027,142.00), which amounts to $322,171.36, to join. As a result, we were unable to obtain specific guidance from either the ACCA office or the Examiners' office on questions related to ARPT. We still have ARPT funds on hand. Corrective Action Planned: If our explanation does not fully satisfy this finding, the County is prepared to reimburse this expense from the General Fund to the ARPT fund account. The ARPT account still maintains a balance, and funds are available to be expended through December 31, 2026. It is important to note that the County received very limited guidance from both the ACCA office and the Examiners of Public Accounts personnel regarding this matter.

View Audit 370661

Finding 1160247 (2022-002)

Material Weakness 2022

Cheyenne-Eagle Butte Airport Association, Inc.

SD

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Finding 2022-002: Written Uniform Guidance Policies Responsible Individuals: Jeannie Walters, Finance Officer Corrective Action Plan: The Association will develop written Uniform Guidance policies. Anticipated Completion Date: December 31, 2025

View Audit 370631

Finding 1160244 (2022-001)

Material Weakness 2022

Cheyenne-Eagle Butte Airport Association, Inc.

SD

Reporting

Finding 2022-001: Uniform Guidance Audit Requirement Responsible Individuals: Jeannie Walters, Finance Officer Corrective Action Plan: The Association will work to complete future audits timely. Anticipated Completion Date: Future federal programs

View Audit 370631

Finding 1160200 (2022-016)

Material Weakness 2022

Fremont County School District No. 21

WY

Subrecipient Monitoring Reporting

Reporting – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However...

Reporting – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However, with other grants the processes have changed. Since FY2022 an accounting firm was hired to catch the school district up on grant requests. This accountant requested funds on a quarterly basis. On July 1, 2025, the District hired a Federal Grants Director to work with the Business Manager to complete the grant catch up process and to create a system that documents each expenditure and the timing of the requests. Once the system is in place cash requests will be completed monthly.

View Audit 370564

Finding 1160197 (2022-015)

Material Weakness 2022

Fremont County School District No. 21

WY

Questioned Costs Subrecipient Monitoring Reporting

Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going f...

Unsupported Expenditures – Education Stabilization Funds INDIVIDUAL RESPONSIBLE: Business Manager and Federal Grants Director ANTICIPATED COMPLETION DATE: FY2026 CORRECTIVE ACTION PLAN: At this point in time the ESSR funds are no longer available, so there will not be any other documentation going forward. However, with other grants the processes have changed. Since FY2022 an accounting firm was hired to catch the school district up on grant requests. This accountant requested funds on a quarterly basis. On July 1, 2025, the District hired a Federal Grants Director to work with the Business Manager to complete the grant catch up process and to create a system that documents each expenditure and the timing of the requests. Once the system is in place cash requests will be completed monthly.

View Audit 370564 Questioned Costs: $1

Finding 1160147 (2022-023)

Material Weakness 2022

College of the Marshall Islands

MH

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.334

Reporting: The College agrees with the finding. To address the repeat finding, the College will implement a standardized reporting check list and a calendar utilizing its Asana Project Management tool to track and monitor all required federal and grant deadlines.

View Audit 370531

Finding 1160144 (2022-022)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Procurement, Suspension & Debarment § 200.214 § 200.303 § 200.318 § 200.319 § 200.320

Procurement and Suspension and Debarment: The College agrees with the finding and takes note of the previous corrective actions that did not fully resolve the issue. The College will update its Purchasing and Accounts Payable Policy to require SAM.gov verification prior to awarding contracts. The Co...

Procurement and Suspension and Debarment: The College agrees with the finding and takes note of the previous corrective actions that did not fully resolve the issue. The College will update its Purchasing and Accounts Payable Policy to require SAM.gov verification prior to awarding contracts. The College will conduct mandatory procurement training to strengthen compliance with federal requirements.

View Audit 370531 Questioned Costs: $1

Finding 1160142 (2022-021)

Material Weakness 2022

College of the Marshall Islands

MH

Subrecipient Monitoring Cash Management § 200.303 § 200.305

Cash Management: The College agrees with the finding. To strengthen internal controls over cash management, the College will establish written guidelines that will clearly define timelines, responsibilities, and approval processes for drawdown and disbursements. The College will reconcile drawdowns ...

Cash Management: The College agrees with the finding. To strengthen internal controls over cash management, the College will establish written guidelines that will clearly define timelines, responsibilities, and approval processes for drawdown and disbursements. The College will reconcile drawdowns to expenditures on a monthly/quarterly basis.

View Audit 370531

Finding 1160139 (2022-020)

Material Weakness 2022

College of the Marshall Islands

MH

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher tra...

Allowable Costs/ Cost Principles: The College agrees with the finding. To address the repeat finding, the College will evaluate and strengthen internal controls by updating its policies/procedures addressing activities allowed or unallowed requirements. The College will conduct regular refresher training to ensure proper and full use and utilization of its document management system and all other College systems.

View Audit 370531

Finding 1160138 (2022-019)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Allowable Costs / Cost Principles Equipment & Real Property Management § 200.303

Activities Allowed or Unallowed/ Allowable Costs/Cost Principles: The College agrees with the finding. We take note previous corrective actions did not fully resolve the issue. The College will implement monthly/quarterly budget-to-actual reconciliations as a new agenda item during its monthly grant...

Activities Allowed or Unallowed/ Allowable Costs/Cost Principles: The College agrees with the finding. We take note previous corrective actions did not fully resolve the issue. The College will implement monthly/quarterly budget-to-actual reconciliations as a new agenda item during its monthly grant meetings. The College will enforce stricter oversight by the grants office to ensure compliance with allowable cost principles.

View Audit 370531 Questioned Costs: $1

Finding 1160136 (2022-018)

Material Weakness 2022

College of the Marshall Islands

MH

Subrecipient Monitoring Eligibility Reporting § 200.303

Reporting College of the Marshall Islands acknowledges the finding and agrees that both the Section II source data file of the Annual Performance Report (APR) and the required Final Performance Report could not be provided during the audit. This occurred due to inadequate internal controls and the l...

Reporting College of the Marshall Islands acknowledges the finding and agrees that both the Section II source data file of the Annual Performance Report (APR) and the required Final Performance Report could not be provided during the audit. This occurred due to inadequate internal controls and the limitations of the previous manual filing system, which led to incomplete retention and difficulty retrieving submitted reports during the audit fieldwork. To correct this, the College has upgraded and institutionalized a cloud-based filing system to ensure all source data files, APR submissions, and Final Performance Reports are properly stored, organized, and easily accessible. Internal control policies and procedures have been strengthened to require that all performance reports are submitted on time, with verified source data and confirmation of successful submission retained in the system. The TRIO Office has established a reporting calendar, supervisory review process, and digital archive protocol to ensure all APR and final reports are prepared, submitted, and properly retained. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to meet federal reporting requirements. Staff have been trained— and will continue to be trained twice a year—on performance reporting procedures and federal reporting standards to prevent recurrence of similar issues in future audits.

View Audit 370531

Finding 1160135 (2022-017)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Subrecipient Monitoring Eligibility § 200.303

Eligibility College of the Marshall Islands acknowledges the finding and agrees that several participant files lacked the required eligibility documentation, including proof of citizenship/residency, verification of academic support needed, documentation of age and grade level at initial selection, ...

Eligibility College of the Marshall Islands acknowledges the finding and agrees that several participant files lacked the required eligibility documentation, including proof of citizenship/residency, verification of academic support needed, documentation of age and grade level at initial selection, and confirmation of first-generation or low- income status. These gaps resulted from weak internal controls and the limitations of the previous manual filing system, which hindered proper tracking and retention of eligibility records during the audit fieldwork. To address these deficiencies, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, organized, and easily retrievable participant eligibility documentation. Internal control policies and procedures have been strengthened to require that all eligibility documents including citizenship/residency proof, age and grade verification, academic support need assessments, and first-generation/low-income eligibility forms—are obtained, reviewed, and approved before a student is enrolled and receives any program benefits or stipends. The TRIO Office has implemented a new eligibility checklist and supervisory review process to verify completeness and compliance for every participant file. With the upgraded systems and the support of newly hired skilled staff, the College is now better positioned to maintain accurate eligibility records. Staff have been trained and will continue to be trained twice a year on federal eligibility requirements and documentation standards to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160134 (2022-016)

Material Weakness 2022

College of the Marshall Islands

MH

Cash Management § 200.303 § 200.305

Cash Management College of the Marshall Islands acknowledges the finding and agrees that the absence of written cash management procedures and the lack of supporting expenditure listings for drawdowns created gaps in compliance with federal requirements. These issues stemmed from inadequate internal...

Cash Management College of the Marshall Islands acknowledges the finding and agrees that the absence of written cash management procedures and the lack of supporting expenditure listings for drawdowns created gaps in compliance with federal requirements. These issues stemmed from inadequate internal controls and the limitations of the previous manual filing system, which made it difficult to verify that drawdowns were fully supported by incurred expenditures during the audit fieldwork. To address this, the College has drafted new cash management policies and procedures in accordance with 2 CFR 200.305, which are now being circulated for review and approval. These policies will require maintaining detailed expenditure listings to support every reimbursement request and ensuring that funds are drawn only after related costs have been incurred. The College has also upgraded and institutionalized a cloud-based filing system to ensure complete documentation and easy retrieval of drawdown support records. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to comply with cash management requirements. Staff have been trained and will continue to be trained twice a year on federal cash management and documentation standards to prevent recurrence of similar issues in future audits.

View Audit 370531

Finding 1160133 (2022-015)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student m...

Allowable Costs/Cost Principle The College of the Marshall Islands acknowledges the finding and agrees that some payroll and non-payroll expenditures charged to the TRIO Upward Bound program lacked sufficient supporting documentation, including missing employment contracts, timesheets, and student meal listings, as well as discrepancies between paid hours/rates and approved documentation. These gaps arose primarily from inadequate internal controls and the limitations of the previous manual filing system, which hindered timely verification during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, organized, and easily accessible documentation for all program expenditures. Internal controls have been strengthened to require proper supporting documents including signed employment contracts, verified timesheets, approval for incentive and leave payments, and student listings—before any program costs are processed or reported. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure accuracy and compliance. Staff have been trained—and will continue to be trained twice a year—on federal cost principles and documentation standards to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160132 (2022-014)

Material Weakness 2022

College of the Marshall Islands

MH

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which ma...

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that the noted questioned costs arose from missing supporting documentation and employment contracts due to limitations in the previous manual filing system, which made timely retrieval difficult during the audit fieldwork. The College has since upgraded and institutionalized a cloud-based filing system to improve recordkeeping, accessibility, and documentation retention for all program expenditures. Internal controls have been strengthened to ensure that all stipends, salaries, and benefits charged to the TRIO Upward Bound program are fully supported by proper documentation, verified, and reviewed before payment and reporting. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to ensure compliance. Staff have been trained—and will continue to be trained twice a year—on federal grant cost principles and documentation requirements to prevent recurrence of similar issues in future audits.

View Audit 370531 Questioned Costs: $1

Finding 1160131 (2022-013)

Material Weakness 2022

College of the Marshall Islands

MH

Subrecipient Monitoring § 200.303

Reporting College of the Marshall Islands acknowledges the finding and agrees that there were deficiencies in the submission and reconciliation of required reports—including missing Form SG1 expenditure budget breakdowns, missing and delayed Form SG2 performance and financial evaluation reports, and...

Reporting College of the Marshall Islands acknowledges the finding and agrees that there were deficiencies in the submission and reconciliation of required reports—including missing Form SG1 expenditure budget breakdowns, missing and delayed Form SG2 performance and financial evaluation reports, and variances between the reported expenditures and the SEFA amounts. These issues primarily resulted from the limitations of the previous manual filing and reporting system, which hindered timely retrieval and review of supporting documents during the audit fieldwork. To address this, the College has upgraded and institutionalized a cloud-based filing and reporting system to ensure all supporting documents and reports are systematically organized, accessible, and securely retained. Internal controls have been strengthened to enforce timely preparation, review, and submission of required Form SG1 and SG2 reports, and to ensure accurate reconciliation of reported expenditures against SEFA. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain proper documentation and meet federal reporting requirements. In addition, staff have been trained and will continue to be trained twice a year on federal reporting standards and sub- award requirements to prevent similar issues from recurring in future audits.

View Audit 370531

Corrective Action Plans

Filters