Corrective Action Plans

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Finding 2022-04 Failure to Establish Documented Procurement Policy Condition: The Organization failed to have a formal, documented procurement policy. There was no written policy in place that detailed the steps to be followed for procurement processes, including requirements for soliciting bids o...
Finding 2022-04 Failure to Establish Documented Procurement Policy Condition: The Organization failed to have a formal, documented procurement policy. There was no written policy in place that detailed the steps to be followed for procurement processes, including requirements for soliciting bids or proposals, evaluating vendor qualifications, selecting vendors, and ensuring compliance with relevant laws and regulations. A comprehensive procurement policy is a crucial internal control mechanism that governs the acquisition of goods and services. This deficiency indicates a gap in the organization's internal controls and compliance framework, potentially leading to increased risks related to procurement activities. Corrective Actions Taken or Planned: The Organization?s Board and Executive Team consisting of the CEO and COO acknowledge the finding related to a procurement policy. In 2023 the Organization adopted a comprehensive procurement policy in line with federal regulations and GAAP.
Finding 2022-03 Expenditure of Funds Outside Contract Period Condition: In the course of testing direct disbursements for adherence to appropriate cutoffs concerning the contract's period of performance, it was discovered that the Organization incurred a substantial amount of expenditures on contr...
Finding 2022-03 Expenditure of Funds Outside Contract Period Condition: In the course of testing direct disbursements for adherence to appropriate cutoffs concerning the contract's period of performance, it was discovered that the Organization incurred a substantial amount of expenditures on contracts prior to the official contract start date. These disbursements took place without acquiring proper authorization for making disbursements prior to the contract's commencement. Despite the unique nature of Naloxone inventory being treated as a prepaid asset due to its delayed usage, the majority, if not all, of the Naloxone units were fully expended before the contract officially commenced. Corrective Actions Taken or Planned: The Organization?s Board and Executive Team consisting of the CEO and the COO acknowledge the finding of expending funds outside the contract period. This finding is connected to the purchase of the emergency medication naloxone. The Organization decided to purchase with no assurance of reimbursement in order to eliminate the lack of emergency medication in an overdose epidemic. The Organization had verbal approval but did not secure approval in writing. Numerous policies will be adopted in 2023 to ensure this does not occur again. Some of these policies include the transition to an experienced nonprofit bookkeeper, training for Finance and Grants Management and tracking mechanisms, monthly grants tracking meetings to ensure inventory and spending, and the adoption of a clear and documented approval process should spending, outside a contract period, be required.
View Audit 261078 Questioned Costs: $1
Finding 2022-02 Schedule of Expenditures of Federal Awards Presentation Condition: During the audit, it was identified that the Organization encountered deficiencies in preparing an accurate and complete Schedule of Expenditures of Federal Awards (?SEFA?). The SEFA is a critical component of the or...
Finding 2022-02 Schedule of Expenditures of Federal Awards Presentation Condition: During the audit, it was identified that the Organization encountered deficiencies in preparing an accurate and complete Schedule of Expenditures of Federal Awards (?SEFA?). The SEFA is a critical component of the organization's reporting process, as it provides a summary of federal funds expended and aids in assessing compliance with federal regulations. The organization's failure to ensure the accuracy and completeness of the SEFA indicates shortcomings in its reporting practices. It was observed that the SEFA presented inaccuracies and omissions, compromising the completeness and reliability of reported information. The SEFA did not accurately reflect all federal awards received and expended during the audit period, and relevant details such as award numbers, funding sources, and program titles were either missing or misstated. These deficiencies reflect a lack of adherence to reporting requirements. Corrective Actions Taken or Planned: The Organization?s Board and Executive Team consisting of the CEO and the COO acknowledge the finding related to the preparation of the SEFA. Leadership is confident the addition of a staff person dedicated to grants management will ensure the proper tracking of federal awards and reporting for preparation of the SEFA in future audits. The new Grants Manager will be acquiring training and knowledge to develop an appropriate tracking mechanism.
Finding 2022-01 Financial Close Process Condition: The auditors noted a lack of a strong financial close process which led to several material audit adjustments that were proposed during the audit and recorded by the client to properly reflect various financial statement accounts. Corrective Acti...
Finding 2022-01 Financial Close Process Condition: The auditors noted a lack of a strong financial close process which led to several material audit adjustments that were proposed during the audit and recorded by the client to properly reflect various financial statement accounts. Corrective Actions Taken or Planned: The Organization?s Board and Executive Team consisting of the Chief Executive Officer (?CEO?) and the Chief Operating Officer (?COO?) recognize the existence of gaps in the financial accounting practices at the organization during the year ending 2022. A transition occurred between independent bookkeepers during this year causing these discrepancies. The Executive Team recognized the need to hire staff and put new policies and processes in place. The Organization began this process in October of 2022 with the hiring of a Finance Manager. Additionally, a transition occurred in the first quarter of 2023 to a new independent bookkeeper with strong training in nonprofit accounting. The Organization will adopt all GAAP nonprofit accounting practices in 2023. New processes have been adopted to reconcile the financial statements weekly. The Finance Manager and Bookkeeper meet weekly for additional oversight. Balance sheet accounts are reconciled monthly and presented to the COO and Board Treasurer.
CORRECTIVE ACTION PLAN Finding 2022-001 Information on the Federal Program: Assistance Listing Number 93.600-Head Start Program, United States Department of Health and Human Services. Pass- Through Entity: the City and County of Denver and Mile High Early Learning. Award Number: MOEAI202158316, MO...
CORRECTIVE ACTION PLAN Finding 2022-001 Information on the Federal Program: Assistance Listing Number 93.600-Head Start Program, United States Department of Health and Human Services. Pass- Through Entity: the City and County of Denver and Mile High Early Learning. Award Number: MOEAI202158316, MOEAI-202158627, 08HP000174-03. Compliance Requirements: Allowable Costs Type of Finding: Material Noncompliance and Significant Deficiency Planned Corrective Action: Management at Sewall Child Development Center has been relying on a manual system of time tracking across our programs. Given the complexities of our various blended funding sources, we agree that we need an improved tracking system with better automation of payroll and the time tracking process. This is especially true with the demands on our staff with the coordination of multiple grants. The review of automated systems is in process. Name of Contact Person: Heidi Heissenbuttel, CEO/President Anticipated Completion Date: We anticipate doing a review of payroll companies by May 2023 to have a new system in place by the new fiscal year, July 2023. Meanwhile, there will be greater supervision of time sheet allocations, implemented immediately.
2022-007 Significant Deficiency in Controls over Compliance and Compliance Finding: Double Reporting of Student Counts. Effective January 2022, the Business Manager now reviews all count sheets and ties the counts to the summary report used to submit claims prior to submittal for reimbursement. She...
2022-007 Significant Deficiency in Controls over Compliance and Compliance Finding: Double Reporting of Student Counts. Effective January 2022, the Business Manager now reviews all count sheets and ties the counts to the summary report used to submit claims prior to submittal for reimbursement. She did not, however, review the actual claims before submittal and discovered after-the-fact that these duplicate counts had occurred. The review procedures were immediately changed to include reviewing the actual claim submittal before the Food Manager certifies their claims.
View Audit 261067 Questioned Costs: $1
2022-006 Significant Deficiency in Controls over Compliance and Compliance Finding: Reporting We are currently working on a tracking system and are in the process of increasing the number of staff who are authorized to file claims.
2022-006 Significant Deficiency in Controls over Compliance and Compliance Finding: Reporting We are currently working on a tracking system and are in the process of increasing the number of staff who are authorized to file claims.
2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.
2022-005 Significant Deficiency in Controls over Compliance: Administrative Requirements of Uniform Guidance-Administrative Policies The schools have documented their administrative policies effective 3/1/2023.
2022-004 Material Weakness in Controls over Compliance: Activities Allowed or Unallowed We agree with the recommendations and have made improvements to our procedures. The schools were not prepared for the rapid expansion of the food program, not only at our two high schools, but our partner schoo...
2022-004 Material Weakness in Controls over Compliance: Activities Allowed or Unallowed We agree with the recommendations and have made improvements to our procedures. The schools were not prepared for the rapid expansion of the food program, not only at our two high schools, but our partner schools' which requested contracted breakfast/lunch food services for their students as well. This unprecedented growth coupled with supply chain issues from food wholesalers, and shortage of employees in the hiring pool, only exacerbated our issues. The audit sample showed a large error rate for one of the schools. We have gone through the entire year for the school(s) individual count sheets. In the event the Michigan Department of Education determines that the identified discrepancies warrant a repayment we have recorded an allowance in the financial statements for the year ended June 30, 2021. Staff were not properly trained in how to complete the count sheets; however, supervisors did not take the time once they saw there was a problem due to everyone trying to simply get the meals served to the children. In addition, there was a lack of oversight of the Food Service Manager by her direct supervisor. At the time of the 2021 audit, when the issue was brought to our attention, we developed new procedures. School staff performing counts have been trained in how to properly complete the count sheets. The Business Manager now reviews all count sheets and ties counts to the summary report used to submit claims prior to submittal for reimbursement. Given that training and implementation of procedures did not fully occur until January 2022, there are errors in counts prior to implementation of the procedures and repeat findings in fiscal year 2021-22. In addition, with the end of the pandemic, beginning with the 2022-23 school year, the schools were able to resume using electronic software to accurately capture the meal counts.
View Audit 261067 Questioned Costs: $1
WAGE RATE REQUIREMENTS Name of contact person: Laurie Hickethier Corrective Action: In the future, the District will put steps in place to ensure all projects funded with federal money that will be over the $2,000 limit will require the company hired to supply the district business manager with a ...
WAGE RATE REQUIREMENTS Name of contact person: Laurie Hickethier Corrective Action: In the future, the District will put steps in place to ensure all projects funded with federal money that will be over the $2,000 limit will require the company hired to supply the district business manager with a certified copy of their payroll for the job done. The district business manager will verify that the wages paid are for the contract no less than the locally prevailing wage for the corresponding work on similar projects in the area. Proposed Completion Date: Immediately
AUDITOR PREPARED FINANCIAL STATEMENTS Name of contact person: Laurie Hickethier Corrective Action: Elysian School does not have the resources in time or money to comply with sending a district representative to school on a periodic basis to keep up with the regulations required to prepare annual f...
AUDITOR PREPARED FINANCIAL STATEMENTS Name of contact person: Laurie Hickethier Corrective Action: Elysian School does not have the resources in time or money to comply with sending a district representative to school on a periodic basis to keep up with the regulations required to prepare annual financial statements and notes to the financial statements. There is a significant cost involved in annual training and also significant time involved in preparing the annual financial statements and notes to the financial statements. The District believes the cost would outweigh the benefits of preparing the annual financial statements and notes to the financial statements. The draft financial statements are read to ensure the quality of the document and the preparer.
SEGREGATION OF DUTIES Name of Contact Person: Laurie Hickethier Corrective Action: Elysian School has numerous compensating controls in place to help prevent mistakes or fraud. The District could always do more to segregate duties, but this would require additional personnel. The District believ...
SEGREGATION OF DUTIES Name of Contact Person: Laurie Hickethier Corrective Action: Elysian School has numerous compensating controls in place to help prevent mistakes or fraud. The District could always do more to segregate duties, but this would require additional personnel. The District believes the costs of the additional personnel would outweigh the benefits to provide perfect segregation of duties. Many steps have been recommended in the past by auditors and all those steps have been taken to ensure proper segregation of duties with our current personnel. Proposed Completion Date: Immediately
Legal Name: Housing and Community, Inc. Audit Firm: CohnReznick Period covered by the audit: January 1, 2022 ? December 31, 2022 Corrective Action Plan prepared by: Name: James Butcher Position: SVP of Finance & Accounting Telephone Number: 210-821-4392 1. Current Findings on the Schedule...
Legal Name: Housing and Community, Inc. Audit Firm: CohnReznick Period covered by the audit: January 1, 2022 ? December 31, 2022 Corrective Action Plan prepared by: Name: James Butcher Position: SVP of Finance & Accounting Telephone Number: 210-821-4392 1. Current Findings on the Schedule of Findings and Questioned Costs 2. Finding 2022-001 a. Comments on the Finding and Each Recommendation Management did not certify income through the EIV system as part of the initial certification procedures for new tenants. b. Action(s) Taken or Planned on the Finding The management company is highly aware of the importance surrounding the EIV information and timeline of when these reports need to be pulled for documentation and review. We will make sure to provide additional training to ensure we remain in compliance going forward. We have also mandated manager reminders be put in place every time new tenants move in, ensuring the EIV be pulled within 90 days and 120 days prior to annual recertifications being performed for existing tenants. Management has also reviewed this proposed resolution with the Southwest Housing Corporation, the area HUD representative, and they have approved the aforementioned proposed resolution.
AUDITOR PREPARED FINANCIAL STATEMENTS Name of contact person: Julie Copeman Corrective Action: The board will consider requesting quotes from third-party persons to evaluate the prepared financial statements. At this time, our Board of Trustees has decided not to hire a third-party to review the D...
AUDITOR PREPARED FINANCIAL STATEMENTS Name of contact person: Julie Copeman Corrective Action: The board will consider requesting quotes from third-party persons to evaluate the prepared financial statements. At this time, our Board of Trustees has decided not to hire a third-party to review the District?s financial statements. The board and district administration will continue to review the annual financial statements to evaluate the quality of the document and the preparer. Proposed Completion Date: Immediately.
Finding Number: 2022-015 ? Cash Management Corrective Action Plan: A process has been put in place for the school principal to review all RFRs prior to submission to the grantor. Approval is evidenced by email sent by principal to the Director of Grant Management, which is saved with the RFR as supp...
Finding Number: 2022-015 ? Cash Management Corrective Action Plan: A process has been put in place for the school principal to review all RFRs prior to submission to the grantor. Approval is evidenced by email sent by principal to the Director of Grant Management, which is saved with the RFR as support. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023
Finding Number: 2022-017 ? SEFA Preparation Corrective Action Plan: In 2022, the office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to verify accuracy of the residual value calculations. To strengthen the oversight of fin...
Finding Number: 2022-017 ? SEFA Preparation Corrective Action Plan: In 2022, the office had downsized due to turnover in staff. While a process was in place for reconciling, a secondary review was not performed to verify accuracy of the residual value calculations. To strengthen the oversight of financial management in the School, Academica Nevada, the School?s management company, has filled all the open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. The grant manager will reconcile all grants to ensure proper cutoff, with a secondary review performed by a member of management. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023
Finding Number: 2022-016 ? Procurement, Suspension, and Debarment Corrective Action Plan: Academica Nevada, the School?s management company, and the School will complete an update of the procurement policies to ensure that federal law and standards are clearly detailed and defined. Responsible Indiv...
Finding Number: 2022-016 ? Procurement, Suspension, and Debarment Corrective Action Plan: Academica Nevada, the School?s management company, and the School will complete an update of the procurement policies to ensure that federal law and standards are clearly detailed and defined. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023
Finding Number: 2022-014 ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Action Plan: A process has been put in place for the school principal to review all RFRs prior to submission to the grantor. Approval is evidenced by email sent by principal to the Director of G...
Finding Number: 2022-014 ? Activities Allowed or Unallowed and Allowable Costs/Cost Principles Corrective Action Plan: A process has been put in place for the school principal to review all RFRs prior to submission to the grantor. Approval is evidenced by email sent by principal to the Director of Grant Management, which is saved with the RFR as support. Responsible Individuals: Nachum Golodner, Director of Accounting Anticipated Completion Date: June 30, 2023
Views of Responsible Officials and Planned Corrective Actions - Management concurs an increased transaction volume has slowed the implantation of procedural changes. However, this finding applied to an immaterial amount. All other requested support was provided to the auditors in full. As management...
Views of Responsible Officials and Planned Corrective Actions - Management concurs an increased transaction volume has slowed the implantation of procedural changes. However, this finding applied to an immaterial amount. All other requested support was provided to the auditors in full. As management noted in their response to Finding 2022-003, transaction volume continues to increase. The new accounting firm will assess current controls and protocols necessary to obtain and retain documentation necessary for all expenditures, both material and immaterial. Any changes needed to these controls will be implemented.
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding. Unfortunately, information rega...
Views of Responsible Officials and Planned Corrective Actions - Management concurs the initial Schedule of Federal Awards was prepared using the total program expenditures and not the program expenditures incurred using just the federal portion of the program funding. Unfortunately, information regarding the federal versus non-federal breakdown of awards is not available in initial program contracts. This information is only disclosed as part of the confirmation process. Management has begun working with the new accounting service provider to be cognizant of the program expenditures by funding source through the year. Management will also work closely with the auditors to ensure funding allocations per confirmations, if different than projected, are reflected properly in the Schedule of Federal Awards.
Views of Responsible Officials and Planned Corrective Actions - Management recognizes the overall volume of transactions the Organization continues to grow each year and it being one of the reasons this is a repeat finding. The questioned costs were immaterial. While improvements were made during th...
Views of Responsible Officials and Planned Corrective Actions - Management recognizes the overall volume of transactions the Organization continues to grow each year and it being one of the reasons this is a repeat finding. The questioned costs were immaterial. While improvements were made during the year, the internal recordkeeping controls and protocols will continue to be reviewed with the new accounting service provider and improved measures implemented.
Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviewed draws on federal funds noting no discrepancies. Going forward, the Chief Financial Officer will calculate the amount of the draw on federal funds, which will then be rev...
Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviewed draws on federal funds noting no discrepancies. Going forward, the Chief Financial Officer will calculate the amount of the draw on federal funds, which will then be reviewed, approved, and documented by the Chief Executive Officer before the draw is submitted. Anticipated correction date: This has already been implemented retroactively effective January 2023. Responsible official: Gabriela Cordero, Chief Financial Officer.
Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviews the documentation for expenditures allowed and unallowed under the terms of the grant agreement, and the drawdown happens only when the amount of allowed expenditures has...
Proposed corrective action: The finance department has already implemented a process in which the Chief Financial Officer reviews the documentation for expenditures allowed and unallowed under the terms of the grant agreement, and the drawdown happens only when the amount of allowed expenditures has been determined. Anticipated correction date: This has already been implemented retroactively effective January 2023. Responsible official: Gabriela Cordero, Chief Financial Officer.
View Audit 235553 Questioned Costs: $1
Management agrees with the finding and has reviewed procedures with the appropriate personnel.
Management agrees with the finding and has reviewed procedures with the appropriate personnel.
Finding 252560 (2022-002)
Significant Deficiency 2022
2022-002 U.S. Department of Agriculture, Food, and Nutrition Service Emergency Food Assistance Program CFDA Number: 10.568/10.569 Passed Through: The Arizona Department of Economic Security Pass Through Number: CtR052634 Award Period: July 1, 2021 ? June 30, 2022 Condition/Context ? Internal cont...
2022-002 U.S. Department of Agriculture, Food, and Nutrition Service Emergency Food Assistance Program CFDA Number: 10.568/10.569 Passed Through: The Arizona Department of Economic Security Pass Through Number: CtR052634 Award Period: July 1, 2021 ? June 30, 2022 Condition/Context ? Internal control procedures over procurement requirements did not ensure compliance with federal awards. For 1 of 8 vendors tested, there was no documented evidence that the vendor was reviewed and approved in accordance with the Organization?s procurement policy. Contact Person ? Megan Montalvo, Chief Financial Officer Corrective Action Plan ? United Food Bank follows the set procurement policy. Quotes are obtained for all vendors who meet a certain dollar threshold. For the instance that occurred, quotes were obtained and reviewed. A meeting was held to discuss the quotes received, and it was decided to use the service of all of the vendors that quotes were obtained from, not just a single vendor. The failure occurred due to not documenting the selection of using multiple vendors for the same service on the Organization?s Vendor Selection Form. The Vendor Selection Form will be completed for all procurement services, even if multiple vendors are selected for the same type of goods or services.
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