Corrective Action Plans

Finding 31035 (2022-001)

Significant Deficiency 2022

University of Health Sciences and Pharmacy in St Louis

MO

Student Financial Aid Subrecipient Monitoring Reporting

The underlying cause of the University's internal control system deficiency regarding Enrollment Reporting primarily related to staffing changes as well as an employee performance matter. The Financial Aid Office has addressed the employee performance matter and provided additional training across ...

The underlying cause of the University's internal control system deficiency regarding Enrollment Reporting primarily related to staffing changes as well as an employee performance matter. The Financial Aid Office has addressed the employee performance matter and provided additional training across all team members. In addition, the Financial Aid Office has implemented new oversight, review processes and procedures across internal departments intended to enhance the timely submission of enrollment changes to the NSLDS in accordance with the requirements. These enhanced processes and procedures were implemented during the fiscal year ending June 30, 2023.

View Audit 28000

Finding 31033 (2022-002)

Material Weakness 2022

Eastwick Section 811 Housing Corporation

PA

HUD Housing Programs Eligibility Material Weakness

Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for portfolio property managers to effectively manage tenant files at each building location. Historically, the management and auditing of tenant files was entirely under the process flows for property m...

Views of Responsible Officials and Planned Corrective Actions: Staffing turnover limited ability for portfolio property managers to effectively manage tenant files at each building location. Historically, the management and auditing of tenant files was entirely under the process flows for property management team. Going forward the Inglis Compliance department will sufficiently sample and review tenant files throughout year to assure tenant files are accurate and audit ready at any given time.

View Audit 28218

Finding 31032 (2022-002)

Significant Deficiency 2022

Mercer County Joint Township Community Hospital

OH

Questioned Costs Reporting Significant Deficiency

To whom it may concern, We have included the correction action plans for both findings included in the Schedule of Findings and Questions costs which accompanies the audited financial statements and supplementary information submitted along with the data collection form used to summarize the results...

To whom it may concern, We have included the correction action plans for both findings included in the Schedule of Findings and Questions costs which accompanies the audited financial statements and supplementary information submitted along with the data collection form used to summarize the results of audits performed in accordance with Government Auditing Standards and Uniform Guidance. Corrective Action Plan for Findings Reported in Accordance with Government Auditing Standards Financial Statement Finding 2022-001: Significant Deficiency, Accounts Receivable and Revenue Recognition Condition During the audit, it was discovered that patient accounts receivable associated with the Medical and Educational Development Foundation Physicians Corporation (MEDF) was understated by $734,127. Corrective Action Plan Corrective Action Planned: Our management team evaluated two options to solve the issue that resulted in finding 2022-001. The first option is to record and report MEDF's net patient accounts receivable on a monthly or annually basis, which is consistent with how management reports hospital patient accounts receivable. The second option is for management to monitor MEDF's patient accounts receivable balance monthly or annually to determine the significance of estimated net patient receivable to the financial reporting, if deemed to be significant management would record and report the balance. We believe both options are reasonable solutions that will resolve the finding moving forward. Management has concluded to implement the first option and report MEDF's net patient accounts receivable on an annual basis. Names of Contact Persons Responsible for Corrective Action: Jon Dingledine, Chief Financial and Operating Officer Cory Albers, Vice President of FinanceAnticipated Completion Date: We plan to implement the corrective action plan beginning with fiscal year ending 3/31/2022. The start of the year is April 1, 2022. Corrective Action Plan for Findings Reported in Accordance with Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Federal Award Finding 2022-002: Significant Deficiency in Internal Control over Compliance, Reporting Condition During the audit performed in accordance with the Uniform Guidance, it was discovered that lost revenues was mistakenly reported using option two in our Provider Relief Fund submissions for reporting periods one and two. Option three should have been selected to report lost revenues since we utilized budget-to-actual patient revenues utilizing 2020, 2021, and 2022 fiscal year budgets which covered the periods of availability; but were not all approved prior to the March 27, 2020 deadline. Corrective Action Plan Corrective Action Planned: Currently, our management team has reviewed the methods used to measure lost revenue for Provider Relief Fund reporting and plans to amend the option used to report past Provider Relief Fund submissions from option two to option three. Our management team plans to continue the use option three for future reporting periods. Names of Contact Persons Responsible for Corrective Action: Jon Dingledine, Chief Financial and Operating Officer Cory Albers, Vice President of Finance Anticipated Completion Date: Management plans to implement the corrective action plan beginning with the next applicable Provider Relief Fund reporting period. This should take place on or before March 31, 2023.

View Audit 27289 Questioned Costs: $1

Finding 31031 (2022-002)

Significant Deficiency 2022

Joint School District No. 2

ID

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Significant Deficiency

Finding 2022-002 Federal Agency Name: Federal Communications Commission Program Name: Emergency Connectivity Fund Federal Assistance Listing: 32.009 Finding Summary: The District purchased laptops with a per unit cost greater than the $400 limit. Under the ECF grant there was only $400 per grant ...

Finding 2022-002 Federal Agency Name: Federal Communications Commission Program Name: Emergency Connectivity Fund Federal Assistance Listing: 32.009 Finding Summary: The District purchased laptops with a per unit cost greater than the $400 limit. Under the ECF grant there was only $400 per grant that was allowed. The full amount of the devices were initially charged to the grant; however as a result of audit procedures, it was discovered that there was a maximum of $400 allowed and therefore the excess cost was charged to a different grant. Responsible Individuals: Jonathan Gillen, Chief Operations Officer Corrective Action Plan: Auditee has designed internal control processes that will also encompass a review of journal entries and the trial balance associated with federal revenues. Anticipated Completion Date: November 2022

View Audit 25849

Finding 31029 (2022-004)

Material Weakness 2022

National University

CA

Material Weakness Reporting Internal Control / Segregation of Duties

FINDING 2022-004 ? Reporting ? Material Weakness in Internal Control over Compliance Condition/Context: Although the University could produce documentation to evidence the periodic updating of its website such as contemporaneous email communication, all previously posted HEERF reports prior to the r...

FINDING 2022-004 ? Reporting ? Material Weakness in Internal Control over Compliance Condition/Context: Although the University could produce documentation to evidence the periodic updating of its website such as contemporaneous email communication, all previously posted HEERF reports prior to the report current as of the timing of our audit could not readily be produced nor could evidence of the review and approval of such reports be produced. The University also was unable to demonstrate that it timely reported the quarterly information to its website. Cause: The exceptions occurred as a result of the lack of internal controls in place to 1) track reporting requirements including the due date per federal regulations, and 2) supervisory review and approval of prepared reports, prior to submission. Corrective Action Plan: NU has updated its HEERF reporting process to include a documented checklist review from the Quality Assurance team, under Brandy Baker, before the report is submitted to demonstrate internal controls and accuracy. NU has created a HEERF report repository that will house historical and current reports. In March of 2023, NU developed a reporting process timeline to better support the collection, processing and reporting of the data in an effort to prevent submission delays managed by Ernie Prunker, Sr. Director Account Services.

View Audit 26192

Finding 31025 (2022-002)

Material Weakness 2022

National University

CA

Student Financial Aid Reporting Material Weakness

FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Material Weakness in Internal Control Condition/Context: A sample of 75 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropp...

FINDING 2022-002 ? Special Tests and Provisions ? Enrollment Reporting: Material Weakness in Internal Control Condition/Context: A sample of 75 federal aid recipient students were selected from system generated reports of students who graduated, reported a physical address change, withdrew, or dropped during the 2021-2022 academic year. Of the 75 students who had a change in address, graduated, or withdrew, 19 were not reported to the NSLDS within the required timeframe. Of the 75 students, 3 had an incorrect effective date reported to the NSLDS. Cause: The attendance queries periodically used for change of status purposes were incomplete and failed to identify several students who had stopped attending class prior to completion of a payment period. Corrective action plan: In January of 2023, NU updated its NSLDS reporting policies and procedures overseen by Jorge Salas from our registrar team. The Quality Assurance, under Brandy Baker, team began reviewing enrollment reporting on a regular basis in February of 2023 to confirm the reporting process is consistent with the Title IV regulation. In the event that the Quality Assurance review yields inaccurate reporting, the Quality Assurance team will lead the investigation to determine the cause of the inaccurate reporting and will work with the appropriate departments and teams to ensure that any required corrections to process, reporting, reporting code or systems is rectified. NU reviewed and confirmed that the revised reporting logic would accurately report enrollment statuses, effective dates, and locations.

View Audit 26192

Finding 31017 (2022-003)

Significant Deficiency 2022

National University

CA

Procurement, Suspension & Debarment Eligibility Significant Deficiency

FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance Condition/Context: A sample of 40 students were selected from a list of all students enrolled and awarded federal student aid in fiscal year 2022. Cause: The exceptions occurred as a result of the lack of ef...

FINDING 2022-003 ? Eligibility ? Significant Deficiency in Internal Control over Compliance Condition/Context: A sample of 40 students were selected from a list of all students enrolled and awarded federal student aid in fiscal year 2022. Cause: The exceptions occurred as a result of the lack of effective internal controls in place to review completed financial aid packages against approved University budgets. Corrective Action Plan: In order to simplify the awarding process, In June of 2022 NU changed its COA policy to align with credits taken rather than expected months. This was done by our processing team under Kimberly Quinn. This has allowed for a simpler process and ensures a more accurate capture of all aspects to the cost of attendance. The Quality Assurance team, under Brandy Baker, has also included a review of COA as part of their regular file review process which will allow us to capture and correct any potential errors. The QA of COA updated its review in July of 2022 to match the changes made by the processing team.

View Audit 26192

Finding 31016 (2022-001)

Material Weakness 2022

National University

CA

Reporting Special Tests & Provisions Student Financial Aid

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control Condition/Context: A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of t...

FINDING 2022-001 ? Special Tests and Provisions ? Return of Title IV: Material Weakness in Internal Control Condition/Context: A sample of 60 students who were recipients of Title IV funding and had withdrawn during the year were selected and the student records were compared to the calculation of the return of Title IV funds, if any, and the federal government?s Common Origination and Disbursement system. National University (NU) did not identify 19 of the 60 sampled students as withdrawn. Of these 19 students, 5 students ultimately required funds to be returned. After the error was identified, NU appropriately returned the funds. For 8 of the 60 sampled students, the amount to be returned was not remitted within the required 45 days after NU?s determination of withdrawal. Cause: The attendance queries periodically used for withdrawal determination purposes were incomplete and failed to identify several students who had stopped attending class prior to completion of a payment period. In addition, there is not an established internal control in place to ensure Title IV funds are returned subsequent to the calculation. Corrective action plan: NU has revamped its R2T4 process completely. We have built new reporting, added additional staff, retrained the team in January of 2023, and created a new workflow management tool within our SIS to ensure timely and accurate completion. We have also expanded our quality reviews through our Quality Assurance (QA) team. The QA team, under the leadership of Brandy Baker, on January 1st of 2023 began reviewing files on a regular basis and providing feedback from the reviews with the leaders of the R2T4 team who then use that information to coach or retrain team members and correct errors. We are confident that all of these changes will allow us to effectively correct the findings from this and the previous audit.

View Audit 26192

Finding 31015 (2022-001)

Significant Deficiency 2022

Encino Gardens, Inc.

NM

HUD Housing Programs Eligibility

Finding 2022-001: Annual income incorrectly reported per HUD 4350.3 REV-1, Change 4, Chapter 5: Paragraph 5-6I. & HUD 4350.3 REV-1, Change 4, Chapter 5: Exhibit 5-2 and 24 CFR 5.609(b) and (c). Section 8 Housing Assistance Payment Program 14.195 Eligibi...

Finding 2022-001: Annual income incorrectly reported per HUD 4350.3 REV-1, Change 4, Chapter 5: Paragraph 5-6I. & HUD 4350.3 REV-1, Change 4, Chapter 5: Exhibit 5-2 and 24 CFR 5.609(b) and (c). Section 8 Housing Assistance Payment Program 14.195 Eligibility Management?s view: Management concurs with the finding that annual income was not calculated correctly on a certain tenant. We believe the miscalculation was the result of confusion on the nature of a portion of the tenant's income that was exempt. We believe the error was a simple mistake and not an internal control weakness or a significant deficiency. Proposed corrective action: Although mistakes will happen, management believes that a comprehensive training program is important and serves to minimize unnecessary errors. Training, specific to this incident, has been conducted with property staff by seasoned, experienced corporate compliance personnel. Anticipated correction date: October 26, 2022 Responsible official: Jerry Burkholder, Controller

View Audit 25848

Finding 31014 (2022-001)

None 2022

Community Housing Services - Johansen, Inc.

UT

HUD Housing Programs Matching / Level of Effort / Earmarking

Community Housing Services ? Johansen, Inc. Corrective Action Plan June 30, 2022 2022-001 Reserve Account The reserve account is underfunded by $459 as of June 30, 2022. Management failed to deposit the funds as required since the Project?s financial position made it difficult to do so. The mis...

Community Housing Services ? Johansen, Inc. Corrective Action Plan June 30, 2022 2022-001 Reserve Account The reserve account is underfunded by $459 as of June 30, 2022. Management failed to deposit the funds as required since the Project?s financial position made it difficult to do so. The missing payment was made in the subsequent period and the reserve account was fully funded as of 8/18/2022.

View Audit 25707

Finding 31013 (2022-001)

Significant Deficiency 2022

Morehouse College

GA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding No. 2022-001: SFA ? Direct Loan Disbursement Reporting Contact person for corrective action: Dr. LaMario Primas/ Executive Director of Financial Aid & Scholarships Correction Action Plan: The college plans to implement the following: ? During the 2022-2023 academic year, the Office of Finan...

Finding No. 2022-001: SFA ? Direct Loan Disbursement Reporting Contact person for corrective action: Dr. LaMario Primas/ Executive Director of Financial Aid & Scholarships Correction Action Plan: The college plans to implement the following: ? During the 2022-2023 academic year, the Office of Financial Aid & Scholarships Department implemented the following mechanisms to ensure that all disbursement records are reported to COD within the required 15 days. o Automic Auto scheduling: ? Automic has been configured to run batch disbursements and send origination records to COD on a weekly basis for Direct Loans. ? Automic will be turned off before the campus closes for Christmas break each year to ensure that no new disbursement and originations are done while the campus is closed.

View Audit 26190

Finding 31008 (2022-001)

Significant Deficiency 2022

Central Nebraska Community Action Partnership INC

NE

Questioned Costs Eligibility

Views of Responsible Officials: Management agrees with the finding. Person Responsible for Corrective Action: Tanya ...

Views of Responsible Officials: Management agrees with the finding. Person Responsible for Corrective Action: Tanya Williams, Assistant Family Outreach Director Corrective Action Plan: Management has implemented a review process by which all eligibility determinations are reviewed and approved by supervisory personnel with sufficient knowledge of program eligibility requirements. CNCAP has developed a screener sheet which will be completed for each participant prior to being served. Anticipated Completion Date: January 3, 2023

View Audit 25896 Questioned Costs: $1

Finding 31007 (2022-001)

Material Weakness 2022

Spindletop Center

TX

Allowable Costs / Cost Principles Eligibility Material Weakness § 200.303

Finding 2022-001 Federal Agency Name: United States Department of Health and Human Services Health Resources & Services Administration Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distributons (PRF) CFDA # 93.498 Finding Summary: The Reporting Period 2 Provider Re...

Finding 2022-001 Federal Agency Name: United States Department of Health and Human Services Health Resources & Services Administration Program Name: COVID-19 Provider Relief Fund and American Rescue Plan Rural Distributons (PRF) CFDA # 93.498 Finding Summary: The Reporting Period 2 Provider Relief Fund Report was not properly reviewed prior to submission, resulting in a reporting error related to lost revenues. Responsible Individuals: Denise LeBlanc, Chief Financial Officer Corrective Action Plan: Controls will be added to ensure all federal and state reporting is reviewed by a member of the financial services staff, who was not the preparer of the report, prior to submission. The amount of lost revenue will be corrected in subsequent reporting. Anticipated Completion Date: Ongoing as of September 1, 2022

View Audit 25782

Finding 31006 (2022-002)

None 2022

Panhandle Cusd #2

IL

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

Condition: The District's general ledger expense total did not agree to the total reported to the Illinois State Board of Education on the quarterly expense report for the period ended June 30, 2022. Recommendation: The District should ensure that the expenditure reports filed with the Illinois...

Condition: The District's general ledger expense total did not agree to the total reported to the Illinois State Board of Education on the quarterly expense report for the period ended June 30, 2022. Recommendation: The District should ensure that the expenditure reports filed with the Illinois State Board of Education are reconciled with the general ledger accounts of the District prior to submission. Management?s Response: The District will take the necessary steps to reconcile the expenditure reports with the general ledger accounts before submitting to the Illinois State Board of Education. Anticipated Date of Completion: June 30, 2023.

View Audit 25845

Finding 31005 (2022-002)

Material Weakness 2022

Low Rent Housing Agency of Knoxville, Iowa

IA

HUD Housing Programs Subrecipient Monitoring

Finding 2022-002 We agree with the finding. Planned corrective action: I have contacted our local banking institution and inquired if they will insure or collateralize our funds at 100%. They continue to pass me onto different individuals within their organization. If I learn they will not insur...

Finding 2022-002 We agree with the finding. Planned corrective action: I have contacted our local banking institution and inquired if they will insure or collateralize our funds at 100%. They continue to pass me onto different individuals within their organization. If I learn they will not insure or collateralize our funds at 100%, we will move our funds to a bank that will insure them at 100%.

View Audit 25704

Finding 31004 (2022-001)

Significant Deficiency 2022

Stiefel Theatre for the Performing Arts Foundation

KS

Significant Deficiency Internal Control / Segregation of Duties

Finding 2022-001 Significant Deficiency Recommendations We recommend the financial accountants include a step in the control process to recalculate hours reported on time sheets and document this review. View of Responsible Officials This grant provided funds to support the ongoing operations...

Finding 2022-001 Significant Deficiency Recommendations We recommend the financial accountants include a step in the control process to recalculate hours reported on time sheets and document this review. View of Responsible Officials This grant provided funds to support the ongoing operations of the Theatre during the midst of the COVID-19 Pandemic. Because of various state and federal restrictions relating to gatherings, the Theatre restructured office locations for various staff and processes as needed during the Pandemic. During this time It was difficult to maintain controls at the same level as pre-pandemic. While there was no compliance findings related to this matter, we continually review our internal control processes to strengthen them. The Theatre will review the internal control processes relating to payroll and include a step to recalculate hours reported on time sheets and add documentation. In addition, all timecards will be submitted to the Executive Director and approved before payment.

View Audit 26909

Finding 31002 (2022-003)

Material Weakness 2022

Des Moines Area Metropolitan Planning Organization

IA

Internal Control / Segregation of Duties

The corrective action plan was documented in our response to the auditor?s comment. See the Schedule of Findings and Questioned Costs.

View Audit 32463

Finding 30993 (2022-008)

Significant Deficiency 2022

Northern New Mexico College

NM

Questioned Costs Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

Auditors? Recommendation - We recommend the College strengthen controls over return of unearned aid the institution is responsible for to ensure timely return within 45 days and monitoring data entry process. Views of Responsible Officials and Planned Corrective Action - The College will review its ...

Auditors? Recommendation - We recommend the College strengthen controls over return of unearned aid the institution is responsible for to ensure timely return within 45 days and monitoring data entry process. Views of Responsible Officials and Planned Corrective Action - The College will review its current procedures and address any deficiency within Banner. The College will address in current procedure for the review and return of Title IV funds, to ensure compliance with the requirement. The College will address specific steps and timeframes for this process to include the proper documentation. Responsible Official ? Ivan Lopez, Provost and Kathy Levine, Director of Financial Aid Timeline and Estimated Completion Date - June 30, 2023

View Audit 30350 Questioned Costs: $1

Finding 30992 (2022-007)

Material Weakness 2022

Northern New Mexico College

NM

Special Tests & Provisions Student Financial Aid Material Weakness § 200.303

Auditors? Recommendation - We recommend the Registrar and/or Admission?s Office strengthen controls over enrollment reporting as well as the requirements under 34 CFR 690.83(b)(2) and 685.309 to ensure accurate reporting to the US Department of Education. Views of Responsible Officials and Planned C...

Auditors? Recommendation - We recommend the Registrar and/or Admission?s Office strengthen controls over enrollment reporting as well as the requirements under 34 CFR 690.83(b)(2) and 685.309 to ensure accurate reporting to the US Department of Education. Views of Responsible Officials and Planned Corrective Action - The College agrees with the finding. The College notes that specific steps were taken during the fiscal year to correct the deficiency; however, the process developed did not work. The College will review and modify its existing procedure to remedy the reporting deficiencies. Responsible Official - Ivan Lopez, Provost, Janice Baca, Registrar, Carmella Sanchez ,Director of Institutional Research, Scott Stokes, Chief Information Officer, and Emma Hashman, Admissions Timeline and Estimated Completion Date - June 30, 2024

View Audit 30350

Finding 30989 (2022-009)

Significant Deficiency 2022

Northern New Mexico College

NM

Allowable Costs / Cost Principles § 200.303

Auditors? Recommendation - We recommend the College strengthen the controls in place to provide assurance that proper review occurs and timeliness of reports. Views of Responsible Officials and Planned Corrective Action - The College reported within the year audited, and will ensure that positions r...

Auditors? Recommendation - We recommend the College strengthen the controls in place to provide assurance that proper review occurs and timeliness of reports. Views of Responsible Officials and Planned Corrective Action - The College reported within the year audited, and will ensure that positions responsible for such reporting do so on a timely basis. Responsible Official ? Ivan Lopez, Provost, Kathy Levine, Director of Financial Aid, and Sandy Krolick, Communications Timeline and Estimated Completion Date - June 30, 2023

View Audit 30350

Finding 30973 (2022-001)

Significant Deficiency 2022

California Lutheran University

CA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigati...

FINDING 2022-001 - Specials Tests and Provisions - Enrollment Reporting - Significant Deficiency in Internal Control over Compliance. Response: Cal Lutheran concurs with the exception of one student for whom a permanent address change was not reported within the required timeframe. After investigation, it was determined that the selection criteria for data extraction required adjustment to ensure all students were included in the data extraction and reporting process. Corrective Action Plan: Maria Kohnke, Associate Vice President of Academic Services & Registrar, modified the selection criteria for the data extraction process in the Colleague system to ensure all permanent address changes are extracted and submitted for all students as required. The Associate Registrar is responsible for reviewing and modifying the selection criteria for the data extraction process at the beginning of each year and at each change in criteria. The criterion will be reviewed and approved by the Associate Vice President of Academic Services & Registrar when changes are made. Responsible person: Maria Kohnke. Date of expected correction: September 1, 2022.

View Audit 30198

Finding 30972 (2022-003)

Significant Deficiency 2022

Missouri Housing Development Commission

MO

Subrecipient Monitoring Reporting

Finding 2022-003 ? Reporting ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: In order to navigate the required Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has imple...

Finding 2022-003 ? Reporting ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: In order to navigate the required Treasury reporting and to ensure that all reports reflect clear and appropriate information, staff has implemented many changes to process. To address staffing limitations, the Community Programs Processes Department was created in the fall of 2021 to aid in the reconciliation and financial tracking processes. In the early part of 2022, the Data and Analytics Department was officially formed to expand reporting capacity. New processes, in response to known limitations and timing restraints, have been developed to ensure adequate record keeping. Regular weekly meetings have been established between the Community Programs Processes Department, the Data and Analytics Department, and the Division Director to improve the coordination between all parties prior to the reporting deadlines. Additionally, where exceptions or changes must be made to reporting processes due to technical deficiencies or changes to guidance, processes have been established for clear communication and approval. Finally, as part of the regular coordination meetings, a debriefing of the reporting process occurs post submission so that improvements to the process may take place as needed. Completion Date: The Commission developed new departments and added additional staffing in fall 2021 and early 2022. New processes for report completion, submission, and record keeping were developed in the late spring of 2022 and regular communication and process improvement are ongoing. The Commission expects to complete implementation of procedures and to document ERA report reconciliations with the general ledger during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197

Finding 30971 (2022-002)

Material Weakness 2022

Missouri Housing Development Commission

MO

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.400 § 200.401

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 202...

Finding 2022-002 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 21.023 Emergency Rental Assistance Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 21.023. Internal controls have been enhanced to mitigate and help prevent further exposure to noncompliance. This includes the adoption of a formal fraud, waste, and abuse policy in July 2021 as well as providing additional training to employees and third parties that are responsible for reviewing and approving applications in order to better detect invalid applicants to prevent funding these applicants. In May 2021 the Commission hired an Internal Compliance Manager and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. Further, internal staffing capacity has been expanded with the creation of the Community Programs Processes Department in fall 2021 and the Data and Analytics Department in early 2022. Additional investigative techniques such as ?mass denial metrics? and tiered level reviews have been implemented into weekly application processing. Processes will continue to be implemented in response to changes in behavior by ineligible actors and ineligible application submission attempts. Staff has set regular internal coordination meetings to improve communication and aid in the identification of new indicators. Internal compliance staff actively participates in national groups administering similar programs, and explores and adopts new preventative measures demonstrated to be effective in other states. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021 and expects to conclude its investigation of the fiscal year identified cases during calendar year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30968 (2022-001)

Material Weakness 2022

Missouri Housing Development Commission

MO

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.400 § 200.401

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years ...

Finding 2022-001 ? Allowable Costs and Activities, Eligibility ? Compliance and Control Funding Federal Award No. 14.231 Emergency Solutions Grant Program ? COVID 19 Corrective Action Plan: The Commission management identified questionable applicants for direct rental assistance during fiscal years 2021 and 2022 and agrees with the finding regarding ALN 14.231. Internal controls have been enhanced to mitigate and identify instances of potential noncompliance. The funding for the direct rental assistance under this program was concluded and the final disbursements made in early May 2021. The Commission hired an Internal Compliance Manager in May 2021 and has engaged a third party law firm and a consulting group to provide consultative assistance to improve processes and to assist in investigating applications deemed to be questionable. A formal fraud, waste and abuse policy was adopted in July 2021. During fiscal year 2022, MHDC undertook extensive efforts to detect instances of ineligible applicants and documentation irregularities, which resulted in identification of these instances of applicant noncompliance. Completion Date: The Commission implemented additional compliance review procedures during fiscal year 2021, reviewed applications to identify potentially fraudulent applications during fiscal year 2022 and expects to conclude its investigation of identified cases during fiscal year 2023. Contact Person: Steve Whitson, Director of Community Programs

View Audit 30197 Questioned Costs: $1

Finding 30967 (2022-001)

Significant Deficiency 2022

Lake Anne Fellowship House, Section I

VA

Subrecipient Monitoring Internal Control / Segregation of Duties

U.S. Department of Housing and Urban Development Lake Anne Fellowship House, Section II FHA Project No. 000-005-NI respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly U.S., LLP 1570 Fruitvill...

U.S. Department of Housing and Urban Development Lake Anne Fellowship House, Section II FHA Project No. 000-005-NI respectfully submits the following corrective action plan for the year ended June 30, 2022. Name and address of independent public accounting firm: Baker Tilly U.S., LLP 1570 Fruitville Pike, Lancaster, PA 17601 Audit period: Year Ending June 30, 2022 The findings from the June 30, 2022 schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINANCIAL STATEMENT FINDINGS None Noted FEDERAL AWARD FINDINGS Finding 2022-001 ? Required Monthly Deposits to the Reserve for Replacement Recommendation: The Corporation should have procedures in place to ensure all required monthly deposits are made. Action Taken: $782.00 shortfall of deposits was funded. Going forward, annually management will verify with ownership monthly deposit required. Anticipated Completion Date: September 22, 2022, the date the Corporation made the underfunded deposit. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Christy Zeitz, CEO at (571) 349-0055.

View Audit 36489

Corrective Action Plans

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