Corrective Action Plans

Finding 51705 (2022-001)

Significant Deficiency 2022

AR

Equipment & Real Property Management Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking

Reference # 2022-001 Equipment and Real Property Management The Prescott School District understands that we have an audit finding due to not complying with the notification requirements regarding compliance with the Davis-Bacon Act and was unable to provide copies of weekly certified payrolls for ...

Reference # 2022-001 Equipment and Real Property Management The Prescott School District understands that we have an audit finding due to not complying with the notification requirements regarding compliance with the Davis-Bacon Act and was unable to provide copies of weekly certified payrolls for workers paid on the projects. The Prescott School District will contact the Arkansas Division of Elementary and Secondary Education for guidance regarding this matter and implement proper controls over program expenditures on any further projects.

View Audit 43090

Finding 51634 (2022-001)

Material Weakness 2022

Neighborhood Place of Puna

HI

Internal Control / Segregation of Duties Reporting

Management?s Response and Corrective Action Plan For the Year ending June 30, 2022 Finding 2022-001 - Lack of Fiscal Oversight by a Trained Accountant due to staff transition, Assistance Listing 21.023 COVID 19 Emergency Rental Assistance Program Neighborhood Place of Puna concurs with Audit Finding...

Management?s Response and Corrective Action Plan For the Year ending June 30, 2022 Finding 2022-001 - Lack of Fiscal Oversight by a Trained Accountant due to staff transition, Assistance Listing 21.023 COVID 19 Emergency Rental Assistance Program Neighborhood Place of Puna concurs with Audit Finding 2022-001. FY 21-22 saw a transition in accounting staff. Neighborhood Place of Puna recognizes the need for additional training for current accounting staff as well as engagement with licensed accounting personnel to ensure correct accounting practices are followed. To this end, Neighborhood Place of Puna will undertake two actions in response to the Audit Finding 2022-001. 1. Neighborhood Place of Puna will identify additional training for current accounting staff. 2. Neighborhood Place of Puna will explore engaging licensed professional accounting personnel either through recruitment to the Board of Directors, or subcontracting, or hiring. Responsible Person: Paul Normann, Executive Directory Email address: paul@neighborhoodplace.org Anticipated Completion Date: Neighborhood Place of Puna Anticipates that the two elements of the Corrective Action Plan will be completed by June 30, 2023.

View Audit 48520

Finding 51631 (2022-006)

None 2022

City of Plentywood

MT

Procurement, Suspension & Debarment § 200.318 § 200.327

FEDERAL PROCUREMENT Name of contact person: Mayor and Clerk Corrective Action: The City understands and agrees that it must order a rule which governs the spending of federally procured recovery funds and grants. More specifically, said rule shall create a standard of conduct which prevents the be...

FEDERAL PROCUREMENT Name of contact person: Mayor and Clerk Corrective Action: The City understands and agrees that it must order a rule which governs the spending of federally procured recovery funds and grants. More specifically, said rule shall create a standard of conduct which prevents the bestowal of federally procured recovery funds based upon relationship rather than merit. See, Mont. Code Ann. ? 2-2-301. To that end, the City shall draft and pass via majority vote of City Council Members a resolution to address this issue which complies with State and Federal regulation of said funds. Said resolution will be passed in 2023 prior to the conclusion of the City's fiscal year. Proposed Completion Date: Fiscal Year 2023.

View Audit 43508

Finding 51630 (2022-005)

Material Weakness 2022

City of Plentywood

MT

Internal Control / Segregation of Duties

AUDITOR PREPARED FINANCIAL STATEMENTS Name of contact person: Mayor and Clerk Corrective Action: We have considered the issue of Auditor-prepared financial statements. However, the City believes that the controls and practices in place adequately serve our needs and that the costs of hiring additi...

AUDITOR PREPARED FINANCIAL STATEMENTS Name of contact person: Mayor and Clerk Corrective Action: We have considered the issue of Auditor-prepared financial statements. However, the City believes that the controls and practices in place adequately serve our needs and that the costs of hiring additional professionals to do this work would not justify the benefits to be gained. As long as we have confidence in the ability and experience of the accounting firm selected to do our audit, and as long as we actively participate in the preparation, preliminary review, and drafting of financial statements, we trust the reliability of the statements to effectively fulfill their purpose. Proposed Completion Date: The City will continue to monitor this concern and avoid problems that may raise questions concerning the reliability of the financial statements.

View Audit 43508

Finding 51578 (2022-002)

None 2022

Silver Lake Joint #1 School District

WI

Management Response - The District Administrator and Business Manager review and approve the financial statements. Upon completion of the full audit, the school board reviews, comments on and approves the audited ?nancial statements.

View Audit 50149

Finding 51577 (2022-001)

None 2022

Silver Lake Joint #1 School District

WI

Internal Control / Segregation of Duties

Management Response ? Because of the size of the office and the district, we are precluded from maintaining a proper staff size to ensure a proper segregation of duties. We are aware of this condition and we realize that the concentration of duties and responsibilities in a limited number of indivi...

Management Response ? Because of the size of the office and the district, we are precluded from maintaining a proper staff size to ensure a proper segregation of duties. We are aware of this condition and we realize that the concentration of duties and responsibilities in a limited number of individuals in not desirable for an effective system of internal control. To mitigate the issue of lack of segregation of duties, we have cross trained virtually each of the business office employees. While we do have a dedicated payroll person, another individual will perform cross checks & verifications independently. The same goes for issuing checks, accounts receivable, accounts payable, and ac?vity funds. These func?ons are overseen by the business manager.

View Audit 50149

Finding 51576 (2022-001)

Material Weakness 2022

United Community Services, Inc.

IA

Reporting Subrecipient Monitoring Cash Management

Finding: 2022-001 Financial Reporting for Claim Reimbursement Our auditors identified that internal controls were not present to prevent incorrect claim submissions. Responsible Individual: Jen Pearson, Executive Director Corrective Action Plan: Management agrees with the finding, has reviewe...

Finding: 2022-001 Financial Reporting for Claim Reimbursement Our auditors identified that internal controls were not present to prevent incorrect claim submissions. Responsible Individual: Jen Pearson, Executive Director Corrective Action Plan: Management agrees with the finding, has reviewed procedures with the appropriate personnel. Date of Completion: June 30, 2023

View Audit 49653

Finding 51575 (2022-003)

Significant Deficiency 2022

Parc Community Homes, Inc. Project No. 072-Hd077

IL

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

2022-003 Section 811 ? New Construction ? Capital Advance Program ? Supportive Housing for Persons with Disabilities ? CFDA No. 14.181 Recommendation: Management should ensure the Corporation makes the required payment to the reserve for replacements on a monthly basis. Explanation of disagreement w...

2022-003 Section 811 ? New Construction ? Capital Advance Program ? Supportive Housing for Persons with Disabilities ? CFDA No. 14.181 Recommendation: Management should ensure the Corporation makes the required payment to the reserve for replacements on a monthly basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will make an additional deposit to make up for the $150 deficit at June 30, 2022. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process.

View Audit 47322

Finding 51574 (2022-002)

Significant Deficiency 2022

Parc Community Homes, Inc. Project No. 072-Hd077

IL

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

2022-002 Section 811 ? New Construction ? Capital Advance Program ? Supportive Housing for Persons with Disabilities ? CFDA No. 14.181 Recommendation: To establish proper internal control over security deposit refunds, the Corporation should design and implement the necessary procedures to ensure th...

2022-002 Section 811 ? New Construction ? Capital Advance Program ? Supportive Housing for Persons with Disabilities ? CFDA No. 14.181 Recommendation: To establish proper internal control over security deposit refunds, the Corporation should design and implement the necessary procedures to ensure the move-out notifications are provided to the accounting office in a timely manner and ensure the tenant's security deposit is processed and refunded within 30 days of the move-out date. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management will monitor future move-outs to ensure the security deposits are processed and refunded within 30 days of the move-out date. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process

View Audit 47322

Finding 51573 (2022-001)

Significant Deficiency 2022

Parc Community Homes, Inc. Project No. 072-Hd077

IL

Internal Control / Segregation of Duties Reporting Significant Deficiency

2022-001 Section 811 ? New Construction ? Capital Advance Program ? Supportive Housing for Persons with Disabilities ? CFDA No. 14.181 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, management?s and the board?s close supervision and re...

2022-001 Section 811 ? New Construction ? Capital Advance Program ? Supportive Housing for Persons with Disabilities ? CFDA No. 14.181 Recommendation: Responsibilities and duties should be segregated whenever possible. When this condition exists, management?s and the board?s close supervision and review of accounting information can help to prevent or detect errors and irregularities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Because the number of staff is inadequate to fully segregate duties, we feel that management staff must have the ability to record disbursement transactions and reconcile bank accounts with the general ledger, particularly for training purposes and periods when there are staff vacancies. Financial resources are insufficient to hire the additional staff to allow for greater segregation of responsibilities. Name(s) of the contact person(s) responsible for corrective action: Debbie Congdon Planned completion date for corrective action plan: In process

View Audit 47322

Finding 51572 (2022-002)

None 2022

Greenville-Spartanburg Airport District

SC

Reporting

Views of Responsible Officials and Planned Corrective Action: Effective immediately, the Airport will follow all compliance reporting obligations per the letter of the grant rather than depend on the Federal Aviation Administration personnel counsel as Accounting was told that this particular report...

Views of Responsible Officials and Planned Corrective Action: Effective immediately, the Airport will follow all compliance reporting obligations per the letter of the grant rather than depend on the Federal Aviation Administration personnel counsel as Accounting was told that this particular report was not needed annually. The Senior Manager - Finance will be responsible for ensuring these reports are filed annually.

View Audit 43404

Finding 51569 (2022-002)

Material Weakness 2022

First Baptist Church Capitol Hill Homes, Inc. D/b/a Kelly Miller Smith Towers

TN

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

First Baptist Church Capitol Hill Homes, Incorporated d/b/a Kelly Miller Smith Towers HUD Project No. 086-EH003-L7-NP-WAH 2136 Cliff Drive Nashville, TN 37218 CORRECTIVE ACTION PLAN - continued February 23, 2023 Finding ? Item 2022-2 Reporting under Government Auditing Standards Finding ? Item 2...

First Baptist Church Capitol Hill Homes, Incorporated d/b/a Kelly Miller Smith Towers HUD Project No. 086-EH003-L7-NP-WAH 2136 Cliff Drive Nashville, TN 37218 CORRECTIVE ACTION PLAN - continued February 23, 2023 Finding ? Item 2022-2 Reporting under Government Auditing Standards Finding ? Item 2022-2 Major Federal Award Program Audit Department of Housing and Urban Development (HUD): Section 223(F) Insured Loan ? Federal Assistance Listing # 14.155 Section 8 Housing Assistance Payments ? Federal Assistance Listing # 14.195 Reporting Statement of Condition: The required Single Audits were not remitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after the the receipted of the auditors' reports or 9 months after the end of the audit periods for the fiscal years ended April 30, 2016 - April 30, 2020. Recommendation: We recommend that the required delinquent submissions of Single Audits be completed as soon as possible. Auditee Response: The Board of Directors and management will work with the auditors to submit and certify to the FAC the Single Audit Reporting Packages for the years ended April 30, 2022 and 2021 immediately upon issuance. This will be completed by May 31, 2023. The Audit Committee of the Board of Directors will insure that future Single Audit Reporting Packages for the year ending April 30, 2023 and beyond with be remitted in accordance with federal regulations. The Board of Directors and management will work with the prior auditors to insure that missing FAC submissions for the years ended April 30, 2020 and prior will be submitted and certified as applicable and in accordance with federal regulation. Weldon B. Kidd, Board Chairman First Baptist Church Capitol Hill Homes, Inc.

View Audit 41146

Finding 51568 (2022-001)

Material Weakness 2022

First Baptist Church Capitol Hill Homes, Inc. D/b/a Kelly Miller Smith Towers

TN

HUD Housing Programs Reporting Matching / Level of Effort / Earmarking

First Baptist Church Capitol Hill Homes, Incorporated d/b/a Kelly Miller Smith Towers HUD Project No. 086-EH003-L7-NP-WAH 2136 Cliff Drive Nashville, TN 37218 CORRECTIVE ACTION PLAN February 23, 2023 To the U. S. Department of Housing and Urban Development First Baptist Church Capitol Hill Homes...

First Baptist Church Capitol Hill Homes, Incorporated d/b/a Kelly Miller Smith Towers HUD Project No. 086-EH003-L7-NP-WAH 2136 Cliff Drive Nashville, TN 37218 CORRECTIVE ACTION PLAN February 23, 2023 To the U. S. Department of Housing and Urban Development First Baptist Church Capitol Hill Homes, Incorporated d/b/a Kelly Miller Smith Towers respectfully submits the following corrective action plan for the year ended April 30, 2021. Name and address of independent public accounting firm: Tabb & Tabb, LLC Certified Public Accountants 260 Peachtree Street, NW, Suite 1201 Atlanta, Georgia 30303 Audit Period: May 1, 2021 to April 30, 2022 The findings from the April 30, 2022 schedule of findings are discussed below. The findings are numbered consistently with the number assigned in the schedule. The Summary of Audit Results does not include findings and is not addressed. Finding ? Item 2022-1 Reporting under Government Auditing Standards Finding ? Item 2022-1 Major Federal Award Program Audit Department of Housing and Urban Development (HUD): Section 223(F) Insured Loan ? Federal Assistance Listing # 14.155 Section 8 Housing Assistance Payments ? Federal Assistance Listing # 14.195 Reporting Statement of Condition: The required annual audits of the financial statements for the years ended April 30, 2022 and April 30, 2021 were not completed and submitted to HUD within the time frame required by HUD. Recommendation: We recommend that all financial reporting and submission requirements and deadlines required by HUD be strictly adhered to for future periods. Auditee Response: The Kelly Miller Smith Towers Board of Directors engaged a new audit firm to conduct the delinquent audits for the years ended April 30, 2022 and 2021. Both audits have been completed and will be submitted to HUD by May 19, 2023. The Board of Directors has established an audit committee who will assure that the audit for the year ending April 30, 2023 and subsequent years' audits will be completed and remitted within HUD's required time frame.

View Audit 41146

Finding 51566 (2022-001)

None 2022

Young Women's Christian Association of Billings

MT

Procurement, Suspension & Debarment Reporting § 200.512

YWCA Billings will continue to work with the auditor to meet the required deadlines to ensure the audited financial statements are submitted on a timely basis to the federal audit clearinghouse.

View Audit 48363

Finding 51562 (2022-002)

Material Weakness 2022

Metropolitan Council of the Twin Cities Area

MN

HUD Housing Programs Eligibility Material Weakness

Finding Number: 2022-002 Finding Title: Eligibility ? Source Documentation Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Name of Contact Person Responsible for Corrective Action: Terri Smith, Director Metro HRA Corrective Action Planned: HRA staff will develop a checkl...

Finding Number: 2022-002 Finding Title: Eligibility ? Source Documentation Program: 14.871 Section 8 Housing Choice Vouchers 14.879 Mainstream Vouchers Name of Contact Person Responsible for Corrective Action: Terri Smith, Director Metro HRA Corrective Action Planned: HRA staff will develop a checklist form and update procedures for all staff to ensure signatures and forms are not missing in case files, this includes but is not limited to background checks performed, citizenship forms and members of the household. The checklist will be completed for each case and stored in each participant file as part of the quality control process. Anticipated Completion Date: The checklist and the review process is currently in place effective June 2023.

View Audit 48360

Finding 51561 (2022-008)

Significant Deficiency 2022

City of Victorville

CA

Procurement, Suspension & Debarment

Views of Responsible Officials: Finance purchasing staff will hold annual training which will include requirements for all purchases, based on funding, to go through this division to ensure that all required verifications and paperwork are adhered to by city personnel. Purchasing staff will also dis...

Views of Responsible Officials: Finance purchasing staff will hold annual training which will include requirements for all purchases, based on funding, to go through this division to ensure that all required verifications and paperwork are adhered to by city personnel. Purchasing staff will also distribute a Purchasing Checklist to each department confirming the requirement to process grant funded projects/procurements through the Purchasing Division which is set up to verify suspension and disbarment status of potential awarded suppliers/contractors.

View Audit 48358

Finding 51560 (2022-007)

Significant Deficiency 2022

City of Victorville

CA

Subrecipient Monitoring Reporting Significant Deficiency

Views of Responsible Officials: In May 2022, it was brought to the City?s CDBG/HOME grant staff?s attention that subawards over the amount of $30,000 must be reported under the Federal Funding Accountability and Transparency Act (FFATA). Staff contacted the City?s Department of Housing and Urban Dev...

Views of Responsible Officials: In May 2022, it was brought to the City?s CDBG/HOME grant staff?s attention that subawards over the amount of $30,000 must be reported under the Federal Funding Accountability and Transparency Act (FFATA). Staff contacted the City?s Department of Housing and Urban Development (HUD) representative to confirm Community Development Block Grant subawards must be entered into the Subaward Reporting System. The HUD representative confirmed this requirement. The City?s CDBG/HOME grant staff began regular reporting in the system quarterly starting with the first quarter of the 2022 2023 fiscal year and has retroactively reported for fiscal year 2021-2022. In order for subawards to be entered into the system, the sub-awardee must possess a Unique Entity ID and other pertinent data that is collected with the initial grant application, which had not previously been collected in full but was collected at the subrecipient application stage beginning with the 2022-2023 fiscal year. Moving forward, City staff will confirm FFATA reporting completion in conjunction with the forwarding of official CDBG award contracts to the City Manager for final signatures, which will ensure timely filing in accordance with FFATA requirements.

View Audit 48358

Finding 51559 (2022-006)

Significant Deficiency 2022

City of Victorville

CA

Allowable Costs / Cost Principles Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials: Since early 2021, City Staff funded by CDBG/HOME entitlement grants have utilized electronic timesheets to track time spent working on the various programs by adjusting their weekly time entries to reflect actual time spent on a specific eligible activity. In some cas...

Views of Responsible Officials: Since early 2021, City Staff funded by CDBG/HOME entitlement grants have utilized electronic timesheets to track time spent working on the various programs by adjusting their weekly time entries to reflect actual time spent on a specific eligible activity. In some cases, these activities are also tracked by a Journal Entry (JE) with a description of the eligible activities and an hourly breakdown provided to supplement the JE. These tracking methods ensure amounts charged to the federal awards are accurate, allowable, and properly allocated. Additionally, both of the methods above require supervisor approval and all City staff approving electronic time sheets related to CDBG/HOME grants have been instructed to ensure time entries are correct and eligible, with technical assistance provided by the City?s CDBG/HOME grant administration staff as needed. All coding changes performed by finance department personnel will be sent via email for approval by supervisors until the payroll division can implement new procedures through the electronic time sheet system that will route approvals to supervisors through the established electronic workflow. Timesheet approval reviewers have since been updated to ensure proper supervisory personnel approves all timesheets in the event primary reviewers are absent or unable to approve.

View Audit 48358

Finding 51558 (2022-005)

Significant Deficiency 2022

City of Victorville

CA

Questioned Costs Allowable Costs / Cost Principles

Views of Responsible Officials: Since early 2021, City staff funded by CDBG/HOME entitlement grants have utilized electronic timesheets to track time spent working on the various programs by adjusting their weekly time entries to reflect actual time spent on a specific eligible activity. In some cas...

Views of Responsible Officials: Since early 2021, City staff funded by CDBG/HOME entitlement grants have utilized electronic timesheets to track time spent working on the various programs by adjusting their weekly time entries to reflect actual time spent on a specific eligible activity. In some cases, these activities are also tracked by a Journal Entry (JE) with a description of the eligible activities and an hourly breakdown provided to supplement the JE. These tracking methods ensure amounts charged to the federal awards are accurate, allowable, and properly allocated. Additionally, overtime hours inadvertently entered by Code Enforcement Staff has been addressed by Code Enforcement Supervisors who are communicating with their employees to ensure they are tracking time and completing electronic time sheets correctly. All coding changes performed by finance department personnel will be sent via email for approval by supervisors until the payroll division can implement new procedures through the electronic timesheet system that will route approvals to supervisors through the established workflow. Additionally, case management / GIS system adjustments at a parcel level will be developed to further improve data correlation between claimed staff hours and program specific locations. Beginning October 2021, as noted, continuing through the reporting period with implementation ongoing since that time, the subject finding has been corrected. The personnel services charged for two employees based on budget to the program has since been corrected beginning October 2021 as noted.

View Audit 48358 Questioned Costs: $1

Finding 51557 (2022-004)

Significant Deficiency 2022

City of Victorville

CA

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

Views of Responsible Officials: The City maintains internal controls to review all CDBG expenditures. These controls vary based upon expenditure type (e.g. administration, City Department subrecipients, and non-City subrecipients); however, all of these expenditure types are reviewed prior to disbur...

Views of Responsible Officials: The City maintains internal controls to review all CDBG expenditures. These controls vary based upon expenditure type (e.g. administration, City Department subrecipients, and non-City subrecipients); however, all of these expenditure types are reviewed prior to disbursement. These controls are summarized as follows: ? Administration ? Expenditures such as hours worked by City Staff, procurement of office supplies used to supplement the CDBG program, and other administrative costs are tracked through the City?s accounting system. These measures currently include the review/approval by managers/supervisors of City staff hours worked and the projects/activities completed, and review/approval of Purchase Requisitions and Purchase Orders by City staff through the City?s accounting system, all of which occur prior to disbursement. Purchase Requisitions and Purchase Orders also include a contract and an invoice or project description that lets appropriate City staff determine the eligibility of the proposed disbursement and the associated account being charged. ? City Department Subrecipients ? Expenditures for City Department Subrecipients are not made until review has been completed and the associated Purchase Requisitions and Purchase Orders is approved by appropriate City staff. Purchase Requisitions and Purchase Orders also include an invoice or project description that lets appropriate City staff determine the eligibility of the proposed disbursement and the associated account being charged. Applicable projects are also tracked through the City?s process to solicit bids/proposals, with the scope of work reviewed during all phases of the project to ensure grant eligibility. ? Non-City Subrecipients ? Subrecipients from outside the organization are subject to a thorough reimbursement protocol that includes the following: o Checklist - Provided to all grantees outlining requirements for submitting reimbursement requests, with example/fillable exhibits to outline eligible expenditures. These exhibits require the submittal of supplemental evidence (e.g. receipts, cancelled check/bank statements, time sheets, description of services provided, client eligibility, etc.). Paper records of these items are maintained. o Reviews - All reimbursement requests are reviewed/verified by two separate City departmental grant staff, with signatures confirming the eligibility of the request. Paper records of these items are maintained. o Purchase Orders - Invoices are included in all submittals to the City?s accounting system. All purchase orders are reviewed/approved by City staff via accounting system. In addition to maintaining paper records, moving forward all Purchase Orders and submitted invoices for non-City subrecipients will include copies of the approved/signed exhibits further confirming staff review of such items. All other Purchase Orders will include invoices that include a signed or initialed acknowledgement by appropriate City staff to supplement reviews/approval performed via the City?s accounting system.

View Audit 48358

Finding 51556 (2022-003)

Significant Deficiency 2022

City of Troy

MO

Matching / Level of Effort / Earmarking

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FEDERAL SIGNIFICANT DEFICIENCY 2022-3 The City has not adopted written policies and procedures related to federal awards as required by Uniform Guidance. Recommendation: We recommend the City adopt the required written policies and procedures requir...

FEDERAL AWARD FINDINGS AND QUESTIONED COSTS FEDERAL SIGNIFICANT DEFICIENCY 2022-3 The City has not adopted written policies and procedures related to federal awards as required by Uniform Guidance. Recommendation: We recommend the City adopt the required written policies and procedures required by Uniform Guidance. City?s Response: The City passed an ordinance amending the City?s Purchasing Ordinance # 1158 to include the specifics of the Uniform Guidance (2CFR Part 200) on March 7, 2022. Planned Completion Date for the Corrective Action Plan: Complete.

View Audit 43346

Finding 51521 (2022-304)

Significant Deficiency 2022

State of Wisconsin

WI

Internal Control / Segregation of Duties Subrecipient Monitoring Cash Management § 200.303

CAP for Finding: 2022-304 DATE: March 23, 2023 TO: Carolyn Stittleburg, Deputy State Auditor Legislative Audit Bureau FROM: Barry Kasten, Director Bureau of Fiscal Services Department of Health Services SUBJECT: Corrective Action Plan ? Coronavirus State and Local Fiscal Recovery Funds ? Monitoring ...

CAP for Finding: 2022-304 DATE: March 23, 2023 TO: Carolyn Stittleburg, Deputy State Auditor Legislative Audit Bureau FROM: Barry Kasten, Director Bureau of Fiscal Services Department of Health Services SUBJECT: Corrective Action Plan ? Coronavirus State and Local Fiscal Recovery Funds ? Monitoring of Local and Tribal Health Department Response and Recovery Support Program Expenditures Department staff has reviewed the Legislative Audit Bureau?s (LAB) interim audit memo for Finding 2022-304: Coronavirus State and Local Fiscal Recovery Funds ? Monitoring of Local and Tribal Health Department Response and Recovery Support Program Expenditures. This is the department?s Corrective Action Plan. ? Recommendation (2022-304): Coronavirus State and Local Fiscal Recovery Funds ? Monitoring of Local and Tribal Health Department Response and Recovery Support Program Expenditures We recommend the Wisconsin Department of Health Services: ? Develop and implement written policies and procedures for the review and tracking of the quarterly reports used to monitor expenditures under the Local and Tribal Health Department Response and Recovery Support program. Wisconsin Department of Health Services Planned Corrective Action: As beneficiaries, the Treasury Guidance indicates that Local and Tribal Health Departments are not subject to subrecipient monitoring and reporting requirements. The designation of beneficiary is unique to the CSLFRF and thus is not as familiar to DHS as the subrecipient designation and subsequent reporting requirements. The uncertainty surrounding this designation resulted in DPH not following the best practices described in the DPH Contract Management Manual. DPH?s Contract Management Manual outlines requirements and best practices for contract management. This Manual describes how to best review and track expenditures to monitor expenditures. The Manual encourages the best practice of requesting enhanced expenditure reporting from agencies, in addition to the reporting required for CARS payments. The Manual describes the role of the contract administrator in reviewing the expenditure information against the approved budget to ensure expenses are reasonable and allowable. The Manual also suggests maintaining copies of submitted reports and verifying the amounts in the submitted reports correspond to CARS reports. Examples of expenditure tracking are provided as is a description of how this tracking and other fiscal monitoring supports bureaus within DPH and DHS. DHS will review the existing policies and procedures in the Contract Management Manual to ensure that the level of detail is sufficient to prevent further non-compliance. We recommend the Wisconsin Department of Health Services: ? Maintain the quarterly reports, document its review of the quarterly reports, and document its correspondence with the public health departments regarding resolution of reporting variances. Wisconsin Department of Health Services Planned Corrective Action: DPH hired a position in June 2022 to manage and track expenditures and reporting for its Coronavirus State and Local Fiscal Recovery Funds granted to locals and tribal public health departments. DPH will continue to review, track, and maintain quarterly reports, and document correspondence with the local and tribal public health departments per best practices in the DPH Contract Management Manual. We recommend the Wisconsin Department of Health Services: ? Review the contracts with the public health departments and determine whether any revisions are needed to clarify expectations for documentation and timeliness of filing the quarterlyreports; and Wisconsin Department of Health Services Planned Corrective Action: DPH will review its contracts with the local and tribal public health departments and ensure timely filing of quarterly reports. Specific areas of non-compliance have been identified and division staff will review and draft updated scope of work language to mitigate delays in reporting from our local partners. We recommend the Wisconsin Department of Health Services: ? Ensure it obtains quarterly reports to support the payments it made to the City of Milwaukee Public Health Department. Wisconsin Department of Health Services Planned Corrective Action: DPH has now obtained quarterly reports from the City of Milwaukee Public Health Department and is in the process of reviewing them. Division staff will work with the City of Milwaukee Health Department to ensure future compliance. Anticipated Completion Date: June 30, 2023 Person responsible for corrective action: Karen Drogsvold, Budget Section Manager Division of Public Health, Bureau of Operations karen.drogsvold@dhs.wisconsin.gov

View Audit 44861

Finding 51518 (2022-100)

Significant Deficiency 2022

State of Wisconsin

WI

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303

CAP for Finding: 2022-100 Auditor Recommendation: Develop and implement controls to identify when an applicant applies for funding under multiple programs and to assess the appropriateness of whether it would be making payments to an applicant that applies under multiple programs. Planned Corrective...

CAP for Finding: 2022-100 Auditor Recommendation: Develop and implement controls to identify when an applicant applies for funding under multiple programs and to assess the appropriateness of whether it would be making payments to an applicant that applies under multiple programs. Planned Corrective Action: The Wisconsin Department of Administration (DOA or Department) will develop and implement controls to identify when an applicant applies for funding under multiple programs and to assess the appropriateness of whether it would be making payments to an applicant that applies under multiple programs. The controls will be documented in the Department?s Grants Management Guide and will consider, among other things, the purpose of the assistance being awarded and the criteria for the award. As the auditors noted specific to this finding and recommendation, DOA implemented controls for certain programs where it was anticipated an applicant might apply under more than one program. For programs where the controls were not implemented prior to award, the Department has subsequently reviewed to verify that an applicant was not paid for the same losses under more than one program, and none aside from that which was the condition for this finding were identified. Anticipated Completion Date: June 30, 2023 Auditor Recommendation: Review the specific payments made to the organization we identified and seek repayment of the amount that was made inappropriately. Planned Corrective Action: DOA has reviewed the specific payments made to the organization identified by the auditors and sought repayment of the amount that was not properly paid. Anticipated Completion Date: March 31, 2023 Person responsible for corrective action: Colleen Holtan, Director Bureau of Financial Management Division of Enterprise Operations colleen.holtan@wisconsin.gov

View Audit 44861 Questioned Costs: $1

Finding 51517 (2022-102)

Material Weakness 2022

State of Wisconsin

WI

Questioned Costs Eligibility Material Weakness

CAP for Finding: 2022-102 Auditor Recommendation: Obtain the required documentation for the 22 individuals we identified or seek to recoup improper benefit payments it made to these individuals. Planned Corrective Action: The Wisconsin Department of Administration (Department or DOA) will request fr...

CAP for Finding: 2022-102 Auditor Recommendation: Obtain the required documentation for the 22 individuals we identified or seek to recoup improper benefit payments it made to these individuals. Planned Corrective Action: The Wisconsin Department of Administration (Department or DOA) will request from the auditors the cases identified, review available documentation in its eligibility and benefit determination system to determine that all of the applicants were eligible to receive benefits under the program or that the costs were allowable to be funded by the Wisconsin Emergency Rental Assistance (WERA) Program, and obtain the required supporting documentation. Should DOA determine that it provided rental and utility assistance to individuals who were ineligible to receive WERA Program benefits, it will identify alternate eligible Department funding sources or seek to recoup improper benefit payments made, as appropriate. Anticipated Completion Date: June 30, 2023 Auditor Recommendation: Closely monitor the documentation being accepted by the community action agencies and Energy Services, Inc., and provide further training to address individual instances of noncompliance with the Wisconsin Emergency Rental Assistance Program Manual and guidance from the U.S. Department of the Treasury. Planned Corrective Action: The Department will monitor the documentation accepted by the community action agencies and Energy Services, Inc. (ESI), and provide further training to address individual instances of noncompliance with the WERA Program Manual and guidance from the U.S. Department of the Treasury. As the auditors noted, DOA provided training to the community action agencies and ESI in June 2022, and updated the WERA Program Manual as of June 30, 2022. The Department further notes that, after serving nearly 40,000 households with close to $250 million of assistance for rent, utilities and home internet bills, and preventing thousands of evictions across the state, the WERA Program closed to new applications as of January 31, 2023, but housing stability services remain available. Anticipated Completion Date: June 30, 2023 Auditor Recommendation: Regularly review and update its procedures to ensure that it is following the guidance from the U.S. Department of the Treasury in administering the Wisconsin Emergency Rental Assistance program. Planned Corrective Action: The Department will continue to review and update its procedures to ensure that it is following the guidance from the U.S. Department of Treasury in administering the WERA program. As the auditors noted, in response to its prior recommendation, DOA updated the WERA Program Manual as of June 30, 2022. Anticipated Completion Date: June 30, 2023 Person responsible for corrective action: Susan Brown, Administrator Division of Energy, Housing and Community Resources susan.brown@wisconsin.gov

View Audit 44861 Questioned Costs: $1

Finding 51509 (2022-103)

Significant Deficiency 2022

State of Wisconsin

WI

Reporting § 200.502 § 200.510 § 200.514

CAP for Finding: 2022-103 Auditor Recommendation: Further evaluate federal grant expenditures reported in the STAR General Ledger as it prepares its schedule of expenditures of federal awards and ensure it is adjusting expenditures for all prior-year transfers of expenditures in the current year. Pl...

CAP for Finding: 2022-103 Auditor Recommendation: Further evaluate federal grant expenditures reported in the STAR General Ledger as it prepares its schedule of expenditures of federal awards and ensure it is adjusting expenditures for all prior-year transfers of expenditures in the current year. Planned Corrective Action: The Wisconsin Department of Administration (DOA or Department) Bureau of Financial Management (BFM) will evaluate federal grant expenditures reported in the STAR General Ledger as it prepares its schedule of expenditures of federal awards (SEFA) and ensure it is adjusting expenditures for material prior-year transfers of expenditures in the current year in a manner consistent with requirements of the Office of Management and Budget Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance or Guidance) and additional guidance, if any, provided by the Department?s State Controller?s Office (SCO). The Uniform Guidance requires the preparation of a SEFA for the period covered by the State's financial statements that includes total federal awards expended [ref. 2 CFR 200.510 (b)]; the determination of when a federal award is expended to be based on when the activity related to the federal award occurs [ref. 2 CFR 200.502]; and that the financial statements and SEFA are for the same audit period [ref. 2 CFR 200.514]. As the auditors noted, in preparing DOA?s SEFA, DOA BFM sought to reflect the amount of federal awards expended for DOA?s grant programs based on the amounts reported in the STAR general ledger. Together with reporting negative expenditures resulting from the transfers of FY 2019-20 and FY 2020-21 expenditures within the Notes to the SEFA, which are an integral part of the SEFA and required by 2 CFR 200.510 (b)(6), and absent OMB guidance that prescribes a uniform method for reporting a transfer of prior year grant expenditures, DOA BFM believed its approach was consistent with the requirements of 2 CFR 200.502 and 2 CFR 200.510 (b), more generally. DOA BFM later modified its SEFA to exclude negative expenditures resulting from the transfers of FY 2019-20 and FY 2020-21 expenditures consistent with the manner in which a prior period adjustment would be reflected within current-year activity in financial statements prepared in accordance with generally accepted accounting principles (GAAP), as described in the criteria and recommended by the auditors. The increased expenditures for the Coronavirus Relief Fund (Assistance Listing number 21.019) and Coronavirus State and Local Fiscal Recovery Funds (Assistance Listing number 21.027) in the SEFA of $241.3 million and $192.1 million, respectively, together with any future exclusions of negative expenditures resulting from the transfer of prior-year expenditures, will cause the lifetime expenditures on the SEFA schedule for these programs to reflect more expenditures than federal funding received. The Notes to the SEFA were also modified to indicate that the SEFA does not reflect a reduction for the prior year transferred expenditures. Anticipated Completion Date: Concurrent with the submission of the FY 2022-23 SEFA, which is anticipated to be November 2023 Auditor Recommendation: Carefully assess the transfer of prior-year expenditures in the current year to determine any potential effects on the total federal expenditures for the prior-year and the effect on the major program expenditures. Planned Corrective Action: DOA BFM will assess the transfer of prior-year expenditures in the current year to determine any potential effects on the total federal expenditures for the prior-year and the effect on the major program expenditures. It has been the practice of DOA BFM to assess the transfer of prior year expenditures in the current year and DOA BFM will continue to prioritize decisions with respect to the same to allow the Department to maximize the availability of federal funding for the purposes intended. Anticipated Completion Date: June 30, 2023 Person responsible for corrective action: Colleen Holtan, Director Bureau of Financial Management Division of Enterprise Operations colleen.holtan@wisconsin.gov

View Audit 44861

Corrective Action Plans

Filters