Corrective Action Plans

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2025-008 SPECIAL TESTS AND PROVISIONS: UI PROGRAM INTEGRITY - OVERPAYMENTS SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 The overpayment in question was caused by an appeal decision made by an Administrative...
2025-008 SPECIAL TESTS AND PROVISIONS: UI PROGRAM INTEGRITY - OVERPAYMENTS SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 The overpayment in question was caused by an appeal decision made by an Administrative Law Judge (ALJ). The overpayment was established and coded correctly based on the ALJ decision in September 2024, even though an overpayment memo was not available. In October 2024, the Benefit Payment Control Overpayment Policy was revised to include instructions to create overpayment memos for all lower and higher authority appeal decisions which result in an overpayment of benefits. Benefit & Technical Support unit staff, who process appeal decisions, were made aware of the requirement.
2025-007 SPECIAL TESTS AND PROVISIONS: UI BENEFIT PAYMENT WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 WFWV acknowledges and agrees with the finding that Benefit Accuracy Measurement (BAM) cases were not reviewed and closed within the time limits established by ET Handbook No. 39...
2025-007 SPECIAL TESTS AND PROVISIONS: UI BENEFIT PAYMENT WORKFORCE WEST VIRGINIA (WFWV) Assistance Listing Number: 17.225 WFWV acknowledges and agrees with the finding that Benefit Accuracy Measurement (BAM) cases were not reviewed and closed within the time limits established by ET Handbook No. 395. During the performance year, the BAM team faced significant staffing challenges, which delayed the timely completion of audits and restricted the availability of personnel for reviewing completed cases. To address this issue, WFWV has implemented the following corrective measures: 1. Trained a support staff member in November 2024 to assist BAM analysts with administrative tasks, including setting up new case files, issuing second and third requests for information, and calculating wages based on employer-provided verification forms. This support enables analysts to dedicate more time to core investigative work. 2. Hired an additional BAM analyst in November 2025 to reduce management’s workload in completing audits, allowing them to prioritize the review of completed cases. Furthermore, as of January 2026, management and the BAM support staff now use a shared redesigned spreadsheet to track the progress of assigned cases. This tool provides real-time visibility into case statuses, ensuring more effective monitoring of completion timeliness and preventing future delays.
2025-006 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) Assistance Listing Number: 15.252 The finding states that the DEP did not report subaward information in accordance with reporting requirements. Specifically, two reports sel...
2025-006 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) Assistance Listing Number: 15.252 The finding states that the DEP did not report subaward information in accordance with reporting requirements. Specifically, two reports selected for testing were not reported in a timely manner. Based on the previous year’s finding, DEP implemented standard operating procedures on January 24, 2024, to ensure compliance with the FFATA reporting requirements. DEP concurs that the two reports found to be in noncompliance were, in fact, submitted after the required deadline. This oversight was primarily due to the understaffing of the Sub Grants Unit at the time these reports were to be submitted. DEP currently has sufficient standard operating procedures to ensure compliance with FFATA reporting. DEP will temporarily reassign staff responsibilities to ensure reporting compliance timelines are met until the current vacancy in the Sub Grants Unit can be filled to provide additional support to the existing staff.
2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally enter...
2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally entered into the FSRS site did not transfer over and had to be re-entered into SAM.gov, making those entries appear late. In addition, we had trouble getting the SAM.gov site to accept our FFATA entries. DOE worked with SAM.gov customer support to eventually get the issues resolved, but this also resulted in late reporting. Subsequent to the systematic issues being resolved, all FFATA reports have been completed timely and will continue to be reported timely going forward.
The University acknowledges the Pell Grant under award identified during the audit. University officials have developed the following corrective actions to ensure correct calculation of Pell Grant awards in accordance with 34 CFR §690.75. To correct the underlying problem, Financial Aid staff will w...
The University acknowledges the Pell Grant under award identified during the audit. University officials have developed the following corrective actions to ensure correct calculation of Pell Grant awards in accordance with 34 CFR §690.75. To correct the underlying problem, Financial Aid staff will work directly with Power FAIDS support to identify the specific cause(s) of the miscalculation of Pell Grant awarding. The University will also enhance staff competency through targeted training on the Pell Grant calculation methodology. All training activities will be documented and maintained in office records as part of the University’s compliance documentation. Additionally, the University will develop and revise internal policies and procedures related to Pell Grants to ensure consistency, accuracy, and adherence to federal regulations. These updated procedures will guide staff in the correct application of Pell rules and system processes. Further, to ensure ongoing compliance, the University will implement monitoring and quality‑assurance measures. These measures will include the conduct of monthly internal audits by an internal reviewer within Financial Aid to ensure Pell award accuracy. Monitoring results will be reviewed by the Director of Financial Aid and reported to the Vice President for Enrollment Management for oversight and accountability. Finally, these officials will ensure that the financial aid software used by the University is properly configured and maintained to address and prevent future awarding issues.
The University has both a written Gramm-Leach-Billey Act (GLBA) security program and a written policy. These documents were developed during June and July of 2025, remained in draft status through July 2025, and were formally approved in August 2025. The seven elements required by 16 CFR 314.4 (b) a...
The University has both a written Gramm-Leach-Billey Act (GLBA) security program and a written policy. These documents were developed during June and July of 2025, remained in draft status through July 2025, and were formally approved in August 2025. The seven elements required by 16 CFR 314.4 (b) are included in the written security program.
2025-002 - Timeliness of Federal Funding Accountability and Transparency Act Reporting Auditor Description of Condition and Effect. The City completed its FFATA reporting after the reporting deadline of 30 days. As a result of this condition, the City did not comply with the requirements of the Unif...
2025-002 - Timeliness of Federal Funding Accountability and Transparency Act Reporting Auditor Description of Condition and Effect. The City completed its FFATA reporting after the reporting deadline of 30 days. As a result of this condition, the City did not comply with the requirements of the Uniform Guidance to complete FFATA reporting in a timely manner. Auditor Recommendation. We recommend that the City complete FFATA reporting requirements in a timely manner. Corrective Action. Management concurs with the finding. The City will complete FFATA reporting requirements in a timely manner going forward. Responsible Person. Deb Chubb - Community Development Block Grant Manager Anticipated Completion Date. June 30, 2026
2025-001 - Equipment and Real Property Management Auditor Description of Condition and Effect. The City has not conducted a physical inventory of equipment in accordance with the requirements of the Uniform Guidance. As a result of this condition, the City did not comply with the requirements of the...
2025-001 - Equipment and Real Property Management Auditor Description of Condition and Effect. The City has not conducted a physical inventory of equipment in accordance with the requirements of the Uniform Guidance. As a result of this condition, the City did not comply with the requirements of the Uniform Guidance, which could also result in further noncompliance if equipment and real property are disposed in future years as a result of not having completed the physical inventory. Auditor Recommendation. We recommend that the City take physical inventory counts of all equipment and real property purchased with federal funds at least once every two years. Corrective Action. Management concurs with the finding. The City will perform an inventory of equipment purchased with federal funds. Responsible Person. Deb Chubb - Community Development Block Grant Manager Anticipated Completion Date. June 30, 2026
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan: This issue was the result of human error, as established procedures were not followed in which a student withdrawal wa...
Finding number: 2025-001 Federal agency: U.S. Department of Education Programs: Student Financial Assistance Cluster AL #: 84.063 and 84.268 Award year: 2025 Corrective Action Plan: This issue was the result of human error, as established procedures were not followed in which a student withdrawal was not forwarded to the Registrar’s Office, preventing timely reporting to NSLDS. The student’s official withdrawal request was not transmitted by the office responsible for approving student leaves and withdrawals to the Registrar’s Office for processing, resulting in the absence of the required enrollment update in the student information system. In response, the Registrar’s Office has implemented a revised procedure for the handling of late leave requests and will coordinate directly with the Financial Aid Office to ensure accurate updates to the NSLDS. Staff in the Advising Office have been retrained on proper transmission protocols, and both the Registrar’s Office and Advising Office have instituted additional quality control and tracking measures to ensure that all leaves and withdrawals are processed and reported in a timely and compliant manner. Timeline for Implementation of Corrective Action Plan: The corrective action plan was implemented as of October 2025. Contact Person Megan Miller, University Registrar
#2025-001 Lack of Required Independent Estimate for Procurement Exceeding the Simplified Acquisition Threshold 1. Update Policies and Procedure Management will revise procurement policies and procedures to clearly require: preparation of an independent estimate, and completion and documentation of a...
#2025-001 Lack of Required Independent Estimate for Procurement Exceeding the Simplified Acquisition Threshold 1. Update Policies and Procedure Management will revise procurement policies and procedures to clearly require: preparation of an independent estimate, and completion and documentation of an independent estimate for all procurements exceeding the simplified acquisition threshold. 2. Implement Procurement Control Checkpoints System-based controls and/or manual review checkpoints will be added to ensure independent estimates are attached before purchase orders or contract awards are approved. 3. Staff Training Procurement and program staff will receive training on: federal procurement requirements (2 CFR 200), when independent estimates are required, and how to properly prepare and retain the documentation. 4. Ongoing Monitoring and Compliance Review Management will implement periodic reviews of procurement files to verify compliance with updated policies. Any deficiencies noted will be corrected promptly and used to inform additional training needs. Responsible Party: Business Manager Timing for Completion: Within 90 days
Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...
Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: A PELL reconciliation report will be pulled monthly to check that the disbursement dates/amounts on COD match the disbursement dates/amounts on PowerFAIDS and Bionic. Name of the contact person responsible for corrective action: Shannon Braccili, Associate Director of Financial Aid Planned completion date for corrective action plan: Effective starting August 2025 with the first Fall 2025 PELL disbursement and continuing through the end of the academic year. This procedure will continue to be followed in subsequent academic years.
U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that a...
U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An investigation that uncovered a National Student Clearinghouse enrollment transmission proofing error related to program-level effective date for graduated students. Name of the contact person responsible for corrective action: James Keane, Registrar Planned Corrective Action Plan: The Registrar's Office will ensure that the program level effective date for graduates is accurate prior to submission. The Registrar will also partner with IITS to ensure that the program-level effective date for graduates is generated in the submission file as expected. Planned completion date for corrective action plan: May 2026, prior to the June 2026 submission date.
To Whom It May Concern: This letter is in response to the audit finding identified in the annual district financial report for fiscal year ending June 30, 2025 issued by Leo Riley & Co. This letter addresses the compliance findings 2025-001 and 2025-002 regarding internal controls. Weston County Sch...
To Whom It May Concern: This letter is in response to the audit finding identified in the annual district financial report for fiscal year ending June 30, 2025 issued by Leo Riley & Co. This letter addresses the compliance findings 2025-001 and 2025-002 regarding internal controls. Weston County School District #7 acknowledges that, due to the small office staff, it makes it impractical for the district to achieve full separation of the accounting functions in the business office. The District believes it has mitigated the risks associated with this limitation through use of various controls and segregation of functions to the greatest extent possible. The governing board is also involved in the approval process being the final authority over accounts payable expenditures. The District utilizes the accounting manual as provided by the Wyoming Department of Education. The business office staff, district administrative staff, and the school board are fully aware of the limitations in this area and have a heightened awareness when performing their duties to further mitigate risks. Gina Barritt WCSD7 Business Manager 307-468-2461
Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subr...
Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subrecipient activities as required under FFATA regulations. However, the lack of a clearly defined responsibility for this task resulted in non-compliance. Management recognizes this gap and is committed to implementing corrective measures to ensure full compliance moving forward.
Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although ...
Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although procedures exist for verifying SAM.gov registration (suspension/debarment status) and obtaining audited financial statements from subgrantees, these procedures were not documented or codified in the Caminos Nacional Policy Manual. Pre-award risk assessments have been conducted informally without a formal determination of risk, and protocols surrounding risk assessment were inadequately documented, resulting in inconsistent implementation.
Views of Responsible Officials: Management acknowledges the findings related to Payroll Allocation, and Training & Compliance, as outlined in the recent audit report. We appreciate the recommendations provided and are committed to implementing corrective actions to strengthen compliance, improve pay...
Views of Responsible Officials: Management acknowledges the findings related to Payroll Allocation, and Training & Compliance, as outlined in the recent audit report. We appreciate the recommendations provided and are committed to implementing corrective actions to strengthen compliance, improve payroll allocation accuracy, and enhance staff knowledge of grant management requirements.
Finding Synopsis: One employee's payroll disbursement made under the Child Nutrition Cluster was improperly calculated. Action Steps: A district staff member will review the payroll calculations so no transpositions or errors occur. Contact Person(s): Dr. Jennifer Garrison, Superintendent Anticipate...
Finding Synopsis: One employee's payroll disbursement made under the Child Nutrition Cluster was improperly calculated. Action Steps: A district staff member will review the payroll calculations so no transpositions or errors occur. Contact Person(s): Dr. Jennifer Garrison, Superintendent Anticipated Completion Date: February 11, 2026
Management is cognizant of this limitation and will implement additional procedures where possible.
Management is cognizant of this limitation and will implement additional procedures where possible.
PBRA/MOD Vacant Units Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and within other relevant records. Explanation of disagreement with audit finding: There is no disagreement with the audi...
PBRA/MOD Vacant Units Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and within other relevant records. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies site staff will retrain staff on the move-out / deposit accounting process and the required month end closeout process no later than February 28, 2026. Regional Managers will review and confirm completion of end-of-month checklists to verify that all required monthly tasks have been performed, thereby reducing the risk of this exception occurring in the future. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately corrected this discrepancy and will implement the remaining corrections by February 28, 2026.
PBRA/MOD Housing Quality Standards Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. Explanation of disagreement with audit finding: ...
PBRA/MOD Housing Quality Standards Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, policy has been updated to reflect the requirement to complete within 365 days of the previous inspection. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action as outlined above.
PBRA/MOD Eligibility Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action tak...
PBRA/MOD Eligibility Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, will retrain all site staff on acceptable and complete forms of income, asset, and expense documentation for initial certifications and the annual recertification process no later than February 15, 2026. Pratum's Compliance team will continue to review each new move-in file from eligibility determination through lease execution to ensure ongoing programmatic compliance. In addition, the Compliance team will complete supplemental training by February 15, 2026, to reinforce proper use of the internal control's checklist, which is required to be attached to all submitted move-in files. Name(s) of the contact person(s) responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action outlined above.
HCVP Housing Quality Standards and Enforcement Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abateme...
HCVP Housing Quality Standards and Enforcement Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abatement of housing assistance payments are being followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC will collaborate with the software vendor, IT department, and a third-party consultant to remediate system deficiencies affecting inspection tracking and compliance. This will include developing and implementing quality control reports to identify units with failed or overdue inspections, restoring accurate inspection date tracking, and strengthening monitoring processes to ensure timely inspections, abatements, and enforcement in accordance with program regulations. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division. Planned completion date for corrective action plan: HRD has initiated implementation of the corrective action plan by engaging the IT department and the software vendor to assess system deficiencies impacting inspection tracking, abatement enforcement, and regulatory compliance. Initial meetings have focused on identifying root causes, reviewing data integrity issues, and evaluating potential system enhancements and reporting solutions to improve monitoring and oversight. HOC will continue coordinated efforts with IT, the software vendor, and a third-party consultant to design, test, and implement corrective measures. Full implementation and stabilization of the identified solutions is anticipated to be completed by December 2026.
Suspension & Debarment – Special Education Cluster (IDEA) Recommendation: We recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Action planned/taken in response to finding: Th...
Suspension & Debarment – Special Education Cluster (IDEA) Recommendation: We recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Action planned/taken in response to finding: The District has reviewed its existing procedures related to suspension and debarment requirements and has reinforced expectations for consistent adherence and documentation in accordance with District policies and federal grant requirements. Management has implemented additional oversight to ensure required checks are completed and properly documented prior to vendor engagement and payment. Procedures will continue to be monitored to ensure compliance is consistently maintained. Name of the contact person responsible for correction action: Kristin Sobocinski Planned completion date for corrective action: June 30, 2026 Responsible Official for Corrective Action Plan: Kristin Sobocinski, Deputy Superintendent (608) 316-1916
Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Explanation of disagreement with audit findi...
Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The District has implemented procedures to ensure that Child Nutrition claims are reviewed and approved prior to submission by an individual knowledgeable of grant requirements. This review includes verification of claim accuracy, supporting documentation, and compliance with applicable federal regulations. Name of the contact person responsible for correction action: Kristin Sobocinski Planned completion date for corrective action: Ongoing, June 30, 2026
Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance D...
Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance Director to review Quarterly Financial Summaries and Annual Cost reports and document this review before submitting to SBS. The payroll coordinator will prepare the quarterly financial summaries and they will be reviewed by the Business Manager prior to submission to ensure accuracy. Responsible Person: Shannon Grindell, Sharon Weise Anticipated Completion Date: Ongoing
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