Corrective Action Plans

Finding 2320 (2022-002)

None 2022

HI

Subrecipient Monitoring Eligibility

Staff responsible for fulfilling applicable compliance requirements was terminated for failture to perform job duties and replaced. In addition, a process to monitor performance of required procedures to complete annual eligibility verifications and income recertifications was implemented upon sta...

Staff responsible for fulfilling applicable compliance requirements was terminated for failture to perform job duties and replaced. In addition, a process to monitor performance of required procedures to complete annual eligibility verifications and income recertifications was implemented upon staff transition.

View Audit 3971

Finding 2314 (2022-001)

None 2022

City of Chelsea

MA

Questioned Costs Allowable Costs / Cost Principles Cash Management

Condition: The City charged the same invoice to two separate federal awards. Corrective Action Planned: This issue has been remedied. The City has corrected this and reversed the charge to the federal grant, reimbursed the grant funder, and filed a revised final grant report. This was an oversigh...

Condition: The City charged the same invoice to two separate federal awards. Corrective Action Planned: This issue has been remedied. The City has corrected this and reversed the charge to the federal grant, reimbursed the grant funder, and filed a revised final grant report. This was an oversight in the management of high volume COVID related grants totaling $10.3M with over 1,000 transactions, and reclassifications had occurred between the two as expenditures became ineligible. Moving forward, the City will take steps to ensure direct expenditures and limit the need for reclassifications. Anticipated Completion Date: October 31, 2023 Contact: Edward M. Dunn, City Auditor

View Audit 3965 Questioned Costs: $1

Finding 2308 (2022-001)

Material Weakness 2022

Lowertown Lofts Cooperative

MN

Material Weakness Reporting Internal Control / Segregation of Duties

The financial statements and year end accounting adjustments will continue to be prepared by an outside CPA firm at this time. We will continue to monitor the outsourced services, making all related decisions, evaluating the adequacy and results of the services, and accepting responsibility for them...

The financial statements and year end accounting adjustments will continue to be prepared by an outside CPA firm at this time. We will continue to monitor the outsourced services, making all related decisions, evaluating the adequacy and results of the services, and accepting responsibility for them.

View Audit 3947

Finding 2300 (2022-002)

Material Weakness 2022

Bellevue School District No. 405

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding caption: The District did not have adequate controls to ensure compliance with federal requirements for test assessment system security. Name, address, and telephone of District contact person: Tom Duenwald, Director of Educational Technology 12111 NE 1st Street Bellevue, WA 98005 (425) 456 ...

Finding caption: The District did not have adequate controls to ensure compliance with federal requirements for test assessment system security. Name, address, and telephone of District contact person: Tom Duenwald, Director of Educational Technology 12111 NE 1st Street Bellevue, WA 98005 (425) 456 - 4250 Corrective action the auditee plans to take in response to the finding: The Bellevue School District concurs with this finding. The District did not have a written Test Security and Building Plan (OSPI TSBP) for each school. For our corrective action, the District will create a SharePoint site to retain each school’s annual OSPI TSBP for all standardized state tests starting with the 2023-24 school year. The District Manager of Data, Testing & Research will provide instructions, professional development, and guidance for each school. Each school’s OSPI TBSP will be retained on the SharePoint site. The District Manager of Data, Testing & Research will verify that each school complies. Anticipated date to complete the corrective action: January 1, 2024

View Audit 3931

Finding 2293 (2022-001)

None 2022

Bellevue School District No. 405

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Finding caption: The District did not have adequate internal controls to ensure compliance with federal requirements for allowable activities and costs. Name, address, and telephone of District contact person: Jenny Hall, Director of Budget 12111 NE 1st Street Bellevue, WA 98005 (425) 456 - 4069 Cor...

Finding caption: The District did not have adequate internal controls to ensure compliance with federal requirements for allowable activities and costs. Name, address, and telephone of District contact person: Jenny Hall, Director of Budget 12111 NE 1st Street Bellevue, WA 98005 (425) 456 - 4069 Corrective action the auditee plans to take in response to the finding: The Bellevue School District concurs with this finding. The Budget Department’s internal procedures will be updated to include instructions for budget analysts to verify the correct indirect rate is used when preparing and reviewing grant claims. A shared document showing the historical indirect rates will continue to be updated annually and used as a reference to verify the correct rate is used in any given fiscal year. When preparing claims for reimbursement, a budget analyst will compare the indirect rate that is hard-coded in OSPI’s iGrants claim system to the calculated maximum indirect rate allowable for the fiscal year in which expenditures are incurred to ensure the correct indirect rate is used. When reviewing the claims for reimbursement, the reviewer will check the grant claim for accuracy, including verifying the indirect rate on the grant claims agrees to the calculated maximum indirect rate allowable. Anticipated date to complete the corrective action: September 30, 2023

View Audit 3931 Questioned Costs: $1

Finding 2285 (2022-002)

Significant Deficiency 2022

Boston Architectural College

MA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Management’s Corrective Action Plan Finding number: 2022-002 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #’s 84.063, 84.268 Award year: 2022 Corrective Action Plan The BAC will augment last year’s monthly automation of ros...

Management’s Corrective Action Plan Finding number: 2022-002 Federal agency: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing #’s 84.063, 84.268 Award year: 2022 Corrective Action Plan The BAC will augment last year’s monthly automation of roster submission with a monthly reconciliation of enrolment status as recorded in our student information system with the data recorded in NSLDS. Management will provide training to those reasonable for reporting enrolment status to NSLDS via the National Student Clearinghouse. This training will include the relevant rules and regulations as well as stress the importance of accuracy and the potential consequences of errors, both to our students and the institution. Timeline for Implementation of Corrective Action Plan The College plans to implement the corrective action plan by October 1, 2023. Contact Person James Ryan, Ph.D. Vice President of Enrollment Management

View Audit 3923

Finding 2284 (2022-002)

Material Weakness 2022

Stand Down Housing Westerly, Inc.

RI

Questioned Costs HUD Housing Programs Allowable Costs / Cost Principles

The Organization will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement and going forward we will make the required monthly deposits.

View Audit 3922 Questioned Costs: $1

Finding 2283 (2022-001)

Material Weakness 2022

Stand Down Housing Westerly, Inc.

RI

Internal Control / Segregation of Duties Reporting

The Organization will develop procedures to allow for greater segregation of duties over financial reporting or establish mitigating controls concerned with review and oversight.

View Audit 3922

Finding 2246 (2022-002)

Material Weakness 2022

Stand Down Housing Westerly, Inc.

RI

Questioned Costs HUD Housing Programs Allowable Costs / Cost Principles

The Organization will make the necessary required deposits to bring the balance of the reserve for replacement in alignment with requirements of Section 811 Capital Advance Program Regulatory Agreement and going forward we will make the required monthly deposits.

View Audit 3870 Questioned Costs: $1

Finding 2245 (2022-001)

Material Weakness 2022

Stand Down Housing Westerly, Inc.

RI

Internal Control / Segregation of Duties Reporting

The Organization will develop procedures to allow for greater segregation of duties over financial reporting or establish mitigating controls concerned with review and oversight.

View Audit 3870

Finding 2243 (2022-001)

Significant Deficiency 2022

Victory Heights, Inc.

MD

HUD Housing Programs Eligibility

Our back up plan for when a staff member is out or a position vacant is to have someone who is authorized to run EIV at another location/site to help cover until a replacement is found. In this case the EIV paperwork was held at a separate location and has since been placed in all the correct files....

Our back up plan for when a staff member is out or a position vacant is to have someone who is authorized to run EIV at another location/site to help cover until a replacement is found. In this case the EIV paperwork was held at a separate location and has since been placed in all the correct files. A full EIV Policy and Procedure manual is located on site and the new employee is trained on these policies by their supervisor and compliance manager. Both items were addressed in the follow up to the audit. The adjusted income was dealing with a lump sum of income which is not included in income. Correction was made to the 50059. The tenant signed her recertification paperwork 20 days late due a transition in the office. This was documented and file has been corrected. Additional training is provided to all managers on Section 8 Policies and Procedures on a regular basis. Policies and Procedures are also located on our direct intra network for individuals to refer to specific calculations, income issues, asset issues, forms and policies. This training is ongoing.

View Audit 3827

Finding 2242 (2022-002)

Material Weakness 2022

Victory Crest, Inc.

MD

HUD Housing Programs Eligibility

Onsite team members have received refresher training and have the EIV binder available onsite. They have also set calendar reminders to make sure that EIV reports are pulled in a timely manner. The findings regarding EIV have been addressed through refresher training and referring to the EIV binder ...

Onsite team members have received refresher training and have the EIV binder available onsite. They have also set calendar reminders to make sure that EIV reports are pulled in a timely manner. The findings regarding EIV have been addressed through refresher training and referring to the EIV binder when any policies/procedures are in question. The regional manager will be following up with the onsite to make sure they are in compliance.

View Audit 3821

Finding 2241 (2022-001)

Material Weakness 2022

Victory Crest, Inc.

MD

HUD Housing Programs Eligibility

Onsite team members have received refresher training and have the EIV binder available onsite. They have also set calendar reminders to make sure that EIV reports are pulled in a timely manner. The findings regarding EIV have been addressed through refresher training and referring to the EIV binder ...

Onsite team members have received refresher training and have the EIV binder available onsite. They have also set calendar reminders to make sure that EIV reports are pulled in a timely manner. The findings regarding EIV have been addressed through refresher training and referring to the EIV binder when any policies/procedures are in question. The regional manager will be following up with the onsite to make sure they are in compliance.

View Audit 3821

Finding 2240 (2022-001)

Material Weakness 2022

Renton School District No. 403

WA

Questioned Costs Equipment & Real Property Management Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Renton School District No. 403 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regul...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Renton School District No. 403 September 1, 2021 through August 31, 2022 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, equipment, and restricted purpose requirements. Name, address, and telephone of District contact person: Jason Franklin, Executive Director 300 S.W. 7th Street Renton, WA 98057 (425) 204-2394 Corrective action the auditee plans to take in response to the finding: The District will correct its internal process of identifying departments participating in federal grants at the inception of the work. This will ensure that proper internal control procedures will be applied to grant applications, claims filing, asset tracking, and program requirements. More specifically, the District will ensure the Technology Department processes grant applications and transactions through the Budget and Grants team to ensure the application of current functioning internal controls. Reviews will be conducted of Technology finance activity with strategic collaboration of task management. Anticipated date to complete the corrective action: 10/27/2023

View Audit 3819 Questioned Costs: $1

Finding 2236 (2022-008)

Significant Deficiency 2022

Enlace Chicago

IL

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

2022-008 Credit Cards Recommendation: We recommend that management follow established policies and procedures for submitting credit card receipts and obtaining supervisor's approval prior to credit card expenses being paid. All support and back up should be maintained. Views of Responsible Offici...

2022-008 Credit Cards Recommendation: We recommend that management follow established policies and procedures for submitting credit card receipts and obtaining supervisor's approval prior to credit card expenses being paid. All support and back up should be maintained. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Action taken in response to finding Enlace Chicago has and follows established policies and procedures for submitting credit card receipts and obtaining supervisor's approval prior to credit card expenses being paid. We were not able to find certain cc holder documentation due to misfiling, but no credit card payment is processed without documentation. A process of signing out filed documentation has been created to establish a system of documenting when a filed document needs to be pulled. We will also improve on the consistency of documenting review and approved by process. Name of the contact person responsible for corrective action: Laura Velazques, Director of Budget and Planning and Myriam Quezada, Assistant Controller Planned completion date for corrective action plan: June 30, 2023For questions regarding this plan, please call Marcella Rodriguez, Co-Executive Director, at 708-577-3373.

View Audit 3817 Questioned Costs: $1

Finding 2235 (2022-007)

Significant Deficiency 2022

Enlace Chicago

IL

Reporting Significant Deficiency Internal Control / Segregation of Duties

Significant Deficiency Immigrant and Refugee Housing Assistance Project 2022-007 Reporting Recommendation: We recommend that management follow established policies and procedures for timely preparation of reports under program requirements financial reports. Documented timing of preparation and ap...

Significant Deficiency Immigrant and Refugee Housing Assistance Project 2022-007 Reporting Recommendation: We recommend that management follow established policies and procedures for timely preparation of reports under program requirements financial reports. Documented timing of preparation and approval should be maintained and documented. Views of Responsible Officials: There is no disagreement with this finding. Action taken in response to finding: Enlace Chicago has continued to review and approve reports prior to submission as required by the state agency. As stated in last year’s finding response, the attestation of review and approval is embedded in the report form provided by the grantor. We will continue to put forth best efforts to take a step further and document preparation and review on the report form to satisfy the internal process requirement. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Budget and Planning Planned completion date for corrective action plan: June 30, 2023

View Audit 3817

Finding 2232 (2022-006)

Material Weakness 2022

Enlace Chicago

IL

Allowable Costs / Cost Principles

Significant Deficiency Immigrant And Refugee Housing Assistance Project 21st Century Community Learning Centers 2022-006 Payroll Allocation Recommendation: We recommend that management follow established policies and procedures for the allocation of employee costs across the Organization's grants a...

Significant Deficiency Immigrant And Refugee Housing Assistance Project 21st Century Community Learning Centers 2022-006 Payroll Allocation Recommendation: We recommend that management follow established policies and procedures for the allocation of employee costs across the Organization's grants and programs. All supporting documentation of time sheets and allocation procedures should be maintained. Additionally, preparer and reviewer sign-offs should be documented with sign-offs and dates. Views of Responsible Officials: Enlace Chicago was unable to provide timesheets to our auditors for FY21 as we transitioned payroll providers in December of 2021. Despite assurances from the prior provider, at the time of request, they were unable to produce prior period timesheets. Despite our inability to generate the timesheets requested, Enlace Chicago requires all staff to complete timesheets in order to process payroll. Providing timesheets for future periods will not be an issue moving forward. Name of the contact person responsible for corrective action: Laura Velazquez, Director of Budget and Planning Planned completion date for corrective action plan: June 30, 2023.

View Audit 3817

Finding 2206 (2022-002)

Material Weakness 2022

Albia Community School District

IA

Internal Control / Segregation of Duties Reporting

The District will continue to review and evaluate staff assignments and areas where additional internal control is necessary. The District Office Manager and Administrative Assistant continue to learn new roles and divide responsibilities in the area of payroll processing, data entry, receiving and...

The District will continue to review and evaluate staff assignments and areas where additional internal control is necessary. The District Office Manager and Administrative Assistant continue to learn new roles and divide responsibilities in the area of payroll processing, data entry, receiving and general ledger at the District level. We are utilizing online payments for lunch accounts, registration and for some activities to reduce overall exposure with cash candling. We have also changed some roles for associates, secretaries and a kitchen assistant to ensure daily deposits, receipts and receipt entry are not under the control of one person.

View Audit 3787

Finding 2166 (2022-002)

Material Weakness 2022

Housing Authority of the City of Omaha

NJ

Questioned Costs HUD Housing Programs Eligibility

Finding Reference Number: 2022-001 Recommendation The Authority should ensure proper internal controls, which include timely monthly reconciliations of account balances, are in place to prevent material weaknesses from occurring. Reporting views of responsible officials Auditee agrees with the au...

Finding Reference Number: 2022-001 Recommendation The Authority should ensure proper internal controls, which include timely monthly reconciliations of account balances, are in place to prevent material weaknesses from occurring. Reporting views of responsible officials Auditee agrees with the auditor and management will be responsible for implementing the corrective action plan. Completion date or proposed completion date: December 31, 2023 Action(s) taken or planned on the finding Gary Hatfield is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring. Finding Reference Number: 2022-002 Recommendation We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Reporting views of responsible officials The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Chief Financial Officer who will implement the required safeguards and ensure that the Authority follows its Section 8 Administrative Plan and the HUD compliance requirements to remedy the aforementioned deficiencies. Completion date or proposed completion date: December 31, 2023 Action(s) taken or planned on the finding Gary Hatfield is responsible for ensuring proper internal controls are in place to prevent significant deficiencies and material weaknesses from occurring.

View Audit 3737 Questioned Costs: $1

Finding 2162 (2022-002)

Significant Deficiency 2022

Biostl

MO

Procurement, Suspension & Debarment

Finding No. 2022-002 Significant Deficiency Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Christina Green, Vice President of Finance and Human Resources, Procurement and Compliance Officer, to be hired, Grant Manager, to be hired Anticipated Completion Dat...

Finding No. 2022-002 Significant Deficiency Personnel Responsible For Corrective Action: Mike Higgins, Vice President of Development, Christina Green, Vice President of Finance and Human Resources, Procurement and Compliance Officer, to be hired, Grant Manager, to be hired Anticipated Completion Date: Completed Corrective Action Plan: Along with strengthening of reporting, the hiring of the dedicated Grants Coordinator position additionally improved controls related to procurement. Updated internal forms to document purchasing and classify procurement requirements were established and integrated with project management tools; new procurement templates were established; and improved repositories for cataloguing procurement materials and invoices were established. Additionally, in 2023, as noted above, BioSTL created a new position to ensure internal programmatic and financial control for grants – initiating the hiring of a new Grants Manager role that has already been posted to our website and recruiting has begun. This role will have more dedicated time and responsibility for internal controls and be responsible for oversight and effectiveness of all internal controls – above and beyond existing and previous supervisory review from the VP, Development and SVP, Programs. In 2024, a Procurement and Compliance Officer role is being added to further ensure internal controls for all contracts are adhered to and to provide further structure around the processes. The required language provided by the EDA is included in all BioSTL contracts as specifically noted by the EDA. There is not a call out specifically to suspension and disbarment, however, the language provided by the EDA entails these aspects. Moving forward, the suspension and disbarment language will now be included specifically in all contracts and has been added into the contract template.

View Audit 3729

Finding 2161 (2022-001)

Significant Deficiency 2022

Biostl

MO

Subrecipient Monitoring Reporting Significant Deficiency

Finding No. 2022-001 Significant Deficiency Personnel Responsible For Corrective Action: Mike Higgins, VP of Development; Ben Johnson, SVP of Programs; and Grant Manager, to be hired Anticipated Completion Date: Completed Corrective Action Plan: Of the six reports selected for testing, the specific ...

Finding No. 2022-001 Significant Deficiency Personnel Responsible For Corrective Action: Mike Higgins, VP of Development; Ben Johnson, SVP of Programs; and Grant Manager, to be hired Anticipated Completion Date: Completed Corrective Action Plan: Of the six reports selected for testing, the specific grant report found to be 7 days after the deadline fell at a time of employee transition – when a prior employee with responsibility for report filing moved on to another role at another company and a newly created Grants Coordinator position was filled to take over responsibility. Given the timing of the on-boarding process and education around EDA processing, the report was submitted 7 days late. It should be noted that all subsequent reports were submitted timely. With the establishment of the dedicated Grants Coordinator position (the timing of which coincided with the timing of the cited report), improved controls came into place – namely: 1) dual supervisory review of reports between the direct supervisor of theGrants Coordinator position and the legacy supervisory role of the Senior Vice President Programs; 2) a clearer timeline of reporting was established with project management systems and document repositories (e.g., Salesforce, Asana, and Box) with additional reminders in place to ensure adequate notice is provided to individuals responsible for providing information; and 3) there is a structured follow-up process, at periodic intervals, for report review to ensure deadlines are met. Additionally, in 2023, BioSTL created another new position to ensure internal programmatic and financial control for grants – initiating the hiring of a new Grants Manager role that has already been posted to our website and recruiting has begun. This role will have more dedicated time and responsibility for internal controls and be responsible for timeliness on all reporting and to monitor against all compliance requirements – above and beyond existing and previous supervisory review from the VP, Development and SVP, Programs.

View Audit 3729

Finding 2157 (2022-002)

Material Weakness 2022

Easton Valley Community School District

IA

Internal Control / Segregation of Duties Reporting

The District will continue to look into our internal controls and review procedures to ensure we are operating efficiently as possible with limited staff numbers.

View Audit 3728

Finding 2123 (2022-001)

Significant Deficiency 2022

Housing Authority of Plainfield

NJ

In response to audit finding 2022-001 cited in the Authority’s audit report as of December 31, 2022, please be advised that it is the Authority’s policy is to follow appropriate procedures with respect to properly maintaining tenant files of the Housing Choice Vouchers program. However, during ye...

In response to audit finding 2022-001 cited in the Authority’s audit report as of December 31, 2022, please be advised that it is the Authority’s policy is to follow appropriate procedures with respect to properly maintaining tenant files of the Housing Choice Vouchers program. However, during year 2022 our Housing Manager resigned and has not been replaced as yet. Her responsibilities were assumed by the Assistant Housing Manager who was not as experienced nor fully trained to assume the responsibilities. Because of the shortage in personnel as a result of the Housing Manager’s resignation, normal monitoring procedures were not performed which led to the deficiencies cited in the audit report.

View Audit 3669

Finding 2123 (2022-001)

Significant Deficiency 2022

Housing Authority of Plainfield

NJ

Subsequently, the Assistant Housing Manager has received and will continue the receive on-going training in procedures of the Housing Choice Vouchers program. We will also continue our monitoring procedures by periodically examining an appropriate selection of tenant files to ensure compliance with...

Subsequently, the Assistant Housing Manager has received and will continue the receive on-going training in procedures of the Housing Choice Vouchers program. We will also continue our monitoring procedures by periodically examining an appropriate selection of tenant files to ensure compliance with the Program’s requirements. Furthermore, we will seek to hire a new, experienced Housing Manager.

View Audit 3669

Finding 2123 (2022-001)

Significant Deficiency 2022

Housing Authority of Plainfield

NJ

As the disruption is service caused by the pandemic comes to an end, we anticipate that we will be able to perform Housing Quality Inspections in accordance with the Housing Choice Vouchers program.

View Audit 3669

Corrective Action Plans

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