Corrective Action Plans

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Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these r...
Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these reports reflect actual amounts posted to internal accounts rather than estimated expenditures, they are used to cross-reference program expenses and support billing submissions. Buckner also implemented additional levels of review to ensure the Program Manager completes billing documentation accurately, the Program Director reviews followed by final review by the Finance Administrator. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective August 20, 2025, and onward
Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calcula...
Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calculate allocations and reduce errors. Each month, the Finance Administrator calculates allocations based on time worked, provides them to the Program Director for billing, and reviews state billing submissions to confirm accuracy. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective June 20, 2025, and onward
Corrective Action Plan Actions Planned – The HRA will implement and monitor controls to ensure policies and procedures related to tenant eligibility determinations and recertifications are consistently followed. Official Responsible – Sarah Abe, HRA Administrator Planned Completion Date – December 3...
Corrective Action Plan Actions Planned – The HRA will implement and monitor controls to ensure policies and procedures related to tenant eligibility determinations and recertifications are consistently followed. Official Responsible – Sarah Abe, HRA Administrator Planned Completion Date – December 31, 2026 Disagreement With or Explanation of Finding – The HRA agrees with this finding. Plan to Monitor – Sarah Abe, HRA Administrator, will oversee the process to ensure tenant checklists for eligibility are completed and a separate program specialist is assigned to review and sign off on the checklists.
Management has reviewed this finding and indicated it will review and revise its procedures to ensure corrective action is taken.
Management has reviewed this finding and indicated it will review and revise its procedures to ensure corrective action is taken.
FINDING 2025-002: Audit report deadline Response: Finance will improve year-end reporting and closing procedures to help ensure the financial information is completed on time and future audit deadlines are met.
FINDING 2025-002: Audit report deadline Response: Finance will improve year-end reporting and closing procedures to help ensure the financial information is completed on time and future audit deadlines are met.
View of Responsible Officials The Foundation did indicate to the subrecipients that the subawards were federal funds and outlined terms and uses associated with the subawards. The Foundation also monitored and reviewed subrecipient reimbursement submissions and corresponding support to ensure reques...
View of Responsible Officials The Foundation did indicate to the subrecipients that the subawards were federal funds and outlined terms and uses associated with the subawards. The Foundation also monitored and reviewed subrecipient reimbursement submissions and corresponding support to ensure requests complied with the terms and conditions of the subaward. Action planned: • Develop and implement written policies and procedures that: o Establish a formal process for identifying all subrecipients receiving federal awards and determining which ones meet the single audit threshold. o Define procedures to ensure subrecipients complete the required audits under 2 CFR 200 Subpart F. o Outline steps for reviewing subrecipient audit reports, identifying findings related to the Foundation's subawards, and ensuring the subrecipient develops a corrective action plan for those findings. o Formalize the process for the Foundation to issue a management decision on relevant findings within the required six-month timeframe. o Include procedures for considering sanctions if a subrecipient does not comply with audit requirements. • Perform a lookback review: o Review existing subrecipient agreements to identify any instances of non-compliance with past monitoring requirements and ensure the necessary follow-up actions (e.g., obtaining audit reports, issuing management decisions) are completed for those periods. • Establish a monitoring system: o Implement a tracking system (e.g., a spreadsheet or software) to monitor the status of subrecipient audits, deadlines for management decisions, and follow-up on corrective actions. o Designate a responsible individual/department to oversee the subrecipient monitoring process and ensure all requirements are met consistently. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. The Finance Manager will be responsible for overseeing the implementation and ongoing compliance of the new subrecipient monitoring procedures. Timeline: • February 2026: Policy approved and implemented, and lookback review of prior periods completed. • Ongoing: Continuously monitor subrecipients and ensure timely action is taken on all future audit findings.
View of Responsible Officials In partnership with the federal program officers assigned to the three federal grant awards, the Foundation filed all required reporting available in SAM.gov by the specified due dates. Action taken: Following the government reopening, the Foundation reached out multipl...
View of Responsible Officials In partnership with the federal program officers assigned to the three federal grant awards, the Foundation filed all required reporting available in SAM.gov by the specified due dates. Action taken: Following the government reopening, the Foundation reached out multiple times to the federal program officers to clarify and determine the requirements for proper reporting in accordance with the grant agreements. The response received was that they were not familiar with the Federal Funding Accountability Transparency Act and suggested filing the report independently. Action planned: Based on the response, the Foundation will file the required reporting. Specific steps: The Foundation will work with the U.S. Department of Education to ensure the proper steps for filing the missing reports are taken and all required information is submitted. In addition, the Foundation will develop and implement a written policy to provide clear guidance on FFATA reporting responsibilities, including the criteria for identifying reportable subawards and the required submission process and deadlines alongside an internal review process. Responsibility: • The Director of Development, Chief Operating Officer, and Finance Manager will ensure the three FFATA reports are filed. • The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. Timeline: • The Foundation will file required reporting alongside due dates outlined by Federal Funding Accountability Transparency Act. • Policy approved and implemented by March 2026.
View of Responsible Officials The Foundation is of the opinion that finding number 2025-001 for Cash Management is not applicable to the Equipment for Skilled Trades Training Programs as part of the Virginia Infrastructure Academy under ALN 84-116Z as requests for advance payments were limited to th...
View of Responsible Officials The Foundation is of the opinion that finding number 2025-001 for Cash Management is not applicable to the Equipment for Skilled Trades Training Programs as part of the Virginia Infrastructure Academy under ALN 84-116Z as requests for advance payments were limited to the minimum amounts needed and were timed with actual, immediate cash requirements to carry out the purpose of the approved programs and projects. With regards to College and Career Success for Foster Youth through Work-based Learning Opportunities and Coaching Support under ALN 84-116Z, the Foundation was notified by the U.S. Department of Education on September 12, 2024, that unused principal be returned. On September 25, 2024, the funds in the amount of $753,800 were refunded by wire transfer. This was the only notification the Foundation received from the U.S. Department of Education; no other notification was received regarding other advance payments made during the fiscal year. With regards to Improving the Quality of Early Childhood Educators under ALN 84-116Z, the Foundation did not receive any notification from the U.S. Department of Education requesting that advance payments be returned. In all instances of advance payments, the Foundation maintained funds in interest bearing accounts as outlined in the respective agreements for the three federal awards. With regards to the requests for advances that were made on a quarterly basis, the respective agreements for the three federal awards do not explicitly outline a timeframe for advance payments, nor did these advances trigger the federal government’s threshold for excessive drawdown. Estimated quarterly advance payments were made from the uncertainty of the U.S. Department of Education clawing back award funding while ensuring sufficient cash on hand to support approaching distributions to students and colleges and mitigating risk to the Foundation covering respective distributions with its own funds. Brown Edwards shared the suggested interpretation is a one-to-three-day timeframe between drawdown and distribution. Action taken: The Foundation calculated advance payment balances as of November 4, 2025, and issued respective returns to the U.S. Department of Education on November 5, 2025. Subsequent drawdowns have been made on a reimbursement basis. Action planned: The Foundation will revise its policies and procedures for requesting federal funds to ensure that requests for advance payments be limited to the minimum amounts needed and be timed with actual, immediate cash requirements to carry out the purpose of approved programs and projects. Specific steps: The Foundation will develop and implement a written policy requiring a documented review of immediate cash needs before any federal fund drawdown request is submitted and establishing a process to request funds on a reimbursement basis or just-in-time advance basis to align drawdowns with actual disbursements. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. Timeline: Policy approved and implemented by February 2026.
Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized pur...
Recommendation: CLA recommends the Organization review their procurement and suspension and debarment policies to ensure they are compliant with Uniform Guidance requirements. CLA also recommends emphasizing the importance of following those standards and established policies with all authorized purchasers within the Organization, including verifying that suspension and debarment checks are performed and documented prior to entering into covered transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization plans to review its procurement and suspension and debarment policies and assess necessary changes to be in accordance with Uniform Guidance going forward. Name(s) of the contact person(s) responsible for corrective action: Trent Henning, Executive Director, and Luke Smetters, Director of Operations Planned completion date for corrective action plan: December 31, 2026
Assistance Listing No. 21.027 Recommendation: CLA recommends that the Organization implement procedures for verifying that performance reports are reviewed and all reports are submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action ta...
Assistance Listing No. 21.027 Recommendation: CLA recommends that the Organization implement procedures for verifying that performance reports are reviewed and all reports are submitted timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has implemented procedures subsequent to year-end to ensure that performance reports are reviewed prior to submission and that all reports are submitted timely going forward. Name(s) of the contact person(s) responsible for corrective action: Trent Henning, Executive Director, and Luke Smetters, Director of Operations Planned completion date for corrective action plan: December 31, 2026
Management Response/Corrective Action Plan: The Finance Office has a monthly task list to ensure reports and other required tasks are completed in a timely manner. Quarterly reports for the Apprenticeship Program grant have been added for future quarters. This practice will be followed for future gr...
Management Response/Corrective Action Plan: The Finance Office has a monthly task list to ensure reports and other required tasks are completed in a timely manner. Quarterly reports for the Apprenticeship Program grant have been added for future quarters. This practice will be followed for future grants.
Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of...
Management Response/Corrective Action Plan: The School Department reviewed both the federal and local procurement policies with the administrative team in December of 2024. A memo was also sent to all administrators specifically discussing the suspension and debarment procedures regarding the use of federal funds. Since then, the School Board has since reviewed both policies and has revised threshold amounts and other language per the advice of legal counsel and MSMA. Now adopted, the policies have been shared with administration to ensure that purchasing procedures are followed and will be reviewed regularly. If there is any chance of federal funds being used for a purchase, the Department will follow the federal procurement requirements. Municipal staff attempted to follow Treasury guidance to administer the State and Local Fiscal Recover Fund (SLFRF) grant and interpreted the “Revenue Replacement” category of expenditure to be exempt from nearly all of the usual federal grant requirements, including the Suspension and Debarment verification step. More recently, the interpretation of the rule changed, but not before certain projects had been initiated, in which the verification step had been missed. Going forward, this will not be an issue as all SLFRF monies have been expended.
FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity...
FA 2025-001 Improve Controls over Procurement and Suspension and Debarment Compliance Requirement: Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Agriculture Pass-Through Entity: Georgia Department of Education AL Numbers and Titles: 10.553 School Breakfast Program 10.555 National School Lunch Program Federal Award Numbers: 255GA324N1199 (Year: 2025) Questioned Costs: $7536 Description: A review of expenditures charged to the Child Nutrition Cluster revealed that the School District's internal control procedures were not operating appropriately to ensure that the School District's procurement and suspension and debarment procedures were followed. Corrective Action Plans: An annual Invitation for Bid (IFB) for equipment repair services will be issued to a minimum of two or more vendors for quotes. Final vendor selection will be made by the SNP Director and communicated to the Board for approval. These steps will ensure compliance with procurement regulations and proper documentation of services. In addition, the Federal Programs Manual will be amended to state that all vendors are reviewed annually to verify their suspension and debarment status. Estimated Completion Date: 6/30/2026 Contact Person: Joshua Worth , CFO Telephone: 912-699-7030 Email: joshua.worth@jeff-davis.k12.ga.us
Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Plan, Uniform Guidance and the compliance supplement. Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the audito...
Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Plan, Uniform Guidance and the compliance supplement. Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies included within the Plan are being followed. Daniel Lyons, Executive Director, is responsible for implementing this corrective action by June 30, 2026.
A designated Finance staff member with knowledge of the Uniform Guidance requirements will be responsible for overseeing SEFA preparation for each fiscal year-end. A grant-by-grant SEFA reconciliation will be completed prior to yearend close, with particular attention to period-end cutoff. The SEFA ...
A designated Finance staff member with knowledge of the Uniform Guidance requirements will be responsible for overseeing SEFA preparation for each fiscal year-end. A grant-by-grant SEFA reconciliation will be completed prior to yearend close, with particular attention to period-end cutoff. The SEFA will be independently reviewed by the Finance Director and compared to grant expenditure reports before the audit commences. Management will engage its external accountants earlier in the year-end close process.
At the start of each fiscal year, the Finance Director will prepare a submission timeline working backward from the March 31 FAC deadline, establishing interim milestones for year-end close, draft financial statement preparation, management review, and auditor fieldwork. Progress against the submiss...
At the start of each fiscal year, the Finance Director will prepare a submission timeline working backward from the March 31 FAC deadline, establishing interim milestones for year-end close, draft financial statement preparation, management review, and auditor fieldwork. Progress against the submission timeline will be monitored by the CEO and reported to the Board of Directors on a quarterly basis. Management will engage its external auditors earlier in the process and ensure adequate finance staffing is maintained prior to the fiscal yearend close.
Condition Identified: During the audit review of 22 tenant files, 8 files contained errors resulting in miscalculated tenant rent. The audit further identified that the Commission did not have an adequate secondary review process for annual rent certifications, resulting in errors in tenant rent cal...
Condition Identified: During the audit review of 22 tenant files, 8 files contained errors resulting in miscalculated tenant rent. The audit further identified that the Commission did not have an adequate secondary review process for annual rent certifications, resulting in errors in tenant rent calculations and missing documentation. Corrective Action Plan The Albion Housing Commission acknowledges the findings and is committed to strengthening internal controls and improving oversight procedures to ensure compliance with HUD regulations and accuracy in tenant rent determinations. The employee primarily responsible for maintaining and processing tenant files during the audit period is no longer employed by the Commission. Management has since evaluated its procedures and is implementing corrective measures to prevent future occurrences. Planned Corrective Actions 1. Implementation of Secondary Review Process Effective immediately, all annual and interim rent certifications will undergo a mandatory second-party review by management or a designated qualified staff member prior to final approval. 2. Third Party File Review 3. Staff Training and Management Improvement 4. Strengthening Internal Controls 5. Monitoring and Compliance
GRAMBLING HOUSING AUTHORITY 300 B.T. Woodard Circle Grambling, LA 71245 Phone No. (318) 247-6035 Fax No. (318) 247-6554 HOUSING AUTHORITY OF GRAMBLING, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2025 Corrective Action Plan Finding: Finding-2025-001-Late Filing of Report- Reporting Con...
GRAMBLING HOUSING AUTHORITY 300 B.T. Woodard Circle Grambling, LA 71245 Phone No. (318) 247-6035 Fax No. (318) 247-6554 HOUSING AUTHORITY OF GRAMBLING, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2025 Corrective Action Plan Finding: Finding-2025-001-Late Filing of Report- Reporting Condition: The audit report was due to the Legislative Auditor by March 31, 2026, six months after audit year end. Corrective Action Planned We will comply with the auditor’s recommendation. Person responsible for corrective action: Sharon Dixson, Executive Director Telephone: (318) 247-6035 Housing Authority of Grambling, Louisiana Fax: (318) 247-6554 596 College Avenue Grambling, LA 71245 Anticipated Completion Date- March 31, 2027
Finding 1217738 (2025-003)
Material Weakness 2025
Finding 2025-003 – Untimely Return of Security Deposits Name of contact person: Lisa Fischer, (Chief Operating Officer) Corrective action: Management agrees with the finding and has implemented procedures to monitor tenant move-outs, document amounts due to former tenants, and issue refund checks in...
Finding 2025-003 – Untimely Return of Security Deposits Name of contact person: Lisa Fischer, (Chief Operating Officer) Corrective action: Management agrees with the finding and has implemented procedures to monitor tenant move-outs, document amounts due to former tenants, and issue refund checks in a timely manner. Proposed completion date: Management has corrected the finding.
Finding 1217731 (2025-002)
Material Weakness 2025
FINDING 2025-002: Unauthorized receipt of COVID-19 Supplemental Payments (CSP) Corrective action - The applications for reimbursement for program periods 1 through 3 were made in error. Management has contacted HUD and is awaiting a response.
FINDING 2025-002: Unauthorized receipt of COVID-19 Supplemental Payments (CSP) Corrective action - The applications for reimbursement for program periods 1 through 3 were made in error. Management has contacted HUD and is awaiting a response.
Finding 1217726 (2025-001)
Material Weakness 2025
FINDING 2025-001: Unauthorized fees paid by the Corporation Corrective action - Management has reached out to HUD to determine a course of action and are waiting for a response.
FINDING 2025-001: Unauthorized fees paid by the Corporation Corrective action - Management has reached out to HUD to determine a course of action and are waiting for a response.
Internal Control Over Reporting Department of Human Services – Grants to States for Medicaid – Assistance Listing No. 93.778 Recommendation: We recommend that the County enact controls to assure employees included in grant are included in reporting submitted. Explanation of disagreement with audit f...
Internal Control Over Reporting Department of Human Services – Grants to States for Medicaid – Assistance Listing No. 93.778 Recommendation: We recommend that the County enact controls to assure employees included in grant are included in reporting submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement procedures to ensure that all reports are reviewed prior to submission. Names of the contact person responsible for corrective action: Pat Paquin, Finance Manager Planned completion date for corrective action plan: December 31, 2026
Finding 1217684 (2025-003)
Material Weakness 2025
We will ensure that security deposits collected will be transferred to the security deposit bank account timely.
We will ensure that security deposits collected will be transferred to the security deposit bank account timely.
Finding 1217683 (2025-002)
Material Weakness 2025
We will develop a procedure to ensure the required monthly deposits to the replacement reserve are made timely.
We will develop a procedure to ensure the required monthly deposits to the replacement reserve are made timely.
Findings #2025-004 and #2025-006 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 –...
Findings #2025-004 and #2025-006 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, 93.566, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Passed through Texas Office for Refugees: 10/01/24 – 09/30/25, FFY2025-27946V-ASA RSS, 10/01/24 – 09/30/25, FFY2025-27946V-AUSAA-RSS, 10/01/24 – 09/30/25, FFY2025-27946V-CMA, 10/01/24 – 09/30/25, FFY2025-27946V-RSS, Passed through United States Conference of Catholic Bishops: 10/01/24 – 09/30/25, 25RSI13A, Passed through U. S. Committee for Refugees: 10/01/24 – 09/30/25, RHP-2025-YMCA-Houston TX-03, 93.567, Refugee and Entrant Assistance Voluntary Agency Programs, Passed through U. S. Committee for Refugees and Immigrants: 10/01/24 – 09/30/25, 2502VARVMG, 10/01/23 – 09/30/24, 2402VARVMG, 93.676, Unaccompanied Alien Children Program, Passed through U. S. Committee for Refugees and Immigrants: 01/01/25 – 12/31/25, 90ZU0630-02. Condition and context: During our testing of the accuracy of accounts payable cutoff and the testing of allowable costs charged to major programs, the following exceptions were identified for expenses recorded in the incorrect period: 3 of 19 subsequent disbursement transactions tested were recorded in the incorrect accounting period. Refugee and Entrant Assistance State/Replacement Designee Administered Programs (ALN 93.566) – 3 out of 40 transactions tested were recorded to the incorrect accounting period. Unaccompanied Alien Children Program (ALN 93.676) – 1 out 40 transactions tested was recorded in the incorrect accounting period. Refugee and Entrant Assistance Voluntary Agency Programs (ALN 93.567) – 1 out of 40 transactions tested was recorded in the incorrect accounting period. Recommendation: Policies and procedures should be enhanced for proper identification of the period that expenses relate to so that expenses will be recorded in the correct accounting period for financial statement reporting and for billing allowable costs to federal programs. Planned corrective action: Management acknowledges the deficiency identified related to the precision of procedures to ensure expenses are recorded in the appropriate accounting period. Processes were in place and operated to identify and record expenses in the correct period, and management’s review procedures are designed to capture all material items for financial reporting and program compliance purposes. The exceptions identified through audit testing represent a limited number of timing differences in a high-volume environment, primarily related to the timing of invoice receipt and processing, and were not material individually or in the aggregate. These items were recorded in the subsequent period in the normal course of operations and do not reflect a systemic breakdown in controls. In response, management has reinforced month-end cutoff procedures, including enhanced review of subsequent disbursements and clearer expectations around accrual identification and invoice timing. Management will continue to monitor cutoff procedures to ensure expenses are recorded in the appropriate period with an appropriate level of precision while maintaining timely vendor payment practices. Responsible officer: Lauren Rome, VP of Financial Operations/Interim CFO. Estimated completion date: June 15, 2026
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