Corrective Action Plans

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2025-002 Student Financial Assistance Cluster – Assistance Listing No. 84.SFA Condition: The disbursement date being reported to COD by the College did not match the disbursement date shown on student account detail reports. Recommendation: Management should review and update internal control proces...
2025-002 Student Financial Assistance Cluster – Assistance Listing No. 84.SFA Condition: The disbursement date being reported to COD by the College did not match the disbursement date shown on student account detail reports. Recommendation: Management should review and update internal control processes over COD reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This system error has been corrected and additional training offered to bursar’s office. Name(s) of the contact person(s) responsible for corrective action: Wendy Davis Planned completion date for corrective action plan: 06/26/2026
2025-001 Student Financial Assistance Cluster – Assistance Listing No. 84.SFA Condition: The College did not report information to NSLDS in a timely manner, enrollment was not being certified every 60 days, and information being reported was inaccurate. Recommendation: Management should review and u...
2025-001 Student Financial Assistance Cluster – Assistance Listing No. 84.SFA Condition: The College did not report information to NSLDS in a timely manner, enrollment was not being certified every 60 days, and information being reported was inaccurate. Recommendation: Management should review and update internal control processes over NSLDS reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The college’s financial aid team has scheduled time for NSLDS reporting until the National Student Clearinghouse reporting has been confirmed by the Department of Education. Name(s) of the contact person(s) responsible for corrective action: Wendy Davis Planned completion date for corrective action plan: 06/26/2026
Corrective Action Plan Management will review and revise policies and procedures related to verifying that correct actual wage rates and related benefits are used to request reimbursements from federal awards. Person Responsible for Implementation: Sarah Unruh, Program Manager of Accounting. Telepho...
Corrective Action Plan Management will review and revise policies and procedures related to verifying that correct actual wage rates and related benefits are used to request reimbursements from federal awards. Person Responsible for Implementation: Sarah Unruh, Program Manager of Accounting. Telephone (816) 595-4269, Email sunruh@clayhealth.com Implementation Date: Implementation of the corrective action plan has been implemented as policies and procedures have been updated and revised. In addition, the Health Center has informed and has been working with the Missouri Department of Health. The April 2026 reimbursement request was modified and corrected for the errors.
Finding 2025-003 — Questioned Costs Related to Expenditures Exceeding Approved Grant Budget Corrective Action Plan Management acknowledges that expenditures under the OASH HEALS award exceeded the approved grant budget by $8,158.59. To prevent similar instances in the future and strengthen complianc...
Finding 2025-003 — Questioned Costs Related to Expenditures Exceeding Approved Grant Budget Corrective Action Plan Management acknowledges that expenditures under the OASH HEALS award exceeded the approved grant budget by $8,158.59. To prevent similar instances in the future and strengthen compliance with Uniform Guidance, management will implement the following corrective actions:  Implement monthly budget-to-actual reviews for each federal award to monitor expenditures against approved budget categories and award ceilings.  Establish a monitoring process with alerts when expenditures approach approved budget limits, allowing management to take timely corrective action.  Require prior written approval from the grantor before incurring expenditures that would exceed approved budget limits or require budget revisions.  Assign responsibility to the Accounting Manager to review grant expenditures monthly and report any potential budget overruns to the Executive Director before additional costs are incurred.  Work with OASH to resolve the current over-award of $8,158.59 and retain documentation of the agency's allowability determination and any required corrective actions. Responsible Party Executive Director; Accounting Manager; Program Directors/Managers. Completion Date Budget monitoring procedures implemented immediately; resolution with OASH targeted by August 31, 2026. Questioned Costs $8,158.59
Finding 2025-002 — Subrecipient Monitoring and Required Documentation Corrective Action Plan During fiscal year 2025, the Organization did not consistently obtain or retain: (i) written pre-award risk assessments for subrecipients; (ii) Single Audit reports for subrecipients expending $750,000 or mo...
Finding 2025-002 — Subrecipient Monitoring and Required Documentation Corrective Action Plan During fiscal year 2025, the Organization did not consistently obtain or retain: (i) written pre-award risk assessments for subrecipients; (ii) Single Audit reports for subrecipients expending $750,000 or more in federal awards; or (iii) Unique Entity Identifier (UEI) confirmations via SAM.gov, as required under 2 CFR §§200.331–200.333. The affected pass-through activity totaled approximately $542,500 across three major federal programs (CFDA 93.310, 93.137, and 93.185). Management will implement the following corrective actions: • Establish a centralized subrecipient monitoring file for each subaward relationship, organized by program and award year, and confirm each subrecipient’s active UEI registration in SAM.gov at the time of award and annually thereafter. • Conduct and document a formal pre-award risk assessment using the Subrecipient Risk Assessment Questionnaire, covering prior federal experience, financial stability, internal controls, audit history, and SAM.gov registration. Perform and document a written subrecipient-vs.-contractor determination consistent with 2 CFR §200.331 before entering into or renewing any agreement. • Ensure all subaward agreements include the required award information, compliance responsibilities, reporting requirements, record retention provisions, and audit access provisions under 2 CFR §200.332. • Use the Subrecipient Desk Review Checklist to document quarterly monitoring, including review of progress reports, invoices, deliverables, indirect cost calculations, and personnel timesheets. Require supporting documentation before approving payments. • Maintain an annual Single Audit tracking log to verify federal expenditure thresholds and document collection, review, and resolution of any subrecipient audit findings. • Train program managers and accounting personnel on Uniform Guidance subrecipient monitoring requirements and present updated procedures to the Board/Finance Committee for formal adoption. Responsible Party Executive Director; Accounting Manager; Program Managers; Treasurer/Finance Committee. Completion Date Management has already begun implementation. Full implementation of the monitoring checklist and centralized files expected by September 30, 2026. Review of open FY2025/FY2026 subrecipient files and documentation requests by September 30,2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The Organization has not deposited residual receipts account funds into accounts insured by the Federal Deposit Insurance Corporation (FDIC). Rather, such funds are deposited in cash accounts with a large brokerage firm and are insured by the Securities Investor Protection Corporation (SI...
Condition: The Organization has not deposited residual receipts account funds into accounts insured by the Federal Deposit Insurance Corporation (FDIC). Rather, such funds are deposited in cash accounts with a large brokerage firm and are insured by the Securities Investor Protection Corporation (SIPC), which is not a government agency. Auditors’ Recommendation: The Organization should transfer these balances to a participating financial institution. Views of Responsible Officials and Planned Corrective Actions: During the year ended June 30, 2026, the Organization plans to transfer the residual receipts reserve account funds to an FDIC-Insured certificate of deposit.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Condition: The Organization has not deposited residual receipts account funds into accounts insured by the Federal Deposit Insurance Corporation (FDIC). Rather, such funds are deposited in cash accounts with a large brokerage firm and are insured by the Securities Investor Protection Corporation (SI...
Condition: The Organization has not deposited residual receipts account funds into accounts insured by the Federal Deposit Insurance Corporation (FDIC). Rather, such funds are deposited in cash accounts with a large brokerage firm and are insured by the Securities Investor Protection Corporation (SIPC), which is not a government agency. Auditors’ Recommendation: The Organization should transfer these balances to a participating financial institution. Views of Responsible Officials and Planned Corrective Actions: During the year ended June 30, 2026, the Organization plans to transfer the residual receipts reserve account funds to an FDIC-Insured certificate of deposit.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
The Organization has made the necessary accounting adjustments for the year ended June 30, 2025 on the September 2025 voucher request.
The Organization has made the necessary accounting adjustments for the year ended June 30, 2025 on the September 2025 voucher request.
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...
Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.
Finding 2024‐002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Condition: For individuals charged to this program who also have time charged to other programs there were no timesheets or other evidence to support the allocation to the program was based on actual time incurre...
Finding 2024‐002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Condition: For individuals charged to this program who also have time charged to other programs there were no timesheets or other evidence to support the allocation to the program was based on actual time incurred to the program but was instead based on the budgeted amounts for those individuals. Corrective Action Planned: Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping and the salary and wage allocations to the federal award are appropriately documented and accurately reflect the level of effort of work performed. Objective: To establish an environment of internal controls and accountability within the Chicago Area Command Finance and Social Services teams specific to the following: Required Action: Ensure appropriate policies and procedures are created and implemented and that accurate documentation is in place to assume responsibility and accountability to meet or exceed expectations. Social Services - Implement and document a process for all individuals assigned to multiple contracts to keep time logs of hours worked on each, with a monthly review that the hours align with the budgeted amounts. In the event hours diverge, workload will be adjusted or a budget adjustment will be requested. Finance - Implement and document a process to conduct an internal spot check at least quarterly by selecting a sample of time sheets from various contracts to ensure that proper procedures and documentation have been implemented and tracked appropriately. Meet with Social Services at least quarterly to confirm time log status for all programs administered by Chicago City Fund. Anticipated Completion Date: August 31, 2026 Name of Contact Person Responsible for the Plan: Shari Koehler, Divisional Chief Finance and Technology Director
Identifying Number: 2025-001 Finding: The data collection form for the year ended June 30, 2025, was filed after the March 31, 2026, deadline, making it a late submission. Corrective Actions Taken or Planned: Envision Unlimited will schedule and complete future external audits in a manner that will ...
Identifying Number: 2025-001 Finding: The data collection form for the year ended June 30, 2025, was filed after the March 31, 2026, deadline, making it a late submission. Corrective Actions Taken or Planned: Envision Unlimited will schedule and complete future external audits in a manner that will allow timely reporting of the Single Audit. Contact people responsible for corrective action is Chris Nordloh, CFO and Mary Ann Livovich-Tomondi, Controller. The anticipated completion date is June 30, 2026.
2025-003 – Material Weakness and Material Noncompliance – Cash Management – Cash Request Recommendation We recommend that the organization implement and enforce policies and procedures, to ensure that all federal fund requests are supported by documented, allowable expenditures. Staff responsible fo...
2025-003 – Material Weakness and Material Noncompliance – Cash Management – Cash Request Recommendation We recommend that the organization implement and enforce policies and procedures, to ensure that all federal fund requests are supported by documented, allowable expenditures. Staff responsible for grant management should receive training in federal compliance requirements, and all reimbursement requests should be reviewed and approved by a qualified financial officer prior to submission. Action Taken CHASS management concurs with the audit findings and will put the following corrective action plan in place to mitigate this finding in the future: Implement separation of expenditures that are funded by grants will be recorded only related to that grant. Implementation of separating only revenue and expenditures to draw down grants will be reflected in general ledger for those grants. Implementation of grant 999 to reflect all other expenditures and revenues that are not covered by the grants. Staff will receive training in federal compliance requirements, and all reimbursement. Reconciliation of grants will be done at least once a quarter by grant clerk and will submit documentation of findings to CFO/ designated staff individuals. The CFO will only draw down funds when the general ledger supports the grant expenses. Monthly general ledgers will serve as backup documentation. CEO approval is required before any drawdown is completed. Responsible Parties: Feliz Valbuena, Chief Executive Office and Angela Salgado, Interim Chief Financial Officer
Finding Number: 2025-001, 2024-001, 2023 01, 2022-001, 2021-001: Material Weakness and Material Noncompliance - Sliding Fee Recommendation We recommend that sliding fee applications be completed for each sliding fee patient. Procedures should be implemented to verify that applications are completed ...
Finding Number: 2025-001, 2024-001, 2023 01, 2022-001, 2021-001: Material Weakness and Material Noncompliance - Sliding Fee Recommendation We recommend that sliding fee applications be completed for each sliding fee patient. Procedures should be implemented to verify that applications are completed before the encounter is billed. Sliding fee discounts per policy should be agreed upon in the billing system to ensure the proper discounts are entered into and updated. In addition, the Center could consider increasing its internal sampling throughout the year to verify that sliding fee applications are obtained, completed, and agree to the discount applied. Action Taken CHASS management concurs with the audit findings and will put the following corrective action plan in place to mitigate this finding in the future. CHASS has developed and implemented a comprehensive series of improvements. After the last fiscal audit (March 2025), it was discovered that the EPIC system had the old Sliding Fee Schedule that had not been updated since 2022 (https://aspe.hhs.gov/poverty-guidelines ). The new sliding fee schedule was implemented in the EPIC system, and since then, the fee schedule has been updated as the government guidelines change (February). Continuing the current implementation will reinforce the process of verification of patients receiving a sliding fee discount. To achieve this, the Center's Customer Service team now generates personalized labels for each eligible patient and cross-checks their entries by the end of each day. The Supervisor/Team Leader will continue to conduct a second review of the labels to ensure the accuracy of the data for each patient utilizing the sliding scale discount program. This review also includes the actual charges in EPIC and the discount being verified with CPT Tables. Third implementation, Clinical Intern Staff will be responsible for reviewing encounters to ensure that the CPT code is correct and charges on patients' accounts have the appropriate sliding scale fee applied. They will be utilizing direct reports from EPIC on all Slide Fee encounters. Any discrepancies will be immediately forwarded to the supervisor for corrections and adjustments. Fourth implementation, the Center's Billing Department is now responsible for performing regular quarterly audits, sampling at least 40 encounters. During these audits, they look at sliding fee discounts and examine the applied fees and the corresponding discounts applied to the patient's account (using the approved CPT Table). This process will also include what sliding discount the patient qualifies for according to their income and family size. Results of the audit will be forwarded to the Chief Operations Officer to review and address appropriately. Through these improvements, CHASS aims to ensure that the Sliding Fee Discount Policy is used accurately and appropriately. These methods have been incorporated into the Center's Sliding Fee Discount Policy to guarantee their utilization and accuracy, and to further strengthen the Center's initiatives in providing access to needed health care services. Responsible Parties: Mariana Guitierrez, Billing Manager, and Angela Salgado, Interim Chief Financial Officer
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