Corrective Action Plans

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FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Federal Communications Commissio...
FA 2022-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Procurement Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Federal Communications Commission Pass-Through Entity: Direct Assistance Listing Number and Title: COVID-19 - 32.009 - Emergency Connectivity Fund Program Questioner Costs: $314,640 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over expenditures as it relates to the Emergency Connectivity Fund program. Corrective Action Plans: Management will continue to ensure federal fund program guidelines and Board-approved policies and procedures are followed. Estimated Completion Date: Ongoing Contact Person: Kyla M. Milton, Finance Director Telephone: 229-868-5661 Email: kmilton@telfairschools.org
View Audit 14693 Questioned Costs: $1
EDC Loan Corporation December 20, 2023 Corrective Action Plan Year Ended April 30, 2022 Finding 2022-002: Assistance #11.307 - Economic Adjustment Assistance - Revolving Loan Fund, U.S. Department of Commerce, Economic Development Administration, Award No. 05-39-01879 (Significant Deficiency) C...
EDC Loan Corporation December 20, 2023 Corrective Action Plan Year Ended April 30, 2022 Finding 2022-002: Assistance #11.307 - Economic Adjustment Assistance - Revolving Loan Fund, U.S. Department of Commerce, Economic Development Administration, Award No. 05-39-01879 (Significant Deficiency) Condition: Performance Progress Report submitted during the year was not submitted within the deadline. Criteria: All Economic Development Administration (EDA) Revolving Loan Fund (RLF) recipients must submit in electronic format Form ED-209 Performance Progress Report through EDA's Revolving Loan Fund Management System (RLFMS) semi-annually based on the entity's fiscal year-end and submitted within 30 calendar days. Corrective Action Plan: The SF425 and Performance Progress Reporting requirements ended when the disbursement phase ended on June 30, 2022. We are now due to report on the ED-917 (EDA GPRA Data Collection): Annual Capacity Outcomes Questionnaire, for reporting period November 2022-October 2023. The deadline to submit is 12/8/2023. The Annual Capacity Outcomes Questionnaire is intended for annual collection of information on the capacity outcomes attributable to program activities sponsored under the same EDA grant (or a cooperative agreement). For this questionnaire, you will report on outcomes for the stated reporting period. Contact Person: Debra Davis Anticipated Completion Date: Dear Economic Development Corporation of Kansas City Missouri, Thank you so much for submitting the ED-917: Annual Capacity Outcomes Questionnaire for your EDA Economic Adjustment Assistance award, 57906018, for reporting period November2022-October2023. This is to confirm receipt of your submission. Your responses have been saved and recorded. 11/27/2023 Tracey ewis, President, CEO December 20, 2023
Finding 10843 (2022-008)
Significant Deficiency 2022
Recommendation: We recommend the City strengthen the controls in place to provide assurance reports are submitted timely. Action Taken: The City agrees with this finding. Key vacancies and personnel changes within the City’s Emergency Management Department and the Finance Department during FY22 resu...
Recommendation: We recommend the City strengthen the controls in place to provide assurance reports are submitted timely. Action Taken: The City agrees with this finding. Key vacancies and personnel changes within the City’s Emergency Management Department and the Finance Department during FY22 resulted in delays in securing approvals of quarterly report required for timely submissions. Staffing issues were resolved in FY22 and FY23, and the Finance Director and the Grants Manager are working with the Emergency Management Department to ensure timely review, approval, and submission of the required quarterly reports. Anticipated Completion Date: December 31, 2023 Responsible Official: Emily Oster-Finance Director, Brian Williams-Emergency Management Director, Cheryl James-Grants Manager
Recommendation: We recommend the City strengthen the controls in place to provide assurance that proper review occurs with someone knowledgeable with the grant and retain backup documentation to support amounts charged to grant. Action Taken: The City agrees with this finding. In September of 2022, ...
Recommendation: We recommend the City strengthen the controls in place to provide assurance that proper review occurs with someone knowledgeable with the grant and retain backup documentation to support amounts charged to grant. Action Taken: The City agrees with this finding. In September of 2022, the City hired a highly qualified Grants Manager who has been continuously working with City Departments that receive grant funding to raise awareness of requirements such as the need to ensure that grant-funded transactions are appropriately reviewed and approved by someone knowledgeable with the grant. Key vacancies and personnel changes at the Airport during FY22 resulted in insufficient staffing to allow for robust internal controls and separation of duties. During FY24 the Finance Director and the Grants Manager will work with the Airport team to develop a procedure to document controls performed to review and approve grant-funded transactions. In FY24 the Grants Manager will provide Uniform Guidance training to City staff which will include allowable costs and internal controls. Anticipated Completion Date: June 30, 2024 Responsible Official: Emily Oster-Finance Director, James Harris-Airport Manager, Airport Operations Manager (in‐process of hiring), Cheryl James-Grants Manager
View Audit 14498 Questioned Costs: $1
Recommendation: We recommend the City strengthen the controls in place to provide assurance Federal Financial Reports are submitted accurately to the grantor agency and retain backup documentation to support amounts reported. Action Taken: The City agrees with this finding. In November 2022 the C...
Recommendation: We recommend the City strengthen the controls in place to provide assurance Federal Financial Reports are submitted accurately to the grantor agency and retain backup documentation to support amounts reported. Action Taken: The City agrees with this finding. In November 2022 the City hired a new Airport Manager with substantial experience managing municipal airports and federal funding for airports. Prior to the hire, the Airport Operations Manager was the acting Manager, but that position was vacated in FY23. In FY24 the Finance Director and the Grants Manager will continue to work with the Airport staff to implement controls and to provide assurance that Federal Financial Reports have adequate supporting documentation and are reviewed and approved prior to submission the grantor agency. Anticipated Completion Date: June 30, 2024 Responsible Official: Emily Oster-Finance Director, James Harries-Airport Manager, Cheryl James-Grants Manager
2022-008 – Written Policies and Procedures Required by the Uniform Grant Guidance Auditor Description of Condition and Effect. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas requ...
2022-008 – Written Policies and Procedures Required by the Uniform Grant Guidance Auditor Description of Condition and Effect. Although the City has processes in place to cover these areas and draft policies have been developed, there are no formal written policies that address all of the areas required by the Uniform Guidance. As a result of this condition, the City did not fully comply with the Uniform Guidance applicable to the above noted grants.Auditor Recommendation. We recommend that the City review and approve the draft policies as soon as practical. Corrective Action. City staff has reviewed drafts and will submit to City Council Uniform Grant Guidelines to be adopted. Responsible Person. City Manager Anticipated Completion Date. June 30, 2024
2022-007 – Reporting (Repeat Finding) Auditor Description of Condition and Effect. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports have either not been submitted as required, or ...
2022-007 – Reporting (Repeat Finding) Auditor Description of Condition and Effect. The City has not performed all of the required Coronavirus State and Local Fiscal Recovery Funds expenditure reporting. Specifically, the Project and Expenditure reports have either not been submitted as required, or material errors were noted in the reports submitted. As a result of this condition, the City did not comply completely with the reporting requirements of the Coronavirus State and Local Fiscal Recovery Funds grant. Auditor Recommendation. We recommend that the City contact the appliable federal agency to address technical issues with the online grant reporting portal and perform required reporting, making corrections as needed related to any previously filed reports in error. Corrective Action. City staff has accessed these reports and attempted to submit all required reports. Ongoing reports have been submitted on time. Assistance will be sought with federal agencies as necessary.Responsible Person. City ManagerAnticipated Completion Date. June 30, 2024
2022-006 – Procurement, Suspension and Debarment (Repeat Finding) Auditor Description of Condition and Effect. The City did not verify that any of their vendors over $25,000 were not suspended or debarred from doing business with the City. As a result of this condition, the City was exposed to the ...
2022-006 – Procurement, Suspension and Debarment (Repeat Finding) Auditor Description of Condition and Effect. The City did not verify that any of their vendors over $25,000 were not suspended or debarred from doing business with the City. As a result of this condition, the City was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government. Auditor Recommendation. We recommend that the City verify that all of their vendors over $25,000 spent with federal funds were not suspended or debarred. Corrective Action. The City will maintain a schedule of dates checked for debarment. Responsible Person. Assistant Finance Director / Director of Planning and Community Development Anticipated Completion Date. June 30, 2024
The documentation of SAM testing that was not provided were related to purchases done by the Board of Education which has separate purchasing authority. The Purchasing Agent will work with their counterpart at the Board of Education to ensure that testing against SAM is completed anddocumented for B...
The documentation of SAM testing that was not provided were related to purchases done by the Board of Education which has separate purchasing authority. The Purchasing Agent will work with their counterpart at the Board of Education to ensure that testing against SAM is completed anddocumented for Board of Education purchases as it is currently for City purchases, along with other procedures in place to comply with the Single Audit Act.
Please see the plan for 2022-003. These actions will address this �inding and will have a direct impact on the accurate reporting in the SEFA and SESA as well as compliance with the uniform guidance.
Please see the plan for 2022-003. These actions will address this �inding and will have a direct impact on the accurate reporting in the SEFA and SESA as well as compliance with the uniform guidance.
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes. Explanation of disagreement with audit finding: There is no Disagreement with the audit finding. Action...
Recommendation: We recommend that County management review its staffing and personnel responsibilities to prioritize the completion of its audit responsibilities within the prescribed timeframes. Explanation of disagreement with audit finding: There is no Disagreement with the audit finding. Action taken in response to finding: Due to the high amount of turnover within the budget and finance department, and the County as a whole, the Single Audit information was not provided in a timely manner. Moving forward, staffing issues have been addressed. Cross training of employees is in progress to facilitate more timely responses to audit inquiries. Name(s) of the contact person(s) responsible for corrective action: Director of Budget and Finance Planned completion date for corrective action plan: January 2024
Recommendation: We recommend the County document and, where applicable, implement policies and procedures that are aligned with Uniform Grant Guidance to limit the risk for noncompliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...
Recommendation: We recommend the County document and, where applicable, implement policies and procedures that are aligned with Uniform Grant Guidance to limit the risk for noncompliance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County contracted with a private entity for oversight on the distribution of ARPA federal awards. We will continue to get guidance from auditors and other municipalities to ensure uniform guidance is followed. Name(s) of the contact person(s) responsible for corrective action: Director of Budget and Finance Planned completion date for corrective action plan: February 2023
Recommendation: We recommend that the County revise its existing subrecipient agreement to include all of the required data elements under Uniform Guidance section 200.331. Further, we recommend that the County develop and implement the necessary written policies and procedures related to subrecipie...
Recommendation: We recommend that the County revise its existing subrecipient agreement to include all of the required data elements under Uniform Guidance section 200.331. Further, we recommend that the County develop and implement the necessary written policies and procedures related to subrecipient monitoring to provide guidance and a formal process for employees to follow when monitoring subrecipients. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement all the recommended changes to ensure we conform with all the required data elements under Uniform Guidance section 200.331. Name(s) of the contact person(s) responsible for corrective action: Director of Office of Community Development. Planned completion date for corrective action plan: March 2024
Planned Corrective Action: See finding 2022-001 listed above. The planned corrective action for this finding is the same. Anticipated Completion Date: Same as finding 2022-001. Responsible Contact Person: Bill Lazar, Executive Director
Planned Corrective Action: See finding 2022-001 listed above. The planned corrective action for this finding is the same. Anticipated Completion Date: Same as finding 2022-001. Responsible Contact Person: Bill Lazar, Executive Director
Planned Corrective Action: We concur with the finding The Partnership has new controls in place for proper tracking of timely reporting to federal agencies. We have also designated an individual with experience with federal grant reporting to ensure future reporting requirements are met in the prope...
Planned Corrective Action: We concur with the finding The Partnership has new controls in place for proper tracking of timely reporting to federal agencies. We have also designated an individual with experience with federal grant reporting to ensure future reporting requirements are met in the proper timeframe. On-Going Anticipated Completion Date: Responsible Contact Person: Bill Lazar, Executive Director
Recommendation: We recommend that management continue to recruit for staff to fill the needed positions in the finance department to ensure the timely completion of financial reporting and the annual audit. Explanation of disagreement with audit finding: There is no disagreement with the audit findi...
Recommendation: We recommend that management continue to recruit for staff to fill the needed positions in the finance department to ensure the timely completion of financial reporting and the annual audit. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Staff have become current on internal financial reporting with the outsourcing of several accounting positions and expect the audit to be completed for the 2023 fiscal year. Name of the contact person responsible for corrective action: Doni Miller, President & Chief Executive Officer Planned completion date for corrective action plan: 2023
Recommendation: We recommend that management instills a system on monitoring all reporting due dates and within the finance department to ensure all grant agreement required reporting is met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action take...
Recommendation: We recommend that management instills a system on monitoring all reporting due dates and within the finance department to ensure all grant agreement required reporting is met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management is implementing a system on monitoring all reporting due dates and within the finance department to ensure all grant agreement required reporting is met. Name of the contact person responsible for corrective action: Doni Miller, President & Chief Executive Officer Planned completion date for corrective action plan: 2023
Recommendation: We recommend that management monitors and trains the staff involved in the suspension and debarment process on an annual basis to ensure all parties are following the Association’s policy and process. Explanation of disagreement with audit finding: There is no disagreement with the a...
Recommendation: We recommend that management monitors and trains the staff involved in the suspension and debarment process on an annual basis to ensure all parties are following the Association’s policy and process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agreed with the above comment and the Association will conduct annual training with the finance department to ensure that all members are educated on the required policies for compliance. Name of the contact person responsible for corrective action: Doni Miller, President & Chief Executive Officer Planned completion date for corrective action plan: 2023
Recommendation: We recommend that management continue to work and educate front desk and intake staff on the importance of the required patient application documentation so that the required support is filed before applying a sliding fee discount to a patient account. In addition, we suggest that ma...
Recommendation: We recommend that management continue to work and educate front desk and intake staff on the importance of the required patient application documentation so that the required support is filed before applying a sliding fee discount to a patient account. In addition, we suggest that management establish a policy to perform regular monitoring of a sample of patient file sliding fee applications to ensure the sliding fees are applied correctly. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agreed with the above comment, and we are working with our intake and finance staff to ensure all documentation is maintained on file and scanned into the EMR system to maintain the required supporting documentation. During 2023 we have implemented a system of monitoring sliding fees applied to patient accounts. Name of the contact person responsible for corrective action: Doni Miller, President & Chief Executive Officer Planned completion date for corrective action plan: 2023
Recommendation: We recommend that management prepare federal draw down schedules on a more timely basis to ensure the accuracy and completeness of the support for all grant expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in ...
Recommendation: We recommend that management prepare federal draw down schedules on a more timely basis to ensure the accuracy and completeness of the support for all grant expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We agreed with the above comment and the Organization has engaged consultants to assist in creating a more robust system to document the supporting expenditures that are charged to the grant to ensure the timing of grant expenditures and allowability are appropriate. Name of the contact person responsible for corrective action: Doni Miller, President & Chief Executive Officer Planned completion date for corrective action plan: 2023
Compliance: Finding 2022-002 – U.S. Department of State - Citizen Exchanges – CFDA No. 19.415 See finding 2022-001 for action taken.
Compliance: Finding 2022-002 – U.S. Department of State - Citizen Exchanges – CFDA No. 19.415 See finding 2022-001 for action taken.
Finding 10638 (2022-001)
Material Weakness 2022
Internal Control Over Compliance: Material Weakness Finding 2022-001 – Timely Completion of Audit and Data Collection Form (DCF) Recommendation: Internal controls should be in place that provide reasonable assurance that the audit is engaged and completed timely and submitted to the Federal Aud...
Internal Control Over Compliance: Material Weakness Finding 2022-001 – Timely Completion of Audit and Data Collection Form (DCF) Recommendation: Internal controls should be in place that provide reasonable assurance that the audit is engaged and completed timely and submitted to the Federal Audit Clearinghouse (now FAC.gov) by the applicable deadline (sooner of 30 days from completion of audit or 9 months from year-end). Action Taken: Management of World Link will engage the audit earlier and provide supporting documentation to the auditors based on the agreed-upon schedule for the 2023 audit to facilitate timely completion and submission of the data collection form. Completion Date: September 30, 2024
As per the CNMI Department of Finance Procurement regulations 70-30.3-225, sole source procurement indicates that a written justification shall be prepared by the official with expenditure authority. In this instance, the selection process of the three contractors chosen was based on quotations for ...
As per the CNMI Department of Finance Procurement regulations 70-30.3-225, sole source procurement indicates that a written justification shall be prepared by the official with expenditure authority. In this instance, the selection process of the three contractors chosen was based on quotations for the required services in face-to-face meetings, and the knowledge that these were the sole qualified local contractors with highly specialized and technical expertise to fulfill the scope of the project in preventing further damage to endangered species corals from typhoon-related marine debris. There was an admitted failure to document the procedure undertaken to retain these contractors’ services, and corrective measures have since been put in place, with completion date of corrective action effective December 31, 2023 for the ongoing remainder of the project period, as well as all future federal grants as follows: a. Requests for Proposals will be published in local media with following detail:  Project title and overview  Scope of Work  Proposal Requirements  Submission Deadline and Contact Information  Evaluation and Selections  Contractual information b. The selection criteria are based on the Proposal Evaluation Form, attached herewith. MINA Proposal Evaluation Form Proposal Information:  RFP Release Date:  Proposal Submission Deadline  Proposal Submitted By:  Title:  Proposal Number:  Evaluator Name:  Criteria for Evaluation: Scoring System: 1: Poor, 2: Below Average, 3: Average, 4: Above Average, 5: Excellent 1. Compliance with RFP Requirements Score:  Proposal conforms to the RFP instructions and guidelines.  All required documentation and attachments are included.  Proposal was submitted before the deadline. 2. Understanding of Requirements Score:  Demonstrated understanding of the project's scope and objectives.  Clear articulation of how the proposal meets the needs outlined in the RFP. 3. Technical Approach Score:  Clarity and feasibility of the proposed technical approach.  Innovation and creativity in addressing project challenges. 4. Qualifications and Experience Score:  Relevant qualifications and expertise of the proposing organization.  Past experience on similar projects. 5. Cost and Budget Score:  Cost breakdown and justification.  Alignment of proposed budget with the project's scope. 6. References and Client Feedback Score:  Provided references and feedback from previous clients. 7. Timeline and Milestones Score:  Realistic project timeline and milestones.  Clearly defined project phases. 8. Risk Assessment and Mitigation Score:  Identification of potential risks and a plan for risk mitigation. 9. Quality Control and Assurance Score:  Explanation of quality control measures to ensure project qualityOverall Assessment:  Total Score: Summary and Recommendations: Evaluation completed by: Print name and sign Date Sole Source Procurement Policy December 12, 2023 Marana Islands Nature Alliance (MINA), as a non-Federal entity, and pursuant to CNMI Department of Finance Procurement regulations section 70-30.3-225, has established the following sole source procurement procedures for the acquisition of property or services required under a Federal award or subaward: 1. A contract may be awarded for a supply, service, or construction without competition when the Executive Director of MINA or his or her designee determines in writing that there is only one source for the required supply, service or construction item. This section shall be construed to include the purpose of obtaining professional services in highly specialized or technical expertise in compliance with federal regulations and whenever so required by any federal granting agencies or grant requirements. 2. The written determination shall state the unique capabilities required and why they are required and the consideration given to alternative sources. The written determination shall contain the specific unique capabilities required; the specific unique capabilities of the contractor; the availability of funding for such services as certified by the MINA accountant; and a written copy of any applicable federal grant or regulation under which the services are authorized or required. Approved by: Roberta Guerrero
Management will continue to complete annual audits within the prescribed due dates. Management will monitor accounting function needs as to provide more timely updated information.
Management will continue to complete annual audits within the prescribed due dates. Management will monitor accounting function needs as to provide more timely updated information.
Finding 10627 (2022-005)
Significant Deficiency 2022
DEPARTMENT OF AGRICULTURE 2022-005 Food Insecurity Nutrition Incentive Grants Program – Assistance Listing No. 10.331 Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsib...
DEPARTMENT OF AGRICULTURE 2022-005 Food Insecurity Nutrition Incentive Grants Program – Assistance Listing No. 10.331 Recommendation: We recommend The Food Trust establish a system of checks and balances that includes a separation of duties. This means that different individuals should be responsible for preparing and requesting the draw of funds, and there should be a clear approval process in place. In addition, it is important to establish a clear process and timeline for performing draws. This may involve regular monitoring of expenditures, timely submission of draw requests, and efficient processing of those requests. By implementing proper segregation of duties, requiring approval from another individual and implementing a timely draw process, the organization can enhance internal controls, reduce the risk of fraud, and ensure the accuracy and integrity of the fund draw process, and can better manage its cash flow, meet its financial obligations, and maintain the smooth operation of the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization had no internal finance staff from October 2020 through July 2021, and was not fully staffed until March 2023. Having adequate staffing levels within the department allows for the proper segregation of duties and internal controls. In addition, the department now has the capacity to perform these draws on a timely basis. Name(s) of the contact person(s) responsible for corrective action: Regine Metellus, Vice President of Finance Planned completion date for corrective action plan: This matter has been corrected since July 2023. If the oversight agency has questions regarding this plan, please call Regine Metellus, Vice President of Finance at 215‐575‐0444 ext. 163.
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