Corrective Action Plans

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Finding 2024-003 - tenant rent payments not deposited timely a. Issue: During the year ended June 30, 2024, Bay Cove Human Services, an affiliate and sponsor agency for Juliette Corporation, collected rent and other client fees related to its clients who are also tenants in the Projects. Bay Cove Hu...
Finding 2024-003 - tenant rent payments not deposited timely a. Issue: During the year ended June 30, 2024, Bay Cove Human Services, an affiliate and sponsor agency for Juliette Corporation, collected rent and other client fees related to its clients who are also tenants in the Projects. Bay Cove Human Services did not timely remit the tenant rent portion of these payments to the Projects which resulted in a total balance owed to the Projects of $161,053 as of June 30, 2024. b. Recommendation: Management should establish or undertake a review of internal controls over monitoring of the tenant rent deposits to ensure deposits are timely made into the Project accounts. c. Action taken: Subsequent to year end, Bay Cove Human Services, Inc. deposited the tenant rent payments of $161,053 with the Projects. In addition, the Assistant Controller has p'rovided proper training to both the Senior Accountant and the Senior Cash Management Accountant regarding the transfers that need to be made from Bay Cove Human Services to the Projects for tenant rent. The Senior Accountant is now preparing these transfers on a monthly basis, with the Assistant Controller reviewing them. In addition, the Senior Cash Management Accountant is now performing a monthly reconciliation of the related balance sheet accounts which show the amounts due to/from the entities for the tenant rents in order to identify any problems with the timeliness of the transfers.
Finding 2024-002 - delinquent deposits to the replacement reserve a. Issue: During the year ended June 30, 2024, the Projects did not make the required monthly deposits to the replacement reserves in the amount of $96,360. The Projects were required to make monthly deposits to the reserves in the am...
Finding 2024-002 - delinquent deposits to the replacement reserve a. Issue: During the year ended June 30, 2024, the Projects did not make the required monthly deposits to the replacement reserves in the amount of $96,360. The Projects were required to make monthly deposits to the reserves in the amount of $144,539 and only $48,179 was deposited during the year ended June 30, 2024. b. Recommendation: Management should establish or undertake a review of internal controls over monitoring of the replacement reserve requirements to ensure deposits are made as required. c. Action taken: The delinquent deposits of $96,360 were made to the replacement reserves subsequent to year end. In addition, a tracking spreadsheet has been re-implemented which lists the monthly amounts required to be transferred to the reserves and has a column for staff to input the date that the transfers were made. This spreadsheet is now reviewed on a weekly basis by both the Senior Cash Management Accountant and the Assistant Controller as part of the weekly check run to ensure that the monthly transfers to the reserves are made early in the month prior to paying other liabilities.
Finding 2024-002 Reporting Aging Cluster (ALN 93.044/93.045/93.053) Corrective Action: Management is in agreement with the finding. Management has bolstered staffing and the fiscal team has completed comprehensive training. Management will ensure the necessary reports are filed with the granting age...
Finding 2024-002 Reporting Aging Cluster (ALN 93.044/93.045/93.053) Corrective Action: Management is in agreement with the finding. Management has bolstered staffing and the fiscal team has completed comprehensive training. Management will ensure the necessary reports are filed with the granting agency in a timely fashion. Management anticipates corrective action to be in place by 10/01/2025. Responsible party: Mary Bateman, Controller.
Corrective Action Plan - A new CFO is in place and staff have received education. Financial statement preparation is now being completed in a timely and accurate manner. Anticipated Completion Date - We have completed these steps. Responsible Parties - Stephanie Cooper, Chief Executive Officer, 909 ...
Corrective Action Plan - A new CFO is in place and staff have received education. Financial statement preparation is now being completed in a timely and accurate manner. Anticipated Completion Date - We have completed these steps. Responsible Parties - Stephanie Cooper, Chief Executive Officer, 909 Broadway, Hannibal, MO 63401 (573)221-3892
Corrective Action Plan - A new CFO is in place and has caught up the reconciliations and is continuing to complete them in a timely manner. Anticipated Completion Date - We have completed these steps. Responsible Parties - Stephanie Cooper, Chief Executive Officer, 909 Broadway, Hannibal, MO 63401 (...
Corrective Action Plan - A new CFO is in place and has caught up the reconciliations and is continuing to complete them in a timely manner. Anticipated Completion Date - We have completed these steps. Responsible Parties - Stephanie Cooper, Chief Executive Officer, 909 Broadway, Hannibal, MO 63401 (573)221-3892
Corrective Action Plan - We acknowledge the audit finding regarding the lack of segregation of duties. To address this issue, we have developed the following corrective action plan: 1. Risk Assessment: We will conduct a risk assessment to identify all areas with Segregation of Duty conflicts. 2. Pol...
Corrective Action Plan - We acknowledge the audit finding regarding the lack of segregation of duties. To address this issue, we have developed the following corrective action plan: 1. Risk Assessment: We will conduct a risk assessment to identify all areas with Segregation of Duty conflicts. 2. Policy Implementation: Policies will be evaluated and will be established to clearly define roles and responsibilities, ensuring no single individual controls multiple aspects of critical financial transactions. 3. Duty Reassignment: We have also hired another position in the finance department with the start date of August 7, 2024. Responsibilities will be assigned among the staff to eliminate conflicts. Accounts Payable entry and check printing have been assigned to separate staff with the CFO reviewing both. 4. Training: Employees will receive training on the importance of Segregation of Duties and their specific roles under the new framework. 5. Monitoring: Regular internal audits and continuous monitoring will be implemented to ensure compliance with the new Segregation of Duties policies. Anticipated Completion Date - We anticipate completing these actions by October 31, 2025. Responsible Parties - Stephanie Cooper, Chief Executive Officer, 909 Broadway, Hannibal, MO 63401 (573)221-3892
Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on...
Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on the Finding: The Corporation concurs with the recommendation and will make the deposit to fully fund the reserve for replacements fund.
View Audit 368702 Questioned Costs: $1
Contact Person Heidi Johnson, Board President Corrective Action Plan The Housing Authority will be more diligent in completing HQS quality control re-inspections on a sample of tenant units each year, as required. Completion Date Effective immediately.
Contact Person Heidi Johnson, Board President Corrective Action Plan The Housing Authority will be more diligent in completing HQS quality control re-inspections on a sample of tenant units each year, as required. Completion Date Effective immediately.
Contact Person Heidi Johnson, Board President Corrective Action Plan The Housing Authority will be more diligent in obtaining general depository agreements with all our financial institutions, as required. Completion Date Effective immediately.
Contact Person Heidi Johnson, Board President Corrective Action Plan The Housing Authority will be more diligent in obtaining general depository agreements with all our financial institutions, as required. Completion Date Effective immediately.
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in maintain tenant file documentation, as required. Completion Date Effective immediately
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in maintain tenant file documentation, as required. Completion Date Effective immediately
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in maintaining a tracking system of failed inspection to verify compliance with required timelines, as required.. Completion Date Effective immediately
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in maintaining a tracking system of failed inspection to verify compliance with required timelines, as required.. Completion Date Effective immediately
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in completing HQS quality control re-inspections on a sample of tenant units each year, as required. Completion Date Effective immediately
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in completing HQS quality control re-inspections on a sample of tenant units each year, as required. Completion Date Effective immediately
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in completing HAP contracts when required, as well as all other required information. Completion Date Effective immediately
Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in completing HAP contracts when required, as well as all other required information. Completion Date Effective immediately
Finding 1156380 (2024-005)
Material Weakness 2024
The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Can...
The subgrantees in question were Boys & Girls Clubs of America, National Youth Service League, Young Men’s Service League, and Boise State. 9/11 Day researched all subgrantees, required each to provide MOUs, program details, and budgets, and verified organizational status using resources such as Candid and Charity Navigator. Financial statements were also reviewed, but documentation of these reviews and verifications was not consistently retained, and certain federal requirements were not fully incorporated into the process. 9/11 Day has now adopted a written policy that ensures that, in its role as a pass-through entity, all subgrants will be made in full compliance with the minimum required elements found under 2 CFR 200.332(b). This shall include implementing a comprehensive tracking and monitoring system for all subgrantees, regardless of funding level, with enhanced verification requirements for those receiving over $30,000. All subaward agreements will be updated to include the minimum required elements under 2 CFR 200.332(b), and the evaluation of subgrantee risk will incorporate all suggested elements under 2 CFR 200.332(c), including consideration of fraud risk and risk of noncompliance. The system will record the time and date of all eligibility verifications and retain supporting documentation, including MOUs, SAM.gov confirmation of suspension and debarment status, IRS Form 990s, financial statements, and audit confirmations. In compliance with 2 CFR 200.332(e)(1), subgrantees will now be required to submit both performance and financial reports, which will be reviewed and compared against project budgets. In addition, 9/11 Day will evaluate subgrantees’ Single Audits, if filed, in accordance with 2 CFR 200.332(e)(2)–(4) and will review any reported deficiencies. All monitoring activities will be documented and logged throughout the life of each project to ensure stronger oversight, complete documentation, and compliance with federal requirements.
Finding 1156379 (2024-004)
Material Weakness 2024
In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a ...
In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a centralized tracking log, and for those receiving pass-through funds exceeding $30,000, the required reporting will be completed directly in SAM.gov, which now includes the Federal Subaward Reporting System (FSRS). Each subgrantee’s eligibility will be verified in SAM.gov, with the date and results of the verification recorded, and all supporting documentation retained on file. This corrective action ensures that all subawards are properly logged, reported, and compliant with FFATA requirements.
View Audit 368692 Questioned Costs: $1
Finding 1156378 (2024-003)
Material Weakness 2024
Following the close of the 2023 audit in October 2024, 9/11 Day implemented a strengthened procurement process for all large vendors, including the adoption of a formal procurement policy that complies with federal guidelines. A vendor log and checklist system has been established to document the re...
Following the close of the 2023 audit in October 2024, 9/11 Day implemented a strengthened procurement process for all large vendors, including the adoption of a formal procurement policy that complies with federal guidelines. A vendor log and checklist system has been established to document the receipt of RFPs, the rationale and method of procurement, and decisions on whether to move forward with a vendor. Although 9/11 Day has, and does verify whether vendors and subgrantees are permitted to receive federal funds, we have now updated our policy to retain printed verification of each vendor’s/subgrantee’s eligibility to receive federal funds, including confirmation that these organizations are not suspended or debarred. These documents will be retained in the procurement file for each vendor/subgrantee. These steps ensure compliance with 2 CFR 200.318 and provide clear documentation and oversight for all procurement activities.
The above finding is the result of two missed rent schedules not being processed. It will be corrected with the execution of an approved repayment plan with HUD.
The above finding is the result of two missed rent schedules not being processed. It will be corrected with the execution of an approved repayment plan with HUD.
As suggested, HUD will be approached for approval to apply the 2022 excess payment of 6K to the 2023 underpayment of 6K. in the unlikely event approval is denied, the shortage will be satisfied within 30 days from denial.
As suggested, HUD will be approached for approval to apply the 2022 excess payment of 6K to the 2023 underpayment of 6K. in the unlikely event approval is denied, the shortage will be satisfied within 30 days from denial.
Trempealeau County, being a small county, has limited resources in personnel to accomplish a multi-verification in the reporting process. We will use additional current employees in house to do the verification to make sure the reporting is accurate before submitting. Responsible Person: Mary Martin...
Trempealeau County, being a small county, has limited resources in personnel to accomplish a multi-verification in the reporting process. We will use additional current employees in house to do the verification to make sure the reporting is accurate before submitting. Responsible Person: Mary Martin, County Clerk Anticipated Completion Date: We will attempt to begin the multiple verification process for the 2025 calendar year
The security deposit was refunded to the tenant on the 78th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.
The security deposit was refunded to the tenant on the 78th day subsequent to their move-out. Management has taken measures to improve internal controls over compliance related to tenant security deposit refunds.
The County will work diligently to implement internal controls over its federal award program to ensure accurate reporting of any activity.
The County will work diligently to implement internal controls over its federal award program to ensure accurate reporting of any activity.
Human Services Department (HSD) HSD acknowledges this finding. While the Department successfully tracked, collected, reviewed, and issued management decision letters to its subrecipients as a standard practice. In this instance a formal management decision was missed for this specific sub-recipient ...
Human Services Department (HSD) HSD acknowledges this finding. While the Department successfully tracked, collected, reviewed, and issued management decision letters to its subrecipients as a standard practice. In this instance a formal management decision was missed for this specific sub-recipient during the review period. The Department has taken corrective measures to strengthen its compliance process, clarify roles and responsibilities to ensure timely completion of this requirement. Office of Economic Development (OED) OED acknowledges this finding. OED intends to take corrective measures through strengthening internal controls over subrecipient single audit monitoring: • Including a step in our internal monitoring processes to document when Program Managers pull and review single audits with federally funded partners • Retaining a monitoring workbook to track and date collection of single audit reports Office of Housing (OH) • OH acknowledges that neither a review of applicable audits nor management decision was sent to subrecipients who had audit findings. OH staff will evaluate its current policies to determine the best way to identify, review and follow-up on any subrecipient audits that may include findings. This review will include appropriate written follow up on actions OH recommends the subrecipient to take to correct the finding(s).
The Human Services Department (HSD) acknowledges this finding regarding the late submission of five FFATA reports and inaccuracies in CAPER reporting. These issues arose during a period of prolonged vacancies and while staff were in the process of being trained on reporting requirements, which reduc...
The Human Services Department (HSD) acknowledges this finding regarding the late submission of five FFATA reports and inaccuracies in CAPER reporting. These issues arose during a period of prolonged vacancies and while staff were in the process of being trained on reporting requirements, which reduced oversight capacity and contributed to delays and errors. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. HSD updated department-wide FFATA Reporting Policies and Procedures following the federal transition to SAM.gov. Staff completed federal training, and prior reports were reviewed and corrected. The Department implemented controls to close workflow gaps to ensure obligations and data corrections are captured before submission. Additionally, ongoing training is being provided to reinforce compliance. These actions strengthen internal controls and are intended to ensure FFATA and CAPER reports are accurate, complete, and submitted in a timely manner moving forward.
The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of co...
The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of contracting with a third-party vendor to complete its annual inspections, including HOME inspections for 2025. The contractor will inspect HUD’s NSPIRE level. With this additional support, OH anticipates it will have the capacity to see that corrections have been completed and documented consistent with the HOME program requirements.
The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) M...
The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. The contract specialist receives structured management oversight and ongoing training to strengthen capacity for accurate budget monitoring. In July 2025, the FGMU updated its ESG policies and procedures to incorporate improved controls for earmarking. In addition, the Department has instituted regular training sessions for all staff responsible for federal grant management to reinforce compliance with earmarking and other federal requirements. These corrective actions are designed to strengthen internal controls, provide clearer oversight, and ensure that future expenditures remain within established budget and earmarking limits.
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