Corrective Action Plans

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Auditor Description of Condition and Effect: Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. As a result of this condition, the District did not fully comply with the Uniform Guidance ...
Auditor Description of Condition and Effect: Although the District has processes in place to cover these areas, there are no formal written policies covering payments, allowability of costs, and compensation. As a result of this condition, the District did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation: We are aware that the District is evaluating options using internal and external resources to take corrective action. We recommend that the District proceed with its selected option as soon as practical, but no later than the end of the next fiscal year. Corrective Action: As noted, the District has processes in place that cover all grant guidelines related to federal funds. However, upon bringing it to our attention that these policies should be in writing, we are making every endeavor to comply. The District is currently working on drafting policies that will meet the criteria set out in the Uniform Guidance. Responsible Person: Maria Gistinger, Interim Chief Financial Officer Anticipated Completion Date: June 30, 2026
Auditor Description of Condition and Effect: During testing, we identified 1 instance out of 40 disbursement selections tested in which the District was unable to provide supporting documentation for charges incurred under the grant. Additionally, we noted 15 instances out of 40 selections tested wh...
Auditor Description of Condition and Effect: During testing, we identified 1 instance out of 40 disbursement selections tested in which the District was unable to provide supporting documentation for charges incurred under the grant. Additionally, we noted 15 instances out of 40 selections tested where the District could not provide evidence of review and approval for grant expenditures. Finally, we identified 3 instances out of 40 selections tested where the hours reported on timesheets did not agree with the hours charged to the grant. The District’s failure to maintain supporting documentation for certain grant expenditures, provide evidence of review and approval, and accurately report time charged to the grant increases the risk of noncompliance with federal requirements under 2 CFR Part 200. These deficiencies create an increased risk of questioned costs which could ultimately lead to disallowed costs and the potential repayment of grant funds to the granting agency. Additionally, inaccurate reporting and weak internal controls diminish the reliability of financial information submitted to the grantor, reduce accountability, and heighten the risk of errors or fraudulent activity. Auditor Recommendation: We recommend that the District review its written policies and procedures over federal awards to ensure that controls are in place that will require that all expenditures for either payroll or disbursements have the appropriate documentation and evidence of review and approval prior to payment. Corrective Action: The District will review its written policies and procedures over federal awards to ensure that all expenditures have the appropriate documentation and evidence of review and approval prior to payment. Responsible Person: Maria Gistinger, Interim Chief Financial Officer Anticipated Completion Date: June 30, 2026
This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our...
This Repeat Finding has been acknowledged. Union has taken several steps towards making the required changes to ensure compliance with our enrollment reporting responsibilities. This includes implementing process improvements related to our National Clearing House (NSC) submissions and reviewing our academic policies related to academic leaves of absence and withdrawals. Timeliness of Enrollment Reporting Rosters: As of January 2024, Union completed the setup and configuration of our enrollment reporting services with NSC as our third-party service provider. The new process is administered by the school Registrar, with back-up responsibilities handled by the Assistant Dean, Director of Financial Aid, and the Vice President of Admissions and Views of Responsible Officials: This Repeat Finding has been acknowledged. Union’s Academic Office is in the late stages of implementing a multi-year action plan to implement the required system, policy, and procedural changes to ensure compliance with all enrollment reporting regulations. As of January 2024, Union completed our migration to the National Clearinghouse (NSC) as our third service provider for enrollment reporting services. We have already experienced a strong positive impact on the timeliness of our enrollment reporting. For example, we have fully addressed the timeliness of our NSLDS Roster response, which is due within 15 days. This year’s testing sample yielded zero (0) errors, demonstrating our ability to successfully address enrollment reporting issues. The steps outlined below will allow us to address the enrollment reporting issue identified in this year’s testing sample. Earlier this academic year, Union revised both our Academic Leave of Absence and Term Withdrawal policies to ensure alignment with our compliance obligations. Due to these changes, Union has already noted a reduction in reporting errors and inconsistencies. The FY25 Single Audit finding is related to the reporting of withdrawal/dismissal actions that took place in summer, a non-required term for students in our programs. Our corrective action will be to: (1) further modify our policies and procedures to specifically address non-required and interim terms; and (2) increase the number of batch enrollment updates to NSC/NSLDS during non-required terms to ensure that all summer withdrawals are communicated within 60 days.
The Authority immediately implemented enhanced financial control measures to strengthen oversite of not only the accounts payable process, but the financial operations. These measures include the adoption of dual control for all ACH transactions, ensuring that no single individual has unilateral aut...
The Authority immediately implemented enhanced financial control measures to strengthen oversite of not only the accounts payable process, but the financial operations. These measures include the adoption of dual control for all ACH transactions, ensuring that no single individual has unilateral authority to initiate and approve electronic payments or to issue paper checks. Prior to any payments being processed, the Chief Executive Officer (CEO) receives a preliminary invoice listing for review and approval. New vendor requests (typically provided by procurement) are processed by the finance department; and, in addition to the required W-9, their standing on Sunbiz.org is reviewed and documented in their vendor file. All documents provided by the new vendor are saved electronically and attached to their vendor file in the Authority's software. Additionally, new financial control policies were adopted by the Palatka Housing Authority's Board of Commissioners at their December 16, 2025 meeting. The new policy follows HUD's financial management training resource suggestions and the finance staff will meet monthly with the CEO to review current financials. All staff will be trained on the new policies by January 31, 2026 providing everyone with the updated requirements. The Authority has also hired an Interim Chief Financial Officer with over 20 years of public housing accounting experience and is actively searching for a permanent staff accountant and CFO, thus ending the fee accountant contract. This brings all accountability back to the in-house team. If the Department of Housing and Urban Development has questions regarding this plan, please contact Oche Bridgeford, Executive Director at (386) 329-0132.
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Findin...
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2025-002 (a) Comments on the Finding and Recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action Taken - The Authority will establish internal tracking and reminder systems to ensure all required reports, including the final P&E and AMCC, are completed and submitted to HUD by the required due dates. Grant reporting responsibilities will be clearly assigned, and submission deadlines will be monitored by the Director of Finance to prevent future delays. These procedures will be implemented immediately. (c) Planned Implementation Date - The Authority plans to implement procedures during the year ending March 31, 2026 to resolve the reported finding.
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Findin...
Name of Auditee: Poughkeepsie Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Thomas Shanley, Accountant Phone: (845) 485-8931 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Finding 2025-003 (a) Comments on the Finding and Recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action Taken - Accounting staff will review and verify key line items (including Unrestricted Net Position, Restircted Net Position, and Cash) against the general ledger prior to VMS submission. Supervisory review will be required to confirm accuracy. (c) Planned Implementation Date - The Authority plans to implement procedures during the year ending March 31, 2026 to resolve the reported finding.
View of the Responsible Official: We agree with the significant deficiency identified. Responsible Persons: School-based food service coordinators and Management director of food service Management Response: Training is conducted annually with school-based food service coordinators to ensure proper ...
View of the Responsible Official: We agree with the significant deficiency identified. Responsible Persons: School-based food service coordinators and Management director of food service Management Response: Training is conducted annually with school-based food service coordinators to ensure proper understanding of reporting requirements. During the 2025-2026 year standardized forms have been distributed to all school food service locations to ensure accurate counting and calculations, which will align with the monthly claim reimbursement reports submitted for reimbursement. It is the expectation that all school-based food service coordinators will properly utilize the updated forms and will receive training as necessary to ensure a thorough understanding of the importance of accurate reporting. Management’s food service director will increase oversight of the meal counts and claims reports to verify the accuracy of the reporting, and to ensure that the count records agree to the claims submitted. Anticipated Completion Date: June 30, 2026
Enforce the organization's R2T4 refund calculation proceedures
Enforce the organization's R2T4 refund calculation proceedures
Corrective Action Plan Finding 2025-001 Federal Award Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance – Reporting Name of Contact Person Kimberly Carlo, Executive Director Corrective Action In this case it was noted that our Organization did not perform reconci...
Corrective Action Plan Finding 2025-001 Federal Award Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance – Reporting Name of Contact Person Kimberly Carlo, Executive Director Corrective Action In this case it was noted that our Organization did not perform reconciliation procedures between the federal program reporting of direct client expenditures with our financial accounting records. Not performing this reconciliation lead to an unreconciled difference when determining whether the data was complete and accurate. We have thoroughly reviewed our internal procedures, identified weaknesses and implemented changes to assure this will never happen again. To prevent and detect such errors in the future, we have changed our internal procedures to include: Project files that are being closed and reported to the grantor are being reviewed on a monthly basis. During the review, project files will be verified that the funding sources used for expenditures reconcile with the funding sources used for payment as recorded in the financial accounting records. Any differences will be reconciled at this point and such documentation will be retained. Additionally, an annual reconciliation of all population data used for program expenditures will be reconciled with our financial accounting records. To prevent and detect such errors in the future, we have changed our internal procedures to include: 1. Each material list along with measures and funding sources will be printed for the client file for direct material and labor charges. 2. The financial coordinator will verify funding sources match with amounts reported in the financial accounting records. 3. Any changes to funding for material and labor will be printed for the client file and given to the financial coordinator to change funding sources in the IWI accounting system. 4. Once funding is changed, verification will be printed for the client file. 5. An annual reconciliation of client program expenditures will be reconciled with our revenue and expenditure report for each funding source. Implementation Immediate.
Person responsible for corrective action – Kyle Dorow, Chief Financial Officer Corrective action planned – Shortly after the conversion to the new patient management system, this error was identified as a systemic issue. The Organization implemented policies and procedures to prevent the system from...
Person responsible for corrective action – Kyle Dorow, Chief Financial Officer Corrective action planned – Shortly after the conversion to the new patient management system, this error was identified as a systemic issue. The Organization implemented policies and procedures to prevent the system from continuing to process these charges incorrectly. In addition, a review of similar transactions and visits was performed to catch any errors that had occurred and these were corrected over the course of the fiscal year. Planned implementation date of corrective action – Fiscal year 2025
2025 – 001: Period of Performance Federal Program CFDA # 14.872 Capital Fund Program Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: Recommendation: It is recommended the Authority review all of the policies in place relating to the obligation of capital progra...
2025 – 001: Period of Performance Federal Program CFDA # 14.872 Capital Fund Program Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: Recommendation: It is recommended the Authority review all of the policies in place relating to the obligation of capital programs to ensure that funding is properly obligated and expended within the required time frame. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action in response to finding: The PHA will proactively seek clarification from HUD when guidance is unclear or when operational challenges arise. The PHA remains committed to full compliance with HUD requirements and values its collaborative relationship with HUD. The Authority appreciates the guidance and technical assistance provided and will continue to work proactively to ensure clarity, transparency, and accountability moving forward. Name of the contact person responsible for corrective action: Jacque Sikes, Executive Director Planned completion date for corrective action plan: January 2026
Statement of condition 2025-001: For the year ended June 30, 2025, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839-...
Statement of condition 2025-001: For the year ended June 30, 2025, the Corporation did not have a HUD approved Project Owner's/Management Agent's Certification (HUD-9839-B). Recommendation: Management should continue to request the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD. Management should not pay any management fees until the executed Project Owner's/Management Agent's Certification (HUD-9839- B) is received. Action(s) taken or planned on the finding: Agree. Management received email correspondence from HUD on August 12, 2021 that stated the Agent is approved to take over management immediately and the Project Owner's/Management Agent's Certification (HUD-9839-B) would be retroactively effective. Management has continued to seek the executed Project Owner's/Management Agent's Certification (HUD-9839-B) from HUD.
Name of Auditee: Cortland Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Ella Diiorio, Executive Director Phone: (607) 753-1771 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Find...
Name of Auditee: Cortland Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Ella Diiorio, Executive Director Phone: (607) 753-1771 (A) Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (2) Finding 2025-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation. Please see below for additional comments and action taken. (b) Action taken - The Authority will implement a formal reconciliation process for all utility cost reporting submitted on Form HUD - 52722. Prior to future submissions, the Authority will ensure all reported amounts are independently verified and reconciled to the utility tracking spreadsheet and supporting invoices. (c) Planned implementation date - The Authority plans to implement procedures during the year ending March 31, 2026 to resolve the reported finding.
Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a...
Name of Auditee: Springfield Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: March 31, 2025 CAP Prepared by: Denise Jordan, Executive Director Phone: (413) 785-4500 (A) Current Findings on the Schedule of Findings and Questioned Costs (2) Finding 2025-002 (a) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendations, please see below for action taken. (b) Action taken - The Authority will continue to utilize CBIZ to provide ongoing fee accounting services to incorporate the recommendations listed above on a monthly basis. A comprehensive year-end checklist will continue to be utilized to ensure all financial reports are reconciled to the underlying support. (c) Planned implementation date of corrective action - Completed by March 31, 2026.
All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be e...
All graduate and withdrawn student files will be reviewed on a monthly basis to verify any status changes are reported to NSLDS within regulatory timeframes. Training and professional development will be required for responsible staff to ensure a compliance schedule is developed. Personnel will be evaluated to ensure existing policies, procedures, and processes are followed and supported through corrective action where needed.
2025-004 – MEAL COUNT REPORTING Corrective Action Plan: We were running two different options within the Summer Food Service program each week - one food distribution for 7 days and one for 3 days. Starting in August, we simplified it to one distribution of 7 days, so that only one report is needed ...
2025-004 – MEAL COUNT REPORTING Corrective Action Plan: We were running two different options within the Summer Food Service program each week - one food distribution for 7 days and one for 3 days. Starting in August, we simplified it to one distribution of 7 days, so that only one report is needed to be completed and handed in for each week. This makes it easier for the team preparing the food and filling out the reports, and also more obvious when all the reporting has been done vs. not. Responsible Party(ies): • Business Manager Anticipated Completion Date: August 31, 2025
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: We have implemented a new policy that requires the Superintendent to review and sign-off on all outgoing EFT and ACH payments. We have implemented a new policy that requires the Superintendent to review and sign-off on all bank statements. Respons...
2025-003 – UNALLOWABLE COSTS Corrective Action Plan: We have implemented a new policy that requires the Superintendent to review and sign-off on all outgoing EFT and ACH payments. We have implemented a new policy that requires the Superintendent to review and sign-off on all bank statements. Responsible Party(ies): • Superintendent and Board of Education Anticipated Completion Date: June 30, 2026
New depository agreements have been executed between the Housing Agency and the banks. Signature from HUD is pending.
New depository agreements have been executed between the Housing Agency and the banks. Signature from HUD is pending.
Management is in contact with the software company to resolve discrepancies between the general ledger and the software generated VMS report
Management is in contact with the software company to resolve discrepancies between the general ledger and the software generated VMS report
Corrective Action Plan: The District will ensure free and reduced meal applications with a case number in Step 2 of the application are part of a program that makes them immediately qualify for free or reduced meals. In addition, approved applications will be reviewed by a 2nd party to ensure accura...
Corrective Action Plan: The District will ensure free and reduced meal applications with a case number in Step 2 of the application are part of a program that makes them immediately qualify for free or reduced meals. In addition, approved applications will be reviewed by a 2nd party to ensure accurate approval has taken place. Anticipated Corrective Action Plan Completion Date: December 2025 Contact Information: For additional information regarding this finding please contact Erica Pickett, Director of Business Services, at 608-877-5011.
When processing unofficial withdrawals through the R2T4 process, an additional step to the withdrawal process has been added. Financial Aid staff will use the NSLDS Enrollment History Update feature to submit the unofficial withdrawal date directly to NSLDS. This ensures that the date has been repor...
When processing unofficial withdrawals through the R2T4 process, an additional step to the withdrawal process has been added. Financial Aid staff will use the NSLDS Enrollment History Update feature to submit the unofficial withdrawal date directly to NSLDS. This ensures that the date has been reported to NSLDS avoiding any potential that the student being reported has missed the regular NSC enrollment reporting rosters.
Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Alth...
Finding: 2025-001 Condition Found: During testing of payroll charges, 3 of the 25 employees tested had salary charges which exceeded the Executive Level II cap. Upon further review of the full population, a total of 4 employees were identified whose salary charges to the grant exceeded the cap. Although the Organization calculated the capped allowable salaries for each employee, the allocations entered into the payroll system reflected full gross wages rather than the capped amounts, resulting in the excess salaries. Individual(s) Responsible for Corrective Action: Philip Kneer, CFO Brandon Gilbert, Corporate Compliance Officer / Co-Director of HR April Bledsoe, / Co-Director of HR Planned Corrective Action: Integrate automatic HRSA salary cap checks into payroll and HRIS systems. Create salary cap flags that prevent or warn when charges exceed allowable rates. Implement quarterly salary compliance audits comparing employee salaries to HRSA limits. Anticipated Completion Date: Update payroll system control within the HRIS/Payroll system by February 28, 2026 First quarterly salary compliance audit to be completed by February 26, 2026
Recommendation: We recommend management establish an informal procedure to reconcile grant funds received with funds expended on a regular basis. We also recommend management implement a formal procedure to reconcile the SEFA with the general ledger at year end. Corrective Action: The Comptroller wi...
Recommendation: We recommend management establish an informal procedure to reconcile grant funds received with funds expended on a regular basis. We also recommend management implement a formal procedure to reconcile the SEFA with the general ledger at year end. Corrective Action: The Comptroller will reconcile this report on a monthly basis making sure that all grants and other Federal / State expenditures are on the SEFA and that the two numbers reconcile with the general ledger. This will be kept in a notebook and the calendar kept in the Comptroller’s desk. The Comptroller will also create a folder in the business office folder on the server and input the current SEFA in this folder and show any discrepancies on a monthly basis and every time this report is run for drawdowns. This process will start immediately. The Comptroller will also make sure at year end that all items are on this report and they have been reconciled with the general ledger. This process will also be in the notebook and calendar within the desk of the Comptroller.
Condition: For one student, the School District used an incorrect number of days attended in the return to Title IV calculation, resulting in an inaccurate refund amount. Planned Corrective Action: We have conducted on-going training, created R2T4 Quick References, Term Calendar Calculators, R2T4 De...
Condition: For one student, the School District used an incorrect number of days attended in the return to Title IV calculation, resulting in an inaccurate refund amount. Planned Corrective Action: We have conducted on-going training, created R2T4 Quick References, Term Calendar Calculators, R2T4 Decision Trees as well as other tools to assist R2T4 team members. These are supplemental to the body of regulations related to R2T4 found in the Student Aid Handbook. We will also perform and document a sample-based review of R2T4 calculations on a semester by semester basis. Contact person responsible for corrective action: Adrian Robson, Director of Financial Aid Anticipated Completion Date: 11/01/2025
Finding 2025-001: Allocation Documentation – Significant Deficiency in Internal Control over Allowable Costs/Cost Principals Name of Contact: Lisa Pearce, Business Manager Corrective Action Plan: To ensure payroll costs charged to multiple federal funds are properly reviewed, approved, and documente...
Finding 2025-001: Allocation Documentation – Significant Deficiency in Internal Control over Allowable Costs/Cost Principals Name of Contact: Lisa Pearce, Business Manager Corrective Action Plan: To ensure payroll costs charged to multiple federal funds are properly reviewed, approved, and documented in compliance with federal, state, and institutional regulations. This procedure ensures transparency, accuracy, and appropriate record retention. Reviews allocation documents; ensures proper coding. Scope: Applies to all employees whose salary or wages are distributed across two or more federal grants, cost centers, or funding sources. Responsibilities: Grant Manager/Project Director • Reviews and certifies accuracy of payroll allocations based on actual effort. • Completes Grant application according to determined allocations. • Verifies compliance with grant requirements/restrictions Business Manager • Reviews allocation documents; ensures proper coding • Verifies compliance with funding requirements/restrictions; maintains documentation for audit and retention Payroll Specialist • Processes approved changes to payroll distribution. * All approvals should be dated and signed (electronic or physical signature). Documentation and Retention: • File the following documents together: o Approved Payroll Allocation Form o Effort certification or time/effort report o Any related correspondence or justification memo. • Retain for at least 3 years after the final expenditure report for the relevant federal award, or longer if required by grantor. Periodic Review: • Conduct at least semi-annual reviews to confirm payroll allocations reflect actual work performed. • Adjust allocations as necessary and re-document approvals. Proposed Completion Date: This procedure was established in the first quarter of FY26. Full implementation of the procedure will be complete by end of FY26 Respectfully Submitted: Lisa Pearce 11/12/2025 ____________________________ __________________________ Lisa Pearce Date Business Manager
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