Corrective Action Plans

Finding 569905 (2024-005)

Material Weakness 2024

City of Chillicothe

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

The City will check SAM.gov for suspended or debarment vendors when making purchases with federal funds.

View Audit 361156

Finding 569900 (2024-001)

Significant Deficiency 2024

Town of Brooklyn

CT

Procurement, Suspension & Debarment Subrecipient Monitoring

FEDERAL FINDING 2024-001 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Description of Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Fed...

FEDERAL FINDING 2024-001 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Description of Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are required to ensure that they do not award contracts or make subawards to any parties that are suspended or debarred from receiving federal funds. This verification may be accomplished by checking the System for Award Management (SAM). The Town does not have a process in place to check that vendors are not suspended or debarred by checking the System for Award Management (SAM). Statement of Concurrence or Nonconcurrence: The Town agrees with the audit finding. Corrective Action: The Town will establish policies and procedures to ensure vendors are not suspended or debarred by checking the System for Award Management (SAM) and maintain documentation showing that verification. Name of Contact Person: Shelley Cates, Finance Director, (860) 774-9732 x217. Projected Completion Date: June 30, 2025.

View Audit 361151

Finding 569899 (2024-007)

Material Weakness 2024

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: Currently, the Authority is tracking all utility consumption for future OpFund application.Proposed Completion Date: Immediately

View Audit 361147

Finding 569898 (2024-006)

Material Weakness 2024

Kings Mountain Housing Authority

NC

HUD Housing Programs

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action:KMHA's Board has approved new written Tenant policies and procedures, to include a new ACOP (CFR 960), and are in place now.Appropriate staff have begun taking proper safeguards to ensure a waiting list is in place...

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action:KMHA's Board has approved new written Tenant policies and procedures, to include a new ACOP (CFR 960), and are in place now.Appropriate staff have begun taking proper safeguards to ensure a waiting list is in place and utilized, each tenant application is filed and proper action taken and tenant files are properly maintained and complete. A checklist is placed inside each tenant file to assist in completeness.Proposed Completion Date: Immediately

View Audit 361147

Finding 569897 (2024-005)

Material Weakness 2024

Kings Mountain Housing Authority

NC

Cash Management HUD Housing Programs Procurement, Suspension & Debarment

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This in...

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action:KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for Capital Fund Program management to ensure proper accountability. This includes the oversight of processing payments of CFP expenditures, which includes the following procedures for: 1) payment of invoices; 2) requisition of funds; 3) monitoring; and 4) reporting of CFP funds.payment of InvoicesAll CFP invoices will be reviewed and clearly marked as approved and documented to show that the source of funds for payment are CFP grant funds by the Executive Director prior to payment. The Executive Director will specify the general ledger code, including the BLI account to be used for payment processing on the invoice before providing the invoice to the accounts payable clerk.Under no circumstances will a payment be made if KMHA has not drawdown and received the respective CFP funds.With the exception of funds associated with BLI 1406 “Operations”, PHAs have three (3) business days to issue and mail the check once the CFP funds are received.The Executive Director/accounts payable clerk will specify the BLI account and CFP grant year on the check voucher prior to sending the check voucher to the fee accountant for financial statement processing.Requisition of FundsFor each drawdown, the Executive Director will print the associated eLOCCS Voucher Payment form from the eLOCCS system.The Executive Director will document the check number(s) and vendor(s) associated with each CFP draw (i.e., the eLOCCS Voucher Payment form). In addition, each individual draw shall be numbered for reference purposes.A copy of each draw shall be submitted to the fee accountant to ensure proper reporting of the grant drawdown.With the exception of funds associated with BLI 1406 “Operations”, in no case shall a draw be made without the proper approved invoices.MonitoringThe fee accountant's monthly financial statements will include a CFP report for each grant which will be reviewed by the Executive Director for proper coding and accuracy.Folder has been created to track all required information in the management of a CFP grant to include correspondence to and from HUD, expenses, grant reimbursements, budgets, closeout documentation and EPIC management.Proposed Completion Date: Immediately

View Audit 361147

Finding 569896 (2024-004)

Material Weakness 2024

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: Management will insure that all insurance policies are up to date and the fidelity bonding will be increased to the appropriate levels.Proposed Completion Date: Immediately

View Audit 361147

Finding 569895 (2024-003)

Material Weakness 2024

Kings Mountain Housing Authority

NC

HUD Housing Programs Internal Control / Segregation of Duties

Name of Contact Person: Veronica Williams, Interim Executive DirectorCorrective Action: A budget for FYE 9/30/25 was approved by the Board in their October 2024 meeting.Proposed Completion Date: Immediately

View Audit 361147

Finding 569894 (2024-002)

Material Weakness 2024

Kings Mountain Housing Authority

NC

Internal Control / Segregation of Duties

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KMHA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for deposits and bank reconciliations to ensure proper accountability. Bank ...

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KMHA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for deposits and bank reconciliations to ensure proper accountability. Bank statements will be provided directly to the Fee Accountant monthly. The reconciliation of all bank accounts in a timely manner is a key component of good controls over cash. The reconciliation of the bank balance with the book balance (i.e., general ledger) is necessary to ensure that:All receipts and disbursements are recorded, which is an essential process for ensuring complete and accurate monthly financial statements;Checks are clearing the bank in a reasonable timeframe;Items reconciled are appropriate and are being recorded;Fraudulent claims can be discovered and investigated; andReconciled cash balance agrees to the general ledger cash balance.Each bank account will be reconciled by the fee accountant returned.This documentation will be made available to the Authority’s auditorProposed Completion Date: Immediately

View Audit 361147

Finding 569893 (2024-001)

Material Weakness 2024

Kings Mountain Housing Authority

NC

Procurement, Suspension & Debarment § 200.320

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for purchasing and procurement actions to ensure proper accountability. The ...

Name of Contact Person:Veronica Williams, Interim Executive DirectorCorrective Action: KHMA’s Board has approved new written policies and procedures and are in place now.Appropriate staff have begun taking proper safeguards for purchasing and procurement actions to ensure proper accountability. The new policy addresses the three types of procurement under CFR 200.320 informal and formal procurement and noncompetitive procurement. Thresholds have been set for Micro purchases and thus simplified procurement under informal practices. Formal methods include Sealed bids and Proposals when sealed bids are not appropriate.All checks are handled in accordance with the new check writing policy and have the necessary documentation to support the purchase and is filed in such a manner to be available for future reviews. This documentation will be made available to the Authority's fee accountant.All procurement actions will be handled in accordance with the new procurement policy and CFR 200.Proposed Completion Date: Immediately

View Audit 361147

Finding 569874 (2024-005)

None 2024

Marion County

SC

Matching / Level of Effort / Earmarking

County staff will work with engineers of the program to ensure that this is done in the future.

View Audit 361144

Finding 569873 (2024-003)

Significant Deficiency 2024

Marion County

SC

Marion County acknowledges the finding and has taken corrective steps to improve financial record keeping. Marion County has hired a full time Accounts Payable Accountant. This employee has been in the position for 1 year and has developed knowledge of the chart of accounts, various fund accounts ...

Marion County acknowledges the finding and has taken corrective steps to improve financial record keeping. Marion County has hired a full time Accounts Payable Accountant. This employee has been in the position for 1 year and has developed knowledge of the chart of accounts, various fund accounts and the Tyler Technology process to ensure that the accounts payable function processes invoices in an accurate manner. Errors on management requisitions are managed by the Procurement Director and audited by Accounts Payable. Management staff have received training on viewing and monitoring their department budget to actual reports on the Tyler technology system. The FY 2026 proposed budget contains a salary for an assistant administrator for oversight of financial departments. This executive will be responsible for assisting Council, Administration and management staff with understaning the financial reports of the County and also, the proper monitoring of the coding of purchase orders and various invoices to ensure adequately maintained records. These measures aim to ensure all transactions are properly recorded and monitored in accordance with the County's chart of accounts.

View Audit 361144

Finding 569872 (2024-002)

Significant Deficiency 2024

Marion County

SC

Reporting Internal Control / Segregation of Duties

Council and Administration will continue to use supervisory reviews such as monitoring financial statements and budget reports, and segregate duties where cost beneficial to do so.

View Audit 361144

Finding 569871 (2024-001)

Significant Deficiency 2024

Marion County

SC

The County will accept this condition and continue to work with the audit staff in the preparation of the financial statements and review and approve the financial statements and related disclosures.

View Audit 361144

Finding 569870 (2024-001)

None 2024

Harrison County Development Commission

MS

Procurement, Suspension & Debarment

The Commission strives to comply with governing rules and regulations. The Commission continues their efforts to improve processes and will utilize their internal controls appropriately in the future. The Commission has a comprehensive procurement checklist to ensure compliance requirements are met ...

The Commission strives to comply with governing rules and regulations. The Commission continues their efforts to improve processes and will utilize their internal controls appropriately in the future. The Commission has a comprehensive procurement checklist to ensure compliance requirements are met prior to contracting with a vendor.

View Audit 361133

Finding 569861 (2024-001)

None 2024

Center for Innovative Public Health Research

CA

§ 200.516

The entity has implemented wording in their vendor contracts that they will not honor invoices that are more than 90 days out.

View Audit 361128

Finding 569860 (2024-001)

Significant Deficiency 2024

Disability Rights Vermont, INC

VT

Allowable Costs / Cost Principles Reporting

Management disagrees with this finding because the executive director does monitor actual employee time to grants during the normal course of employee and time sheet reviews. However, she will set up a recurring meeting with the Finance Director and each staff member going forward to review the actu...

Management disagrees with this finding because the executive director does monitor actual employee time to grants during the normal course of employee and time sheet reviews. However, she will set up a recurring meeting with the Finance Director and each staff member going forward to review the actual grant allocations. She will also try to note on time sheets that the percentage of time spent on each grant has been reviewed and approved or addressed with staff.

View Audit 361127

Finding 569859 (2024-001)

Significant Deficiency 2024

Coachella Valley Rescue Mission

CA

Equipment & Real Property Management Significant Deficiency § 200.313

2024-001 – Equipment and Real Property Management Policy Planned Corrective Action: Management is working on creating and implementing policies and procedures surrounding equipment and real property management. Name of Contact Persons: Amanda Galindo, Executive Director, Angie Warren, Finance Mana...

2024-001 – Equipment and Real Property Management Policy Planned Corrective Action: Management is working on creating and implementing policies and procedures surrounding equipment and real property management. Name of Contact Persons: Amanda Galindo, Executive Director, Angie Warren, Finance Manager and Teri Ortiz, Grants Specialist Anticipated completion date: May 23, 2025

View Audit 361125

Finding 569858 (2024-002)

Material Weakness 2024

Impact Community Action Partnership, Inc.

IA

Management’s Response: Management agrees with the finding. Contact Person Responsible for Corrective Action: Anne Bacon, CEO Corrective Action Plan: The corrective action plan outlined in the 2023 audit was followed and the board has had the appropriate balance of low-income members since July, 2024...

Management’s Response: Management agrees with the finding. Contact Person Responsible for Corrective Action: Anne Bacon, CEO Corrective Action Plan: The corrective action plan outlined in the 2023 audit was followed and the board has had the appropriate balance of low-income members since July, 2024.

View Audit 361122

Finding 569855 (2024-001)

Material Weakness 2024

Impact Community Action Partnership, Inc.

IA

Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Management’s Response: Management agrees with the finding. Contact Person Responsible for Corrective Action: Anne Bacon, CEO Corrective Action Plan: The auditor finding concludes that the cause of the finding is: “Rapid growth of new funding without a corresponding increase in fiscal personnel, comb...

Management’s Response: Management agrees with the finding. Contact Person Responsible for Corrective Action: Anne Bacon, CEO Corrective Action Plan: The auditor finding concludes that the cause of the finding is: “Rapid growth of new funding without a corresponding increase in fiscal personnel, combined with the replacement of the CFO resulted in significant delays in reconciliations and preparing for the September 30, 2024 audit..” In order to address these causes, IMPACT Community Action Partnership will follow a rectifying course of action. 1. Establish a Reconciliation Schedule: A monthly reconciliation calendar will be implemented, assigning specific due dates for reconciling each of the following accounts: o Cash o Grant revenue and receivables o Prepaid expenses o Accounts payable o Accrued liabilities o Receivable advances Anticipated completion date: July 15, 2025 2. Assign Responsibilities: The Controller will be responsible for completing and reviewing all reconciliations monthly. The Chief Operating Officer will provide a second-level review and sign-off and will provide weekly verbal updates to the Chief Executive Officer beginning in August, 2025 3. Document Procedures: Standard Operating Procedures (SOPs) will be created or updated for each account reconciliation process, including templates and documentation requirements and entered into the Whale software. Anticipated completion date: August 30, 2025 4. Training: All finance staff involved in reconciliations will receive training on reconciliation standards, documentation. Anticipated completion date: September 30, 2025 5. Monitoring and Reporting: A reconciliation checklist and status report will be submitted to the board of directors each month for accountability beginning in August, 2025

View Audit 361122

Finding 569850 (2024-003)

Significant Deficiency 2024

Catholic Charities of the Diocese of Agana Dba Catholic Social Service

GU

Internal Control / Segregation of Duties Procurement, Suspension & Debarment

- CSS will revisit the existing forms and procedure to streamline approvals and minimize redundant approvals by the same individual/ authority while maintaining sound internal control. Orientation with program staff will be conducted.

View Audit 361119

Finding 569849 (2024-002)

Significant Deficiency 2024

Catholic Charities of the Diocese of Agana Dba Catholic Social Service

GU

Subrecipient Monitoring Internal Control / Segregation of Duties

- Review existing CSS personnel procedure 4.1 to streamline and improve efficiency of payroll process. '- Develop written procedure on payroll documentation on timesheets, leave request forms, and overtime work as incurred including review requirements and timelines. '- Review and discuss proposed r...

- Review existing CSS personnel procedure 4.1 to streamline and improve efficiency of payroll process. '- Develop written procedure on payroll documentation on timesheets, leave request forms, and overtime work as incurred including review requirements and timelines. '- Review and discuss proposed revisions during management meeting to address issues and concerns. '- Finalize policy/procedure and distribute to management staff. Coordinate orientation of policy to program staff directly involved with payroll.

View Audit 361119

Finding 569834 (2024-001)

Significant Deficiency 2024

California Institute of Environmental Studies

CA

Reporting Significant Deficiency

1. Federal grant agreements will be reviewed at inception and during year-end close to assess the presence of noncash assistance. 2. Coordination between program and finance staff will be enhanced to improve federal award documentation and reporting. 3. A SEFA checklist has been adopted to guide yea...

1. Federal grant agreements will be reviewed at inception and during year-end close to assess the presence of noncash assistance. 2. Coordination between program and finance staff will be enhanced to improve federal award documentation and reporting. 3. A SEFA checklist has been adopted to guide year-end reporting and audit requirement determination. 4. Training will be provided to accounting and grants management staff on Uniform Guidance requirements, especially 2 CFR 200.502 and 200.510.

View Audit 361104

Finding 569833 (2024-001)

Significant Deficiency 2024

Mountainview Daycare Nutrition Program

WA

Questioned Costs Cash Management

In response to the Operational Weakness found during the recent audit, MDNP has put into effect the following training and processes. MDNP is in the process of converting all day care sites to electronic enrollment through the KidKare software. Electronic enrollments require all information to be co...

In response to the Operational Weakness found during the recent audit, MDNP has put into effect the following training and processes. MDNP is in the process of converting all day care sites to electronic enrollment through the KidKare software. Electronic enrollments require all information to be completed and all information to be correct before approval. This will eliminate errors on the Enrollment/Income-Eligibility Forms (EIEA's). We will be training current staff and new staff for center EIEA review.

View Audit 361098 Questioned Costs: $1

Finding 569830 (2024-004)

None 2024

Jacksonville Housing Authority

FL

Reporting

The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Contract (ACC), the program receives over $90M from the United States Department of Housing and Urban Development (HU...

The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Contract (ACC), the program receives over $90M from the United States Department of Housing and Urban Development (HUD) and assist over 7,700 families each year. The ACC requires JHA to comply with federal regulations and HUD guidelines, as amended from time to time. Audit Findings Berman Hopkins Wright & LaHam, CPAs and Associates, LLP conducted the recent FY2024 JHA Audit (Period: October 1, 2023 – September 30, 2024) and identified continued material weakness findings within the JHA Housing Choice Voucher (HCV) program including but not limited to: Material Weaknesses in Internal Controls, Material Weaknesses in Non-Compliance and Material Weaknesses in the Housing Quality Standards (HQS) Inspection process. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP previously conducted JHA’s FY2023 audit (Period: October 1, 2022 – September 30, 2023) and FY2022 audit (Period: October 1, 2021 – September 30, 2022) which disclosed consecutive historical material weaknesses in JHAs internal controls and noncompliance of the Housing Choice Voucher (HCV) program. Under new CEO leadership at JHA, a request to the JHA Board of Commissioners is in place for a vote on Friday, June 27, 2025, to authorize the following action of Nan McKay & Associates to Administer, Manage and Operate the JHA Housing Choice Voucher Program for an effective date of Monday July 7, 2025. This will also include HCV HQS inspections. Pending Resolution: AUTHORIZE THE AWARD OF THE MIAMI-DADE HOUSING & COMMUNITY DEVELOPMENT PIGGYBACK CONTRACT IN THE NOT-TO-EXCEED AMOUNT OF 72% OF THE ADMINISTRATIVE FEES CONCURRENT WITH THE EXISTING CONTRACT TERMS TO NAM MCKAY AND ASSOCIATES, FOR HOUSING CHOICE VOUCHER MANAGEMENT AND OPERATIONS. As evidenced by the increase in overall HCV audit findings, loss of federal revenues, inability to correctly serve existing and future HCV program participants, noncompliance on both a local and federal level for section 8 program funding for the administration and operations of the HCV program, immediate action is requested to authorize Nan McKay & Associates to administer and operate JHA’s HCV program. Combined with a plethora of likely compliance issues and deteriorated financial condition, these concerns pose a significant threat to both the immediate and long-term success of Jacksonville’s HCV program. Responsible: Nan McKay & Associates POINT OF CONTACT: Steven Rosario, Sr. Director EMAIL: srosario@nanmckay.com JHA POC: Roslyn Phillips, Interim COO EMAIL: RPHILLIPS@JAXHA.ORG

View Audit 361093

Finding 569828 (2024-003)

Material Weakness 2024

Jacksonville Housing Authority

FL

HUD Housing Programs Eligibility Internal Control / Segregation of Duties

The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Contract (ACC), the program receives over $90M from the United States Department of Housing and Urban Development (HU...

The Jacksonville Housing Authority’s (JHA) Housing Choice Voucher (HCV) program is the largest rental assistance program in the City of Jacksonville. Through the Annual Contributions Contract (ACC), the program receives over $90M from the United States Department of Housing and Urban Development (HUD) and assist over 7,700 families each year. The ACC requires JHA to comply with federal regulations and HUD guidelines, as amended from time to time. Audit Findings Berman Hopkins Wright & LaHam, CPAs and Associates, LLP conducted the recent FY2024 JHA Audit (Period: October 1, 2023 – September 30, 2024) and identified continued material weakness findings within the JHA Housing Choice Voucher (HCV) program including but not limited to: Material Weaknesses in Internal Controls, Material Weaknesses in Non-Compliance and Material Weaknesses in the Housing Quality Standards (HQS) Inspection process. Berman Hopkins Wright & LaHam, CPAs and Associates, LLP previously conducted JHA’s FY2023 audit (Period: October 1, 2022 – September 30, 2023) and FY2022 audit (Period: October 1, 2021 – September 30, 2022) which disclosed consecutive historical material weaknesses in JHAs internal controls and noncompliance of the Housing Choice Voucher (HCV) program. Under new CEO leadership at JHA, a request to the JHA Board of Commissioners is in place for a vote on Friday, June 27, 2025, to authorize the following action of Nan McKay & Associates to Administer, Manage and Operate the JHA Housing Choice Voucher Program for an effective date of Monday July 7, 2025. Pending Resolution: AUTHORIZE THE AWARD OF THE MIAMI-DADE HOUSING & COMMUNITY DEVELOPMENT PIGGYBACK CONTRACT IN THE NOT-TO-EXCEED AMOUNT OF 72% OF THE ADMINISTRATIVE FEES CONCURRENT WITH THE EXISTING CONTRACT TERMS TO NAM MCKAY AND ASSOCIATES, FOR HOUSING CHOICE VOUCHER MANAGEMENT AND OPERATIONS. As evidenced by the increase in overall HCV audit findings, loss of federal revenues, inability to correctly serve existing and future HCV program participants, noncompliance on both a local and federal level for section 8 program funding for the administration and operations of the HCV program, immediate action is requested to authorize Nan McKay & Associates to administer and operate JHA’s HCV program immediately. Combined with a plethora of likely compliance issues and deteriorated financial condition, these concerns pose a significant threat to both the immediate and long-term success of Jacksonville’s HCV program. Responsible: Nan McKay & Associates POINT OF CONTACT: Steven Rosario, Sr. Director EMAIL: srosario@nanmckay.com JHA POC: Roslyn Phillips, Interim COO EMAIL: RPHILLIPS@JAXHA.ORG

View Audit 361093

Corrective Action Plans

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