Corrective Action Plans

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Finding Reference # 2022-002, Material Weakness in internal control over compliance and instance of immaterial noncompliance. Compliance Requirement: Allowable Costs Auditor’s Recommendation: We recommend management return to the previous process for recording payroll costs to grants and programs by...
Finding Reference # 2022-002, Material Weakness in internal control over compliance and instance of immaterial noncompliance. Compliance Requirement: Allowable Costs Auditor’s Recommendation: We recommend management return to the previous process for recording payroll costs to grants and programs by which individual employee salaries and wages are allocated based on actual time spent on various activities and are directly charged to the respective activity cost centers benefited. Corrective Action: In 2022, we began outsourcing our payroll processing to Paychex, Inc. During that transition, we changed our process for entering payroll into our accounting software and began using aggregation of total employee hours. Management will return to the practice of allocating payroll per employee instead of using aggregate totals, effective immediately. Management will also contact grantors to resolve any errors in cost reimbursements resulting from 2022 payroll allocation corrections.
Finding 2022-003 When orders are generated in Ceres a ship date is established. Occasionally, due to weather, agency staffing, or other issues, the anticipated distribution date will have to change. There are also situations where disruptions in the computer system may require a different date in t...
Finding 2022-003 When orders are generated in Ceres a ship date is established. Occasionally, due to weather, agency staffing, or other issues, the anticipated distribution date will have to change. There are also situations where disruptions in the computer system may require a different date in the system when is available. GHFB takes several measures in making sure the records are secured and stored in an area known by several employees so that once a record is completed it can be filed and inventory integrity is maintained. Person responsible: Norman Stafford...10/1/23 completion date
Finding 2022-002 Golden Harvest Food Bank (GHFB) does not generate the Bill of Lading (BOL) for product being delivered. The USDA instructs vendors to include several numbers to be annotated on the BOL for reporting reasons. These numbers start with 1000, 2000, 3000, 4000, and 5000. There are occas...
Finding 2022-002 Golden Harvest Food Bank (GHFB) does not generate the Bill of Lading (BOL) for product being delivered. The USDA instructs vendors to include several numbers to be annotated on the BOL for reporting reasons. These numbers start with 1000, 2000, 3000, 4000, and 5000. There are occasions where some of these numbers are not included on the accompanying BOL when delivered. GHFB personnel look for any of the above numbers to insure items are TEFAP. As required, GHFB is required to report the receipt of the TEFAP items to the appropriate state entity that manages the TEFAP program. This report requests the 4000 and the 5000 numbers. If either one of those numbers is not on the BOL, the omission is annotated in this report. In addition to these numbers GHFB also maintains a listing of TEFAP products due in the first 15 days of the month and TEFAP products due in the second half of each month. GHFB believes all BOL have been signed by our personnel. Going forward all BOLs will be signed by both the individual who receives the product as well as the warehouse or inventory manager. Person responsible: Norman Stafford...10/1/23 completion date
Finding 2022-001 ...
Finding 2022-001 Mercy Church was a new agency in 2022 and signed all agreements July 20, 2022. The annual mandatory Recertification training for all agencies occurs at the end of July and the first of August each year. Therefore, there is an approximate six-week period before the new fiscal year begins October 1. Following recertification, all agencies are activated in CERES for the new year and as a result, Mercy Church was also activated and placed their first order in September shortly before the new fiscal year began. They have been compliant ever since, it was just a matter of timing. Our Community Impact team will ensure that new agencies that are brought on prior to the fiscal year are not activated in our systems until the new fiscal year begins to prevent this in the future. All agencies are trained and monitored for federal compliance on a regular basis. Person responsible: Amy Breitmann...10/1/23 completion date
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s internal controls were not designed to properl...
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s internal controls were not designed to properly ensure a review over program expenditures occurred that expenses being incurred and the basis for ultimate reimbursement were incurred within the grant award’s period of performance. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will implement controls that address whether expenses incurred have a basis for reimbursement and are incurred within the period of performance. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: March 2024
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s existing controls over federal award reporting...
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation’s existing controls over federal award reporting did not identify and correct that reports submitted to the grantor were submitted with inaccurate information and that the supporting documentation used to prepare the reports were utilizing budgeted expensed amounts rather than actual. Furthermore, the budgeted expensed amounts from the supporting documentation that were the basis for the amounts to report, did not agree with the ultimate amount reported. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will leverage our general ledger to retain documentation for approval and review of expenditures. We will utilize actual amounts for expenditures and in circumstances where budgeted amounts are needed, we will perform a true-up on a quarterly basis. Management will perform quarterly reviews over financial reporting. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: July 2023
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The auditors identified certain expenditures tested lacked prop...
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The auditors identified certain expenditures tested lacked proper documentation of review and approval and those expenditures submitted for reimbursement were based on budgeted amounts expended rather than actual with no true up performed. They also identified one expenditure deemed potentially unallowable. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will leverage our general ledger to retain documentation for approval and review of expenditures. We will utilize actual amounts for expenditures and in circumstances where budgeted amounts are needed, we will perform a true-up on a quarterly basis. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: July 2023
View Audit 10124 Questioned Costs: $1
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation did not retain documentation to support performa...
U.S. Department of the Treasury Passed through State of Arizona, Maricopa County (Maricopa County), Federal Financial Assistance Listing #21.027, PE386182260A4 2022 Coronavirus State and Local Fiscal Recovery Funds Finding Summary: The Foundation did not retain documentation to support performance of a price analysis nor provide the opportunity for open competition. Additionally, the Foundation did not review for suspension or debarment and required contract provisions were not followed. Management’s Response and Corrective Action Plan: Televerde Foundation has experienced significant growth from inception in March 2020 to fiscal year ended December 31, 2022. We have grown from contributions and grants of $83 thousand and $50 thousand, respectively, in March 2020 to contributions and grants of $236 thousand and $978 thousand, respectively, as of December 31, 2022. During this same period, Televerde Foundation went from 3 employees to 21 employees and experienced significant turnover in finance staff including 2 CFO’s, 2 Controllers, and four staff accountants. The growth combined with lack of a consistent finance team is the primary cause of this deficiency. To address the deficiency, management will perform the actions below. Management will retain and catalog documentation related to price quotes for certain Foundation expenditures. We will update our procurement policy to be consistent with federal guidelines to assist in streamlining the procurement process. We have hired a Grant Administrator and Analyst who is responsible for reviewing contractors against the System for Award Management for suspension or debarment, including subrecipients. Responsible Individuals: Michelle Cirocco, Executive Director Anticipated Completion Date: January 2024
View Audit 10124 Questioned Costs: $1
The Breathitt County Fiscal Court has adopted the KY Model Procurement Code, effective in August 2023. In addition the Fiscal Court hired a new Applicant Agent in January 2023 and transitioned all FEMA related work to the in-house Applicant Agent in August of 2023 rather than contracting services th...
The Breathitt County Fiscal Court has adopted the KY Model Procurement Code, effective in August 2023. In addition the Fiscal Court hired a new Applicant Agent in January 2023 and transitioned all FEMA related work to the in-house Applicant Agent in August of 2023 rather than contracting services through the Disaster Recovery firm the court had been working with prior to August 2023. With the hiring of the new Applicant Agent, proper bid documentation is being maintained & proper procedures are being followed for procurement of bids. The Breathitt County Fiscal Court has also changed the software used for tracking purchase orders which will allow for better tracking of both planned expenditures and already expended funds.
View Audit 10099 Questioned Costs: $1
Corrective Action Plan: The District will ensure its Schedule of Expenditures of Federal Awards is complete and expenditures are properly reported.
Corrective Action Plan: The District will ensure its Schedule of Expenditures of Federal Awards is complete and expenditures are properly reported.
The duties will continue to be segregated as much as possible, and the Board will continue to remain involved in the financial affairs of the Agency to provide oversight and independent review functions.
The duties will continue to be segregated as much as possible, and the Board will continue to remain involved in the financial affairs of the Agency to provide oversight and independent review functions.
The Agency will continue to work to ensure that the financial statements are completed, audited and issued prior to the Data Collection Form due date.
The Agency will continue to work to ensure that the financial statements are completed, audited and issued prior to the Data Collection Form due date.
The University agrees with this finding. To mitigate future risk all FEMA funds received in FY24 or later will be recorded by our Sponsored Program Accounting team, consistent with all other federal awards. Additionally, beginning in FY24 management will implement a formal reconciliation process for...
The University agrees with this finding. To mitigate future risk all FEMA funds received in FY24 or later will be recorded by our Sponsored Program Accounting team, consistent with all other federal awards. Additionally, beginning in FY24 management will implement a formal reconciliation process for all income recorded as “Other Income” and work directly with the University Office of Sponsored Programs to evaluate all uncommon income receipts.
Corrective Action: The lack of timeliness in payouts to SSVF subrecipients was largely due to the transition CAPO underwent in fiscal providers in 2022, and to a lack of sufficient internal staff to adequately manage the SSVF program’s growing fiscal requirements. The amount of SSVF funding CAPO pa...
Corrective Action: The lack of timeliness in payouts to SSVF subrecipients was largely due to the transition CAPO underwent in fiscal providers in 2022, and to a lack of sufficient internal staff to adequately manage the SSVF program’s growing fiscal requirements. The amount of SSVF funding CAPO passes through has increased significantly since 2021, and existing staffing was insufficient to assure timely tracking of draws and payments. Since moving to SMJ and hiring a Finance Manager, CAPO has improved the fiscal management of this grant considerably. CAPO is also hiring an Account Specialist to be assigned directly to SSVF invoicing and accounting needs. They will be charged to the VA grant and will work with the SSVF Program Manager and CAPO’s Finance Manager to process invoices, draw funds, and issue payments. Person Responsible: Janet Allanach, Rose Bradshaw, SSVF Program Manager; Shane Melton, Finance Manager. Timing for Implementation: Partially complete/In progress until December 31st, 2023, completion.
Corrective Action: CAPO was unable to locate Board minutes from FY 22 that indicate any increase in compensation for Janet Merrell (prior Executive Director through May 2022). We have been informed by the Board that the last increase was likely prior to 2020, as she had requested additional time of...
Corrective Action: CAPO was unable to locate Board minutes from FY 22 that indicate any increase in compensation for Janet Merrell (prior Executive Director through May 2022). We have been informed by the Board that the last increase was likely prior to 2020, as she had requested additional time off in lieu of additional salary increases. The last record of an evaluation is in the minutes from a Board meeting in August of 2020. Discussion of compensation would have occurred during an Executive Session and would be in the possession of the Secretary at the time and not in CAPO files. Currently, Executive session notes are kept by the Treasurer and will be carefully retained for and accessible to future audits. Person Responsible: CAPO Board of Directors Timing for Implementation: Complete
Corrective Action: Immediately after coming on board in May of 2022, the new Executive Director took action to move CAPO’s fiscal services contract from the current provider to a new accounting firm in Portland, Oregon – Susan Matlack Jones and Associates (SMJ) – as of July 1, 2022. SMJ works with ...
Corrective Action: Immediately after coming on board in May of 2022, the new Executive Director took action to move CAPO’s fiscal services contract from the current provider to a new accounting firm in Portland, Oregon – Susan Matlack Jones and Associates (SMJ) – as of July 1, 2022. SMJ works with several Community Action agencies in Oregon and their expertise is specifically in nonprofit accounting. They worked to resolve accounting issues from the latter half of FY 22 for the purposes of the audit and currently produce timely, accurate financial statements for CAPO management and Board review. As of October 2023, CAPO has also hired an in-house Finance Manager with experience in Community Action and federal fund accounting. Person Responsible: Janet Allanach, CAPO Executive Director Timing for Implementation: Complete as of July 1, 2022.
Finding 7604 (2022-004)
Significant Deficiency 2022
The Housing Services Development District (HSDD) had previously been attempting to reconstruct, where feasible, the client files received from the previous management contractor. We have continued on this effort in an attempt to eliminate the audit finding moving forward. It should be noted, that fi...
The Housing Services Development District (HSDD) had previously been attempting to reconstruct, where feasible, the client files received from the previous management contractor. We have continued on this effort in an attempt to eliminate the audit finding moving forward. It should be noted, that files effected under the HSDD Management did not contain this deficiency. As such, audit files selected for the 2023 audit year will contain all relevant monitoring documentation.
Finding 7602 (2022-003)
Significant Deficiency 2022
In response to the sole December 31, 2022 Audit finding related to JeffCAP, the finding was corrected for Head Start Birth to Five Program Year 2022- 2023. The department requested and obtained extensive training and professional development from the Office of Head Start related to reporting. Polici...
In response to the sole December 31, 2022 Audit finding related to JeffCAP, the finding was corrected for Head Start Birth to Five Program Year 2022- 2023. The department requested and obtained extensive training and professional development from the Office of Head Start related to reporting. Policies and procedures were reviewed and updated to include developing a timeline for submitting all reports and supporting documentation. Additionally, training with the Parish Accounting Department and Information Technology Department to obtain fiscal data and documentation to prepare necessary reports. The department has solicited services from a third-party entity to assist with all fiscal matters and support compliance related to reporting. JeffCAP Head Start Governing Board and Policy Council reviewed and approved all policies and procedures related to Fiscal Reporting and Account Set Up and Emergency Preparedness: Fiscal Reporting, Reimbursement, and Receipt Verification. The Head Start Fiscal Policy and Procedure was written per Head Start Performance Standards 1302.102(d)l23 and local, state, and federal (45CPR 75.400 and 2 CPR, Part 200) standards and compliance regulations. In addition, Head Start Emergency Preparedness Policy and Procedure was written following US Department of Agriculture (USDA) 7CFR Part 226, Food & Nutrition Service (FNS) 796-2, LA Department of Education- CACFP Training Module 7, and local, state and federal (45CFR, Part 74 and 2 CPR, Part 200) standards and compliance regulations.
Views of Responsible Officials and Planned Corrective Actions: Management understands the importance of defining and following the necessary policies and procedures to remain in compliance with the requirements under 2 CFR 200.302 and have sufficient staff to comply. We will follow the recommendat...
Views of Responsible Officials and Planned Corrective Actions: Management understands the importance of defining and following the necessary policies and procedures to remain in compliance with the requirements under 2 CFR 200.302 and have sufficient staff to comply. We will follow the recommendation of the Audit. Action Taken: Horsham will adopt new policies that address CFR 200.302 requirements. Anticipated Completion: January 2023
Views of Responsible Officials and Planned Corrective Actions: Management understands the importance of following good financial practices. We now have sufficient staff in order to perform the necessary bank reconciliations, ledger adjustments and correcting entries so that we don’t take a chance ...
Views of Responsible Officials and Planned Corrective Actions: Management understands the importance of following good financial practices. We now have sufficient staff in order to perform the necessary bank reconciliations, ledger adjustments and correcting entries so that we don’t take a chance on having any errors in financial reporting. We will follow the recommendation of the Audit. Action Taken: Horsham Township will ensure that bank reconciliations are performed timely now that the staffing requirements are filled. Anticipated Completion: Immediate
Finding: Care’s Single Audit package was not submitted to the Federal Audit Clearinghouse by the deadline of September 30, 2023. Corrective Actions Taken or Planned: We plan to submit the Single Audit report package to the Federal Audit Clearinghouse upon issuance of the Single Audit report. Pers...
Finding: Care’s Single Audit package was not submitted to the Federal Audit Clearinghouse by the deadline of September 30, 2023. Corrective Actions Taken or Planned: We plan to submit the Single Audit report package to the Federal Audit Clearinghouse upon issuance of the Single Audit report. Person Responsible: Dave Dixon SVP/CFO Anticipated Completion Date: 12/28/23
The district continues to find solutions to help segregate duties with our minimally staffed central office (business manager, HR director & nutrition direct). This year we modified duties of our building secretaries due to being short staffed. This eliminated an additional check & balance measure a...
The district continues to find solutions to help segregate duties with our minimally staffed central office (business manager, HR director & nutrition direct). This year we modified duties of our building secretaries due to being short staffed. This eliminated an additional check & balance measure added a few years ago of the secretary entering receipts into WebLink. The building secretaries continue to write deposit slips & post payment to our student information system. The district’s business manager & HR director will work with board members on the finance & negotiations committee to develop a plan to add more checks & balances to our current operation. We will use the segregation of duties handbook to help with this process.
We will continue to review procedures and re-align duties to obtain the maximum internal control possible.
We will continue to review procedures and re-align duties to obtain the maximum internal control possible.
The Council began a building renovation project before it became aware that funds were available to support the project. Therefore, the Council was not able to comply with regulations at the time of project design, bidding, planning, and construction. In addition, the Council’s project was only part...
The Council began a building renovation project before it became aware that funds were available to support the project. Therefore, the Council was not able to comply with regulations at the time of project design, bidding, planning, and construction. In addition, the Council’s project was only partially funded by the Coronavirus Recovery Funds, the majority of the project was funded through the Council’s fundraising efforts. Management agrees with the finding and is in the process of implementing the recommended procedures for future projects.
DEPARTMENT OF AGRICULTURE. Market Access Program and Agricultural Trade Promotion Program Assistance Listing Number: 10.601 & 10.618. Recommendation: We recommend the Organization ensure the completion of the controls within their policies to ensure an adequate review process is in place prior to ca...
DEPARTMENT OF AGRICULTURE. Market Access Program and Agricultural Trade Promotion Program Assistance Listing Number: 10.601 & 10.618. Recommendation: We recommend the Organization ensure the completion of the controls within their policies to ensure an adequate review process is in place prior to cash disbursement payments and claims submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Food Export-Northeast, under the direction of the new Executive Director /CEO, has undergone a significant restructuring effective July 2023. This restructure has resulted in the installation of a Chief Financial Officer, reporting directly to the Executive Director/CEO. Similar “C-suite” positions now exist in Operations, Programs, and Communications. This has significantly increased the scope and ability for oversight and internal control. Internal policies and procedures are currently under review; any changes to policies and procedures will be made as needed/identified. Increased monitoring and enforcement of existing internal control measures has already resulted in improved completeness and accuracy of financial reporting. In September 2023, the Food Export staff met with FAS staff to review procedures and policies, including meetings with Management to review and evaluate controls. The feedback from those meetings will be incorporated into any updates on procedure. Names of the contact person(s) responsible for corrective action: Brendan Wilson, Food Export Executive Director/CEO; Michelle Rogowski, Chief Operating Officer, Laura England, Deputy Director/Chief Communications Officer; Robert Lowe, CPA, Chief Financial Officer; Teresa Miller, Chief Program and Partnership Officer. Planned completion date for corrective action plan: December 31, 2023. If the U.S. Department of Agriculture has questions regarding this plan, please call Laura England at (215) 599-9738 or contact via email at lengland@foodexport.org.
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