Corrective Action Plans

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Item: 2025-001 Assistance Listing Number: 17.280 Program: WIOA Dislocated Worker National Reserve Demonstration Grants Federal Agency: U.S. Department of Labor Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: 23A60YP000003 Award Year: September 30, 2023 to September 30, 2...
Item: 2025-001 Assistance Listing Number: 17.280 Program: WIOA Dislocated Worker National Reserve Demonstration Grants Federal Agency: U.S. Department of Labor Pass-Through Agencies: n/a Contract/Pass-Through Grantor Identifying Number: 23A60YP000003 Award Year: September 30, 2023 to September 30, 2026 Compliance Requirement: Reporting - FFATA Criteria: The Federal Funding Accountability and Transparency Act (FFATA), as implemented by OMB at 2 CFR Part 170, requires prime recipients of federal awards to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: The Foundation did not complete the required FFATA reporting in FSRS for applicable first-tier subawards. Name of Contact Person Steve Zylstra, President & CEO Phone Number: (602) 422-9447 Anticipated Completion Date: July 31, 2026 Views of Responsible Officials and Corrective Actions: The Foundation has corrected missed FFATA reporting by submitting outstanding subaward information to FSRS as of February 2026. Additionally, the Foundation will establish and document a FFATA reporting policy that defines the FFATA threshold and timing requirements. The Foundation will also assign clear responsibility for FFATA compliance and implement a monthly reconciliation of subaward obligations to FSRS submissions. Lastly, the Foundation will provide periodic training to grants, procurement, and finance staff on FFATA requirements and FSRS processes.
Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management will monitor security deposit refunds in order to ensure refunds meet the Regulatory Agreement requirements.
Management acknowledges noncompliance in the current fiscal year and has taken measures to improve internal controls over compliance. Management will monitor security deposit refunds in order to ensure refunds meet the Regulatory Agreement requirements.
Finding 2025-002: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, one of the twenty-four resident files selected for testing under the OMB Compliance Supplement were unable to be located by the Agent. The Agent should review resident files completed by the F...
Finding 2025-002: Comments on the Finding and Each Recommendation: During the year ended December 31, 2025, one of the twenty-four resident files selected for testing under the OMB Compliance Supplement were unable to be located by the Agent. The Agent should review resident files completed by the Former Agent to ensure that all resident files include all properly executed and documented resident eligibility forms and ensure that these files are maintained at the Property for a minimum of three years. Action(s) taken or planned on the finding: The Agent concurs with the finding and the recommendation. The Agent will review resident files completed by the Former Agent to ensure that all resident files include all properly executed and documented resident eligibility forms and ensure that these files are maintained at the Property for a minimum of three years.
Finding 2025-001: Comments on the Finding and Each Recommendation: The Former Agent did not obtain a HUD approved Project Owner's/Management Agent's Certification (Form HUD-9839-B) and the Property paid unapproved management fees to the Former Agent. The Agent should obtain a HUD-approved Project Ow...
Finding 2025-001: Comments on the Finding and Each Recommendation: The Former Agent did not obtain a HUD approved Project Owner's/Management Agent's Certification (Form HUD-9839-B) and the Property paid unapproved management fees to the Former Agent. The Agent should obtain a HUD-approved Project Owner's/Management Agent's Certification. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. Management of the property transitioned to the Agent on June 1, 2025 and the Agent received a HUD-aproved Project Owner's/Management Agent's Certification for the Property.
FINDING 2025-003: Title I Eligibility Response: To ensure all records are correctly filed and maintained, the district is establishing new protocols for documenting Title eligibility.
FINDING 2025-003: Title I Eligibility Response: To ensure all records are correctly filed and maintained, the district is establishing new protocols for documenting Title eligibility.
This finding is due to the Township not having control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Subsequently, the Township’s engineer has searched the state procurement office webpage to check if any vendor for a federal project...
This finding is due to the Township not having control procedures in place for ensuring contractors performing work on federal projects were not suspended or debarred. Subsequently, the Township’s engineer has searched the state procurement office webpage to check if any vendor for a federal project is on the debarment list, which they are not. In the future, the Township will have controls in place to ensure that vendors are not debarred or suspended from federal funding awards. The person responsible for the corrective action is the Supervisor. The anticipated completion date of the corrective action plan is before the end of the 2026 fiscal year. The plan for adherence is the Board will review implement controls to ensure that vendors are not suspended, debarred, or otherwise excluded.
This finding is due to the Township not having formal written policies in place required by Uniform Guidance. The Township is now aware that these policies are required and will adopt all necessary policies. The Township does not believe that there were any actual nonallowable costs or transactions ...
This finding is due to the Township not having formal written policies in place required by Uniform Guidance. The Township is now aware that these policies are required and will adopt all necessary policies. The Township does not believe that there were any actual nonallowable costs or transactions because of the lack of written policies as required by Uniform Guidance. The Township will adopt all necessary policies to be in compliance. The person responsible for the corrective action is the Supervisor. The anticipated completion date of the corrective action plan is before the end of the 2026 fiscal year. The plan for adherence is that the Board will review all proposed policies and adopt them, the Board will also monitor any changes to policy requirements to ensure that they are in compliance in the future.
Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operat...
Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operations during the lapse in rental assistance payments. Management has since resumed compliance with all HUD approval requirements and will enhance documentation and contingency planning to address similar circumstances in the future. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agent's procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Corrective Action: Management agrees with the finding. Management acknowledges that the withdrawal exceeded the amount approved by HUD and is reviewing internal procedures to ensure replacement reserve withdrawals comply with HUD approval requirements. Mangement will coordinate with HUD to resolve t...
Corrective Action: Management agrees with the finding. Management acknowledges that the withdrawal exceeded the amount approved by HUD and is reviewing internal procedures to ensure replacement reserve withdrawals comply with HUD approval requirements. Mangement will coordinate with HUD to resolve the unapproved portion of the withdrawal and take corrective action as necessary. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson , Chief Financial and Operating Officer.
Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certifications in acco...
Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certifications in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they document and maintain tenant files in accordance with HUD and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson , Chief Financial and Operating Officer.
Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certification...
Corrective Action: The Organization agrees with the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing, documenting, and retaining certifications in accordance with applicable regulations. Ownership periodically reviews the agents' procedures to ensure that they document and maintain tenant files in accordance with HUD and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a tra...
Corrective Action: The Organization agrees with the finding and has continued to implement strategies to address the finding. To address this finding, ownership has moved its portfolio, with the exception of one project, to third party property managers as of January 1, 2026. These agents have a track record of completing certifications on time and in accordance with applicable regulations. Ownership periodically reviews the agent's procedures to ensure that they complete tenant files on time and have routine internal audits of tenant files to ensure compliance with HUD regulations. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operat...
Corrective Action: Management agress with the finding. Due to the federal government shutdown and the temporary suspension of HUD operations, approval for one replacement reserve withdrawal could not be obtained prior to disbursement. The withdrawal was necessary to maintain essential project operations during the lapse in rental assistance payments. Management has since resumed compliance with all HUD approval requirements and will enhance documentation and contingency planning to address similar circumstances in the future. Proposed completion date: Management has begun the corrective action and is expected to have additional internal controls in place by December 31, 2026. Name of contact person: Jennifer Anderson, Chief Financial and Operating Officer
Special Provisions: Rent Reasonableness Federal Agency: Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: January 1, 2025 – December 31, 2025 Compliance Requirement Section: Special Provisions Type of ...
Special Provisions: Rent Reasonableness Federal Agency: Department of Housing and Urban Development Federal Program Title: Section 8 Housing Choice Vouchers Assistance Listing Number: 14.871 Award Period: January 1, 2025 – December 31, 2025 Compliance Requirement Section: Special Provisions Type of Finding: Material Weakness in Internal Control Over Compliance and Other Matters Recommendation: The agency should update its rent reasonableness procedures to ensure: • Rental comparison data is current and regularly refreshed; • Comparable non-assisted units are consistently used; and • Staff are trained on proper rent reasonableness documentation and review standards. The agency should also review a sample of recent rent reasonableness determinations to ensure corrective actions are fully implemented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has taken the following steps to correct the finding: • Updated and refreshed rent reasonableness software data to reflect current market rents. • Configured and are using the software to require selection of comparable non assisted units. • Revisee procedures to document software generated rent reasonableness results in tenant files. • Train staff on correct use of the rent reasonableness software and regulatory requirements. • Conduct supervisory reviews of software based determinations for compliance. Name of the contact person responsible for corrective action: Karen Young, Finance Director Planned completion date for correct action plan: The corrective action plan has already been implemented and will be corrected before December 31, 2026.
Management plans to revamp procedures to ensure that the reports are filed in a timely manner in the future.
Management plans to revamp procedures to ensure that the reports are filed in a timely manner in the future.
Management's Views and Corrective Action Plan: Re: Response to finding 2025-001 2025-001 - RETURN OF TITLE IV FUNDS Cluster: Student Financial Assistance Cluster Sponsoring Agency: Department of Education Award Name: Federal Direct Student Loans Program ALN Number: 84.268 Award Period: 2024-2025 Pas...
Management's Views and Corrective Action Plan: Re: Response to finding 2025-001 2025-001 - RETURN OF TITLE IV FUNDS Cluster: Student Financial Assistance Cluster Sponsoring Agency: Department of Education Award Name: Federal Direct Student Loans Program ALN Number: 84.268 Award Period: 2024-2025 Pass-through Entity: Not applicable Management concurs with the finding. To prevent future delays, we plan to stabilize staffing, increase oversight, and improve workflow efficiency: 1. Increase staffing Following the audit recommendation to maintain consistent staffing, the Graduate School of Education and Psychology’s (GSEP) Financial Aid Office will: • Prioritize hiring by expediting the recruitment and onboarding of full-time Financial Aid positions to fill existing vacancies within the GSEP Financial Aid office. • Cross-train staff and establish a backup schedule where multiple staff members are trained on the Return to Title IV (R2T4) process and can assist during peak withdrawal periods and unexpected staff vacancies. 2. Increase oversight To ensure compliance, the GSEP Financial Aid Office will improve the R2T4 log, tracking every student withdrawal and term cancelation from the date of determination and add internal oversight at the 30-day mark to ensure the 45-day deadline is met. A manager will complete a secondary review of all R2T4 calculations to ensure accuracy and compliance. 3. Improve workflow efficiency To alleviate the high volume of inquiries that contributed to processing backlogs, GSEP is exploring partnering with CollegeVine, a third-party technology solution, to implement school-specific AI agents. With CollegeVine handling routine inquiries via chat and phone, the Financial Aid staff will be able to focus on compliance-oriented tasks. IMPLEMENTATION TIMELINE Increase staffing: Clear existing R2T4 backlog. (Completion: May 1, 2026) Increase staffing: Cross-training Financial Aid staff and implement contingency plan. (Completion: June 1, 2026) Increase staffing: Fill all GSEP Financial Aid vacancies. (Estimated Completion: June 1, 2026) Increase oversight: Implement additional monitoring, reconciliation, and compliance checks. (Completion: June 1, 2026) Workflow efficiency: Implement CollegeVine AI Agents. (Estimated Completion: Undetermined- pending approval) CONCLUSION By stabilizing our workforce and leveraging additional efficiencies, GSEP will ensure that R2T4 processing is prioritized and completed within the 45-day regulatory timeframe. CONTACT FOR THIS PLAN: Jillian Doyle Robinson Director of Student Financial Services Pepperdine Graziadio Business School & Graduate School of Education and Psychology Jillian.Doyle@pepperdine.edu 310-568-5578
The Nutrition Services management team has established an internal schedule to ensure visits are done in a timely and compliant manner.
The Nutrition Services management team has established an internal schedule to ensure visits are done in a timely and compliant manner.
The District will strengthen its internal control system to ensure that each entry within the Nutrition Services data management system meets required program criteria and is fully supported by appropriate documentation. A more robust process of review and verification will be implemented to safegua...
The District will strengthen its internal control system to ensure that each entry within the Nutrition Services data management system meets required program criteria and is fully supported by appropriate documentation. A more robust process of review and verification will be implemented to safeguard the integrity of originating data and prevent compromise. System access controls will also be reinforced to ensure that granted access is appropriate and used in accordance with established protocols. Ensuring the accuracy of meal data will support accurate revenue reporting and, in turn, reliable financial reporting. Moreover, the District will continue to foster a culture of integrity in which all allegations of fraud are taken seriously and addressed promptly. The District will also enhance the visibility and accessibility of its WeTip reporting system to ensure employees, students, and community members can report concerns.
Recommendation: Management should implement stronger internal controls to ensure surplus cash deposits are made in accordance with the required deadlines. This may include setting up automated reminders, improving oversight, or assigning clear responsibilities to ensure compliance. Views of Responsi...
Recommendation: Management should implement stronger internal controls to ensure surplus cash deposits are made in accordance with the required deadlines. This may include setting up automated reminders, improving oversight, or assigning clear responsibilities to ensure compliance. Views of Responsible Officials and Planned Corrective Actions: Management has reviewed the audit finding and acknowledges the delay in depositing surplus cash. Management has submitted a request to HUD to retain the surplus cash for future capital improvements to the property.
Views of Responsible Officials and Planned Corrective Action CRRUA’s fiscal agent, Dona Ana County, implemented a new ERP system, along with key staff changes, that necessitated financial documentation being run several times which delayed complete financial information being provided to the audit t...
Views of Responsible Officials and Planned Corrective Action CRRUA’s fiscal agent, Dona Ana County, implemented a new ERP system, along with key staff changes, that necessitated financial documentation being run several times which delayed complete financial information being provided to the audit team. CRRUA has a new fiscal agent, the City of Sunland Park, for the upcoming fiscal year. CRRUA Board approval of fiscal agent happened in July 2026. CRRUA’s new fiscal agent, the City of Sunland Park, started providing services in FY26. Executive director and assistant director will work with the City of Sunland Park to ensure timely submission of information to the audit team. Finding resolution timeline: June 30, 2026 Designation of employee position responsible for meeting this deadline: Juan Carlos Crosby, Executive Director and David Espinoza, Assistant Director
Corrective Action: LSA will provide training to the appropriate departments and individuals to reinforce disbursement and purchase order policies and procedures within 30 days of the audit submission. Additionally, LSA will provide training to employees emphasizing the organizational policies requir...
Corrective Action: LSA will provide training to the appropriate departments and individuals to reinforce disbursement and purchase order policies and procedures within 30 days of the audit submission. Additionally, LSA will provide training to employees emphasizing the organizational policies requiring employee certification of their payroll timesheets. This change will be made within the next 90 days. Contact Person: George Fort, Director of Finance, (334) 223-0251; gfort@alsp.org
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