Corrective Action Plans

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#2025-001 Lack of Required Independent Estimate for Procurement Exceeding the Simplified Acquisition Threshold 1. Update Policies and Procedure Management will revise procurement policies and procedures to clearly require: preparation of an independent estimate, and completion and documentation of a...
#2025-001 Lack of Required Independent Estimate for Procurement Exceeding the Simplified Acquisition Threshold 1. Update Policies and Procedure Management will revise procurement policies and procedures to clearly require: preparation of an independent estimate, and completion and documentation of an independent estimate for all procurements exceeding the simplified acquisition threshold. 2. Implement Procurement Control Checkpoints System-based controls and/or manual review checkpoints will be added to ensure independent estimates are attached before purchase orders or contract awards are approved. 3. Staff Training Procurement and program staff will receive training on: federal procurement requirements (2 CFR 200), when independent estimates are required, and how to properly prepare and retain the documentation. 4. Ongoing Monitoring and Compliance Review Management will implement periodic reviews of procurement files to verify compliance with updated policies. Any deficiencies noted will be corrected promptly and used to inform additional training needs. Responsible Party: Business Manager Timing for Completion: Within 90 days
Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit fin...
Common Origination and Disbursement (COD) Reporting Recommendation: We recommend the College evaluate its policies and procedures around reporting to the COD to ensure that information is reported accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: A PELL reconciliation report will be pulled monthly to check that the disbursement dates/amounts on COD match the disbursement dates/amounts on PowerFAIDS and Bionic. Name of the contact person responsible for corrective action: Shannon Braccili, Associate Director of Financial Aid Planned completion date for corrective action plan: Effective starting August 2025 with the first Fall 2025 PELL disbursement and continuing through the end of the academic year. This procedure will continue to be followed in subsequent academic years.
U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that a...
U.S. Department of Education National Student Loan Data Systems (NSLDS) Enrollment Reporting - Federal Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College review its policies and procedures on reporting of enrollment status changes to NSLDS to ensure that all status changes are being reported accurately to be in compliance with regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: An investigation that uncovered a National Student Clearinghouse enrollment transmission proofing error related to program-level effective date for graduated students. Name of the contact person responsible for corrective action: James Keane, Registrar Planned Corrective Action Plan: The Registrar's Office will ensure that the program level effective date for graduates is accurate prior to submission. The Registrar will also partner with IITS to ensure that the program-level effective date for graduates is generated in the submission file as expected. Planned completion date for corrective action plan: May 2026, prior to the June 2026 submission date.
To Whom It May Concern: This letter is in response to the audit finding identified in the annual district financial report for fiscal year ending June 30, 2025 issued by Leo Riley & Co. This letter addresses the compliance findings 2025-001 and 2025-002 regarding internal controls. Weston County Sch...
To Whom It May Concern: This letter is in response to the audit finding identified in the annual district financial report for fiscal year ending June 30, 2025 issued by Leo Riley & Co. This letter addresses the compliance findings 2025-001 and 2025-002 regarding internal controls. Weston County School District #7 acknowledges that, due to the small office staff, it makes it impractical for the district to achieve full separation of the accounting functions in the business office. The District believes it has mitigated the risks associated with this limitation through use of various controls and segregation of functions to the greatest extent possible. The governing board is also involved in the approval process being the final authority over accounts payable expenditures. The District utilizes the accounting manual as provided by the Wyoming Department of Education. The business office staff, district administrative staff, and the school board are fully aware of the limitations in this area and have a heightened awareness when performing their duties to further mitigate risks. Gina Barritt WCSD7 Business Manager 307-468-2461
Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subr...
Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subrecipient activities as required under FFATA regulations. However, the lack of a clearly defined responsibility for this task resulted in non-compliance. Management recognizes this gap and is committed to implementing corrective measures to ensure full compliance moving forward.
Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although ...
Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although procedures exist for verifying SAM.gov registration (suspension/debarment status) and obtaining audited financial statements from subgrantees, these procedures were not documented or codified in the Caminos Nacional Policy Manual. Pre-award risk assessments have been conducted informally without a formal determination of risk, and protocols surrounding risk assessment were inadequately documented, resulting in inconsistent implementation.
Views of Responsible Officials: Management acknowledges the findings related to Payroll Allocation, and Training & Compliance, as outlined in the recent audit report. We appreciate the recommendations provided and are committed to implementing corrective actions to strengthen compliance, improve pay...
Views of Responsible Officials: Management acknowledges the findings related to Payroll Allocation, and Training & Compliance, as outlined in the recent audit report. We appreciate the recommendations provided and are committed to implementing corrective actions to strengthen compliance, improve payroll allocation accuracy, and enhance staff knowledge of grant management requirements.
Finding Synopsis: One employee's payroll disbursement made under the Child Nutrition Cluster was improperly calculated. Action Steps: A district staff member will review the payroll calculations so no transpositions or errors occur. Contact Person(s): Dr. Jennifer Garrison, Superintendent Anticipate...
Finding Synopsis: One employee's payroll disbursement made under the Child Nutrition Cluster was improperly calculated. Action Steps: A district staff member will review the payroll calculations so no transpositions or errors occur. Contact Person(s): Dr. Jennifer Garrison, Superintendent Anticipated Completion Date: February 11, 2026
Management is cognizant of this limitation and will implement additional procedures where possible.
Management is cognizant of this limitation and will implement additional procedures where possible.
PBRA/MOD Vacant Units Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and within other relevant records. Explanation of disagreement with audit finding: There is no disagreement with the audi...
PBRA/MOD Vacant Units Recommendation: The Commission should implement processes to ensure that vacancies are appropriately accounted for in the HUD-52670's, within HAP registers, and within other relevant records. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies site staff will retrain staff on the move-out / deposit accounting process and the required month end closeout process no later than February 28, 2026. Regional Managers will review and confirm completion of end-of-month checklists to verify that all required monthly tasks have been performed, thereby reducing the risk of this exception occurring in the future. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately corrected this discrepancy and will implement the remaining corrections by February 28, 2026.
PBRA/MOD Housing Quality Standards Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. Explanation of disagreement with audit finding: ...
PBRA/MOD Housing Quality Standards Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences and that related inspections are performed on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, policy has been updated to reflect the requirement to complete within 365 days of the previous inspection. Name(s} of the contact person(s} responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action as outlined above.
PBRA/MOD Eligibility Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action tak...
PBRA/MOD Eligibility Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained during the recertification process for every client. Explanation of disagreement with audit finding: There is no disagreement with the audit findings. Action taken in response to finding: HOC's third-party management agent, Pratum Companies, will retrain all site staff on acceptable and complete forms of income, asset, and expense documentation for initial certifications and the annual recertification process no later than February 15, 2026. Pratum's Compliance team will continue to review each new move-in file from eligibility determination through lease execution to ensure ongoing programmatic compliance. In addition, the Compliance team will complete supplemental training by February 15, 2026, to reinforce proper use of the internal control's checklist, which is required to be attached to all submitted move-in files. Name(s) of the contact person(s) responsible for corrective action: Shannon Bodnar, Senior Vice President of Compliance, Pratum Darcel Cox, Vice President of Compliance, HOC Planned completion date for corrective action plan: Pratum immediately implemented the corrective action outlined above.
HCVP Housing Quality Standards and Enforcement Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abateme...
HCVP Housing Quality Standards and Enforcement Recommendation: The Commission should implement processes to ensure that all proper documentation is being maintained for inspections of tenant residences, that related inspections are performed on a timely basis, and ensure standards related to abatement of housing assistance payments are being followed. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HOC will collaborate with the software vendor, IT department, and a third-party consultant to remediate system deficiencies affecting inspection tracking and compliance. This will include developing and implementing quality control reports to identify units with failed or overdue inspections, restoring accurate inspection date tracking, and strengthening monitoring processes to ensure timely inspections, abatements, and enforcement in accordance with program regulations. Name(s) of the contact person(s) responsible for corrective action: Lynn Hayes, Vice President of Housing Resources Division. Planned completion date for corrective action plan: HRD has initiated implementation of the corrective action plan by engaging the IT department and the software vendor to assess system deficiencies impacting inspection tracking, abatement enforcement, and regulatory compliance. Initial meetings have focused on identifying root causes, reviewing data integrity issues, and evaluating potential system enhancements and reporting solutions to improve monitoring and oversight. HOC will continue coordinated efforts with IT, the software vendor, and a third-party consultant to design, test, and implement corrective measures. Full implementation and stabilization of the identified solutions is anticipated to be completed by December 2026.
Suspension & Debarment – Special Education Cluster (IDEA) Recommendation: We recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Action planned/taken in response to finding: Th...
Suspension & Debarment – Special Education Cluster (IDEA) Recommendation: We recommend the District evaluate current procedures and controls to ensure that policies are consistently followed and properly documented in accordance with District policies. Action planned/taken in response to finding: The District has reviewed its existing procedures related to suspension and debarment requirements and has reinforced expectations for consistent adherence and documentation in accordance with District policies and federal grant requirements. Management has implemented additional oversight to ensure required checks are completed and properly documented prior to vendor engagement and payment. Procedures will continue to be monitored to ensure compliance is consistently maintained. Name of the contact person responsible for correction action: Kristin Sobocinski Planned completion date for corrective action: June 30, 2026 Responsible Official for Corrective Action Plan: Kristin Sobocinski, Deputy Superintendent (608) 316-1916
Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Explanation of disagreement with audit findi...
Segregation of Duties – Child Nutrition Cluster Recommendation: We recommend the District establish a procedure for timely review and approval of claims prior to their submission for reimbursement by someone who is knowledgeable of the grant requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The District has implemented procedures to ensure that Child Nutrition claims are reviewed and approved prior to submission by an individual knowledgeable of grant requirements. This review includes verification of claim accuracy, supporting documentation, and compliance with applicable federal regulations. Name of the contact person responsible for correction action: Kristin Sobocinski Planned completion date for corrective action: Ongoing, June 30, 2026
Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance D...
Finding Reference Number: Finding 2025-004: Significant Deficiency in Internal Control and Compliance over Reporting – Medicaid Cluster Corrective Action: The District submitted corrected versions of the Quarterly Financial Summaries to SBS after audit fieldwork. The District plans for the Finance Director to review Quarterly Financial Summaries and Annual Cost reports and document this review before submitting to SBS. The payroll coordinator will prepare the quarterly financial summaries and they will be reviewed by the Business Manager prior to submission to ensure accuracy. Responsible Person: Shannon Grindell, Sharon Weise Anticipated Completion Date: Ongoing
Finding Reference Number: Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement – Child Nutrition Cluster Corrective Action: The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service depart...
Finding Reference Number: Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement – Child Nutrition Cluster Corrective Action: The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the procurements. The District will assign someone in the District office to review procurement requirements and ensure contracts meet the District’s policies. The Business Manager will work with the Food Service Director on a process to review procurement requirements and to ensure the contracts meet the District’s policies. This will include language to ensure that a person in the business office will review purchases submitted by the food service department to ensure they are meeting policy requirements. Responsible Person: Shannon Grindell, Susan Mayer
Jeff Cottingham, Management agent, and Father Elia, sponsor of the project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent, and Father Elia, sponsor of the project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Father Elia, sponsor of project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Father Elia, sponsor of project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Wes Clanton, board president of project will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Jeff Cottingham, Management agent and Wes Clanton, board president of project will be responsible for monitoring monthly financial results and accounting information as correction is not practical.
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the ...
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the expenditure reports against the budget items before submitting. Management Response: The District will add a verification process to reconcile the general ledger to the budget and expenditure reports before submitting. The District will consider implementing a detailed grant tracking sheet to ensure the general ledger expenditures agree to the expenses reported to ISBE by grant. Anticipated Date of Completion: June 30, 2026
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the ...
Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the expenditure reports against the budget items before submitting. Management Response: The District will add a verification process to reconcile the general ledger to the budget and expenditure reports before submitting. The District will consider implementing a detailed grant tracking sheet to ensure the general ledger expenditures agree to the expenses reported to ISBE by grant. Anticipated Date of Completion: June 30, 2026
Condition: Equipment records with all required information were not maintained for all items purchased with federal funds. Recommendation: We recommend that the District begins the process of maintaining a capital asset log for all equipment purchased with federal funding. Management Response: Manag...
Condition: Equipment records with all required information were not maintained for all items purchased with federal funds. Recommendation: We recommend that the District begins the process of maintaining a capital asset log for all equipment purchased with federal funding. Management Response: Management agrees to take the necessary steps to ensure compliance requirements are met and will discuss implementing an inventory record-keeping process for all equipment purchased with federal funds. Anticipated Date of Completion: June 30, 2026
Condition: We noted that two of the five required expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Mana...
Condition: We noted that two of the five required expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly reports on time in the future. Anticipated Date of Completion: June 30, 2026
The entity has implemented new procedures for the preparation and review of reimbursement requests.
The entity has implemented new procedures for the preparation and review of reimbursement requests.
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