Corrective Action Plans

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5. Budget revisions are evaluated under 45 CFR § 75.308, and HRSA prior approval is requested when required.
5. Budget revisions are evaluated under 45 CFR § 75.308, and HRSA prior approval is requested when required.
6. All budgets and budget modifications are approved by the Board of Directors and reflected in monthly financial management reports.
6. All budgets and budget modifications are approved by the Board of Directors and reflected in monthly financial management reports.
Corrective Action Plan:
Corrective Action Plan:
1. The Controller, outside account and CEO conduct monthly budget-to-actual reviews for all federal awards, using variance analysis tools.
1. The Controller, outside account and CEO conduct monthly budget-to-actual reviews for all federal awards, using variance analysis tools.
2. Variance reports are submitted to the CEO and reviewed with the Finance Committee on a monthly basis.
2. Variance reports are submitted to the CEO and reviewed with the Finance Committee on a monthly basis.
3. HRSA budget categories were added to the general ledger in 2024 to enable accurate expenditure tracking by category.
3. HRSA budget categories were added to the general ledger in 2024 to enable accurate expenditure tracking by category.
4. Training on budget monitoring and federal requirements was conducted in June 2024 and will be repeated annually.
4. Training on budget monitoring and federal requirements was conducted in June 2024 and will be repeated annually.
5. Budget compliance is reviewed quarterly as part of SCMRC’s internal financial monitoring processes.
5. Budget compliance is reviewed quarterly as part of SCMRC’s internal financial monitoring processes.
Corrective Actions Taken:
Corrective Actions Taken:
1. Responsibility for tracking the period of performance for all federal grants was assigned to the Controller in April 2025, with oversight provided by the CEO and Finance Committee.
1. Responsibility for tracking the period of performance for all federal grants was assigned to the Controller in April 2025, with oversight provided by the CEO and Finance Committee.
2. A centralized compliance calendar is now maintained to track grant start and end dates, obligation deadlines, and reporting due dates.
2. A centralized compliance calendar is now maintained to track grant start and end dates, obligation deadlines, and reporting due dates.
3. Internal controls have been implemented within the accounting and review process to help ensure obligations and expenditures occur within approved grant timelines.
3. Internal controls have been implemented within the accounting and review process to help ensure obligations and expenditures occur within approved grant timelines.
4. Monthly reviews of federal grant expenditures now include verification of the period of performance.
4. Monthly reviews of federal grant expenditures now include verification of the period of performance.
5. A retrospective review of FY21–FY23 grant expenditures was initiated in 2025.
5. A retrospective review of FY21–FY23 grant expenditures was initiated in 2025.
Corrective Action Plan:
Corrective Action Plan:
1. Period-of-performance tracking will be formally added to Finance Committee updates starting Q4 2025.
1. Period-of-performance tracking will be formally added to Finance Committee updates starting Q4 2025.
2. The Controller and CEO will complete a comprehensive retrospective review of grant obligations spanning prior period end dates by December 2025, with appropriate documentation and HRSA notification as needed.
2. The Controller and CEO will complete a comprehensive retrospective review of grant obligations spanning prior period end dates by December 2025, with appropriate documentation and HRSA notification as needed.
3. Internal audit checklists will be updated in Q4 2025 to include period-of-performance compliance for all sampled federal expenditures.
3. Internal audit checklists will be updated in Q4 2025 to include period-of-performance compliance for all sampled federal expenditures.
4. Finance staff will receive refresher training on period-of-performance requirements and documentation standards by the end of 2025.
4. Finance staff will receive refresher training on period-of-performance requirements and documentation standards by the end of 2025.
Corrective Actions Taken:
Corrective Actions Taken:
1. SCMRC revised its federal drawdown procedures in 2024 to require documented review and approval of all expenditures before submitting any drawdown request.
1. SCMRC revised its federal drawdown procedures in 2024 to require documented review and approval of all expenditures before submitting any drawdown request.
2. A Draw Down Request Workbook is now prepared by the Controller and reviewed against supporting documentation, including invoices, timecards, and purchase records.
2. A Draw Down Request Workbook is now prepared by the Controller and reviewed against supporting documentation, including invoices, timecards, and purchase records.
3. The CEO reviews and signs off on each Draw Down Request prior to submission.
3. The CEO reviews and signs off on each Draw Down Request prior to submission.
4. Completed Draw Down Request Workbooks are submitted to HRSA for prior approval and retained for audit purposes.
4. Completed Draw Down Request Workbooks are submitted to HRSA for prior approval and retained for audit purposes.
5. Internal drawdown audits are conducted monthly to confirm alignment with federal cash management standards.
5. Internal drawdown audits are conducted monthly to confirm alignment with federal cash management standards.
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