Corrective Action Plans

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Finding 2024-016 Material Weakness in Internal Control and Material Noncompliance – Procurement and Suspension and Debarment Condition: The DPS Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases Competitive” procurement policies, that were compliant with Federal Pa...
Finding 2024-016 Material Weakness in Internal Control and Material Noncompliance – Procurement and Suspension and Debarment Condition: The DPS Grant Administration did not adhere to the Danbury Public Schools “Bids and Purchases Competitive” procurement policies, that were compliant with Federal Part 3 compliance guidelines. DPS had a procurement policy in place that was consistent with the standards of the aforementioned compliance sections; however, DPS did not follow their own procurement policy in certain instances which consists of obtaining three quotes for a small purchase procurements and advertising for bids publicly for large >$5,000 purchase procurements. They only obtained one quote for small purchases, and they did not use a public bid process for expenditures over $5,000. Additionally, DPS did not have internal controls in place to ensure vendor eligibility was verified prior to entering into a covered transaction with them. Contact Person: Michael Weaver, CFO, Danbury Public Schools Corrective Actions Planned: We agree with the finding. The policy was revised at the end of the 2025 Fiscal Year. Additionally, a new and additional review process was put into place prior toentering a requisition for approval. This process requires all necessary documentation be furnished to the finance office prior to the requisition being approved. Completion Date: 7/16/2025
Finding 2024-017 Significant Deficiency in Internal Control – Earmarking Condition: Under the Coronavirus State & Local Fiscal Recovery Funds (21.027), the 2022 Final Rule, recipients can elect a one-time “standard allowance” of $10 million (not to exceed the recipient’s award amount) to spend on th...
Finding 2024-017 Significant Deficiency in Internal Control – Earmarking Condition: Under the Coronavirus State & Local Fiscal Recovery Funds (21.027), the 2022 Final Rule, recipients can elect a one-time “standard allowance” of $10 million (not to exceed the recipient’s award amount) to spend on the “provision of government services” during the period of performance. Alternatively, recipients can calculate lost revenue for the years 2020, 2021, 2022, and 2023 based on the formula provided in the 2022 Final Rule to determine the amount of SLFRF funds that can be used for the “provision of government services.” The City of Danbury elected to claim the standard allowance even though their initial award from Treasury exceeded that. Contact Person: Kara Prunty, Assistant Director of Finance – Grants, City of Danbury Corrective Actions Completed: We agree with the finding. The City implemented a controlled SLFRF project classification and support process by documenting approval of each project’s expenditure category/allowability with performing periodic reconciliations tying the tracker to the general ledger and reported totals, with approvals and reconciliations retained in the SLFRF grant file.
Finding 2024-011 Material Weakness and Material Noncompliance Finding, Reporting – Special Reporting Condition: For Coronavirus State and Local Fiscal Recovery Funds (ALN# 21.027), none of the quarterly Project and Expenditure Reports were submitted as required, and instead the City elected to submi...
Finding 2024-011 Material Weakness and Material Noncompliance Finding, Reporting – Special Reporting Condition: For Coronavirus State and Local Fiscal Recovery Funds (ALN# 21.027), none of the quarterly Project and Expenditure Reports were submitted as required, and instead the City elected to submit an annual Project and Expenditure Report that was submitted past the deadline for the fourth quarterly report. Contact Person: Kara Prunty, Assistant Director of Finance – Grants, City of Danbury Corrective Actions Completed: We agree with the finding. The City has implemented a centralized SLFRF quarterly reporting process under a designated grants/finance lead, including a recurring quarterly close schedule and a two-level review (preparer and approver) prior to submission. All submitted reports, supporting documentation, and submission confirmations are retained in a central repository.
Finding 2024-014: Material Weakness in Internal Control and Material Noncompliance – Reporting Condition: For the Community Development Block Grants (CDBG) Entitlement/Special Purpose Grants Cluster (14.218), For the entitlement funding allocated to the City, they were required to submit four quarte...
Finding 2024-014: Material Weakness in Internal Control and Material Noncompliance – Reporting Condition: For the Community Development Block Grants (CDBG) Entitlement/Special Purpose Grants Cluster (14.218), For the entitlement funding allocated to the City, they were required to submit four quarterly reports during the year and two annual reports. Of the three entitlement reports selected for testing, each one was submitted after the deadline. For the COVID-19 funding allocated to the City, they were required to submit quarterly reports duringthe year for two separate awards, for a total of eight quarterly reports, and one annual report. None of the required COVID-19 funding reports were submitted during the current year. Contact Person: Kara Prunty, Assistant Director of Finance – Grants, City of Danbury Corrective Actions Completed: We agree with the finding. The City has implemented a centralized reporting process under a designated grants/finance lead, including a recurring quarterly close schedule and a two-level review (preparer and approver) prior to submission. All submitted reports, supporting documentation, and submission confirmations are retained in a central repository.
Name of Contact Person: Yolanda White, Director of Bertie County Department of Social Services Corrective Action/Management's Response: DSS agrees that there were some discrepancies found in two out of twentythree employee day sheets vs. timesheets resulting in more program time reported on the day ...
Name of Contact Person: Yolanda White, Director of Bertie County Department of Social Services Corrective Action/Management's Response: DSS agrees that there were some discrepancies found in two out of twentythree employee day sheets vs. timesheets resulting in more program time reported on the day sheets than the approved timesheets. Supervisors are responsible for ensuring that time reported on an employee day sheets match the timesheets. Bertie County DSS utilizes an Excel spreadsheet provided by Bertie County Government that is completed by each employee monthly to report time worked. As it is the Supervisor's responsibility to verify and approve the accuracy of employee day sheets, the Supervisor is expected to reconcile time reported on employee day sheets to time reported on employee timesheets. Plan of Action: • Provide employees training on how to complete their Day Sheets • Reiterate the importance of employees reporting the same amount of time on the day sheet vs. the timesheet. • Communicate with Supervisors the importance of reconciling employee day sheets vs. timesheets. Proposed Completion Date: As soon as the discrepancy was identified by the auditor, management began working with staff on the importance of tracking their time and the procedures they need to follow to ensure the compliance with federal and state guidelines for the year ending June 30, 2024 while continuing training staff in FY 2025 to ensure compliance.
Name of Contact Person: Willie Mack Carawan, Jr., Finance Director Corrective Action/Management's Response: This finding is primarily the result of turnover/ transition/ reporting access of key personnel. Management is working with staff member to establish contact with reporting agencies and to gai...
Name of Contact Person: Willie Mack Carawan, Jr., Finance Director Corrective Action/Management's Response: This finding is primarily the result of turnover/ transition/ reporting access of key personnel. Management is working with staff member to establish contact with reporting agencies and to gain the necessary access for reporting purposes, as well as reporting requirements. Proposed Completion Date: As soon as the discrepancy was identified by the auditor, management began working with staff to list their points of contact in the likelihood they are not available to meet reporting requirements for the year ending June 30, 2024.
Fund Account - Deposit funds to reimburse account - October 16, 2025 Segregation & Monitoring - Transfer all new deposits immediately; perform monthly reconciliations - Effective immediately. Policies & Training - Update policies; train staff on deposit handling and monitoring - May/June 2026 Oversi...
Fund Account - Deposit funds to reimburse account - October 16, 2025 Segregation & Monitoring - Transfer all new deposits immediately; perform monthly reconciliations - Effective immediately. Policies & Training - Update policies; train staff on deposit handling and monitoring - May/June 2026 Oversight & Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to Finance Committee - Ongoing
Fund Account - Deposit additional funds to cover shortfall. - March 3, 2026 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - May/June ...
Fund Account - Deposit additional funds to cover shortfall. - March 3, 2026 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - May/June 2026 Oversight and reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to Finance Committee - ongoing
Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards,...
Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards, and updated procedures Ongoing Monitoring - Quarterly internal audits; COO and Board Finance Committee review of compliance - ongoing Oversight and Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to finance committee - ongoing
Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic up...
Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic updates to CEO and Board Finance Committee Contingency Procedure - Submit owner-certified report if audited statements not finalized within 90 days - as needed
Fund Account - Deposited back to the replacement reserve account - October 16, 2025 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - M...
Fund Account - Deposited back to the replacement reserve account - October 16, 2025 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - May/June 2026 Oversight and Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to Finance Committee. - Ongoing
Fund Account - Deposit additional funds to cover shortfall - March 25, 2026 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - May/June ...
Fund Account - Deposit additional funds to cover shortfall - March 25, 2026 Segregation and Monitoring - Transfer all new deposits immediately; perform monthly reconciliations. - Effective immediately Policies and Training - Update policies; train staff on deposit handling and monitoring - May/June 2026 Oversight and Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to Finance Committee - Ongoing
Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards,...
Tenant File Review - Review all tenant files; obtain and file missing documentation - May 2026 Policies and procedures - Update and document procedures; implement standardized checklist; supervisory review required. - May 2026 Staff Training - Train staff on HUD eligibility, documentation standards, and updated procedures Ongoing Monitoring - Quarterly internal audits; COO and Board Finance Committee review of compliance - ongoing Oversight and Reporting - CFO/Controller review monthly reconciliations; provide quarterly updates to finance committee - ongoing
Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic up...
Compliance Calendar - Implement a calendar for all federal reporting deadlines with advance reminders - May 2026 Month-End and Year-End Close - Standardize closing procedures; set internal deadlines ahead of REAC requirement - May 2026 Oversight and Monitoring - CFO review of compliance; periodic updates to CEO and Board Finance Committee Contingency Procedure - Submit owner-certified report if audited statements not finalized within 90 days - as needed
The Board of Directors recognizes the importance of ensuring that the accounting period is "closed" in a timely manner to meet the requirements of Section 320(a) of 0MB Circular A- 133. Therefore, the Board has reorganized the accounting department, beginning with the hiring of a new staff accountan...
The Board of Directors recognizes the importance of ensuring that the accounting period is "closed" in a timely manner to meet the requirements of Section 320(a) of 0MB Circular A- 133. Therefore, the Board has reorganized the accounting department, beginning with the hiring of a new staff accountant. These changes will ensure the accounting period is "closed" in a timely manner to meet all requirements of Section 320(a) of 0MB Circular A-133. The Board will implement the above procedure immediately; however, due to the backlog for the audit completions, the change in procedures will become effective for the 9/30/2025 year-end.
Management will coordinate with external auditors and implement procedures to monitor audit progress and ensure timely completion and submission of future Single Audit reporting packages.
Management will coordinate with external auditors and implement procedures to monitor audit progress and ensure timely completion and submission of future Single Audit reporting packages.
Management will establish a reporting calendar and tracking system to ensure monthly Financial Status Reports are prepared, reviewed, and submitted timely in accordance with grant requirements.
Management will establish a reporting calendar and tracking system to ensure monthly Financial Status Reports are prepared, reviewed, and submitted timely in accordance with grant requirements.
Management will implement procedures to identify and properly allocate prepaid and multi-period expenses across the applicable benefit periods. Prepaid expenses will be recorded and amortized over the service period in accordance with GAAP and federal cost principles.
Management will implement procedures to identify and properly allocate prepaid and multi-period expenses across the applicable benefit periods. Prepaid expenses will be recorded and amortized over the service period in accordance with GAAP and federal cost principles.
The City anticipates being able to complete the next audit timely which will lead to a timely submission of the data collection form.
The City anticipates being able to complete the next audit timely which will lead to a timely submission of the data collection form.
Due to various internal and external issues, the single audit was not issued by the September 30 due date. The 2025 single audit will be performed in conjunction with the financial audit and issued well in advance of the deadline.
Due to various internal and external issues, the single audit was not issued by the September 30 due date. The 2025 single audit will be performed in conjunction with the financial audit and issued well in advance of the deadline.
Action taken: CRMHS management concurs with the finding. During the fiscal year ended June 30, 2024, CRMHS did not consistently operate internal controls over federal cash management as designed. Specifically, a federal draw was processed in excess of immediate cash needs and was not fully reconcile...
Action taken: CRMHS management concurs with the finding. During the fiscal year ended June 30, 2024, CRMHS did not consistently operate internal controls over federal cash management as designed. Specifically, a federal draw was processed in excess of immediate cash needs and was not fully reconciled to supporting allowable expenditures prior to submission. This resulted in federal funds being drawn in advance of program disbursement requirements. Management acknowledges that this practice does not comply with 2 CFR §200.305, which requires non-federal entities to minimize the time between drawdown of federal funds and their disbursement for program purposes. While the funds were ultimately expended on allowable program costs, the timing of the draw created a compliance exception and reflects a material weakness in internal control over compliance. Management takes this matter seriously and has implemented corrective measures to strengthen cash management oversight and reconciliation procedures. Such actions include: • CRMHS has completed a full reconciliation of all drawdowns under Assistance Listing 93.696 to supporting allowable expenditures through June 30, 2024. • Any excess cash balances identified were evaluated and adjusted to ensure compliance with federal cash management requirements. • Pre-Draw Reconciliation Requirement—No draw request may be submitted without documented reconciliation to recorded allowable expenditures. • Segregation of Duties and Review—the draw request and documented reconciliation will be reviewed and signed off on by a second qualified member of the accounting team. • Monthly Grant Cash Monitoring—CRMHS will compare cumulative drawdowns to cumulative allowable expenditures to identify and resolve any excess cash position.
Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s inability to properly retain documentation relating to the noted selection was due in large part to rapid staff turnover at the senior level and an inabi...
Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s inability to properly retain documentation relating to the noted selection was due in large part to rapid staff turnover at the senior level and an inability to access records from previous employees. Following the 2024 grant year, College for Social Innovation made updates to our accounting manual and segregation of duties protocols to ensure redundancy in the event of staff turnover. Additionally, College for Social Innovation has instituted new document storage and record keeping practices including the use of Google Drive and DropBox to securely store critical records and ensure access by relevant financial staff. At all times, at least two current staff members maintain access to record keeping digital drives and folders to ensure access redundancy. These policies and practices were first implemented in the beginning of the 2026 fiscal year and remain ongoing. Anticipated Completion Date: 7/1/2025
Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: Following the 2024 grant year, College for Social Innovation made updates to our internal controls procedures to ensure greater oversight of financial calculation and appropriate segreg...
Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: Following the 2024 grant year, College for Social Innovation made updates to our internal controls procedures to ensure greater oversight of financial calculation and appropriate segregation of duties. These updates include additional steps for review and approval of drawdown submissions, training for supervisory staff, and procedures for updating controls procedures as our staff grows and changes. These updates were completed as part of our Corrective Action Plan administered through AmeriCorps’ Office of Monitoring and confirmed as resolved in a notice dated 11/25/2025 [Re: Notification of Corrective Action Plan Closed – 23NDFMA002]. In considering the recommendations provided in this report, College for Social Innovation will further amend our internal controls procedures to include an additional layer of review, reconciliation, and approval of staff time and salary calculations related to AmeriCorps grant activities. In addition to the existing process of compilation by the Chief Operating Officer and review and approval by the Chief Executive Officer, staff time and salary calculations will now also be conducted by the Director of People Operations independently. This secondary calculation will be used for review and reconciliation by the Chief Operating Officer and Director of People Operations to ensure alignment and compliance to AmeriCorps and general accounting standards. Anticipated Completion Date: 2/23/26
Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s corrective action plan to ensure timely preparedness for auditing is twofold. First, we are developing a new “Financial Command Center” tool to allow gre...
Person Responsible for Corrective Action: Edward S. Churchill Jr., Chief Operating Officer Corrective Action Plan: College for Social Innovation’s corrective action plan to ensure timely preparedness for auditing is twofold. First, we are developing a new “Financial Command Center” tool to allow greater speed, accuracy, and regularity in tracking account balances and transactions. This new tool better consolidates our tracking processes and allows for regular reconciliations across tracking platforms including Expensify, QuickBooks, Excel, and BambooHR. Second, College for Social Innovation is currently seeking the support services of a Certified Public Accountant. As of February 2, 2026, we have identified a list of potential candidates, are developing a formal request for proposals, and expect to enter a contracted agreement in early March of 2026. This new supporting role will assist in ensuring that our accounting practices fully align with accounting principles generally accepted in the United States. Anticipated Completion Date: 3/30/2026
Person Responsible for Corrective Action: Ange Zuniga-Aleman, Manager of Operations Corrective Action Plan: Following the 2024 grant year, College for Social Innovation instituted a system of annual review of the CFSI Accounting Manual including training sessions for key financial staff. Training se...
Person Responsible for Corrective Action: Ange Zuniga-Aleman, Manager of Operations Corrective Action Plan: Following the 2024 grant year, College for Social Innovation instituted a system of annual review of the CFSI Accounting Manual including training sessions for key financial staff. Training sessions were conducted with key financial staff on 11/15/24, and 12/15/25. Review, training, and updates to the CFSI Accounting Manual were conducted as part of a Corrective Action Plan administered through AmeriCorps’ Office of Monitoring and confirmed as resolved in a notice dated 11/25/2025 [Re: Notification of Corrective Action Plan Closed – 23NDFMA002]. In addition to these regular reviews and training, College for Social Innovation has implemented a system of monthly, quarterly, and annual reviews of account balances and transactions. This new system includes monthly reviews with the Chief Operating Officer and Manager of Operations as well as the addition of a summer support intern for annual reviews at fiscal year-end. The first of these monthly reviews were conducted in July of 2025 and remain ongoing. Anticipated Completion Date: 7/1/2025
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