Corrective Action Plans

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The District has reviewed the audit finding in coordination with its consultant responsible for preparing the quarterly reports. To address this issue, both the consultant and District staff have implemented enhanced scheduling controls, including the establishment of multiple interim deadlines. The...
The District has reviewed the audit finding in coordination with its consultant responsible for preparing the quarterly reports. To address this issue, both the consultant and District staff have implemented enhanced scheduling controls, including the establishment of multiple interim deadlines. These measures are intended to ensure timely preparation of draft reports, allow sufficient time for internal review and revisions, and support submission of finalized reports in advance of EPA -required deadlines.
2025-003: Noncompliance with Reporting Requirements The planned corrective action: University Settlement did not submit the SF425 because we had submitted a budget revision to the Office of Head Start and were still awaiting approval. University Settlement did not submit the SF429 because we are cur...
2025-003: Noncompliance with Reporting Requirements The planned corrective action: University Settlement did not submit the SF425 because we had submitted a budget revision to the Office of Head Start and were still awaiting approval. University Settlement did not submit the SF429 because we are currently in discussions with the Office of Head Start regarding the status of federal interest in property owned by USS. We should have communicated in writing to confirm expectations prior to the deadline and submitted the reports accordingly and on time. Going forward, University Settlement will clarify any questions regarding reporting requirements and deadlines in writing to our funder with sufficient time for response prior to a filing deadline. The name(s) of the contact person(s) responsible for corrective action: Lisa Stein, CFO Julia Kagan, Managing Director, Finance The anticipated completion date for the corrective action. 4/30/2026
2025-002: Noncompliance with Suspension and Debarment Requirements The planned corrective action: Immediate: By 4/30/2026, the Managing Director of Finance, the Director of Accounts Payable and Purchasing, and the CFO will meet with all program managers and review this requirement. Program managers ...
2025-002: Noncompliance with Suspension and Debarment Requirements The planned corrective action: Immediate: By 4/30/2026, the Managing Director of Finance, the Director of Accounts Payable and Purchasing, and the CFO will meet with all program managers and review this requirement. Program managers will review existing vendors paid with federal funds and verify they are not on a suspended or barred list. They will then print this screenshot to document and affirm that the vendor is not prohibited. This documentation will then be attached to a request for payment. This step will be added to the manual check list rolling out by 4/30/26 and provided to all purchasers and approvers. Medium Term: In FY26, University Settlement is reviewing and updating its financial policies and will roll these out for approval and implementation by the close of FY26. There will also be formal communication and training provided to finance and program managers. The name(s) of the contact person(s) responsible for corrective action: Lisa Stein, CFO Julia Kagan, Managing Director, Finance Virginia Viloria, Director, Accounts Payable and Purchasing The anticipated completion date for the corrective action. 6/30/2026
2025-001: Noncompliance with Competitive Bidding Requirements. The planned corrective action: Immediate: By 4/30/2026, the Managing Director of Finance, the Director of Accounts Payable and Purchasing, and the CFO will meet with all program managers and review the current purchasing policies and the...
2025-001: Noncompliance with Competitive Bidding Requirements. The planned corrective action: Immediate: By 4/30/2026, the Managing Director of Finance, the Director of Accounts Payable and Purchasing, and the CFO will meet with all program managers and review the current purchasing policies and the corresponding documentation required for submission for payment. A checklist for easy reference will be provided to all relevant requestors and approvers. Medium Term: Over the course of FY26, the CFO has been working with finance managers to review and update payment software, payment methods and financial policies. Updates will be rolled out for approval and implementation by 6/30/2026. There will also be formal communication and training provided to finance and program managers. The name(s) of the contact person(s) responsible for corrective action: Lisa Stein, CFO Julia Kagan, Managing Director, Finance Virginia Viloria, Director, Accounts Payable and Purchasing The anticipated completion date for the corrective action. 6/30/2026
2025-001 Auditor's Recommendation: We recommend that NH Housing Development ensures all required information for the data collection is available in a timely fashion to ensure timely filing of the data collection form. Management response: Management acknowledges that the reporting package and Data ...
2025-001 Auditor's Recommendation: We recommend that NH Housing Development ensures all required information for the data collection is available in a timely fashion to ensure timely filing of the data collection form. Management response: Management acknowledges that the reporting package and Data Collection Form were not submitted to the Federal Audit Clearinghouse within the timeframe required under 2 CFR 200.512(a). Management recognizes the significance of this repeat finding and acknowledges that prior corrective measures were not sufficiently formalized to ensure compliance. To prevent recurrence, Management will implement a documented submission timeline, assign clear primary and backup responsibility for certification and filing, and require documented confirmation of Federal Audit Clearinghouse acceptance. Management is committed to strengthening oversight controls to ensure timely submission in future reporting periods. If the funding agency has questions regarding this plan, please call me at 708 829-4358.
The Organization will also look into hiring an independent accountant to assist with financial statement preparations to ensure accuracy. The Organization will also take steps to ensure the loan liability balance held at South State Bank is reported accurately.
The Organization will also look into hiring an independent accountant to assist with financial statement preparations to ensure accuracy. The Organization will also take steps to ensure the loan liability balance held at South State Bank is reported accurately.
The Organization’s Board of Directors will ensure its review of the monthly bank statements, reconciliations and cancelled check images, payroll registers, financial statements and general ledger activity is documented through physical signatures, sign off with initials or email approval. The Organi...
The Organization’s Board of Directors will ensure its review of the monthly bank statements, reconciliations and cancelled check images, payroll registers, financial statements and general ledger activity is documented through physical signatures, sign off with initials or email approval. The Organization will also look into hiring an independent accountant to assist with financial statement preparation.
The Organization will begin performing bank reconciliations for all accounts held by the Organization to ensure accuracy between bank statement balances and amounts recorded in QuickBooks. The Organization will also look into hiring an independent accountant to assist with financial statement prepar...
The Organization will begin performing bank reconciliations for all accounts held by the Organization to ensure accuracy between bank statement balances and amounts recorded in QuickBooks. The Organization will also look into hiring an independent accountant to assist with financial statement preparation.
Response: Management agrees with the finding regarding the need to ensure that the Schedule of Expenditures of Federal Awards (SEFA) accurately presents total federal expenditures for the reporting period and that expenditures are recorded in the appropriate fiscal year. The condition occurred due t...
Response: Management agrees with the finding regarding the need to ensure that the Schedule of Expenditures of Federal Awards (SEFA) accurately presents total federal expenditures for the reporting period and that expenditures are recorded in the appropriate fiscal year. The condition occurred due to limited formal procedures related to the year-end review of federal grant expenditures and cutoff testing. Management recognizes the importance of ensuring that federal expenditures are properly identified, recorded, and reported in the correct fiscal period in accordance with the requirements of the Uniform Guidance (2 CFR Part 200). To address this matter, management will implement enhanced procedures for preparing and reviewing the SEFA. These procedures include performing a detailed reconciliation between the SEFA, grant reports, and the general ledger; reviewing expenditures near year-end to ensure proper fiscal year cutoff; and verifying that all federal programs and related expenditures are completely and accurately reported. In addition, management will document the SEFA preparation and review process and provide additional training to accounting staff involved in federal grant reporting. The Finance Department will be responsible for implementing these procedures, and management expects these corrective actions to be fully implemented beginning with the current fiscal year reporting process. Contact person responsible for corrective action: Lynne Duong, Compliance and Risk Manager Anticipated completion date: June 30, 2026
Management will strengthen internal controls to ensure compliance with grant requirements related to level of effort and changes in key personnel. Management will review all active grant agreements to identify and document requirements related to level of effort and key personnel designations. A mon...
Management will strengthen internal controls to ensure compliance with grant requirements related to level of effort and changes in key personnel. Management will review all active grant agreements to identify and document requirements related to level of effort and key personnel designations. A monitoring process will be implemented to track personnel assignments and effort charged to federal grants to ensure compliance with grant requirements. Any proposed changes in key personnel or significant changes in level of effort will be reviewed by the Grants Management staff prior to implementation. When required by the grant terms, written approval will be obtained from the grant agency before any changes to key personnel or level of effort are made. Contact person responsible for corrective action: Lynne Duong, Compliance and Risk Manager Anticipated completion date: June 30, 2026
Management agrees with the finding and acknowledges that a significant deficiency was identified related to report submission delay. To prevent this issue from recurring, we are implementing several corrective actions. These include establishing a stricter communication schedule with Post Award Admi...
Management agrees with the finding and acknowledges that a significant deficiency was identified related to report submission delay. To prevent this issue from recurring, we are implementing several corrective actions. These include establishing a stricter communication schedule with Post Award Administrators to ensure timely submission of reports and strengthening of our internal monitoring procedures by tracking submission deadlines more closely. Contact person responsible for corrective action: Lynne Duong, Compliance and Risk Manager Anticipated completion date: June 30, 2026
Management agrees with the finding and will reevaluate internal processes and procedures. This error highlights the need for better oversight and timely communication between our organization and its subrecipients to ensure accurate reporting. The root cause of this issue was insufficient monitoring...
Management agrees with the finding and will reevaluate internal processes and procedures. This error highlights the need for better oversight and timely communication between our organization and its subrecipients to ensure accurate reporting. The root cause of this issue was insufficient monitoring and communication between the subrecipient and our grants management team. To address this, we are implementing several corrective actions. These include establishing a stricter communication schedule with subrecipients to ensure timely submission of invoices and expense reports and strengthening our internal monitoring procedures by tracking submission deadlines more closely. Additionally, we will improve guidance and capacity-building efforts for subrecipients to ensure they understand reporting requirements, and we will conduct quarterly reviews of subrecipient expenses to proactively identify and mitigate reporting delays. Contact person responsible for corrective action: Lynne Duong, Compliance and Risk Manager Anticipated completion date: June 30, 2026
FINDING 2025-013 Finding Subject: Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Artiya Nash, Head Start Director Contact Phone Number and Email A...
FINDING 2025-013 Finding Subject: Head Start Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Artiya Nash, Head Start Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com anash@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business office will generate a payroll distribution report by fund after each payroll period. This report will list each individual paid from this fund. This report will be provided to the grant director and will be signed and dated and returned to the business office to be filed with the payroll file. Anticipated Completion Date: This will be implemented immediately. 62
FINDING 2025-012 Finding Subject: COVID-19 Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Regin Johnson, Title I Grant Director Contact Phone Number and Email Add...
FINDING 2025-012 Finding Subject: COVID-19 Education Stabilization Fund – Equipment and Real Property Management Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Regin Johnson, Title I Grant Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com rjohnson@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will create a binder with any expenditure qualifying as a capital asset expenditure. This binder will be provided to the capital asset consultant, currently AdTec. Anticipated Completion Date: This will be implemented immediately.
FINDING 2025-011 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Regin Johnson, Title I Grant Director Contact ...
FINDING 2025-011 Finding Subject: COVID-19 Education Stabilization Fund – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Regin Johnson, Title I Grant Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com rjohnson@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business office will generate a payroll distribution report by fund after each payroll period. This report will list each individual paid from this fund. This report will be provided to the grant director and will be signed and dated and returned to the business office to be filed with the payroll file. All claims submitted to the business office for payment will need to be signed by the grant director prior to payment. The grant director will provide a detailed invoice, and grant expenditure account information. All stipends will require a copy of the approved board minutes to be included in the payroll file. This letter must provide the expenditure account to be charged for the stipend. These stipend letters will be reviewed and signed by the treasurer or business manager as part of the regular payroll review process. Anticipated Completion Date: This will be implemented immediately.
FINDING 2025-010 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Cynthia Mose-Trevino, Assistant Superintendent...
FINDING 2025-010 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Assessment System Security Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Cynthia Mose-Trevino, Assistant Superintendent Corporation Test Coordinator Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com cynthia.mose-trevino@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A two layer verification of completion will be implemented by each building level STC ensuring completion of test security training at their site, and the CTC verifying this completion data for all required district personnel. Anticipated Completion Date: This revised process will be fully implemented by the beginning of the 2027 calendar year.
FINDING 2025-009 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Regin Johnson, Title 1 Director Rae Lopez, Student Services Director Contact Phone Number and Email Address: rjohnson@chsnewtech.com rlopez@chsnewtech.com 21...
FINDING 2025-009 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Regin Johnson, Title 1 Director Rae Lopez, Student Services Director Contact Phone Number and Email Address: rjohnson@chsnewtech.com rlopez@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The error causing this finding is within part of the annual student registration process. If a parent did not provide the socio-economic status (SES) data necessary to determine Title I eligibility, the student information system defaulted their SES to a former value. To correct this error, the collection of the SES data will be reviewed by the data manager to identify missing information. School registrars will request the parent/guardian provide any missing information. Students that have no current SES data by student count day will be automatically flagged as ineligible for the Title I count. This verified data will be what is submitted to the IDOE Data Exchange. Anticipated Completion Date: This revised process will be implemented for the 2026-2027 school year enrollment registration process. 58 INDIANA STATE BOARD OF ACCOUNTS 60
FINDING 2025-008 Finding Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Regin Johnson, Title I Grant Director C...
FINDING 2025-008 Finding Subject: Title I Grants to Local Educational Agencies - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Regin Johnson, Title I Grant Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com rjohnson@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The business office will generate a payroll distribution report by fund after each payroll period. This report will list each individual paid from this fund. This report will be provided to the grant director and will be signed and dated and returned to the business office to be filed with the payroll file. All claims submitted to the business office for payment will need to be signed by the grant director prior to payment. The grant director will provide a detailed invoice, and grant expenditure account information. Anticipated Completion Date: This will be implemented immediately.
FINDING 2025-007 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819 Vie...
FINDING 2025-007 Finding Subject: Special Education Cluster (IDEA) - Procurement Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The corporation will require the cooperative to submit an annual procurement compliance certification. The report must list all vendors that exceed $150,000. If any vendor exceeds 100,000, the corporation will request documentation that the cooperative met the formal method requirements before it meets the 150,000 limit. Anticipated Completion Date: This will be completed by June 30, 2026.
FINDING 2025-006 Finding Subject: Special Education Cluster (IDEA) – Level of Effort Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819...
FINDING 2025-006 Finding Subject: Special Education Cluster (IDEA) – Level of Effort Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will use the Form 9 to reconcile the MOE. The treasurer will prepare a report providing the total monthly expenditures to the cooperative, along with the wage and benefit report provided by the cooperative. Transportation expenses will be divided and recorded in the ledger clearly delineating which expenses are special education. When reporting MOE, the school corporation will reconcile the ledger with invoices. The business manager will review these costs prior to the MOE Workbook submission as part of the Special Education grant application. Anticipated Completion Date: This will be completed by the next SEFA submission date of August 29, 2026.
FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819 View...
FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will request an update to the Cooperative Agreement requiring the cooperative to provide school specific expenditure reports for non-public services on a quarterly basis. The school corporation will require detail level data from the cooperative for earmarking compliance. During SEFA and AFR preparation, the treasurer will reconcile the cooperatives year-end report to the proportionate share requirement listed in the IDOE grant award letter. Anticipated Completion Date: This will be completed by the next SEFA submission date of August 29, 2026.
FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Fredrick Vaughn, Food Service Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chs...
FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Reporting Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Fredrick Vaughn, Food Service Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com fvaughn@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director will prepare the daily meal counts from the POS system and create a claim summary sheet. This sheet will show the total reimbursable breakfasts, lunches and total enrollment for the month. Included with this will be a monthly POS summary report showing these counts. This report will be reviewed and signed by the treasurer and the food service director. After the review the treasurer will submit the claim in the IDOE CNP web portal. Anticipated Completion Date: This will be implemented for the February 2026 claim.
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Fredrick Vaughn, Food Service Director Contact Phone Number ...
FINDING 2025-003 Finding Subject: Child Nutrition Cluster - Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Adrian Wilkerson, Chief Financial Officer Chris Akers, Treasurer Fredrick Vaughn, Food Service Director Contact Phone Number and Email Address: awilkerson@chsnewtech.com cakers@chsnewtech.com fvaughn@chsnewtech.com 219-838-1819 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The monthly review process will include detailed ledgers with receipts and invoices provided. The business manager and food service director will review 2CFR 200.403. The business manager or treasurer will review five random line items and trace them back to the source document. The monthly review will be signed by the business manager, food service director and treasurer. Anticipated Completion Date: This will be implemented with the February 2026 monthly review process.
Disaster Grants –Public Assistance (Presidentially Declared Disasters) (97.036) COVID-19 Disaster Grants –Public Assistance (Presidentially Declared Disasters) (97.036) State Agency: Department of Law and Public Safety Federal Agency: U.S. Department of Homeland Security Disaster Grants –Public Assi...
Disaster Grants –Public Assistance (Presidentially Declared Disasters) (97.036) COVID-19 Disaster Grants –Public Assistance (Presidentially Declared Disasters) (97.036) State Agency: Department of Law and Public Safety Federal Agency: U.S. Department of Homeland Security Disaster Grants –Public Assistance (Presidentially Declared Disasters) (97.036) COVID-19 Disaster Grants –Public Assistance (Presidentially Declared Disasters) (97.036) State Agency: Department of Law and Public Safety Federal Agency: U.S. Department of Homeland Security Reporting - Federal Funding Accountability and Transparency Act (FFATA) VIEWS OF RESPONSIBLE OFFICIALS AND CORRECTIVE ACTION PLAN The Department of Law and Public Safety (DLPS) acknowledges that certain FFATA reports for awards obligated in prior fiscal years were not submitted on time due to technical issues with the FEMA system, which prevented timely reporting. These technical issues have since been resolved. The DLPS has been in full compliance with FFATA reporting requirements since August 2024. COMPLETION DATE/ CONTACT PERSON & PHONE# Fiscal Year 2024 and Ongoing Salvatore Marcello (609) 882-2000 ext.3046 Salvatore.Marcello@njsp.gov
Block Grants for Prevention and Treatment of Substance Abuse (93.959) COVID-19 –Block Grants for Prevention and Treatment of Substance Abuse (93.959) State Agency: Department of Human Services Federal Agency: U.S. Department of Health and Human Services Reporting – Federal Funding Accountability and...
Block Grants for Prevention and Treatment of Substance Abuse (93.959) COVID-19 –Block Grants for Prevention and Treatment of Substance Abuse (93.959) State Agency: Department of Human Services Federal Agency: U.S. Department of Health and Human Services Reporting – Federal Funding Accountability and Transparency Act (FFATA) VIEWS OF RESPONSIBLE OFFICIALS AND CORRECTIVE ACTION PLAN The Department of Human Services, Division of Mental Health and Addiction Services (DMHAS) does not dispute the FFATA upload dates for three (3) of the thirteen (13) subawards tested, but it disputes that such uploads were untimely. One subaward was uploaded only seven (7) days late. DMHAS submits that it substantially complied, no finding should issue and no corrective action is required in that instance. The two (2) remaining awards at issue were funded with the ARPA Block Grant. On March 24, 2025, U.S. DHHS took unprecedented action and issued a notice of early termination of ARPA funding, purportedly for cause because the Covid-19 health emergency had ended. The notice of early termination and subsequent, revised Notice of Award (NOA), required DMHAS to cease all activities. It also sought to revise the original grant terms, retroactive to the original September 1, 2021 project start date. By way of example, the revised NOA also includes new conditions and certifications required to draw down federal funds. DMHAS complied with the notice of early termination and immediately ceased all activities; it stopped issuing subaward letters, it ceased all subaward uploads into its Contract Information Management System, it stopped all reimbursements, and it stopped all FFATA uploads pending or in process. Also in response to the abrupt early termination of funding, DMHAS issued “stop work” orders to all impacted agencies and advised that there was no assurance of reimbursement as of the effective date of notice. Shortly thereafter, DMHAS joined numerous other State authorities and filed a formal complaint in federal district court, alleging that the early termination was unlawful and caused the States irreparable harm. On April 5, 2025, the court entered a temporary injunction and scheduled a hearing for preliminary injunctive relief. U.S. DHHS moved for reconsideration. Several weeks later, the Court entered a preliminary injunction enjoining the enforcement of the early termination of ARPA until further order of the Court. The cessation of FFATA uploads from the March termination to the receipt of injunctive relief was necessary to: 1. Maintain strict compliance with the revised NOA terms and conditions, including the written obligation to cease all activities; 2. Maintain strict compliance with the revised NOA terms and conditions, by issuing “stop work” orders; 3. Ensuring DMHAS’s “stop work” orders were not superseded by FFATA uploads or USA.Spending publications while the request for injunctive relief was pending, so no individual or entity (including the US Office of the Attorney General, US DHHS, or subawardee) could construe the upload as renewed authority to continue to expend funds through subaward end date; 4. Fully protect the prosecution of DMHAS’s claims in the pending, federal litigation, as well as DMHAS’s defenses; and 5. Mitigate DMHAS and subawardee damages in the underlying litigation. Based on the unprecedented early termination of block grant funding and ensuing litigation, DMHAS submits that the timeline to complete FFATA uploads was stayed. Such determination is consistent with the Court’s preliminary injunction, which makes clear that U.S. DHHS immediately treat any actions taken to implement or enforce the early funding terminations, as null and void and rescinded. Therefore, DMHAS should not be issued a FFATA finding that relates directly to the revised NOAs or the direction to cease all activities, and under these extraordinary circumstances, the uploads in question should be classified as non-reportable and immaterial, with no corrective action required. COMPLETION DATE/ CONTACT PERSON & PHONE# January 1,2025 Gordon Horvath, CFO (609) 544-6817 Gordon.Horvath@dhs.nj.gov John Fogliano, Deputy CFO (609) 438-4278 John.Fogliano@dhs.nj.gov
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