Corrective Action Plans

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Finding 2024-002: Allocation of Payroll Costs - Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance – Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services – Medicaid Cluster Response and Corrective Action Plan: Management acknowle...
Finding 2024-002: Allocation of Payroll Costs - Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance – Allowable Costs/Cost Principles Program: U.S. Department of Health and Human Services – Medicaid Cluster Response and Corrective Action Plan: Management acknowledges that documentation supporting payroll allocations for PATH CITED-related activities did not fully align with Uniform Guidance expectations for federal awards. However, similar to Finding 2024-001, the Organization was not aware that PATH CITED funding constituted federal assistance during FY2024 due to the absence of federal identifiers in grant documentation and related communications from DHCS. As such, payroll costs were managed under the Organization’s standard operational practices rather than federal compliance-specific requirements. The Organization applied a reasonable and consistent allocation methodology based on supervisory oversight and expected levels of effort, which management believes appropriately reflected the work performed, given the nature of the program at that time. Upon confirmation of the federal nature of the funding, management will take the following corrective actions which includes enhancing a time attestation/time studies process for personnel working on federal awards and strengthening policies requiring periodic after-the-fact review of payroll allocations and documentation retention requirements for supervisory approvals. Anticipated Completion Date: by June 30, 2026 Responsible Person: Virginia Lui VP, Controller
Finding 2024-001: Preparation of the Schedule of Expenditures of Federal Awards - Significant Deficiency in Internal Control Over Compliance Program: U.S. Department of Health and Human Services – Medicaid Cluster Management acknowledges the omission of PATH CITED expenditures from the SEFA for the ...
Finding 2024-001: Preparation of the Schedule of Expenditures of Federal Awards - Significant Deficiency in Internal Control Over Compliance Program: U.S. Department of Health and Human Services – Medicaid Cluster Management acknowledges the omission of PATH CITED expenditures from the SEFA for the year ended June 30, 2024. Management notes that the federal nature of the PATH CITED program was not identified in the original grant documentation or publicly available information provided by DHCS at the time the funding was awarded. Upon confirmation in 2025 that the program includes federal pass-through funding, the Organization worked to restate the SEFA and include the appropriate federal expenditures. To strengthen internal controls going forward, management has implemented procedures requiring review of funding agreements for federal funding indicators, maintaining a centralized register of federal awards to support SEFA preparation, and obtaining confirmation from funding agencies when the federal status of a program is unclear. Anticipated Completion Date: by June 30, 2026 Responsible Person: Virginia Lui VP, Controller
The School Board agrees that, while the reimbursable expenses did not include personnel costs, the Wage Rate (Davis Bacon Act) was not included in the contract language as required for federally funded projects. Management has implemented processes to ensure that any current and future contracts for...
The School Board agrees that, while the reimbursable expenses did not include personnel costs, the Wage Rate (Davis Bacon Act) was not included in the contract language as required for federally funded projects. Management has implemented processes to ensure that any current and future contracts for federally funded projects will include the Wage Rate (Davis Bacon Act) and DOL regulations to ensure compliance.
Management will work to complete the annual audit in a more timely manner, which is necessary to submit the annual data collection form in a more timely manner in future years.
Management will work to complete the annual audit in a more timely manner, which is necessary to submit the annual data collection form in a more timely manner in future years.
CONTACT PERSON: Mandy Hess, Finance Director, mhess@pickenscity.com CORRECTIVE ACTION: The City has implemented procedures to ensure that amounts reported for grant reporting amounts are accurate and are consistent with the City’s general ledger. PROPOSED COMPLETION DATE: December 31, 2026
CONTACT PERSON: Mandy Hess, Finance Director, mhess@pickenscity.com CORRECTIVE ACTION: The City has implemented procedures to ensure that amounts reported for grant reporting amounts are accurate and are consistent with the City’s general ledger. PROPOSED COMPLETION DATE: December 31, 2026
2024-005 REPORTING - SIGNIFICANT DEFICIENCY Federal Program Education Stabilization Fund - U.S. Department of Education passed through the Pennsylvania Department of Education COVID-19 - Elementary and Secondary School Emergency Relief Fund (ARP ESSER) ALN 84.425U; Contract #223-21-0141; Grant Perio...
2024-005 REPORTING - SIGNIFICANT DEFICIENCY Federal Program Education Stabilization Fund - U.S. Department of Education passed through the Pennsylvania Department of Education COVID-19 - Elementary and Secondary School Emergency Relief Fund (ARP ESSER) ALN 84.425U; Contract #223-21-0141; Grant Period 03/13/20 - 09/30/24 COVID-19 - ARP ESSER Learning Loss Set Aside ALN 84.425U; Contract #225-21-0141; Grant Period 03/13/20 - 09/30/24 Criteria The District is required to submit an annual performance report to the Commonwealth of Pennsylvania (the “State”) with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. Condition During the year ended June 30, 2024, the District submitted a report for the funds used during the year ended June 30, 2023. The report submitted by the District contained expenditure amounts that did not agree to the amounts reported on the schedule of expenditures of federal awards for the year ended June 30, 2023 as well as other key reporting line items. Recommendation We recommend the District keep a reconciliation of grant awards available to expenditure incurred. The accurate use of funding source codes will assist in that process. We also recommend the District continue working toward more timely financial and compliance audits. Management Response When the district received the audit, the 2023 federal reports were already submitted. The District made the adjustments for non-allowable expenses in the 2023 SEFA and took out the non-allowable in the 2024 State reports. The District has begun using and reconciling funding source codes related to grants more timely.
Management will file the audited financial statements for the year ended June 30, 2024, as soon as possible. The underlying causes included prolonged resource constraints within the Finance Department, turnover in key accounting positions, challenges associated with the ERP system implementation, an...
Management will file the audited financial statements for the year ended June 30, 2024, as soon as possible. The underlying causes included prolonged resource constraints within the Finance Department, turnover in key accounting positions, challenges associated with the ERP system implementation, and delays in reconciling certain major balance sheet accounts. To address these issues, the City engaged an external financial consultant to assist in completing outstanding bank reconciliations and restoring timely financial reporting. Management is also implementing additional corrective measures, including reprioritizing workloads, enhancing oversight of monthly close activities, and establishing standardized reconciliation checklists for all major balance sheet accounts. Management anticipates that this finding will extend through the Fiscal Year 2025, and possibly Fiscal Year 2026 financial statement reporting cycles, with full resolution expected in Fiscal Year 2027.
FINDING #2024-003 RESIDUAL RECEIPTS DEPOSIT Recommendation: The management agent should compute an estimate of surplus cash (residual receipts) for the fiscal year upon completion of that period. In the event that surplus cash exists at the completion of the fiscal period, the management agent must ...
FINDING #2024-003 RESIDUAL RECEIPTS DEPOSIT Recommendation: The management agent should compute an estimate of surplus cash (residual receipts) for the fiscal year upon completion of that period. In the event that surplus cash exists at the completion of the fiscal period, the management agent must further ensure that all required deposits are made to the residual receipts account within the required time frame and that the balance in that account meets the minimum required balance in accordance with the regulatory agreement between the Entity and HUD. Views of Responsible Officials and Planned Corrective Action: The management agent agrees with the finding and the auditor’s recommendations have been adopted. Surplus cash will be calculated upon the completion of an annual fiscal period. If it is concluded that surplus cash exists at the end of the annual fiscal period, and further determined that the surplus cash was received within that fiscal period, that amount of surplus cash will be deposited into the Residual Receipts Account within ninety days of the close of that fiscal period.
FINDING #2024-002 LATE CENSUS BUREAU FILING Recommendation: We recommend that the property comply with all continuing compliance requirements and ensure that the data collection form is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Ma...
FINDING #2024-002 LATE CENSUS BUREAU FILING Recommendation: We recommend that the property comply with all continuing compliance requirements and ensure that the data collection form is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is now aware of the continuing compliance requirement and will comply with this recommendation in the future.
FINDING #2024-001 LATE AUDIT SUBMISSION Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is aware and will comply...
FINDING #2024-001 LATE AUDIT SUBMISSION Recommendation: We recommend that the property comply with HUD’s audit requirements and ensure that the audit is submitted by the required deadline in the future. Views of Responsible Officials and Planned Corrective Action: Management is aware and will comply with this recommendation in the future.
Finding 1213951 (2024-010)
Material Weakness 2024
The Creek County Clerk’s Office will work with the SEFA preparer to ensure that the correct paid dates are being used when reporting. This should eliminate the actual expenditures differences. We will work to educate all offices involved in the reporting process on financial statement and SEFA.
The Creek County Clerk’s Office will work with the SEFA preparer to ensure that the correct paid dates are being used when reporting. This should eliminate the actual expenditures differences. We will work to educate all offices involved in the reporting process on financial statement and SEFA.
Finding 1213950 (2024-009)
Material Weakness 2024
It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all e...
It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control and add this be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk’s Office will work with the District Attorney’s Office for proper language.
2024-001 – Data Collection Forms Finding: Our audit procedures noted Alliance for Rights and Recovery, Inc. did not certify or submit the required Data Collection Form for the fiscal year ended December 31, 2023 related to the 2023 Single Audit. As of the date of our 2024 audit, the Data Collection ...
2024-001 – Data Collection Forms Finding: Our audit procedures noted Alliance for Rights and Recovery, Inc. did not certify or submit the required Data Collection Form for the fiscal year ended December 31, 2023 related to the 2023 Single Audit. As of the date of our 2024 audit, the Data Collection Form and accompanying reporting package remain unsubmitted. Recommendation: We recommend that the organization implement procedures to ensure the timely preparation, certification, and submission of the annual Data Collection Form and reporting package. This should include assigning responsibility for tracking deadlines, establishing a completion checklist, and documenting management review prior to submission. Action Taken: The Agency will assign the CFO the responsibility of reviewing all 9melines and documents needed for the annual audit.
Name of Contact Person: Willow Hetrick-Price Corrective Action Planned: Due to turnover of the Commission's accounting staff, the Commission was unable to have the annual audit completed within the required timeframe, and subsequently was also late in submission of the FAC report. The Commission has...
Name of Contact Person: Willow Hetrick-Price Corrective Action Planned: Due to turnover of the Commission's accounting staff, the Commission was unable to have the annual audit completed within the required timeframe, and subsequently was also late in submission of the FAC report. The Commission has hired internal staff to help with the audit preparation and contracted with an accounting firm that has provided the Commission a CPA to conduct audit preparation and other financial services as requested. The Commission will work on getting financial information in a timely fashion and submit the reporting package in accordance with the guidelines. Anticipated completion date: September 30, 2026.
FINDING NO. 2024-002 – Unsupported Costs Federal Program: Continuum of Care Program Assistance Listing Number: 14.267 U.S. Department of Health and Human Services Significant Deficiency Condition: During our testing of purchases made under the Continuum of Care program, we tested 40 items. We noted ...
FINDING NO. 2024-002 – Unsupported Costs Federal Program: Continuum of Care Program Assistance Listing Number: 14.267 U.S. Department of Health and Human Services Significant Deficiency Condition: During our testing of purchases made under the Continuum of Care program, we tested 40 items. We noted that two of those items had no supporting invoices as these were purged from the system when a credit card became compromised. Corrective Action Plan: The Association is currently evaluating new credit card management tools with enhanced retention, documentation, and audit-trail functionality to ensure supporting invoices are preserved even in the event of card compromise or account changes. In conjunction with this effort, the Association is revising formal credit card administration and documentation procedures, including defined invoice retention requirements and periodic review controls. Management believes these actions will strengthen documentation controls and prevent recurrence of unsupported purchases. Responsible Official: John Manning, COO Anticipated Completion Date: Targeting resolution by June 30, 2026.
The Authority has revised its policy for Section 3 and will include the policy and requirements in all applicable agreements, pre-bid documents, and resulting contracts. Section 3 requirements will also be reviewed during pre-construction meetings for any applicable projects.
The Authority has revised its policy for Section 3 and will include the policy and requirements in all applicable agreements, pre-bid documents, and resulting contracts. Section 3 requirements will also be reviewed during pre-construction meetings for any applicable projects.
While the Authority continues to be delinquent on the current year audit completion, a consulting firm was hired to assist with bringing records up to date. The Authority also had hired an assistant fiscal officer in the fall of 2021 and another assistant fiscal officer in the fall of 2022. As a res...
While the Authority continues to be delinquent on the current year audit completion, a consulting firm was hired to assist with bringing records up to date. The Authority also had hired an assistant fiscal officer in the fall of 2021 and another assistant fiscal officer in the fall of 2022. As a result of the hiring, job responsibilities have been re-assigned and data gathering for future audits will occur in a timely manner. Accounts have been reconciled through December 31, 2025 prior to the 2024 audit commencing. The Authority will continue to execute their plan to have the audits completed on a timely basis and expects to submit the audited financial statements and single audit reporting package for the year ended December 31, 2025 to the Federal Audit Clearinghouse timely.
The Authority implemented a new policy to track and document program income: a. Upon receipt of program income, it shall be entered individually into IDIS and assigned to an activity or activities within fifteen (15) calendar days of receipt. b. At the next request for funds for an activity which in...
The Authority implemented a new policy to track and document program income: a. Upon receipt of program income, it shall be entered individually into IDIS and assigned to an activity or activities within fifteen (15) calendar days of receipt. b. At the next request for funds for an activity which includes funding from program income, program income shall be used prior to requesting federal funds for the activity. c. The request for federal funds shall be prepared by the Fiscal Officer and reviewed by one of the Assistant Fiscal Officers to determine if program income is being used prior to the request of federal funds. d. If it has been determined and documented that program income is being used prior to the request for federal funds, the request shall be forwarded to the Executive Director for approval. This finding has since been resolved in 2025, with a new policy developed and implemented on April 1, 2025.
In general, management agrees with the finding. It should be noted that internal controls for supervisory review of reporting requirements were in place but were not written controls or processes. Reporting for the CDBG Program is accomplished through the preparation of the annual Comprehensive Annu...
In general, management agrees with the finding. It should be noted that internal controls for supervisory review of reporting requirements were in place but were not written controls or processes. Reporting for the CDBG Program is accomplished through the preparation of the annual Comprehensive Annual Performance and Evaluation Report (CAPER). Written policies and procedures for the CAPER have been developed. Reporting for the Emergency Rental Assistance Program is accomplished through an online reporting system of the U.S. Treasury and by email to the Pennsylvania Human Services Department. This finding has since been resolved in 2025, with a new policy developed and implemented on December 12, 2025.
Finding 2024-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Cindy Sharp, Deputy Finance Director Corrective Action Plan: Management has hired a new finance director with governmental accounting experience, as well as an accountant (a licensed CPA in Colorado...
Finding 2024-002 Late Reporting and Noncompliance with Reporting Requirements Name of Contact Person: Cindy Sharp, Deputy Finance Director Corrective Action Plan: Management has hired a new finance director with governmental accounting experience, as well as an accountant (a licensed CPA in Colorado) with a long history of governmental auditing and accounting experience. Management, together with experienced accounting staff, will review reporting deadlines and work diligently toward timely report submissions in the future. Management and accounting staff will also carefully review reporting requirements and ensure that requirements are adhered to. This includes the following program(s): Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) / ARPA Non-Profit Recovery Funds (NPRF) (ALN 21.027). Proposed Completion Date: Fiscal year 2025.
Management has started the audit preparation process for 2054 and will ensure that the 2025 audit is completed within the required timeframe.
Management has started the audit preparation process for 2054 and will ensure that the 2025 audit is completed within the required timeframe.
Planned Corrective Action: The Division will implement their control of ensuring that they only charge allowable costs incurred during the approved budget period of a federal award’s period of performance or will obtain authorization from the grantor for any costs incurred before the grant's approve...
Planned Corrective Action: The Division will implement their control of ensuring that they only charge allowable costs incurred during the approved budget period of a federal award’s period of performance or will obtain authorization from the grantor for any costs incurred before the grant's approved budget period. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller
Planned Corrective Action: The Division will design and implement a precise control to ensure that the inventory reports are reviewed prior to being submitted to the grantor and that the backup documentation is maintained. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon,...
Planned Corrective Action: The Division will design and implement a precise control to ensure that the inventory reports are reviewed prior to being submitted to the grantor and that the backup documentation is maintained. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller
Planned Corrective Action: The Division will design and implement a precise control to ensure that participants self-certify that they meet the grant eligibility requirements and maintain such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Divisi...
Planned Corrective Action: The Division will design and implement a precise control to ensure that participants self-certify that they meet the grant eligibility requirements and maintain such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller
Planned Corrective Action: The Division will design and implement a precise control to ensure that the amount of food distributed is properly reviewed and that the Division maintains such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Co...
Planned Corrective Action: The Division will design and implement a precise control to ensure that the amount of food distributed is properly reviewed and that the Division maintains such evidence. Anticipated Completion Date: 9/30/2026 Responsible Contact Person: Al Agpoon, Golden State Division Controller
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