Corrective Action Plans

Finding 1223380 (2024-071)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Procurement, Suspension & Debarment § 200.303 § 200.317

VIDE has implemented additional system controls to ensure all procurements meet federal documentation standards and to adequately maintain completed contract files. To address documentation gaps and ensure compliance with suspension and debarment requirements, the department has transitioned to a mo...

VIDE has implemented additional system controls to ensure all procurements meet federal documentation standards and to adequately maintain completed contract files. To address documentation gaps and ensure compliance with suspension and debarment requirements, the department has transitioned to a model where the required contract, along with all necessary supporting documentation (specifically including bids, quotations, justification letters, and evaluation reports), must be attached directly to each invoice entry within the ERP system. This requirement ensures that a complete, centralized procurement file is retained and reviewed for compliance prior to any final disbursement.

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Finding 1223379 (2024-070)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Equipment & Real Property Management § 200.303 § 200.313

As part of our ongoing commitment to strengthen internal controls, VIDE is finalizing its comprehensive Standard Operating Procedures (SOPs) for Equipment and Real Property Management. To directly address the recommendation for improved monitoring and communication, the Fixed Asset Director is imple...

As part of our ongoing commitment to strengthen internal controls, VIDE is finalizing its comprehensive Standard Operating Procedures (SOPs) for Equipment and Real Property Management. To directly address the recommendation for improved monitoring and communication, the Fixed Asset Director is implementing a formal process to perform and document quarterly inventory reconciliations, ensuring timely coordination across all divisions handling federal assets. Munis serves as our official system of record. Current controls dictate that all required data fields (as outlined in 2 CFR 200.313) must be inputted before an asset record can be created in the system. The Government acknowledges the current limitation where a system reporting error prevents certain populated information from exporting onto standard reports. The Third-Party Fiduciary Agent (TPFA) is actively escalating this issue with Munis technical support. To ensure compliance to date, no permanent system solution has been found; therefore, the Fixed Asset Director will implement an interim workaround. This will involve utilizing alternative data queries or manual consolidation from the Munis asset profiles to ensure that complete, fully compliant equipment listings can be successfully generated and provided upon request, until the system reporting error is permanently resolved by the TPFA and Munis.

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Finding 1223378 (2024-069)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles § 200.303 § 200.403

VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention o...

VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention of indirect costs. Currently, the Third-Party Fiduciary Agent (TPFA) controls and executes this specific process on behalf of the Department. To ensure the newly finalized procedures are fully operationalized, VIDE is scheduling mandatory training. VIDE will coordinate directly with the TPFA to facilitate this training for all relevant VIDE staff. This will ensure that internal personnel are fully equipped to actively verify, compile, and securely store the required check payment details and detailed project expenditure reports. Building this internal capacity will strengthen VIDE's oversight of the TPFA's processes and prevent future documentation gaps.

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Finding 1223377 (2024-068)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both th...

VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both the payroll processing register and the final reimbursement invoice. Approved timesheets, Notices of Per Diem, and related payroll support will be centrally retained in SharePoint by pay period and attached to applicable invoices or general ledger journal entries. Program staff and supervisors will receive mandatory training on updated timesheet procedures and federal time and effort requirements. The Office of Fiscal and Administrative Services will also conduct monthly spot checks of SharePoint repositories and ERP logs to document compliance, identify control gaps, and ensure timely corrective action. Finalization of the formal SOPs and supporting controls is a top priority to achieve the necessary level of control precision and prevent repeat findings.

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Finding 1223376 (2024-067)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Procurement, Suspension & Debarment § 200.303 § 200.317

VIDE has implemented additional system controls to ensure all procurements meet federal documentation standards and to adequately maintain completed contract files. To address documentation gaps and ensure compliance with suspension and debarment requirements, the department has transitioned to a mo...

VIDE has implemented additional system controls to ensure all procurements meet federal documentation standards and to adequately maintain completed contract files. To address documentation gaps and ensure compliance with suspension and debarment requirements, the department has transitioned to a model where the required contract, along with all necessary supporting documentation (specifically including bids, quotations, justification letters, and evaluation reports), must be attached directly to each invoice entry within the ERP system. This requirement ensures that a complete, centralized procurement file is retained and reviewed for compliance prior to any final disbursement.

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Finding 1223375 (2024-066)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Cash Management Period of Performance Matching / Level of Effort / Earmarking § 200.303

VIDE is strengthening its internal controls and record retention procedures to ensure strict adherence to federal period of performance and liquidation provisions. To address the missing payment support, the department is enforcing a strict back-end system control. All required supporting documentat...

VIDE is strengthening its internal controls and record retention procedures to ensure strict adherence to federal period of performance and liquidation provisions. To address the missing payment support, the department is enforcing a strict back-end system control. All required supporting documentation evidencing payment must be attached directly to the transaction entry within the ERP system prior to final disbursement. To address the specific instance regarding the missing indirect cost reimbursement report, VIDE will leverage its newly finalized Indirect Cost Standard Operating Procedure (SOP). VIDE will coordinate with the Third-Party Fiduciary Agent (TPFA) to ensure that all detailed reimbursement reports are actively verified and securely stored in a centralized repository before indirect costs are drawn down and liquidated. Furthermore, the Office of Fiscal and Administrative Services will implement a mandatory final review step during the grant closeout and liquidation phase. This review will systematically verify the presence and accuracy of all payment and indirect cost documentation within the ERP and SharePoint repositories, ensuring that all expenditures are properly supported, allowable, and completely liquidated within the mandated period of performance timeframe.

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Finding 1223374 (2024-065)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Matching / Level of Effort / Earmarking § 200.303 § 200.306

VIDE recognizes that the inability to verify underlying student and poverty data due to a lack of certified documentation is a critical internal control deficiency. Accordingly, VIDE will establish a formal data collection and certification process. VIDE will update its specific Standard Operating P...

VIDE recognizes that the inability to verify underlying student and poverty data due to a lack of certified documentation is a critical internal control deficiency. Accordingly, VIDE will establish a formal data collection and certification process. VIDE will update its specific Standard Operating Procedure (SOP) for the collection of MFS and Earmarking data to mandate a process wherein LEAs will be required to submit a Student Count and Poverty Data Certification Form. This form must be signed by the District Superintendent and the District Data Manager to certify the student numbers and poverty counts as of the specific federal reporting date. Supporting source documentation, such as PowerSchool reports, must be attached to this certification. At the SEA level, the State Office of Special Education will be responsible for reviewing these submissions and issuing a formal Verification of Data Accuracy memo prior to the data being used for financial calculations. To address the recommendation for deployed resources and to correct the MOE deficiency, VIDE will formalize the organizational chart within the Federal Grants Office to clearly designate the team responsible for compliance reviews. This team will be tasked with conducting quarterly reviews of the certified data packets to ensure the documentation required for audit verification is securely archived and readily available. Additionally, the Budget Office and Federal Grants Office will implement a standard MFS Calculation Worksheet that requires the attachment of the certified source data and the specific approval and signature of the Deputy Commissioner of Fiscal and Administrative Services before the allocation is finalized. Finally, the Deputy Commissioner of Curriculum and Instruction will maintain a Compliance Review Log tracking the receipt of annual data certifications from the LEAs, and the Deputy Commissioner of Fiscal and Administrative Services will review this log alongside the MOE Calculation Worksheets prior to the submission of the Annual Performance Report.

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Finding 1223373 (2024-064)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Equipment & Real Property Management § 200.303 § 200.313

As part of our ongoing commitment to strengthen internal controls, VIDE is finalizing its comprehensive Standard Operating Procedures (SOPs) for Equipment and Real Property Management. To directly address the recommendation for improved monitoring and communication, the Fixed Asset Director is imple...

As part of our ongoing commitment to strengthen internal controls, VIDE is finalizing its comprehensive Standard Operating Procedures (SOPs) for Equipment and Real Property Management. To directly address the recommendation for improved monitoring and communication, the Fixed Asset Director is implementing a formal process to perform and document quarterly inventory reconciliations, ensuring timely coordination across all divisions handling federal assets. Munis serves as our official system of record. Current controls dictate that all required data fields (as outlined in 2 CFR 200.313) must be inputted before an asset record can be created in the system. The Government acknowledges the current limitation where a system reporting error prevents certain populated information from exporting onto standard reports. The Third-Party Fiduciary Agent (TPFA) is actively escalating this issue with Munis technical support. To ensure compliance to date, no permanent system solution has been found; therefore, the Fixed Asset Director will implement an interim workaround. This will involve utilizing alternative data queries or manual consolidation from the Munis asset profiles to ensure that complete, fully compliant equipment listings can be successfully generated and provided upon request until the system reporting error is permanently resolved by the TPFA and Munis.

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Finding 1223372 (2024-063)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles § 200.303 § 200.403

VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention o...

VIDE will reinforce its procedures for tracking, compiling, and storing documentation related to grant expenditures. To achieve the necessary level of control precision, VIDE has successfully finalized the Standard Operating Procedure (SOP) governing the calculation, tracking, and record retention of indirect costs. Currently, the Third-Party Fiduciary Agent (TPFA) controls and executes this specific process on behalf of the Department. To ensure the newly finalized procedures are fully operationalized, VIDE is scheduling mandatory training. VIDE will coordinate directly with the TPFA to facilitate this training for all relevant VIDE staff. This will ensure that internal personnel are fully equipped to actively verify, compile, and securely store the required check payment details and detailed project expenditure reports. Building this internal capacity will strengthen VIDE's oversight of the TPFA's processes and prevent future documentation gaps.

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Finding 1223371 (2024-062)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.113 § 200.303 § 200.403 § 200.430

VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both th...

VIDE will strengthen payroll and personnel action controls by requiring the Budget Team and Deputy Commissioner to review and approve all personnel actions before NOPA execution to validate pay rates. Furthermore, Payroll will establish a final review step to reconcile approved hours against both the payroll processing register and the final reimbursement invoice. Approved timesheets, Notices of Per Diem, and related payroll support will be centrally retained in SharePoint by pay period and attached to applicable invoices or general ledger journal entries. Program staff and supervisors will receive mandatory training on updated timesheet procedures and federal time and effort requirements. The Office of Fiscal and Administrative Services will also conduct monthly spot checks of SharePoint repositories and ERP logs to document compliance, identify control gaps, and ensure timely corrective action. Finalization of the formal SOPs and supporting controls is a top priority to achieve the necessary level of control precision and prevent repeat findings.

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Finding 1223370 (2024-061)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles § 200.303

VIDE is strengthening its policies and procedures to ensure all non-payroll expenditures are fully supported by underlying documentation prior to charging federal programs. To address the documentation gap identified, the department is enforcing a strict back-end system control within the accounts p...

VIDE is strengthening its policies and procedures to ensure all non-payroll expenditures are fully supported by underlying documentation prior to charging federal programs. To address the documentation gap identified, the department is enforcing a strict back-end system control within the accounts payable process. Moving forward, all required supporting documentation—such as vendor invoices, receipts, and programmatic approvals—must be attached directly to the transaction entry within the ERP system. Furthermore, the Office of Fiscal and Administrative Services will implement a mandatory final review step to verify the presence and accuracy of this documentation in the system before any disbursement is authorized or charged to the Special Education Cluster.

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Finding 1223362 (2024-060)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.344

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Opera...

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including period of performance. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

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Finding 1223361 (2024-059)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Cash Management § 200.303

DPNR will reevaluate and strengthen its cash management policies and procedures to ensure compliance with the Cash Management Improvement Act (CMIA), Treasury-State Agreement requirements, and Federal cash management regulations. To support these requirements, DPNR alongside RMA will establish a rep...

DPNR will reevaluate and strengthen its cash management policies and procedures to ensure compliance with the Cash Management Improvement Act (CMIA), Treasury-State Agreement requirements, and Federal cash management regulations. To support these requirements, DPNR alongside RMA will establish a repository that will serve as the official source of record for all drawdown activities and related supporting documentation.

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Finding 1223360 (2024-058)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles § 200.303 § 200.403 § 200.430

DPNR recognizes the discrepancies identified between the employee pay rates reflected in the payroll registers and the Notices of Personnel Action (NOPAs) that were provided during the audit. Preliminary review indicates that the payroll system calculates employee compensation based on approved pers...

DPNR recognizes the discrepancies identified between the employee pay rates reflected in the payroll registers and the Notices of Personnel Action (NOPAs) that were provided during the audit. Preliminary review indicates that the payroll system calculates employee compensation based on approved personnel actions maintained within the payroll system; however, it is possible that the NOPAs provided for audit testing did not reflect the most current approved personnel actions or subsequent amendments affecting employee compensation. Additionally, DPNR's procedures for maintaining and readily retrieving complete personnel and payroll support documentation were not sufficiently centralized to ensure that the most current supporting records were consistently available for audit review. DPNR will conduct a comprehensive internal review of the payroll transactions identified in the audit sample to determine the cause of the discrepancies between the payroll registers and the NOPAs provided during the audit. The review will include: • Verification of the official personnel actions maintained in the payroll system; • Review of any amended or revised NOPAs affecting employee compensation; • Reconciliation of payroll registers to approved personnel actions; • Verification that salaries and wages charged to Federal awards are properly supported and accurately reflected in official records; and • Identification and correction of any deficiencies in document retention or record management procedures.

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Finding 1223359 (2024-057)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring § 200.303 § 200.322 § 200.332 § 200.501 § 200.521

The Government concurs with the auditor’s findings and recommendations. Corrective action plan as follows: - Develop subrecipient monitoring policies (2 CFR 200.331–200.332) - Conduct risk assessments - Monitor financial and performance reports - Establish tracking system - Require follow-up on audi...

The Government concurs with the auditor’s findings and recommendations. Corrective action plan as follows: - Develop subrecipient monitoring policies (2 CFR 200.331–200.332) - Conduct risk assessments - Monitor financial and performance reports - Establish tracking system - Require follow-up on audit findings

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Finding 1223358 (2024-056)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

The Government concurs with the auditor’s findings and recommendations. Corrective action plan as follows: - Establish review and approval procedures - Maintain supporting documentation - Central repository for reports - Conduct periodic audits - Train staff

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Finding 1223357 (2024-055)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Cash Management Internal Control / Segregation of Duties § 200.303

The Government concurs with the auditor’s findings and recommendations. Strengthening procedures is necessary. Corrective Action Plan: - Reconcile drawdowns monthly - Assign oversight for draw requests - Conduct internal reviews

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Finding 1223356 (2024-054)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Subrecipient Monitoring Period of Performance § 200.303 § 200.403

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Opera...

The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including fiscal and administrative requirements for expending and accounting for payroll expenditures. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

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Finding 1223355 (2024-053)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance p...

The Government concurs with the auditor’s findings and recommendations and finalizing a comprehensive corrective action plan to strengthen grant management and compliance through the Public Finance Management initiative including the development of a three-tier overarching Financial and Compliance policy and procedures framework. The Government’s Audit Committee is leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including allowable cost and cost principles. Regular training sessions will be provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

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Finding 1223354 (2024-052)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303 § 200.322 § 200.332 § 200.501 § 200.521

To address this finding, OMB will strengthen its subrecipient monitoring controls and formalize procedures to ensure compliance with 2 CFR 200.303 and 2 CFR 200.332, including requirements related to identifying subawards, assessing subrecipient risk, documenting monitoring activities, following up ...

To address this finding, OMB will strengthen its subrecipient monitoring controls and formalize procedures to ensure compliance with 2 CFR 200.303 and 2 CFR 200.332, including requirements related to identifying subawards, assessing subrecipient risk, documenting monitoring activities, following up on deficiencies, and maintaining evidence of supervisory review. OMB will also conduct periodic internal quality control reviews of subrecipient files to confirm that monitoring documentation is complete, timely, and consistent with federal requirements.

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Finding 1223353 (2024-051)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Subrecipient Monitoring § 200.303

OMB agrees with the finding and will strengthen its internal controls over the preparation, review, reconciliation, and retention of documentation supporting CSLFRF reports. OMB implemented corrective measures to ensure that all Quarterly reporting consistently utilizes ERP Post Dates to ensure that...

OMB agrees with the finding and will strengthen its internal controls over the preparation, review, reconciliation, and retention of documentation supporting CSLFRF reports. OMB implemented corrective measures to ensure that all Quarterly reporting consistently utilizes ERP Post Dates to ensure that all applicable activity is fully captured. OMB will also establish a centralized process for maintaining reporting support, including reconciliations, review checklists, and evidence of supervisory approval, to ensure adequate documentation is retained for monitoring and audit purposes.

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Finding 1223352 (2024-050)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.321 § 200.322 § 200.323 § 200.327

The Government will retain all necessary supporting documentation for purchase orders, contracts, and vendor profiles to ensure adherence to internal policies and regulatory requirements. Management will implement procedures to regularly review and verify that all procurement activities are properly...

The Government will retain all necessary supporting documentation for purchase orders, contracts, and vendor profiles to ensure adherence to internal policies and regulatory requirements. Management will implement procedures to regularly review and verify that all procurement activities are properly documented and compliant with applicable regulations. Management will implement a formal process to ensure all executed contracts are timely included on GVIBUY. DPP will liaise more frequently with DOF IT team to rectify any potential system issues that can affect data accuracy. In collaboration with DPP and DOF, OMB will do the following: Formalize Policies and Procedures (SOP Updates): OMB will update its internal Standard Operating Procedures (SOPs) to clearly define: • Roles and responsibilities for procurement oversight • Required documentation standards - to ensure all procurement actions related to federal awards are captured, documented, and readily accessible for audit purposes. • Review and approval workflows Training and Capacity Building: OMB will conduct training sessions for all staff involved in procurement and grant management to reinforce compliance with: • Uniform Guidance (2 CFR 200.318–200.327) • Local procurement requirements (Title 31 VIC)

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Finding 1223351 (2024-049)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.403 § 200.430

OMB acknowledges the findings and notes that OMB does not calculate or determine fringe benefit amounts charged to payroll expenditures. However, OMB will coordinate with the Department of Finance to communicate the identified discrepancy and will work collaboratively to strengthen review procedures...

OMB acknowledges the findings and notes that OMB does not calculate or determine fringe benefit amounts charged to payroll expenditures. However, OMB will coordinate with the Department of Finance to communicate the identified discrepancy and will work collaboratively to strengthen review procedures over payroll cost allocations charged to federal programs. In addition, OMB will reevaluate its existing oversight controls to ensure that payroll expenditures charged to federal awards are supported by appropriate documentation and reviewed for compliance with applicable federal requirements.

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Finding 1223350 (2024-048)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.303

A comprehensive corrective action plan includes hiring key personnel to provide oversight and expertise in grant management. The Government’s Audit Committee is also leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This ...

A comprehensive corrective action plan includes hiring key personnel to provide oversight and expertise in grant management. The Government’s Audit Committee is also leading the development of a structured, three-tier policy and procedures framework under the Public Finance Management project. This framework includes Tier 1, which establishes the overarching Financial and Compliance Policy; Tier 2, which defines Standard Operating Procedures (SOPs) to promote cross-agency consistency; and Tier 3, which outlines detailed, step-by-step procedures that clearly define roles and responsibilities and accountability measures to ensure compliance with all federal regulations including internal controls for procurement vetting in corporation with the Department of Property and Procurement with primary responsibility over procurement. Regular training sessions are provided to staff involved in grant management to ensure they understand and adhere to compliance requirements with monitoring and evaluation occurring by the OMB Compliance Unit supported by the Government’s Audit Committee, to assess and improve the effectiveness of controls.

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Finding 1223349 (2024-047)

Material Weakness 2024

The Virgin Islands Hsg Finance Authority - Paradise Mills Apartments

FL

Special Tests & Provisions Eligibility Reporting § 200.303

VIDOL acknowledges the auditor’s finding regarding the failure to submit the required ETA 9129 RESEA Quarterly Reports in a timely manner under the UI-Reemployment Services and Eligibility Assessment (RESEA) program. VIDOL recognizes the importance of maintaining effective internal controls to ensur...

VIDOL acknowledges the auditor’s finding regarding the failure to submit the required ETA 9129 RESEA Quarterly Reports in a timely manner under the UI-Reemployment Services and Eligibility Assessment (RESEA) program. VIDOL recognizes the importance of maintaining effective internal controls to ensure all required Federal reports are accurate, complete, properly reviewed, and submitted within established deadlines in compliance with 2 CFR 200.303. VIDOL concurs with the auditor’s recommendation and is committed to strengthening reporting controls and implementing system improvements to ensure ongoing compliance with Federal reporting requirements. To address the deficiencies identified, VIDOL will implement the following corrective actions: 1. Implementation of RESEA Case Management System: VIDOL is currently in the implementation stage of the core portion of the RESEA case management system that will serve as the official system of record for all RESEA claimant services and reporting activities. The system is expected to go out to production/testing by June 2026 with an identified vendor. The new system will: •Centralize claimant and program data; •Improve tracking of RESEA activities and outcomes; • Generate data necessary for required Federal reporting; •Enhance data accuracy and consistency; and •Support timely submission of ETA 9129 Quarterly Reports. 2. Development of Reporting Policies and Procedures: VIDOL will develop and formalize written policies and procedures governing the preparation, review, approval, and submission of RESEA quarterly reports. These procedures will include: •Clearly defined staff responsibilities; •Reporting timelines and submission deadlines; • Required supervisory review and approval processes; and • Documentation retention requirements supporting reported data. 3. Strengthening Internal Controls Over Reporting: VIDOL will enhance internal controls to ensure: •Required reports are monitored through a reporting calendar and tracking system; •Reports are reviewed for completeness and accuracy prior to submission; •Supporting documentation is maintained and readily accessible; and •Management oversight is performed to ensure compliance with Federal reporting requirements. 4. Periodic Monitoring and Compliance Reviews: Management will conduct periodic reviews of reporting activities to verify reports are submitted timely and supported by accurate documentation. Any reporting deficiencies identified will be addressed promptly through corrective action and additional oversight. 5. Staff Training and Technical Assistance: Staff responsible for RESEA program administration and reporting will receive training on: •Federal reporting requirements for ETA 9129 reports; •Internal control and documentation standards; •Use of the RESEA case management system; and •Procedures for timely report preparation and submission. VIDOL will also seek technical assistance, as needed, to support implementation of the new reporting system and improve compliance processes.

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Corrective Action Plans

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