Corrective Action Plans

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The Department is working with Human Resources to strengthen procedures for initiating, completing, and maintaining documentation for required background investigations in accordance with tribal policy. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: December 31, 2026
The Department is working with Human Resources to strengthen procedures for initiating, completing, and maintaining documentation for required background investigations in accordance with tribal policy. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: December 31, 2026
The Department of Treasury is working closely with the Procurement, Grants, and Contracts program to monitor and enforce proper internal controls and reviews for vendors. Procurement and Accounts Payable teams have been notified of the required SAM.gov checks and related documentation requirements. ...
The Department of Treasury is working closely with the Procurement, Grants, and Contracts program to monitor and enforce proper internal controls and reviews for vendors. Procurement and Accounts Payable teams have been notified of the required SAM.gov checks and related documentation requirements. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: December 31, 2027
Approval responsibility for both Project and Expenditure Reports and Obligation and Expenditure Reports were reassigned from the Lt. Governor to the Acting Treasurer to improve the timeliness of report review and submission. For financial reports, the Department has strengthened its reporting proces...
Approval responsibility for both Project and Expenditure Reports and Obligation and Expenditure Reports were reassigned from the Lt. Governor to the Acting Treasurer to improve the timeliness of report review and submission. For financial reports, the Department has strengthened its reporting process by requiring secondary review and approval prior to submission and will continue monitoring report preparation and filing to support timely compliance. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: December 31, 2026
The Treasury Department will continue strengthening year-end close, reconciliation, and financial reporting processes to support timely completion of future audits and Single Audit submissions. Management is working to improve the accuracy and timeliness of accounting records, implement a more struc...
The Treasury Department will continue strengthening year-end close, reconciliation, and financial reporting processes to support timely completion of future audits and Single Audit submissions. Management is working to improve the accuracy and timeliness of accounting records, implement a more structured closing process, and enhance audit preparation procedures to help ensure future reporting packages are submitted by required deadlines. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: September 30, 2027
Finding 1218369 (2024-004)
Material Weakness 2024
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures or workflow restrictions that prevent employees from self‑approving their own timecards. Explanation of disagreement wi...
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures or workflow restrictions that prevent employees from self‑approving their own timecards. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. During 2024, the Organization implemented BanbooHR to replace manual timekeeping and strengthen payroll controls. The self-approval issue occurred during initial system implementation and was identified through audit procedures. A corrective control has since been established whereby the Human Resources Manager reviews and approves the Executive Director's timecards, eliminating the ability for self-approval. In addition, payroll continues to be independently processed and reviewed by the Senior Director of Finanice, providing an additional layer of oversight. These control enhancements ensure proper segregation of duties and prevent self-approval of timecards going forward. Name(s) of the contact person(s) responsible for corrective action: Monique Valenzuela, Executive Director and Theo Everheart, Senior Director of Finance. Planned completion date for corrective action plan: May 2026
Finding 1218367 (2024-003)
Material Weakness 2024
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should...
Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the Organization develop and implement formal policies and procedures to ensure required performance reports are prepared, reviewed, and submitted in a timely manner. Such procedures should include clearly defined roles and responsibilities, tracking of reporting deadlines, and documented evidence of supervisory review and approval prior to submission. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was related to a one-time ARPA grant during a period of staff transition, where performance reports were not consistently documented as reviewed and approved prior to submission. Since then, management has implemented formalized procedures for grant reporting. All performance reports are now prepared by designated program staff, tracked against reporting deadlines, and subject to supervisory review and approval by the Executive Director prior to submission. These procedures establish clear roles and responsibilities and ensure timely, documented review and submission of required reports. Name(s) of the contact person(s) responsible for corrective action: Monique Valenzuela, Executive Director and Theo Everhearts, Senior Director of Finance. Planned completion date for corrective action plan: June 2024
Management will review reports on a more frequent basis and will to the best of our abilities, schedule recertifications well in advance to advance to ensure recertifications are completed timely. Verterans will now be notified at the 60 day mark in order to retain eligibility.
Management will review reports on a more frequent basis and will to the best of our abilities, schedule recertifications well in advance to advance to ensure recertifications are completed timely. Verterans will now be notified at the 60 day mark in order to retain eligibility.
CRT will initiate an outreach plan for low-income representation to fill the open positions on the Board. The President and Chief Executive Officer or designee will solicit Low-Income Director nominations from organizations and groups within the agency or the community that are recognized as serving...
CRT will initiate an outreach plan for low-income representation to fill the open positions on the Board. The President and Chief Executive Officer or designee will solicit Low-Income Director nominations from organizations and groups within the agency or the community that are recognized as serving or representing low-income residents following federal regulations, State statutes, CRT By-Laws and agency approved Democratic Selection Procedures. Upon review of the qualifications of the nominated candidates by the CRT Nominating Subcomittee, they will vote to select the best qualified candidate(s) for appointment to the Board. After the candidate(s) have been determined by the Nominating Subcommitee to meet the qualifications, the Board will vote whether to elect the proposed individual to the Board.
Management Corrective Action Plan: The District acknowledges the finding regarding the untimely submission of required reports to the Pennsylvania Department of Education related to federal grant programs. Management recognizes the importance of timely and accurate reporting to ensure compliance wit...
Management Corrective Action Plan: The District acknowledges the finding regarding the untimely submission of required reports to the Pennsylvania Department of Education related to federal grant programs. Management recognizes the importance of timely and accurate reporting to ensure compliance with grant requirements and maintain effective oversight of federal funding. The delays in submission were primarily the result of staffing transitions within the Business Office and challenges associated with completing prior year financial information needed for reporting purposes. The District has worked cooperatively with the Pennsylvania Department of Education throughout this process and has taken steps to address outstanding reporting requirements. To address this matter, the District has begun implementing corrective actions which include: · Establishing internal reporting calendars and compliance deadlines for all required state and federal submissions; · Assigning specific staff responsibilities for grant reporting and monitoring; · Implementing supervisory review procedures to ensure reports are completed accurately and submitted timely; and · Providing additional oversight and coordination related to federal grant compliance and reporting requirements. Individual(s) Responsible: CFO, Finance Officer Anticipated Completion Date: Prior to issuance of the Fiscal Year 2025 Financial Statements
The Organization is recording all revenue per the conditions the Organization is subjected to in the grant agreement..
The Organization is recording all revenue per the conditions the Organization is subjected to in the grant agreement..
The Organization is recording all fixed assets per their capitalization policy.
The Organization is recording all fixed assets per their capitalization policy.
The Organization is recording non cash donations based on policy
The Organization is recording non cash donations based on policy
The Organization is documenting their review for proper suspension and debarment compliance prior to entering a transaction.
The Organization is documenting their review for proper suspension and debarment compliance prior to entering a transaction.
Finding 2024-007: During the year ended June 30, 2024, Housing Choice Voucher Program funds were used by other federal programs, resulting in Housing Choice Voucher Program funds being used to cover expenses for other federal programs and defederalized funds. a. Comments on the Finding We agree with...
Finding 2024-007: During the year ended June 30, 2024, Housing Choice Voucher Program funds were used by other federal programs, resulting in Housing Choice Voucher Program funds being used to cover expenses for other federal programs and defederalized funds. a. Comments on the Finding We agree with finding 2024-007 b. Action(s) Taken or Planned on the Finding The Authority has hired a new CFO who will provide the leadership and technical assistance needed to ensure the Finance department operates effectively within regulations. The Authority has created new policies ensuring monthly reconciliations and implemented the process of reconciling interfund balances to ensure balances are settled monthly, to ensure funds are not intermingled with other federal programs. Columbia Housing is also in the process of implementing a new software system that will provide software solutions to ensure accurate financial processing.
Finding 2024-006: No electronic income verification was done within the required time period for 1 of 40 participant selections. No abatement of housing assistance payments of failed unit inspections after 30 day maintenance windows was completed on 25 participant selections. a. Comments on the Find...
Finding 2024-006: No electronic income verification was done within the required time period for 1 of 40 participant selections. No abatement of housing assistance payments of failed unit inspections after 30 day maintenance windows was completed on 25 participant selections. a. Comments on the Finding We agree with finding 2024-006 b. Action(s) Taken or Planned on the Finding Annual training on program rules has been established for the Housing Choice Voucher Program, to ensure staff are aware of the proper implementation of the program rules. Additionally, a quality control protocol will be established that will require a review of at least 15% of all files. All failed inspection actions will be reviewed to ensure compliance with abatement protocols.
All federal programs requiring engineering assistance will be also be tracked internally for compliance.
All federal programs requiring engineering assistance will be also be tracked internally for compliance.
Finding Number: 2024-006 Planned Corrective Action: AMHA will require staff to follow all requirements set forth in 24 CFR 982 regarding income documentation such as obtaining third party verification and documenting the file as to why it was not available, related to annual income, assets, expenses...
Finding Number: 2024-006 Planned Corrective Action: AMHA will require staff to follow all requirements set forth in 24 CFR 982 regarding income documentation such as obtaining third party verification and documenting the file as to why it was not available, related to annual income, assets, expenses, etc. Staff will be instructed to double check calculations before inputting the information into the computer/50058 and to check to make sure calculations are accurate prior to adding the 50058 for submission. AMHA will continue to send staff to the appropriate training courses and AMHA has contracted with Nelrod for online training and will ensure this also includes EIV training courses. AMHA staff will conduct quality control on the files at random. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Finding Number: 2024-005 Planned Corrective Action: The Housing Authority has contracted with the Nelrod Company a national technical consulting firm specializing in Federal Assisted Housing Programs to perform our rent reasonableness determinations. Anticipated Completion Date: 6/11/2026 Responsibl...
Finding Number: 2024-005 Planned Corrective Action: The Housing Authority has contracted with the Nelrod Company a national technical consulting firm specializing in Federal Assisted Housing Programs to perform our rent reasonableness determinations. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completio...
Finding Number: 2024-004 Planned Corrective Action: The Housing Authority along with Leggins Casterline & Company LLC accounting will continue working to rectify the accounting issues resulting from the former Executive Director and have all submissions done in a timely manner. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Finding Number: 2024-003 Planned Corrective Action: Housing Quality Standards are now done internally by the Executive Director and the authority has one dedicated staff member monitoring and they assure a re-inspection is automatically scheduled and notice sent to landlord and tenant. Anticipated C...
Finding Number: 2024-003 Planned Corrective Action: Housing Quality Standards are now done internally by the Executive Director and the authority has one dedicated staff member monitoring and they assure a re-inspection is automatically scheduled and notice sent to landlord and tenant. Anticipated Completion Date: 6/11/2026 Responsible Contact Person: Zackary Dye, Executive Director
Management has implemented a formal procedure to ensure that future Single Audits are completed and submitted within the required timeframe. This procedure includes the following actions: First Quarter (January – March): The Purchasing Unit will initiate the procurement process for the independent a...
Management has implemented a formal procedure to ensure that future Single Audits are completed and submitted within the required timeframe. This procedure includes the following actions: First Quarter (January – March): The Purchasing Unit will initiate the procurement process for the independent auditors, in coordination with the Fiscal Manager, while year-end closing activities are being completed, to ensure timely engagement of audit services. Second Quarter (April – June): Once the auditor is engaged, the program will initiate the audit engagement and provide the required documentation in accordance with the established audit schedule.
FINDING 2024-003 Criteria: Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Audit Recommendation: We recommend that the Organization 1) maintains timely and accur...
FINDING 2024-003 Criteria: Recipients of federal awards must minimize the time elapsing between the receipt of funds from the U.S. Treasury and disbursement by the Organization set out at 2 CFR section 200.305(b). Audit Recommendation: We recommend that the Organization 1) maintains timely and accurate recording of disbursements in its job-costing system and 2) regularly request grant funds based on amounts expended as report in the Organization’s job-costing system. Auditee Response: UICSL revised its job costing system to better comply with these requirements and had overlap from previous programs/grants within its old QuickBooks Accounting system. UICSL now has a credit card tracking system by class code, ensures an invoice is allocated, and has focused on reimbursement method invoicing. Corrective Action Plan: Invoices and transactions will not be processed without approval and proper coding. Prior grant personnel and leadership are no longer within the organization. Monthly and quarterly invoices are sent according to each grant / contract agreement will be enforced by the GDCM and DFO in compliance with 2 CFR section 200.305(b). UICL is in active good status with all its current grantors, specifically Indian Health Servies (IHS). Person Responsible: Som Chivukula, Finance Director; Matt Poss, Executive Director Timeline: UICSL removing QuickBooks and switching to Oracle NetSuite in 2025/2026. Scheduling monthly check-ins and expenditure reports reviewed with department leads upon hiring of new Finance Director. All invoices reviewed with grant/project leads and logged appropriately. Staff accountant hired in late 2024 to help provide additional checks but also ensure UICSL focuses on reimbursement (post-expense).
FINDING 2024-002 Criteria: Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards for salaries and wages must be based on records that accurately reflect ...
FINDING 2024-002 Criteria: Recipients of federal awards must follow the costs principles set out at 2 CFR section 200.430 to substantiate compensation and other purchases charged to a federal program. “Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: …(iii) reasonable reflect the total activity for which the employee is compensated by the non-Federal entity” 2 CFR section 200.430(i). The Organization’s processes did not maintain sufficient documentation of the approval of the activity of each employee or the purchase of goods/services. Audit Recommendation: We recommend the Organization ensure it 1) maintains records of each employee’s activity and 2) monitors compliance with the job-costing system implemented. Auditee Response: Organization believes that prior leadership and lack of supervision allowed paychecks to be approved without the proper flow. FY24 Turnover was roughly 75% in leadership and 60% across the organization. Corrective Action Plan: UICSL moved away to Paycom early 2024 to better help account for Labor Allocation and Grant Codes. With Paycom, employees are automated to each program and there is a designated reporting function allowing us to review what is assigned. UICSL going into 2025 has better defined leadership and Directors for each division so there are clearly defined approvers and supervisors for each purchase and transaction – leadership turnover was high. Person Responsible: Som Chivukula, Finance Director; Matt Poss, Executive Director; Eva Leyer, Human Resources Manager Timeline: UICSL filled all leadership positions by mid-2025 and went through two organizational restructures, creating more mid-level management. This will help ensure compliance with FY25 Audit.
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts...
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts issued three weeks in advance. Written approval from the Commissioner is required for any deviation. 2.) Dedicated Department email: A staff-independent email account (finance@mechanicvilleny.gov) has been established to maintain continuity and ensure traceability of all compliance correspondence and filings. 3.) Two-tier Review Process : Effective immediately, all federal reimbursement claims undergo a two-level review - initial preparation by program staff followed by certification by the Deputy Commissioner prior to submission.
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts...
To prevent recurrence, management has implemented the following permanent corrective measurers: 1.) Centralized Compliance Calendar: A Finance Compliance Calendar has been established within the City's operational system. All statutory and grant related deadlines are programmed with automated alerts issued three weeks in advance. Written approval from the Commissioner is required for any deviation. 2.) Dedicated Department email: A staff-independent email account (finance@mechanicvilleny.gov) has been established to maintain continuity and ensure traceability of all compliance correspondence and filings. 3.) Two-tier Review Process : Effective immediately, all federal reimbursement claims undergo a two-level review - initial preparation by program staff followed by certification by the Deputy Commissioner prior to submission.
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