Corrective Action Plans

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Corrective Action Plan: Management will formalize a procurement policy in line with federal guidelines. Anticipated Completion date: 10/31/2025 Responsible Person: Rebecca Solow, Co-Founder and Executive Director
Corrective Action Plan: Management will formalize a procurement policy in line with federal guidelines. Anticipated Completion date: 10/31/2025 Responsible Person: Rebecca Solow, Co-Founder and Executive Director
Finding #2024-003 – Significant Deficiency and Other Noncompliance. Condition and context: During our testing of the Schedule of Expenditures of Federal Awards (SEFA) and the SESA, we noted that the expenditures were not reported in accordance with GAAP. An adjustment of $268,000 was recorded to pro...
Finding #2024-003 – Significant Deficiency and Other Noncompliance. Condition and context: During our testing of the Schedule of Expenditures of Federal Awards (SEFA) and the SESA, we noted that the expenditures were not reported in accordance with GAAP. An adjustment of $268,000 was recorded to properly state the expenditures. Recommendation: Implement policies and procedures to ensure that all expenditures have been properly recorded in accordance with GAAP in the SEFA and SESA. Corrective action plan: Management agrees with the finding. Beginning in fiscal year 2025, a detailed reconciliation process will be implemented to ensure that all expenditures are properly accrued and reported at the grant level in the SEFA and SESA, aligned with the appropriate reporting period, and the general ledger. Responsible officer: Gouri Kulkarni, Vice President of Finance. Estimated completion date: December 31, 2025.
Finding #2024-002 – Material Weakness and Other Noncompliance. Condition and context: During testing of a sample of 5 transactions requiring procurement, we identified that simplified acquisition procedures of obtaining and documenting bids were not performed for a vendor with expenditures greater t...
Finding #2024-002 – Material Weakness and Other Noncompliance. Condition and context: During testing of a sample of 5 transactions requiring procurement, we identified that simplified acquisition procedures of obtaining and documenting bids were not performed for a vendor with expenditures greater than $10,000 but less than $250,000 and competitive procurement procedures were not performed for 2 vendors with expenditures greater than $250,000. Brighter Bites’ rational for the selection of the vendor and approval was documented, however the procurement file did not include bids from other vendors under the simplified acquisition procedures and did not include a request for proposal, vendor responses, and an evaluation of the proposals to support Brighter Bites’ procurement rationale. Recommendation: Provide additional training to employees responsible for procurement on Brighter Bites’ procurement policy. Corrective action plan: Management agrees with the finding. Brighter Bites will enhance procurement compliance by providing additional targeted training to all staff involved in procurement activities. The organization will also revise its procurement checklist to ensure full documentation, including bids or proposals, vendor evaluations, and justification for selection. Internal audits will be conducted periodically to assess adherence to policy. Responsible officer: Amy Priebe, Vice President of Operations. Estimated completion date: December 31, 2025.
Finding 2024-007 SEFA Reporting Issue: We lacked consistent grant-level financial reporting, which made preparation of the required Schedule of Expenditures of Federal Awards {SEFA) difficult and time-consuming. • What's been done: We have improved our accounting systems and can now produce regular ...
Finding 2024-007 SEFA Reporting Issue: We lacked consistent grant-level financial reporting, which made preparation of the required Schedule of Expenditures of Federal Awards {SEFA) difficult and time-consuming. • What's been done: We have improved our accounting systems and can now produce regular internal financial reports by grant. All grant managers are given a monthly transaction listing for their grants to ensure transactions are posted to the correct grant. They are also given monthly financial statements for each grant to reconcile with their records. • Next steps: Financial reporting will be done on a timely basis, ideally no more than 5 days after the month closing so grant managers can reconcile their records. • Timeline: By early October, we hope to implement the monthly closing no more than 5 days after the month end. • Responsible party: Finance manager with oversight by President
Finding 2024-005 and Finding 2024-006: Procurement Procedures Issue: The audit noted gaps in documenting procurement. The organization did not adopt a formal procurement policy compliant with 2 CFR 200.320 until June 2024. As a result, several contracts executed earlier in the year were noncom plian...
Finding 2024-005 and Finding 2024-006: Procurement Procedures Issue: The audit noted gaps in documenting procurement. The organization did not adopt a formal procurement policy compliant with 2 CFR 200.320 until June 2024. As a result, several contracts executed earlier in the year were noncom pliant with federal procurement standards. Since the policy adoption, all new procurements have followed the updated procedures. The organization also did not keep records of debarment search results. • What's been done: All procurement following the adoption of the procurement policy has been done in alignment with the policy. We also introduced procurement "kickoff meetings" for new grants to review each budget line, determine the correct procurement method, and plan documentation for the procurement process. This has been piloted with our most recent grant. All vendors now have debarment searches in their QuickBooks vendor information tab. • Next steps: Apply this process to all new grants to ensure compliance from the outset. • Responsible party: Finance manager and Executive Director of Michigan Center for Adult College Success with oversight by President
Finding 2024-005 and Finding 2024-006: Procurement Procedures Issue: The audit noted gaps in documenting procurement. The organization did not adopt a formal procurement policy compliant with 2 CFR 200.320 until June 2024. As a result, several contracts executed earlier in the year were noncom plian...
Finding 2024-005 and Finding 2024-006: Procurement Procedures Issue: The audit noted gaps in documenting procurement. The organization did not adopt a formal procurement policy compliant with 2 CFR 200.320 until June 2024. As a result, several contracts executed earlier in the year were noncom pliant with federal procurement standards. Since the policy adoption, all new procurements have followed the updated procedures. The organization also did not keep records of debarment search results. • What's been done: All procurement following the adoption of the procurement policy has been done in alignment with the policy. We also introduced procurement "kickoff meetings" for new grants to review each budget line, determine the correct procurement method, and plan documentation for the procurement process. This has been piloted with our most recent grant. All vendors now have debarment searches in their QuickBooks vendor information tab. • Next steps: Apply this process to all new grants to ensure compliance from the outset. • Responsible party: Finance manager and Executive Director of Michigan Center for Adult College Success with oversight by President
Finding 2024-004: Cutoff Procedures Issue: Previously, there were no formal cutoff procedures to ensure expenses were recorded in the correct period, which caused inconsistencies and required post-year-end journal entries to correct expense timing. • What's been done: Contracts are now recorded as p...
Finding 2024-004: Cutoff Procedures Issue: Previously, there were no formal cutoff procedures to ensure expenses were recorded in the correct period, which caused inconsistencies and required post-year-end journal entries to correct expense timing. • What's been done: Contracts are now recorded as prepaid or accrued expenses and are being expensed monthly. • Next steps: Salaries and benefits incurred before month-end will be accrued to grants at grant cutoff dates (e.g., September 30) and at year-end. Estimated monthly accruals for salaries will be implemented. • Timeline: Full implementation by the end of September 2025. • Responsible party: Finance manager with oversight by President
Recommendation: The Organization should formally adopt a written procurement policy that is in compliance with the Uniform Guidance.
Recommendation: The Organization should formally adopt a written procurement policy that is in compliance with the Uniform Guidance.
Views of Responsible Officials and planned Corrective Actions: The Organization concurs with the recommendation to adopt a written procurement policy and will adopt one for the next fiscal year.
Views of Responsible Officials and planned Corrective Actions: The Organization concurs with the recommendation to adopt a written procurement policy and will adopt one for the next fiscal year.
Recommendation: The Organization should formally adopt a written procurement policy that is in compliance with the Uniform Guidance.
Recommendation: The Organization should formally adopt a written procurement policy that is in compliance with the Uniform Guidance.
Views of Responsible Officials and planned Corrective Actions: The Organization concurs with the recommendation to adopt a written procurement policy and will adopt one for the next fiscal year.
Views of Responsible Officials and planned Corrective Actions: The Organization concurs with the recommendation to adopt a written procurement policy and will adopt one for the next fiscal year.
Recommendation: We recommend that the Board of Directors be aware of the internal control deficiencies over financial reporting. And, if possible, implement procedures to ensure that the Organization has the expertise necessary to prevent, detect and correct misstatements and be capable of drafting ...
Recommendation: We recommend that the Board of Directors be aware of the internal control deficiencies over financial reporting. And, if possible, implement procedures to ensure that the Organization has the expertise necessary to prevent, detect and correct misstatements and be capable of drafting the financial statements, related footnote disclosures and SEFA in accordance with the modified cash basis of accounting.
Views of responsible officials and planned corrective actions: The Association believes it has personnel who possess suitable skill, knowledge, or experience to oversee services the auditor provides in assisting with financial statement presentation which requires a lower level of technical knowledg...
Views of responsible officials and planned corrective actions: The Association believes it has personnel who possess suitable skill, knowledge, or experience to oversee services the auditor provides in assisting with financial statement presentation which requires a lower level of technical knowledge than the competence required to prepare the financial statements, related footnote disclosures, and SEFA in accordance with the modified cash basis of accounting.
To address the issues that resulted in material audit adjustments during FY2024, we will be implementing a new grant and accounting system designed to improve financial accuracy, oversight, and reporting. This system will replace outdated processes that contributed to the inconsistencies identified ...
To address the issues that resulted in material audit adjustments during FY2024, we will be implementing a new grant and accounting system designed to improve financial accuracy, oversight, and reporting. This system will replace outdated processes that contributed to the inconsistencies identified during the audit.
Finding 1155929 (2024-006)
Material Weakness 2024
In ten (10) out of ten (10) applicants/tenants selected for testing, there was no documentation provided, indicating that the tenant was placed on the waiting list.
In ten (10) out of ten (10) applicants/tenants selected for testing, there was no documentation provided, indicating that the tenant was placed on the waiting list.
Finding 1155929 (2024-006)
Material Weakness 2024
Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor’s recommendation that a waiting list be maintained in accordance with the guidelines established in the HUD Handbook 4350.3 REV..
Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor’s recommendation that a waiting list be maintained in accordance with the guidelines established in the HUD Handbook 4350.3 REV..
Finding 1155929 (2024-006)
Material Weakness 2024
Actions Taken on the Finding.
Actions Taken on the Finding.
Finding 1155929 (2024-006)
Material Weakness 2024
Corrected going forward.
Corrected going forward.
Finding 1155928 (2024-005)
Material Weakness 2024
The Project is required by the Department of HUD to make monthly deposit of $9,708.89 into the replacement reserve fund.
The Project is required by the Department of HUD to make monthly deposit of $9,708.89 into the replacement reserve fund.
Finding 1155928 (2024-005)
Material Weakness 2024
Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor’s recommendation that the required monthly deposit of $9,708.89 should be deposited in the replacement reserve account. In addition, a deposit of $3,382.44 is required to be in compliance with the es...
Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor’s recommendation that the required monthly deposit of $9,708.89 should be deposited in the replacement reserve account. In addition, a deposit of $3,382.44 is required to be in compliance with the established Department of HUD guidelines.
Finding 1155928 (2024-005)
Material Weakness 2024
Actions Taken on the Finding.
Actions Taken on the Finding.
Finding 1155928 (2024-005)
Material Weakness 2024
The additional deposit was made 3/24/25.
The additional deposit was made 3/24/25.
Finding 1155927 (2024-004)
Material Weakness 2024
Tenant Files
Tenant Files
View Audit 368350 Questioned Costs: $1
Finding 1155927 (2024-004)
Material Weakness 2024
Move-in:
Move-in:
View Audit 368350 Questioned Costs: $1
Finding 1155927 (2024-004)
Material Weakness 2024
1. In two (2) instances out of ten (10) tenant files selected for testing, the lease agreement was not signed by the landlord.
1. In two (2) instances out of ten (10) tenant files selected for testing, the lease agreement was not signed by the landlord.
View Audit 368350 Questioned Costs: $1
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