Corrective Action Plans

Finding 1208802 (2024-006)

Material Weakness 2024

Metra - Commuter Rail Division & Commuter Railroad Corporation

IL

Allowable Costs / Cost Principles § 200.403 § 200.414 § 200.441 § 200.511

Finding Reference: 2024-006 Finding Title: Indirect Cost Rate Pool, Noncompliance and Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Alan Ochab, Senior Director, Budget Management & Analysis, (312) 322-1519 Planned Corrective A...

Finding Reference: 2024-006 Finding Title: Indirect Cost Rate Pool, Noncompliance and Significant Deficiency CAP Contact Persons: • John Morris, Chief Financial Officer, Financial Affairs, (312) 322-6420 • Alan Ochab, Senior Director, Budget Management & Analysis, (312) 322-1519 Planned Corrective Actions: 1. Correction Adjustment: Management has communicated to its consultant, Maximus, its expectation that the final 2026 indirect cost rate report will incorporate an adjustment to remove the disallowed expense related to the unallowable tax penalty for all affected 2026 rates. Metra will not authorize submission of the final report to the Federal Transit Administration (FTA) until the Finance team confirms that the adjustment has been appropriately reflected and its impact fully evaluated. The adjustment, including relevant background information and its general impact on the rates, will be disclosed in the transmittal letter submitted to the FTA with the final report. 2. Independent Review Controls: Management will strengthen internal review controls by implementing a secondary review of the indirect cost rate data, including consulting with Internal Audit to improve review procedures. This review will verify that costs included in the indirect cost pool are allowable, reasonable, and adequately supported in accordance with 2 CFR Part 200, prior to submission to the Federal Transit Administration (FTA). Anticipated Completion Date: 09/30/2026

View Audit 399665

Finding 1208637 (2024-007)

Material Weakness 2024

Jefferson Parish

LA

Procurement, Suspension & Debarment § 200.327

Management acknowledges the finding and agrees that strengthening procurement controls is necessary to ensure full compliance with federal requirements. To address this issue, the Parish has implemented a standardized contract for use in federally funded procurements that incorporates all applicable...

Management acknowledges the finding and agrees that strengthening procurement controls is necessary to ensure full compliance with federal requirements. To address this issue, the Parish has implemented a standardized contract for use in federally funded procurements that incorporates all applicable requirements under 2 CFR §200.327 and Appendix II to Part 200. In this specific instance the two contracts noted were state contracts. When state contracts are utilized, the Parish will take the necessary steps to validate that such contracts include all required federal contract provisions prior to utilizing any state contracts. Guidance will also be provided to all procurement personnel involved in contracting to reinforce understanding and consistent application of federal requirements. Management expects these corrective actions to be implemented in the near term and will conduct ongoing monitoring to ensure compliance and effectiveness of the enhanced controls. Interim Finance Director Victor LaRocca, Purchasing Director Renny Simno and Assistant Accounting Director Charles “Joey” Vasquez will ensure that this is enacted immediately and that guidance is provided to procurement personnel by June of 2026.

View Audit 399587

Finding 1208624 (2024-006)

Material Weakness 2024

Jefferson Parish

LA

Reporting Subrecipient Monitoring HUD Housing Programs

Management acknowledges this repeat finding and recognizes that, while prior conditions contributed to the issue, corrective actions have been implemented and significant progress has been made to resolve the finding. Since the audit finding, required compliance reports have been submitted timely. M...

Management acknowledges this repeat finding and recognizes that, while prior conditions contributed to the issue, corrective actions have been implemented and significant progress has been made to resolve the finding. Since the audit finding, required compliance reports have been submitted timely. Management considers the issue resolved; however, monitoring procedures will remain in place as a precaution to ensure continued compliance. Chief Administrative Assistant Nicole Thompson and Community Development Director Stephanie Brumfield will continue to monitor the submission of timely reports in compliance with federal requirements.

View Audit 399587

Finding 1208623 (2024-005)

Material Weakness 2024

Jefferson Parish

LA

Procurement, Suspension & Debarment Reporting Subrecipient Monitoring

Management acknowledges this repeat finding and the importance of full compliance with federal reporting requirements. While progress has been made, additional monitoring is still necessary to fully remediate this issue. As part of these efforts, Jefferson Parish, has established a process to monito...

Management acknowledges this repeat finding and the importance of full compliance with federal reporting requirements. While progress has been made, additional monitoring is still necessary to fully remediate this issue. As part of these efforts, Jefferson Parish, has established a process to monitor the timely submission of reports in compliance with federal requirements. Management considers the corrective action to be substantially implemented. Ongoing review has been put into place to confirm continued compliance. Chief Administrative Assistant Nicole Thompson will continue to monitor the submission of timely reports in compliance with federal requirements.

View Audit 399587

Finding 1208595 (2024-004)

Material Weakness 2024

Vernon J. Harris East End Community Health Center

VA

HUD Housing Programs Internal Control / Segregation of Duties

Management will implement standardized procedures for determining and verifying patient eligibility for sliding fee discounts, including required documentation and supervisory review. System controls will be enhanced to reduce manual errors, and staff will receive training on proper application of t...

Management will implement standardized procedures for determining and verifying patient eligibility for sliding fee discounts, including required documentation and supervisory review. System controls will be enhanced to reduce manual errors, and staff will receive training on proper application of the sliding fee schedule. Routine audits will be conducted to verify compliance and ensure accuracy in patient fee assignments.

View Audit 399556

Finding 1208594 (2024-003)

Material Weakness 2024

Vernon J. Harris East End Community Health Center

VA

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Management will establish a formal reconciliation process between the general ledger and all federal reports prior to submission. This will include documented review procedures, supervisory approval, and the use of standardized reconciliation templates. Staff will be trained on reporting accuracy re...

Management will establish a formal reconciliation process between the general ledger and all federal reports prior to submission. This will include documented review procedures, supervisory approval, and the use of standardized reconciliation templates. Staff will be trained on reporting accuracy requirements, and periodic internal reviews will be conducted to ensure financial data integrity and compliance.

View Audit 399556

Finding 1208593 (2024-002)

Material Weakness 2024

Vernon J. Harris East End Community Health Center

VA

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Management will implement a centralized compliance tracking system that includes a reporting calendar with automated reminders for all federal reporting deadlines. Responsibility for report preparation and submission will be formally assigned, with supervisory review prior to submission. Compliance ...

Management will implement a centralized compliance tracking system that includes a reporting calendar with automated reminders for all federal reporting deadlines. Responsibility for report preparation and submission will be formally assigned, with supervisory review prior to submission. Compliance meetings will be established to monitor reporting status and ensure deadlines are met.

View Audit 399556

Finding 1208592 (2024-004)

Material Weakness 2024

San Diego Workforce Partnership

CA

Subrecipient Monitoring § 200.332

SDWP acknowledges the requirement under 2 CFR 200.332(b) to provide specified Federal award information to subrecipients at the time of subaward. During the audit period, certain required elements (including Assistance Listing information, Federal Award Identification Number, and other required data...

SDWP acknowledges the requirement under 2 CFR 200.332(b) to provide specified Federal award information to subrecipients at the time of subaward. During the audit period, certain required elements (including Assistance Listing information, Federal Award Identification Number, and other required data elements) were not consistently included in subaward agreements at the time of issuance. This condition was primarily due to the absence of a standardized subaward agreement template and checklist to ensure all required elements under Uniform Guidance were included and communicated to subrecipients at the time of subaward. To address this finding, effective April 1, 2026, the Contract Manager will include all required data elements in a standardized subaward agreement template, confirm source of funding for each subaward, and include required data elements in all applicable subaward agreements.

View Audit 399554

Finding 1208591 (2024-003)

Material Weakness 2024

San Diego Workforce Partnership

CA

Effective July 1, 2025, the San Diego Workforce Partnership (SDWP) will strengthen its internal controls to ensure compliance with the WIOA Youth Out‑of‑School Youth (OSY) expenditure requirement. SDWP recognizes that the 75 percent minimum Out of School Youth (OSY) expenditure requirement was not m...

Effective July 1, 2025, the San Diego Workforce Partnership (SDWP) will strengthen its internal controls to ensure compliance with the WIOA Youth Out‑of‑School Youth (OSY) expenditure requirement. SDWP recognizes that the 75 percent minimum Out of School Youth (OSY) expenditure requirement was not met during the audit period. This resulted from insufficient monitoring controls, the absence of a systematic process to track spending progress, and the failure to pursue and obtain an approved waiver to reduce the requirement to the allowable 50 percent minimum. To address this finding, SDWP is implementing an enhanced expenditure tracking and monitoring system that will include: • A monthly OSY expenditure report that reconciles budget‑to‑actual spending and highlights progress toward the requirement. • A review process requiring the Programs Manager to validate monthly OSY compliance reports. • Quarterly financial compliance reviews conducted by the CFO to ensure timely corrective action if spending trends indicate potential noncompliance. • An annual review process will be established to determine whether submission of a waiver is applicable, including the preparation and formal review of any required waiver documentation. The WIOA Out of School Youth Waiver Application for FY25–26 has been completed and will be incorporated into this annual review process moving forward. The Accounting Manager will be responsible for maintaining the tracking system, performing monthly reviews, and coordinating with program staff to ensure expenditures align with federal requirements. The Chief Financial Officer (CFO) will provide oversight, verify compliance during quarterly reviews, and ensure that policies and procedures are adhered to.

View Audit 399554

Finding 1208588 (2024-002)

Material Weakness 2024

San Diego Workforce Partnership

CA

Subrecipient Monitoring HUD Housing Programs Reporting

Effective March 1, 2026, the San Diego Workforce Partnership will incorporate the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) reporting deadline into the Month‑End Schedule. The activities outlined in this schedule help ensure that all required financ...

Effective March 1, 2026, the San Diego Workforce Partnership will incorporate the Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting System (FSRS) reporting deadline into the Month‑End Schedule. The activities outlined in this schedule help ensure that all required financial data is captured, reviewed, and reported in a timely and complete manner. The Accounting Manager will oversee the operational steps required to meet FSRS reporting deadlines, while the Chief Financial Officer (CFO) will provide overall oversight to ensure that these procedures are consistently followed and that internal control expectations are met. Effective March 1, 2026, to address the delay in submission of monthly reports for the ARPA grant to the pass-through agency, the San Diego Workforce Partnership is implementing strengthened internal controls and workflow procedures to ensure all required reports are submitted by the 15th day following the end of each month, as stipulated in the grant agreement.

View Audit 399554

Finding 1208582 (2024-001)

Material Weakness 2024

TOWN OF LOCKHART

SC

Reporting Significant Deficiency Internal Control / Segregation of Duties

Significant Deficiency 2024-001 – Internal Control Over Financial Reporting Name of Contact Person: Helen McFalls, Town Clerk Corrective Action: The Town is committed to taking steps to improve its financial management and accounting capacity and the Council will remain involved in the financial aff...

Significant Deficiency 2024-001 – Internal Control Over Financial Reporting Name of Contact Person: Helen McFalls, Town Clerk Corrective Action: The Town is committed to taking steps to improve its financial management and accounting capacity and the Council will remain involved in the financial affairs of the Town to provide oversight. Proposed Completion Date: Management has implemented the above action.

View Audit 399545

Finding 1208575 (2024-004)

Material Weakness 2024

Calhoun, Greene, Jersey, and Macoupin Counties Regional Office of Education No. 40

IL

Allowable Costs / Cost Principles

The ROE will use time and effort documentation to distribute salary and benefit costs for all employees. The ROE will implement the necessary controls over payroll to ensure that payroll is being properly prepared and calculated.

View Audit 399505

Finding 1208573 (2024-002)

Material Weakness 2024

Special Olympics Massachusetts, Inc.

MA

Procurement, Suspension & Debarment

In 2024, Special Olympics Massachusetts relied on nationally approved vendors for procurement of education materials, awards and specialty items. These nationally approved vendors provide affiliated programs discounted rates based on the bulk item purchase of programs. In 2025, some of those nationa...

In 2024, Special Olympics Massachusetts relied on nationally approved vendors for procurement of education materials, awards and specialty items. These nationally approved vendors provide affiliated programs discounted rates based on the bulk item purchase of programs. In 2025, some of those nationally affiliated programs were discontinued and Special Olympics MA did seek multiple bids for items such as awards and materials. Moving forward, CFO Clinton Rowe will develop and implement a written procurement policy that meets the requirements of the Uniform Guidance by June 30, 2026.

View Audit 399496

Finding 1208435 (2024-006)

Material Weakness 2024

Town of Beaver, Oklahoma

OK

Management will make arrangements to have their records inspected quicker after year-end to ensure the timely completion of an audit. Additionally, follow-up procedures will be executed to ensure all parties have received the required information to complete audit procedures prior to the deadline. M...

Management will make arrangements to have their records inspected quicker after year-end to ensure the timely completion of an audit. Additionally, follow-up procedures will be executed to ensure all parties have received the required information to complete audit procedures prior to the deadline. Management acknowledges the findings and agrees that improvements to procurement documentation are needed. The Town will review and strengthen its purchasing procedurs, implement a procurement documentation checklist, and provide training to staff to ensure complance with OKlahoma statutes and Town policy going forward. Additionally, management will review their current employee hand ook and make necessary adjustments to implement procedures related to changing employee timesheets prior to payment approval.

View Audit 399387

Finding 1208412 (2024-002)

Material Weakness 2024

Anderson Place Apartments, Inc.

IN

Eligibility HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenant...

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenants should sign the recertification form. In addition, management should review all files and report any discrepancies to HUD in a timely manner. Action Taken: The management of Anderson Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will complete and document all annual recertifications, will maintain all documentation in tenant files to support the 50059 forms, will review all tenant files and report any discrepancies to HUD, and will make the necessary adjustments to tenant rent and rental subsidy calculations on the 50059 forms as soon as possible.

View Audit 399377

Finding 1208411 (2024-003)

Material Weakness 2024

Cain Center Apartments, Inc. Dba Brown-MacKinnon Apartments

KY

HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure adjustments made to the monthly PRAC billings are accurate before submission. Excess subsidy payments should be repaid to HUD. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments a...

Recommendation: The design of the current controls should be reviewed to ensure adjustments made to the monthly PRAC billings are accurate before submission. Excess subsidy payments should be repaid to HUD. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billings are reviewed for accuracy before submission. Excess subsidy payments will be repaid to HUD through adjustments to monthly billing.

View Audit 399375

Finding 1208410 (2024-002)

Material Weakness 2024

Cain Center Apartments, Inc. Dba Brown-MacKinnon Apartments

KY

Eligibility HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenant...

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenants should sign the recertification form. In addition, management should review all files and report any discrepancies to HUD in a timely manner. Action Taken: The management of Cain Center Apartments, Inc. dba Brown-Mackinnon Apartments accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will complete and document all annual recertifications, will maintain all documentation in tenant files to support the 50059 forms, will review all tenant files and report any discrepancies to HUD, and will make the necessary adjustments to tenant rent and rental subsidy calculations on the 50059 forms as soon as possible.

View Audit 399375

Finding 1208409 (2024-002)

Material Weakness 2024

Thompson-Woodlief Apartments, Inc.

KY

Eligibility HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenants sho...

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenants should sign the recertification form. In addition, management should review all files and report any discrepancies to HUD in a timely manner. Action Taken: The management of Thompson-Woodlief Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will complete and document all annual recertifications, will maintain all documentation in tenant files to support the 50059 forms, will review all tenant files and report any discrepancies to HUD, and will make the necessary adjustments to tenant rent and rental subsidy calculations on the 50059 forms as soon as possible.

View Audit 399374

Finding 1208408 (2024-004)

Material Weakness 2024

Jude's Place Apartments, Inc.

KY

HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized in the event of a deceased tenant. The overpayment of subsidy received on behalf of the deceased tenant should be repaid to HUD. Action Taken: The management of Jude’s Place Apartments, ...

Recommendation: The design of the current controls should be reviewed to ensure proper vacancy dates are utilized in the event of a deceased tenant. The overpayment of subsidy received on behalf of the deceased tenant should be repaid to HUD. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that moveouts as a result of a deceased tenant are processed in accordance with HUD guidelines. The overpayment of subsidy will be repaid to HUD through adjustments to monthly billing.

View Audit 399373

Finding 1208407 (2024-003)

Material Weakness 2024

Jude's Place Apartments, Inc.

KY

HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before processing. The Organization should repay overpayment of subsidy to HUD. Action Taken:The management of Jude’s Place Apartments, Inc. accepts the recommendatio...

Recommendation: The design of the current controls should be reviewed to ensure that all adjustments to monthly billings are reviewed before processing. The Organization should repay overpayment of subsidy to HUD. Action Taken:The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will implement procedures to ensure that all adjustments to monthly billing are reviewed to ensure they are processed correctly. Overpayment of subsidy will be repaid to HUD through adjustments to monthly billing.

View Audit 399373

Finding 1208406 (2024-002)

Material Weakness 2024

Jude's Place Apartments, Inc.

KY

Eligibility HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenant...

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenants should sign the recertification form. In addition, management should review all files and report any discrepancies to HUD in a timely manner. Action Taken: The management of Jude’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will complete and document all annual recertifications, will maintain all documentation in tenant files to support the 50059 forms, will review all tenant files and report any discrepancies to HUD, and will make the necessary adjustments to tenant rent and rental subsidy calculations on the 50059 forms as soon as possible.

View Audit 399373

Finding 1208405 (2024-003)

Material Weakness 2024

Edsil's Place Apartments, Inc.

KY

HUD Housing Programs Cash Management

Recommendation: The Organization should contact HUD to facilitate the remittance of excess residual receipts. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will contact HUD to ensure that al...

Recommendation: The Organization should contact HUD to facilitate the remittance of excess residual receipts. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will contact HUD to ensure that all excess residual receipts are remitted to HUD as soon as possible.

View Audit 399372

Finding 1208404 (2024-002)

Material Weakness 2024

Edsil's Place Apartments, Inc.

KY

Eligibility HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenant...

Recommendation: The design of the current controls should be reviewed to ensure tenant files are complete and accurate. The Organization should fill out and maintain HUD Form 50059 for each annual recertification and keep information in the files that support the data used in its preparation. Tenants should sign the recertification form. In addition, management should review all files and report any discrepancies to HUD in a timely manner. Action Taken: The management of Edsil’s Place Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will complete and document all annual recertifications, will maintain all documentation in tenant files to support the 50059 forms, will review all tenant files and report any discrepancies to HUD, and will make the necessary adjustments to tenant rent and rental subsidy calculations on the 50059 forms as soon as possible.

View Audit 399372

Finding 1208399 (2024-004)

Material Weakness 2024

Adams-Bodine Apartments, Inc.

KY

HUD Housing Programs

Recommendation: The design of the current controls should be reviewed to ensure tenant assets are complete and accurate. The information in the files should support the tenant assets used in preparing the Form 50059 and calculating the corresponding tenant’s share of the rent. Action Taken:The manag...

Recommendation: The design of the current controls should be reviewed to ensure tenant assets are complete and accurate. The information in the files should support the tenant assets used in preparing the Form 50059 and calculating the corresponding tenant’s share of the rent. Action Taken:The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will review all tenant assets and report any discrepancies to HUD and make the necessary adjustments to tenant rent and rental subsidy calculations on the 50059 forms as soon as possible.

View Audit 399370

Finding 1208398 (2024-003)

Material Weakness 2024

Adams-Bodine Apartments, Inc.

KY

Equipment & Real Property Management

Recommendation: The design of the current controls should be reviewed to ensure proper reconciliation of the reserve for replacement is performed. The Organization should ensure that all required deposits to the reserve for replacement are made during the year. Action Taken:The management of Adams-B...

Recommendation: The design of the current controls should be reviewed to ensure proper reconciliation of the reserve for replacement is performed. The Organization should ensure that all required deposits to the reserve for replacement are made during the year. Action Taken:The management of Adams-Bodine Apartments, Inc. accepts the recommendation of Deming, Malone, Livesay & Ostroff and, accordingly, management will regularly reconcile its deposits for the reserve for replacement and ensure that all required deposits to the reserve for replacement are made during the year. A deposit has been made to correct the shortage.

View Audit 399370

Corrective Action Plans

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