Corrective Action Plans

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Reporting – Data Collection Form and Reporting Package (Significant Deficiency) U.S. Department of Education Adult Education – Basic Grants to States (Federal Assistance Listing #84.002) Federal Award Year: 2023-20 Responsible Officials Contact Information: 1) Archana Jayaram, CEO Telephone 718-310-...
Reporting – Data Collection Form and Reporting Package (Significant Deficiency) U.S. Department of Education Adult Education – Basic Grants to States (Federal Assistance Listing #84.002) Federal Award Year: 2023-20 Responsible Officials Contact Information: 1) Archana Jayaram, CEO Telephone 718-310-5626 ajayaram@wearebcs.org 2) Jodi Querbach, COO Telephone 718-310-1015 jquerbach@wearebcs.org View of Responsible Officials and Corrective Action Plan: Management agrees that the single audit reporting package was not submitted within the required timeframe due to key employee turnover coupled with staffing challenges subsequent to year end. This was also after a period of time when the organization’s finance functions were externally managed by an accounting firm. The former firm held the general ledger data for BCS and has been slow to turn it over in a manageable manner causing the delay in filing of the single audit report package. Frank Lei (current Chief Financial Officer) was hired in February of 2025 and has actively hired a new internal finance team, including a controller Daniel Pensante, hired in March of 2025. In our new configuration, BCS will: 1) own its financial software and data, 2) be sufficiently staffed to run its day-to-day financial operations, 3) be able to support program operations in an efficient manner, and 4) be able to respond and complete audits on time. Management will ensure that the single audit report package is submitted before the March 31, 2027 deadline.
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: ALN 14.267 – Continuum of Care Program Grant Period: Year ended December 31, 2024 Condition: The single audit reports were not submitted to the federal audit clearinghouse prior to the September 30, 2025 deadline. Crit...
Federal Agency: U.S. Department of Housing and Urban Development Federal Program: ALN 14.267 – Continuum of Care Program Grant Period: Year ended December 31, 2024 Condition: The single audit reports were not submitted to the federal audit clearinghouse prior to the September 30, 2025 deadline. Criteria: Single audits are required to be submitted to the Federal Audit Clearinghouse at the earlier of 30 days after issuance of the financial statements or nine months after the fiscal year has ended. September 30, 2025 would have been 9 months after the Organization’s fiscal year end of December 31, 2024. Cause: Due to delays in the receipt of the necessary audit documentation, the audit was not able to be completed within the required timeframe. Effect: The Organization was not in compliance with a significant clause of its federal grants and the audit requirements of Uniform Guidance. Context: This noncompliance related to all federal programs, because the submission of the single audit reports to the federal audit clearinghouse is performed at the entity wide level. The finding was identified as part of a statistical sample. Repeat Finding: Yes. A similar finding was reported in the prior year as finding 2023-001. Recommendation: The Organization should put in place policies and procedures to ensure that the books are closed and provided to the auditor in a timely manner that provides sufficient time for an audit to be completed prior to the single audit due date. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges that the single audit was not submitted by the required deadline. Corrective actions have been implemented to improve audit readiness, as stated in our response to finding 2024-001. These measures are expected to ensure timely completion and submission of the 2025 single audit.
Pearl River County Board of Supervisors and the County Administrator will work with the Airport Board to ensure compliance and monitoring of all future federal grants. We will establish an effective process to implement in the future to monitor all expenditures and receipts.
Pearl River County Board of Supervisors and the County Administrator will work with the Airport Board to ensure compliance and monitoring of all future federal grants. We will establish an effective process to implement in the future to monitor all expenditures and receipts.
To address the finding, the Authority has implemented corrective actions that include establishing a formal year-end SEFA preparation and review process involving Accounting and Grant Program Mangers; reconciling federal expenditures reported on the SEFA to the general ledger and year end accruals, ...
To address the finding, the Authority has implemented corrective actions that include establishing a formal year-end SEFA preparation and review process involving Accounting and Grant Program Mangers; reconciling federal expenditures reported on the SEFA to the general ledger and year end accruals, reviewing active federal awards at fiscal year-end to identify eligible expenditures that may not have been reported; Revising the Grants Management Procedures Manual to formalize year-end cutoff, review, reconciliation, and approval procedures prior to SEFA issuance. These procedures will be incorporated into the FY26 year-end close and reporting process.
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.
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