Corrective Action Plans

Finding 564297 (2024-003)

Material Weakness 2024

TX

Reporting Equipment & Real Property Management Matching / Level of Effort / Earmarking

CORRECTIVE ACTION PLANNED: We agree with the finding and have implemented corrective action, including strengthening of written procedures as well as the engagement of outside consultants to assist with training and policy direction. The control deficiencies noted were originally identified in fisca...

CORRECTIVE ACTION PLANNED: We agree with the finding and have implemented corrective action, including strengthening of written procedures as well as the engagement of outside consultants to assist with training and policy direction. The control deficiencies noted were originally identified in fiscal year 2022 but certain programmatic changes delayed full completion of corrective action. However, management believes that now-implemented procedures will address the deficiency in future years. PERSON RESPONSIBLE FOR CORRECTION ACTION: James McCullough, Board President ANTICIPATED COMPLETION DATE: September 30, 2025

View Audit 358437

Finding 564290 (2024-002)

Material Weakness 2024

Greene County Community School District

IA

Internal Control / Segregation of Duties

We acknowledge the auditor’s comment regarding segregation of duties in the handling and recording of cash receipts. The district recently transitioned to a new accounting software system, which has prompted a review and adjustment of internal procedures to strengthen internal controls. As part of t...

We acknowledge the auditor’s comment regarding segregation of duties in the handling and recording of cash receipts. The district recently transitioned to a new accounting software system, which has prompted a review and adjustment of internal procedures to strengthen internal controls. As part of this transition, we are actively training building secretaries to assume greater responsibility in the initial steps of the cash receipt process. Specifically, secretaries will be responsible for: • Receiving and documenting cash and checks at their respective buildings. • Preparing and depositing funds directly at the bank. • Completing a cash receipt form and forwarding it, along with deposit confirmation, to the business office. The business office staff will then independently record the transactions into the accounting system, ensuring a clear segregation between the receipt of funds and their entry into the general ledger. We anticipate full implementation of this updated process by 8/2025, with training sessions and support ongoing to ensure consistency and compliance across all buildings. We believe this revised procedure addresses the concern by separating duties between collection/deposit and system entry, thereby reducing the risk of errors or misappropriation.

View Audit 358425

Finding 564279 (2024-001)

Significant Deficiency 2024

The Geneva Foundation

WA

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

Contact Person(s): Kristen Bacon, Director of Finance Corrective action planned: The corrective actions to enhance Geneva’s lease management process are being implemented in Q1 and Q2 of 2025. A retroactive review of all Lease agreements was conducted in Q1 2025. An outcome of this review is th...

Contact Person(s): Kristen Bacon, Director of Finance Corrective action planned: The corrective actions to enhance Geneva’s lease management process are being implemented in Q1 and Q2 of 2025. A retroactive review of all Lease agreements was conducted in Q1 2025. An outcome of this review is the rollout of a requirement for real estate development firms to submit monthly invoices per the contractual terms with Geneva. In addition, a monthly reconciliation process is being performed by the Accounting Manager with an extra layer of review by the Director, Finance and Accounting, along with a quarterly reconciliation of leases (by location) performed by the Accounting Manager to ensure that payments match the data in recent Lease modifications by location. Lastly, the Accounting Manager is re-training Finance staff on file management and the utilization of a lease management tracker. If process deficiencies are identified or Standard Operating Procedures are not current, updates will be made, and end user compliance training will be rolled out to ensure a clear understanding. Recovery of the excessive lease payments will occur prior to 30 June 2025. Anticipated completion date: 30 June 2025

View Audit 358417 Questioned Costs: $1

Finding 564276 (2024-002)

Material Weakness 2024

West Monona Community School District

IA

Internal Control / Segregation of Duties Reporting

All nutrition money received from students will be received by secretaries. The secretaries will write up receipts and give the money to the Nutrition Assistant to be entered into the nutrition account. The superintendent will check over and sign off on monthly bank reconciliations, posted monthly j...

All nutrition money received from students will be received by secretaries. The secretaries will write up receipts and give the money to the Nutrition Assistant to be entered into the nutrition account. The superintendent will check over and sign off on monthly bank reconciliations, posted monthly journal entries, and all bank transfers.

View Audit 358416

Finding 564275 (2024-001)

Significant Deficiency 2024

Regent at Apple Valley, LLC Dba: the Seasons at Apple Valley

MN

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to retain the HUD approved management agreement to ensure payments made are in accordance with HUD requirements. The Project does not have a HUD approved management agreement. Recommendation: Recommend that manage...

Section 232 HUD-Insured Mortgage– Assistance Listing No. 14.129 Management is required to retain the HUD approved management agreement to ensure payments made are in accordance with HUD requirements. The Project does not have a HUD approved management agreement. Recommendation: Recommend that management work with HUD to have the current management agreement approved. There is no disagreement with the audit finding. Action taken in response to finding: We have contacted HUD to obtain an approved management agreement. Name of the contact person responsible for corrective action: Doug Harrison Planned completion date for corrective action plan: September 2025

View Audit 358406

Finding 564274 (2024-003)

Significant Deficiency 2024

East River Legal Services Corporation

SD

Internal Control / Segregation of Duties Cash Management Eligibility

Federal Agency Name: Legal Services Corporation Program Name: Legal Services Corporation – Basic Field Grant FFAL#: 09-542026 Finding Summary: Testing identified one case in which the U.S. Citizen Attestation was not obtained and one case in which documentation was not obtained and retained within ...

Federal Agency Name: Legal Services Corporation Program Name: Legal Services Corporation – Basic Field Grant FFAL#: 09-542026 Finding Summary: Testing identified one case in which the U.S. Citizen Attestation was not obtained and one case in which documentation was not obtained and retained within the case file detailing immigration documents being received and reviewed. Responsible Individuals: Lea Wroblewski, Executive Director. Corrective Action Plan: The Organization will communicate to staff the importance of ensuring all required case file documentation is obtained and retained as required by the federal program. The compliance officer will review case file documentation for compliance after the case is closed and will provide staff training as needed to improve compliance. Completion Date: May 2025

View Audit 358389

Finding 564273 (2024-002)

Significant Deficiency 2024

East River Legal Services Corporation

SD

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

Federal Agency Name: Legal Services Corporation Program Name: Legal Services Corporation – Basic Field Grant FFAL#: 09-542026 Finding Summary: The Organization did not perform an annual IT risk assessment during 2024 and did not test an emergency disaster prevention and recovery plan as required in...

Federal Agency Name: Legal Services Corporation Program Name: Legal Services Corporation – Basic Field Grant FFAL#: 09-542026 Finding Summary: The Organization did not perform an annual IT risk assessment during 2024 and did not test an emergency disaster prevention and recovery plan as required in Section 2.5.3 of the LSC Financial Guide. Responsible Individuals: Lea Wroblewski, Executive Director Corrective Action Plan: The Executive Director shared the risk assessment guidelines with the 3rd party IT consultants, CMIT Solutions of Sioux Falls, who is familiar with technology utilized by ERLS. CMIT Solutions will conduct an annual risk assessment, help create an emergency disaster prevention and recovery plan, and help ensure that risk assessment guidelines are followed. At the regularly scheduled annual review with CMIT, ERLS will review the necessity of additional technology improvements following the completion of the 2022 Technology Assessment. Completion Date: July 2025

View Audit 358389

Finding 564272 (2024-005)

None 2024

Los Angeles Community College District

CA

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking

Corrective Actions: The District will continue to focus on learning and improving the delivery of its grant programs. While proud of the effort and engagement demonstrated in this program, which has been recognized as a gold standard for similar programs nationwide, the District is committed to sett...

Corrective Actions: The District will continue to focus on learning and improving the delivery of its grant programs. While proud of the effort and engagement demonstrated in this program, which has been recognized as a gold standard for similar programs nationwide, the District is committed to setting higher goals and expectations. We will continue to work diligently to achieve these ambitious objectives in future programs. Going forward, we will establish a communication protocol with the granting agencies to clarify the program goals and grant requirements as needed. We will implement more frequent monitoring tools for the early identification of potential concerns that may require further attention from the granting agencies. Personnel Responsible for Implementation: Nyame-Tease Prempeh, Director of Accounting, Los Angeles Community College District College Personnel, Grant Coordinators Expected Date of Implementation: December 1, 2024

View Audit 358384

Finding 564268 (2024-004)

None 2024

Los Angeles Community College District

CA

Reporting Student Financial Aid Special Tests & Provisions

Corrective Actions: The Financial Aid Supervisor will check the monthly V4/V5 report to ensure timely submission. However, according to the May 23, 2024, Electronic Announcement (GENERAL-24-63), the V4/V5 reporting deadlines are impacted by 2024-25 FAFSA processing and FAFSA Partner Portal (FPP) fun...

Corrective Actions: The Financial Aid Supervisor will check the monthly V4/V5 report to ensure timely submission. However, according to the May 23, 2024, Electronic Announcement (GENERAL-24-63), the V4/V5 reporting deadlines are impacted by 2024-25 FAFSA processing and FAFSA Partner Portal (FPP) functionality delays. Personnel Responsible for Implementation: Ludwig Perez, Financial Aid Manager, Los Angeles Harbor College Marisol Velazquez, Financial Aid Manager, Los Angeles Technical Trade College Vernon Bridges, Financial Aid Manager, Los Angeles Valley College Expected Date of Implementation: When FPP becomes available

View Audit 358384

Finding 564264 (2024-003)

None 2024

Los Angeles Community College District

CA

Subrecipient Monitoring Special Tests & Provisions Student Financial Aid

Corrective Actions: A. Perform Timely Access Revocation and Strengthen User Access Reviews ‐ The District implemented a new automated solution to terminate SSO and PS SIS access. This was implemented October 2024. ‐ The District’s plan is, upon implementation of the automated solution to deprovision...

Corrective Actions: A. Perform Timely Access Revocation and Strengthen User Access Reviews ‐ The District implemented a new automated solution to terminate SSO and PS SIS access. This was implemented October 2024. ‐ The District’s plan is, upon implementation of the automated solution to deprovision SSO and PS SIS access, our team is planning on performing annual user access for SSO and PS SIS reviews beginning Q1 2025. The District is also implementing Pathlock that will introduce user access reviews. ‐ For SAP access revocation the SAP Team is looking into options to deprovision users and audit user access through internal or third-party tools. The District anticipates selection of the tools by June 30, 2025. Upon implementation of the selected SAP tools the District will perform periodic access reviews for regular users. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: June 30, 2025 B. Maintain and Review Logs of Users' Activity for both SAP and PS SIS ‐ Upon implementation of Pathlock, the District will perform periodic access reviews for regular users. ‐ Upon implementation of the selected SAP tools, the District will perform periodic access reviews for regular users. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: June 30, 2025 C. Implement Data-at-Rest encryption for SAP and PS SIS Servers ‐ The District is in the process of upgrading PS SIS PeopleTools after which we will determine the most expedient path to implementing database encryption. The target completion for the PS SIS database encryption is Q3 of 2025 ‐ The District is currently evaluating the feasibility of adding the encryption of the SAP database to the HANA upgrade project. If the District determines that it’s not feasible, we will engage a third party to encrypt the SAP database. The target completion for the SAP database encryption is Q3 of 2025. Personnel responsible for Implementation: Carmen V. Lidz, Vice Chancellor & Chief Information Office Expected Date of Implementation: Q3 of 2025

View Audit 358384

Finding 564262 (2024-002)

Significant Deficiency 2024

Los Angeles Community College District

CA

Questioned Costs Student Financial Aid Special Tests & Provisions

Corrective Actions: A. Incorrect Calculation of Return of Title IV Funds Los Angeles Harbor College The District’s Central Financial Aid Unit (CFAU) R2T4 Unit centralized the R2T4 process at all nine colleges during the 2023-24 aid year. CFAU is currently processing R2T4 calculations for Los Angeles...

Corrective Actions: A. Incorrect Calculation of Return of Title IV Funds Los Angeles Harbor College The District’s Central Financial Aid Unit (CFAU) R2T4 Unit centralized the R2T4 process at all nine colleges during the 2023-24 aid year. CFAU is currently processing R2T4 calculations for Los Angeles Harbor College. Personnel Responsible for Implementation: Ludwig Perez, Financial Aid Manager, Los Angeles Harbor College Steve Giorgi, Financial Aid Manager, Central Financial Aid Unit Expected Date of Implementation: Already Implemented B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) EPIE will share the most recent annual internal audit review with each college team and require each college to develop a corrective action plan. EPIE will submit a request to add a pop-up message to the faculty roster directly tied to completion of the mandatory exclusion roster (census roster), supplemental roster, and active enrollment roster. The pop-up message will continue to be displayed until the faculty member successfully submits their roster. EPIE will work with the distance education (DE) faculty coordinators to create professional development training geared toward using Canvas to determine an online student’s last date of academic engagement and will offer the training annually. Additionally, EPIE will conduct training for administrators on the use of queries to monitor pending rosters. Personnel Responsible for Implementation: Nicole Albo-Lopez, Vice Chancellor, EPIE Expected Date of Implementation: June 30, 2025

View Audit 358384 Questioned Costs: $1

Finding 564260 (2024-001)

None 2024

Los Angeles Community College District

CA

Student Financial Aid Reporting Matching / Level of Effort / Earmarking

Corrective Action: The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will analyze the current programming and test cases and develop programming to correct the misalignment of the student status effective date reported to the NSC and s...

Corrective Action: The District’s Educational Programs & Institutional Effectiveness (EPIE) and Information Technology (IT) divisions will analyze the current programming and test cases and develop programming to correct the misalignment of the student status effective date reported to the NSC and student status date in PeopleSoft. EPIE will continue to monitor post-submission errors and warning reports to review the effectiveness of the programming change. Personnel Responsible for Implementation: Maury Pearl, Associate Vice Chancellor Andrew Alvarez, IT Business Analyst Stan Levin, Senior Research Analyst Expected Date of Implementation: March 31, 2025

View Audit 358384

Finding 564259 (2024-001)

Significant Deficiency 2024

Isabella Citizens for Health, INC

MI

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.320

2024-001 Federal Program - Federal Program AL# 93.526 - Health Center Infrastructure Support - Significant Deficiency in internal control over federal award program and Noncompliance - Procurement Recommendation – We recommend that management reinforce adherence to the Center’s procurement policy by...

2024-001 Federal Program - Federal Program AL# 93.526 - Health Center Infrastructure Support - Significant Deficiency in internal control over federal award program and Noncompliance - Procurement Recommendation – We recommend that management reinforce adherence to the Center’s procurement policy by providing periodic training to all staff involved in the purchasing process, with a focus on the appropriate application of procurement methods in accordance with 2 CFR § 200.320. Additionally, management should implement a formal review and oversight mechanism to ensure that all procurement transactions exceeding established thresholds are properly evaluated on an aggregate basis, fully documented, and compliant with both internal policies and federal regulations. Action Taken – We concur with the audit finding. While the Center has a policy that meets the compliance requirements, management is responsible for the implementation and monitoring of those processes and procedures. the Center will conduct training for all relevant staff on the proper application of procurement thresholds and documentation requirements. Additionally, management will implement a procurement review checklist and approval process to ensure that all purchases are evaluated in accordance with applicable procedures. These corrective actions will be implemented by December 31, 2025.

View Audit 358378 Questioned Costs: $1

Finding 564258 (2024-001)

Material Weakness 2024

Lakeland Union High School

WI

Cash Management Reporting

Condition: The District audit resulted in a material restatement to fund balance/net position that was detected by auditing procedures. Plan: The District acknowledges the finding and will continue to review new standards as part of the fiscal audit process. Anticipated Date of Completion: The Distr...

Condition: The District audit resulted in a material restatement to fund balance/net position that was detected by auditing procedures. Plan: The District acknowledges the finding and will continue to review new standards as part of the fiscal audit process. Anticipated Date of Completion: The District will immediately implement yearly review of new standards as part of the fiscal audit process.

View Audit 358371

Finding 564254 (2024-002)

Significant Deficiency 2024

Amphitheater Unified School District No. 10

AZ

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Finding Number: 2024‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be r...

Finding Number: 2024‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be requiring all District LEAs to take the necessary training through the Arizona Department of Education web portal and related classes as necessary to be better informed on ESSER reporting and supporting documentation.

View Audit 358361

Finding 564250 (2024-001)

Significant Deficiency 2024

Amphitheater Unified School District No. 10

AZ

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.439

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be requiring...

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be requiring all District LEAs to take the necessary training through the Arizona Department of Education web portal and related classes as necessary to be better informed on Capital Expenditures and required approval and form submission.

View Audit 358361 Questioned Costs: $1

Finding 564248 (2024-001)

Material Weakness 2024

Lorna Doone Associates, LLC

UT

Questioned Costs HUD Housing Programs Matching / Level of Effort / Earmarking

a. Management is negotiating a solution with the State of Utah and HUD for a refund of the payment.

View Audit 358354 Questioned Costs: $1

Finding 564247 (2024-001)

Material Weakness 2024

Metro Towers, Inc. St. James Place

MO

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2024. Finding 2024-001 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2025

View Audit 358353

Finding 564243 (2024-015)

Material Weakness 2024

Charter County of Wayne, Michigan

MI

Eligibility Material Weakness Matching / Level of Effort / Earmarking § 200.303

Condition: The County’s controls over meal participants did not ensure a review was in place to check the intake forms for Halal Home Delivered meal participants or that updated assessments were obtained for home delivered meals. Lastly there was not a control in place to ensure liquid meal particip...

Condition: The County’s controls over meal participants did not ensure a review was in place to check the intake forms for Halal Home Delivered meal participants or that updated assessments were obtained for home delivered meals. Lastly there was not a control in place to ensure liquid meal participants maintained a physician order, renewed every six months, stating the need for the continued supplement service. Planned Corrective Action: Wayne County’s Department of Senior Services will implement processes to ensure only eligible individuals receive meals. A quarterly report will be run to verify all home delivered meal clients have updated assessments and reassessments and will be reviewed by the Department Director and or Division Director quarterly. Halal home delivered meal clients assessments will be reviewed by a second staff member to ensure eligibility and verified by the Department Director and or Division Director monthly. Contact person responsible for corrective action: Joan Siavrakas, Division Director Anticipated Completion Date: 04/25/2025

View Audit 358351

Finding 564240 (2024-002)

Significant Deficiency 2024

Cardea Services

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Sexually Transmitted Diseases (STD) Prevention and Control Grants – Assistance Listing No. 93.977 Recommendation: CLA recommends Cardea update policies to ensure that Uniform Guidance requirements are met to perform and document suspension and debarment checks are being done. Explanation of disagree...

Sexually Transmitted Diseases (STD) Prevention and Control Grants – Assistance Listing No. 93.977 Recommendation: CLA recommends Cardea update policies to ensure that Uniform Guidance requirements are met to perform and document suspension and debarment checks are being done. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management updated its policies and procedures to include the required suspension and debarment check. Suspension and debarment checks are completed for all relevant vendors on a quarterly basis. In addition, a Vendor Approval process has been implemented to confirm no debarment or suspension exists prior to utilizing all new vendors. The reviews will be saved and approved by the CFO. Name(s) of the contact person(s) responsible for corrective action: Cathy Bogan Planned completion date for corrective action plan: June 2025

View Audit 358349

Finding 564239 (2024-002)

Significant Deficiency 2024

Housing Connector

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.306

Corrective action planned: Housing Connector will develop and implement a written policy to address company match contributions used to meet federal cost share requirements, in alignment with 2 CFR 200.306. The policy will provide general guidance on the allowability, tracking, and reporting of matc...

Corrective action planned: Housing Connector will develop and implement a written policy to address company match contributions used to meet federal cost share requirements, in alignment with 2 CFR 200.306. The policy will provide general guidance on the allowability, tracking, and reporting of match to ensure compliance with federal grant regulations. Relevant staff will be informed once the policy is finalized.

View Audit 358335

Finding 564238 (2024-001)

Significant Deficiency 2024

Housing Connector

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Corrective action planned: In alignment with 2 CFR 200.430, Housing Connector will develop and implement a formal time tracking policy and procedure to ensure that personnel expenses charged to federal grants are supported by records reflecting the actual time worked on each award.

View Audit 358335 Questioned Costs: $1

Finding 564236 (2024-003)

Significant Deficiency 2024

National Railroad Passenger Corporation

DC

Questioned Costs Allowable Costs / Cost Principles § 200.1 § 200.405

Finding 2024-003: Unsubstantiated Expense The single audit report included the following recommendation: We recommend that management strengthen the process to identify and review funding sources of underlying expenditures, that support the amounts of the reclassification journal entries. This co...

Finding 2024-003: Unsubstantiated Expense The single audit report included the following recommendation: We recommend that management strengthen the process to identify and review funding sources of underlying expenditures, that support the amounts of the reclassification journal entries. This could include reviewing approved budgets for the federal award in scope at a necessary level of detail to determine appropriateness of allocations in a timely manner. Management Response/Status of Action Plans: Amtrak believes education and reinforcing the existing upfront controls to ensure the correct initial coding of the expenditures is correct is the best way to address this issue. When this issue was identified during the audit, the company coordinated a meeting with the department where these costs originated to reinforce the need to properly code the expenditures in the purchase order process. Leadership in that department acknowledged the miscoding and committed to proper coding going forward. The company understands that the issue of training on this control to properly code purchase orders may exist in other departments and will develop communication to reinforce education in the proper processes and controls in this area. The contact for this item is Carol Hanna, VP Controller. Amtrak anticipates that changes described above will remediate this finding in the fiscal year ending September 30, 2025

View Audit 358334 Questioned Costs: $1

Finding 564234 (2024-002)

Significant Deficiency 2024

National Railroad Passenger Corporation

DC

Subrecipient Monitoring Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.302 § 200.303

Finding 2024-002: Review of Compliance Matrices and Narratives The single audit report included the following recommendation: We recommend that Amtrak establishes a more defined timeline for the events that would trigger the update and review of the compliance matrices and compliance narrative, w...

Finding 2024-002: Review of Compliance Matrices and Narratives The single audit report included the following recommendation: We recommend that Amtrak establishes a more defined timeline for the events that would trigger the update and review of the compliance matrices and compliance narrative, which could include execution of any new federal awards or amendments to existing federal awards. Additionally, Amtrak should establish a process where the modifications to the provisions are assessed for materiality/applicability and include documentation of the respective conclusions as part of the review process. Management Response/Status of Action Plans: Amtrak acknowledges the need to augment process documentation around the controls over the preparation and updates to the compliance matrices. The company is in the process of updating these controls now and will incorporate the identified findings in developing more robust controls. The company specifically notes the need to add more documentation on considerations for what provisions are updated in the compliance matrices and the evidence of review. The review procedures and controls are being enhanced to include a checklist to improve the review. This checklist will be completed by both the compliance matrix creator (upon creation) and the compliance matrix reviewer/approver (upon review and final approval). The contact for this item is Lucia Butts, AVP Funding and Grants and Meghan Histand, Director of Discretionary Grants. Amtrak anticipates fully remediating this finding by September 2025.

View Audit 358334

Finding 564233 (2024-001)

Significant Deficiency 2024

National Railroad Passenger Corporation

DC

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, includi...

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner Management Response/Status of Action Plans: Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The contact for this item is Lucia Butts, AVP Funding and Grants. Amtrak anticipates fully remediating this finding by September 2025.

View Audit 358334

Corrective Action Plans

Filters