Corrective Action Plans

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Corrective Action Plan Finding No. 2025-003 Condition – The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Departmen...
Corrective Action Plan Finding No. 2025-003 Condition – The auditee did not obtain the required certified payroll reports from contractors in accordance with the Davis‑Bacon Act and related labor standards, nor did the contractors or subcontractors submit the certified payrolls to the U.S. Department of Labor as required. Plan – The District’s Director of Maintenance, Operations & Risk Management will ensure certified payrolls are submitted with invoices and a copy of the submissions to the US Department of Labor are attached to final pay invoice. Anticipated Date of Completion: 03.06.26 Name of Contact Person: Delfaye Jason, Chief School Business Official
HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1....
HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1. StaffingA new rental housing inspector has been hired. The position has been converted from part-time to full-time, allowingadequate time for the inspector to monitor inspection timelines, complete required inspections and reinspections, andensure timely reporting and compliance with program requirements. 2. Training and CertificationStaff completed training on new inspection guidelines and protocols in March 2024. Certification in both HQS andNSPIRE inspection standards are currently underway for the new inspector. This training will ensure the inspector isfully knowledgeable of federal inspection requirements, documentation standards, and required compliancetimelines. 3. Improved Inspection Monitoring and DocumentationThe EDA has strengthen internal procedures for scheduling and tracking inspections and reinspections within theinspection software to ensure all failed inspections are documented and scheduled for reinspection within therequired timeframe. 4. Transition to Electronic Inspection ReportingThe EDA requires the use of iPad-based electronic inspections rather than paper inspection forms. This changeprovides real-time documentation, ensure inspections are entered directly into the tracking system, and reduce therisk of inspections being completed but not logged. 5.Compliance Notification and Payment ControlsA formal procedure has been established to notify appropriate staff in the event of inspection non-compliance. Underthis procedure, Housing Assistance Payments (HAP) will be held until compliance is achieved or the tenant has movedfrom the unit, consistent with program regulations. Management believes these corrective actions will strengthen internal controls over the inspection process, improve documentation and tracking, and ensure compliance with HUD Housing Quality Standards requirements moving forward. The EDA will continue to monitor inspection activities to maintain safe and habitable housing conditions for program participants. Official Responsible for Ensuring CAP: Nicole Cunningham, Housing Coordinator, is the official responsible for ensuring corrective action.
2025-001 HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective ac...
2025-001 HQS Enforcement CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: To address the issues identified and prevent recurrence, the EDA has implemented the following corrective actions: 1. Staffing A new rental housing inspector has been hired. The position has been converted from part-time to full-time, allowing adequate time for the inspector to monitor inspection timelines, complete required inspections and reinspections, and ensure timely reporting and compliance with program requirements. 2. Training and Certification Staff completed training on new inspection guidelines and protocols in March 2024. Certification in both HQS and NSPIRE inspection standards are currently underway for the new inspector. This training will ensure the inspector is fully knowledgeable of federal inspection requirements, documentation standards, and required compliance timelines. 3. Improved Inspection Monitoring and Documentation The EDA has strengthened internal procedures for scheduling and tracking inspections and reinspections within the inspection software to ensure all failed inspections are documented and scheduled for reinspection within the required timeframe. 4. Transition to Electronic Inspection Reporting The EDA requires the use of iPad-based electronic inspections rather than paper inspection forms. This change provides real-time documentation, ensures inspections are entered directly into the tracking system, and reduce the risk of inspections being completed but not logged. 5. Compliance Notification and Payment Controls A formal procedure has been established to notify appropriate staff in the event of inspection non-compliance. Under this procedure, Housing Assistance Payments (HAP) will be held until compliance is achieved or the tenant has moved from the unit, consistent with program regulations. Management believes these corrective actions will strengthen internal controls over the inspection process, improve documentation and tracking, and ensure compliance with HUD Housing Quality Standards requirements moving forward. The EDA will continue to monitor inspection activities to maintain safe and habitable housing conditions for program participants. Official Responsible for Ensuring CAP: Nicole Cunningham, Housing Coordinator, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding. Nicole Cunningham Housing Coordinator
Views of Responsible Officials: Management concurs with the finding. During FY2025, the organization experienced significant disruption related to Federal stop-work orders and associated cost-reduction measures, including staff terminations and the discontinuation of certain legacy systems during th...
Views of Responsible Officials: Management concurs with the finding. During FY2025, the organization experienced significant disruption related to Federal stop-work orders and associated cost-reduction measures, including staff terminations and the discontinuation of certain legacy systems during the transition and integration of operations with Global Communities. As a result, for some employees in the audit sample—particularly those who separated from the organization prior to the FY2025 attestation cycle—management was unable to retrieve employee-signed conflict of interest attestations for the immediately preceding period because the systems and files used to capture and retain those acknowledgments were no longer accessible, and responsible personnel were no longer employed. Management notes that, for a portion of the employee population, the FY2025 ethics training included a conflicts of interest section requiring employee acknowledgment; however, system limitations affected the ability to produce individual, employee-named attestations for all sampled employees in a format suitable for audit evidence. Planned Corrective Actions: Following the operational integration with Global Communities, management is strengthening controls over conflict of interest compliance by: (1) requiring conflict of interest acknowledgment at onboarding and on a periodic basis thereafter through a standardized process; (2) maintaining a centralized tracking mechanism to monitor completion status; (3) retaining documentation in a centralized repository/personnel record to ensure retrievability; and (4) performing periodic monitoring to confirm completion and retention across headquarters and field locations. These actions are intended to improve documentation, transparency, and ongoing compliance with conflict of interest requirements and standards of conduct.
Views of Responsible Officials: Management concurs with the finding. During FY2025, in response to Federal stopwork orders and related cost reduction measures, IntraHealth experienced significant disruption, including staff terminations and the planned integration of operations with Global Communiti...
Views of Responsible Officials: Management concurs with the finding. During FY2025, in response to Federal stopwork orders and related cost reduction measures, IntraHealth experienced significant disruption, including staff terminations and the planned integration of operations with Global Communities. As part of this transition, the legacy timekeeping system was retired at the end of its renewal period, with the intent to move to Global Communities’ timekeeping process shortly thereafter. During the interim period, time for the remaining staff was captured using manual timesheets. In two instances, documented supervisory approval could not be located because the employees’ supervisor separated from IntraHealth during the transition period. Planned Corrective Actions: Effective April 1, 2025, all IntraHealth staff transitioned to Global Communities following the completion of operational integration, IntraHealth has transitioned to Global Communities’ timekeeping and payroll process using ADP, which includes electronic time entry, supervisor review/approval workflow, and centralized record retention. Management believes this materially strengthens controls by reducing reliance on manual documentation, and improving the retention and retrievability of approvals. Management will also reinforce the requirement that time records are approved prior to payroll processing and will perform periodic monitoring to confirm compliance with the approval control.
Management’s response and corrective action plan (unaudited): Property Manager has reviewed the Course Presentation Handbook on Enterprise Income Verification Specialist (EIVS) and will ensure EIV Income reports are run on time. In addition, management at Casitas of Hayward, Inc. ("Casitas") will im...
Management’s response and corrective action plan (unaudited): Property Manager has reviewed the Course Presentation Handbook on Enterprise Income Verification Specialist (EIVS) and will ensure EIV Income reports are run on time. In addition, management at Casitas of Hayward, Inc. ("Casitas") will implement a review process to ensure that all required EIV reports are run timely and maintained in the tenant lease file as required by HUD Handbook 4350.3, Chapter 9, Section 1, 9-58.
Finding Number: 2025-003 Management concurs with the finding. However, the finding relates to Subrecipient monitoring for contract ended in February 2025 and was not renewed. The Organization has no other subrecipients expenses.
Finding Number: 2025-003 Management concurs with the finding. However, the finding relates to Subrecipient monitoring for contract ended in February 2025 and was not renewed. The Organization has no other subrecipients expenses.
Finding Number: 2025-002 Management concurs with the finding. However, the cut-off finding relates to Subrecipient expenses for contract ended in February 2025 and was not renewed. The Organization has no other subrecipients expenses.
Finding Number: 2025-002 Management concurs with the finding. However, the cut-off finding relates to Subrecipient expenses for contract ended in February 2025 and was not renewed. The Organization has no other subrecipients expenses.
Corrective Actions Implemented: 1. Monthly Reconciliation Process: A reconciliation procedure has been implemented requiring cafeteria site managers to compare meal production records, point-of-sale (POS) reports, and student attendance records (including Saturday School attendance, when applicable)...
Corrective Actions Implemented: 1. Monthly Reconciliation Process: A reconciliation procedure has been implemented requiring cafeteria site managers to compare meal production records, point-of-sale (POS) reports, and student attendance records (including Saturday School attendance, when applicable) prior to submission of CNIPS claims. Any discrepancies are investigated and corrected. 2. Verification of Meal Counts: Site managers are now required to review production records and POS data to ensure that only meals actually served to eligible students are included in reimbursement claims. 3. Staff Training: Training has been provided to cafeteria staff and site managers on proper meal counting and claiming procedures to ensure compliance with federal requirements. 4. Supervisory Review: All monthly CNIPS claims are now subject to review and approval by the Child Nutrition Director prior to submission to ensure accuracy and completeness. 5. Ongoing Monitoring: The Director will conduct periodic internal reviews of meal counting and claiming procedures to ensure continued compliance and prevent recurrence of this issue. The District believes these corrective actions address the cause of the finding and will ensure accurate reporting of meals served going forward.
Finding 2025-003 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The Project made twelve monthly deposits into the replacement reserve account; however, the dep...
Finding 2025-003 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The Project made twelve monthly deposits into the replacement reserve account; however, the deposits were not at the amount identified and required by HUD. Corrective Action Plan: Management is working with our mortgagor to appropriately fund the replacement reserve account for the underfunding and will deposit into the replacement reserve account $4,962. Responsible Individuals: Mary Morgan, Executive Director Anticipated Completion Date: April 2026
Finding 2025-002 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The testing of property, operations, and distributions detected one instance of underpayment of...
Finding 2025-002 Federal Agency Name: U.S. Department of Housing and Urban Development Federal Financial Assistance Listing Number: #14.134 Program Name: Mortgage Insurance Rental Housing Finding Summary: The testing of property, operations, and distributions detected one instance of underpayment of an expense based upon review of supporting invoices and the allocation of the expense. Corrective Action Plan: The invoice approval form will include a note stating that, before completing a disbursement of funds, the request must include supporting documents including allocation calculations and approvals. Accounts Payable staff retraining on allocation calculations has been completed, and the calculation formulas have been updated. Responsible Individuals: Mary Morgan, Executive Director Anticipated Completion Date: April 2026
II. Findings and Questioned Costs Related to Federal and State Awards Finding Number: 2025‐001 Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program Contact Person: Ted Ross, Executive Director Updated Corre...
II. Findings and Questioned Costs Related to Federal and State Awards Finding Number: 2025‐001 Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District has revised its procurement procedures to meet Uniform Guidance requirements. Enhancements include: - Mandatory documentation of quotes for applicable procurements - Centralization of procurement records in accordance with best practices Policy training and practices are already in place and are being followed. Certification The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.
Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency keep track of which subrecipients need to be monitored during each year and ensure all monitoring is completed. Explanation of disagreement with audit finding: There is no disagreement with...
Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency keep track of which subrecipients need to be monitored during each year and ensure all monitoring is completed. Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Agency will review its subrecipient tracking to ensure all monitoring is completed. Name of the contact person responsible for corrective action: Tony Vermazen, Fiscal Manager Planned completion date for corrective action plan: Fiscal Year 2026
Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency implement an internal control to have a documented review of the reports by a person independent of the preparer of the report Explanation of disagreement with audit finding: There is no di...
Aging Cluster – Assistance Listing Numbers: 93.044, 93.045, and 93.053 Recommendation: We recommend the Agency implement an internal control to have a documented review of the reports by a person independent of the preparer of the report Explanation of disagreement with audit finding: There is no disagreement with the finding. Action taken in response to finding: The Agency will review its processes to ensure an internal control is implemented. Name of the contact person responsible for corrective action: Tony Vermazen, Fiscal Manager Planned completion date for corrective action plan: Fiscal Year 2026
The School will prepare and submit a plan to the state agency to address excess net cash resources in the nonprofit food service account. Management will implement procedures to monitor net cash resources on a periodic basis, including timely preparation and review of the food service program’s stat...
The School will prepare and submit a plan to the state agency to address excess net cash resources in the nonprofit food service account. Management will implement procedures to monitor net cash resources on a periodic basis, including timely preparation and review of the food service program’s statement of financial performance, to ensure compliance with program requirements and timely completion of any required follow-up actions.
The district purchased a welding lab exhaust system through the ESSER program as part of the welding shop renovation project. While the primary contract for the project included the required Davis-Bacon provisions, a separate purchase was made for the exhaust system that was believed to be equipment...
The district purchased a welding lab exhaust system through the ESSER program as part of the welding shop renovation project. While the primary contract for the project included the required Davis-Bacon provisions, a separate purchase was made for the exhaust system that was believed to be equipment only. However, the vendor agreement included labor, and the existing contract did not cover this portion of the work. As a result, the required Davis-Bacon language was not included, and certified payroll documentation was not obtained. The district does not typically pay for construction projects involving labor with federal funds. To address this moving forward, the district is implementing additional review procedures to ensure all federally funded purchases are evaluated for potential labor components prior to approval. Any purchase involving labor will include the required federal provisions and documentation. The district will also strengthen internal communication during project planning to ensure all components are properly identified and compliant.
The institution reviewed the identified R2T4 calculations and, where necessary, corrected the amounts returned to ensure compliance with federal regulations. The College implemented several procedural and staffing changes to strengthen internal controls and improve segregation of duties related to t...
The institution reviewed the identified R2T4 calculations and, where necessary, corrected the amounts returned to ensure compliance with federal regulations. The College implemented several procedural and staffing changes to strengthen internal controls and improve segregation of duties related to the Return of Title IV Funds process. These improvements include: • Establishing a formal secondary review of all R2T4 calculations and fund return transactions prior to processing. A second qualified Finance staff member will review and verify: • The withdrawal date • The calculation methodology • The percentage of the payment period completed • The final amount of Title IV funds returned • Separating responsibilities for calculation, review, and posting of Title IV fund returns to ensure appropriate segregation of duties. • Implementing documented procedures and checklists to verify that the correct type and amount of Title IV funds are returned in accordance with federal requirements. • Providing additional staff training related to R2T4 processing and compliance requirements. Management believes that these corrective actions significantly strengthen internal controls and reduce the likelihood of similar errors occurring in the future. The College will continue to monitor compliance with these procedures and perform periodic supervisory reviews to ensure that controls remain effective.
Management should transfer excess funds from the operating account to the reserve for replacements account and continue to work toward bringing the delinquent accounts current. Management should implement automated reminders and tracking measures to address the delay and ensure timely completion of ...
Management should transfer excess funds from the operating account to the reserve for replacements account and continue to work toward bringing the delinquent accounts current. Management should implement automated reminders and tracking measures to address the delay and ensure timely completion of all future recertifications.
ECA agrees with this finding and has created calendar reminders for all federal contracts to comply with all financial and programmatic requirements. ECA also hired a Director of Development in March 2026, who will also be partially responsible for maintaining contract compliance.
ECA agrees with this finding and has created calendar reminders for all federal contracts to comply with all financial and programmatic requirements. ECA also hired a Director of Development in March 2026, who will also be partially responsible for maintaining contract compliance.
ECA Agrees with this finding and has created a new policy specifically outlining the requirements for onboarding new contractors and checking existing contractors to confirm that they are not federally debarred. ECA will review its existing contracts to confirm that no current contractors are debarr...
ECA Agrees with this finding and has created a new policy specifically outlining the requirements for onboarding new contractors and checking existing contractors to confirm that they are not federally debarred. ECA will review its existing contracts to confirm that no current contractors are debarred and will take further action if necessary.
Management will review and amend waiting list procedures to ensure continued compliance with Section 202 requirments and that all waiting list additions, removals, or status changes are documented.
Management will review and amend waiting list procedures to ensure continued compliance with Section 202 requirments and that all waiting list additions, removals, or status changes are documented.
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, MT-ARPA-CG-23-613, RRG-22-1864A, RRG-22-1864A, YEAR ENDED JUNE 30, 2025 Name of contact person: City Manager Corrective Actio...
NONCOMPLIANCE WITH PROCUREMENT AND SUSPENSION AND DEBARMENT REQUIREMENTS, CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS, ASSISTANCE LISTING No. 21.027, Direct Allocation, MT-ARPA-CG-23-613, RRG-22-1864A, RRG-22-1864A, YEAR ENDED JUNE 30, 2025 Name of contact person: City Manager Corrective Action: The City ensures that debarment requirements for prime contractors and subcontractors are met prior to the use of federal funds. Moving forward, the City will expand compliance efforts to include all required parties. Staff will be educated on these requirements, and the City will work with engineers to ensure debarment language is included in project bidding documents and supplementary conditions. Proposed Completion Date: Immediately
The District plans to design and implement a formal month-end reconciliation and claim certification process that includes: matching food service vendor meal counts to internal District records, dual review and approval, timely corrections, training and cross-training, and monitoring.
The District plans to design and implement a formal month-end reconciliation and claim certification process that includes: matching food service vendor meal counts to internal District records, dual review and approval, timely corrections, training and cross-training, and monitoring.
Management agrees with the finding. The replacement reserve deficeincy will be funded. Management will ensure that the replacement reserve deposits are made on a timely basis in the future.
Management agrees with the finding. The replacement reserve deficeincy will be funded. Management will ensure that the replacement reserve deposits are made on a timely basis in the future.
MANAGEMENT AGREES WITH THE FINDING. THE REPLACEMENT RESERVE DEFICIENCY WILL BE FUNDED ON A TIMELY BASIS IN THE AMOUNT OF $3,033. MANAGEMENT WILL ENSURE THAT THE REPLACEMENT RESERVE DEPOSITS ARE MADE ON A TIMELY BASIS IN THE FUTURE.
MANAGEMENT AGREES WITH THE FINDING. THE REPLACEMENT RESERVE DEFICIENCY WILL BE FUNDED ON A TIMELY BASIS IN THE AMOUNT OF $3,033. MANAGEMENT WILL ENSURE THAT THE REPLACEMENT RESERVE DEPOSITS ARE MADE ON A TIMELY BASIS IN THE FUTURE.
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