Corrective Action Plans

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For ALN 93.958, the discount fee was not properly calculated and/or documented on the Financial Assessment Form for 3 of the 60 clients tested. Additionally, 4 of the 60 clients tested on the Block Grant for Mental Health had dates that did not fall within one year after the FAF completion. For ALN ...
For ALN 93.958, the discount fee was not properly calculated and/or documented on the Financial Assessment Form for 3 of the 60 clients tested. Additionally, 4 of the 60 clients tested on the Block Grant for Mental Health had dates that did not fall within one year after the FAF completion. For ALN 93.959, 1 of the 60 clients tested on the Block Grant for Prevention and Treatment of Substance Abuse did not have a completed FAF and 1 of the 60 tested had a missing client signature. For ALN 93.788, 1 of the 40 clients tested on Opioid STR Program did not have a completed FA. Our internal tracking of completion of the Financial Assessment Form at admission indicates that compliance with this requirement occurs about 90% of the time. We have identified that some of the missing FAs are a result of Telehealth appointments and clients not coming into the office. As a corrective action, the Client Service Specialist will be trained by their managers to ensure data is entered accurately and how to properly apply the FAs. SMA will also include the completion of the Financial Assessment Form both at admission and annually with data to be reviewed monthly by the managers. In addition, we will be working with IT to identify a way to collect the FAs from clients that utilize Telehealth services. Reporting will be sent out monthly and if out of compliance the managers will be required to be present at the quarterly Quality Assurance Committee meeting if not at 100%.
Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Staff have been retrained, and additional monitoring procedures have been implemented. The Food Service Director will oversee ongoing compliance. Official Responsi...
Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: Staff have been retrained, and additional monitoring procedures have been implemented. The Food Service Director will oversee ongoing compliance. Official Responsible for Ensuring CAP: Dan Anderson, Superintendent, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: June 30, 2026. Plan to Monitor Completion of CAP: The Board of Education will be monitoring this corrective action plan. Dan Anderson Superintendent
The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 16, 2022, to administer the federal grants to ensure that the Town would comply with allfederalprogram requirements. The Town was led to believe that th...
The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 16, 2022, to administer the federal grants to ensure that the Town would comply with allfederalprogram requirements. The Town was led to believe that they were in compliance with all federal program requirements. This is the second year of both federal grant programs, and the Town is just being made aware of the suspension and debarment requirement. It should be noted that all contractors and the consultant are not on the suspension and debarment lists.
All payments to contractors and vendors for the Water Sector Program are reviewed and approved by the outside consulting firm prior to payment. The outside consultant directs the Clerk as to the amount to pay and who to pay. The outside consultant acknowledged that they made the error in instructing...
All payments to contractors and vendors for the Water Sector Program are reviewed and approved by the outside consulting firm prior to payment. The outside consultant directs the Clerk as to the amount to pay and who to pay. The outside consultant acknowledged that they made the error in instructing the Town to make the payment. The State of Louisiana was contacted by the outside consultant to discuss the corrective action plan. The State advised the consultant to not make any corrections to the pay request that they would “bagout” the overpayment. Before the next pay request, the contractor returned the overpayment which was deposited into the Town’s Water Sector grant bank account.
The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that...
The Town recognized its lack of understanding of Uniform Guidance as it relates to federal grant programs and hired an outside consultant on August 1 6, 2022, to administer the federal grants to ensure that the Town would comply with all federal program requirements. The Town was led to believe that they were in compliance with all federal program requirements. The Town will develop, formally adopt, and implement written policies and procedures to comply with Uniform Guidance (2 CFR 200).
The District has revised and resubmitted the Final Expenditure Report for the Title I School Improvement (a) grant and will repay the unallowable costs to DESE. In addition the District will ensure that its procedures and the Uniform Guidance requirements are being followed regarding allowable trave...
The District has revised and resubmitted the Final Expenditure Report for the Title I School Improvement (a) grant and will repay the unallowable costs to DESE. In addition the District will ensure that its procedures and the Uniform Guidance requirements are being followed regarding allowable travel expenses.
The District will review the general ledger and compare to expenditure reports to ensure agreement before the reports are submitted.
The District will review the general ledger and compare to expenditure reports to ensure agreement before the reports are submitted.
The business manager will be the second person to review the application information and verify accuracy.
The business manager will be the second person to review the application information and verify accuracy.
The entity's finance department will work to ensure that the Board packets include a list of disbursements from each fund.
The entity's finance department will work to ensure that the Board packets include a list of disbursements from each fund.
The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concer...
The entity's Board continually evaluates the distribution of duties to employees and closely monitors all accounting functions. The School District has implemented controls within its accounting functions to mitigate the lack of segregation of duties but recognizes that this should still be a concern for the School District and the Board.
FINDING 2025-001: PROCUREMENT (50000) Federal Agency: U.S. Department of Education Passthrough Entity: California Department of Education Program Names: Individuals with Disabilities Education Act (IDEA) (AL No. 84.027, 84.173) Response to finding: During the 2025-26 fiscal year, the District implem...
FINDING 2025-001: PROCUREMENT (50000) Federal Agency: U.S. Department of Education Passthrough Entity: California Department of Education Program Names: Individuals with Disabilities Education Act (IDEA) (AL No. 84.027, 84.173) Response to finding: During the 2025-26 fiscal year, the District implemented changes to reclassify certain contracts from federal funding sources to state funding. The District utilized the SELPA Master Contract for applicable vendors to ensure proper contracting and compliance. Federal funds will continue to be used to support Instructional Aides (IAs). These actions were taken to improve alignment with funding requirements and strengthen fiscal compliance. The Assistant Superintendent of Educational Services is responsible for monitoring and implementing federal procurement procedures to ensure compliance. This procedure was implemented beginning the 2025–26 School Year.
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a corrective action involving updates to the CIF Procurement Policies & Procedures. This polic...
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a corrective action involving updates to the CIF Procurement Policies & Procedures. This policy, which includes a Conflict of Interest section, was updated to reflect a decrease of the micro-purchase threshold from $50,000 to $10,000, clarifies that the SAM.gov check for suspension and debarment will occur prior to contract execution with the contractor, and the SAM.gov check will be documented with the date it was conducted. The updated CIF Procurement Policies & Procedures will be approved by the Board of Directors.
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented multiple corrective actions to address this finding: 1. CIF created a new template for Subawar...
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented multiple corrective actions to address this finding: 1. CIF created a new template for Subaward Agreements that includes all elements required under 2 CFR 200.332(b). This template will be used for any future Subaward Agreements into which CIF enters. 2. CIF created an Amendment template for each active Federal award Subaward/Subrecipient Agreement that includes all elements required under 2 CFR 200.332(b), a requirement to submit period financial reports to CIF, and a section on compliance with audit requirements according to 2 CFR 200.332(g) / 2 CFR 200.501. 3. For each Subrecipient of CIF’s grant NR233A750004G045 under ALN #10.937, formerly known as the Partnerships for Climate Smart Commodities grant but now known as the Advancing Markets for Producers (AMP) program, CIF will use that template to execute an Amendment to the Subaward/Subrecipient Agreement following the execution of the Amendment to the Grant Agreement between CIF and the United States Department of Agriculture (USDA). 4. CIF implemented a schedule for reviewing current subrecipients’ FY 25 Audit Reports after they are published in the Federal Audit Clearinghouse in mid-2026, document the impact of any audit findings on the federally funded program, and implement a corrective action plan. 5. CIF made revisions in the FY 26 update to the CIF Subaward Management & Subrecipient Monitoring Policy and Procedures which will apply to any new subawards. The pre-award risk assessment procedures now include dating and ensure that results are documented prior to subaward execution. The monitoring procedures are now explicitly linked to risk assessment results, with greater oversight required for subrecipients without experience managing Federal funds.
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements w...
CIF grew substantially in FY 24 following execution of the Federal award. This finding reflects the learning phase as CIF came into compliance with the Uniform Guidance. Beginning in FY 26, CIF implemented a system for documenting time and effort in a manner that complies with Federal requirements which involves timesheets that record actual time spent on a funding source and are accompanied by supervisory approvals. This system has been formally documented in the FY 26 update to the CIF Financial Policy and includes annual training for staff responsible for managing payroll allocations and Federal reporting. Charges to Federal awards for salaries and wages are now based on records that accurately reflect the work performed. The records are supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. The records support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.
FINDING: FINANCIAL REPORTING – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Finding Type: Material Weakness in Compliance and Internal Control over Compliance Finding No. 2025-002 Recommendation: Management should implement procedures to ensure an accurate schedule of expenditures of federal awards wi...
FINDING: FINANCIAL REPORTING – SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS Finding Type: Material Weakness in Compliance and Internal Control over Compliance Finding No. 2025-002 Recommendation: Management should implement procedures to ensure an accurate schedule of expenditures of federal awards with a corresponding reconciliation to the accrual basis trial balance. It is recommended that management establish and enforce review and approval procedures related to the schedule of expenditures of federal awards and the accrual basis trial balance. Responsible Official: Anthony D’Agostino, CEO Corrective Action Plan: The Organization acknowledges the importance regarding the accuracy of the schedule of expenditures of federal awards and corresponding reconciliation to the accrual basis trial balance. The Organization is taking steps to ensure the accuracy and completeness of the schedule of expenditures of federal awards. The Organization will also consider the employment of additional personnel with suitable knowledge, skills, and experience to contribute to the functions of the finance department. Planned completion date for corrective action plan: Fiscal year 2026
Significant Deficiency Item 2025-007 - Cash Management - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we...
Significant Deficiency Item 2025-007 - Cash Management - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that there is no evidence of review and approval of drawdowns from the Health Center Program Cluster and the supporting records. Recommendation: We recommend that LBUCC implement a policy that requires all drawdowns and supporting documents to be reviewed and that such review and approval be documented. Action Taken: LBUCC revised the drawdown policy which now includes a review and approval from the CFO and the process is documented. Effectivity Date: Implemented 12/3/2025.
Significant Deficiency Item 2025-006 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 During ...
Significant Deficiency Item 2025-006 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that LBUCC conducted quarterly internal audit reviews of fifty (50) samples self-pay patients to review for sliding fee discount determination. However, we noted that the findings or exceptions identified in the quarterly internal audit review remained uncorrected. Recommendation: We recommend that LBUCC establish a process for communicating, investigating and correcting all internal audit findings or exceptions on a timely manner. Additionally, we recommend that management identify the potential cause of such findings or exceptions and that necessary corrective actions be taken to address such cause. For example, LBUCC may conduct periodic training of all employees involved in the patient intake and screening process. Action Taken: The internal audit process has been redesigned and expanded to include weekly reviews and all exceptions/errors will be corrected and the cause determined. Additional training will be provided with the expectation that the exceptions/errors will reduce going forward. Effectivity Date: This will be fully implemented by 1/31/2026
Material Weakness Item 2025-005 -Activities Allowed and Una/lowed Costs - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 Dur...
Material Weakness Item 2025-005 -Activities Allowed and Una/lowed Costs - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 During our audit, we noted that LBUCC charged salaries to the Section 330 grant based on pre-determined allocations or budget rather than actual hours worked. LBUCC utilized timesheets that reflect the allocations as its time and effort documentation. Recommendation: We recommend that LBUCC implement a time and effort reporting system that tracks actual hours worked on each program or grant. We recommend that they require supervisors to review and approve the actual time spent on grant activities and that such review and approval be documented. Action Taken: LBUCC will implement a time and effort reporting system to include a semi-annual certification for all employees funded by the HRSA 330 grant and a time card reporting system for those funded by multiple grants. Effectivity Date: Time and effort reporting will be implemented in January 2026 and fully in place by 1/31/2026
Significant Deficiency Item 2025-004 - Reporting - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 LBUCC did not maintain doc...
Significant Deficiency Item 2025-004 - Reporting - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 HBLCS50772-01-00 and 6 HBHCS46163-03-01 LBUCC did not maintain documentation evidencing management's review of the Federal Financial Report (SF-425) prior to submission. Although the reports were submitted timely, there were no indication of formal review procedures to validate the accuracy, completeness, or consistency of reported financial data with the accounting records. Recommendation: We recommend that LBUCC establish and implement a formal review process over the Federal Financial Report (SF-425); we also recommend that evidence of the review be documented and approval be kept on file. Action Taken: Process in place where Director of Accounting will prepare the Federal Financial Report (SF-425) and the Chief Financial Officer will review and document approval which will be kept on file. Effectivity Date: Process was implemented 12/1/2025
Material Weakness Item 2025-003 - Period of Performance - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8/-ICS46163-03-01 During our audit,...
Material Weakness Item 2025-003 - Period of Performance - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8/-ICS46163-03-01 During our audit, we noted that LBUCC drew down $190,688 of federal grant funds under the Section 330 program for the budget period beginning June 1, 2024 to reimburse salary expenses incurred in May 2024. Recommendation: We recommend that LBUCC implement procedures to ensure that all drawdowns are supported by expenses incurred strictly within the grant's approved period of performance and train staff on grant compliance requirements. Action Taken: A change in the process to draw down funds has been implemented to determine that the funds were incurred in the proper funding period rather than the period it was paid. Effectivity Date: Process change was implemented 12/1/2025.
Material Weakness Item 2025-002 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 During our a...
Material Weakness Item 2025-002 - Special Tests and Provisions - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 During our audit, we noted that LBUCC did not properly determine the sliding fee discount provided to certain eligible patients based on information provided during the patient registration process. Additionally, we could not ascertain if the sliding fee discount provided to certain eligible patients were correct as LBUCC did not maintain documentation of the proof of income of those eligible patients. Recommendation: We recommend that LBUCC conduct training of all of its personnel who are involved in determining and applying the sliding fee scale of patients. We also recommend LBUCC to maintain complete and auditable documentation supporting each patient's eligibility for sliding fee discount. Action Taken: Eligibility was provided additional training which included training on a tool to assist them in determining the proper sliding fee discount. Effectivity Date: Training was held on October 28, 2025, and the tool to assist them was reviewed and provided at that time and implemented immediately thereafter.
Material Weakness Item 2025-001 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 Dur...
Material Weakness Item 2025-001 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 HB0CS00505-23-04, 6 H2ECS45602-02-04, 1 H8LCS50772-01-00 and 6 H8HCS46163-03-01 During our audit, we noted that there is no evidence that any exclusion search was conducted in 2025 for all sample employees tested. Recommendation: We recommend that LBUCC develop and implement a formal exclusion search policy for employees whose salaries are charged to HHS grants to ensure compliance with federal and state regulations. The policy should include documentation procedures and procedures for investigating and resolving any exceptions found during the search. Action Taken: LBU has subscribed to the software platform Verify Comply which will allow us to upload a list of all employees and vendors in bulk for exclusion monitoring in OIG, SAM and other federal and state exclusion lists. Ongoing monitoring will occur to include all new hires and new vendors. A report will be available to support and validate monitoring. Effectivity Date: Software implementation and training is scheduled for 1/7/2026 with the expectation that all vendors and employees will be monitored by 1/30/2026.
Name of auditee: Riverside Episcopal Housing Development Fund Company, Inc. TIN: 014-EH261 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: June 30, 2025 CAP prepared by: James Juliano CFO/Vice President Episcopal Community Housing, Inc. (716) 929-5817 Current Findings on the Sche...
Name of auditee: Riverside Episcopal Housing Development Fund Company, Inc. TIN: 014-EH261 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: June 30, 2025 CAP prepared by: James Juliano CFO/Vice President Episcopal Community Housing, Inc. (716) 929-5817 Current Findings on the Schedule of Findings and Questioned Costs and Recommendations 1) Finding 2025-001 (a) Comments on the finding and recommendation: Management agrees with the finding. Management also agrees with the recommendation, please see below for action taken. (b) Action taken: Management informed us that the amount will be deposited as soon as cash flow and operational circumstances permit.
Name of auditee: Bishop (CSI) Non-Profit Housing Corporation HUD auditee identification number: 044-11134 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Anne Sackrison Position: Chief Executive Officer Telephone number: 5...
Name of auditee: Bishop (CSI) Non-Profit Housing Corporation HUD auditee identification number: 044-11134 Name of audit firm: Dauby O'Connor & Zaleski, LLC Period covered by the audit: Year ended June 30, 2025 CAP prepared by Name: Anne Sackrison Position: Chief Executive Officer Telephone number: 586-753-9052 Current Findings on the Schedule of Findings, Questioned Costs, and Recommendations Finding #2025-001: Effective May 1, 2025, the required monthly deposit to the reserve for replacements increased from $12,539 to $63,106 based on the capital needs assessment and replacement reserve analysis. The Corporation did not increase the monthly deposits and as of June 30, 2025, the reserve for replacements account is underfunded by $99,135. Comments on the Finding and Each Recommendation: Management should transfer $99,135 from the operating account in order to bring the reserve for replacements account current. Action(s) taken or planned on the finding: Agreed. On July 1, 2025, management transferred $99,135 to the reserve for replacements account.
Finding #2025-002 – Significant Deficiency and Other Noncompliance – Reporting. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.959, Passed through Texas Health and Human Services Commission, All contracts, Contract years: 09/01/23 – 08/31/24 and 09/...
Finding #2025-002 – Significant Deficiency and Other Noncompliance – Reporting. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.959, Passed through Texas Health and Human Services Commission, All contracts, Contract years: 09/01/23 – 08/31/24 and 09/01/24 – 08/31/25. Condition and context: In our testing of a sample of monthly billings and quarterly reports from throughout the fiscal year, we noted that reports were not being submitted within the required timelines for several reporting periods. Management communicated their delays to Texas Health and Human Services Commission (THHS), and their plan to rectify the delays. Phoenix Houses of Texas were able to file all delayed quarterly reports and monthly billings prior to June 30, 2025. THHS has approved all the delayed monthly billings and quarterly reports. Recommendation: Re-emphasize internal controls over timely grant billing and reporting to comply with grant contracts. Planned corrective action: All outstanding billings were subsequently submitted and billings are now current and submitted in accordance with required timelines. Corrective actions implemented include updates to Finance Department policies and procedures to formalize month-end closing and billing timelines and to strengthen oversight and monitoring controls. These changes ensure that billing and reporting are performed on a timely and ongoing basis. Responsible officer: Drew Dutton, CEO and Anunoy Mou, Finance Director. Estimated completion date: Completed September 2025.
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