Corrective Action Plans

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Inadequate Segregation of Duties Actions Planned - The school district has implemented a process for federal programs by distributing duties, and adding additional oversight. Program managers are assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers ...
Inadequate Segregation of Duties Actions Planned - The school district has implemented a process for federal programs by distributing duties, and adding additional oversight. Program managers are assigned to monitor and give oversight approval for federal fund expenses and budgets. Program managers sign off on all receipts and disbursements. Monthly reports given to program managers to assist in the oversight. The Special Education Director acts as a program manager for special ed funds, a Principal acts as a program manager for Title funds, and the Superintendent acts as program manager for all other federal funds. Request for reimbursement and receipting is completed by the Administrative Assistant with oversight by the Business Manager and Superintendent. The key action to eliminate inadequate segregation of duties is developing strong controls over the review and approval of adjusting journal entires. This involves detailed review by the program manager and the Superintendent. Adjusting journal entries are discussed and signed off on each month to timely detect misstatements. Official Responsible - Business Manager and Superintendent of Schools Planned Completion Date - December 31, 2025 Disagreement with Finding - None - ISD #701 - Hibbing concurs with the finding. Plan to monitor - The District is aware of the situation and will monitor, as it deems appropriate. Monitoring will include educating program managers to provide additional oversight fo the interim and year end reportin. This finding will like be ongoing due to limited resources.
Inadequate documentation over time and effort Actions Planned - The District has met with the administrative team and expressed the necessity to follow all documentation requirements. Administrative duties changed during the fiscal year and the position overseeing the federal program was unaware of ...
Inadequate documentation over time and effort Actions Planned - The District has met with the administrative team and expressed the necessity to follow all documentation requirements. Administrative duties changed during the fiscal year and the position overseeing the federal program was unaware of the requirement to document the time spent between state and federal activity. Official Responsible - Business Manager and Superintendent of Schools Planned Completion Date - December 31st, 2025 Disagreement with Finding - None - ISD #701-Hibbing concurs with the findng. Plan to Monitor - Further training and updates will be shared with the adminsitrative team as well as paryoll personel to ensure approriate documentaiton is provided.
Corrective Action Plan 1. Implement Automated Notifications (New and Long-Term Solutions) The institution will establish a two-phase approach to ensure timely and compliant Title IV disbursement notifications. New Process: A weekly report will be generated for Title IV loan disbursements with the co...
Corrective Action Plan 1. Implement Automated Notifications (New and Long-Term Solutions) The institution will establish a two-phase approach to ensure timely and compliant Title IV disbursement notifications. New Process: A weekly report will be generated for Title IV loan disbursements with the corresponding notifications sent to students. Financial aid staff will review the report to confirm that each required notification was issued within the regulatory timeframe. Any missing notifications will be immediately sent and documented. This interim process will remain in effect until full automation is implemented. Long-Term Automated Solution: The student information system will be configured to automatically generate and send Title IV disbursement notifications to students. Each notification will be sent no earlier than 30 days before, and no later than 30 days after, the crediting of Title IV loan funds to the student’s ledger account, as required by 34 CFR §668.165(a)(2). The system will also store a timestamped record of each notification in the student’s electronic file for audit and compliance verification. 2. Develop Written Procedures A formal institutional policy and procedural guide will be developed to define the timing, content, and method of Title IV disbursement notifications. This documentation will explicitly address regulatory requirements under 34 CFR §668.165(a) and outline staff responsibilities for monitoring and documentation. 3. Staff Training Financial Aid staff will receive training on the new automated notification process, including policy updates, system functionality, and documentation requirements. Completion of training will be tracked to ensure all relevant personnel are fully informed and able to implement the new procedures consistently. 4. Periodic Compliance Reviews Quarterly internal audits will be conducted to confirm that required notifications are being issued as scheduled and properly documented in each student’s record. Any discrepancies identified will result in immediate corrective measures and additional staff coaching as needed. Responsible Party Director of Financial Aid Timeline for Completion - New System Implementation: Immediate - Long-Term Solution: Work with software provider and IT for options to implement this process - Policy Documentation & Staff Training: Within 90 days - First Compliance Review: Within 90 days
Significant Deficiency Finding: 2025-001 Certification of Tenants Criteria and Condition The grant agreement requires ECS to (1) maintain complete tenant files in the San Francisco HMIS ONE System with hard-copy eligibility documents; (2) apply changes to tenant rent portions based on City and Count...
Significant Deficiency Finding: 2025-001 Certification of Tenants Criteria and Condition The grant agreement requires ECS to (1) maintain complete tenant files in the San Francisco HMIS ONE System with hard-copy eligibility documents; (2) apply changes to tenant rent portions based on City and County of San Francisco Department of Homelessness and Supporting Housing (HSH) notifications; and (3) perform required initial, annual, and interim recertifications under the Housing First program model. We noted instances where tenant files did not contain complete eligibility documentation and/or where required recertifications or updates to tenant rent portions were not performed or documented in accordance with the grant requirements. Context ECS provides rental assistance under the program described in Appendix A-2, which requires full documentation of tenant eligibility and strict adherence to rent-portion updates and recertification timelines. Of our 31 selections, we noted 6 instances where homelessness verification was missing, 6 instances where the rent portions based on HSH notifications were incorrect and 10 instances where the recertifications were not completed for the grant period under audit. Questioned Cost There are no questioned costs regarding this finding. Cause The exceptions result from inconsistent file maintenance and monitoring procedures, including insufficient review over documentation completeness and timeliness of recertifications. The issues were centered on tenant files managed by a third-party service provider. Effect Incomplete tenant files and untimely recertifications increase the risk of noncompliance with grant requirements and may result in incorrect tenant rent portions being charged or insufficient support for program eligibility. Repeat Finding This finding is not a repeat finding. Recommendation We recommend that ECS enhance its documentation and monitoring processes with its third-party property managers by implementing a standardized tenant file checklist, conducting periodic supervisory reviews to confirm that all eligibility documents and recertifications are completed and retained, and establishing a tracking process to ensure tenant rent portions are updated promptly based on HSH notifications. View of responsible officials Management agrees with the recommendation. Corrective Action Planned ECS has taken and will continue to take the following steps in the 2026 fiscal year to correct this deficiency. Step 1: Resources ECS began addressing Certificate of Tenancy errors with the hiring an Associate Chief of Real Estate and Asset Management in August, a Director of Property Management in October and a Property Management Compliance Manager in September. Step 2: Best Practices ECS has hired a consulting firm to correct Certificate of Tenancy errors at its one of its sites and will apply the best practices learned to all the affiliate and master lease sites. In addition, ECS has put together policies and procedures and has offered training to both ECS and subcontracted staff on Certificate of Tenancy. ECS will continue to offer compliance training as it takes over property management across all Master Lease sites and the affiliate portfolio. Step 3: Take control of property management Replace outsourced property management with ECS staff to better control Tenant documentation at all master lease and affiliate sites. Step 4: Quality and Compliance ECS has started in a few sites to review Tenant documentation and will expand this review to all sites across its entire portfolio. Implementation Date ECS will fully correct Certificate of Tenancy errors by June 30, 2026. Responsible Personnel The Chief Operating Officer and the Associate Chief of Real Estate and Asset Management.
2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District o...
2025-001 Reporting US Department of Education – AL #s10.553, 10.555, 10.559 and 10.582 Child Nutrition Cluster Condition: The District submitted monthly child nutrition reimbursement claims that contained inaccurate meal counts for multiple months during the fiscal year. Specifically, the District overstated reimbursable meal counts due to errors in including non-reimbursable meals served. Additionally, the claims were not subject to an independent review prior to submission to ensure accuracy and completeness. Name of Contact Person: Ann Berman, Business Manager Plan of Action: The District will revisit the internal control processes surrounding the grant reporting and reimbursement process to ensure meal count information submitted is within program requirements of Child Nutrition Cluster programs. In the event there are questions surrounding meal count and other information subject to reporting, the District will continue to rely on timely guidance from external governmental accounting consultants, the Oregon Department of Revenue, and the Oregon Department of Education.
Finding #2025-001 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Assistance Listing #14.218, Passed through Harris County, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Gra...
Finding #2025-001 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Housing and Urban Development, Assistance Listing #14.218, Passed through Harris County, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #’s: C2023-006G, C2024-006H, and C2020-050G, Contract years: 10/23-09/24, 10/24-09/25, and 03/24-09/24. Assistance Listing #14.218, Passed through City of Houston, Community Development Block Grants/Entitlement Grants – CDBG – Entitlement/Special Purpose Grants Cluster, Contract #: 4600016648, Contract year: 05/25-06/25. U. S. Department of Health and Human Services, Assistance Listing #93.576, Passed through Episcopal Migration Ministries, Refugee and Entrant Assistance Discretionary Grants, Contract #’s: 90RP0117‐01-00, 90RP0117-02-00, 90RP0117-03-00, and 90RP0117-04-00, Contract years: 10/23-09/24 and 10/24-09/25. Applicable state program: Texas Department of Agriculture, Home-Delivered Meal Grant Program, Contract #’s: HDM2024029-070-071 and HDM2025052-053, Contract years: 02/24-01/25 and 02/25-01/26. Condition and context: During our testing of 24 expenditures requiring procurement, we identified one instance of expenditures in Home-Delivered Meal Grant Program greater than the simplified acquisition threshold of $10,000 where simplified acquisition procedures in accordance with Interfaith Ministries’ policy were not followed. Recommendation: Emphasize adherence to established policies and procedures to ensure procurement is performed according to the procurement policy, and that proper procurement documentation is maintained. Planned corrective action: Our organization implemented a robust procurement policy effective July 1, 2018 that complies with the guidelines of 2 CFR 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart D – Post Federal Award Requirements, Procurement Standards 200.317-326 and the Texas Grants Management Standards. Under the established procurement method for small purchases between $10,000 and $100,000, Interfaith Ministries is required to obtain price or rate quotations from a minimum of three sources. The management team will re-emphasize the established policy and procedures for procurement with Interfaith Ministries staff. Responsible officer: Sheroo Mukhtiar, Chief Executive Officer and Stephanie Alvarez, Chief Financial Officer. Estimated completion date: December 1, 2025
Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.566, Passed through Texas Office for Refugees, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Contra...
Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Assistance Listing #93.566, Passed through Texas Office for Refugees, Refugee and Entrant Assistance State/Replacement Designee Administered Programs, Contract #’s: FFY2024-27947V-CMA and FFY2025-27947V-CMA, Contract years: 10/23-09/24 and 10/24-09/25. Condition and context: Interfaith Ministries’ policies and procedures for verifying the completeness of documentation includes ensuring the acknowledgement of receipt of a debit card by the client is maintained in the client file. In a sample of 33 client files tested for refugee cash assistance program, we noted one client who received a debit card in February 2025 did not have the acknowledgement receipt in the client file. Recommendation: Emphasize adherence to established policies and procedures to ensure acknowledgement of receipt of a debit card by the client is maintained in the client file. Planned corrective action: With the implementation of the Refugee Cash Assistance (RCA) Debit Card program by TXOR, our organization established the policy that client case files must contain a copy of the Debit Card Activation Page with the client’s signature and the date the card was delivered to the client as required by TXOR. Our program team will re-emphasize these policies through additional staff training to ensure compliance with the established policy and procedures for the RCA Debit Card program. Additionally, our compliance department will establish procedures to perform periodic reviews to ensure that the client files are complete. Responsible officer: Ali Al Sudani, Chief Program Officer and Terry Merriett, VP of Quality Assurance & Compliance. Estimated completion date: December 1, 2025.
Responsible party for corrective action: Chris LaTondresse, President and CEO Corrective action: Beacon Interfaith Housing Collaborative agrees with the finding. Management is currently updating its policies to require retaining documentation from checks that verify whether individuals or entities s...
Responsible party for corrective action: Chris LaTondresse, President and CEO Corrective action: Beacon Interfaith Housing Collaborative agrees with the finding. Management is currently updating its policies to require retaining documentation from checks that verify whether individuals or entities serving as vendors are debarred or suspended. Proposed completion date: Management has begun the corrective action and is expected to have new policies in place by June 30, 2026.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
This was the result of being understaffed during this period. Priorities were determined and unfortunately these reports were delayed. Sufficient staff have been hired since this occurred and I don't see this as a problem going forward.
Finding 2025-003: Subrecipient Monitoring Condition: The Sponsoring Organization did not consistently perform the required initial on-site review for new subrecipients (centers and FCC providers) within the mandatory 28-day timeframe. View of Responsible Officials: 4C agrees with the audit finding. ...
Finding 2025-003: Subrecipient Monitoring Condition: The Sponsoring Organization did not consistently perform the required initial on-site review for new subrecipients (centers and FCC providers) within the mandatory 28-day timeframe. View of Responsible Officials: 4C agrees with the audit finding. Corrective Action Plan: 4C will implement a new process of requiring the first visit for new providers to be conducted by the 20th of the month with notes required in kidcare system related to scheduling and rescheduling of visit. Responsible Party: Pagie Runion, Strategic Director of Business Services Anticipated Completion Date: June 30, 2026
Finding 2025-002: Subrecipient Monitoring Condition: During the review of internal controls related to subrecipient monitoring, it was noted that the monthly meetings required between the Program Manager and the Monitoring Specialist were not consistently performed throughout the fiscal year. Specif...
Finding 2025-002: Subrecipient Monitoring Condition: During the review of internal controls related to subrecipient monitoring, it was noted that the monthly meetings required between the Program Manager and the Monitoring Specialist were not consistently performed throughout the fiscal year. Specifically, for the 12-month period tested, the required monthly reviews were not documented for 3 out of 12 months. View of Responsible Officials: 4C agrees with the audit finding. Corrective Action Plan: 4C will improve their control process to include a mandatory monthly check with the department manager to verify visits are completed timely. Responsible Party: Pagie Runion, Strategic Director of Business Services Anticipated Completion Date: June 30, 2026
Finding 2025-001: Suspension and Debarment Condition: The Sponsoring Organization did not consistently document the verification that new Child and Adult Care Food Program (CACFP) centers or Family Child Care (FCC) providers were not suspended or debarred prior to enrollment. View of Responsible Off...
Finding 2025-001: Suspension and Debarment Condition: The Sponsoring Organization did not consistently document the verification that new Child and Adult Care Food Program (CACFP) centers or Family Child Care (FCC) providers were not suspended or debarred prior to enrollment. View of Responsible Officials: 4C agrees with the audit finding. Corrective Action Plan: 4C will implement a control process within the onboarding process. The onboarding check list will have sign offs for the manager and strategic director over the program. Responsible Party: Pagie Runion, Strategic Director of Business Services Anticipated Completion Date: June 30, 2026
The Workforce Development Department (GuilfordWorks) experienced turnover in program service level staffing during FY 2025 along with certain periods of vacancies. Additional training related to federal grant accounting, particularly the reporting requirements for the Department of Labor, will be co...
The Workforce Development Department (GuilfordWorks) experienced turnover in program service level staffing during FY 2025 along with certain periods of vacancies. Additional training related to federal grant accounting, particularly the reporting requirements for the Department of Labor, will be conducted with program staff. Backup program staff are now in place in case of primary staff absences. Finance Department staff will also hold periodic discussions with GuilfordWorks staff to ensure that reporting deadlines are consistently being met timely.
The District is correcting the eligibility status of student participants and is providing training to those that determine the eligibility status to ensure proper eligibility determination in the future.
The District is correcting the eligibility status of student participants and is providing training to those that determine the eligibility status to ensure proper eligibility determination in the future.
See table on page 48.
See table on page 48.
See table on page 48.
See table on page 48.
See table on page 48.
See table on page 48.
See table on page 48.
See table on page 48.
With the late submission/approval of the grants, these dates just slipped through the cracks. Will be monitored better moving forward to ensure the dates they are asking for are made in a timely manner.
With the late submission/approval of the grants, these dates just slipped through the cracks. Will be monitored better moving forward to ensure the dates they are asking for are made in a timely manner.
With the late submission/approval of the grants, these dates just slipped through the cracks. Will be monitored better moving forward to ensure the dates they are asking for are made in a timely manner.
With the late submission/approval of the grants, these dates just slipped through the cracks. Will be monitored better moving forward to ensure the dates they are asking for are made in a timely manner.
With the late submission/approval of the grants, these dates just slipped through the cracks. Will be monitored better moving forward to ensure the dates they are asking for are made in a timely manner.
With the late submission/approval of the grants, these dates just slipped through the cracks. Will be monitored better moving forward to ensure the dates they are asking for are made in a timely manner.
Continued understanding is still needed from prior fiscal years. We have improved but more leanring and improvement is needed. We will continue to review account numbers throughout the year to better understand what journal entries need to be made.
Continued understanding is still needed from prior fiscal years. We have improved but more leanring and improvement is needed. We will continue to review account numbers throughout the year to better understand what journal entries need to be made.
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