Corrective Action Plans

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Finding 547443 (2024-012)
Significant Deficiency 2024
To begin, Iowa Workforce Development did conduct monitoring of subrecipient activities throughout the relevant period. However, the sophistication and intent behind the fraud, coupled with structural weaknesses in the oversight processes, allowed these actions to persist undetected. While the moni...
To begin, Iowa Workforce Development did conduct monitoring of subrecipient activities throughout the relevant period. However, the sophistication and intent behind the fraud, coupled with structural weaknesses in the oversight processes, allowed these actions to persist undetected. While the monitoring in place adhered to Federal standards, the circumstances demonstrated the need for a more targeted approach to identify potential vulnerabilities proactively, especially when dealing with sophisticated methods employed by fraudsters. Second, the findings in this report clearly highlight a significant breakdown in internal controls that allowed fraudulent activities to occur over an extended period of time. The misuse of $436,179.92 in program funds, including $321,520.32 in questioned costs under the Workforce Innovation and Opportunity Act (WIOA), underscores the exploitation of these weaknesses by an individual who acted with intent to defraud. When an individual willfully circumvents internal controls at multiple levels, including fiscal agents, the subrecipient organization, and the external auditors – this highlights the importance of strong internal controls, and risk assessments by all parties involved. Effective oversight requires reciprocal diligence by all stakeholders, and in this instance, the extended period during which irregularities occurred suggests an opportunity for more proactive intervention at all levels. Moreover, Iowa Workforce Development has already initiated measures to address the issues raised within this report, including: Enhanced Monitoring Protocols: Revising and expanding monitoring practices to include more frequent on-site reviews, enhanced financial documentation requirements, and stricter oversight of subrecipient compliance with state & federal statutes. Training and Capacity Building: Conducting mandatory training sessions for Iowa Workforce Development staff and providing necessary technical assistance to subrecipients to ensure a thorough understanding of grant management requirements. Auditor Accountability: Collaborating and creating a more transparent relationship with the state auditor’s office to establish clearer expectations for identifying and reporting financial discrepancies promptly, as well as discussing potential issues that arise more frequently. Iowa Workforce Development remains committed to continue collaborating with all stakeholders – at the Federal & State level – to ensure situations such as this do not occur hereafter.
View Audit 351653 Questioned Costs: $1
Finding 547440 (2024-011)
Significant Deficiency 2024
The Department established policies and procedures to perform financial subrecipient monitoring for subawards related to WIOA and began that process in May 2023. This finding centers on the timing of monitoring reports and determination letters. While not all monitoring reports and/or determinatio...
The Department established policies and procedures to perform financial subrecipient monitoring for subawards related to WIOA and began that process in May 2023. This finding centers on the timing of monitoring reports and determination letters. While not all monitoring reports and/or determination letters were issued timely per the policy, all local areas were notified if/when a report or determination letter could be expected to be sent after the established time frames in state policy. This is not because monitoring was not complete, but rather, to ensure comprehensive and effective monitoring reports and determination letters were issued, demonstrating Iowa Workforce Development’s commitment to thorough and effective monitoring of its subrecipients. The Department is also enhancing its fiscal review process starting with funding requests from sub-recipients and partnering with WIOA Title I program staff to identify areas of risk. Monitoring will continue to be performed to ensure compliance with WIOA and Uniform Guidance, Part 200.332 and Part 200.501(h).
Finding 547437 (2024-010)
Significant Deficiency 2024
Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements.
Effective late fiscal year 2024; new sub-awards and pass thru grant agreements utilize a cover sheet to ensure all required elements listed in 2 CFR 200.332 are clearly included in the subaward agreements.
Finding 547434 (2024-009)
Significant Deficiency 2024
As of the beginning of fiscal year 2025, the Department has established the necessary policies and procedures surrounding FFATA reporting, and all necessary reporting has been completed for the current fiscal year.
As of the beginning of fiscal year 2025, the Department has established the necessary policies and procedures surrounding FFATA reporting, and all necessary reporting has been completed for the current fiscal year.
Finding 547431 (2024-008)
Significant Deficiency 2024
The Department has implemented a procedure to ensure ETA 9130 reports are filed timely and reconcile to supporting documentation. Moreover, all staff have access to a reporting calendar that flags reporting deadlines, so that way adequate reviews can be completed ahead of deadlines.
The Department has implemented a procedure to ensure ETA 9130 reports are filed timely and reconcile to supporting documentation. Moreover, all staff have access to a reporting calendar that flags reporting deadlines, so that way adequate reviews can be completed ahead of deadlines.
Finding 547429 (2024-007)
Significant Deficiency 2024
Iowa has been working with our region five UI program specialist at Department of Labor and other region five states to set goals and make major changes to our processes. Iowa BAM team as of February 1, 2025, is now paperless. This will reduce the amount of time printing, scanning and manually rev...
Iowa has been working with our region five UI program specialist at Department of Labor and other region five states to set goals and make major changes to our processes. Iowa BAM team as of February 1, 2025, is now paperless. This will reduce the amount of time printing, scanning and manually reviewing cases. We will have seven BAM Auditors at this point with one retiring in March. This position has already been posted to refill. Additionally, we still have part-time help from previous BAM Auditors who are still employed in the Unemployment Division. As stated above we have gone paperless. The amount of time spent printing each case, organizing etc. was extraordinary. We have also updated all documents, and they are located in a central location for use by the team. We will meet with BAM Auditors on a weekly basis (done by Workforce Program Coordinator) to keep Auditors on track and to assist them with any case issue. They will also self-report on case progress weekly so they can be assisted in the event the timeline is in danger of not being met. The Quality Control Manager will send weekly progress updates to the Bureau Chief on each person’s case management workload in addition to meeting with each Auditor.
Finding 547427 (2024-006)
Significant Deficiency 2024
During fiscal year 2024, Iowa Workforce Development was without a CFO and Deputy CFO for a majority of the year. Once a CFO and Deputy were onboarded, these reviews began as required by internal policies and procedures.
During fiscal year 2024, Iowa Workforce Development was without a CFO and Deputy CFO for a majority of the year. Once a CFO and Deputy were onboarded, these reviews began as required by internal policies and procedures.
Finding 547425 (2024-005)
Significant Deficiency 2024
The Department will review with staff and retrain as necessary to follow existing policies and procedures to ensure variances identified during the year end reconciliation process are appropriately documented and reconciled to ending and beginning balances. In addition, management will review ETA 21...
The Department will review with staff and retrain as necessary to follow existing policies and procedures to ensure variances identified during the year end reconciliation process are appropriately documented and reconciled to ending and beginning balances. In addition, management will review ETA 2112 reports for accuracy and to identify if an amended report should be filed.
Finding 547423 (2024-004)
Significant Deficiency 2024
The current UI mainframe system only allows for this data to be shown in summary form and cannot be obtained at the more detailed level. As modernization is set to go live in summer 2025, the new UI system will allow for this data to be obtained at a more detailed level, and then saved as support f...
The current UI mainframe system only allows for this data to be shown in summary form and cannot be obtained at the more detailed level. As modernization is set to go live in summer 2025, the new UI system will allow for this data to be obtained at a more detailed level, and then saved as support for these reports.
Finding 547421 (2024-003)
Significant Deficiency 2024
The agency is currently having discussions with both Department of Labor, as well as with Department of Administrative Services to see if UI benefits would be able to be added as an exemption to the Treasury Stat agreement for CMIA requirements.
The agency is currently having discussions with both Department of Labor, as well as with Department of Administrative Services to see if UI benefits would be able to be added as an exemption to the Treasury Stat agreement for CMIA requirements.
Finding 547419 (2024-002)
Significant Deficiency 2024
The Bureau has a new Bureau Chief and Management along with several newly hired and trained Field audit staff. The Department will follow policies and procedures in place for fiscal year 2025. As of this response, the fiscal year 2025 file currently only has 23 open 940 discrepancies remaining and...
The Bureau has a new Bureau Chief and Management along with several newly hired and trained Field audit staff. The Department will follow policies and procedures in place for fiscal year 2025. As of this response, the fiscal year 2025 file currently only has 23 open 940 discrepancies remaining and will have those resolved by April 2025.
Finding 547417 (2024-001)
Significant Deficiency 2024
The Department will review its policies and procedures to determine how often cost rates should be updated to its cost allocation plan. IWD will be moving to an annual review, with quarterly updates only being made in the case of material changes or reorganizations – when and if they occur. If a m...
The Department will review its policies and procedures to determine how often cost rates should be updated to its cost allocation plan. IWD will be moving to an annual review, with quarterly updates only being made in the case of material changes or reorganizations – when and if they occur. If a material event does not occur, an annual review would suffice by the end of fiscal year 2025.
CORRECTIVE ACTION PLAN March 31, 2025 Total Action Against Poverty respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period...
CORRECTIVE ACTION PLAN March 31, 2025 Total Action Against Poverty respectfully submits the following corrective action plan for the year ended June 30, 2024. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 3906 Electric Road Roanoke, VA 24018 Audit period: June 30, 2024 The findings from the June 30, 2024, Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAM AUDIT 2024-001: HeadStart Cluster– Assistance Listing #93.600; Activities Allowed/Unallowed Condition: Included in HeadStart expenditures for 2024 are amounts that are believed to be fraudulently expended and not for their intended use. In some instances, the funds were disbursed without proper authorization, primarily through use of Agency credit cards. In other instances, co-payments for HeadStart services were not properly remitted for deposits, resulting in the need to use additional Federal funds to cover costs. Criteria: All expenditures are to be properly authorized, and all funds are to be properly remitted for deposit. The Agency does have policies in place requiring these to occur. Cause: Employees acted outside the policies and procedures in place to misappropriate funds. Effect: HeadStart funds were not used for their intended purpose. Questioned Costs: Final amounts to be determined. Perspective Information: N/A Repeat Finding: N/A Recommendation: While HeadStart has review and approval policies in place, we recommend that they continue to look for ways to tighten policies and procedures around agency card use and remittance of funds for deposit. Any additional segregation of processes that can be feasibly made should be taken. Corrective Action: 1) We have and will be working closely with our HR and Head Start attorneys to recoup as much of the potentially fraudulent charges as possible and for guidance in communication with the persons involved. The Head start Attorney suggested we retain forensic accountants to conduct a fraud audit of all Tap Head start financial records. The accountants have been retained and are beginning work. 2) We will create policies to require detailed explanation of meal purchases, prohibit TAP credit card use for purchases from personal on-line accounts, and address any additional issues they auditors may find. Our Junior staff accountant will review credit card payment vouchers for compliance. 3) A separate object code (account) will be created in our accounting software where all gift card purchases will be coded. Our accounts payable clerks will submit copies of any gift card charges to our Junior staff accountant, who will be responsible for reviewing and verifying that all required documentation is included (as required in Gift Card policies on TAP’s accounting manual). 4) Copies of Center receipt logs for parent payments will be submitted to Finance where they will be reconciled by the Head Start Finance Director to funds remitted. If the Federal Audit Clearinghouse has questions regarding this plan, please call Angela Penn, President & CEO at 540-283-4818. Sincerely yours, Angela Penn President & CEO
View Audit 351652 Questioned Costs: $1
Finding 547414 (2024-004)
Significant Deficiency 2024
Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families (SSVF) Assistance Listing Number: 64.033 Federal Award Identification Number: 20-ZZ-026 Award Period: 10/01/2023 - 09/30/2024 Type of Finding: Significant Deficiency in Internal Cont...
Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families (SSVF) Assistance Listing Number: 64.033 Federal Award Identification Number: 20-ZZ-026 Award Period: 10/01/2023 - 09/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Compliance Requirement: Cash Management Actions Planned in Response to Finding: The organization will establish and implement a formal drawdown reconciliation process. This will include developing written procedures, training staff on reconciliation requirements, and maintaining clear documentation for each reconciliation. Executive personnel will conduct monthly reviews to verify compliance and address any discrepancies promptly prior to drawdown. Official Responsible for Ensuring CAP: The Interim ED will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The completion date is March 1, 2025. Plan to Monitor Completion of CAP: The Board of Directors meet with the Executive team at least quarterly to review financials.
Finding 547413 (2024-003)
Material Weakness 2024
Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families (SSVF) Assistance Listing Number: 64.033 Federal Award Identification Number: 20-ZZ-026 Award Period: 10/01/2023 - 09/30/2024 Type of Finding: Material Weakness in Internal Control o...
Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families (SSVF) Assistance Listing Number: 64.033 Federal Award Identification Number: 20-ZZ-026 Award Period: 10/01/2023 - 09/30/2024 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Compliance Requirement: Allowable Costs Actions Planned in Response to Finding: The organization will implement a reconciliation process to verify that all travel costs align with the allowable amounts under the SSVF program's policies. Additionally, relevant staff will be trained to ensure full compliance with federal travel regulations and documentation requirements. Official Responsible for Ensuring CAP: The Interim ED will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The completion date was October 10, 2024. Plan to Monitor Completion of CAP: The Board of Directors monitored the completion of the CAP as new policy presented at Board Meeting.
View Audit 351650 Questioned Costs: $1
Finding 547412 (2024-002)
Material Weakness 2024
Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families (SSVF) Assistance Listing Number: 64.033 Federal Award Identification Number: 20-ZZ-026 Award Period: I 0/01/2023 - 09/30/2024 Type of Finding: Material Weakness in Internal Control ...
Federal Agency: U.S. Department of Veterans Affairs Federal Program Name: VA Supportive Services for Veteran Families (SSVF) Assistance Listing Number: 64.033 Federal Award Identification Number: 20-ZZ-026 Award Period: I 0/01/2023 - 09/30/2024 Type of Finding: Material Weakness in Internal Control over Compliance Compliance Requirement: Allowable Costs Actions Planned in Response to Finding: In response to the finding, the organization will implement a formal review and approval process for administrative expenses, enhance documentation practices, conduct regular internal audits, and train staff on federal cost principles. New management acknowledges that intentional collusion and failure to follow procedures contributed to the issue; corrective action has been taken and safeguards are being put in place to ensure accountability and prevent recurrence.Official Responsible for Ensuring CAP: The interim ED will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The completion date was June 6, 2024. Plan to Monitor Completion of CAP: The board will monitor the completion of the CAP through meeting at least quarterly with Director, Finance, and Compliance personnel.
View Audit 351650 Questioned Costs: $1
Actions Planned in Response to Finding: In response to the finding, the organization will establish and implement a formal journal entry review process. All journal entries will be reviewed and approved by authorized personnel before being posted to the financial system. Additionally, clear document...
Actions Planned in Response to Finding: In response to the finding, the organization will establish and implement a formal journal entry review process. All journal entries will be reviewed and approved by authorized personnel before being posted to the financial system. Additionally, clear documentation of the review and approval process will be maintained to ensure accuracy and compliance. Official Responsible for Ensuring CAP: The Interim ED will be responsible for overseeing the implementation of corrective actions. Planned Completion Date for CAP: The planned completion date is June 30, 2025. Plan to Monitor Completion of CAP: The Board of Directors will monitor the completion of the CAP through reviews of journal entries to ensure the review process is being followed and all necessary documentation is maintained.
Corrective Action Plan: The finding was due an administrative error as we did have the students fill out the agreement, but they have been misplaced do to winding down operations. Timeline for Implementation of Corrective Action Plan The process is no longer valid as the College will no longer be a...
Corrective Action Plan: The finding was due an administrative error as we did have the students fill out the agreement, but they have been misplaced do to winding down operations. Timeline for Implementation of Corrective Action Plan The process is no longer valid as the College will no longer be awarding federal work-study. Contact Person Troy Martin, Director of Student Financial Services
Corrective Action Plan: The finding was due an administrative error in the Pell award for this particular student. The College corrected this error and disbursed $492.50 to the student. Timeline for Implementation of Corrective Action Plan By using the incorrect enrollment status, the student was un...
Corrective Action Plan: The finding was due an administrative error in the Pell award for this particular student. The College corrected this error and disbursed $492.50 to the student. Timeline for Implementation of Corrective Action Plan By using the incorrect enrollment status, the student was under awarded Federal Pell Grant funds. Contact Person Troy Martin, Director of Student Financial Services
View Audit 351649 Questioned Costs: $1
Finding 547401 (2024-002)
Significant Deficiency 2024
Pittsburgh Mercy Health System has created a tool to calculate and document the required matching expenditures for HUD programs which will be maintained monthly. Additionally, Pittsburgh Mercy Health System will be reviewing the internal allocations of indirect and overhead costs to enhance and ens...
Pittsburgh Mercy Health System has created a tool to calculate and document the required matching expenditures for HUD programs which will be maintained monthly. Additionally, Pittsburgh Mercy Health System will be reviewing the internal allocations of indirect and overhead costs to enhance and ensure compliance with terms for each Federal grant awarded to ensure eligibility of costs including matching expenditures.
Finding 547400 (2024-001)
Significant Deficiency 2024
During the fiscal year ended June 30, 2024, there was a high amount of turnover within the operational team responsible for this grant, including the Project Coordinator, the Program Manager and the Director of the department. The staff member who had been responsible for performing the rent reason...
During the fiscal year ended June 30, 2024, there was a high amount of turnover within the operational team responsible for this grant, including the Project Coordinator, the Program Manager and the Director of the department. The staff member who had been responsible for performing the rent reasonableness review terminated employment and the report documentation was either not completed, completed but not signed, or not filed in a secure location. Beginning in late 2024, all current staff members have been instructed to complete the rent reasonableness review for each incoming client, ensuring it is signed and saved in the client chart. In addition, the staff has been instructed to save an electronic copy of the rent reasonableness review in a secure folder to ensure it is accessible in the future. To ensure compliance with new process, the team will do periodic reviews of existing charts to ensure all documentation is in place and all requirements are met. Additionally, in some instances, damages were paid in excess of the allowable limits or were reimbursed for expenses made during the normal course of business instead of at the exit period. All team members associated with this grant have received and reviewed the Grant Agreement and are familiar with agreement terms and the damage payments not to exceed allowable limits. All future requests for damages will be reviewed and approved by the Departmental Director prior to the payment request being submitted for processing by the Accounts Payable Department. Additionally, the voucher submission process for damange requests will also include a Finance team member for review and authorization of the voucher detail to ensure compliance of all grant parameters before processing by the Accounts Payable Department.
View Audit 351637 Questioned Costs: $1
Views of Responsible Officials: NEW understands the importance of adhering to their federally compliant Procurement Policy, and will ensure that future procurement follows the policy. For one of the vendors noted above, they were recommended by NEW’s federal fund pass-through agency, and NEW did not...
Views of Responsible Officials: NEW understands the importance of adhering to their federally compliant Procurement Policy, and will ensure that future procurement follows the policy. For one of the vendors noted above, they were recommended by NEW’s federal fund pass-through agency, and NEW did not realize that a full procurement process was still necessary. For the other vendor, NEW did not initially expect costs to exceed the federal threshold during the year, and so neglected to document a procurement process for this vendor.
View Audit 351635 Questioned Costs: $1
Views of Responsible Officials: As of June 1, 2024, NEW's accounting has been outsourced and a new accounting system began being used for the next fiscal year. NEW is setting up the new system to track expenditures by grant, as well as by program.
Views of Responsible Officials: As of June 1, 2024, NEW's accounting has been outsourced and a new accounting system began being used for the next fiscal year. NEW is setting up the new system to track expenditures by grant, as well as by program.
Department of Education NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Auditors’ Recommendation: The University must review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreeme...
Department of Education NSLDS Enrollment Reporting Student Financial Aid Cluster – Assistance Listing No. 84.268, 84.063, 84.007, 84.033 Auditors’ Recommendation: The University must review their enrollment reporting policies and procedures to ensure accurate reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Point University uses National Student Clearinghouse (NSC) for the enrollment reporting process. The registrar’s office prepares a monthly enrollment change report which is sent to NSC. NSC processes the report and returns a file for any discrepancies and potential errors for the school to fix. The school reviews and makes any necessary updates and submits the report to NSC. NSC updates the enrollment information at NSLDS. For graduated students, the school also submits a degree verification file at the end of each term after graduated status is assigned by the school. This file is separate from the enrollment reporting file. The school inquired as to why the updates were not completed and found that updating enrollment status is not part of NSC’s process for the degree verification files. Moving forward, the registrar will submit a separate enrollment report file along with the degree verification to ensure that graduate status is updated at NSC and NSLDS after the school assigns them. During the 2024-2025 school year, while the school was reviewing FVT/GE reporting that was due in January of 2025, the school was able to review enrollment data that had been reported to NSC for the 2023-24 school year and make corrections to that data. Moving forward, the enrollment data is maintained in the new student information system and updated in real time by the registrar’s office prior to the enrollment reports being sent to NSC. Of the 33 students reviewed for NSLDS enrollment status, five had errors. All five students were graduates whose status errors were related to data migration. All five were corrected during the school’s review of enrollment statuses while reviewing data for the FVT/GE reporting, which was done November 2025 through January 2025. Documentation of corrected enrollment statuses with the dates of the certification corrections is attached as Appendix 2024-002A. Name(s) of the contact person(s) responsible for corrective action: Natalie Brown-Motes, Point University Registrar, natalie.brown@point.edu Planned completion date for corrective action plan: FVT/GE status review is completed. School has process in place moving forward for updating graduated students beginning with Spring 2025 semester.
UCB recognizes its obligation under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwi...
UCB recognizes its obligation under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in supportof the administration of the federal student financial aid programs. The Gramm-Leach-Bliley Act (GLBA) (Pub. L. No. 106-102) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). To ensure that the University complies with the requirement, during this year that ends at June 30, 2025, University risk assessment addressed the elements required by (16 CFR 314.4). Accordingly, for this year UCB already performed the following: 1. Vulnerability test 2. Penetration test 3. Backup test was performed during year ended June 30, 2025. Anticipated completion date: Immediately.
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