Corrective Action Plans

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2025-002 SUSPENSION AND DEBARMENT U.S. Department of Housing and Urban Development ALN 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Contract No. B-22-CP-KY-0347 (2022) and B-23-CP-KY-0612 (2023) Criteria and Condition: During our audit procedures, we ...
2025-002 SUSPENSION AND DEBARMENT U.S. Department of Housing and Urban Development ALN 14.251 – Economic Development Initiative, Community Project Funding, and Miscellaneous Grants Contract No. B-22-CP-KY-0347 (2022) and B-23-CP-KY-0612 (2023) Criteria and Condition: During our audit procedures, we noted there was no process in place to ensure vendors were not on a suspension or debarment list, and were eligible to be reimbursed with federal grant funds. Cause: Certain internal controls were not in place to prevent or detect and correct payments made to suspended or debarred vendors. Effect: Federal funds could be used to reimburse payments made to vendors that are suspended or debarred. Questioned Costs: None. Recommendation: We recommend management obtain a greater understanding of the Compliance Supplement requirements over HUD grants, and implement a review process whereby vendors are periodically checked for suspension and debarment. Action Taken: The Authority will implement procedures to include verifying new and existing vendors are not on suspension and debarment listings. Individual(s) responsible for implementing: Maureen Carpenter, CEO Anticipated Completion Date: June 30, 2026
Management has implemented checklists to ensure that the data collection form is submitted timely in the future.
Management has implemented checklists to ensure that the data collection form is submitted timely in the future.
Recommendation: It is not cost effective for the auditee to employ additional personnel solely for financial reporting purposes. Therefore, the School should continue to utilize the expertise of their auditors to assist with the preparation of the Schedule of Expenditures of Federal Awards. Action T...
Recommendation: It is not cost effective for the auditee to employ additional personnel solely for financial reporting purposes. Therefore, the School should continue to utilize the expertise of their auditors to assist with the preparation of the Schedule of Expenditures of Federal Awards. Action Taken: We will continue to use our auditors assist with the preparation of the Schedule of Expenditures of Federal Awards..
Recommendation: It is not cost effective for the auditee to employ additional personnel solely for financial reporting purposes. Therefore, the School should continue to utilize the financial expertise of their contracted bookkeeping service performed by CPAs. Action Taken: We will continue to use a...
Recommendation: It is not cost effective for the auditee to employ additional personnel solely for financial reporting purposes. Therefore, the School should continue to utilize the financial expertise of their contracted bookkeeping service performed by CPAs. Action Taken: We will continue to use a CPA bookkeeping service.
Management has implemented checklists to ensure that the REAC is submitted timely in the future
Management has implemented checklists to ensure that the REAC is submitted timely in the future
Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongo...
Corrective Action Planned: Due to the Authority's size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size. Completion Date: Ongoing
We recommend Christian Care management strengthen internal controls and oversight over the rental assistance calculations and tenant eligibility documentation to ensure accuracy of all assistance payments.
We recommend Christian Care management strengthen internal controls and oversight over the rental assistance calculations and tenant eligibility documentation to ensure accuracy of all assistance payments.
Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Finding Summary: The District does not have a written procurement policy in place that satifies all provisions of Title 2 CFR Part 200.318 through 200.327. Responsible Individuals: Neil Breidenbach, Sys...
Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Finding Summary: The District does not have a written procurement policy in place that satifies all provisions of Title 2 CFR Part 200.318 through 200.327. Responsible Individuals: Neil Breidenbach, System Manager Corrective Action Plan: The District will review the requirements of CFR sections 200.318 through 200.327 and update their procurement policy that meets the requirements. Anticipated Completion Date: December 31, 2026
2025-005 Lack of Reporting Review Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal. Management Response: Management agrees that reports should be reviewed prior to submission and notes that the City does have controls in place to ensure app...
2025-005 Lack of Reporting Review Recommendation: The City should have controls in place to ensure all reports are reviewed prior to submittal. Management Response: Management agrees that reports should be reviewed prior to submission and notes that the City does have controls in place to ensure appropriate review procedures are performed. In this instance, the report was prepared and submitted by the City Manager, and due to limitations within the Federal Government’s online reporting system, there was not a built-in approval workflow available to document the review process. To strengthen our controls, the City will print and retain a copy of the report prior to electronic submission to allow for documented review and approval. This will ensure appropriate oversight is evidenced and that sufficient supporting documentation is maintained to demonstrate the review process was completed. Responsible Parties: Brittany Retherford, City Manager, Mindy Brown, Comptroller, and Bethany Messersmith, Assistant Comptroller Anticipated Completion Date: September 30, 2026
2025-004 Suspension and Debarment Recommendation: The City should require all vendors to provide certification of their status before a contract or purchase order is completed with the vendor and the City should obtain new certificates annually to ensure the vendor status has not changed. Management...
2025-004 Suspension and Debarment Recommendation: The City should require all vendors to provide certification of their status before a contract or purchase order is completed with the vendor and the City should obtain new certificates annually to ensure the vendor status has not changed. Management Response: Management agrees with the recommendation. The City has implemented procedures requiring all departments to obtain vendor certification of status prior to executing a contract or issuing a purchase order. Over the past year, we have worked diligently to educate departments on the importance of obtaining and maintaining proper vendor certifications to ensure compliance with applicable requirements. We will continue to reinforce this expectation and monitor compliance, including obtaining updated certifications annually to ensure vendor status has not changed. Responsible Parties: Brittany Retherford, City Manager, Mindy Brown, Comptroller, and Bethany Messersmith, Assistant Comptroller Anticipated Completion Date: September 30, 2026
Views of Responsible Officials: CVT has reviewed training in timely FFATA reporting with Finance staff working with sub-recipients.
Views of Responsible Officials: CVT has reviewed training in timely FFATA reporting with Finance staff working with sub-recipients.
Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifica...
Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifically, utility expenses were allocated among four tenants instead of five occupied tenants, resulting in an overallocation of utility costs to certain residents. The error was due to an input/calculation issue within the allocation spreadsheet and not a deficiency in the underlying allocation methodology. The organization’s documented utility allocation policy requires that total utility costs be allocated equally among occupied tenants, which is consistent with HUD requirements. Management has evaluated the exceptions identified and determined that the issue was isolated to specific instances of spreadsheet error rather than a systemic failure of the allocation methodology. Corrective Actions Implemented / To Be Implemented • The utility allocation spreadsheet will be corrected to ensure that the total number of occupied tenants is accurately reflected in the allocation calculation. • A two-level review control will be implemented over utility allocations. The Leasing Assistant/Clerk will prepare the allocation, and the Leasing Manager will independently verify accuracy prior to finalization. • Verification will include tenant count validation to the rent roll or occupancy report, recalculation of the per-tenant allocation, and confirmation that total allocations agree to the original utility invoice. • Allocation schedules will be supported by rent roll or occupancy documentation. • A standardized checklist will be implemented for monthly allocation procedures. • Any identified allocation errors will be promptly corrected to ensure tenants are not overcharged. Training Training on utility allocation procedures will be conducted by May 1, 2026, for leasing staff and management, with annual refresher training. Responsible Staff: Leasing Assistant/Clerk – Preparation Leasing Manager – Review and verification Controller – Oversight Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions are being implemented immediately upon identification of the finding. Ongoing monitoring will occur monthly.
Special Tests and Provisions – Material Weakness in Internal Controls over Compliance (Replacement Reserve Disbursement – HUD Approval Requirement) Management Response Management acknowledges that a disbursement of $15,000 was made from the replacement reserve account without obtaining prior written...
Special Tests and Provisions – Material Weakness in Internal Controls over Compliance (Replacement Reserve Disbursement – HUD Approval Requirement) Management Response Management acknowledges that a disbursement of $15,000 was made from the replacement reserve account without obtaining prior written approval from HUD, as required under the Capital Advance Regulatory Agreement. Management recognizes that appropriate controls were not in place to prevent disbursement of restricted reserve funds without required approval, resulting in noncompliance. Management has initiated communication with HUD to disclose the transaction and request guidance on the appropriate resolution. The organization will comply with all directives issued by HUD and will continue to follow up as necessary to ensure timely resolution. Corrective Actions Implemented / To Be Implemented • A formal control will be implemented requiring documented written HUD approval prior to any disbursement from the replacement reserve account. • All reserve disbursements will require documented HUD approval prior to processing and will be subject to Controller review to ensure compliance with HUD requirements. • Replacement reserve accounts will be formally designated as restricted funds within internal financial procedures. • A formal policy governing replacement reserve disbursements will be established. • Alternative funding sources will be used when HUD approval is not available. • Training will be provided to relevant staff on HUD requirements and reserve controls.Training Training on reserve account procedures will be conducted by May 1, 2026, with refresher training annually. Responsible Staff: Controller – Oversight of compliance Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions related to implementation of review controls will be implemented immediately. Resolution will follow HUD guidance.
Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure meal counts are correctly accumulated and reported and in accordance with the requirem...
Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure meal counts are correctly accumulated and reported and in accordance with the requirements of the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure expenses are allocated correctly and in accordance with the requirements of the Unifor...
Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure expenses are allocated correctly and in accordance with the requirements of the Uniform Guidance.
Finding Reference Number: 2025-001 – Significant Deficiency in Internal Control Over Compliance and Non-Material Non-Compliance Finding: One instance where a unit failed its inspection and re-inspection was not performed or scheduled within the required timeframe. The Organization also failed to aba...
Finding Reference Number: 2025-001 – Significant Deficiency in Internal Control Over Compliance and Non-Material Non-Compliance Finding: One instance where a unit failed its inspection and re-inspection was not performed or scheduled within the required timeframe. The Organization also failed to abate the housing assist payments (HAP) or terminate the HAP contract for this unit in a timely manner. Additionally, for this unit the inspection was not performed on the required biennial basis. Planned Corrective Action: The housing team utilizes Yardi to manage the housing program. The team has been using the software to schedule inspections. Through their internal review, the team confirmed Yardi's reporting capabilities within the system were not being fully utilized to monitor overdue reinspections or trigger abatement actions. This gap contributed to the oversight cited in the audit finding. A retraining on Yardi is being scheduled for April 2026 to ensure the full reporting capabilities within the system will be utilized to ensure proper monitoring of overdue inspections. In addition, there are adequate policies and procedures in place to ensure inspection and reinspection of units, but we will revise current policy to strengthen this area. Anticipated Completion Date: Ongoing with a completion date of April 30, 2026. Name(s) of the Contact Person(s) Responsible for Corrective Action: Ronald Walker, CPA, Vice President, Finance, 202-893-9907, ronald.walker@ccdc1.org Sanique Lyn, MPH, AVP-Clinical Housing, 202-870-5090, slyn@ccdc1.org
Name of Contact Person: Pamela Rizkallah, Superintendent. Recommendation: We recommend that the District only charge costs that are allowable under the grant agreement. We also recommend that the District contact ISBE to discuss if the District will need to return the funds reimbursed by the Illinoi...
Name of Contact Person: Pamela Rizkallah, Superintendent. Recommendation: We recommend that the District only charge costs that are allowable under the grant agreement. We also recommend that the District contact ISBE to discuss if the District will need to return the funds reimbursed by the Illinois School Board of Education for these unallowable expenditures. Corrective Action: The District will ensure that all costs charged to the Title I grant are allowable per the grant agreement going forward. Proposed Completion Date: Immediately.
Name of Contact Person: Dotty Schnobrich, City Clerk
Name of Contact Person: Dotty Schnobrich, City Clerk
Correction Action: The finance related tasks will be separated as much as possible and alternative controls will be used to compensate for the lack of separation. The City Council will become more involved in providing some of these controls.
Correction Action: The finance related tasks will be separated as much as possible and alternative controls will be used to compensate for the lack of separation. The City Council will become more involved in providing some of these controls.
Proposed Completion Date: The City Council will implement the above procedures immediately.
Proposed Completion Date: The City Council will implement the above procedures immediately.
Name of Contact Person: Dotty Schnobrich, City Clerk
Name of Contact Person: Dotty Schnobrich, City Clerk
Correction Action: The City Clerk will continue to review GASB pronouncements and GASB disclosure checklists to ensure she is aware of financial statement requirements and new pronouncements.
Correction Action: The City Clerk will continue to review GASB pronouncements and GASB disclosure checklists to ensure she is aware of financial statement requirements and new pronouncements.
Proposed Completion Date: The City Council will implement the above procedures immediately.
Proposed Completion Date: The City Council will implement the above procedures immediately.
The district Business Manager has implemented a system whereby copies of all invoices will be emailed to the Treasurer for approval before invoices are paid from any State, Local or Federal Funds. This will help prevent the district from using Federal funds for unallowable costs or activities. This ...
The district Business Manager has implemented a system whereby copies of all invoices will be emailed to the Treasurer for approval before invoices are paid from any State, Local or Federal Funds. This will help prevent the district from using Federal funds for unallowable costs or activities. This process will help ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.
Establish a consistent process for maintaining accurate documentation to support student withdrawals, graduation cohorts, and attendance by regularly reviewing EMIS data related to enrollment, attendance and graduation.. The attendance team, an administrator, and the EMIS coordinator will conduct mo...
Establish a consistent process for maintaining accurate documentation to support student withdrawals, graduation cohorts, and attendance by regularly reviewing EMIS data related to enrollment, attendance and graduation.. The attendance team, an administrator, and the EMIS coordinator will conduct monthly reviews of current data to ensure accuracy, compliance, and timely corrections.
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