Corrective Action Plans

Finding 540921 (2024-006)

Significant Deficiency 2024

DE

Questioned Costs Matching / Level of Effort / Earmarking Eligibility

The program has corrected the calculation error in its income calculations form. Additionally, increased weekly training and case review have been implemented to detect and prevent such errors.

View Audit 350549 Questioned Costs: $1

Finding 540920 (2024-005)

Significant Deficiency 2024

Delaware State Housing Authority

DE

Questioned Costs Allowable Costs / Cost Principles § 200.406

DSHA has implemented the process of requiring the reduction of applicable credits to be applied to all future payment batches and be utilized to fund assistance. This as a result, will eliminate the funds being held by the vendor and remove the need to report as a federal expenditure. The responsibi...

DSHA has implemented the process of requiring the reduction of applicable credits to be applied to all future payment batches and be utilized to fund assistance. This as a result, will eliminate the funds being held by the vendor and remove the need to report as a federal expenditure. The responsibility for implementing this corrective action lies with the following DSHA staff: HAF Program Manager, Director of Housing Finance, Financial Accounting & Reporting Section Manager, and the Director of Financial Management. They will oversee the necessary adjustments to the process and ensure that future payment batches adhere to the revised guidelines.

View Audit 350549 Questioned Costs: $1

Finding 540919 (2024-004)

Significant Deficiency 2024

Delaware State Housing Authority

DE

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303

DSHA will implement a policy and procedure requiring the retention of reporting backup data to be retained with the submitted report. Additionally, DSHA will require that the review of the submitted report be documented and that any identified report discrepancies be noted and retained with the sub...

DSHA will implement a policy and procedure requiring the retention of reporting backup data to be retained with the submitted report. Additionally, DSHA will require that the review of the submitted report be documented and that any identified report discrepancies be noted and retained with the submitted report.

View Audit 350549

Finding 540918 (2024-003)

Significant Deficiency 2024

Delaware State Housing Authority

DE

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

DSHA has expanded the use of the program policy and procedure change log to include this program.

View Audit 350549

Finding 540903 (2024-001)

Significant Deficiency 2024

The Gavin Foundation, Inc.

MA

Procurement, Suspension & Debarment § 200.318 § 200.327

CORRECTIVE ACTION PLAN March 17, 2025 Health Resources and Services Administration 5600 Fishers Lane Rockville, MD 20857 The Gavin Foundation, Inc. respectively submits the following corrective action plan for the year ended June 30, 2024. CohnReznick LLP 350 Granite Street, Suite 1200 Braintree...

CORRECTIVE ACTION PLAN March 17, 2025 Health Resources and Services Administration 5600 Fishers Lane Rockville, MD 20857 The Gavin Foundation, Inc. respectively submits the following corrective action plan for the year ended June 30, 2024. CohnReznick LLP 350 Granite Street, Suite 1200 Braintree, MA 02184 Audit Period: June 30, 2024 The finding from the June 30, 2024 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDING - FEDERAL AWARD PROGRAM AUDIT U.S. Department of Health and Human Services 2024-001 Congressional Directives - Assistance Listing No. 93.493 SIGNIFICANT DEFICIENCY Recommendation Management should establish procedures to ensure contract files include the history of procurements and the documentation is maintained. Action Taken The organization performed procurement procedures, including soliciting bids/proposals from multiple contractors, evaluating them and selecting the contractor based on their procurement procedures. However, as the project was completed we maintained the contracts related to the contractor selected but inadvertently disposed of the documentation related to the procurement process. We have met with employees responsible for completion and filing of the procurement documentation and discussed the importance of not only completing the documentation, but also the importance of its proper filing. We have updated our procedures to ensure procurement history is adequately documented and maintained in the contract files. These actions were implemented (or are anticipated to be implemented) effective March 17, 2025. If the Health Resources and Services Administration has questions regarding this plan, please call Peter Barbuto at (857) 496-7341. Sincerely yours, Peter Barbuto, CEO The Gavin Foundation, Inc.

View Audit 350539

Finding 540902 (2024-001)

Material Weakness 2024

Wayne Independent School District No. 10

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

We did not realize the requirements of the Davis Bacon Act until our FY 23 Audit. The projects requiring the use of the act were done prior to the audit in March of 2024. The District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards...

We did not realize the requirements of the Davis Bacon Act until our FY 23 Audit. The projects requiring the use of the act were done prior to the audit in March of 2024. The District will develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. The District will also ensure that all items are posted at the work site to ensure compliance.

View Audit 350531

Finding 540894 (2024-004)

Significant Deficiency 2024

City of Waltham, Massachusetts

MA

Procurement, Suspension & Debarment

The Business Office will update the Grants Requisition Form to include a field to indicate whether or not a Debarment Certification is required. Both the Grants Manager and Assistant Superintendent of Finance and Operations are required to sign off on all Grant Requisition Forms. Additionally, the F...

The Business Office will update the Grants Requisition Form to include a field to indicate whether or not a Debarment Certification is required. Both the Grants Manager and Assistant Superintendent of Finance and Operations are required to sign off on all Grant Requisition Forms. Additionally, the Fiscal Coordinator will work with her Accounts Payable team to make sure they are double checking the Debarment Certification field as part of their review of all submitted grant requisitions.

View Audit 350527

Finding 540886 (2024-003)

Material Weakness 2024

City of Waltham, Massachusetts

MA

Questioned Costs Procurement, Suspension & Debarment

The Fiscal Coordinator, Supervisor of Transportation, Assistant Superintendent of Finance and Operations, and Grants Manager have all been briefed on the procurement standards. The Grants Manager will develop a grants management manual to share with all educators and administrators who are implement...

The Fiscal Coordinator, Supervisor of Transportation, Assistant Superintendent of Finance and Operations, and Grants Manager have all been briefed on the procurement standards. The Grants Manager will develop a grants management manual to share with all educators and administrators who are implementing grants, and will meet individually with the lead person on each grant to make sure all standards and procedures are clear. The Business Office will update the Grants Requisition Form to include a field to indicate whether procurement standards have been met. Both the Grants Manager and Assistant Superintendent of Finance and Operations are required to sign off on all Grant Requisition Forms.

View Audit 350527 Questioned Costs: $1

Finding 540878 (2024-002)

Significant Deficiency 2024

City of Waltham, Massachusetts

MA

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency

Moving forward all Time & Efforts Records for federal grant funded positions will be on a single schedule (December and June) of each calendar year and tracked by each program department with support from administrative assistants. All forms will be collected electronically and remain on file in one...

Moving forward all Time & Efforts Records for federal grant funded positions will be on a single schedule (December and June) of each calendar year and tracked by each program department with support from administrative assistants. All forms will be collected electronically and remain on file in one central location in the Finance Department through Grants. This process was begun last year and worked well, but we learned that we need to include a mechanism for ensuring that staff complete Time and Effort forms upon their departure if they leave their role/the district prior to the December or June collection dates. We are working with HR to make sure that this is part of the exit process for any federally-funded staff.

View Audit 350527 Questioned Costs: $1

Finding 540877 (2024-007)

Material Weakness 2024

Putnam County Commission

WV

Reporting Special Tests & Provisions § 200.1

The County Commission will ensure all expenditures are properly reported to the governing entity during the proper reporting period.

View Audit 350525

Finding 540876 (2024-006)

Material Weakness 2024

Putnam County Commission

WV

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.404

The County Commission will work directly with the vendor to ensure future payment requests properly align with payment information listed on the federal contract.

View Audit 350525

Finding 540859 (2024-001)

Significant Deficiency 2024

Magnolia School District

AR

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.439

At the time of the purchase for this particular building, the district had several prior approval applications for HVAC replacment submitted to DESE for approval. We believe this one had been submitted as well but was unable to confirm that with DESE. We will develop a better checklist for items s...

At the time of the purchase for this particular building, the district had several prior approval applications for HVAC replacment submitted to DESE for approval. We believe this one had been submitted as well but was unable to confirm that with DESE. We will develop a better checklist for items submitted to DESE for prior approvals so nothing is overlooked.

View Audit 350512 Questioned Costs: $1

Finding 540858 (2024-001)

Material Weakness 2024

Bladen County

NC

Eligibility Matching / Level of Effort / Earmarking

Corrective Action- Internal Control Error: Failure to comply with policy requirement: Five (5) Instances of failure to complete at least one compliance component. All identified missing or incomplete verification of facts or were improperly forced. Income Maintenance Medicaid Supervisors will ...

Corrective Action- Internal Control Error: Failure to comply with policy requirement: Five (5) Instances of failure to complete at least one compliance component. All identified missing or incomplete verification of facts or were improperly forced. Income Maintenance Medicaid Supervisors will complete monthly second party reviews for application approvals/recertifications/denials/withdrawals for applications and ongoing cases. Based on findings from the monthly second party review of applications/recertifications individual meetings will be held with the responsible Income Maintenance Caseworker to discuss the errors found and ways to improve the work performance. The individual counseling will assist in assuring that the worker understands the error and what they need to do for improvements. Monthly a spreadsheet is created from each individual score, from each Income Maintenance Caseworkers audit. The spreadsheet is reviewed monthly and presented quarterly at the Bladen County Health and Human Service Advisory Committee meeting. In addition to the above ongoing process a meeting/training will be held with the Medicaid staff on or prior to January 15, 2025 and the following manual sections will be addressed (handouts given): DMA Admin Letter 02-19 The Work Number Procedures, Job Aid: The Work Number, Job Aid: Online Verifications; Manual calculations of Income MA 2250; Resources and verifications MA 2230; Job Aid: Evidence Dashboard Relationships; Approved Uses of Forced Eligibility last update 03/01/2023. NC FAST Mandatory Evidence and Verifications, last updated 01/25/2019 Proposed Completion Date: July 1, 2025 (Improvements from 06/01/2024 – 07/ 01/2025)

View Audit 350499

Finding 540856 (2024-003)

Material Weakness 2024

Ashtabula County Educational Service Center

OH

Procurement, Suspension & Debarment § 200.318 § 200.319 § 200.320 § 200.327

The Service Center will be sure to follow the federal procurement requirements pursuant to Policy 6325 and verify that appropriate controls and compliance with federal requirements are maintained with documentation supporting the procurement types.

View Audit 350470

Finding 540854 (2024-002)

Material Weakness 2024

Ashtabula County Educational Service Center

OH

Questioned Costs Allowable Costs / Cost Principles Reporting § 200.430

The Treasurer will ensure that the appropriate documentation supporting the time spent on a federal grant, in accordance with the Service Center’s Policy 6116 for Time and Effort, for all employees having wages and/or benefits charged to federal grants.

View Audit 350470 Questioned Costs: $1

Finding 540846 (2024-004)

Material Weakness 2024

Kankakee Valley School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.1 § 200.303

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) Period of Performance Summary of Finding: During fiscal year 2023-24, the School Corporation was part of Cooperative School Services, which managed special education programs and federal funds for member schools. Funds for Special Ed...

FINDING 2024-004 Finding Subject: Special Education Cluster (IDEA) Period of Performance Summary of Finding: During fiscal year 2023-24, the School Corporation was part of Cooperative School Services, which managed special education programs and federal funds for member schools. Funds for Special Education needed to be obligated by September 30, 2023. Three exceptions occurred with late obligations. It is recommended that the School Corporation create internal controls to prevent late costs and ensure compliance. Contact Person Responsible for Corrective Action: Chris Richie Business Manager/Treasurer Contact Phone Number and Email Address: 219 987 4711, crichie@kv.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The school corporation will work with Cooperative School Services to ensure that funds are obligated prior to the grant obligation deadline. Anticipated Completion Date: June 1, 2025

View Audit 350469

Finding 540840 (2024-003)

Material Weakness 2024

Kankakee Valley School Corporation

IN

Questioned Costs Allowable Costs / Cost Principles § 200.303 § 200.403

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: During the fiscal year 2023-2024, the School Corporation was part of Cooperative School Services, which managed special education programs and finan...

FINDING 2024-003 Finding Subject: Special Education Cluster (IDEA) Activities Allowed or Unallowed, Allowable Costs/Cost Principles Summary of Finding: During the fiscal year 2023-2024, the School Corporation was part of Cooperative School Services, which managed special education programs and finances for its schools. There were recognized issues where non-public schools received direct reimbursements. It is recommended that the School Corporation implement internal controls to prevent direct reimbursements, ensuring compliance with grant requirements and financial regulations. Contact Person Responsible for Corrective Action: Chris Richie Business Manager/Treasurer Contact Phone Number and Email Address: 219 987 4711, crichie@kv.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will work with Cooperative School Services to ensure allowable cost requirements are met. Reports tracking expenditures will be reviewed semiannually for compliance. Anticipated Completion Date: June 1, 2025

View Audit 350469 Questioned Costs: $1

Finding 540834 (2024-002)

Material Weakness 2024

Kankakee Valley School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) Earmarking Summary of Finding: As a member of Cooperative School Services, special education funding was administered by the Cooperative. The School Corporation only partially spent required funds for some grants. It is recommended t...

FINDING 2024-002 Finding Subject: Special Education Cluster (IDEA) Earmarking Summary of Finding: As a member of Cooperative School Services, special education funding was administered by the Cooperative. The School Corporation only partially spent required funds for some grants. It is recommended that the School Corporation creates written policies to track non-public expenditures to meet earmarking requirements. Contact Person Responsible for Corrective Action: Chris Richie Business Manager/Treasurer Contact Phone Number and Email Address: 219 987 4711, crichie@kv.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Kankakee Valley School Corporation will work with Cooperative School Services to ensure that Earmarking requirements are met. Reports tracking expenditures will be reviewed semiannually for compliance. Anticipated Completion Date: June 1, 2025

View Audit 350469

Finding 540831 (2024-001)

Significant Deficiency 2024

Vantage Aging

OH

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Vantage Aging acknowledges the condition and recommendation of the audit finding. In reviewing and updating our internal control procedures, we have implemented additional hour checks to the payroll worksheets. This will provide a comparison of hours entered each payroll into the in-kind reporting s...

Vantage Aging acknowledges the condition and recommendation of the audit finding. In reviewing and updating our internal control procedures, we have implemented additional hour checks to the payroll worksheets. This will provide a comparison of hours entered each payroll into the in-kind reporting system to ensure reasonableness of the hours being reported for match. Staff who are in charge of running in-kind reporting will also be notified of completed and reviewed payroll periods to allow for the inclusion or exclusion within in-kind reports to ensure that non-completed payroll periods are not included in reports prior to their recognition into our general ledger and programmatic reports.

View Audit 350468

Finding 540830 (2024-002)

None 2024

Newbern Housing Authority

TN

HUD Housing Programs

2024-002 FINDING: Budget Line Item Improper Expenditures (Public Housing Capital Fund - ALN 14.872) – Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, 2025 Planned Correct...

2024-002 FINDING: Budget Line Item Improper Expenditures (Public Housing Capital Fund - ALN 14.872) – Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, 2025 Planned Corrective Action: The Authority will work on ensuring all changes in which Capital Fund monies are spent are approved by HUD in the budget amendment process

View Audit 350466

Finding 540829 (2024-001)

Significant Deficiency 2024

Newbern Housing Authority

TN

Questioned Costs Cash Management HUD Housing Programs

2024-001 FINDING: Excess Reimbursement Requested (Public Housing Capital Fund - ALN 14.872) – Significant Deficiency and Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, ...

2024-001 FINDING: Excess Reimbursement Requested (Public Housing Capital Fund - ALN 14.872) – Significant Deficiency and Noncompliance Person responsible for Implementing the Corrective Action: The Board of Commissioners and David Jones Anticipated Completion Date of Corrective Action: June 30, 2025 Planned Corrective Action: The Authority will work on ensuring requests for reimbursement of capital funds will have supporting documentation and management will take measures to ensure duplicate requests aren't made for a single invoice.

View Audit 350466 Questioned Costs: $1

Finding 540828 (2024-002)

Significant Deficiency 2024

Municipality of Naguabo-Los Hucares I

PR

Internal Control / Segregation of Duties

The Finance Department staff is aware about the compliance requirement, and instructions were given to the accounting staff to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Responsible Person: Mr. Diego Meléndez – Finance Department Director...

The Finance Department staff is aware about the compliance requirement, and instructions were given to the accounting staff to maintain a dateline control sheet to ascertain that required reports were submitted within the due date. Responsible Person: Mr. Diego Meléndez – Finance Department Director Implementation Date: Fiscal Year 2024-2025

View Audit 350461

Finding 540827 (2024-001)

Significant Deficiency 2024

Municipality of Naguabo-Los Hucares I

PR

Reporting

Management gave instructions to the Finance Department staff to submit, in a timely manner, all the required information, to our external consultants and to our external auditors, in order to comply with the datelines for the submission of the Single Audit Report. Implementation Date: March 31, 2025...

Management gave instructions to the Finance Department staff to submit, in a timely manner, all the required information, to our external consultants and to our external auditors, in order to comply with the datelines for the submission of the Single Audit Report. Implementation Date: March 31, 2025 Responsible Person: Mr. Diego Melendez - Finance Department Director

View Audit 350461

Finding 540826 (2024-004)

Significant Deficiency 2024

Muncie Community Schools

IN

Internal Control / Segregation of Duties Reporting Significant Deficiency § 200.302 § 200.303 § 200.328

FINDING 2024-004 – COVID-19 – Education Stabilization Fund – Reporting Context: The School Corporation was required to submit one Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that t...

FINDING 2024-004 – COVID-19 – Education Stabilization Fund – Reporting Context: The School Corporation was required to submit one Annual Data Reports to the Indiana Department of Education (IDOE) during the audit period to meet federal reporting requirements for ESSER grant awards. We noted that the ESSER II amount reported for the reports covering the FY23 time period ($4,934,473) did not agree to the underlying expenditure records ($4,801,053) for the period of July 1, 2022 through June 30, 2023. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all ESSER reports include accurate information that agree to the underlying disbursement records. Anticipated Completion Date: Next ESSER reports due in FY25

View Audit 350456

Finding 540823 (2024-003)

Significant Deficiency 2024

Muncie Community Schools

IN

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.430

Finding 2024-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employee’s time charged to the grant...

Finding 2024-003 – Child Nutrition Cluster – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Context: For 5 selections, in a sample of 5 payroll transactions, the School Corporation did not have time and effort logs to support the portion of the employee’s time charged to the grant. The employees’ time was split with a non-federal fund; however, the School Corporation did not have support for the allocation of the time charged to the School Lunch fund. Contact Person Responsible for Corrective Action: Brad DeRome Contact Phone Number: 765-747-5222 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: We will ensure all payroll amounts recorded to food service are reviewed to ensure they represent food service payroll activity only. Anticipated Completion Date: March 2025

View Audit 350456 Questioned Costs: $1

Corrective Action Plans

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