Corrective Action Plans

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Finding 2025‐001: Contact Person NAME: Julia Delgado PHONE: (503) 280-2600 E-Mail: jdelgado@ulpdx.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned The Urban League of Port...
Finding 2025‐001: Contact Person NAME: Julia Delgado PHONE: (503) 280-2600 E-Mail: jdelgado@ulpdx.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned The Urban League of Portland is committed to an environment of continuous improvement. Further training shall be provided to Program Managers regarding the organizations’ documented internal controls and the importance of adhering to the established approval process. Urban League has currently hired a seasoned Controller and is in the process of hiring an experienced Accounting Manager. Tracking expiring grants more thoroughly and having further reviews in place to assure transactions are recorded within the grant’s agreed upon period of performance shall provide confidence expenses are recorded properly. Anticipated Completion Date May 1, 2024
2025-101 Cluster name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.038 Federal Perkins Loan Program – Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Fe...
2025-101 Cluster name: Student Financial Assistance Cluster Assistance Listing number and name: 84.007 Federal Supplemental Educational Opportunity Grants 84.033 Federal Work Study Program 84.038 Federal Perkins Loan Program – Federal Capital Contributions 84.063 Federal Pell Grant Program 84.268 Federal Direct Student Loans Award numbers and years: P063P241066 July 1, 2024 to June 30, 2025 P007A240115 July 1, 2024 to June 30, 2025 P033A240115 July 1, 2024 to June 30, 2025 P268K241066 July 1,2024 to June 30, 2025 Federal Agency: U.S. Department of Education Compliance Requirements: Special Tests and Provisions – return of Title IV funds Questioned Costs: None Name of Contact Persons: Kristina Winterstein, Controller Anticipated Completion Date: December 31, 2025 The Maricopa County Community College District understands the importance of adhering to District polices and procedures for the return of Title IV funds. During Fiscal Year 2025, the District Student Financial Services office experienced the unexpected death of a team member, which caused a temporary disruption of workflow and necessitated the reassignment of job duties. This disruption and reassignment caused a delay of return of Title IV completion within the required timeframe. The District has since updated it’s return of Title IV tracking procedures and added supervisory monitoring to ensure calculations are completed within the 45 day regulatory timeframe to ensure compliance with both District and Federal guidelines.
We recommend that the District provide accurate federal expenditure information prior to the beginning of audit fieldwork. Management’s Response: The District concurs with the finding. Responsible Individual: Trish Wilkinson, Accounting Supervisor Corrective Action Plan: The District will provide ac...
We recommend that the District provide accurate federal expenditure information prior to the beginning of audit fieldwork. Management’s Response: The District concurs with the finding. Responsible Individual: Trish Wilkinson, Accounting Supervisor Corrective Action Plan: The District will provide accurate federal expenditure information prior to the beginning of the audit fieldwork. Anticipated Completion Date: June 30, 2026
Views of Responsible Official: Management agrees with the finding. Management will develop an alert system for Program Directors to use in tracking their sub-awards and sub-contracted engagement values and related amendments. This system will create an alert when a contract value exceeds $30,000 pro...
Views of Responsible Official: Management agrees with the finding. Management will develop an alert system for Program Directors to use in tracking their sub-awards and sub-contracted engagement values and related amendments. This system will create an alert when a contract value exceeds $30,000 prompting the Program Director to file, or work with appropriate staff to file the FFATA.
Views of Responsible Official: Management agrees with the finding. Management will institute additional calendar alerts and accountability procedures to ensure reports are filed on time. Recognizing that technical issues, illness, and other unforeseen circumstances can arise, Management will institu...
Views of Responsible Official: Management agrees with the finding. Management will institute additional calendar alerts and accountability procedures to ensure reports are filed on time. Recognizing that technical issues, illness, and other unforeseen circumstances can arise, Management will institute a requirement that all late filings must be communicated to the Contract Monitor as soon as the delay is anticipated.
Views of Responsible Official: Management notes that the Federal Payment Management System (PMS) automatically tracks when different users enter information such as submitting and certifying/approving draw-down amounts. During the time of the grant there were periods when only one staff member had a...
Views of Responsible Official: Management notes that the Federal Payment Management System (PMS) automatically tracks when different users enter information such as submitting and certifying/approving draw-down amounts. During the time of the grant there were periods when only one staff member had access to PMS due to technical issues and delays in adding new users. To ensure there is back-up documentation of the approval workflow, we will institute a form to capture the individual signatures of the preparer and submitter of each draw down as additional evidence of multiple people connected to the process.
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: ...
Student Financial Assistance Cluster – Assistance Listing No. Various Recommendation: We recommend the University review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is reviewing its enrollment reporting process in coordination with the Registrar’s Office to identify any potential issues affecting data transmission through the National Student Clearinghouse. As part of this review, the University is evaluating additional reconciliation and verification procedures to confirm that enrollment status data submitted to the Clearinghouse is accurately reflected in NSLDS. The University will continue to monitor enrollment status reporting on an ongoing basis to ensure compliance with federal reporting requirements. Name(s) of the contact person(s) responsible for corrective action: Mark Freed Planned completion date for corrective action plan: 06/30/2026
The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.
The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.
The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.
The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.
Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office to further understand the analyst processing timelines to strategize effective submission and error resolution dates to ensure output is captured in the monthly NSC bat...
Regent University agrees with this finding. The University will engage with the National Student Clearinghouse audit support office to further understand the analyst processing timelines to strategize effective submission and error resolution dates to ensure output is captured in the monthly NSC batches. The University will continue to engage the established working group with appropriate Regent stakeholders to review suggested changes made by the NSC to reporting methods, time buffers between reports, reporting frequency, and other “upstream” preventative measures that may be taken to prevent file backlogs. Internally, the University will establish a customized and shared enrollment reporting tracker available to all stakeholders in the working group. This will transparently represent the dates to maintain the 60-day compliance window and allow us to manually intervene where possible. Regent University will implement the plan by June 30, 2026. Name of responsible parties: Elizabeth Bayless (University Registrar) & Tameka Lyons (Senior Associate Registrar)
Name: Conway Apartments, Inc. Contact: Jeffrey Woods, Director of Accounting Contact Phone Number: 479-967-5570 Audit Period Ending: June 30, 2025 Anticipated Completion Date: March 18, 2026 Finding 2025-001: The Project did not remit residual receipts in excess of $250 per unit to HUD upon renewal ...
Name: Conway Apartments, Inc. Contact: Jeffrey Woods, Director of Accounting Contact Phone Number: 479-967-5570 Audit Period Ending: June 30, 2025 Anticipated Completion Date: March 18, 2026 Finding 2025-001: The Project did not remit residual receipts in excess of $250 per unit to HUD upon renewal of its PRAC on January 1, 2025, as required by HUD guidance. Management had not recorded a liability for the recapture and was not aware of the requirements. Management’s Response and Planning Corrective Actions: Management has contacted Willaim Stokes at HUD and has been advised to use the funds on an upcoming remodel. The money will be spent by June 30, 2026. Moving forward the Residual Account will be monitored to ensure prompt repayment of funds. Management concurs with findings and plans to implement recommendations above.
City of Marshall, Missouri respectfully submits the following Corrective Action Plan for the year ended September 30, 2025. Contact information for the individual responsible for the corrective action: Aimee Klinge, Finance Officer City of Marshall, Missouri Independent Public Accounting Firm: Gerdi...
City of Marshall, Missouri respectfully submits the following Corrective Action Plan for the year ended September 30, 2025. Contact information for the individual responsible for the corrective action: Aimee Klinge, Finance Officer City of Marshall, Missouri Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended September 30, 2025 The findings from the September 30, 2025, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2025-002 Uniform Guidance Audit Submission Recommendation: The City should submit its single audit reporting package to the federal audit clearinghouse no later than 9 months after fiscal year-end. Action Taken: The City will ensure their single audit submission will be submitted within the nine month deadline in the future.
Completion Date: September 30, 2026
Completion Date: September 30, 2026
Sincerely, Aimee Klinge, Finance Officer City of Marshall, Missouri
Sincerely, Aimee Klinge, Finance Officer City of Marshall, Missouri
2025-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on Client #20 Corrective Action: Section 1 RE: Incorrect Rental Calculation: The incorrect calculation refe...
2025-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on Client #20 Corrective Action: Section 1 RE: Incorrect Rental Calculation: The incorrect calculation referenced in this finding was due to a typo, which resulted in an incorrect payment. To catch simple human errors such as this in the future, management will update the rent calculation worksheet to include reminders to double check data entry in fields that are easy to transpose. Management will also update the recertification process to add the following additional steps: The Data Technician will also review the rent calculation worksheet and the supporting documentation to ensure the amounts in the supporting document(s) match the entry in the worksheet; the Housing Coordinator will conduct a randomized audit of at least two rent calculation worksheets each month. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2023-24 audit: 2023-24 Total Deficient Eligibility Records: 2024-25 Total Deficient Eligibility Records: WNCAP expects to see continued improvement in subsequent audits.
• Corrective Action Plan: The staff will ensure that all invoices affected by the fiscal year-end encumbrance rollover process are prioritized in the purchasing review workflow. The Purchasing Division, presently constituted of a newly onboard Purchasing Manager and Purchasing Specialist, will ensur...
• Corrective Action Plan: The staff will ensure that all invoices affected by the fiscal year-end encumbrance rollover process are prioritized in the purchasing review workflow. The Purchasing Division, presently constituted of a newly onboard Purchasing Manager and Purchasing Specialist, will ensure that established encumbrance rollover procedures are followed in coordination with key Finance Department staff who have supervisorial ownership of the encumbrance rollover process. The Purchasing Division will receive training from the Finance Department to ensure that it is able to take task ownership of its purchasing reviews involved within the fiscal year-end encumbrance rollover process. • Anticipated Completion Date: 6/30/2026 • Corrective Action Plan: The Construction Management (CM) Team will include a standing Progress Payment agenda item in the weekly progress meetings with the Contractor. During these meetings, the team will review all progress payments that have been submitted or are in progress and track their review and approval status. This process will ensure that progress payments are monitored regularly and processed within the required timeframe. Under standard practice, progress payments are typically processed and paid within two weeks of submission. The weekly tracking process will provide additional oversight to help ensure payments continue to be reviewed and approved in a timely manner. • Anticipated Completion Date: 04/01/2026
The City will implement the following corrective actions to ensure timely compliance with all grant requirements: 1. Grant Compliance Tracking • The City will establish a formal, centralized tracking system for all active grants and associated compliance deadlines, including award package submittals...
The City will implement the following corrective actions to ensure timely compliance with all grant requirements: 1. Grant Compliance Tracking • The City will establish a formal, centralized tracking system for all active grants and associated compliance deadlines, including award package submittals. • Grant requirements will be reviewed on a weekly basis as part of an established internal coordination meeting. • Submission deadlines (including the 60-day award package requirement) will be tracked and monitored proactively. 2. Integration into Existing City Processes • Since contract award actions are already tracked through established internal coordination meetings, staff will incorporate post-award compliance milestones into this workflow. • This ensures continuity between award approval and required grant documentation submittals. 3. Implementation of Grant Management Software • The City is implementing a grant management system through Euna Solutions (formerly AmpliFund) to strengthen compliance and oversight. • This system will: • Centralize grant information and documentation • Track deadlines, requirements, and deliverables in one platform • Provide automated reminders and notifications for key dates • Maintain audit-ready records and reporting • As described by the platform, grant management software helps "centralize and streamline the entire grant lifecycle...ensuring compliance" and provides "automatic notifications to remind you of key dates and deadlines" while improving transparency and accountability. • The system also enables real-time visibility into grant requirements, deadlines, and progress, helping agencies "track compliance requirements... and provide complete audit trails" to reduce risk of future findings. 4. Enhanced Accountability and Oversight • Responsibility for tracking and submitting award packages will be clearly assigned to designated staff, identified as the Senior Civil Engineer in the Capital Improvement Program assigned to the project. • Supervisory review will be incorporated into the weekly tracking process to ensure accountability. Expected Outcome These corrective actions will: • Ensure all award packages and grant deliverables are submitted within required timeframes • Improve internal coordination and accountability • Reduce administrative risk and prevent recurrence of audit findings • Enhance overall grant compliance through centralized tracking and automated reminders Anticipated Completion Date: • Weekly tracking procedures: Implemented immediately • Integration into City processes: Implemented immediately • Grant management software (Euna Solutions): Implementation underway, full integration estimated by January 31, 2027
2025-003: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV ...
2025-003: Late Return of Title IV Financial Aid - Student Financial Aid Cluster – Assistance Listing #s 84.007, 84.033, 84.063, 84.268 - Grant Period - Year Ended June 30, 2025 Condition Found During our Return of Title IV Fund testing, we noted that the College did not calculate or return Title IV Student Financial Aid for ten out of twenty-five students tested until after 45 days when the student ceased attendance. We consider the untimely calculation and Return of Title IV Student Financial Aid to be a material weakness relating to the Special Tests and Provisions Compliance Requirement. Corrective Action Plan The weekly Official Withdrawal report is reviewed and processed by the Assistant Dean. As applicable, a week after the calculation is performed and funds are returned to DOE, each student recorded is reviewed on the Common Origination and Disbursement (COD) site to ensure that funds were returned. This additional step is conducted monthly by members of the Financial Aid Management and student worker teams. Additionally, the Assistant Dean performs a monthly check of the Official Withdrawal report to ensure that the Return to Title IV calculation was performed for all required students. The review includes viewing the record in Colleague as well as COD. Responsible Person for Corrective Action Plan Yvette M. McGhee Assistant Dean of Financial Aid Implementation Date of Corrective Action Plan The Correction Action Plan was implemented at the beginning of the Fall 25 semester (approximately August 15, 2025)
Finding 2025-006 - Procurement and Suspension and Debarment Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: The City will strengthen its procurement procedures to ensure verification of suspension and debarment status is performed prior to ent...
Finding 2025-006 - Procurement and Suspension and Debarment Name of Contact Person: Darla Hawkins, City Treasurer, City of Sheridan, Wyoming Corrective Action Plan: The City will strengthen its procurement procedures to ensure verification of suspension and debarment status is performed prior to entering into covered transactions funded with federal awards. Management will verify vendors are not suspended or debarred by checking the System for Award Management (SAM.gov) or by obtaining vendor certification prior to awarding contracts. Documentation of the verification will be maintained with the procurement records to ensure compliance with federal requirements. Proposed Completion Date: June 30, 2026
Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Corrective Action Plan: The District will implement procedures that incorporate a second review of meal reimbursement claims before the request is submitted for reimbursement during the monthly processing...
Reference Number: 2025-004 No secondary review of meal claim reimbursements prior to submission Corrective Action Plan: The District will implement procedures that incorporate a second review of meal reimbursement claims before the request is submitted for reimbursement during the monthly processing. Contact Person: Cristina Campbell Implementation Time Frame: August 31, 2026
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College is in agreement with the finding. At the time of noncompliance in this area the college was transitioning to a new software system for the college. The ...
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College is in agreement with the finding. At the time of noncompliance in this area the college was transitioning to a new software system for the college. The software was required to “go dark” for a period time and during this time no processing could be completed. Because of other issues with the system, the R2T4 timeline for returning the funds was not calculated correctly and the deadline was missed by a few days. Administration did not realize the error until after the deadline had passed. As soon as the error was found, the process was completed immediately. We do not expect to have this issue in the future. The R2T4 process for review has always been that one person in the financial aid office is responsible for completing the process and another person reviews the documents once the process is complete. We will continue this process and look for other procedures to implement to ensure an accurate R2T4 process is completed.
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. The college realizes this is a repeat finding and we have struggled with compliance in this area due to the inadequacy of the s...
Contact person responsible for correction action – Michell Hall, CFO Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. The college realizes this is a repeat finding and we have struggled with compliance in this area due to the inadequacy of the system we were using and turnover in the financial aid office and the registrar’s office. With the new system, and the more seasoned personnel in each of the departments, we strive to make improvements in the enrollment reporting process. We are still actively running monthly processes to review enrollment reporting data to ensure the accuracy of our reporting. The new system will aid us in doing these processes better and continued training with personnel will be prioritized. We will continue to review policy and procedures and look for ways to make this process better.
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of this noncompliance the College was implementing a new financial aid system (JFA). The financi...
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of this noncompliance the College was implementing a new financial aid system (JFA). The financial aid system went live in July 2024. The business office module did not go live until November 2024. The college’s IT implemented a bridge to connect the two systems while we waited for the business office module to go live. There were issues with the bridge between the two systems which caused the aid posting process to work inaccurately. We immediately contacted IT to help with the situation, but they took longer than expected to find a solution. Because we knew time was of the essence and our system would be “going dark” (unable to process anything for a period of time), we manually started processing aid in order to post aid to student accounts so that students could receive their refunds. The financial aid system had disbursement dates already set up and all of those dates had to be manually updated. Unfortunately, the College missed updating one date for the student that was found during audit, and the date that was reported to COD was the original disbursement date instead of the actual disbursement date. The system no longer requires the bridge, and we have not experienced any issues since all systems came on board. Now that the system is working properly, there is a process that looks at the disbursement date on the student account and compares it to what the financial aid system has in place. If the dates do not match, the system automatically updates the disbursement date in the financial aid system and there is a file that is generated to send an update to COD automatically. We do not expect to have this issue in the future but have implemented processes to review disbursement dates through the reconciliation process in the new system.
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of noncompliance the college was transitioning to a new financial aid system. The compliance eng...
Contact person responsible for correction action – Mitzi Suhler, Financial Aid Director Anticipated completion date – June 30, 2025 Corrective action Sterling College agrees with the finding. At the time of noncompliance the college was transitioning to a new financial aid system. The compliance engine of the new system was set up but there was a gap in the compliance which allowed aid for students who were not enrolled to post without warning. The issue was found by the financial aid administrators and corrected as soon as it was discovered. Upon finding the issues, the financial aid administrators reached out to the IT department for more training on the compliance portion of the software and have worked diligently to update the system and put in place processes that will ensure that aid is canceled for students that are not enrolled. The system also has compliance setup to ensure checks and balances are in place to look for students who are eligible to receive aid and will not post aid for students who are not enrolled even if the aid has not been canceled before the official disbursement date.
Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-002 - Procur...
Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-002 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6, 2 H80CS00646-24-01, 1 H8LCS51923-01-00 for 2024 and 2025, 1 H8NCS54043-01- 00 for 2025 - (Significant Deficiency) During our audit, we noted that certain employees have no record of an exclusion search conducted during 2025. There were also certain employees for whom an exclusion search was not consistently conducted on a monthly basis. Recommendation We recommend that the Center train its personnel in relation to the exclusion screening and proper documentation thereof and that the Center conduct regular reviews to ensure the completeness of exclusion search documentation. Action Taken Management agrees with the finding and will be conducting training for its personnel to help ensure the accuracy, completeness and timeliness of exclusion searches. Effectivity Date: June 30, 2026
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