Corrective Action Plans

Finding 516897 (2024-004)

Material Weakness 2024

Wheeler County

OR

finding. Ensuring program managers receive appropriate training to review grant agreements and identify all

View Audit 334786

Finding 516897 (2024-004)

Material Weakness 2024

Wheeler County

OR

applicable material program requirements will help ensure reports are submitted timely and completel

View Audit 334786

Finding 516896 (2024-003)

Significant Deficiency 2024

Wheeler County

OR

Questioned Costs Allowable Costs / Cost Principles

Views of Responsible Officials and Planned Corrective Actions: The county understands and concurs with this

View Audit 334786 Questioned Costs: $1

Finding 516896 (2024-003)

Significant Deficiency 2024

Wheeler County

OR

Questioned Costs Allowable Costs / Cost Principles

finding. It is the intention of the county to implement a review process to be completed prior to making formal

View Audit 334786 Questioned Costs: $1

Finding 516896 (2024-003)

Significant Deficiency 2024

Wheeler County

OR

Questioned Costs Allowable Costs / Cost Principles

allocation for the Forest Service Schools and Roads Cluster.

View Audit 334786 Questioned Costs: $1

Finding 516870 (2024-001)

Significant Deficiency 2024

American Councils for International Education: Actr/accels, Inc.

DC

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

National Security Language & Student Exchange - Assistance Listing No. 19.415 & 19.009 Recommendation: We recommend the Organization to design controls to ensure that there is an internal control designed to validate the timeline where the final FFATA reports were submitted/updated in the FSRS syst...

National Security Language & Student Exchange - Assistance Listing No. 19.415 & 19.009 Recommendation: We recommend the Organization to design controls to ensure that there is an internal control designed to validate the timeline where the final FFATA reports were submitted/updated in the FSRS system. If this timeline cannot be readily available, we also recommend contacting the FSRS portal to for further clarification on the FSRS system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Finance Staff will take "screen shots" to validate the submission of FFATA reports when they are updated in the FSRS system. Name(s) of the contact person(s) responsible for corrective action: John Henderson, CFO Planned completion date for corrective action plan: 11-21-24 If the Department of State has questions regarding this plan, please call John Henderson, CFO, at 202-833-7522.

View Audit 334780

Finding 516776 (2024-001)

Material Weakness 2024

Two Rivers Regional Council of Public Officials

IL

Internal Control / Segregation of Duties

It is TRRC policy for the Executive Director to sign off on all check authorizations and have two authorized check signers to sign each check being disbursed. The Executive Director has approved the bank reconciliations, journal entries, and all check authorizations for the entire fiscal year 2024. ...

It is TRRC policy for the Executive Director to sign off on all check authorizations and have two authorized check signers to sign each check being disbursed. The Executive Director has approved the bank reconciliations, journal entries, and all check authorizations for the entire fiscal year 2024. Also, bank reconciliations were prepared by the fiscal clerk for the entire fiscal year 2024.

View Audit 334739

Finding 516775 (2024-002)

Significant Deficiency 2024

Future Earth

CO

Questioned Costs Cash Management § 200.305

We were made aware of this issue by a desk review from the National Science Foundation and we have developed and implemented the following policies and internal controls to ensure grant funds are drawn down only after qualifying expenditures on a monthly basis.: If a grant is awarded on a cost-reim...

We were made aware of this issue by a desk review from the National Science Foundation and we have developed and implemented the following policies and internal controls to ensure grant funds are drawn down only after qualifying expenditures on a monthly basis.: If a grant is awarded on a cost-reimbursement basis, Future Earth draws down funds approximately once a month, unless the funder requires another way of accessing their funds. Funds are not drawn down until they have been spent. Before each drawdown, the third-party accounting firm will confirm the grant's cash balance. If there is a positive cash balance, the third-party accounting firm and COO will investigate the cause and correct it immediately. Grants with negative cash balance will be checked by third-party accounting firm to confirm that the grant was active when the expenses were incurred. The third-party account firm will provide a report of the associated transactions of the negative cash balance. The PI will confirm the report transactions and approve the drawdown request. Once approved, the third-party accounting firm will create an invoice and journal entry in the Quickbooks accounting system and the COO will request the drawdown from the funder.

View Audit 334729 Questioned Costs: $1

Finding 516774 (2024-001)

Significant Deficiency 2024

Future Earth

CO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214

We will amend our existing procurement policy to address suspension and debarment for contractors when using federal grant funds to ensure compliance with federal regulations. We will implement a procurement checklist to document and verify contractor eligibility on SAM.gov prior to engaging in con...

We will amend our existing procurement policy to address suspension and debarment for contractors when using federal grant funds to ensure compliance with federal regulations. We will implement a procurement checklist to document and verify contractor eligibility on SAM.gov prior to engaging in contracts utilizing federal funds.

View Audit 334729

Finding 516748 (2024-003)

Significant Deficiency 2024

Sea Mar Community Health Center and Subsidiaries

WA

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding Reference Number: 2024-003 Corrective Action: Sea Mar will create a list of all report deadlines and due dates and have multiple staff review and monitor the list to ensure deadlines are met. This process will mitigate the chances that reports are submitted late. Name of Contact Person: Dust...

Finding Reference Number: 2024-003 Corrective Action: Sea Mar will create a list of all report deadlines and due dates and have multiple staff review and monitor the list to ensure deadlines are met. This process will mitigate the chances that reports are submitted late. Name of Contact Person: Dustin Greer, CFO, DustinGreer@seamarchc.org Projected Completion Date: 3/31/2025

View Audit 334705

Finding 516747 (2024-002)

Significant Deficiency 2024

Sea Mar Community Health Center and Subsidiaries

WA

Reporting § 200.510

Finding Reference Number: 2024-002. Corrective Action: Sea Mar will train its accounting and finance staff to recognize the difference between a state and local grant and a federal grant by learning how to read and interpret the provisions of the gran and determine whether this is a federal or state...

Finding Reference Number: 2024-002. Corrective Action: Sea Mar will train its accounting and finance staff to recognize the difference between a state and local grant and a federal grant by learning how to read and interpret the provisions of the gran and determine whether this is a federal or state and local grant. The training will be conducted by the CFO and Controller of Sea Mar, and staff members will have to acknowledge they understand by signing acknowledgement forms stating they received the training and understand the differences. Staff will also be instructed not to rely on the name of grant because many times the name of the grant is not indicative of the agency that is funding the grant. Controls will also be developed to ensure the SEFA captures all the appropriate information and during the contract review process it will be noted whether grants are federal or not. Name of Contact Person: Dustin Greer, CFO, DustinGreer@seamarchc.org Projected Completion Date: 3/31/2025

View Audit 334705

Finding 516743 (2024-001)

Significant Deficiency 2024

Sea Mar Community Health Center and Subsidiaries

WA

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Finding Reference Number: 2024-001. Corrective Action: Sea Mar will follow up with additional training on the sliding fee scale for all employees who issue the discount to patients. This training will be done via Relias, which is Sea Mar's web-based training platform. A score of 100% will be require...

Finding Reference Number: 2024-001. Corrective Action: Sea Mar will follow up with additional training on the sliding fee scale for all employees who issue the discount to patients. This training will be done via Relias, which is Sea Mar's web-based training platform. A score of 100% will be required to pass. Employees who do not score 100% will be retrained and will retake the test. Sea Mar has set a goal to achieve accuracy percentage of 95% and achieved its goal with 97% pass rate, but still had a finding on the audit because Sea Mar did not reach 100%. Sea Mar conducts monthly audits to monitor accuracy. Sea Mar will continue to use a process that will require supervisors to review and sign off on employee's income verifications to ensure they are accurate. Supervisors will be expected to ensure this process is being conducted accurately at their sites and to retrain staff who are not accurately verifying income. This review and sign off process will be verified during the quarterly audit. The quarterly audit will also identify sites and staff who need additional training. Name of Contact Person: Harshiem Ross, Senior Vice President of Operations, HarshiemRoss@seamarchc.org Projected Completion Date: 3/31/2025

View Audit 334705

Finding 516733 (2024-001)

Significant Deficiency 2024

Springville Community and Rural Foundation, Inc. D/b/a Springville Community Academy

IN

Subrecipient Monitoring Procurement, Suspension & Debarment Significant Deficiency § 200.317 § 200.318 § 200.327

December 18, 2024 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 Subject: Response to Uniform Guidance Audit Finding for FY23-24 Finding 2024-001 Procurement Significant Deficiency Federal Program: Charter Schools Program Assistance Listing Numbers: 84.282A Springville C...

December 18, 2024 Donovan CPAs 9292 N. Meridian Street, Suite 150 Indianapolis, IN 46260 Subject: Response to Uniform Guidance Audit Finding for FY23-24 Finding 2024-001 Procurement Significant Deficiency Federal Program: Charter Schools Program Assistance Listing Numbers: 84.282A Springville Community Academy (SCA) plans to develop a written procurement policy that incorporates the Federal regulations and procurement standards identified in §200.317 through 200.327. I, Corbin Dietrich, will work with the Board of Directors of SCA and our consultants with Indiana Charters to develop the appropriate procurement policies and procedures. We plan to draft and approve the required policies at the board meeting in January 2025. Sincerely, Corbin Dietrich, Treasurer

View Audit 334699

Finding 516717 (2024-005)

Material Weakness 2024

Bolivar-Richburg Central School District

NY

Cash Management Reporting

Bank Reconciliations, Interfund Balances Reconciliations and Other Balance Sheet Accounts Year ended June 30, 2024 Auditors’ Recommendation: We recommend that the District prepare bank reconciliations soon after the end of each month. As part of the reconciliation process the District’s general ledg...

Bank Reconciliations, Interfund Balances Reconciliations and Other Balance Sheet Accounts Year ended June 30, 2024 Auditors’ Recommendation: We recommend that the District prepare bank reconciliations soon after the end of each month. As part of the reconciliation process the District’s general ledger cash balances should be compared against the bank reconciliation, with any differences being immediately investigated. Once complete, the bank reconciliation should be reviewed by someone independent of the preparer. In addition, a worksheet should be developed which reconciles interfund balances on a monthly basis. Any differences in the reconciliation process should be immediately investigated. We recommend that asset and liability accounts be reconciled on a regular and routine basis. Further, reconciliations should be reviewed by management to ensure their accurate and timely completion. District’s Response: The School Business Administrator, Amy Ginnitti, and Treasurer, Hilary Hadden, will ensure that bank reconciliations are prepared in a timely manner and verify that balances within the general ledger cash accounts agree to the bank reconciliation, along with ensuring that interfund balances reconcile and that balance sheet asset and liabilities are reconciled to supporting documentation for the year ending June 30, 2025.

View Audit 334694

Finding 516701 (2024-004)

Material Weakness 2024

Bolivar-Richburg Central School District

NY

Internal Control / Segregation of Duties

Adjusting Journal Entries, Required Disclosures and Draft Financial Statements Year ended June 30, 2024 Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and, in the future, under the new pronouncement, the District should continue to review and accept both...

Adjusting Journal Entries, Required Disclosures and Draft Financial Statements Year ended June 30, 2024 Auditor’s Recommendation: Although auditors may continue to provide such assistance both now and, in the future, under the new pronouncement, the District should continue to review and accept both proposed adjusting journal entries and footnote disclosures, along with the draft financial statements. School District’s Response: The District and School Business Administrator, Amy Ginnitti, has received, reviewed and approved all journal entries, footnote disclosures and draft financial statements proposed for the current year audit and will continue to review similar information for the year ending June 30, 2025. Further, the School Business Administrator, Amy Ginnitti, believes she has a thorough understanding of these financial statements and the ability to make informed judgments based on these financial statements.

View Audit 334694

Finding 516700 (2024-003)

Material Weakness 2024

Verdugo Tower, Inc.

CA

HUD Housing Programs

Reporting views of responsible officials: The Company will repay the erroneous withdrawal from the Replacement Reserve. Auditors' summary of auditee's comments on the findings and recommendations: The Company repaid the erroneous withdrawal from the Replacement Reserve. On August 13, 2024 the Com...

Reporting views of responsible officials: The Company will repay the erroneous withdrawal from the Replacement Reserve. Auditors' summary of auditee's comments on the findings and recommendations: The Company repaid the erroneous withdrawal from the Replacement Reserve. On August 13, 2024 the Company transferred $196,334 to the Replacement Reserve. Response indicator: Agree. Response: The Company repaid the erroneous withdrawal from the Replacement Reserve on August 13, 2024. Completion date: August 13, 2024

View Audit 334688

Finding 516699 (2024-002)

Material Weakness 2024

Verdugo Tower, Inc.

CA

Cash Management HUD Housing Programs

Reporting views of responsible officials: The Company will develop a plan to monitor the cash balances in the financial institutions to ensure that cash balances are maintained within HUD’s guidelines. Auditors' summary of auditee's comments on the findings and recommendations: The Company will de...

Reporting views of responsible officials: The Company will develop a plan to monitor the cash balances in the financial institutions to ensure that cash balances are maintained within HUD’s guidelines. Auditors' summary of auditee's comments on the findings and recommendations: The Company will develop a plan to monitor the cash balances in the financial institutions to ensure that cash balances are maintained within HUD’s guidelines. Response indicator: Agree. Response: The Company will work with the financial institutions to ensure that HUD’s requirements are followed. Completion date: September 30, 2024

View Audit 334688

Finding 516698 (2024-001)

Material Weakness 2024

Verdugo Tower, Inc.

CA

HUD Housing Programs

Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on the findings and recomm...

Reporting views of responsible officials: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Auditors' summary of auditee's comments on the findings and recommendations: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Response indicator: Agree. Response: The Company has already submitted the audit package to the Federal Audit Clearinghouse and the Company will timely file the audit package with the Federal Audit Clearinghouse in the future. Completion date: March 25, 2024

View Audit 334688

Finding 516693 (2024-002)

Significant Deficiency 2024

Crook County School District 1

WY

Internal Control / Segregation of Duties

Auditee Response: CCSD #1 acknowledges that, due to the small office staff, it makes it impractical for the District to achieve full separation of the accounting functions within the business office. CCSD #1 is unable to fully segregate the accounting functions of approval, accounting/ reconciling...

Auditee Response: CCSD #1 acknowledges that, due to the small office staff, it makes it impractical for the District to achieve full separation of the accounting functions within the business office. CCSD #1 is unable to fully segregate the accounting functions of approval, accounting/ reconciling, and asset custody. The District has mitigated the risks associated with this limitation through use of various compensating controls and segregating the functions to the extent reasonably possible. This has been accomplished by placing various security levels into the approval process for payroll and cash disbursements, and this is evidenced through an audit trail for approval at each level of approval process. Additionally, accounting reports are reviewed monthly for discrepancies and errors. The governing board is also involved in the approval process as the final authority over payment approval. The District has formal policy procedure manuals for accounting controls procedures and follows Wyoming State Statutes to mitigate, to the lowest level possible, any risk of errors or irregularities and to timely detect any such errors or irregularities. The accounting staff, management and the School Board are fully aware of the situation and are therefore on heightened awareness in performing their duties to further mitigate any risks that have not been mitigated.

View Audit 334684

Finding 516688 (2024-001)

Significant Deficiency 2024

Lawndale Christian Health Center and Affiliates

IL

Cash Management Matching / Level of Effort / Earmarking § 200.303 § 200.305

Action taken in response to finding: LCHC management has implemented a robust task-management software to assist with internal controls, especially when related to grant management. Furthermore, a cloud-hosted warehouse for internal procedures was implemented to properly manage the assignment and tr...

Action taken in response to finding: LCHC management has implemented a robust task-management software to assist with internal controls, especially when related to grant management. Furthermore, a cloud-hosted warehouse for internal procedures was implemented to properly manage the assignment and transfer of accounting roles/responsibilities like the review and approval of grant drawdown request. Name(s) of the contact person(s) responsible for corrective action: Jeff Nelson, Accounting and Financial Analysis Director Planned completion date for corrective action plan: 9/30/2024

View Audit 334674

Finding 516684 (2024-008)

Significant Deficiency 2024

Progressive Community Health Centers, Inc.

WI

Special Tests & Provisions Subrecipient Monitoring

The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we w...

The Organization is currently reviewing our sliding fee discount policy to switch from a percentage-based model to a flat fee model. This simplification should reduce our sliding fee adjustment errors, while maintaining compliance with the Health Center Program Compliance Manual. In addition, we will be implementing regular monitoring to ensure that patient accounts are accurate and reflect our posted sliding fee rates. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters. Official Responsible for Ensuring the Corrective Action Plan: Danielle Hahn, Progressive Community Health Center Chief Financial Officer. Planned Completion Date for the Corrective Action Plan: The Organization plans to obtain Board approval for the updated sliding fee discount program in March 2025 and will continue to monitor throughout the year.

View Audit 334670

Finding 516682 (2024-007)

Material Weakness 2024

Progressive Community Health Centers, Inc.

WI

Questioned Costs Reporting Allowable Costs / Cost Principles

The Organization is unable to amend its erroneously submitted FFR. As funds that had already been spent on expenditures within the initial period of performance were erroneously reported as needing to be carried over, no reallocation of grant expenditures was needed. The Organization has also review...

The Organization is unable to amend its erroneously submitted FFR. As funds that had already been spent on expenditures within the initial period of performance were erroneously reported as needing to be carried over, no reallocation of grant expenditures was needed. The Organization has also reviewed our internal process for FFR submission. In general, we do not have carryover on our FFR, and this error occurred due to the additional Covid-19 funding the organization had received. Relevant staff participated in a training focused on CHC grants management matters, including preparation of the FFR, in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters. Official Responsible for Ensuring the Corrective Action Plan: Danielle Hahn, Progressive Community Health Center Chief Financial Officer. Planned Completion Date for the Corrective Action Plan: The Organization has implemented the corrective action plan as of December 2024 and will continue to monitor throughout the year.

View Audit 334670 Questioned Costs: $1

Finding 516678 (2024-006)

Significant Deficiency 2024

Progressive Community Health Centers, Inc.

WI

Procurement, Suspension & Debarment

The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quart...

The Organization has reviewed our current process regarding suspension and debarment with vendors. We have increased documentation when adding new vendors to include our SAM.gov verification in our vendor file. In addition, we are working to identify an internal process to verify all vendors quarterly. While this process can manually be done, we are working to identify an automated process to ensure compliance for all vendors. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters. Official Responsible for Ensuring the Corrective Action Plan: Danielle Hahn, Progressive Community Health Center Chief Financial Officer. Planned Completion Date for the Corrective Action Plan: The Organization has implemented the corrective action plan as of December 2024 and will continue to monitor throughout the year.

View Audit 334670

Finding 516674 (2024-005)

Significant Deficiency 2024

Progressive Community Health Centers, Inc.

WI

Procurement, Suspension & Debarment § 200.318

The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters...

The Organization has historically addressed procurement in our finance manual., however we will create a stand-alone procurement policy that is monitored regularly to ensure compliance with Uniform Guidance. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters. Official Responsible for Ensuring the Corrective Action Plan: Danielle Hahn, Progressive Community Health Center Chief Financial Officer. Planned Completion Date for the Corrective Action Plan: The Organization plans to obtain Board approval for the updated procurement policy in January 2025 and will continue to monitor throughout the year.

View Audit 334670

Finding 516673 (2024-004)

Significant Deficiency 2024

Progressive Community Health Centers, Inc.

WI

Questioned Costs Allowable Costs / Cost Principles § 200.430

Upon identification of costs incurred prior to the beginning of the period of performance, the Organization identified allowable costs incurred within the period of performance and previously charged to program income in order to reallocate grant expenditures without creating other instances of nonc...

Upon identification of costs incurred prior to the beginning of the period of performance, the Organization identified allowable costs incurred within the period of performance and previously charged to program income in order to reallocate grant expenditures without creating other instances of noncompliance (such as cash management). Although the initial support provided to auditors contained instances of expenditures incurred prior to the beginning of the period of performance, expenditure justification has been updated to reflect corrections and all subsequent grant expenditure detail has been reviewed to ensure no recurrence in the subsequent period. The Organization has also reviewed our internal processes for cut-off procedures related to grant expenditures. We will implement additional internal controls at the end of the grant and the beginning of the grant to ensure accuracy of the salaries being posted are in the correct period of performance. We are also working with our accounting software vendor and payroll vendor to automate the allocation of grant salaries based on time and effort of each individual rather than after-the-fact allocations to grants. This will reduce the need to maintain manual spreadsheets to track staff by lining up grant expenditures with pay periods instead of monthly allocations. Further, relevant staff participated in a training focused on CHC grants management matters in December 2024 and will continue to look for learning opportunities to support and challenge compliance matters. Official Responsible for Ensuring the Corrective Action Plan: Danielle Hahn, Progressive Community Health Center Chief Financial Officer. Planned Completion Date for the Corrective Action Plan: The Organization has implemented the corrective action plan as of December 2024 and will continue to monitor throughout the year.

View Audit 334670 Questioned Costs: $1

Corrective Action Plans

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