Corrective Action Plans

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Corrective action plan: Dallas County HCVP will expand inspection capacity by hiring additional full-time and contractual inspectors, including an Inspector Supervisor to ensure timely completion of all inspections. Additionally, the Housing Supervisor will review inspection status regularly to ensu...
Corrective action plan: Dallas County HCVP will expand inspection capacity by hiring additional full-time and contractual inspectors, including an Inspector Supervisor to ensure timely completion of all inspections. Additionally, the Housing Supervisor will review inspection status regularly to ensure compliance with HUD­related inspection schedules. Increasing staffing levels will allow the program to meet HUD-required timeframes consistently and reduce the likelihood of delays. Implementation dates: September 30, 2026 Responsible persons: Kesete Yohannes, Assistant Director of Housing
Corrective action plan: Dallas County HCVP will expand inspection capacity by hiring additional full-time and contractual inspectors, including an Inspector Supervisor, to ensure timely completion of all inspections within HUD-required timeframes. Increasing staffing levels will enable the program t...
Corrective action plan: Dallas County HCVP will expand inspection capacity by hiring additional full-time and contractual inspectors, including an Inspector Supervisor, to ensure timely completion of all inspections within HUD-required timeframes. Increasing staffing levels will enable the program to meet HUD-required timeframes consistently and reduce the likelihood of delays. Additionally, the Housing Supervisor will review inspection status regularly to ensure compliance with HUD-related inspection schedules. Implementation dates: September 30, 2026 Responsible persons: Kesete Yohannes, Assistant Director of Housing
Corrective Action Plan: Dallas County HCVP leadership addressed EIV compliance during the April 2026 and May 2026 monthly staff meetings and will continue to emphasize the requirement. Review of meetings agendas dated April 22, 2026, and May 20, 2026, confirm that EIV compliance was discussed. Addit...
Corrective Action Plan: Dallas County HCVP leadership addressed EIV compliance during the April 2026 and May 2026 monthly staff meetings and will continue to emphasize the requirement. Review of meetings agendas dated April 22, 2026, and May 20, 2026, confirm that EIV compliance was discussed. Additionally, the HCVP Housing Supervisor issued an email to all staff reiterating the requirement to retain EIV reports for all transactions, including but limited to recertifications, interims, and relocations. Implementation Date: June 11, 2026 Responsible Party: Kesete Yohannes, Assistant Director of Housing
Corrective action plan: The Ryan White Grants Management Division will ensure the addition of enhanced controls to the existing subaward agreement template. Implementation dates: August 30, 2026 Responsible persons: Sonya Hughes, Assistant Director, Ryan White Grants Compliance
Corrective action plan: The Ryan White Grants Management Division will ensure the addition of enhanced controls to the existing subaward agreement template. Implementation dates: August 30, 2026 Responsible persons: Sonya Hughes, Assistant Director, Ryan White Grants Compliance
We concur with the finding and are implementing procedures to address all issues. The payroll allocation errors identified were caused by inconsistent application of time allocation procedures at the employee level and insufficient monitoring controls to detect misallocations in a timely manner. CAP...
We concur with the finding and are implementing procedures to address all issues. The payroll allocation errors identified were caused by inconsistent application of time allocation procedures at the employee level and insufficient monitoring controls to detect misallocations in a timely manner. CAP plans to reimburse the related unallowable costs to the Federal Government by June 30, 2026. To address these issues, CAP is enhancing its internal controls over payroll allocations. CAP will conduct mandatory refresher training for applicable staff on time allocation requirements to reinforce compliance expectations. Additionally, CAP has implemented a new accounting system that will allow for the use of validation rules designed to prompt time allocations when employees charged to federal funding engage in non-federal activities. CAP will also perform periodic reviews of payroll allocations to ensure that they align with employees’ current duties and funding sources, and these reviews will be documented and performed by personnel independent of the preparer. These actions are designed to improve the accuracy and consistency of payroll allocations and ensure compliance with federal cost principles. CAP expects to fully implement these corrective actions by June 2026.
We concur with the finding and are implementing procedures to address all issues. The untimely submission of the SF-425 resulted from deficiencies in internal controls during the fiscal year end closeout process. Specifically, responsibilities for tracking and submitting required federal reports wer...
We concur with the finding and are implementing procedures to address all issues. The untimely submission of the SF-425 resulted from deficiencies in internal controls during the fiscal year end closeout process. Specifically, responsibilities for tracking and submitting required federal reports were not sufficiently defined, and monitoring procedures did not ensure that reporting deadlines were met. CAP is implementing corrective actions to strengthen its reporting processes. These actions include establishing a formal reporting calendar that identifies all required federal reporting deadlines, clearly assigning responsibility and backup responsibility for report preparation and submission, and implementing a documented supervisory review process to verify that reports are submitted timely. These corrective measures are intended to ensure compliance with reporting requirements and improve accountability. CAP expects these actions to be fully implemented by 30 September 2026.
We concur with the finding and are implementing procedures to address all issues. Civil Air Patrol (CAP) experienced turnover in key positions within the General Counsel and Contracting offices, which resulted in a lapse in the consistent execution of procurement file review controls. As a result, c...
We concur with the finding and are implementing procedures to address all issues. Civil Air Patrol (CAP) experienced turnover in key positions within the General Counsel and Contracting offices, which resulted in a lapse in the consistent execution of procurement file review controls. As a result, certain required procurement reviews were not completed in accordance with CAP policy. CAP has since filled the vacant positions and initiated a comprehensive review of procurement files. This review includes the completion of the CAPF GCC-06 Procurement File Review Checklist, as required, and the retroactive reconciliation of procurement documentation to the extent practicable. In addition, CAP is strengthening internal controls by enhancing monitoring procedures to ensure procurement file completeness prior to closeout and providing targeted training to procurement and program staff on applicable federal and internal documentation requirements. CAP expects to complete the retrospective file review and fully implement these enhanced controls by 30 September 2026.
American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund – Assistance Listing No. 84.425 Recommendation: We recommend the District strengthen internal controls over ESSER-funded construction projects by ensuring all contracts contain required prevailing wage provisions ...
American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund – Assistance Listing No. 84.425 Recommendation: We recommend the District strengthen internal controls over ESSER-funded construction projects by ensuring all contracts contain required prevailing wage provisions when applicable. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: If given ESSER funding again we will ensure the district abides by the adequate controls for funded contracts. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund – Assistance Listing No. 84.425 Recommendation: We recommend the District establish and document formal procedures to ensure compliance with equitable services requirements for ESSER funds. These procedures should...
American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund – Assistance Listing No. 84.425 Recommendation: We recommend the District establish and document formal procedures to ensure compliance with equitable services requirements for ESSER funds. These procedures should include timely and meaningful consultation with private school officials, proper documentation of consultation and decision‑making, and ongoing monitoring to ensure services are provided in accordance with federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure compliance with equitable services to private schools. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund – Assistance Listing No. 84.425 Recommendation: We recommend the District implement written procedures that require timely preparation and retention of documentation supporting the work performed and allocation me...
American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund – Assistance Listing No. 84.425 Recommendation: We recommend the District implement written procedures that require timely preparation and retention of documentation supporting the work performed and allocation methodology and supervisory review/approval consistent with the District's policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district will ensure we are completing time and effort logs for staff who are federally funded. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
All programs Recommendation: We recommend the District implement procedures to monitor audit reporting deadlines and ensure the data collection form and reporting package are submitted to the Federal Audit Clearinghouse within the required timeframe. Explanation of disagreement with audit finding: T...
All programs Recommendation: We recommend the District implement procedures to monitor audit reporting deadlines and ensure the data collection form and reporting package are submitted to the Federal Audit Clearinghouse within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We had a different auditing firm and were under the impression they had submitted it. We will ensure we will not be late again and submit it on time. . Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend the District implement a formal process requiring documented evidence of review and approval of all reimbursement requests prior to submission, such as dated sign-offs or electronic approval records, to strengthen i...
Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend the District implement a formal process requiring documented evidence of review and approval of all reimbursement requests prior to submission, such as dated sign-offs or electronic approval records, to strengthen internal controls and ensure compliance with Federal requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will provide formal documentation by reviewing and signing the claims for approval of reimbursement requests before submission to the state. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend the District obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to ...
Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend the District obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM.gov. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will ensure the process of suspension and debarment checks are performed prior to entering into contracts. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend that the District develop, approve, and implement written standards of conduct in compliance with 2 CFR §200.318(c)(1)–(2). The standards should address individual and District conflicts of interest, restrictions on...
Child Nutrition Cluster – Assistance Listing No. 10.CNC Recommendation: We recommend that the District develop, approve, and implement written standards of conduct in compliance with 2 CFR §200.318(c)(1)–(2). The standards should address individual and District conflicts of interest, restrictions on gifts and gratuities, and disciplinary actions for violations, and should be communicated to all personnel involved in procurement activities. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will create a policy for conflict of interest requirements of Uniform Guidance. Name(s) of the contact person(s) responsible for corrective action: Stacy Rodriguez Director of Finance Planned completion date for corrective action plan: September 2025
Audit Finding Reference Number: 2025 – 003 Finding: NERACOOS submitted FFATA reports for the initial subaward agreements; however, the reports were not updated timely for subsequent subaward amendments. Specifically, amended subaward amounts and amendment dates were not reported timely and accuratel...
Audit Finding Reference Number: 2025 – 003 Finding: NERACOOS submitted FFATA reports for the initial subaward agreements; however, the reports were not updated timely for subsequent subaward amendments. Specifically, amended subaward amounts and amendment dates were not reported timely and accurately in SAM.gov. Corrective Action Plan: Develop a subaward amendment tracking log to record all subaward modifications, including amendment dates, revised subaward amounts, and FFATA reporting due dates. The log will be updated each time a subaward amendment is executed. Establish a written procedure requiring that any subaward amendment triggering a change in amount or key data be reported in SAM.gov within the required timeframe (no later than the end of the month following the month in which the obligation or award was made). Designate a staff member responsible for FFATA reporting compliance and assign a backup to ensure coverage during absences. Implement a quarterly reconciliation between executed subaward agreements/amendments and SAM.gov reporting records to identify and remediate any unreported or inaccurate entries. Provide training to relevant Finance and Grants Management staff on FFATA reporting requirements under 2 CFR Section 200.332 and SAM.gov reporting procedures. Retroactively update SAM.gov for any subaward amendments identified during the audit as not having been reported or reported inaccurately. Responsible Official: Jake Kritzer, Executive Director Anticipated Completion Date: August 31, 2026 (retroactive corrections); ongoing quarterly reconciliation beginning July 2026
Audit Finding Reference Number: 2025 – 002 Finding: NERACOOS recorded federal grant revenue for certain grants related to FY2025 activities in FY2026, based on the timing of reimbursement receipts rather than when the underlying expenditures were incurred. As a result, federal grant revenue and rela...
Audit Finding Reference Number: 2025 – 002 Finding: NERACOOS recorded federal grant revenue for certain grants related to FY2025 activities in FY2026, based on the timing of reimbursement receipts rather than when the underlying expenditures were incurred. As a result, federal grant revenue and related receivables for FY2025 were understated, while revenue in FY2026 was overstated for the related amounts. In addition, this may lead to misstatements in financial reporting if similar cutoff issues occur in future periods. Corrective Action Plan: Develop and implement a formal year-end revenue cutoff checklist specifically for federal grants. The checklist will require a review of all active federal awards within 60 days and then again in 30 days of fiscal year-end to identify allowable expenditures incurred but not yet reimbursed. Establish a procedure to record grant receivables and revenue accruals for identified unbilled costs prior to closing the accounting records each fiscal year. Train the Finance staff responsible for grant accounting on the accrual basis requirements under 2 CFR Part 200 and proper cutoff procedures. Incorporate a supervisory review step into the year-end close process to verify that all grant-related receivables and revenue accruals have been posted before the books are closed. Incorporate the cutoff review into the annual audit preparation timeline and document results for auditor review. Review the FY2025 federal financial reports submitted for CFDA 11.012 to determine whether any amendments or corrections are required, and coordinate with the federal agency as appropriate. Prior to submission of any federal financial reports (e.g., SF-425 Federal Financial Reports), confirm that recorded grant revenue and expenditures reflect all accrued amounts throughout the reporting period. Review draft federal financial reports against the general ledger before submission to verify consistency between reported and recorded amounts. Responsible Official: Jake Kritzer, Executive Director Anticipated Completion Date: September 30, 2026
FINDING 2025-004 The City does not have documented procurement policies and procedures in place as required by the Uniform Guidance. Furthermore, the City did not monitor contractor compliance with BABA provisions. Management’s Response The City will adopt documented procurement policies and procedu...
FINDING 2025-004 The City does not have documented procurement policies and procedures in place as required by the Uniform Guidance. Furthermore, the City did not monitor contractor compliance with BABA provisions. Management’s Response The City will adopt documented procurement policies and procedures and monitor contractor compliance with BABA provisions in FY 2026.
Poverty and Social Reform Institute Dba Leaps and Bounds Family Services has updated the policies and procedures for the agency to reflect the Uniform Guidance requirements regarding the process and controls used to administer federal awards. These changes address the issue of non-compliance by form...
Poverty and Social Reform Institute Dba Leaps and Bounds Family Services has updated the policies and procedures for the agency to reflect the Uniform Guidance requirements regarding the process and controls used to administer federal awards. These changes address the issue of non-compliance by formally addressing the roles and responsibilities in writing of who at the agency is responsible for insuring that the Uniform Guidance is followed. The updated policy covers the areas of: allowable costs, cash management, procedures, and conflicts of interest. The new policy will be presented and reviewed for approval at the July 22nd, 2026, board meeting. We believe this corrective action plan will address the non-compliance and bring the agency into full compliance moving forward.
Comment #2025-001 COMPENSATION METHODOLOGY SHOULD BE REVIEWED FOR INCENTIVE PAYMENTS COMMUNITY SERVICES BLOCK GRANT AND LOW-INCOME HOME ENERGY ASSISTANCE PROGRAM FAL #93.569 and 93.568 Views of Responsible Officials and Planned Corrective Actions: Management concurs with the recommendation. FACAA up...
Comment #2025-001 COMPENSATION METHODOLOGY SHOULD BE REVIEWED FOR INCENTIVE PAYMENTS COMMUNITY SERVICES BLOCK GRANT AND LOW-INCOME HOME ENERGY ASSISTANCE PROGRAM FAL #93.569 and 93.568 Views of Responsible Officials and Planned Corrective Actions: Management concurs with the recommendation. FACAA updated its Incentive Compensation Policy, which was approved by the Board of Directors, in accordance with 2 CFR 200.430 and 2 CFR 200.303. The policy establishes the methodology for incentive payments, and all incentive payments have been documented and supported by appropriate records to ensure compliance with applicable federal requirements. Implementation Date: Effective immediately, our policies have been enhanced to clarify and support our methodology used during the periods noted under review, and for all subsequent periods. Responsible Person(s): Dr. Howard Grant, President/CEO
Actions Planned - The Authority is not in position to hire additional staff members for the sole purpose of eliminated the segregation of duties finding from our audit. The Airport Office Adminstrator communicates with the Executive Director and commission members regarding all major account transac...
Actions Planned - The Authority is not in position to hire additional staff members for the sole purpose of eliminated the segregation of duties finding from our audit. The Airport Office Adminstrator communicates with the Executive Director and commission members regarding all major account transactions, including the recording of recurring and non-recurring jounral entry adjustments. The commission meets monthly and closely monitors the financial information provded to them. Official responsible: Airport Office Administrator Planned Completion Date - On-going monitoring Disagreement with Finding - none, the Authority concurs with the finding. Plan to Monitor - The Authority is aware of the situation and will monitor, as it deems appropriate. Monitoring will include commission member oversight for the interim and year-end reporting.
Finding 1220053 (2025-002)
Material Weakness 2025
Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Ionia County, Michigan (the County), Single Audit report for the year ended December 31, 2025, and corrective actions to be completed. 2025-002 – Procurement, Suspensi...
Pursuant to federal regulations, Uniform Administrative Requirements Section 200.511, the following are the findings as noted in the Ionia County, Michigan (the County), Single Audit report for the year ended December 31, 2025, and corrective actions to be completed. 2025-002 – Procurement, Suspension and Debarment Auditor Description of Condition and Effect. While the County indicated that they have been completing suspension and debarment checks on County vendors in the past, evidence of these suspension and debarment checks was not retained and made available for audit. As a result of this condition, the County was exposed to the risk that disbursements of federal awards would be made to vendors suspended or debarred by the federal government and subject to disallowance by the grantor. Auditor Recommendation. We recommend that the County verify that any of their vendors with $25,000 spent with federal funds were not suspended or debarred and that documentation of these procedures be retained. Corrective Action. The County will review vendors over $25,000 spent with federal funds to ensure that they are not suspended or debarred and retain documented support for the procedures performed. Responsible Person. Chad Shaw, County Administrator Anticipated Completion Date. December 31, 2026
Our district plans to adhere to the Davis-Bacon Act when utilizing federal funding.
Our district plans to adhere to the Davis-Bacon Act when utilizing federal funding.
Description of Finding: The organization did not complete and submit its Single Audit within the required timeframe due to special projects (mortgage sales) that dramatically limited staff bandwidth in key financial management positions, resulting in delays in audit coordination and reporting and th...
Description of Finding: The organization did not complete and submit its Single Audit within the required timeframe due to special projects (mortgage sales) that dramatically limited staff bandwidth in key financial management positions, resulting in delays in audit coordination and reporting and the timing of commencing the audit.Statement of Concurrence: The organization concurs with this finding.Corrective Action: The organization has resolved the underlying cause of this finding by streamlining the data collection process related to mortgage sales transactions. Furthermore, the organization is in the process of reorganizing the financial department to streamline workflows. The Staff Accountant in partnership with the Director of Finance & Administration are responsible for oversight of financial reporting, compliance with Uniform Guidance (2 CFR Part 200), and coordination of the Single Audit process.Corrective actions implemented include:• Departmental reorganization is underway to streamline workflows and provide clear ownership of departmental responsibilities (including single audit compliance) between Staff Accountant and Director of Finance and Administration.• Development of a formal audit timeline and internal milestones to ensure timely audit initiation, completion, and submission.• Strengthening of internal controls over financial reporting and audit documentation.• Ongoing communication and coordination with external auditors to ensure compliance with federal audit requirements. These actions ensure that future Single Audits will be completed and submitted timely in accordance with Uniform Guidance.Status of Finding: This finding resulted from unexpected special projects that limited financial staff bandwidth as well as fragmented workflows, which have both been addressed. Corrective action is in process.Projected Completion Date: Corrective action completed as of 6/5/2026, with ongoing monitoring incorporated into standard financial management procedures.
Finding 1220032 (2025-003)
Material Weakness 2025
SRC will reinforce its price analysis internal controls by providing staff with additional training on SPP 3.2, Performing a Price Analysis. SRC will also strengthen its internal controls to ensure proper price analyses are performed for all applicable purchases in accordance with FAR 15.404(b)(2)(i...
SRC will reinforce its price analysis internal controls by providing staff with additional training on SPP 3.2, Performing a Price Analysis. SRC will also strengthen its internal controls to ensure proper price analyses are performed for all applicable purchases in accordance with FAR 15.404(b)(2)(ii)(A). Contact Person Responsible for Corrective Action: Victor Burdukov, Manager, Subs & Procure Compliance Completion Date: Training, review of policy and procedures will be completed by September 30, 2026.
Finding 1220031 (2025-002)
Material Weakness 2025
SRC will revise its Labor Recording Policy to establish a specific timeframe for the replacement of all interim employee signatures and supervisory approvals. While SRC believes that strong internal controls are currently in place for this process, we will review these controls and make updates as n...
SRC will revise its Labor Recording Policy to establish a specific timeframe for the replacement of all interim employee signatures and supervisory approvals. While SRC believes that strong internal controls are currently in place for this process, we will review these controls and make updates as needed to ensure continued compliance and effective monitoring. Contact Person Responsible for Corrective Action: Lisa Kennedy, Director, Corporate Controller Completion Date: Review of policy and procedures will be completed by September 30, 2026.
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