Corrective Action Plans

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Condition 1 & 2: Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management. Condition 3: The Budget Division will...
Condition 1 & 2: Effective FY2025, the Accounting Division is now required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted to the Finance Secretary only after approval by Accounting Management. Condition 3: The Budget Division will now be required to prepare drawdown request forms using the detailed expenditure report (journal listing). Each request is submitted onto the portal only after approval by Budget Management.
Condition 1: There is currently a MOF process in place when creating a new budget (SPG) account, in which all relevant documents are uploaded to the FMIS prior to releasing the budget, including the notice of award, budget narrative, and workplan. Furthermore, Management has reiterated that all supp...
Condition 1: There is currently a MOF process in place when creating a new budget (SPG) account, in which all relevant documents are uploaded to the FMIS prior to releasing the budget, including the notice of award, budget narrative, and workplan. Furthermore, Management has reiterated that all supporting documents must be attached, including those supporting cost allocation and grantor-approved system vouchers for generally unallowable expenses. Condition 2: Effective FY2025, payroll supporting documentation, including signed leave slips, is required to be uploaded into the FMIS. In addition, effective February 2026, approved overtime requests will now be uploaded into the system to verify authorization prior to payroll processing.
The Ministry acknowledges this finding and notes that the inability to reconcile the staff list was primarily due to the system migration from 4Gov to the new FMIS, which required additional time to review and make necessary adjustments. As a corrective measure, all personnel must be entered into th...
The Ministry acknowledges this finding and notes that the inability to reconcile the staff list was primarily due to the system migration from 4Gov to the new FMIS, which required additional time to review and make necessary adjustments. As a corrective measure, all personnel must be entered into the system using their RMI Social Security Number, legal names, and confirmation from the Budget Division regarding the funding source to support payroll. The Budget Division is now required to upload all supporting documents into FMIS prior to establishing and releasing funds. Any changes to the approved budget narrative must include an official communication from the grantor, which must also be uploaded. Requests will not be processed without the required documentation.
Condition 1: #1–4, #5–7, #11–13: The MOF requires that all necessary documents, including expenditure and financial reports, be submitted prior to the release of subsequent funding. These reports are reviewed and processed by the Compliance Unit once complete. #8-9, #10, #12: The MOF, through the Co...
Condition 1: #1–4, #5–7, #11–13: The MOF requires that all necessary documents, including expenditure and financial reports, be submitted prior to the release of subsequent funding. These reports are reviewed and processed by the Compliance Unit once complete. #8-9, #10, #12: The MOF, through the Compliance Unit, enforces payment terms strictly in accordance with the relevant memoranda of agreement. Condition 2: The subrecipient monitoring tool will be consolidated and used by the Budget Division, SOEMU, and the Compliance Unit. Once MOAs are drafted, the preparer will update the monitoring tool, which will then be reviewed by the Compliance Unit for completeness and accuracy against the Appropriation Act. Condition 3: The subrecipient monitoring tool will be updated to track the time elapsed between the transfer of Federal funds to the subrecipient and the disbursement of those funds for program purposes.
Conditions 1-3: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Con...
Conditions 1-3: The MOF acknowledges this finding and will address the deficiencies by reinforcing documentation and compliance requirements. Annual refresher training will be provided to current staff, and onboarding will be conducted for new staff to ensure adherence to established procedures. Condition 4: The MOF acknowledges this finding and notes that screening for debarred, suspended, or excluded entities was incorporated into the Grants and Sub-Grants Monitoring Procedures Manual in November 2024. The Ministry further confirms that this requirement will be enforced immediately.
Condition 1: The new FMIS includes built-in controls to monitor the period of performance, including tracking the last day for encumbrances and payments, ensuring timely and accurate financial management. Condition 2: In FY2025, all invoices with corresponding purchase orders are uploaded into the s...
Condition 1: The new FMIS includes built-in controls to monitor the period of performance, including tracking the last day for encumbrances and payments, ensuring timely and accurate financial management. Condition 2: In FY2025, all invoices with corresponding purchase orders are uploaded into the system by the Procurement & Supply Division. Once uploaded, the Accounting Division reviews and processes payments accordingly. Additionally, Accounting Management reinstated the pre- review of payment request vouchers with corresponding BRVs prior to payment issuance to strengthen controls and ensure compliance. Condition 3: A control process is currently in place whereby each Notice of Award (NOA) is assigned to a single, corresponding SPG account. Condition 4: NOAs and all relevant grant documents are required to be uploaded to Bisan at the time a new SPG account is created.
Condition 1: #1 In FY2025, the Accounting Management reinstated the pre- review of payment voucher requests to ensure all payments are properly reviewed prior to issuance. #2 Effective 3rd qtr. of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment ...
Condition 1: #1 In FY2025, the Accounting Management reinstated the pre- review of payment voucher requests to ensure all payments are properly reviewed prior to issuance. #2 Effective 3rd qtr. of FY2025, all transactions charged to the Enewetak grant go through the national procurement and payment process. Condition 2: #1 In early June 2025, a memo was issued to all Ministries and Agencies instructing that payroll will not be approved without submission of leave slips. #2 Same response as Condition 1 #2
Management acknowledges the finding and commits to taking corrective action. A thorough review of the factors contributing to the late filing will be conducted, and procedural enhancements will be implemented to ensure timely compliance with the submission requirements outlined in the Uniform Guidan...
Management acknowledges the finding and commits to taking corrective action. A thorough review of the factors contributing to the late filing will be conducted, and procedural enhancements will be implemented to ensure timely compliance with the submission requirements outlined in the Uniform Guidance. Management will also establish monitoring mechanisms to prevent future occurrences of late filings and ensure ongoing compliance.
Finding 1171703 (2023-013)
Material Weakness 2023
Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developi...
Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of Federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on Grants and Awards. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.
Finding 1171702 (2023-012)
Material Weakness 2023
Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developi...
Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as revenue loss, we would not have to submit the report annually. The final reporting was submitted prior to deadline.
Finding 1171701 (2023-011)
Material Weakness 2023
Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on ...
Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.
Finding 1171700 (2023-010)
Material Weakness 2023
Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk's administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to up...
Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk's administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to update procedures and build stronger internal controls, • developing and formalizing policies to ensure full compliance with federal grant requirements, • and improving communication between offices to ensure federal reporting is accurate and timely. Our collective commitment is to put permanent measures in place to prevent these issues from recurring and to uphold the highest level of compliance for all federal programs. County Clerk: I was not the County Clerk in office at this time. The County will comply with all aspects of grant reporting and requirements. The Officials will work together to put policies and procedures in place to ensure more accurate reporting. County Treasurer: The County Officers will work on better communication to more accurately report the SEFA funds.
Finding 1171699 (2023-009)
Material Weakness 2023
Chairman of the Board of County Commissioners: These findings trace back to gaps under the prior Clerk's administration and her lack of cooperation with the Board of County Commissioners, but our focus is on fixing the problems, not dwelling on them. Under the current leadership, the Board of County...
Chairman of the Board of County Commissioners: These findings trace back to gaps under the prior Clerk's administration and her lack of cooperation with the Board of County Commissioners, but our focus is on fixing the problems, not dwelling on them. Under the current leadership, the Board of County Commissioners, the new County Clerk and the other elected officials have made addressing these control weaknesses a priority. Together, we are: • strengthening county-wide policies and procedures to meet federal compliance requirements • improving communication and oversight to ensure accurate and timely federal reporting • and establishing clear standards and training for all reporting officers to prevent inaccurate or untimely reporting. Our collective goal is to build a stronger, more accountable system that ensures federal programs are managed with the highest level of integrity. County Clerk: I was not the County Clerk in office at this time. Ensure that the County has standards in place that will deter inaccurate and untimely reporting. In addition, those reporting have the knowledge and understanding to properly report. County Treasurer: The County Officers will work on better communication to more accurately report the Schedule of Expenditures of Federal Awards (SEFA) funds.
Management has been in contact with their funders regarding the late submission and no action is expected. Management will arrange for future audits and submissions to be performed timely
Management has been in contact with their funders regarding the late submission and no action is expected. Management will arrange for future audits and submissions to be performed timely
View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges this findingrelated to federalaward financialmanagementduringfiscalyear 2023.Drawdownswere previouslymanaged by theorganization’s externalaccounting firm,and internalreviewbystaffnolongerwith theorganization was notsuf...
View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges this findingrelated to federalaward financialmanagementduringfiscalyear 2023.Drawdownswere previouslymanaged by theorganization’s externalaccounting firm,and internalreviewbystaffnolongerwith theorganization was notsufficiently consistent.These issues were a keyfactorin management’sdecisionto endtherelationship with theprioraccounting firm. We transitioned all drawdown and reimbursement responsibilities internally. We required management review and initialing of all drawdowns prior to submission. We implemented standardized reconciliation processes tying drawdowns to the general ledger by reporting period. We retained all drawdown support directly within QuickBooks to document how totals were calculated. We developed grant-specific allocation roadmaps. We established a centralized grant file system for all federal financial documentation. We engaged a new accounting firm for compliance support and oversight. All drawdowns and reimbursements are reviewed and approved by the Executive Director prior to submission, with ongoing oversight from the accounting firm. Corrective actions have been implemented and are operating on an ongoing basis.
View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges anisolated payrollprocessingerrorduringfiscalyear2023in which overtime hours werenotproperlyenteredforoneemployee.Thiserrordidnotresultinquestionedcosts,asreimbursedpayrollexpenseswere less thanactualpayrollcosts incur...
View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges anisolated payrollprocessingerrorduringfiscalyear2023in which overtime hours werenotproperlyenteredforoneemployee.Thiserrordidnotresultinquestionedcosts,asreimbursedpayrollexpenseswere less thanactualpayrollcosts incurred. We retrained staffonpayrollprocessingwithemphasis onovertimeentry andverification.Weupdatedpayrollprocesses toensurepayrollstaffarenotifiedwhen overtime isapproved.Weimplementedpre-processingpayrollreconciliation andsupervisoryreviewpriortofinalsubmission.Payrollentries are subjectto supervisory reviewand periodic spotchecks.Correctiveactions havebeenimplementedand are operating onanongoingbasis.
View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges this findingrelatedtoinconsistentretentionoflease extensionsorrenewals forrentalassistanceprovided beyond originallease terms duringfiscalyear2023.Originalleases were retained forallparticipants;however,extensionsweren...
View ofResponsible Officials and Planned CorrectiveActions:Managementacknowledges this findingrelatedtoinconsistentretentionoflease extensionsorrenewals forrentalassistanceprovided beyond originallease terms duringfiscalyear2023.Originalleases were retained forallparticipants;however,extensionswerenotconsistently obtained. We implementedalease trackingprocess to monitorlease expirationdates.Weupdatedproceduresto requirelease renewalsorextensions priorto issuingassistancebeyondtheoriginallease term.Weimplementedstandardizedfile checklists.Supervisorystaffconductperiodic filereviewsto confirmleasedocumentation coverage.Corrective actionshavebeenimplementedand are operatingonanongoingbasis.
View of Responsible Officials and Planned Corrective Actions: Management acknowledges this finding related to documentation retention for a single participant-related expense during fiscal year 2023. While isolated in nature, management recognizes the importance of complete documentation to support ...
View of Responsible Officials and Planned Corrective Actions: Management acknowledges this finding related to documentation retention for a single participant-related expense during fiscal year 2023. While isolated in nature, management recognizes the importance of complete documentation to support allowability under Uniform Guidance. We updated procedures to require receipt and verification of all required documentation prior to charging costs to federal awards. We implemented standardized documentation checklists to support consistent compliance. We reinforced documentation standards through staff training and supervisory review to ensure proper adherence. Supervisory staff conduct periodic file reviews prior to reimbursement and drawdown activity. Corrective actions have been implemented and are operating on an ongoing basis.
VITEMA concurs with this finding. VITEMA uses the sub-recipient agreement as the source of documentation for enrollment into FFATA. This agreement is signed by the Director of VITEMA and Sub Recipient. VITEMA's Grant Management staff will upload this information into the FRS/SAMS.GOV system. VITEMA'...
VITEMA concurs with this finding. VITEMA uses the sub-recipient agreement as the source of documentation for enrollment into FFATA. This agreement is signed by the Director of VITEMA and Sub Recipient. VITEMA's Grant Management staff will upload this information into the FRS/SAMS.GOV system. VITEMA's Deputy Director of Grants Management will review the FFTA information and validate that the information is true and correct based on the amount approved by DHS and sub-recipient agreement. This FFTA document will be signed and dated by the Deputy Director of Grants Management within the 30 days of required enrollment.
VITEMA concurs with this finding. This information is documented in BSIR as part of the submittal process and does not allow for the submittal of reporting if not verified to meet this requirement. VITEMA will also document this information when preparing the SF 425 report by including this informat...
VITEMA concurs with this finding. This information is documented in BSIR as part of the submittal process and does not allow for the submittal of reporting if not verified to meet this requirement. VITEMA will also document this information when preparing the SF 425 report by including this information in the notes section of this report. This will be conducted on a quarterly basis.
The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the recipient, it is the territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient a...
The formal process for completing and retaining Subrecipient Agreements is now operational to ensure compliance with programmatic obligations. As the recipient, it is the territory's responsibility to notify the Subrecipient when the federal funds are obligated and provide them with a subrecipient agreement which outlines the terms and conditions of the program. The Disaster Program Financial Specialist is responsible for obtaining the subrecipient agreement and ensure it has been signed by the Applicant/Subrecipient and Governor's Authorized Rep and later provided to the Territorial Public Assistance Officer (TPAO). As such, no funds will be disbursed until the Subrecipient signs and returns the agreement. These agreements are saved in a centralized location for documentation and audit purposes. In accordance with the 2CFR #200 Subpart F, all Subrecipients must comply with applicable audit requirements because the applicant is in the receipt of federal funding. Under 2CFR #200.500 Subpart F applies to any non-federal entity that expends $750,000 or more in federal awards during a fiscal year. Subrecipients meeting this threshold are required to undergo a single audit or a program specific audit for that fiscal year. The TPAO will review audit requirements during the applicant's briefing and will incorporate these requirements into the Subrecipient Agreement.
In accordance with 2CFR #200.303 federal recipients VITEMA/ODR must create internal controls that provide reasonable assurance that FFATA reporting requirements are met. Currently, internal controls have been established to ensure compliance with the Federal Funding Accountability and Transparency A...
In accordance with 2CFR #200.303 federal recipients VITEMA/ODR must create internal controls that provide reasonable assurance that FFATA reporting requirements are met. Currently, internal controls have been established to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA). On a monthly basis, the Disaster Program Administrative Assistant in responsible for obtaining the P5 report from the Grants Manager and entering all project with obligated funds exceeding $30,000 into the SAM.gov database, formerly FSRS.gov. The report must be submitted by the end of the following month. Once the data is entered, the Territorial Public Assistance Officer reviews the submission and, upon the verification, certifies that the information has been accurately reported in the federal database. The reports and associated certifications will be placed in a centralized database.
DHS continues working with a vendor on the implementation of the Provider Enrollment Application (PEA). Beginning in February 2026, the vendor will assume responsibility for enrolling all USVI providers—both in-territory and out-of-territory. Their enrollment process will address the three bulleted ...
DHS continues working with a vendor on the implementation of the Provider Enrollment Application (PEA). Beginning in February 2026, the vendor will assume responsibility for enrolling all USVI providers—both in-territory and out-of-territory. Their enrollment process will address the three bulleted conditions.
The Department understands the importance of System Security and recognizing its weaknesses and vulnerabilities. In lieu of this, we have conducted an overall cybersecurity risk assessment for entire IT infrastructure. The Department’s strategy to become compliant with the VIBES System Security Revi...
The Department understands the importance of System Security and recognizing its weaknesses and vulnerabilities. In lieu of this, we have conducted an overall cybersecurity risk assessment for entire IT infrastructure. The Department’s strategy to become compliant with the VIBES System Security Review includes updating the scope of work with contracted vendor for this system. The scope of work will now include annual Risk Assessments and Security Reviews.
The Department of Human Services intends to shift the responsibility of Cost Reports internally to Fiscal Office, under the supervision of the Director of Audit and Compliance. The first step towards this initiative will require a contract to be executed, and subsequently the utilization of a templa...
The Department of Human Services intends to shift the responsibility of Cost Reports internally to Fiscal Office, under the supervision of the Director of Audit and Compliance. The first step towards this initiative will require a contract to be executed, and subsequently the utilization of a template for quick calculation. We consider this a high-priority initiative that will provide much-needed revenues to the coffers. Once the contract has been executed, goal is to be up-to-date within 6-9 months.
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