Corrective Action Plans

Finding 1164721 (2023-002)

Material Weakness 2023

IL

Allowable Costs / Cost Principles § 200.430

Since January of 2024, CRA has done the following: Created a Human Resources Department, which did not exist before. Hired a Full Time Human Resources Director to oversee the department. Initiated a comprehensive Human Resources system where staff can review their pay, track their time, and review b...

Since January of 2024, CRA has done the following: Created a Human Resources Department, which did not exist before. Hired a Full Time Human Resources Director to oversee the department. Initiated a comprehensive Human Resources system where staff can review their pay, track their time, and review benefits. Initiated the process of uploading personnel information to our new system, while keeping backups secured in our Google Nonprofit workspace - including hiring documentation and change of status forms for employees.

View Audit 374435

Finding 1164634 (2023-004)

Material Weakness 2023

Northeast Treatment Centers, Inc.

PA

Internal Control / Segregation of Duties

Recommendation: We recommend that management ensures that there is documented approval for all employees’current pay rates and that a copy of all employee’s work documents (I-9, W4, background checks) are kept on file in line with the Centers’ policies Explanation of Disagreement with Audit Finding:...

Recommendation: We recommend that management ensures that there is documented approval for all employees’current pay rates and that a copy of all employee’s work documents (I-9, W4, background checks) are kept on file in line with the Centers’ policies Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented a new payroll system and new policies within the HR department to ensure documentation is maintained electronically to support pay rates as well as maintaining all employee documents, including I-9, W4 and background checks. Name of the contact person responsible for corrective action: Regan Kelly, CEO of NorthEast Treatment Centers, Inc. (215) 451-7000

View Audit 374237

Finding 1164633 (2023-003)

Material Weakness 2023

Net Treatment Services, Inc. D/b/a Net Community Care

PA

Questioned Costs Student Financial Aid Cash Management

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E & Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing Numbers: 93.658 & 93.645 Federal Award Identification Number and Year: 21-20016 (2023) & 21-20017 (2023) Award Period: J...

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E & Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing Numbers: 93.658 & 93.645 Federal Award Identification Number and Year: 21-20016 (2023) & 21-20017 (2023) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Cash Management Recommendation: We recommend that management ensure that all invoices are based on actual expenses incurred and that there is a review an approval process of invoices before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Aciton take in response to finding: Management has implemented a policy which requires each invoice to be based only on actual expenses incurred for the period and prohibits the use of a straight-line calculation to draw down funds. Invoices are also approved by the CFO prior to submission for reimbursement. Name of contact person responsible for corrective action: Regan Kelly, CEO of NorthEast Treatment Cetners, Inc. (215) 451-7000 Planned completion date for corrective action plan: January 31, 2024

View Audit 374235 Questioned Costs: $1

Finding 1164572 (2023-001)

Material Weakness 2023

Strategic Capacity Group, Inc.

VA

STRATEGIC CAPACITY GROUP CORRECTIVE ACTION PLAN For the Year Ended December 31, 2023 U.S. DEPARTMENT OF STATE Strategic Capacity Group (SCG) submits the following corrective action plan for the year ended December 31, 2023. Independent Public Accounting Firm: CBIZ CPAs P.C. 1899 L Street NW, Suite 8...

STRATEGIC CAPACITY GROUP CORRECTIVE ACTION PLAN For the Year Ended December 31, 2023 U.S. DEPARTMENT OF STATE Strategic Capacity Group (SCG) submits the following corrective action plan for the year ended December 31, 2023. Independent Public Accounting Firm: CBIZ CPAs P.C. 1899 L Street NW, Suite 850 Washington, DC 20036 Audit Period: The finding from the December 31, 2023 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDING - FINANCIAL STATEMENT FINDINGS Finding No. 2023-001: Late Filing of Data Collection Form – Compliance Finding – All Federal Awards Criteria In accordance with the Uniform Guidance, the audit package and the Data Collection Form must be submitted within 30 days after receipt of the auditors’ report or nine months after the end of the fiscal year, whichever comes first. Condition and Context The Data Collection Form for the year ended December 31, 2023 was not submitted to the Federal Audit Clearinghouse by the September 30, 2024 deadline. Recommendation It was recommended that management continue its efforts to ensure that all filing requirements under federal awards are met. Views of Responsible Officials and Planned Corrective Actions SCG has consistently ensured that all audits preceding fiscal year 2023 were completed by the annual September 30 deadline. As this was a singular occurrence arising from SCG’s appeal to the U.S. Department of State on December 20, 2023 concerning differing interpretations surrounding the configuration and application of the Negotiated Indirect Cost Rate Agreement (NICRA), SCG believes no corrective action is warranted. SCG received a response to its appeal only on September 24, 2024. Had it not been for this unique circumstance and the timing of the U.S. Department of State’s appeal determination, SCG’s 2023 audit would have been completed and submitted by the required deadline of September 30, 2024. Contact Person Responsible for Corrective Action: Querine Hanlon, President _______________ If the US Department of State has questions regarding this plan, please call Querine Hanlon, President, (202) 746-7317. Sincerely, Querine Hanlon President Strategic Capacity Group

View Audit 374156

Finding 1164380 (2023-004)

Material Weakness 2023

Biddeford-Saco-Old Orchard Beach Transit Committee

ME

Procurement, Suspension & Debarment § 200.318

2023-004 Procurement, Suspension and Debarment The Committee acknowledges that certain procurement procedures were not followed, leading to a finding of noncompliance. To remedy this, on July 1, 2025 we put new workflow controls in place within our new integrated accounting software. These workflows...

2023-004 Procurement, Suspension and Debarment The Committee acknowledges that certain procurement procedures were not followed, leading to a finding of noncompliance. To remedy this, on July 1, 2025 we put new workflow controls in place within our new integrated accounting software. These workflows support compliance with our procurement policies and ensure all required supporting documentation, including forms for micro and small purchases, are secured and archived for capital purchases and grant expenditures. This will ensure that all procurement policies, which are in compliance with all FTA guidelines, are consistently followed.

View Audit 373784

Finding 1164368 (2023-003)

Material Weakness 2023

Biddeford-Saco-Old Orchard Beach Transit Committee

ME

Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.302

2023-003 Allowable Costs/Cost Principles: Written Financial Policies The Biddeford-Saco-Old Orchard Beach Transit Committee acknowledges the need to formally adopt certain written financial management policies as outlined in federal regulations. The new finance manager is currently working to draft ...

2023-003 Allowable Costs/Cost Principles: Written Financial Policies The Biddeford-Saco-Old Orchard Beach Transit Committee acknowledges the need to formally adopt certain written financial management policies as outlined in federal regulations. The new finance manager is currently working to draft and formalize these policies and procedures with a targeted completion date of March 31, 2026. We will present them to the Board of Directors for review and official adoption.

View Audit 373784

Finding 1164356 (2023-002)

Material Weakness 2023

Biddeford-Saco-Old Orchard Beach Transit Committee

ME

Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.303

2023-002 Activities Allowed and Allowable Costs To address the finding regarding missing backup documentation for cash disbursements, the Biddeford-Saco-Old Orchard Beach Transit Committee has implemented new workflow controls in our new integrated accounting software. Starting July 1, 2025 all empl...

2023-002 Activities Allowed and Allowable Costs To address the finding regarding missing backup documentation for cash disbursements, the Biddeford-Saco-Old Orchard Beach Transit Committee has implemented new workflow controls in our new integrated accounting software. Starting July 1, 2025 all employees are now required to create a purchase order (PO) and obtain approvals before payments can be made. This process controlled by the finance manager creates a complete audit trail for every transaction, ensuring that all disbursements are properly documented.

View Audit 373784

Finding 1164330 (2023-001)

Material Weakness 2023

JXN Water

MS

Internal Control / Segregation of Duties

JXN Water, Inc. hired Horne LLP to assist with grant management in May 2024. Additionally, EPA instituted new procedures in March 2024, requiring all grant funded invoices be submitted and approved by EPA prior to releasing funds from the two grants. Going forward JXN Water, Inc. is looking to hire ...

JXN Water, Inc. hired Horne LLP to assist with grant management in May 2024. Additionally, EPA instituted new procedures in March 2024, requiring all grant funded invoices be submitted and approved by EPA prior to releasing funds from the two grants. Going forward JXN Water, Inc. is looking to hire a construction contract manager to review and approve all construction related invoices prior to payment. Non construction invoices will be approved by the JXN Water, Inc. Administrative Manager prior to payment in BILL.COM. These changes should be in place by December 31, 2024.

View Audit 373772

Finding 1164324 (2023-005)

Material Weakness 2023

Consolidated Public Water Supply District No 1 of Clark County Mo

MO

Internal Control / Segregation of Duties

Subsequent to year-end, the District’s Board approved a written policy on internal controls over grant funds.

View Audit 373746

Finding 1164323 (2023-004)

Material Weakness 2023

Consolidated Public Water Supply District No 1 of Clark County Mo

MO

There were extenuating circumstances and problems with the District’s accounting system software conversion that prevented timely completion of the audit. The data collection form was completed as soon as the information was available.

View Audit 373746

Finding 1164322 (2023-003)

Material Weakness 2023

Consolidated Public Water Supply District No 1 of Clark County Mo

MO

Internal Control / Segregation of Duties HUD Housing Programs

The Board and management are aware of the inadequate separation of accounting duties when reviewing the monthly operations and financial results of the District. As an ongoing mitigating control, at the board meetings management and the board members review the monthly check register of disbursement...

The Board and management are aware of the inadequate separation of accounting duties when reviewing the monthly operations and financial results of the District. As an ongoing mitigating control, at the board meetings management and the board members review the monthly check register of disbursements, interim financial reports, summary of cash and certificates of deposits held, and contract pay applications and construction project status as presented by the project engineer for review and approval by the Board.

View Audit 373746

Finding 1164321 (2023-002)

Material Weakness 2023

Consolidated Public Water Supply District No 1 of Clark County Mo

MO

Subrecipient Monitoring

Management is aware that significant year-end adjustments are required for accrual basis financial statement presentation and does not believe the adjustments indicate a misstatement or error in financial reporting although material in amount. Management has the skill, knowledge and experience regar...

Management is aware that significant year-end adjustments are required for accrual basis financial statement presentation and does not believe the adjustments indicate a misstatement or error in financial reporting although material in amount. Management has the skill, knowledge and experience regarding the District operations to understand and take responsibility for the adjusting journal entries. The District has also engaged an external CPA to come to the office on a monthly basis to assist with monthly reconciliations and adjustments

View Audit 373746

Finding 1164320 (2023-001)

Material Weakness 2023

Consolidated Public Water Supply District No 1 of Clark County Mo

MO

Management has the skill, knowledge and experience regarding the District operations to understand and take responsibility for the financial statements.

View Audit 373746

Finding 1164298 (2023-002)

Material Weakness 2023

Commonwealth Utilities Corporation

MP

Reporting Internal Control / Segregation of Duties § 200.328

Person Responsible: Fiscal Administrator (Grants and Budget) Deadline: CUC agrees to develop and create a more refined tracking system and staffing for compliance purposes. A tracking system is in place as of this writing.

View Audit 373671

Finding 1164261 (2023-010)

Material Weakness 2023

Bristlecone Family Resources

CA

Eligibility Material Weakness Reporting

Management will review its current policies and the grant requirements set forth by its grant agreements as well as review the CFR requirements and adopt numerous policies in FY2025

View Audit 373603

Finding 1164209 (2023-001)

Material Weakness 2023

Southfield Public Schools

MI

School Nutrition Programs

Condition: The School District did not complete on-site monitoring reviews for any buildings operating school lunch and breakfast programs within the School District during the year ended June 30, 2023. Planned Corrective Action: Southfield Public Schools contracts its food service with Southwest Fo...

Condition: The School District did not complete on-site monitoring reviews for any buildings operating school lunch and breakfast programs within the School District during the year ended June 30, 2023. Planned Corrective Action: Southfield Public Schools contracts its food service with Southwest Food Service. To address the noncompliance, the Food Service Director (Southwest Food Service), and Food Service Purchasing (Southfield Public Schools) will coordinate the on-site monitoring reviews and its completion to Michigan Department of Education standards, and make sure the required forms are completed before deadlines. Contact person responsible for corrective action: Marc Ingram, Chief Financial Officer Anticipated Completion Date: 02/01/2024

View Audit 373501

Finding 1163631 (2023-001)

Material Weakness 2023

Addie Mae Collins Community Services, Inc.

NY

§ 200.512

December 4, 2025 Person responsible: Diane Spann, Executive Director Fiscal Year Ended June 30, 2023 Section III – Federal Awards Findings and Questioned Costs Item 2023 – 001 Federal Assistance Listing Number: 93.600 Head Start Condition The Organization’s Data Collection Form submission to the Fed...

December 4, 2025 Person responsible: Diane Spann, Executive Director Fiscal Year Ended June 30, 2023 Section III – Federal Awards Findings and Questioned Costs Item 2023 – 001 Federal Assistance Listing Number: 93.600 Head Start Condition The Organization’s Data Collection Form submission to the Federal Audit Clearinghouse was not filed on time within nine months of the end of its fiscal year. Views of Responsible Officials and Corrective Action Additional time was needed to complete accurate fiscal records for the year ended June 30, 2023. The Data Collection form for the year ended June 30, 2022 will be submitted as soon as the financial statements have been finalized.

View Audit 373477

Finding 1163621 (2023-004)

Material Weakness 2023

Economic Development Board For Tacoma-Pierce County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. Recommendation: CLA recommends EDB update policies to match Uniform Guidance requirements and to update procedures to require document be kept showing that suspension and debarment checks are done prior to entering into a cov...

Coronavirus State and Local Fiscal Recovery Funds – Assistance Listing No. Recommendation: CLA recommends EDB update policies to match Uniform Guidance requirements and to update procedures to require document be kept showing that suspension and debarment checks are done prior to entering into a covered transaction. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: 1. Policy Updates: Update all policies and procedures to align with Uniform Guidance requirements (2 CFR Part 200) related to suspension and debarment compliance. 2. Suspension and Debarment Checks: Implement procedures requiring that suspension and debarment checks be performed and documented prior to entering into any covered transaction. Maintain evidence of these checks in accordance with federal requirements. 3. Documentation and Records: Establish a systematic process for maintaining documentation showing that suspension and debarment checks have been completed for all covered transactions, ensuring records are readily available for audit purposes. Name(s) of the contact person(s) responsible for corrective action: Michael Catsi Planned completion date for corrective action plan: December 31, 2025. If the U.S. Department of the Treasury has questions regarding this plan, please call Michael Catsi at 253-924-9031.

View Audit 373406

Finding 1163589 (2023-001)

Material Weakness 2023

CHESTERFIELD SQUARE MUTUAL HOMES, INC.

VA

HUD Housing Programs

Finding: 2023-001 Agency: Chesterfield Square Mutual Homes, Inc. Name of Contact Person and Title: Sharon B. Stover, Controller, Drucker & Falk, LLC Agent Anticipated Completion Date: 10/30/2023 Agency's Response: Concur Chesterfield Square Mutual Homes agrees with this finding and will implement th...

Finding: 2023-001 Agency: Chesterfield Square Mutual Homes, Inc. Name of Contact Person and Title: Sharon B. Stover, Controller, Drucker & Falk, LLC Agent Anticipated Completion Date: 10/30/2023 Agency's Response: Concur Chesterfield Square Mutual Homes agrees with this finding and will implement the following: Drucker& Falk, LLC will immediately remit a catch-up contribution for the deficient reserve contribution. Sharon B. Stover, Controller Drucker & Falk, LLC Agent

View Audit 373332

Finding 1163587 (2023-007)

Material Weakness 2023

SEMILLITAS DE AMOR INC

PR

Cash Management Allowable Costs / Cost Principles § 200.305

Finding 2023-007 – Payroll and Cash Management Deficiencies Responsible official: Executive Director and Accountants Corrective action planned: Management acknowledges that the same payroll and cash management deficiencies identified in the 2023 audit also occurred during 2024 and part of 2025. Spec...

Finding 2023-007 – Payroll and Cash Management Deficiencies Responsible official: Executive Director and Accountants Corrective action planned: Management acknowledges that the same payroll and cash management deficiencies identified in the 2023 audit also occurred during 2024 and part of 2025. Specifically, when federal cash balances were insufficient, payroll was paid temporarily from private funds, followed by the issuance of federal checks to employees for reimbursement purposes. During the 2025 audit, management recognized this as a recurring and systemic deficiency. A formal Cash Management and Interfund Transfer Policy is now being drafted and will be approved by the Board by February 2026. This policy will require: 1. Payroll to be processed directly from the federal account when possible. 2. Temporary transfers from private funds to be documented as interfund advances, with full repayment recorded upon reimbursement. 3. Prohibition of issuing duplicate payroll checks to employees. 4. Reconciliation of all interfund transfers within ten (10) business days after reimbursement. The organization will also implement a dual-authorization process for interfund transactions and establish a monthly reconciliation checklist to be completed by accounting staff and reviewed by the Executive Director. Monitoring: Monthly payroll and cash reconciliations will be reviewed by the Executive Director, and External Accountant. Evidence of reconciliations and approvals will be retained for audit purposes. Target completion date: March 31, 2026 Status: New finding – corrective actions in process.

View Audit 373330

Finding 1163586 (2023-006)

Material Weakness 2023

SEMILLITAS DE AMOR INC

PR

Reporting § 200.512

Finding 2023-006 – Timely Submission of the Single Audit Responsible official: Executive Director Corrective action planned: Management has acknowledged the delay in the submission of prior audits and has begun implementing stronger scheduling and monitoring controls to prevent recurrence. A complia...

Finding 2023-006 – Timely Submission of the Single Audit Responsible official: Executive Director Corrective action planned: Management has acknowledged the delay in the submission of prior audits and has begun implementing stronger scheduling and monitoring controls to prevent recurrence. A compliance calendar has been created listing all federal and financial reporting deadlines, including the nine-month requirement for Single Audit submissions. The Executive Director will coordinate with the external accountants within the first quarter following fiscal year-end to initiate audit planning and fieldwork early. The Board will monitor progress to ensure that financial closing and audit engagement activities are completed in sufficient time to meet the next federal submission deadline. Monitoring: Management will review the audit timeline audit process in order to remains on schedule. Target completion date: For the 2025 audit – submission to the Federal Audit Clearinghouse by September 30, 2026. Status: Corrective action in process. Controls have been established but were not fully effective for the 2024 audit cycle. Management is applying the revised procedures for the 2025 audit to ensure timely completion and submission.

View Audit 373330

Finding 1163498 (2023-003)

Material Weakness 2023

State of Kosrae

FM

Reporting

Finding No. 2023-003 Area: Reporting Views of Auditee and Planned Corrective Action: We agree with this finding. Kosrae Project Management Office hired a Finance Officer in FY2024 and started preparing SF-425 reports for its infrastructure projects. The Office of Finance consolidates all SF-425 form...

Finding No. 2023-003 Area: Reporting Views of Auditee and Planned Corrective Action: We agree with this finding. Kosrae Project Management Office hired a Finance Officer in FY2024 and started preparing SF-425 reports for its infrastructure projects. The Office of Finance consolidates all SF-425 forms for all Compact sector grants and sends them to the FSM National Government on a quarterly basis. Anticipated Completion Date: Ongoing Name of Contact Person: Mr. Palokoa George Finance Officer Kosrae Project Management Office Email: psgeorge@kosrae.gov.fm

View Audit 373101

Finding 1163490 (2023-002)

Material Weakness 2023

State of Kosrae

FM

Questioned Costs Procurement, Suspension & Debarment

Finding No. 2023-002 Area: Procurement, Suspension and Debarment Views of Auditee and Planned Corrective Action: We agree with this finding. The administering departments will strengthen their procedures for verifying the suspension and debarment status of vendors by (1) checking ‘SAM.gov exclusions...

Finding No. 2023-002 Area: Procurement, Suspension and Debarment Views of Auditee and Planned Corrective Action: We agree with this finding. The administering departments will strengthen their procedures for verifying the suspension and debarment status of vendors by (1) checking ‘SAM.gov exclusions” and (2) attaching to the purchase requisition a printout of the appropriate page from the SAM Exclusion website. Anticipated Completion Date: Ongoing Name of Contact Person: Ms. Lona Lyndon Esau Administrator, Office of Finance Department of Administration and Finance Email: alomalya.dofa@gmail.com

View Audit 373101 Questioned Costs: $1

Finding 1163482 (2023-001)

Material Weakness 2023

State of Kosrae

FM

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No. 2023-001 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action: We agree with this finding and the department will have to seek available funds from our State General Funds to settle this. Unfortunately, this was an expenditure passed two fiscal years, I ca...

Finding No. 2023-001 Area: Allowable Costs/Cost Principles Views of Auditee and Planned Corrective Action: We agree with this finding and the department will have to seek available funds from our State General Funds to settle this. Unfortunately, this was an expenditure passed two fiscal years, I can only admit that the payment process sounded acceptable due to the urgency of the situation at that time; however, now that we have realized that Sector money used to bring the students back was inappropriate and should not have been allowed, we regretfully have to admit our failure and seek solutions to settle this appropriately. In line with the findings, the department of education management is looking into this with the Kosrae State Scholarship Board and agree to formulate a new disbursement policy with Sector student scholarship awards. This new disbursement policy with sector student scholarship will have all student scholarship routed thru Kosrae Department of Education Director’s office for his or his designee for compliance. The department will also strengthen it’s internal control by verifying terms and conditions specified in the Compact grant awards before we proceed with the fund disbursement. Anticipated Completion Date: Ongoing Name of Contact Person: Mr. Tulensru Waguk Director Department of Education Email: twaguk@kosrae.doe.fm

View Audit 373101 Questioned Costs: $1

Finding 1163470 (2023-003)

Material Weakness 2023

Pohnpei Utilities Corporation

FM

Special Tests & Provisions HUD Housing Programs Reporting

PUC concurs with the auditor's recommendation. PUC will access its' needs for additional personnel and resources. October 2025, Daisy Nanpei, CFO

View Audit 373080

Corrective Action Plans

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