Corrective Action Plans

Finding 560431 (2023-001)

Material Weakness 2023

The Center for Black Women's Wellness, Inc.

GA

Cash Management Internal Control / Segregation of Duties § 200.303 § 200.305

Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement. Grantee Response and Corrective Action Plan 2023-001: We concur...

Recommendation: We recommend that internal controls be strengthened and processes implemented to ensure all draw down requests are reviewed and approved to ensure costs were accurately reported and paid before requesting reimbursement. Grantee Response and Corrective Action Plan 2023-001: We concur with this finding and have implemented measures to mitigate the repetition or additional occurrences. Previously draw down documentation was uploaded to a shared folder, in which the CEO and Fiscal Manager had access. In 2024, we implemented additional procedures to document review of drawdowns and supporting documentation. Additionally, documentation includes attaining the CEO signature on draw down documentation before the draw down is made. Responsible Parties: Jemea Dorsey, CEO Date Corrected: April 30, 2024

View Audit 356331

Finding 560406 (2023-003)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Finding Reference Number: 2023-003 Condition: In September 2023, HUD suspended its HAP subsidy to the Organization due to noncompliance regarding the tenant recertifications requirements under the HAP Contract. Recommendation: We recommend that control systems are put in place to ensure there are re...

Finding Reference Number: 2023-003 Condition: In September 2023, HUD suspended its HAP subsidy to the Organization due to noncompliance regarding the tenant recertifications requirements under the HAP Contract. Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding OJF has completed all overdue tenant recertifications. To prevent future delinquent recertifications, OJF will conduct a root cause analysis by January 15, 2025 to identify gaps in the current process. Once gaps are identified, procedures will be updated to provide clear guidelines and timelines to staff. By February 15, 2025, OJF will implement a tracking system for tenant recertifications, including supervisory review of all tenant files. By March 15, 2025, relevant OJF staff will undergo training on compliance with HUD requirements. This will include the creation of a compliance calendar. OJF’s senior management team and board of directors will monitor progress towards these goals. Progress reports will be drafted no later than April 15, 2024

View Audit 356309

Finding 560404 (2023-002)

Significant Deficiency 2023

The Pines Housing, Inc.

OR

Eligibility HUD Housing Programs Reporting

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 mov...

Finding Reference Number: 2023-002 Condition: As of December 12, 2024, management was unable to provide tenant income documents for 2 tenant files of 7 tenant files sampled out of the population (66 total tenant files). Management was unable to provide tenant security deposit documents for all 3 move-ins and move-outs sampled out of the population (9 total move-ins and 13 total move-outs during the audit period). Recommendation: We recommend that control systems are put in place to ensure there are regular reviews of tenant files to enable management to identify deficiencies and provide training, guidance, and procedures to eliminate errors and issues of noncompliance in the future. Reporting views of responsible officials Our Just Future, on behalf of The Pines Housing, Inc., both concurs with these findings and agrees with auditor recommendations. Completion date or proposed completion date: December 18, 2024 Action(s) taken or planned on the finding To address this finding, OJF will take the following actions: 1. Implement regular tenant file reviews at least semi-annually beginning January 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 2. Develop a mandatory training program on compliance requirements for property management site staff to follow by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 3. Revise and distribute existing tenant file management procedures by February 15, 2025 a. Responsible party: OJF asset management director and property management portfolio manager 4. Establish a monitoring and feedback system by March 15, 2025 for site staff to seek guidance on or report challenges of file management so that advice can be given and/or corrective action taken a. Responsible party: OJF asset management director and property management portfolio manager 5. Conduct quarterly management reviews beginning 4/15/2025 to discuss and evaluate the effectiveness of above actions a. Responsible party: OJF asset management director and property management portfolio manager

View Audit 356309

Finding 560393 (2023-004)

Material Weakness 2023

Bakersfield, American Indian Health Project INC

CA

Reporting Internal Control / Segregation of Duties

Establish and Maintain a Reporting Calendar: A comprehensive grant reporting calendar will be implemented to track all financial and performance reporting deadlines. Calendar will include due dates, responsible staff, and required supporting documentation. Assigned Clear Roles and Responsibilities:...

Establish and Maintain a Reporting Calendar: A comprehensive grant reporting calendar will be implemented to track all financial and performance reporting deadlines. Calendar will include due dates, responsible staff, and required supporting documentation. Assigned Clear Roles and Responsibilities: Each grant report will have a designated preparer and reviewer. The Controller will be responsible for ensuring that all reports reconcile to the general ledger before submission. Implemented Standardized Reporting Procedures: A written Grants Reporting and Procedure Manual will be developed outining step-by-step procedures for preparing, reviewing, and submitting reports. Reports will only be submitted after reconciliation with the accounting system and documented approval from the Finance Director or Controller. Training and Capacity Building: Staff responsible for grant reporting will receive annual training on federal compliance requirements, Uniform Guidance, and internal procedures. Training sessions will include examples of common reporting errors and reconciliation best practices. Monitoring and Internal Reviews: The Finance Director will conduct a monthly compliance check to verify timely completion and accuracy of each report. Quarterly internal audits will be conducted to assess adherence to the reporting procedures and controls.

View Audit 356287

Finding 560390 (2023-003)

Material Weakness 2023

Bakersfield, American Indian Health Project INC

CA

Reporting Internal Control / Segregation of Duties

Reporting Calendar and Schedule: A grant reporting calendar will be created and maintained, outlining all required reporting deadlines for each funding source, including due dates, responsible staff, and required documentation. The calendar will be reviewed weekly by the Finance Director to ensure u...

Reporting Calendar and Schedule: A grant reporting calendar will be created and maintained, outlining all required reporting deadlines for each funding source, including due dates, responsible staff, and required documentation. The calendar will be reviewed weekly by the Finance Director to ensure upcoming deadlines are met. Assignment of Responsibilities: Clear responsibilities will be assigned to specific personnel for each step of the reporting process, including data preparation, report drafting, internal review, and final submission. A checklist will be used for each report to document the review proceduress and ensure all elements are completed accurately and timely. Reconciliation Procedures: All reports will be reconciled to the general ledger and supporting schedules prior to submission to ensure consistency and accuracy. Supporting documentation will be attached to each report file to provide an audit trail. Internal Review Process: A second-level review by the Controller or Finance Director will be required before reports are submitted to funding agencies. Review will include verifying accuracy, completeness, and agreement with accounting system data. Training and Internal Controls: Staff responsible for report preparation will undergo annual training on grant compliance requirements, Uniform Guidance, and reporting accuracy. Internal controls will be documented in Grants Management Policy and Procedures Manual, including reporting guidelines. Monitoring and Follow-Up: Compliance with the reporting calendar and procedures will be tracked monthly. Any missed or delayed reports will be investigated, and corrective actions taken immediately.

View Audit 356287

Finding 560385 (2023-002)

Significant Deficiency 2023

Public Housing Authority of Butte

MT

HUD Housing Programs Eligibility Reporting

The Public Housing Authority of Butte will contract with the Certified Public Accounting firm to assist with timely submission of the FY 2024 unaudited Financial Data Schedule. This will provide su icient time for the audit to get completed by the audited FASSPHA deadline.

View Audit 356277

Finding 560353 (2023-003)

Material Weakness 2023

Cornerstone Whole Healthcare Organization, Inc.

ID

Questioned Costs Cash Management Material Weakness

Plan of Action: A New Cash Management Procedure was implemented on 5/5/24. We have also developed a tracking system in Microsoft Forms for the Project Director or Authorizing Officer to request and approve funds.

View Audit 356257 Questioned Costs: $1

Finding 560348 (2023-002)

Material Weakness 2023

Cornerstone Whole Healthcare Organization, Inc.

ID

Reporting Material Weakness § 200.328

Plan of Action: To correct deficiencies in the preparation and submission of the SF-425 Federal Financial Report, the organization has established SOP F1.03: Submission and Recordkeeping of Federal Financial Reports (SF-425). This procedure outlines the steps for accurately completing the SF-425 usi...

Plan of Action: To correct deficiencies in the preparation and submission of the SF-425 Federal Financial Report, the organization has established SOP F1.03: Submission and Recordkeeping of Federal Financial Reports (SF-425). This procedure outlines the steps for accurately completing the SF-425 using verified financial data, submitting it through the appropriate federal systems by required deadlines, and maintaining supporting documentation in compliance with federal recordkeeping standards. It applies to all staff involved in financial reporting on federally funded grants.

View Audit 356257

Finding 560343 (2023-001)

Material Weakness 2023

Cornerstone Whole Healthcare Organization, Inc.

ID

Procurement, Suspension & Debarment § 200.318 § 200.326

Plan of Action: Provided policy F2.0 Materials Management, F2.01 Vendor Selection & Discount – currently being reviewed with the board for updates, and F2.03 Inventory and Supplies, which were not provided to the auditor due to the organization’s operational error in financial policy classification....

Plan of Action: Provided policy F2.0 Materials Management, F2.01 Vendor Selection & Discount – currently being reviewed with the board for updates, and F2.03 Inventory and Supplies, which were not provided to the auditor due to the organization’s operational error in financial policy classification. Additionally, the F2.02 Capital and Equipment policy was drafted in 2021 will be reviewed and signed by the organizational board on Aug 26, 2024. The organization acknowledges that the procurement policy was not followed for one vendor procurement in 2022 due to an administrative error. This policy will be implemented and strictly followed immediately.

View Audit 356257

Finding 560342 (2023-001)

Significant Deficiency 2023

Healthy Relationships California

CA

§ 200.512

Healthy Relationships California management will ensure the audit is completed within the required time period and submitted to the Federal Audit Clearinghouse promptly in conjunction with the external accounting firm.

View Audit 356255

Finding 560337 (2023-002)

None 2023

Near West Side Multi-Service Corporation

OH

Internal Control / Segregation of Duties

We will implement a comprehensive review process to ensure all required documentation is included. This will involve regular audits of case files, enhanced training for staff on documentation requirements, and the development of a standardized checklist to ensure completeness.

View Audit 356241

Finding 560336 (2023-001)

None 2023

Near West Side Multi-Service Corporation

OH

Reporting Internal Control / Segregation of Duties

We will implement stricter adherence to deadlines and ensure that all reports are filed on time. Measures will include setting up reminder systems and providing additional training to staff on the importance of meeting these deadlines.

View Audit 356241

Finding 560335 (2023-004)

None 2023

City of Dunkirk, New York

NY

Reporting

View of Responsible Officials and Planned Corrective Action Plan—The City will update amounts and descriptions within the Department of Treasury’s reporting portal to ensure all amounts expended are properly reported.

View Audit 356234

Finding 560313 (2023-002)

Material Weakness 2023

Springboard Collaborative

PA

Questioned Costs Allowable Costs / Cost Principles Material Weakness

Issue Corrective Actions Responsible Party Status Springboard Collaborative did not maintain adequate time and effort reports for staff salaries and fringe benefits for all employees who spent less than 100% of their time working on this major program. Implement quarterly effort report certification...

Issue Corrective Actions Responsible Party Status Springboard Collaborative did not maintain adequate time and effort reports for staff salaries and fringe benefits for all employees who spent less than 100% of their time working on this major program. Implement quarterly effort report certification process, which requires eligible employees, their managers, and the grant management staff to review and certify effort charged to grant funding during the applicable reporting period. **The effort report certification process was fully enabled and completed in response to Single Audit review during the FY23 audit process and in preparation for FY24 audit. Grant management staff (Associate Director, Fiscal Grant Management) Completed Corrective Action

View Audit 356226 Questioned Costs: $1

Finding 560310 (2023-003)

Material Weakness 2023

Windsor Housing Authority

CT

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accou...

2023-003- REPORTING Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action WHA will develop written accounting policies and a deliverables calendar to eliminate late submissions moving forward. We will incorporate this into training for all staff and work with the fee accountant and Auditors to make sure deadlines are realistic, coordinated and attainable. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 560309 (2023-002)

Material Weakness 2023

Windsor Housing Authority

CT

HUD Housing Programs Subrecipient Monitoring Eligibility

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for ten...

2023-002- ELIGIBILITY Material Weakness/Noncompliance Auditee’s Response and Planned Corrective Action We follow HUD guidelines where required and Untimely recertifications are typically not within the control of the Housing Authority. Encompassing HUD guidelines, the recertification process for tenants begins 90 days prior to the recert date, but if tenants do not provide all the requested information, the recertification will be delayed until the information is provided, tenant is converted to a market rate rent, or we begin the termination process for termination of the voucher. We will continue to follow the HUD process for the management of the Housing Choice Voucher Programs/Mainstream voucher programs. Planned Implementation Date of Corrective Action: Immediately Person Responsible for Corrective Action: Maria DeMarco, President of DeMarco Management Corporation

View Audit 356224

Finding 560269 (2023-002)

Material Weakness 2023

Benton Franklin Community Action Committee

WA

Questioned Costs Allowable Costs / Cost Principles

BFCAC made a change in personnel during 2024. Subsequently BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this...

BFCAC made a change in personnel during 2024. Subsequently BFCAC has emphasized the need to maintain supporting documentation for all charges, including changes to timesheets, and supporting documentation for manual adjustments. The Executive Director and the Finance Manager are responsible for this corrective action.

View Audit 356210 Questioned Costs: $1

Finding 560261 (2023-001)

Material Weakness 2023

Appalachian Community Capital Corporation

VA

Reporting

Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: Decem...

Appalachian Community Capital Corporation respectfully submits the following corrective action plan for the year ended December 31, 2023. Name and address of independent public accounting firm: Brown, Edwards & Company, L.L.P. 105 Arbor Drive, 3rd Floor Christiansburg, VA 24073 Audit period: December 31, 2023 The findings from the December 31, 2023 Schedule of Findings and Questioned Costs (the “Schedule”) are discussed below. The findings are numbered consistently with the number assigned in the Schedule. FINDINGS – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT 2023-001: Community Development Financial Institutions Fund – Assistance Listing No. 21.024, Rapid Response Program, Restatement of Schedule of Expenditures of Federal Awards, Material Weakness Criteria and Condition: Recipients of federal funds are required to prepare a complete and accurate Schedule of Expenditures of Federal Awards. Additionally, recipients must establish and maintain effective internal controls over federal awards to provide reasonable assurance of accurate financial reporting Context: The Company restated the 2023 Schedule of Expenditures of Federal Awards by a material amount a result of misinterpretation of reporting requirements for loan loss reserves and allocations of other allowable purposes. Cause: The omission occurred due to a misinterpretation of reporting requirements involving the treatment of grant expenditures for the purpose of loan loss reserve funds, which differs in nature from general program expenditures. Management identified the issue and determined a change in reporting was needed to simplify tracking and reporting of federal grants, and to ensure compliance with the technical definition of expenditures in the guidance. Effect: Loan loss reserves allocated in the wrong period resulted in an understatement of total federal expenditures on the Schedule of Expenditures of Federal Awards. Recommendation: We recommend that the Company implement a formalized review process to ensure all applicable expenditures, including loan loss reserves, are properly recorded in the period in which assigned. Views of Responsible Officials and Planned Corrective Actions: We agree with the finding and have established a process to ensure all expenditures are properly included in the SEFA. Name of Contact Person: Donna Gambrell, President and Chief Executive Officer Signature of Contact Person:

View Audit 356165

Finding 560181 (2023-231)

Significant Deficiency 2023

Talmud Torah Yesodei Hatorah

NJ

The audit report was due to be received by the State of New Jersey no later than March 31, 2023. As a result, the audit was not submitted timely. Recommendation: The School should alert the auditor about new funding received during the year to give ample time to research and prepare. Action Taken: T...

The audit report was due to be received by the State of New Jersey no later than March 31, 2023. As a result, the audit was not submitted timely. Recommendation: The School should alert the auditor about new funding received during the year to give ample time to research and prepare. Action Taken: The administrator will monitor the School’s funding that they receive throughout the year and will alert the auditor as soon as they receive funding from a new program. As such, the required corrective actions have been implemented. Implementation Date: Corrective Action Plan has been implemented as of April 3, 2024. Person Responsible for Implementation: Mr. Rother, the Administrator, is the responsible party for implementation of the CAP. Telephone Number: (732)-722-5511.

View Audit 356150

Finding 560112 (2023-004)

Significant Deficiency 2023

Town of Enfield

NH

Cash Management Significant Deficiency

We will reconcile all of 2024 accounts to ensure accuracy. Expenditure and reimbursement of all federal funds will be recorded timely and accurately.

View Audit 356131

Finding 560111 (2023-003)

Significant Deficiency 2023

Town of Enfield

NH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency

We will implement more internal training with the Accounts Payable department to ensure manifests are signed.

View Audit 356131

Finding 560097 (2023-002)

Significant Deficiency 2023

Central Area Rural Transit System, Inc.

AK

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expendit...

Finding 2023-002 Significant Deficiency in Internal Control over Compliance, Noncompliance - Reporting Corrective Action Plan To prevent recurrence of the late filing of financial reports, staff will work to prepare year end reconciliations for major programs, state and federal schedules of expenditures to determine single audit status, and file corresponding reports in a timely manner. Expected Completion Date June 30, 2025

View Audit 356074

Finding 560093 (2023-003)

Significant Deficiency 2023

Murray County

MN

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency § 200.303

Finding Number: 2023-003 Finding Title: Special Tests and Provisions – Davis‐Bacon Act Name of Contact Person Responsible for Corrective Action: Heidi E. Winter, County Auditor-Treasurer Corrective Action Planned: County staff will obtain and properly review the certified payrolls received from a...

Finding Number: 2023-003 Finding Title: Special Tests and Provisions – Davis‐Bacon Act Name of Contact Person Responsible for Corrective Action: Heidi E. Winter, County Auditor-Treasurer Corrective Action Planned: County staff will obtain and properly review the certified payrolls received from all contractors and subcontractors for compliance with the Davis‐Bacon Act and Title 29 U.S. Code of Federal Regulations Part 5 and ensure documentation exists to support monitoring of and compliance with this requirement. Anticipated Completion Date: December 31, 2024

View Audit 356059

Finding 560078 (2023-002)

Significant Deficiency 2023

Town of Marlborough

CT

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Suspension and Debarment over COVID-19 America Rescue Plan Act Recommendation: We recommend that the Town design controls to ensure an adequate review process in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: The...

Suspension and Debarment over COVID-19 America Rescue Plan Act Recommendation: We recommend that the Town design controls to ensure an adequate review process in place to review potential contractors to determine they are not suspended or debarred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Town has a system in place to review contractors. A written process will be prepared to record and maintain appropriate documentation. Name of the contact person responsible for corrective action: Town Manager and Finance Director Planned completion date for corrective action plan: Since this report is overdue, the estimated date is before the start of the FY 24 audit.

View Audit 356034

Finding 560076 (2023-001)

Significant Deficiency 2023

Church Street Corporation

NJ

§ 200.512

Recommendation: Controls should be implemented to ensure timely filing of the audit package to the Federal Audit Clearinghouse. Views of Responsible Officials: The Organization agrees with the auditors' recommendation.

View Audit 356030

Corrective Action Plans

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