Corrective Action Plans

Finding 555201 (2023-002)

Significant Deficiency 2023

CA

Reporting

The University will review and enhance its procedures and internal controls to ensure reporting requirements related to the HEERF grants are met and information is reported timely and accurately.

View Audit 353823

Finding 555197 (2023-001)

Significant Deficiency 2023

California State University

CA

Reporting

The University will further review and refine the policies and procedures to strengthen internal controls and to ensure the timely and accurate reporting to NSLDS.

View Audit 353823

Finding 555183 (2023-003)

Material Weakness 2023

Porchlight, Inc.

WI

Procurement, Suspension & Debarment Material Weakness Period of Performance

We will implement several key improvements to enhance our compliance and reporting processes. We will utilize new software to automate the preparation and compilation of audit and compliance reports, streamlining workflows and reducing the risk of delays. Additionally, we are establishing a centrali...

We will implement several key improvements to enhance our compliance and reporting processes. We will utilize new software to automate the preparation and compilation of audit and compliance reports, streamlining workflows and reducing the risk of delays. Additionally, we are establishing a centralized document management system with strong retention and access protocols to ensure all relevant documentation is properly maintained and readily accessible. As part of this process, we will improve our procedures for identifying and aligning expenses with the appropriate grants to ensure accurate reporting and proper use of funds.

View Audit 353787

Finding 555180 (2023-002)

Significant Deficiency 2023

Porchlight, Inc.

WI

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

We will utilize new software to automate the preparation and compilation of audit reports and compliance reports, streamlining the entire process and reducing the likelihood of delays. We will establish a centralized document management system with robust retention protocols. This system will ensure...

We will utilize new software to automate the preparation and compilation of audit reports and compliance reports, streamlining the entire process and reducing the likelihood of delays. We will establish a centralized document management system with robust retention protocols. This system will ensure that all relevant documents and information required for the reports are readily accessible and properly maintained, minimizing delays caused by searching for necessary materials. We will institute a schedule for regular reviews and monitoring of the reporting process. This will involve conducting periodic assessments to identify any bottlenecks or potential issues that could lead to delays, allowing for proactive intervention and resolution. By implementing these measures, we aim to mitigate the risk of late filing of the audit report, thereby enhancing compliance with regulatory requirements and ensuring timely and accurate reporting.

View Audit 353787

Finding 555179 (2023-001)

Material Weakness 2023

Porchlight, Inc.

WI

Reporting Procurement, Suspension & Debarment Material Weakness

To fortify our internal controls over financial reporting, we will introduce new software to streamline data management and reporting processes, ensuring both accuracy and efficiency. Concurrently, we will refine our internal workflows, introducing comprehensive procedural guides to standardize oper...

To fortify our internal controls over financial reporting, we will introduce new software to streamline data management and reporting processes, ensuring both accuracy and efficiency. Concurrently, we will refine our internal workflows, introducing comprehensive procedural guides to standardize operations and enhance transparency across all departments. Additionally, we'll implement a centralized repository for document storage with stringent retention policies to uphold organized and accessible record-keeping. Finally, we commit to conducting regular, rigorous reviews of financial information by designated personnel, enabling timely identification and resolution of any discrepancies, thereby reinforcing our control environment and safeguarding the integrity of our financial reporting system.

View Audit 353787

Finding 555166 (2023-001)

Significant Deficiency 2023

City of Lemoore

CA

Reporting § 200.502

The City will implement a standardized grant reporting procedure to ensure all departments, including Finance, are promptly informed of grant awards. This will include a centralized grant tracking system and regular interdepartmental meetings to enhance communication and oversight. Additionally, t...

The City will implement a standardized grant reporting procedure to ensure all departments, including Finance, are promptly informed of grant awards. This will include a centralized grant tracking system and regular interdepartmental meetings to enhance communication and oversight. Additionally, training will be provided to department staff on grant notification protocols to prevent similar oversights in the future.

View Audit 353768

Finding 555152 (2023-001)

Significant Deficiency 2023

Sites Project Authority

CA

Reporting § 200.510

Sites Authority staff did not understand the requirements that expenditures included in the Schedule of Expenditures of Federal Awards (SEFA) be provided on an accrual basis. As such, the first SEFA submittal was based on actuals. Staff was informed by the auditor that the SEFA submittal should be b...

Sites Authority staff did not understand the requirements that expenditures included in the Schedule of Expenditures of Federal Awards (SEFA) be provided on an accrual basis. As such, the first SEFA submittal was based on actuals. Staff was informed by the auditor that the SEFA submittal should be based on an accrual basis. The team submitted a SEFA based on an accrual basis. Staff made a mistake of not including in the SEFA 25% of a $180,000 ($45,000) payment. This $45,000 omission was less than 0.4% of the total expenditures of $10,697,736 included in the SEFA. There were 634 invoices processed with thousands of expense items used to prepare the SEFA. Staff will document in its internal SEFA procedure the appropriate federal CFR sections for SEFAs to ensure such sections and requirements are met. The recommended training will occur before end of FY24 to avoid this recurring in the Dec 31, 2024 audit report.

View Audit 353758

Finding 555151 (2023-008)

Significant Deficiency 2023

Samu Foundation

DC

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials: Based on this audit finding, SAMU agreed addressing the following: 1. Implement a formal review and approval process for program reports, including documentation of reviewer's name and date. 2. Establish a system to retain internal documentation of report submission d...

Views of Responsible Officials: Based on this audit finding, SAMU agreed addressing the following: 1. Implement a formal review and approval process for program reports, including documentation of reviewer's name and date. 2. Establish a system to retain internal documentation of report submission dates. 3. Develop a reporting calendar with internal deadlines for report preparation and review. 4. Designate specific individuals responsible for report preparation, review, and submission.

View Audit 353757

Finding 555150 (2023-007)

Material Weakness 2023

Samu Foundation

DC

Questioned Costs Procurement, Suspension & Debarment § 200.213

Views of Responsible Officials: SAMU will develop a comprehensive corrective action plan that addresses: 1. Creation and implementation of a formal suspension and debarment screening policy 2. Establishment of a documented screening process with clear timelines 3. Training program for staff on feder...

Views of Responsible Officials: SAMU will develop a comprehensive corrective action plan that addresses: 1. Creation and implementation of a formal suspension and debarment screening policy 2. Establishment of a documented screening process with clear timelines 3. Training program for staff on federal requirements and internal procedures 4. Regular monitoring and internal audit procedures By implementing these measures, SAMU can strengthen its compliance with federal regulations, mitigate the risk of providing funds to suspended or debarred parties, and protect its federal funding sources.

View Audit 353757 Questioned Costs: $1

Finding 555149 (2023-006)

Material Weakness 2023

Samu Foundation

DC

Questioned Costs Procurement, Suspension & Debarment § 200.303 § 200.318 § 200.319 § 200.320

Views of Responsible Officials: The procurement policy will be expanded for all re-procuring of longterm contracts procedures. All contracts with service providers or contractors will be reviewed and a renewal or re-procurement process will be taken care accordingly.

View Audit 353757 Questioned Costs: $1

Finding 555148 (2023-005)

Significant Deficiency 2023

Samu Foundation

DC

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials: SAMU management has ordered that all SAMU staff that corresponds with grantor personnel has to document such correspondence via emails or other means the afreed procedures including those of delayed submission of drawdowns.

View Audit 353757

Finding 555147 (2023-004)

Material Weakness 2023

Samu Foundation

DC

Reporting Material Weakness § 200.510

Views of Responsible Officials: SAMU has identified the following actions point: 1. Implement a thorough review process for all funding streams to determine if they are federal, state, or private. 2. Establish clear guidelines for identifying and tracking federal awards. 3. Provide training to accou...

Views of Responsible Officials: SAMU has identified the following actions point: 1. Implement a thorough review process for all funding streams to determine if they are federal, state, or private. 2. Establish clear guidelines for identifying and tracking federal awards. 3. Provide training to accounting staff on the proper application of ASC 958, particularly regarding the recognition of conditional awards. 4. Develop a checklist for SEFA preparation to ensure all required elements are included and properly reported. 5. Consider seeking expert advice or additional training on federal award accounting and reporting. By implementing these measures, SAMU can improve the accuracy of its SEFA, ensure compliance with federal regulations, and provide a more reliable basis for audit procedures.

View Audit 353757

Finding 555146 (2023-003)

Significant Deficiency 2023

Samu Foundation

DC

Allowable Costs / Cost Principles Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Views of Responsible Officials: SAMU has finalized comprehensive Logistics and procurement policy that covers the credit cards policy and the respective treatment and control for approvals. A comprehensive corrective action plan has been greed it addresses: 1. Establishment of a documented review pr...

Views of Responsible Officials: SAMU has finalized comprehensive Logistics and procurement policy that covers the credit cards policy and the respective treatment and control for approvals. A comprehensive corrective action plan has been greed it addresses: 1. Establishment of a documented review process with clear timelines 2. Training program for staff on federal cost principles and internal procedures 3. Regular monitoring and internal audit procedures By implementing these measures, SAMU emphasizes the importance of strengthened internal controls, ensure compliance with federal regulations, and mitigate the risk of charging unallowable costs to federal awards.

View Audit 353757

Finding 555145 (2023-002)

Significant Deficiency 2023

Housing Authority of the Township of Neptune

NJ

Questioned Costs Allowable Costs / Cost Principles § 200.423 § 200.438

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook,...

Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Bart Cook, Executive Director, is responsible for implementing this corrective action by September 30, 2024.

View Audit 353750 Questioned Costs: $1

Finding 555119 (2023-007)

Significant Deficiency 2023

City of Soldier

IA

The City of Soldier will establish policies and procedures to guarantee that all financial date is submitted to finance agencies.

View Audit 353717

Finding 555111 (2023-002)

Significant Deficiency 2023

Crosspurpose

CO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.3

Management recruited a procurement officer in December 2024 to design and implement best practice procurement processes effective the first quarter 2025. Procurement policies will ensure full compliance with Federal and State requirements. Procurement policies will incorporate clearly defined proc...

Management recruited a procurement officer in December 2024 to design and implement best practice procurement processes effective the first quarter 2025. Procurement policies will ensure full compliance with Federal and State requirements. Procurement policies will incorporate clearly defined procedures around all contractors ensuring appropriate selection processes and contractual terms.

View Audit 353705

Finding 555110 (2023-001)

Material Weakness 2023

Crosspurpose

CO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.4

Effective October 1, 2023, management implemented extensive accounting and documentation controls to ensure full accounting and reporting compliance on direct costs incurred for all federal grants and expenditures. These controls are reviewed and monitored for compliance by management on a periodic ...

Effective October 1, 2023, management implemented extensive accounting and documentation controls to ensure full accounting and reporting compliance on direct costs incurred for all federal grants and expenditures. These controls are reviewed and monitored for compliance by management on a periodic basis during the year.

View Audit 353705 Questioned Costs: $1

Finding 555086 (2023-001)

Material Weakness 2023

Walla Walla County

WA

Subrecipient Monitoring

Two full days of on-site training on federal grants management were provided for all DCH staff in May of 2023. In June of 2023, WWCDCH contracted with ENJ Consulting to create a federally compliant policy and procedures manual for the management of federal grants, and to train staff on the content a...

Two full days of on-site training on federal grants management were provided for all DCH staff in May of 2023. In June of 2023, WWCDCH contracted with ENJ Consulting to create a federally compliant policy and procedures manual for the management of federal grants, and to train staff on the content and use of the manual. The final product has been delayed due to OMB’s proposed changes to the Uniform Guidance; however, OMB has announced that they will release the final update on April 4, 2024, and we expect to receive our finalized policy and procedures manual shortly thereafter. DCH Grants and Contractions Coordinator will attend a webinar on April 4, 2024 covering the launch of the revised Uniform Guidance. DCH’s source grant and subaward under 21.019 were successfully closed 2021, so no action was taken to perform a retroactive risk assessment or monitoring activities. In response to the finding and consistent with WWDCH's commitment to compliance with applicable laws, rules, regulations, and award terms and conditions, WWDCH obtained training regarding subrecipient monitoring requirements and best practices regarding implementation of the same. In addition, WWDCH established a monitoring program for ERAP 2.0, which included testing of a sample of 25 applications for compliance with programmatic and financial requirements. Testing of the 25 sampled applications is complete; however, final reporting and resolution of monitoring observations are still in-process. WWDCH anticipates completion of this corrective action to occur during FY25.

View Audit 353642

Finding 554899 (2023-001)

Material Weakness 2023

Santa Clara Valley Transportation Authority

CA

Reporting Allowable Costs / Cost Principles Material Weakness § 200.502 § 200.510

2023-001 Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: Metropolitan Transportation Commission Award Year: 2023 Grant Award Number: MTC/STP Agreement Compliance Requirements: Other - Title 2 ...

2023-001 Program: Highway Planning and Construction Federal Financial Assistance Listing No.: 20.205 Federal Agency: U.S. Department of Transportation Pass-through: Metropolitan Transportation Commission Award Year: 2023 Grant Award Number: MTC/STP Agreement Compliance Requirements: Other - Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b)- Schedule of expenditures of Federal awards Recommendation: VTA should establish policies and implement internal controls to ensure all federal expenditures are accurately identified on the Schedule of Expenditures of Federal Awards (SEFA). Corrective Action: VTA will reinforce its system of internal control in communicating timely the Catalog of Federal Domestic Assistance (CFDA) number to the department preparing the SEFA. CFDA of direct and pass-through grants will be obtained from the Federal Transit Administration (FTA) and related grantors, respectively. If the CFDA number of a grant is not available at the time of preparation of SEFA, this will be identified accordingly. Responsible Party: The Fiscal Resources Manager and the Transportation Planners, Grants Implementation Date: March 31, 2025

View Audit 353461

Finding 554898 (2023-006)

Material Weakness 2023

Lincoln Hall

NY

Procurement, Suspension & Debarment

Finding Number: 2023-006 Procurement and Suspension and Debarment (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that management’s method of allocating s...

Finding Number: 2023-006 Procurement and Suspension and Debarment (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that management’s method of allocating shared personnel costs was performed after the fiscal year had ended, rather than through timely allocations during the year. Additionally, they identified one instance where the internal process for obtaining multiple bids was not followed, contrary to the organization’s stated procurement policy. Management acknowledges that the prior-year approach of allocating shared costs at year-end limited the ability to isolate federal program-specific transactions during the audit. Beginning in FY 2025, all shared costs—including personnel, OTPS, and other indirect expenses—are being allocated to the appropriate cost centers on a monthly basis. This approach improves the accuracy and timeliness of federal program reporting and ensures alignment with Uniform Guidance cost allocation principles. These enhancements support more precise tracking of federal expenditures and create a clearer, more auditable record of procurement transactions tied to federal programs. In addition, the Bidding Requirements policy has been reassessed, and both the language and related controls have been strengthened. This includes clarified rules regarding exceptions and the required documentation for each. A revised Bid Assessment Form has also been implemented to support compliance and consistency in procurement practices. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025

View Audit 353459

Finding 554897 (2023-005)

Material Weakness 2023

Lincoln Hall

NY

Allowable Costs / Cost Principles

Finding Number: 2023-005 Activities Allowed or Unallowed; Allowable Costs/Cost Principles (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that management’...

Finding Number: 2023-005 Activities Allowed or Unallowed; Allowable Costs/Cost Principles (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that management’s method for allocating shared personnel costs was performed after the close of the fiscal year, rather than through timely allocations made throughout the year. Additionally, during testing of 60 payroll samples, the auditors were unable to obtain sufficient documentation to support the approved pay rates for two employees. Beginning in FY 2025, personnel costs are being manually recorded to the correct cost centers in Serenic Navigator each month. A parallel review of employee setups in ADP, our payroll system, led to the reassignment of staff to appropriate cost centers as needed. Going forward, ADP cost center assignments will be reviewed monthly to reflect any departmental changes. These steps are expected to reduce manual adjustments, improve the accuracy of interim financials, and ensure more precise federal and program drawdowns. With respect to the two instances where documentation supporting employee pay rate approvals could not be located, management acknowledges the oversight. These cases appear to be isolated. To address this, we have implemented a more formalized process for documenting and storing all personnel actions, including pay rate approvals. All compensation-related approvals are now required to be documented in writing and retained in a centralized digital personnel file accessible to HR and Finance. These corrective actions are intended to strengthen internal controls over payroll and personnel cost allocations and ensure full compliance with federal and organizational requirements going forward. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025

View Audit 353459

Finding 554896 (2023-004)

Material Weakness 2023

Lincoln Hall

NY

Reporting

Finding Number: 2023-004 Reporting (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that two SF-PPR quarterly reports and the Uniform Guidance report were ...

Finding Number: 2023-004 Reporting (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that two SF-PPR quarterly reports and the Uniform Guidance report were not submitted on time. Additionally, for one of the SF-425 reports submitted during the year, the auditors were unable to trace the amounts reported back to the underlying accounting records and supporting documentation. Management acknowledges these items. Since that time, corrective actions have been implemented to improve timeliness, accuracy, and documentation: • A centralized reporting calendar has been established, identifying all required submission deadlines under Uniform Guidance §200.328, §200.329, and §200.512. • Ownership of report preparation and review responsibilities has been clearly assigned to designated Program and Finance staff. • A standardized reconciliation template is now being used for the SF-425 to ensure all amounts reported can be tied directly to accounting records and underlying support. •Management has reinforced the importance of timely filing through internal policies and incorporated review steps to verify completeness and accuracy of each report before submission. These improvements are designed to ensure ongoing compliance with all federal reporting requirements and to prevent recurrence of these issues in future reporting periods. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025

View Audit 353459

Finding 554895 (2023-003)

Material Weakness 2023

Lincoln Hall

NY

Cash Management Allowable Costs / Cost Principles

Finding Number: 2023-003 Allowable Costs; Cash Management (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that certain payroll expenses and other than ...

Finding Number: 2023-003 Allowable Costs; Cash Management (Material Weakness) Programs: Unaccompanied Alien Children Program ALN#93.676 Contract#: 90ZU0323 & 90ZU0548 Contract Period: 07/01/22 - 06/30/23 Planned Corrective Action: The auditors noted that certain payroll expenses and other than personnel service (OTPS) expenses are not being charged directly or allocated to the correct cost center in the accounting system monthly. Therefore, the amounts being drawn down during any given month may not be fully supported until the year-end when a reallocation of costs by function occurs. Beginning in FY 2025, personnel costs are being manually recorded to the correct cost centers in Serenic Navigator each month. A parallel review of employee setups in ADP, our payroll system, led to the reassignment of staff to appropriate cost centers as needed. Going forward, ADP cost center assignments will be reviewed monthly to reflect any departmental changes. These steps are expected to reduce manual adjustments, improve the accuracy of interim financials, and ensure more precise federal and program drawdowns. Additionally, OTPS expenses have been charged directly or allocated to the appropriate cost centers on a monthly basis since the start of FY 2025. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025

View Audit 353459

Finding 554894 (2023-002)

Material Weakness 2023

Lincoln Hall

NY

Internal Control / Segregation of Duties Material Weakness Reporting

Finding Number: 2023-002 Closing Process – (Material Weakness) Planned Corrective Action: The auditors noted issues related to the timeliness of the financial statement close process, the quantity of entries to close the books, the reconciliation of the beginning trial balance to the prior year aud...

Finding Number: 2023-002 Closing Process – (Material Weakness) Planned Corrective Action: The auditors noted issues related to the timeliness of the financial statement close process, the quantity of entries to close the books, the reconciliation of the beginning trial balance to the prior year audited trial balance, and a lack of segregation of duties which led to journal entries being prepared, reviewed and posted by the same person in the general ledger system. The issues noted were largely the result of significant turnover within the Finance Department, including the departure of the former head of the department without a proper transfer of institutional knowledge to remaining staff or incoming leadership. Since that time, oversight has improved considerably, and key processes have been reviewed, updated, and formally documented. While the current size of the Finance Team necessitates that the same individual generally enters and posts journal entries, we have implemented compensating controls that we believe are appropriate given the assessed levels of risk and materiality. These controls include role-specific responsibilities for journal entries and reconciliations. For example, with respect to cash activity, different team members handle cash receipts, disbursements, and inter-account transfers. A fourth team member is responsible for preparing the monthly bank reconciliations, which are then formally reviewed and signed off by Fiscal Department management, including the CFO. Management remains committed to strengthening internal controls, maintaining adequate segregation of duties to the extent practicable, and continuing to enhance the overall financial close and reporting process. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025

View Audit 353459

Finding 554893 (2023-001)

Material Weakness 2023

Lincoln Hall

NY

Allowable Costs / Cost Principles Material Weakness

Finding Number: 2023-001 Cost Allocations – (Material Weakness) Planned Corrective Action: The auditors noted that payroll and the related personnel costs are not being charged directly or allocated to the correct cost center in the Serenic Navigator accounting system monthly. The Finance team perf...

Finding Number: 2023-001 Cost Allocations – (Material Weakness) Planned Corrective Action: The auditors noted that payroll and the related personnel costs are not being charged directly or allocated to the correct cost center in the Serenic Navigator accounting system monthly. The Finance team performed manual calculations of all allocations in Excel at the end of the fiscal year to update the allocations. Beginning in FY 2025, personnel costs are being manually recorded to the correct cost centers in Serenic Navigator each month. A parallel review of employee setups in ADP, our payroll system, led to the reassignment of staff to appropriate cost centers as needed. Going forward, ADP cost center assignments will be reviewed monthly to reflect any departmental changes. These steps are expected to reduce manual adjustments, improve the accuracy of interim financials, and ensure more precise federal and program drawdowns. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: April 30, 2025

View Audit 353459

Corrective Action Plans

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