Corrective Action Plans

Finding 1216945 (2023-001)

Material Weakness 2023

DC

Subrecipient Monitoring § 200.512

Views of Responsible Officials and Planned Corrective Actions: LHCA acknowledges that the 2023 Uniform Guidance audit was submitted after the nine-month deadline required under 2 CFR §200.512. We take our compliance obligations seriously and are committed to timely submission going forward. LHCA ack...

Views of Responsible Officials and Planned Corrective Actions: LHCA acknowledges that the 2023 Uniform Guidance audit was submitted after the nine-month deadline required under 2 CFR §200.512. We take our compliance obligations seriously and are committed to timely submission going forward. LHCA acknowledges that, regardless of contributing factors, the responsibility for timely submission rests with the organization under 2 CFR 200.512. To ensure timely completion in future years, LHCA has implemented the following corrective actions: A dedicated audit liaison has been designated to coordinate all auditor requests and ensure document delivery within 72 hours of any request.Moving forward, LHCA will formally engage its audit firm no later than February 1st of each subsequent audit year, allowing sufficient time for fieldwork to be completed well in advance of the September 30th submission deadline. At engagement initiation, LHCA and its audit firm will establish a shared audit timeline with agreed milestone dates for fieldwork completion, draft report delivery, management response, and final FAC submission, with September 15th as the internal target submission date to provide a two-week buffer before the regulatory deadline. Financial records and grant documentation are now organized in a standardized Google Drive structure that allows immediate retrieval of any document requested during the audit process, reducing response time, and eliminating documentation delays as a source of audit timeline risk. LHCA is confident these measures will prevent recurrence and ensure timely submission of all future Uniform Guidance audits.

View Audit 403243

Finding 1216748 (2023-002)

Material Weakness 2023

Neighborhood Alliance

OH

Reporting

The Agency will close books within three months of year end to allow the audit to be conducted in May/June timeframe.

View Audit 403195

Finding 1216738 (2023-004)

Material Weakness 2023

City of Harrisburg

PA

§ 200.512

DEPARTMENT OR BUREAU: FINANCIAL MANAGEMENT CONTACT PERSON: BRYAN MCCUTCHEON ACCOUNTING MANAGER FINDING TITLE: GENERAL REPORT SUBMISSION THE PLANNED AUDIT TIMELINE WAS IMPACTED BY ONGOING FUNCTIONAL ISSUES OF THE NEWER ERP CITY-WIDE FINANCIAL MANAGEMENT SYSTEM, EXPANDED MANAGERIAL BUDGET AND RELATED ...

DEPARTMENT OR BUREAU: FINANCIAL MANAGEMENT CONTACT PERSON: BRYAN MCCUTCHEON ACCOUNTING MANAGER FINDING TITLE: GENERAL REPORT SUBMISSION THE PLANNED AUDIT TIMELINE WAS IMPACTED BY ONGOING FUNCTIONAL ISSUES OF THE NEWER ERP CITY-WIDE FINANCIAL MANAGEMENT SYSTEM, EXPANDED MANAGERIAL BUDGET AND RELATED PROJECT SUPPORTING WORK ASKED OF THE ACCOUNTING MANAGER, AND RECENT OCCURRING VACANCIES IN KEY FINANCIAL MANAGERIAL POSITIONS. THE ACCOUNTING MANAGER WILL CONTINUE TO WORK AND STRATEGIZE FOR IMPROVED EFFICIENCY IN THE PERFORMANCE OF FUTURE AUDIT PREPARATION WORK. ANTICIPATED COMPLETION DATE: ON OR BEFORE 12/31/2026

View Audit 403181

Finding 1216736 (2023-003)

Material Weakness 2023

City of Harrisburg

PA

Equipment & Real Property Management § 200.313

DEPARTMENT OR BUREAU: BUILDING AND HOUSING DEVELOPMENT CONTACT PERSON: DIRECTOR OF HOUSING AND ECONOMIC DEVELOPMENT, AND ACCOUNTING MANAGER FINDING TITLE: EQUIPMENT AND REAL PROPERTY MANAGEMENT EXPENDITURES OF CDBG GRANT FUNDING FOR CAPITAL OUTLAYS ON EQUIPMENT AND REAL PROPERTY ARE READILY IDENTIFI...

DEPARTMENT OR BUREAU: BUILDING AND HOUSING DEVELOPMENT CONTACT PERSON: DIRECTOR OF HOUSING AND ECONOMIC DEVELOPMENT, AND ACCOUNTING MANAGER FINDING TITLE: EQUIPMENT AND REAL PROPERTY MANAGEMENT EXPENDITURES OF CDBG GRANT FUNDING FOR CAPITAL OUTLAYS ON EQUIPMENT AND REAL PROPERTY ARE READILY IDENTIFIABLE WITHIN THE CITY'S FIXED ASSETS MODULE OF THE ACCOUNTING SYSTEM, INCLUDING SUBSEQUENT RETIREMENTS OF ANY SUCH CAPITAL ASSETS. THE DEPARTMENT ACKNOWLEDGES RELATED PHYSICAL INVENTORY OBSERVATIONS TO IDENTIFY THESE ASSETS HAVE BEEN ACTIVELY PERFORMED AND WILL WORK TO FORMALIZE SUCH INVENTORY PROCEDURES. THE CITY WILL LOOK TO COMPLETE SUCH PROCESS INTERNALLY AS SOON AS POSSIBLE. ANTICIPATED COMPLETION DATE: BY OR BEFORE 12/31/2026

View Audit 403181

Finding 1216734 (2023-002)

Material Weakness 2023

STEPS to Recovery Homes

AZ

Reporting Matching / Level of Effort / Earmarking Special Tests & Provisions

Management of the Organization has an accounting firm engaged who will perform future required audits.

View Audit 403177

Finding 1216733 (2023-001)

Material Weakness 2023

STEPS to Recovery Homes

AZ

Subrecipient Monitoring Allowable Costs / Cost Principles

Management of the Organization will restructure all classes in the functional classing system, as well as utilize the project function, and consistently apply expenditures such that system reports accurately reflect income and expenditures by program / grant.

View Audit 403177

Finding 1216675 (2023-018)

Material Weakness 2023

College of the Marshall Islands

MH

Subrecipient Monitoring Special Tests & Provisions Student Financial Aid

Special Tests and Provisions- Gramm-Leach-Bliley Act-Student Information System The College agrees with the finding and acknowledges the need to strengthen compliance with GLBA Safeguards Rule requirements related to student information security. Although the College already maintain Information Tec...

Special Tests and Provisions- Gramm-Leach-Bliley Act-Student Information System The College agrees with the finding and acknowledges the need to strengthen compliance with GLBA Safeguards Rule requirements related to student information security. Although the College already maintain Information Technology policies addressing many of the required safeguards, a formalized written Information Security Program specifically referencing GLBA requirements had not been fully established during the audit period. To address this finding, the College is developing a formalizing a comprehensive written ISP under the College Information Technology policies and procedures, with applicable student information confidentiality provisions also incorporated into the FAO policies and procedures. The College continues to provide training and guidance to staff regarding student information security and data protection to support ongoing compliance with federal requirements.

View Audit 403112

Finding 1216674 (2023-017)

Material Weakness 2023

College of the Marshall Islands

MH

Student Financial Aid Special Tests & Provisions Reporting

Special Tests and Provisions- Enrollment Reporting The College agrees with the finding; however, the issues resulted from a misunderstanding regarding the type of NSLDS documentation requested during the audit process. Enrollment reporting was completed manually through the NSLDS web portal on an in...

Special Tests and Provisions- Enrollment Reporting The College agrees with the finding; however, the issues resulted from a misunderstanding regarding the type of NSLDS documentation requested during the audit process. Enrollment reporting was completed manually through the NSLDS web portal on an individual student basis rather than through batch processing; therefore, batch files were not available to provide during fieldwork. The FAO staff has since received additional guidance and training regarding NSLDS enrollment reporting documentation and audit requirements. The FAO staff will continue participating in training opportunities to strengthen compliance and documentation practices for future audits.

View Audit 403112

Finding 1216673 (2023-016)

Material Weakness 2023

College of the Marshall Islands

MH

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

Special Tests and Provisions – Disbursements to or on Behalf of Students The College agrees with the finding and acknowledges that, during the audit period, certain Title IV disbursement notification, credit balance disbursement, and ISIR review procedures were not consistently completed in accordan...

Special Tests and Provisions – Disbursements to or on Behalf of Students The College agrees with the finding and acknowledges that, during the audit period, certain Title IV disbursement notification, credit balance disbursement, and ISIR review procedures were not consistently completed in accordance with federal requirements. To address this issue, the College reviewed and updated its FAO policies and procedures related to award notifications, cash management, disbursement processing, and verification procedures. The College also implemented JFA system to improve the tracking and monitoring of student awards, disbursements, verification activities, and credit balance timelines. In addition, the implementation of FAFSA priority deadline prior to each semester provides additional time for staff to review files, complete packaging, finalize verification requirements, and issue timely award notifications before processing begins. The College also amended its internal verification policy to align with the US DOE’s verification requirements by verifying only students selected by US DOE as indication on the student’s ISIR. The College will continue monitoring these corrective actions to support ongoing compliance with Title IV requirements.

View Audit 403112

Finding 1216672 (2023-015)

Material Weakness 2023

College of the Marshall Islands

MH

Student Financial Aid Special Tests & Provisions

Special Tests and Provisions – Verification The College agrees with the finding and acknowledges that the Financial Aid Office policies and procedures related to FAFSA verification did not fully incorporate all required federal verification provisions during the audit period and that discrepancies e...

Special Tests and Provisions – Verification The College agrees with the finding and acknowledges that the Financial Aid Office policies and procedures related to FAFSA verification did not fully incorporate all required federal verification provisions during the audit period and that discrepancies existed between supporting verification document, verification worksheets, and certain students’ ISIR. Corrective actions have already been implemented. The College reviewed and updated the FAO verification policies and procedures to incorporate applicable federal verification requirements, including verification deadlines, required documentation, correction procedures, conflicting information resolution, applicant responsibilities, and the requirement that verification must be completed prior to professional judgement adjustments in accordance with federal regulations and FSA Handbook requirements. In addition, the College strengthened its verification review, document collection, and conflicting resolution procedures to improve the accuracy of Title IV eligibility determinations and related reporting. The implementation of Jenzabar Financial Aid (JFA) system has also improved the FAO’s ability to track, organize, and monitor verification documents and related processing activities. The College will continue monitoring these procedures to ensure ongoing compliance with federal verification requirements.

View Audit 403112

Finding 1216671 (2023-014)

Material Weakness 2023

College of the Marshall Islands

MH

Student Financial Aid Period of Performance Reporting

Reporting The College partially agrees with the finding. While the College disagrees with the auditors’ conclusions regarding the calculation of cost of attendance and Pell award amounts for the students tested, the College acknowledges the need to strengthen its review and documentation procedures ...

Reporting The College partially agrees with the finding. While the College disagrees with the auditors’ conclusions regarding the calculation of cost of attendance and Pell award amounts for the students tested, the College acknowledges the need to strengthen its review and documentation procedures over origination records and COD submissions to ensure consistency and completeness of reporting records.

View Audit 403112

Finding 1216670 (2023-013)

Material Weakness 2023

College of the Marshall Islands

MH

Cash Management Student Financial Aid Subrecipient Monitoring § 200.303

Cash Management The College agrees with the finding. During 2024 and continuing into FY2025-2026, the College strengthened its cash management procedures for Pell Grant drawdowns under HCM1 payment method. To address this issue, the College implemented a drawdown memorandum process, whereby supporti...

Cash Management The College agrees with the finding. During 2024 and continuing into FY2025-2026, the College strengthened its cash management procedures for Pell Grant drawdowns under HCM1 payment method. To address this issue, the College implemented a drawdown memorandum process, whereby supporting documentation and justification for the requested amount are reviewed and approved before funds are drawn down.

View Audit 403112

Finding 1216669 (2023-012)

Material Weakness 2023

College of the Marshall Islands

MH

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Reporting The College acknowledges the finding and recognizes the need to strengthen oversight of reporting requirements. To prevent recurrence, the College will enhance its monitoring processes by developing formal reporting procedures and using the Asana Project Management system to schedule, moni...

Reporting The College acknowledges the finding and recognizes the need to strengthen oversight of reporting requirements. To prevent recurrence, the College will enhance its monitoring processes by developing formal reporting procedures and using the Asana Project Management system to schedule, monitor, and provide reminders for all federal and grant- related reporting deadlines and submissions.

View Audit 403112

Finding 1216666 (2023-011)

Material Weakness 2023

College of the Marshall Islands

MH

Procurement, Suspension & Debarment § 200.303 § 200.319 § 200.320 § 200.324

Procurement and Suspension and Debarment The College acknowledges the finding and recognizes the need for additional improvements to ensure full compliance with federal procurement regulations. Moving forward, procurement procedures will be strengthened by incorporating vendor eligibility verificati...

Procurement and Suspension and Debarment The College acknowledges the finding and recognizes the need for additional improvements to ensure full compliance with federal procurement regulations. Moving forward, procurement procedures will be strengthened by incorporating vendor eligibility verification requirements, including review of SAM.gov prior to contract execution or purchase approval. The college will also implement recurring training and oversight measures for employees involved in procurement activities to improve adherence to federal standards and internal procedures.

View Audit 403112

Finding 1216665 (2023-010)

Material Weakness 2023

College of the Marshall Islands

MH

Subrecipient Monitoring Cash Management § 200.302 § 200.303 § 200.305

Cash Management The College acknowledges the finding and will enhance its cash management practices by developing formal procedures outlining responsibilities, authorization requirements, and timelines related to federal drawdown and disbursements. In addition, the College will implement routine rec...

Cash Management The College acknowledges the finding and will enhance its cash management practices by developing formal procedures outlining responsibilities, authorization requirements, and timelines related to federal drawdown and disbursements. In addition, the College will implement routine reconciliations of drawdown activity against recorded expenditures on a monthly or quarterly basis to improve monitoring and ensure compliance with federal requirements.

View Audit 403112

Finding 1216662 (2023-009)

Material Weakness 2023

College of the Marshall Islands

MH

Allowable Costs / Cost Principles § 200.303 § 200.403

Activities Allowed or Unallowed/ Allowable Costs/Cost Principles The College acknowledges the finding and recognizes earlier corrective measures were not sufficient to fully address the concern. To improve monitoring of allowable expenditures and compliance with federal cost principles, the College ...

Activities Allowed or Unallowed/ Allowable Costs/Cost Principles The College acknowledges the finding and recognizes earlier corrective measures were not sufficient to fully address the concern. To improve monitoring of allowable expenditures and compliance with federal cost principles, the College will incorporate routine budget-to-expenditure reviews into its recurring grant management meetings. Additional oversight and review responsibilities will also be assigned to the Grants Office to strengthen compliance monitoring, improve accountability, and ensure expenditures are properly evaluated and documented prior to approval.

View Audit 403112

Finding 1216660 (2023-008)

Material Weakness 2023

College of the Marshall Islands

MH

Procurement, Suspension & Debarment § 200.303 § 200.320

Procurement and Suspension and Debarment College of the Marshall Islands acknowledges that this finding was reported in 2022 and was repeated in FY2023. The College agrees that certain procurement transactions were not adequately supported with sufficient documentation to demonstrate compliance with...

Procurement and Suspension and Debarment College of the Marshall Islands acknowledges that this finding was reported in 2022 and was repeated in FY2023. The College agrees that certain procurement transactions were not adequately supported with sufficient documentation to demonstrate compliance with procurement requirements, including vendor quotations, sole source justification, and procurement history documentation. The College has since upgraded and institutionalized a cloud-based filing system to ensure complete documentation, proper retention, and easy retrieval of procurement records. Internal control policies and procedures have been strengthened to ensure compliance with the RMI Procurement Code, including vendor selection documentation, sole source justification, quotations, and bid evaluations. In addition, newly hired Procurement and Accounts Payable staff have been assigned responsibilities for monitoring compliance, a staff training on federal procurement requirements and documentation standards will continue periodically to strengthen oversight and prevent recurrence.

View Audit 403112

Finding 1216659 (2023-007)

Material Weakness 2023

College of the Marshall Islands

MH

Subrecipient Monitoring § 200.303

Period of Performance College of the Marshall Islands acknowledges that this finding, reported in 2022, was repeated in 2023. The college confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit...

Period of Performance College of the Marshall Islands acknowledges that this finding, reported in 2022, was repeated in 2023. The college confirms that this resulted from gaps in the previous manual filing and monitoring system, which made it difficult to verify funding period dates during the audit fieldwork. The College has since upgraded and institutionalized a cloud- based filing system and strengthened internal controls to ensure all costs are properly aligned with the funding periods stipulated in the grant awards. In addition, the College has been continuously working to improve coordination between the Business Office, Human Resources, and program personnel to ensure payroll periods and expenditure dates are properly reviewed and aligned with grant award periods.

View Audit 403112

Finding 1216658 (2023-006)

Material Weakness 2023

College of the Marshall Islands

MH

Equipment & Real Property Management Subrecipient Monitoring § 200.303 § 200.313

Equipment and Real Property Management College of the Marshall Islands agrees that capital asset records and reconciliation procedures were not fully maintained in accordance with federal equipment and real property management requirements. The deficiencies were primarily due to reliance on manual r...

Equipment and Real Property Management College of the Marshall Islands agrees that capital asset records and reconciliation procedures were not fully maintained in accordance with federal equipment and real property management requirements. The deficiencies were primarily due to reliance on manual recordkeeping processes, incomplete asset documentation, and delays in updating and reconciling the fixed asset records with the general ledger. To address this finding, the College is actively working to automate and strengthen its fixed asset management process through implementation of the MIP Fixed Asset Module.

View Audit 403112

Finding 1216657 (2023-005)

Material Weakness 2023

College of the Marshall Islands

MH

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.403

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll and non-payroll expenditures charged to federal programs were not adequately supported with sufficient documentation to clearly demonstrate allow...

Activities Allowed or Unallowed & Allowable Costs/Cost Principles College of the Marshall Islands acknowledges the finding and agrees that certain payroll and non-payroll expenditures charged to federal programs were not adequately supported with sufficient documentation to clearly demonstrate allowability, proper allocation, and alignment with objectives. The deficiencies resulted from weaknesses in internal control procedures, incomplete supporting documentation, and prior filing and record retention practices. To address this, the College has upgraded and institutionalized a cloud-based filing system to ensure complete, accessible, and properly organized documentation for all grant-funded positions and expenditures. Internal controls have been strengthened to require signed employment and overload contracts, proper funding source verification, and supervisory review before any grant-related payroll costs are charged. With the upgraded systems and the support of newly hired skilled staff, the College is now better equipped to maintain compliance and oversight. Staff will continue to be trained twice a year on federal allowability and cost principles to prevent recurrence of similar issues in future audits.

View Audit 403112

Finding 1216523 (2023-003)

Material Weakness 2023

City of Fulton, New York

NY

Reporting

Name of auditee: City of Fulton, New York TIN: 15-6000406 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: Misty DeGroat Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Finding 2023-003 (a) Comments on the...

Name of auditee: City of Fulton, New York TIN: 15-6000406 Name of Audit Firm: EFPR Group, CPAs, PLLC Period covered by audit: December 31, 2023 CAP prepared by: Misty DeGroat Current Finding on the Schedule of Findings and Questioned Costs and Recommendations (3) Finding 2023-003 (a) Comments on the finding and recommendations - Management agrees with the finding. Management also agrees with the recommendation. See below for action taken. (b) Action taken - The City acknowledges the finding and will work with a third party specialist to obtain all audit information closer to the end of the year to ensure that all future reporting deadlines can be met.

View Audit 403018

Finding 1216465 (2023-006)

Material Weakness 2023

Mt Pleasant Housing Develpment Fund Company

NY

Both Concord and the Ascendant Neighborhood Development Corp (ANDC) were unaware of the inability to pay damages and legal fees from the entity. Going forward we will ensure such payments are made by ANDC and not through the entity operating account. A receivable has been recorded for ANDC to return...

Both Concord and the Ascendant Neighborhood Development Corp (ANDC) were unaware of the inability to pay damages and legal fees from the entity. Going forward we will ensure such payments are made by ANDC and not through the entity operating account. A receivable has been recorded for ANDC to return the funds to Mt Pleasant.

View Audit 402963

Finding 1216464 (2023-005)

Material Weakness 2023

Mt Pleasant Housing Develpment Fund Company

NY

The required funds have been transferred to the tenant security account as required.

View Audit 402963

Finding 1216463 (2023-004)

Material Weakness 2023

Mt Pleasant Housing Develpment Fund Company

NY

Eligibility HUD Housing Programs

Concord’s Compliance Dept has implemented procedures to ensure the tenant security deposits are correctly recorded, tenant eligibility is correctly determined and that the tenant lease files are properly maintained in accordance with HUD’s requirements.

View Audit 402963

Finding 1216462 (2023-003)

Material Weakness 2023

Mt Pleasant Housing Develpment Fund Company

NY

HUD Housing Programs

Concord is making “unauthorized” loans only as it pertains to insurance payments. Until the rental increases are large enough to cover the ongoing increasing costs of insurance premiums, management has no choice but to allow the entity with the most stable cashflow to make the monthly insurance paym...

Concord is making “unauthorized” loans only as it pertains to insurance payments. Until the rental increases are large enough to cover the ongoing increasing costs of insurance premiums, management has no choice but to allow the entity with the most stable cashflow to make the monthly insurance payments on behalf of the entities that are unable to cover their portion. The only available insurance coverage is via a policy that covers all three entities as the cost to cover the entities individually is astronomical. The only way to ensure the entities are insured and there is no lapse in coverage is to allow the entity with the stable cashflow to make the payments and for the other entities to reimburse for their portion. That is until the rental increases are substantial enough to actually cover the rising costs of insurance premiums.

View Audit 402963

Corrective Action Plans

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