Corrective Action Plans

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In Finding 2023-002, a condition was noted in which the Organization did not verify that employees and certain vendors were not suspended, debarred, or otherwise excluded from participating in federal programs before entering into transactions with them. Management recognizes the importance of com...
In Finding 2023-002, a condition was noted in which the Organization did not verify that employees and certain vendors were not suspended, debarred, or otherwise excluded from participating in federal programs before entering into transactions with them. Management recognizes the importance of complying with procurement, debarment, and suspension guidelines. In response to Finding 2023-002, procedures will be implemented to ensure that employees and vendors are not suspended, debarred or otherwise excluded from participating in federal programs.
Finding 521997 (2023-001)
Significant Deficiency 2023
Finding Reference Number #SA2023-001: Suspension and Debarment for Contracts and Subcontracts Assistance Listing Numbers: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award Identification Number: ...
Finding Reference Number #SA2023-001: Suspension and Debarment for Contracts and Subcontracts Assistance Listing Numbers: 21.027 Assistance Listing Title: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Federal Agency: Department of Treasury Federal Award Identification Number: SLFRP4371 266737 Pass-Through Entity: California State Water Resources Control Board  Fiscal Year of Initial Finding: 2021  Name(s) of the contact person: Isaac Moreno, Finance Director  Corrective Action Plan: The City has drafted an updated citywide procurement policy that includes the requirement to be compliant with 2 C.F.R Part 180 and is expected to be approved in June 2025.  Anticipated Completion Date: 6/30/2025
Management Response and Corrective Action Plan Finding 2023-002 – Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: 93.837 and 93.847 Responsible Individual: Roy Bourne, Director, ...
Management Response and Corrective Action Plan Finding 2023-002 – Subrecipient Monitoring Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: 93.837 and 93.847 Responsible Individual: Roy Bourne, Director, Research Finance and Operations Contact Information: rbourne2@joslin.harvard.edu; 617-309-5741 Joslin Diabetes Center’s (Center) subrecipient monitoring process did not clearly indicate risk assessment procedures or the required monitoring activities in certain audited instances. While the Center has a Subrecipient Monitoring and Management policy, review suggests that a thorough evaluation of this plan, formal documentation, and secondary oversight will improve internal control. Management agrees with the recommendation and will evaluate the subrecipient monitoring process according to 2 CFR 200.332 and update established policy where applicable. Corrective Action Plan: - Management will review the Subrecipient Monitoring and Management policy for relevant updates and improvements to internal control - Results of risk assessment procedures and subrecipient monitoring will be formally documented within the tracking log - Log entries will be updated to reflect a reviewers note documenting material and date of review - Director of Research Finance and Operations will review log semi-annually for secondary oversight Expected Completion Date: June 30, 2025 Status of Completion: In Process
Management Response and Corrective Action Plan Finding 2023-003 – Reporting Program: Provider Relief Fund and American Rescue Plan Federal Agency: Health Resources and Services Administration Assistance Listing Number: 93.498 Responsible Individual: Katherine Bacher, VP of System Services Account...
Management Response and Corrective Action Plan Finding 2023-003 – Reporting Program: Provider Relief Fund and American Rescue Plan Federal Agency: Health Resources and Services Administration Assistance Listing Number: 93.498 Responsible Individual: Katherine Bacher, VP of System Services Accounting and Finance Contact Information: Katherine.bacher@bilh.org; 617-278-7059 Management agrees with the recommendation and moving forward, BILH will centralize the compilation of the SEFA, along with conducting periodic reconciliations of the schedule, the general ledger and supporting documentation. Management will also utilize its new accounting system to track all federal funding by requiring the appropriate worktags be utilized when recording such transactions, allowing for accurate reporting. Lastly, management will require at least two reviews of the SEFA. Corrective Action Plan: • Management will have training sessions with the Finance staff on the use of worktags when recording federal funding. • A new position has been created, Director of Technical Accounting, who will be responsible for compiling the SEFA and ensuring accuracy of the filing, with sign off by department managers who are submitting information • Director of Research Finance will review initial draft of SEFA for completeness and accuracy • VP of Revenue and Reimbursement will review the initial draft of SEFA for completeness and accuracy • VP of System Services Accounting and Finance will final review for completeness and accuracy Expected Completion Date: June 30, 2025 Status of Completion: In Process
Management Response and Corrective Action Plan Finding 2023-001 Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: Various Responsible Individual: Jarod Kohr, Director, Research Finance Contact Information: ...
Management Response and Corrective Action Plan Finding 2023-001 Federal Agency: United States Department of Health and Human Services Program Name: Research and Development (R&D) Assistance Listing Number: Various Responsible Individual: Jarod Kohr, Director, Research Finance Contact Information: jkohr@bidmc.harvard.edu; 617-667-4136 A review of the Beth Israel Deaconess Medical Center’s (BIDMC) property records maintenance revealed incomplete biennial physical inventory and incomplete tagging of new equipment purchased on federal awards. Management agrees with the recommendation and will update the asset tagging system to support completing the biennial inventory and resume tagging new equipment according to established policy. Corrective Action Plan: Tagging System • Director of Operations and Director of Research Computing will complete work with vendor to update scanning devices and software (complete) • Director of Operations will develop plan to complete inventory and new tagging (complete) Tagging New Equipment • Complete update to equipment list including identifying new (untagged) equipment (complete) • Tag all new items received (complete) • Maintain list of new pending equipment to be tagged Physical Inventory • Establish inventory schedule with clear notification to Research community • Identify all equipment on current inventory • Identify any equipment in lab spaces not on current inventory and tag if appropriate • Reconcile all inventory including any disposition discrepancies Expected Completion Date: June 30, 2024 Status of Completion: In Process
Corrective Action: To ensure that future submissions are completed in accordance with 45 CRF Part 75, Subpart F, the Finance Manager will submit a timeline to begin the FAC submission within a week after the audit report is received. This will allow necessary time for all information to be submitte...
Corrective Action: To ensure that future submissions are completed in accordance with 45 CRF Part 75, Subpart F, the Finance Manager will submit a timeline to begin the FAC submission within a week after the audit report is received. This will allow necessary time for all information to be submitted, documents uploaded and appropriate signoffs complete prior to the deadline.
Management will continue to rely on the audit firm to draft the financial statements and the related notes to the financial statements, and will review, approve, and accept responsibility for the annual financial statements prior to their issuance. Management will continue to increase internal abili...
Management will continue to rely on the audit firm to draft the financial statements and the related notes to the financial statements, and will review, approve, and accept responsibility for the annual financial statements prior to their issuance. Management will continue to increase internal abilities and advancement in order to monimize reliance on audit firm for financial statements.
The program tested requires a manual entry directly into the grantors system. Going forward the Organization will document the review and approval of the amounts submitted monthly to this system.
The program tested requires a manual entry directly into the grantors system. Going forward the Organization will document the review and approval of the amounts submitted monthly to this system.
The Organization has taken steps to address this problem by hiring additional staff in the accounting department. Additionally, the accounting and operations departments are now separate and distinct departments. This allows for the appropriate individuals to have more time to concentrate on Alterna...
The Organization has taken steps to address this problem by hiring additional staff in the accounting department. Additionally, the accounting and operations departments are now separate and distinct departments. This allows for the appropriate individuals to have more time to concentrate on Alternatives finances and improve the timing and accuracy of the monthly and year-end financial close. The Organization experienced substantial growth of programmatic activities which required the department to focus on ongoing maintenance and tracking. The department expects to be able to take the results of these changes and properly close out the June 30, 2024 year end.
Problem: Lake County Government did not file quarterly or annual reports as required by Coronavirus State and Local Fiscal Recovery Funds as per Department of Treasury. Actions Steps: All Coronavirus State and Local Fiscal Recovery Funds must be managed going forward as per the standardized grant fu...
Problem: Lake County Government did not file quarterly or annual reports as required by Coronavirus State and Local Fiscal Recovery Funds as per Department of Treasury. Actions Steps: All Coronavirus State and Local Fiscal Recovery Funds must be managed going forward as per the standardized grant funding policy in both process and procedure. Status: Granted funds awarded to Lake County Government are managed and controlled via the BOCC voted and approved Lake County Grant Policy. Dates: July 2024 to present Goal: To accurately and reliably manage and report on all funds granted awarded to Lake County Government.
Management accepts the finding and recommendation. During fiscal year 2023, the finance department hired additional personnel to assist with the completion of the year-end closing processes and procedures. We have discussed with employees the importance of timely submission of the City’s annual audi...
Management accepts the finding and recommendation. During fiscal year 2023, the finance department hired additional personnel to assist with the completion of the year-end closing processes and procedures. We have discussed with employees the importance of timely submission of the City’s annual audit package and data collection form to the federal audit clearinghouse on an ongoing basis.
Views of Responsible Officials and Planned Corrective Actions – The District is committed to enhancing its processes to ensure timely and efficient preparation for audit requests. To align with the standards set forth in the New Mexico Administrative Code Title 2, Chapter 2, Part 2, we will implemen...
Views of Responsible Officials and Planned Corrective Actions – The District is committed to enhancing its processes to ensure timely and efficient preparation for audit requests. To align with the standards set forth in the New Mexico Administrative Code Title 2, Chapter 2, Part 2, we will implement more robust internal procedures to improve audit readiness and ensure that all necessary documentation is readily available. These efforts will support compliance with deadlines and strengthen overall audit management across the District’s operations. Responsible Parties: Director of Finance and the District’s business office. Estimated Completion Date: December 30, 2024.
Management Responses: The Organization has corrected prior year filings. Moving forward, the Organization will file with the Federal Clearinghouse in a timely manner.
Management Responses: The Organization has corrected prior year filings. Moving forward, the Organization will file with the Federal Clearinghouse in a timely manner.
View Audit 341049 Questioned Costs: $1
See Corrective Action Plan for Chart/Table
See Corrective Action Plan for Chart/Table
See Corrective Action Plan for Chart/Table
See Corrective Action Plan for Chart/Table
Finding 521096 (2023-009)
Significant Deficiency 2023
Condition: Suspension and debarment compliance was not verified for two covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also u...
Condition: Suspension and debarment compliance was not verified for two covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also update our School Contract language to include specific wording where the Vendor acknowledges the law and forfeits the contract if they are on the debarment list after the contract has been signed. A statement will be added to the contracts that states the following: ‘The Contractor (or use the term in the contract that identifies the vendor instead of Contractor) certifies under the pains and penalties of perjury, that the Contractor is not currently debarred or suspended by the Federal government, or any of its agencies, entities or subdivisions, nor is the Contractor currently debarred or suspended by the Commonwealth Massachusetts or any of its agencies, entities or subdivisions.’ If there is a section in the contract where the vendor certifies to other conditions (i.e. state taxes paid), then this language could be included under that section as another certification requirement. A Google Drive has been created to upload all supporting documents on a yearly basis. Anticipated Completion Date: 2/17/2025 Contact: Noel Velez, Director of Finance and Fiona Maxwell, Procurement Director
Condition: Five vendors were awarded a contract without a competitive procurement process. Corrective Action Planned: Complete competitive procurement will be done via the federal guidelines for Purchase Orders below and over the $50,000.00 threshold. This means upholding the laws laid out in 20...
Condition: Five vendors were awarded a contract without a competitive procurement process. Corrective Action Planned: Complete competitive procurement will be done via the federal guidelines for Purchase Orders below and over the $50,000.00 threshold. This means upholding the laws laid out in 200.319 by allowing competitive bidding for each contract given out to a vendor by soliciting quotes and having a written internal procedure with the help of the audit team. We will create a Google folder to upload all supporting documents on a yearly basis. Anticipated Completion Date: 2/17/2025 Contact: Noel Velez, Director of Finance
View Audit 341024 Questioned Costs: $1
Condition: The City did not reconcile its 2021 and 2022 revenue loss calculations with the final adjusted general ledger. Calendar year 2021 revenue was understated by $5,040,960 and calendar year 2022 revenue was understated by $1,455,486 in the 2021 and 2022 revenue loss calculations, respective...
Condition: The City did not reconcile its 2021 and 2022 revenue loss calculations with the final adjusted general ledger. Calendar year 2021 revenue was understated by $5,040,960 and calendar year 2022 revenue was understated by $1,455,486 in the 2021 and 2022 revenue loss calculations, respectively. Corrective Action Planned: Revenue reports for Calendar years 2020 - 2023 have been re-run and revenue loss calculations have been re-run by ARPA consultant for those years with results given to Auditors. Anticipated Completion Date: Complete Contact: Robert Dickinson, City Auditor
Finding 521085 (2023-007)
Significant Deficiency 2023
Condition: Suspension and debarment compliance was not verified for five covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also ...
Condition: Suspension and debarment compliance was not verified for five covered transactions. Corrective Action Planned: All Purchase Order requests that are associated with a federal government grant will all have an attached list showing the company is not on the debarment list. We will also update our School Contract language to include specific wording where the Vendor acknowledges the law and forfeits the contract if they are on the debarment list after the contract has been signed. A statement will be added to the contracts that states the following: ‘The Contractor (or use the term in the contract that identifies the vendor instead of Contractor) certifies under the pains and penalties of perjury, that the Contractor is not currently debarred or suspended by the Federal government, or any of its agencies, entities or subdivisions, nor is the Contractor currently debarred or suspended by the Commonwealth Massachusetts or any of its agencies, entities or subdivisions.’ If there is a section in the contract where the vendor certifies to other conditions (i.e. state taxes paid), then this language could be included under that section as another certification requirement. A Google Drive has been created to upload all supporting documents on a yearly basis. Anticipated Completion Date: 2/17/2025 Contact: Noel Velez, Director of Finance and Fiona Maxwell, Procurement Director
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency. Corrective Action Planned: No applications were submitted to be verified. The school district prompted caregivers on numerous occasions to return the forms witho...
Condition: The Food Service Department did not perform its verification process by the date required by the state pass-through agency. Corrective Action Planned: No applications were submitted to be verified. The school district prompted caregivers on numerous occasions to return the forms without receiving any. Anticipated Completion Date: 2/17/2025 Contact: Peter Cushing, Assistant Superintendent
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year. Corrective Action Planned: The School District has hired a qualified leader for the School Nutrition Program i...
Condition: Free or reduced meals applications could not be provided. The Food Service Department did not process free or reduced priced meals applications for the 2022-2023 school year. Corrective Action Planned: The School District has hired a qualified leader for the School Nutrition Program in order to comply with the requirements of this program. Additionally, the school district has enrolled all but the Brooks Elementary School as Community Eligibility Provision (CEP) sites and we are no longer required to collect these forms. At the Brooks School, these forms were sent to families from the Brooks School during the FY24 school year. Despite the efforts of the school and Food Services Director, no forms were returned to the school. Presently the forms are not required for the Brooks as the CEP eligibility requirements were reduced from 40% to 25% for determination. Anticipated Completion Date: 2/15/2025 Contact: Peter Cushing, Assistant Superintendent
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. Th...
Condition: Claims support could only be provided by the School for two months. For one month, support was in the form of spreadsheets with tray counts in lieu of a point-of-sale system. For the other month, the tray count spreadsheets were accompanied by reports from the point-of-sale system. The point-of-sale system reports provided did not agree to the amounts claimed for reimbursement. The tray counts did not indicate whether the meal provided was paid, free or reduced. The claims for reimbursement submitted by the School used allocation percentages derived from prior year claims when estimating amounts to be claimed as paid, free and reduced. The tray count spreadsheets for the other months could not be located by the School. Corrective Action Planned: In January 2023 DESE sent an auditor to review the Medford School Nutrition Program. Before this review, there was significantly limited oversight by the central office finance team. Almost no documents were prepared before the review as required by DESE. As a result of this audit a 58-item, 19-page Corrective Action Plan was issued to the district. A new district leader was assigned for departmental oversight. The district then had weekly meetings with DESE to address the corrective action plan, for this was the single largest CAP DESE has issued to any district of our size. Nearly $1.3 million in reimbursements were withheld from the district from approximately November 2022 through the end of the Fiscal Year. DESE issued the reimbursements with a nominal penalty during the summer of 2023. At the end of FY23, the district terminated the director of the program. We are now training several individuals in the MCPPO program for enhanced oversight. DESE forced an immediate return audit for FY24. This was an exceptional action as DESE has only rarely done this. The same reviewer attended and noted significant improvements as a result of district actions undertaken. As relates to this particular finding, the School Department has purchased and is consistently using a point of sale system for students to purchase their meals. The system is used to track all transactions. Anticipated Completion Date: 2/17/2025 Contact: Peter Cushing, Assistant Superintendent
View Audit 341024 Questioned Costs: $1
The Meadows Mental Health Policy Institute for Texas (the Institute) respectfully submits the following corrective action plan for the year ended December 31, 2023. Audit period: 01/01/2023 – 12/31/2023 The findings from the Schedule of Findings and Questioned Costs identified in the December 05, 20...
The Meadows Mental Health Policy Institute for Texas (the Institute) respectfully submits the following corrective action plan for the year ended December 31, 2023. Audit period: 01/01/2023 – 12/31/2023 The findings from the Schedule of Findings and Questioned Costs identified in the December 05, 2024, audit report are discussed below. Findings are numbered consistently with the numbers assigned in the schedule. Findings – Federal Awards Audit Significant Deficiency Federal Awards Program Audit Findings and Recommendations Finding 2023-001: Reporting – significant deficiency in internal control over compliance and compliance finding. All federal grants. Criteria: Grantees who are subject to single audit requirements are required to submit their Data Collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditors’ report or 9 months after the audit period. Condition: The Institute’s Data Collection form was late for the years ended December 31, 2022, and 2023. Cause: Delays in completing the audits resulted in the Data Collection forms being submitted after 9 months from the end of the audit report. Effect: The Institute was not in compliance with single audit reporting requirements. Recommendation: Internal controls and processes should be implemented to ensure audits are completed in a timely manner to meet federal reporting deadlines. Institute Action Plan: • Hire new finance and accounting senior management [completed November 2024]. o Hired new CFO (October 2024; started January 02, 2025) o Hired new Controller (November 2024; starts February 17, 2025) Establish timeline for review and acceptance of 2024 audit [initiated December 2024]. o By May 01, 2025: Institute submits 2024 General Ledger and Trial Balance to auditor o May 01, 2025 – May 11, 2025: Auditor sends sample and other requests for information o May 12, 2025 – May 23, 2025: Audit fieldwork o Week of July 07, 2025: Auditor sends draft audit report to Institute management for review. o Week of July 21, 2025: Institute management reviews draft audit report and notes areas needing clarification and/or corrections. o By Week of August 11, 2025: Auditor provides a final revised audit report to Institute management. o Week of August 18, 2025: Institute management sends audit report to the Institute Board’s Audit and Finance Committee for review. o By week of September 1, 2025: The Audit and Finance Committee meets to review and accept final audit report on behalf of the Board. o By September 15, 2025: Data Collection Form is submitted to the Federal Audit Clearinghouse (i.e., well in advance of the September 30, 2025, submission due date for the Data Collection Form). o October 29, 2025: The Institute Board ratifies the Audit and Finance Committee’s acceptance of final audit report. • Q1-Q2 2025: Perform gap analysis evaluation of existing Accounting staff and address any gaps in coverage and provide access to and training on financial systems and historical data archives [initiated and ongoing]. Corrective Action Contact Person(s): Maryana Geller, Chief Financial and Administrative Officer Planned Completion Date for Corrective Action Plan: September 15, 2025
Accounts payable testing and internal controls. A. Name of contact person responsible for corrective action: Name: Delorean Hall Title: Business Manager B. Corrective action planned: The District will implement policies and procedures to establish an internal control system that will requi...
Accounts payable testing and internal controls. A. Name of contact person responsible for corrective action: Name: Delorean Hall Title: Business Manager B. Corrective action planned: The District will implement policies and procedures to establish an internal control system that will require accountability with regard to accounts payable and purchasing. The District will ensure all purchasing laws are being followed. C. Anticipated completion date: Immediately
See Corrective Action Plan table/chart.
See Corrective Action Plan table/chart.
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