Corrective Action Plans

Finding 1160395 (2023-004)

Material Weakness 2023

California Asian Pacific Chamber of Commerce

CA

Allowable Costs / Cost Principles Significant Deficiency § 200.400

Finding Reference Number: 2023-004 Description of Finding: The allocation of payroll costs to programs are done manually instead of done based on entity-wide timesheets. Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. C...

Finding Reference Number: 2023-004 Description of Finding: The allocation of payroll costs to programs are done manually instead of done based on entity-wide timesheets. Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian acknowledges the serious nature of this finding and the potential for damage to relationships with the grantors and Federal entities. The Controller and Director of Finance have implemented an ERP system which allows for better cost collection, reporting and reviews of the grant-related expenses for accuracy, reliability, and reconciliation.We also understand these findings are repetitive from the 2021 and 2022 audits; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2023 audit. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. The implemented ERP system includes electronic timesheets for daily charging to specific grants, as well as more visibility into the proper separation of direct, indirect, and unallowable costs per the CFR. Timesheet training has been performed and timesheet completion is required for all employees each day. This began effective January 1, 2025 and provides support for hours worked/billed, as well as documentation of the certification and approvals that all staff time entered is accurate and in compliance with contract requirements and provides proper support for all grant labor costs and indirect costs. Monthly reviews by the Project Directors/Managers plus Accounting will be performed to identify any potential cost charging issues and corrective action(s) required. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Susan Wright, Controller, 256-689-7055, swright@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: January 2025

View Audit 370809

Finding 1160394 (2023-003)

Material Weakness 2023

California Asian Pacific Chamber of Commerce

CA

Reporting Internal Control / Segregation of Duties Material Weakness § 200.510

Finding Reference Number: 2023-003 Description of Finding: SEFA reporting Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian acknowledges the significance of this finding and the potential for n...

Finding Reference Number: 2023-003 Description of Finding: SEFA reporting Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian acknowledges the significance of this finding and the potential for noncompliance with Uniform Guidance with the grantors and Federal entities, as well as potential increased risk of omitted federal programs and incorrect major program determination. Moving forward, SEFA reporting will be reviewed and approved by multiple reviewers, including the President & CEO, Controller, and Director of Finance. Individual directors under relevant federal programs being reported on the SEFA will also be required to review that the information listed on the SEFA report is complete and accurate. This review process will be in place for the 2024 audit and subsequent audits. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: September 2025

View Audit 370809

Finding 1160393 (2023-002)

Material Weakness 2023

California Asian Pacific Chamber of Commerce

CA

Procurement, Suspension & Debarment § 200.318 § 200.320 § 200.327 § 200.339

Finding Reference Number: 2023-002 Description of Finding: Lack of documentation on sole source contracts and verification of vendors Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understan...

Finding Reference Number: 2023-002 Description of Finding: Lack of documentation on sole source contracts and verification of vendors Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the serious nature of this finding and the compliance required with 2 CFR sections 200.318 through 200.327, as well as Part 1326 for vendor exclusions. The Controller and Director of Finance updated procedures to document requirements for all procurement activities, regardless of type. We also understand these findings are repetitive from the 2021 and 2022 audits; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2023 audit, as 2021 and 2022 audit reports were not received until 2024. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. Resolution of this issue began in 2024 as the procurement policy was distributed to staff and reviewed during staff meetings. Further, the policy and procedures for procurement were reviewed directly with programmatic staff to ensure that they were familiar with the policies and what is required to be captured for documentation to ensure all procurement activities adhere to the company policies. Continuing education for staff will be provided in subsequent years to ensure continued compliance with these policies. Periodic reviews of the procurement activities will be performed to ensure compliance with these procedures to mitigate the risk of continued deficiencies. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: December 2024

View Audit 370809

Finding 1160392 (2023-001)

Material Weakness 2023

California Asian Pacific Chamber of Commerce

CA

Reporting Subrecipient Monitoring Material Weakness

Finding Reference Number: 2023-001 Description of Finding: Untimely audit submission in accordance with OMB Uniform Guidance Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the se...

Finding Reference Number: 2023-001 Description of Finding: Untimely audit submission in accordance with OMB Uniform Guidance Statement of Concurrence or Nonconcurrence: The California Asian Pacific Chamber of Commerce (CalAsian) agrees with the finding. Corrective Action: CalAsian understands the seriousness of this deficiency and the need for strict adherence to timely audit submissions per the OMB Uniform Guidance. Additional staff have been hired to assist in accounting processes, including a Controller to review all accounting processes and procedures with the Director of Finance, implement best practice recommendations and month-end closing schedule. We also understand these findings are repetitive from the 2021 and 2022 audits; however, due to catch-up of the prior year audits, we were unable to address these issues prior to completion of the 2023 audit. This delay was caused by a change in auditors as our previous auditor did not have the capacity to retain us as clients due to staff shortages related to COVID. An outside finance and accounting firm has been hired to provide additional support to bring the audits current by March 2026. This issue will be further mitigated in subsequent periods with the implementation of the new accounting system, which was implemented effective January 2025. Monthly reviews of the 2024 financial data, including reconciliations of all accounts were performed and reviewed by the Controller and Director of Finance. This will allow us to provide the 2024 financial data to the auditors in a more timely manner to ensure completion and submission of the audit per the OMB guidance. Continued compliance with these new procedures will help to mitigate the risk of untimely submissions in future years. Name of Contact Person: Ryan Fong, Director of Finance, 916-446-7883, rfong@calasiancc.org Pat Fong Kushida, President & CEO, 916-446-7883, patfongkushida@calasiancc.org Projected Completion Date: March 2026

View Audit 370809

Finding 1160387 (2023-001)

Material Weakness 2023

Municipality of Madison

SD

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

The City of Madison will finalize and adopt a formal, written procurement policy that complies with the Uniform Guidance (2CFR 200.318) and ensures consistency with federal, state, and local requirements. The plan will include: Procurement Policy Development: Implementation of a comprehensive writte...

The City of Madison will finalize and adopt a formal, written procurement policy that complies with the Uniform Guidance (2CFR 200.318) and ensures consistency with federal, state, and local requirements. The plan will include: Procurement Policy Development: Implementation of a comprehensive written policy covering competitive bidding, conflict of interest standards, and documentation requirements. Staff Training: Provide training for all personnel responsible for federal award administration to ensure understanding and compliance with procurement and internal control expectations. Monitoring and Review: Establish a periodic review process to evaluate procurement practices and ensure ongoing compliance with federal regulations.

View Audit 370803

Finding 1160385 (2023-002)

Material Weakness 2023

Municipality of Ciales

PR

Reporting

We recommend that the Project should start the process of compiling and preparing the financial information to complete the Financial Statements and the Schedule of Expenditures of Federal Awards with enough time to assure that such information is available for the audit process, before March 31, an...

We recommend that the Project should start the process of compiling and preparing the financial information to complete the Financial Statements and the Schedule of Expenditures of Federal Awards with enough time to assure that such information is available for the audit process, before March 31, and to provide it with enough time so the audit process can be completed before such due date.

View Audit 370795

Finding 1160384 (2023-001)

Material Weakness 2023

Municipality of Ciales

PR

Cash Management HUD Housing Programs

: Management must strengthen internal controls to ensure that it meets the deadline period for making the deposit to the Residual Receipt Bank Account in the event of a surplus cash.

View Audit 370795

Finding 1160370 (2023-002)

Material Weakness 2023

Detroit Rescue Mission Ministries and Lakeview Farms Missions

MI

Reporting Internal Control / Segregation of Duties

Management has implemented enhanced review processes to ensure accuracy in key accounts and prevent discrepancies. A formal review procedure is now in place to examine journal entries before they are posted.

View Audit 370770

Finding 1160369 (2023-001)

Material Weakness 2023

Detroit Rescue Mission Ministries and Lakeview Farms Missions

MI

Reporting

Management will ensure that the books are closed within 45 days of the end of each reporting period. To support this timeframe, we have put a dedicated team in place. Additionally, a month-end checklist has been established to confirm that all tasks are completed on schedule.

View Audit 370770

Finding 1160368 (2023-005)

Material Weakness 2023

Redevelopment Authority of the County of Lancaster

NJ

Internal Control / Segregation of Duties Allowable Costs / Cost Principles HUD Housing Programs § 200.328

Corrective Action Plan For the year ended December 31, 2023 The Housing Authority of the City of Hoboken respectfully submits the following corrective action plan for the year ended September 30, 2024. Auditor: Polcari & Company CPA 2035 Hamburg Tpke Unit H Wayne, New Jersey 07470 The findings from ...

Corrective Action Plan For the year ended December 31, 2023 The Housing Authority of the City of Hoboken respectfully submits the following corrective action plan for the year ended September 30, 2024. Auditor: Polcari & Company CPA 2035 Hamburg Tpke Unit H Wayne, New Jersey 07470 The findings from December 31, 2023, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding- 2023-005 Redevelopment Authority – CDBG Type of Deficiency – Significant Deficiency Compliance Requirement – Reporting The Authority did not file accurate and timely PR-26 “Financial Summary Report” and PR-29 “Cash on Hand Report” as required. The PR-29 report is HUD’s quarterly cash on hand report of CDBG and CDBG-CV Programs Cause: The Authority did not implement proper controls, including a review process to ensure that quarterly and year-end reporting information extracted from IDIS were accurate and timely reported as required. Condition: The Authority did not have proper controls in place to ensure that quarterly and year-end reports were done in a timely manner. Criteria: The Authority is required under 24CFR570.502(b) to remit the annual performance report PR-26 specifying the amount of funds drawn from the IDIS system 90 days after year end. Under CFR 200 – Uniform Administrative Requirements, Cost Principles and Audit Requirements Subpart D section 200.328 the PR-29 quarterly report is required to be submit quarterly no later than 30 days after year end Effect of Condition: The effect of not accurate and timely reporting affects HUD’s ability to analyze program activities and properly fund programs to meet the needs of the populations served. View of Responsible Officials and Corrective Actions: This report was late every month in 2023, due to the new Finance Director trying to research and submit the correct numbers to HUD. In 2024 this report was submitted timely. If there are any questions regarding this plan, please contact: Justin Eby Executive Director (717) 394-0793 jeby@lchra.com

View Audit 370757

Finding 1160367 (2023-002)

Material Weakness 2023

Choctaw County City of Hugo Hospital Authority Dba Choctaw Memorial Hospital

OK

Allowable Costs / Cost Principles Eligibility Material Weakness § 200.303

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting - Material Weakness in Internal Control over Compliance Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.498 Program Name: Provider Relief Fund and American Rescue Plan (ARP) Rur...

Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting - Material Weakness in Internal Control over Compliance Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.498 Program Name: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: There was no documentation of review and approval of the expenditure listing, lost revenue calculation, or the Department of Health and Human Services Period 4 report prior to submission of the HHS Period 4 report. Responsible Individuals: Dawn Ballard Corrective Action Plan: Management agrees with the finding. Due to the small accounting staff, there was little internal review of the calculations resulting in unallowed expenditures based on underlying supporting schedules that was not recognized until single audit. The Authority has adopted policies where every spreadsheet and schedule will be reviewed and checked by a second member of the Administration team as well as final review by the Contracted CPA. Anticipated Completion Date: September 29, 2023

View Audit 370750

Finding 1160366 (2023-001)

Material Weakness 2023

Choctaw County City of Hugo Hospital Authority Dba Choctaw Memorial Hospital

OK

Allowable Costs / Cost Principles Material Weakness Reporting § 200.303

Reporting - Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.498 Program Name: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: The Author...

Reporting - Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Agency Name: Department of Health and Human Services Assistance Listing Number: 93.498 Program Name: Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution Finding Summary: The Authority selected Option 1, as defined by HRSA, to calculate lost revenue. This option consists of reporting actual revenues from relevant quarters in the period of availability with the system calculating lost revenues because of declines. The fiscal year 2021 single audit identified unallowable expenses totaling $263,861. The Authority utilized excess lost revenues at the time to cover this difference. To capture the use of these lost revenues from Period 1, the Authority should have used Option 3, as defined by HRSA, to calculate and report lost revenues. Within that calculation, lost revenues could then be reduced by the $263,861. Responsible Individuals: Dawn Ballard Corrective Action Plan: Due to the timing of completion of the 2021 single audit, which included the identification of questioned costs, and the deadline for the Period 4 Provider Relief Fund report to the HHS portal, the Period 4 report was submitted utilizing Option 1. The Authority does not expect to complete any additional HHS reports related to this program. Management will implement a process and procedures to ensure all required reports are completed accurately, in the event similar funding is received in the future. Anticipated Completion Date: January 16, 2025

View Audit 370750

Finding 1160362 (2023-004)

Material Weakness 2023

Kansas Alliance for Wetlands and Streams INC

KS

Internal Control / Segregation of Duties

2023-004: Internal Control over Cash Management and Matching Responsible Party: Libby Albers, Executive Director Implementation Date: 1/21/2025 The KAWS Executive Director sends drafts of every affidavit to six of the staff funded by EPA 31 grants. As additional grant projects came onboard, this eff...

2023-004: Internal Control over Cash Management and Matching Responsible Party: Libby Albers, Executive Director Implementation Date: 1/21/2025 The KAWS Executive Director sends drafts of every affidavit to six of the staff funded by EPA 31 grants. As additional grant projects came onboard, this effective review approach was not carried over through the new grants. This oversight was discussed during the audit and the same affidavit review process was applied to the other EPA 319 grant.

View Audit 370743

Finding 1160361 (2023-003)

Material Weakness 2023

Kansas Alliance for Wetlands and Streams INC

KS

Questioned Costs Allowable Costs / Cost Principles Reporting

2023-003: Allowable Costs of Indirect Costs Responsible Party: Libby Albers, Executive Director Implementation Date: 11/1/2025 The KAWS Executive Director requested reimbursements of audit expenses that included contractual invoices and billing for direct hours spent on the effort. However, the Dire...

2023-003: Allowable Costs of Indirect Costs Responsible Party: Libby Albers, Executive Director Implementation Date: 11/1/2025 The KAWS Executive Director requested reimbursements of audit expenses that included contractual invoices and billing for direct hours spent on the effort. However, the Director neglected to follow up with the independent account to transfer reimbursement of the personnel hours out of the grant and into the administrative project code. The KAWS Executive Director will request a P&L by job report from the accountant on an annual basis and again when a grant is closing to ensure that any costs recorded as direct or indirect administrative expenses have been moved to the administrative project code and out of the grant.

View Audit 370743 Questioned Costs: $1

Finding 1160360 (2023-002)

Material Weakness 2023

Kansas Alliance for Wetlands and Streams INC

KS

Internal Control / Segregation of Duties

2023-002: Oversight over the Revenue Process Responsible Party: Libby Albers, Executive Director Implementation Date: Originally 2/15/2024, revised to retroactively begin with the 1/1/2025 statement 1. KAWS Executive Director will continue to log deposits and deposit documentation in an internal spr...

2023-002: Oversight over the Revenue Process Responsible Party: Libby Albers, Executive Director Implementation Date: Originally 2/15/2024, revised to retroactively begin with the 1/1/2025 statement 1. KAWS Executive Director will continue to log deposits and deposit documentation in an internal spreadsheet and reporting each deposit to the KAWS accountant via email. The Conservation Easement Specialists will check the deposit spreadsheet against the monthly bank statement to ensure that all deposits are present. This extra reviewer of bank statements is independent of any of the parties handling the deposits. 2. The Executive Director will request a monthly reconciliation report from the independent accountant and the Conservation Easement Specialist will compare the data against the expense reporting platforms, payment requests, and bank statements. The Conservation Easement Specialists will provide an email response upon completion of the review of the statements.

View Audit 370743

Finding 1160359 (2023-001)

Material Weakness 2023

Kansas Alliance for Wetlands and Streams INC

KS

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

2023-001: Financial Reporting on Indirect Costs Responsible Party: Libby Albers, Executive Director Implementation Date: 1/29/2025 1. The KAWS WRAPS grants are multi-year grants. To date, KAWS has reported a flat indirect rate on each affidavit split evently across the reporting periods of the grant...

2023-001: Financial Reporting on Indirect Costs Responsible Party: Libby Albers, Executive Director Implementation Date: 1/29/2025 1. The KAWS WRAPS grants are multi-year grants. To date, KAWS has reported a flat indirect rate on each affidavit split evently across the reporting periods of the grant. With the additional reimbursement of the audit expenses in 2023, and loss of Assistant Director position, 2023 closed out with less administrative expenses than had been budgeted. 2. The Executive Director requested and received written acknowledgement from the Kansas Department of Health and Environment that the unexpected adminstrative income from 2023 could be applied to expenses incurred in 2024.

View Audit 370743

Finding 1160358 (2023-002)

Material Weakness 2023

Arizona's Children Association

AZ

Allowable Costs / Cost Principles Reporting

The unallowable expenses were "replaced" by unreimbursed lost revenue. All expenses that were submitted are being replaced by unreimbursed lost revenue.

View Audit 370742

Finding 1160357 (2023-002)

Material Weakness 2023

City of Middlesboro, Kentucky

KY

Reporting

The City has submitted the report timely for the period of April 1, 2023-March 31, 2024. The missed reporting deadline was a one-off and all other reporting deadlines for the grant have been met.

View Audit 370741

Finding 1160352 (2023-002)

Material Weakness 2023

Legal Aid of Northwest Texas

TX

Reporting

Finding 2023-002 Major Federal Program: 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Compliance Requirements: Reporting Response: LANWT acknowledges that the SEFA initially submitted to the auditors included a clerical error in the FALN classification for Contract #1696416. ...

Finding 2023-002 Major Federal Program: 21.027 - COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Compliance Requirements: Reporting Response: LANWT acknowledges that the SEFA initially submitted to the auditors included a clerical error in the FALN classification for Contract #1696416. The $1,617,909 in expenditures was inadvertently reported under FALN 16.575 rather than the correct FALN 21.027 in the SEFA spreadsheet. However, the expenditures were allowable, properly documented, and fully supported by the grant agreement, which was provided to the auditors during fieldwork. LANWT respectfully disagrees with the classification of this matter as a compliance finding and significant deficiency. The misclassification did not involve any questioned costs, noncompliance with the grant terms, or omission of federal expenditures. The auditors had access to the source grant documentation, which clearly identified the correct FALN. In our view, this error was a joint oversight that resulted in a SEFA presentation correction, not a failure in internal control or compliance. Corrective Action: To prevent recurrence, LANWT has strengthened its SEFA preparation process by implementing the following procedures: All SEFA entries are now reviewed against source grant agreements by two independent finance staff members prior to submission. A checklist has been introduced to confirm correct ALNs and funding sources before SEFA finalization. Internal training has been conducted on SEFA requirements, including proper identification and reporting of federal assistance listing numbers. In future audits, LANWT will also request that the audit firm verify that the ALN and program name recorded on the SEFA are consistent with those identified in the source grant agreements, which are made available to the auditors during field work. The Chief Financial Officer (CFO) is responsible for ensuring the implementation and ongoing oversight of these corrective actions. LANWT remains committed to accurate and compliant reporting and appreciates the opportunity to clarify this matter. Date of Completion: June 20, 2025 Person Responsible to Ensure Completion: Bhuvana Kannan, CFO

View Audit 370737

Finding 1160351 (2023-001)

Material Weakness 2023

Legal Aid of Northwest Texas

TX

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Finding 2023-001 Major Federal Program; 09.744050 – Legal Services Corporation – Basic Field Grant Compliance Requirements: Allowable Cost and Cost Principles Response and Corrective Action: The Chief Executive Officer (CEO) and LANWT accounting department will review and train on 45 CFR 1631 regard...

Finding 2023-001 Major Federal Program; 09.744050 – Legal Services Corporation – Basic Field Grant Compliance Requirements: Allowable Cost and Cost Principles Response and Corrective Action: The Chief Executive Officer (CEO) and LANWT accounting department will review and train on 45 CFR 1631 regarding the subject of Purchasing and Property Management. LANWT will review its policies and protocols to require prior purchase approval and exigent circumstances approval. Deadlines shall be calendared by the CEO and the accounting department whenever there is an exigent circumstance and approval will need to be requested within the 30-day notice period. The CEO will remain in periodic contact with LSC if any extenuating circumstances exist. The accounting manual will be updated with this protocol. Date of Completion: June 1, 2024 Person Responsible to Ensure Completion: Maria Thomas-Jones, CEO

View Audit 370737 Questioned Costs: $1

Finding 1160349 (2023-004)

Material Weakness 2023

Roanoke-Chowan Regional Housing Authority

NC

HUD Housing Programs Eligibility

1. Revisiting AMA Consulting Group Proposal:_x000B_RCRHA is in the process of revisiting a formal proposal previously received from AMA Consulting Group, LLC, which outlines a detailed "Agency Health Check" for our Public Housing program. This proposal includes: • An operational audit of tenant file...

1. Revisiting AMA Consulting Group Proposal:_x000B_RCRHA is in the process of revisiting a formal proposal previously received from AMA Consulting Group, LLC, which outlines a detailed "Agency Health Check" for our Public Housing program. This proposal includes: • An operational audit of tenant files and eligibility documentation • Process mapping to improve workflow and accountability • Quality control implementation • Recommendations for electronic file storage and ongoing compliance monitoring. 2. Recent Staff Training: Nan McKay Rent Calculation Course:_x000B_To immediately address gaps in eligibility documentation practices, RCRHA staff participated in the Nan McKay HCV and Public Housing Rent Calculations Course, held March 18-20, 2025, in Washington, NC._x000B_The three-day seminar provided comprehensive instruction in: • Income and asset verification under 24 CFR Part 5 • Adjusted income and allowable deductions • Total Tenant Payment (TTP) calculations for both HCV and Public Housing • Case study applications using HUD Form 50058. 3. Internal File Review and Compliance Checklist Implementation:_x000B_RCRHA has initiated a review of all active Public Housing tenant files to ensure that required eligibility documents are present, accurate, and properly stored. A standardized checklist is being introduced to guide staff and ensure uniform compliance across all tenant records. 4. Electronic File System Evaluation:_x000B_In alignment with HUD best practices and our consultant's recommendation, RCRHA is evaluating the feasibility of transitioning to an electronic document management system to ensure long-term retention, audit readiness, and streamlined access to eligibility documentation.

View Audit 370734

Finding 1160312 (2023-002)

Material Weakness 2023

Trailhead Institute

CO

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.331 § 200.332 § 200.339 § 200.425 § 200.501

Trailhead is establishing a new Contract and Compliance Coordinator role to oversee contract compliance processes and to ensure that Trailhead’s policy on subrecipient monitoring is followed. This role will be responsible for ensuring that compliance requirements are integrated at the outset of each...

Trailhead is establishing a new Contract and Compliance Coordinator role to oversee contract compliance processes and to ensure that Trailhead’s policy on subrecipient monitoring is followed. This role will be responsible for ensuring that compliance requirements are integrated at the outset of each grant. This role will be responsible for internal monitoring and auditing. This role will ensure that all grant kick-off meetings follow a standard procedure and include: 1) A clear understanding of federal requirements for all involved fiscal, program, and compliance staff 2) Delegated assignments to program staff for implementing and documenting: a) Suspension and debarment prior to contracting with subrecipients b) Subrecipient vs contractor determinations c) Evaluation of each subrecipient’s risk of noncompliance i) Establish the appropriate subrecipient monitoring level based on risk. This compliance role will have the authority to ensure the procedures are completed by the assigned staff. Evidence of the completed procedure must be documented and saved in a newly created contracts database. This database will be a centralized storage that will be reviewed during internal compliance checks to ensure all required steps have been completed and documented. These documents and associated grant and contract documents will be part of an official repository.

View Audit 370698

Finding 1160310 (2023-001)

Material Weakness 2023

Trailhead Institute

CO

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting

Trailhead is establishing a new Compliance Coordinator role to oversee contract compliance processes. This role will be responsible for ensuring that compliance requirements are integrated at the outset of each grant and contract, that all necessary documents are properly filed, and that ongoing mon...

Trailhead is establishing a new Compliance Coordinator role to oversee contract compliance processes. This role will be responsible for ensuring that compliance requirements are integrated at the outset of each grant and contract, that all necessary documents are properly filed, and that ongoing monitoring is in place. This role will be responsible for internal monitoring and auditing. This role will ensure that all grant kick-off meeting follow a standard procedure, including a clear understanding of federal requirements. This position will either complete the FFATA themselves or delegate the responsibility to another. This role will have authority for ensuring the procedures are completed. Furthermore, evidence of the completed procedure will be documented and saved in a newly created contracts database. This database is a centralized storage that will be reviewed during internal compliance checks to ensure all required steps have been completed and documented.

View Audit 370698

Finding 1160271 (2023-002)

Material Weakness 2023

Heart of Georgia Regional Airport Authority

GA

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

THE BOARD WILL DOCUMENT THE PROCUREMENT PROCEDURES FOR FEDERAL AWARDS AND SUBAWARDS.

View Audit 370658

Finding 1160233 (2023-002)

Material Weakness 2023

Blue Mountain Land Trust

WA

Procurement, Suspension & Debarment § 200.318 § 200.326

Action taken in response to finding: BMLT’s Board of Directors adopted a written procurement policy at its July 26, 2025, Board meeting.

View Audit 370625

Corrective Action Plans

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