Corrective Action Plans

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·       Provide training to relevant staff on federal suspension and debarment requirements.
·       Provide training to relevant staff on federal suspension and debarment requirements.
·       Conduct periodic reviews to ensure ongoing compliance with federal regulations.
·       Conduct periodic reviews to ensure ongoing compliance with federal regulations.
·       Require a certification related to not being suspended or barred when I-9s are received from vendors.
·       Require a certification related to not being suspended or barred when I-9s are received from vendors.
2023-006 – Major Program Disbursements Were Not Processed in Accordance with the Control Procedures Designed by the Organization.
2023-006 – Major Program Disbursements Were Not Processed in Accordance with the Control Procedures Designed by the Organization.
Views of Responsible Officials and Planned Corrective Actions:
Views of Responsible Officials and Planned Corrective Actions:
We agree that not all transactions complied with our internal control procedures. We expect this to no longer be an issue due to change in Lead The Way Learning Academy’s management team.
We agree that not all transactions complied with our internal control procedures. We expect this to no longer be an issue due to change in Lead The Way Learning Academy’s management team.
Finding No. 2023-002- Corrective Action Plan 1. Name of the contact person responsible for corrective action: Anthony G Caputo 2. Corrective action planned: Management will ensure that all future reporting will be prepared by an accounting official and be reviewed by a reviewer who is a level above ...
Finding No. 2023-002- Corrective Action Plan 1. Name of the contact person responsible for corrective action: Anthony G Caputo 2. Corrective action planned: Management will ensure that all future reporting will be prepared by an accounting official and be reviewed by a reviewer who is a level above the preparer. Management will also maintain evidence of the review process. 3. Anticipated completion date: The new processes and revenue reconciliation will be implemented immediately for any future PRF submissions. 4. If the client does not agree with the audit findings or believes corrective action is not required, include an explanation and specific reasons: We agree with finding No. 2023-002
Recommendation: The Organization should ensure that terms and conditions of grant awards are reviewed to identify unallowable activities. The Organization should also implement procedures to ensure that costs being charged to the grant program are reviewed and approved. Views of Responsible Official...
Recommendation: The Organization should ensure that terms and conditions of grant awards are reviewed to identify unallowable activities. The Organization should also implement procedures to ensure that costs being charged to the grant program are reviewed and approved. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will work closely with the CFAO and FM to immediately implement a process to ensure that terms and conditions of state and/or federal grant awards are reviewed by the CFAO and FM to identify unallowable activities. Identification of unallowable activities will be conveyed to all relevant parties. BGCCG management will also work closely with the CFAO and FM to implement procedures for pre-reviewing and pre-approval of all recommended purchases/costs to be charged to state and/or federal grant programs. Acknowledged, Phillip Bryant President & CEO
Recommendation: The Organization should establish procedures to ensure that timesheets for all employees charging time to Federal grant programs are reviewed and approved and to ensure that all non-payroll expenditures charged to Federal grant programs are reviewed and approved. Views of Responsibl...
Recommendation: The Organization should establish procedures to ensure that timesheets for all employees charging time to Federal grant programs are reviewed and approved and to ensure that all non-payroll expenditures charged to Federal grant programs are reviewed and approved. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will work closely with the CFAO and FM to immediately implement a process to ensure that timesheets for all employees charging time to any Federal grant programs are reviewed and approved by the employee’s immediate supervisor, FM and CFAO, and/or CEO. BGCCG management will also work closely with the CFAO and FM to immediately implement a process to ensure that all non-payroll expenditures charged to Federal grant programs are reviewed and pre-approved by the FM and CFAO, and/or CEO. Acknowledged, Phillip Bryant President & CEO
Recommendation: The Organization should establish procedures to ensure that timesheets for all employees charging time to Federal grant programs are reviewed and approved. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of R...
Recommendation: The Organization should establish procedures to ensure that timesheets for all employees charging time to Federal grant programs are reviewed and approved. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will work closely with the CFAO and FM to immediately implement a process to ensure that timesheets for all employees charging time to any Federal grant programs are reviewed and approved by the employee’s immediate supervisor, FM and CFAO. Acknowledged, Phillip Bryant President & CEO
Recommendation: Marshall Jones recommends that the Organization establish a process to close their year-end books in a timely manner and begin the audit well in advance of the filing deadline for the data collection form and reporting package. Views of Responsible Officials: Management of BGCCG ack...
Recommendation: Marshall Jones recommends that the Organization establish a process to close their year-end books in a timely manner and begin the audit well in advance of the filing deadline for the data collection form and reporting package. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will work closely with the CFAO and FM to immediately implement a process to close out its 2024 fiscal year-end books in a timely manner. BGCCG will seek to close out its 2024 fiscal year-end books on or before March 30, 2025, and will seek to begin the 2024 auditing process on or before June1, 2025, well in advance of the filing deadline for the data collection form and reporting package. Acknowledged, Phillip Bryant President & CEO
Recommendation: Marshall Jones recommends that the Organization receive additional assistance in improving their financial reporting processes from individuals who are familiar with GAAP. Marshall Jones also recommends that management establish policies and procedures to ensure that management level...
Recommendation: Marshall Jones recommends that the Organization receive additional assistance in improving their financial reporting processes from individuals who are familiar with GAAP. Marshall Jones also recommends that management establish policies and procedures to ensure that management level reviews of monthly and annual financial information are performed on a timely basis. Views of Responsible Officials: Management of BGCCG acknowledges the finding and concurs with the recommendation. Response of Responsible Officials: To continuously improve BGCCG’s Accounting and Financial Reporting, workflow, and internal controls, BGCCG has begun the process to transition the back-office accounting providers from part-time status to full-time status to sufficiently accommodate the needs of the Organization. BGCCG will employ a full-time Chief Finance & Administrative Officer (CFAO), preferably with CPA/CGMA certification, and strong analytical and financial modeling and forecasting skills as well as deep knowledge of GAAP for nonprofits. This pivotal role will provide strategic direction to ensure the financial health of the Organization while driving innovative financial solutions. The CFAO will oversee all financial and accounting operations of the Organization, including the creation and execution of sound financial policies, procedures and internal controls, budgeting, accounting, cash and debt management, audits, investments, tax compliance, and weekly Accounting and Finance reporting to the CEO and Board Finance Chair. The CFAO will report directly to the CEO. This position will be employed on or before December 31, 2024. BGCCG will also employ a full-time Finance Manager (FM) with commensurate experience that demonstrates exemplary strategic and financial acumen. The FM will be responsible for intermediate-level finance and accounting functions such as general ledger/account maintenance, timely account reconciliation, accounts payable, accounts receivables, data processing, payroll processing, and reporting to the CFAO. The FM will report directly to the CFAO. This position will be employed on or before December 31, 2024. Upon the hiring and on-boarding of the CFAO and FM, BGCCG will immediately begin the process of updating its Financial Management & Accounting Control Policies & Procedures to further strengthen BGCCG’s internal controls. Corrective Action Plan: Upon the hiring and on-boarding of the new full-time CFAO and FM, management of BGCCG will ensure the back-office finance and accounting providers seek and attend professional development trainings as often as possible, in addition to receiving additional assistance from the Board Finance Chair and Treasurer, and CEO to continue improving the financial reporting processes as recommended. Management of the Organization will begin to work closely with the CFAO and FM to conduct weekly, monthly, and semi-annual financial reviews to ensure operational compliance, accuracy, and timely reporting of financial matters. Acknowledged, Phillip Bryant President & CEO
Management Comments: Management agrees with the finding and will implement the recommendation of reviewing the process of providing information to the independent auditor ensure timely filings in the future.
Management Comments: Management agrees with the finding and will implement the recommendation of reviewing the process of providing information to the independent auditor ensure timely filings in the future.
Finding 509773 (2023-006)
Significant Deficiency 2023
CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: Management should develop a procedure to track its federal award advances to ensure those funds are placed in interest-bearing accounts, when applicable, and any interest earnings on those funds are separately tracked, repo...
CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: Management should develop a procedure to track its federal award advances to ensure those funds are placed in interest-bearing accounts, when applicable, and any interest earnings on those funds are separately tracked, reported, and remitted in accordance with the program requirements. A documented review of this activity should be performed by a knowledge individual who is aware of the program requirements prior to reporting or remitting payment back to the federal agency. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will ensure funds that are not being used from federal awards be placed in interest-bearing accounts and any interest earnings on those funds will be tracked. Name(s) of the contact person(s) responsible for corrective action: Arlo Washington Planned completion date for corrective action plan: January 1, 2025
Finding 509772 (2023-005)
Significant Deficiency 2023
CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: Management should update its policies and procedures to waive any organizational fees for the borrower or beneficiary and instead recover those costs through directly charging the underly expenses as part of the federal awa...
CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: Management should update its policies and procedures to waive any organizational fees for the borrower or beneficiary and instead recover those costs through directly charging the underly expenses as part of the federal award’s “operational support activities” budget line. In addition, management should consult the appropriate federal agency on any further corrective action related to the fees already paid and allocated as “program activities”. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will update it’s policies and procedures to waive fees for the borrower as part of the federal award. Mangement will consult with the CDFI Fund for any further corrective action related to the fees. Name(s) of the contact person(s) responsible for corrective action: Arlo Washington and Erica Baldwin Planned completion date for corrective action plan: Janurary 1, 2025
View Audit 329488 Questioned Costs: $1
Finding 509771 (2023-004)
Material Weakness 2023
CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: We recommend management develop procedures requiring employees to track their time and effort by grant. Another individual should periodically review and approve these time and effort records before the funding request is s...
CDFI ERP Program (COVID-19) – Assistance Listing No. 21.033 Recommendation: We recommend management develop procedures requiring employees to track their time and effort by grant. Another individual should periodically review and approve these time and effort records before the funding request is sent to the federal agency or charged to the federal award. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Each employee will track their time spent on the grant through Paychex. Timesheets will be approved by Arlo Washington, President, each payroll period. Name(s) of the contact person(s) responsible for corrective action: Arlo Washington Planned completion date for corrective action plan: January 1, 2025
Management agrees with the recommendation. All updates and appropriate changes have been implemented at the time of this response. We developed a reconciliation process that includes all reconciliations are done in the recommended time frames after the standard entries are done. This revised policy ...
Management agrees with the recommendation. All updates and appropriate changes have been implemented at the time of this response. We developed a reconciliation process that includes all reconciliations are done in the recommended time frames after the standard entries are done. This revised policy has been communicated to the appropriate individuals as a means of reiterating the importance of complete and accurate reconciliations.
Management agrees with the recommendation. All updates and appropriate changes have been implemented at the time of this response. We developed a reconciliation process that includes all reconciliations are done in the recommended time frames after the standard entries are done. This revised policy ...
Management agrees with the recommendation. All updates and appropriate changes have been implemented at the time of this response. We developed a reconciliation process that includes all reconciliations are done in the recommended time frames after the standard entries are done. This revised policy has been communicated to the appropriate individuals as a means of reiterating the importance of complete and accurate reconciliations.
GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN October 18, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments,...
GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN October 18, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments, Inc., HUD Project No. 054-EE081-WAH, respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended June 30, 2023 The findings from the Schedule of Findings and Questioned Costs for the year ended June 30, 2023 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2023-001: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly (Section 202), Assistance Listing #14.157 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due date. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. Finding 2023-002: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly (Section 202), Assistance Listing #14.157 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.
GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN October 18, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments,...
GENESIS II APARTMENTS, INC. Mullins, South Carolina CORRECTIVE ACTION PLAN October 18, 2024 U. S. Department of Housing and Urban Development Charles Bennett Federal Building 400 West Bay Street, Suite 1015 Jacksonville, Florida 32202 Genesis II Apartments, Inc., HUD Project No. 054-EE081-WAH, respectfully submits the following Corrective Action Plan for the year ended June 30, 2023. Bernard Robinson & Company, L.L.P. Post Office Box 19608 Greensboro, North Carolina 27419-9608 Audit period: Year ended June 30, 2023 The findings from the Schedule of Findings and Questioned Costs for the year ended June 30, 2023 are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Finding 2023-001: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly (Section 202), Assistance Listing #14.157 Recommendation: We recommend the board of directors and management ensure that the annual financial reports to HUD are submitted by the required due date. Action Taken: We agree with Finding 2023-001 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the annual financial statements are submitted once the audits are back on track with the scheduled due dates. Finding 2023-002: U.S. Department of Housing and Urban Development, Supportive Housing for the Elderly (Section 202), Assistance Listing #14.157 Recommendation: We recommend the board of directors and management ensure that the audit and data collection forms are completed timely and the data collection form and required reporting package are submitted electronically to the FAC each fiscal year going forward. Action Taken: We agree with Finding 2023-002 described in the accompanying schedule of findings and questioned costs. The new management company will ensure the data collection forms are submitted electronically to the FAC each fiscal year. If HUD has questions regarding this plan, please call (803) 808-3966. Sincerely yours, Reese Quick, President Southern Development Management Company, Inc.
The management agent has made every effort to have the audits completed on a timely basis and has changed the audit firm to provide for timely submissions.
The management agent has made every effort to have the audits completed on a timely basis and has changed the audit firm to provide for timely submissions.
Management has reviewed and modernized the policies and procedures over federal grant reports.
Management has reviewed and modernized the policies and procedures over federal grant reports.
Contact Person LeAnn Littlewolf, Executive Director Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2024
Contact Person LeAnn Littlewolf, Executive Director Corrective Action Plan We are in the process of updating the Organization’s written policies and procedures to include the requirements of the Uniform Guidance. Completion Date Fiscal year end 2024
In March 2023, the Organization contracted a third-party accounting firm that implemented new accounting and financial reporting procedures. While this could not cover prior lost information, their updated processes and support ensured the books of record were correctly stated and supported to have...
In March 2023, the Organization contracted a third-party accounting firm that implemented new accounting and financial reporting procedures. While this could not cover prior lost information, their updated processes and support ensured the books of record were correctly stated and supported to have accurate July 31, 2024, financial statements and related notes. Specific additional actions taken include the following internal controls: 1. All reconciliations are now reviewed by multiple individuals, including the third-party accounting firm and management, before they are finalized. 2. In July 2024, the Organization retained the services of a third-party fractional CFO, who is providing an additional level of review to ensure completeness and accuracy. 3. The Organization has increased the use of shared, company-controlled electronic data storage to ensure the retention of all source documentation.
Effective March 2023, the Organization reviewed its procedures and implemented additional procedures to ensure the generation and retention of External Award Activity Reports before the closeout of any current or future federal awards. The Vice President of Research and Operations ensures complianc...
Effective March 2023, the Organization reviewed its procedures and implemented additional procedures to ensure the generation and retention of External Award Activity Reports before the closeout of any current or future federal awards. The Vice President of Research and Operations ensures compliance with these new procedures.
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