Corrective Action Plans

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U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Eligibility Repeat Finding: Yes Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 14...
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Eligibility Repeat Finding: Yes Auditee’s Corrective Action Plan: Condition #1 Response MOHS acknowledges the finding that 14 out of 40 files did not have management review. Corrective Action: The Program Manager will conduct quality control reviews for 30% of files that have been recertified each month. The quality control review will verify all eligibility components under the program were met. Condition #2 Response MOHS acknowledges the finding that 25 out of 40 selections did not have the supporting thirdparty documentation of income. MOHS followed the HOPWA guidance outlined in the Self- Certification of Income and Credible Information on HIV Status waivers released by HUD for September 2021 and March 2023. The waiver permits HOPWA grantees and project sponsors to rely upon a family member’s self-certification of income and credible information on their HIV status. The HUD-CPD notices are referenced in Exhibits A-B of this response. The program accepted the self-certification of income until the waivers from HUD ended for COVID-19 on March 31, 2023. Corrective Action: MOHS has resumed following the process of requesting third party verification of income, assets, and medical expenses to ensure proper calculation of tenant rent. Client records are being updated with the appropriate verification of income documentation from the third-party source. Condition #3 Response MOHS acknowledges the finding 6 out of 40 selections did not have documentation of the rent reasonableness. Corrective Action: MOHS uses GoSection8, an online rent comparable website to conduct rent reasonableness. Rent reasonableness is conducted at the initial move-in and with each rent increase request. Documentation of the comparison is maintained in the client record. Contact Person: Lakeysha Williams – 410-396-4887 or Lakeysha.williams@baltimorecity.gov Completion Date: July 2024
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Auditee’s Corrective Action Plan: MOHS has developed a comprehensive standard operations p...
U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunities for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Cash Management Repeat Finding: No Auditee’s Corrective Action Plan: MOHS has developed a comprehensive standard operations procedure for our program compliance and fiscal teams. This manual includes a standardized process of completing drawer requests, having supporting documentation that aligns with the request stored in each contracts permanent file on the agencies shared “G drive which is accessible to all fiscal staff. In addition, our fiscal team is required to adopt a naming conversion for each grant and draw request, Confirmation of payment posting to the GL and save supporting documentation to the Fiscal “G drive”. Contact Person: MOHS Fiscal Director – Diamond Okojie Completion Date: July 2024
U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Significant Deficiency in Internal Controls and Noncompliance over Special Tests - Housing Quality Standards Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the compr...
U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Significant Deficiency in Internal Controls and Noncompliance over Special Tests - Housing Quality Standards Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the comprehensive review of this program and concurs with this finding. It is the responsibility of DHCD to perform physical inspections annually. This process includes creating and maintaining inspection review forms and correspondence with the inspected properties. We believe the oversights discovered were caused in part to an increase in the workload of the sole compliance officer performing the physical inspections. Because of this increase in workload, exacerbated by impromptu medical leave, the other compliance officers have received some cross training in HQS inspecting and are now available to assist in the record keeping process. The unit is also in the process of hiring an additional Compliance Officer to assume the physical inspection responsibilities. Additionally, all active compliance officers will review the program’s standard operating procedures for inspections. If necessary, any needed adjustments to the plan will be made at this time. We will also review all FY 24 inspections to ensure that all Inspection Findings and Corrective Measures have been issued and are available in the department’s shared drive. Contact Person: Eugene Greene, HOME Program Manager Completion Date: December 2024
U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Material Weakness in Internal Controls and Noncompliance over Program Income Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the comprehensive review of this program ...
U.S. Department of Housing and Urban Development (HUD) AL No. 14.239 HOME Investment Partnerships Program Material Weakness in Internal Controls and Noncompliance over Program Income Repeat Finding: No Auditee’s Corrective Action Plan: The Agency appreciates the comprehensive review of this program and concurs with this finding. The Department of Housing and Community Development (DHCD) understands that while the City of Baltimore’s Department of Finance is responsible for recording and reporting program income into the general ledger, DHCD must ensure that ensure funds are properly recorded in the accounting records. Therefore, DHCD will work with the Department of Finance to ensure that program income deposits are documented correctly, are properly reflected on the general ledger and deposited into the correct accounts. Going forward, DHCD will request the general ledger details for all program income deposits on a minimum quarterly basis to ensure its accuracy and availability. Contact Person: Eugene Greene, HOME Program Manager Completion Date: December 2024
Significant Deficiency and Noncompliance over Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of Augu...
Significant Deficiency and Noncompliance over Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients’ information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. Prior to the completion of the SEFA, the City instituted training sessions with the agencies to ensure that the reporting is understood by the agencies, with special emphasis on subrecipient payments being reported properly. Additionally, the City will give access to the grant report upon which the SEFA is based. The City will keep a check list to ensure that all agencies respond to the grant certification to ensure that all agencies review the grant data. Based on FY 23 training and feedback the City is expanding that training schedule to begin with agency preparation in November 2024. Additionally, the corrective actions for grants have included citywide trainings in the fourth quarter FY24 led by the Grants Management Office and BAPS on key grant accounting functions in Workday; including for example, Billing, Creating an Award, Sub Recipients with each training having between 50-70 agency grant staff attending. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City Completion Date: December 2024
Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although W...
Material Weakness over Schedule of Expenditures of Federal Awards (SEFA) Reporting Repeat Finding: Yes Auditee’s Corrective Action Plan: The City has purchased Workday, an Enterprise Resource Planning (ERP) system, and implemented the software with the assistance of Accenture consultants. Although Workday is “live” as of August 2022, the City is currently working to refine the software and fully utilize functionality. The Workday grants modules requires the grant funding source be defined prior to grant approval and fields are available for the AL titles and numbers and sub-recipients’ information. The implementation of the Workday grants modules centralizes much of the grant management function by requiring the agencies to upload the grant documents into Workday. The City has: • Held weekly meetings for two years with agency grant representatives to design and configure the Workday grant module. • Uploaded the grant award, sponsor information and grant budget data into a Workday. • Implemented a “new grant” request which uses a Workday business process. • In the process of reviewing and correcting recoverable costs per grant award so it is properly recorded. • Within Workday we are able to track grant performance period, CFDA, manage and capture grant related expenditures and calculate automated billing to sponsors on recoverable costs Business processes have been developed and implemented in Workday’s grant management module to include: Definition of the grant funding source by creating a system-generated grant work tag (identifier) upon receipt of the Sponsor’s Notice of Award; populated fields in Workday with passthrough award data with Prime Sponsor and Bill to sponsor Billing data, and modification of the create award process to add the Grants Management Office to final approval. In FY 24 the City implemented a citywide Grants Management Committee coordinated by the Mayor's Office of Performance and Innovation. Through feedback from this workgroup we identified an expanded scope of responsibility for the Grants Management Office; including oversight and compliance, technology, training and budget monitoring. In the short term a new Grants Director position was created and onboarding is to occur in the first quarter of FY25. Contact Person: Michael Moiseyev, Chief Financial Officer, Baltimore City. Completion Date: June 2024
CORRECTIVE ACTION PLAN (Concerning Finding 2023-007) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-007 The current Town Manager was appointed by...
CORRECTIVE ACTION PLAN (Concerning Finding 2023-007) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-007 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and drafted, has had approved, and has implemented the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024
CORRECTIVE ACTION PLAN (Concerning Finding 2023-006) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Town Manager and Select Board will take the following actions to address finding 2023-006 The current Town Manager was appointed by the Select...
CORRECTIVE ACTION PLAN (Concerning Finding 2023-006) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Town Manager and Select Board will take the following actions to address finding 2023-006 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and has implemented the new Internal Controls Policy that addresses this deficiency. This policy will includes sections on risk assessment and management, annual audit, chart of account, general ledger, reconciliation and verification, reserve funds and reserve accounts, investments, financial reporting, fraud, accounting software, online transactions and banking, documentation daily cash-ups, grants and projects, AR process, AP process, and payroll. Anticipated Completion Date: This was completed February 20, 2024.
CORRECTIVE ACTION PLAN (Concerning Finding 2023-005) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-005 The current Town Manager was appointed by...
CORRECTIVE ACTION PLAN (Concerning Finding 2023-005) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-005 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and us using the new Internal Controls Policy that addresses this deficiency. Additionally, Department Heads are required to turn in no later than Thursday by 9 am, invoices to be paid on that week’s warrant. The Treasurer has been given authority by the Town Manager to contact Department Heads and request that they come to the office weekly to turn in invoices. All invoices must have the appropriate expense code and be signed by the Department Head. Anticipated Completion Date: This was completed January 23, 2024.
CORRECTIVE ACTION PLAN (Concerning Finding 2023-004) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-004 The current Town Manager was appointed by...
CORRECTIVE ACTION PLAN (Concerning Finding 2023-004) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-004 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager and has drafted, had approved and is using the new Procurement Policy that addresses this deficiency. Anticipated Completion Date: This was completed January 23, 2024.
CORRECTIVE ACTION PLAN (Concerning Finding 2023-003) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-003 The current Town Manager was appointed by...
CORRECTIVE ACTION PLAN (Concerning Finding 2023-003) Contact Person Responsible for Corrective Action: Carrie Castonguay, Town Manager Corrective Action: The Treasurer, Town Manager and Select Board will take the following actions to address finding 2023-003 The current Town Manager was appointed by the Select Board on August 14, 2023, and had no knowledge of this material weakness. She is an experienced Manager that has implemented training for the Treasurer and the Select Board. She has implemented a process of having the Treasurer complete a warrant each week. The Select Board meets bi-monthly and the Town Manager has the Select Board review and approve all warrants as a regular action item in their meeting. Additionally, Department Heads are required to turn in no later than Thursday by 9 am, invoices to be paid on that week’s warrant. The Treasurer has been given authority by the Town Manager to contact Department Heads and request that they come to the office weekly to turn in invoices. All invoices must have the appropriate expense code and be signed by the Department Head. Anticipated Completion Date: This corrective action has been implemented as of October 2023.
ITEM 2023-002: DUPLICATE ACCOUNTING RECORDS In response to Finding 2023-002, we clarify that the duplication of accounting records originated from the implementation of an FY22 audit recommendation. The auditing firm was designated to address and reconcile these duplicate entries; however, this task...
ITEM 2023-002: DUPLICATE ACCOUNTING RECORDS In response to Finding 2023-002, we clarify that the duplication of accounting records originated from the implementation of an FY22 audit recommendation. The auditing firm was designated to address and reconcile these duplicate entries; however, this task was not completed, leading to a backlog that impacted the timely completion of the FY23 audit. We have since undertaken a comprehensive reconciliation of all duplicate entries, ensuring accurate and complete financial records moving forward. With this corrective action finalized, we are now positioned to prevent reoccurrence and maintain a streamlined, efficient accounting process. Contact person: Tim Nichols Anticipated completion date: November 29, 2024
FINDING 2023-001: SEGREGATION OF DUTIES Classes of financial transactions have been segregated to the extent possible among the existing employees. However, because of the limited number of employees involved in the accounting and bookkeeping functions, a corrective action plan to remedy the lack of...
FINDING 2023-001: SEGREGATION OF DUTIES Classes of financial transactions have been segregated to the extent possible among the existing employees. However, because of the limited number of employees involved in the accounting and bookkeeping functions, a corrective action plan to remedy the lack of segregation of duties is not cost justified. Rather, each level of management, the Board of Directors and Administrator, are aware of the concept of "segregation of duties" and are also aware of potential problems that may occur when accounting and bookkeeping duties cannot be segregated. Because there is awareness, each level of management is charged with the responsibility to follow-up on any circumstances or transactions that they perceive to be unusual. Contact person: Tim Nichols Anticipated completion date: Unknown
Due to the limited number of office staff, achieving complete segregation of duties presents challenges. However, the District has carefully reviewed and strengthened its control procedures to ensure the highest level of internal control feasible under these circumstances.
Due to the limited number of office staff, achieving complete segregation of duties presents challenges. However, the District has carefully reviewed and strengthened its control procedures to ensure the highest level of internal control feasible under these circumstances.
Condition: The Authority did not identify that they were subject to an audit under the Uniform Guidance (U.G.) and a schedule of expenditures of federal awards (SEFA) was not prepared by management. Recommendation: The Authority should review federal, state, and local grants to determine if they a...
Condition: The Authority did not identify that they were subject to an audit under the Uniform Guidance (U.G.) and a schedule of expenditures of federal awards (SEFA) was not prepared by management. Recommendation: The Authority should review federal, state, and local grants to determine if they are federally funded and, if federally funded, utilize the account number outlined in the State of Michigan chart of accounts to track federal funding. Planned Corrective Action: A schedule of federal awards will be created to track total costs covered by federal awards beginning in FY24. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024
Condition: As a precondition to receive federal awards, prospective recipients must have effective internal controls over the federal award. As described in 2 CFR, Part 200.303, nonfederal entities must have certain written policies and procedures surrounding the management of their federal awards. ...
Condition: As a precondition to receive federal awards, prospective recipients must have effective internal controls over the federal award. As described in 2 CFR, Part 200.303, nonfederal entities must have certain written policies and procedures surrounding the management of their federal awards. Such policies should include procedures for collecting payments of federal funds per 2 CRF 200.305, cash management (i.e., minimizing the time between draws and actual disbursing of federal awards) per 2 CFR 200.302(b)(6), allowable cost per 2 CFR 200.403, and conflict of interest per 2 CFR 200.318. Per 2 CFR 200.319(d), the non-Federal entity must have written procedures for procurement transactions. Recommendation: The Authority should adopt written policies and procedures over cash management and allowable costs required under the Uniform Guidance. Planned Corrective Action: The Authority implemented these policies during the FY 2024 (BA054 Cash Management Policy and BA059 Authorization of Purchases). Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024
Condition: During procurement testing of the Certified Community Behavior Health Clinic Expansion Grant, we noted that the Authority did not have documentation that sam.gov was reviewed to ensure the consultant utilized was not suspended or debarred for two of the three contracts expended. The Autho...
Condition: During procurement testing of the Certified Community Behavior Health Clinic Expansion Grant, we noted that the Authority did not have documentation that sam.gov was reviewed to ensure the consultant utilized was not suspended or debarred for two of the three contracts expended. The Authority checked suspension and debarment on the individual clinicians, however, did not check it for the company. Recommendation: The Authority should implement adequate controls to ensure verification of debarment, suspension or exclusion takes place before entering covered transactions. Planned Corrective Action: Going forward the agency will implement policy changes that will include the organization as well as the individual prior to entering into any contract. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024
Condition: The Authority did not utilize federal procurement requirements cited above for the tele-health services and SUD Peer Recovery Service contracted service providers utilized for the Certified Community Behavioral Health Clinics project. (no documentation for sole source, no proof that it wa...
Condition: The Authority did not utilize federal procurement requirements cited above for the tele-health services and SUD Peer Recovery Service contracted service providers utilized for the Certified Community Behavioral Health Clinics project. (no documentation for sole source, no proof that it was advertised, google search was provided from 7/24/24 is not sufficient, board cannot waive federal requirement). Recommendation: The Authority follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Planned Corrective Action: Going forward the Authority will follow federal procurement as required in 2 CFR 200.319(d) for all contracts reimbursed with federal funds. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024
View Audit 329033 Questioned Costs: $1
Condition: Accrued PTO time was adjusted as of September 30, 2023, however certain employees were transferred over to the grant program that had accrued PTO as of September 30, 2022 that was not taken into account. As a result, the grant was charged PTO time for amounts that had been accrued in prio...
Condition: Accrued PTO time was adjusted as of September 30, 2023, however certain employees were transferred over to the grant program that had accrued PTO as of September 30, 2022 that was not taken into account. As a result, the grant was charged PTO time for amounts that had been accrued in prior years in other programs and activities. Recommendation: Schedule should be revised to take into account the PTO time employees have prior to being transferred into the grant activities Planned Corrective Action: A new schedule has been created that will calculate only the increase in PTO cost year over year per individual and used to accrue PTO cost at year end. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024
View Audit 329033 Questioned Costs: $1
Condition: The Authority allocated wages and fringe benefits to the program based on the grant budget, with no adjustment made to actual time spent. Recommendation: Implement a review process to ensure the amount charged to a federal award is based on the time the employees spend on providing the se...
Condition: The Authority allocated wages and fringe benefits to the program based on the grant budget, with no adjustment made to actual time spent. Recommendation: Implement a review process to ensure the amount charged to a federal award is based on the time the employees spend on providing the services. Planned Corrective Action: This process has been corrected and only timesheet hours will be used to allocate cost going forward. Contact Person: Anthony Shaver, Chief Financial Officer Anticipated Completion Date: 9/30/2024
View Audit 329033 Questioned Costs: $1
The Authority did not realize quarterly reports were required and was never asked by USDA for these. USDA was contacted and the Authority has been informed that a quarterly Balance Sheet and Profit and Loss Statement will fulfill this requirement. The past due reports will be sent to USDA this mon...
The Authority did not realize quarterly reports were required and was never asked by USDA for these. USDA was contacted and the Authority has been informed that a quarterly Balance Sheet and Profit and Loss Statement will fulfill this requirement. The past due reports will be sent to USDA this month and going forward, quarterly reports will be forwarded to USDA within 30 days of the end of each quarter.
Management intends to have its 2024 audit performed in a timely manner to allow sufficient time to file its 2024 data collection form prior to the due date.
Management intends to have its 2024 audit performed in a timely manner to allow sufficient time to file its 2024 data collection form prior to the due date.
have taken added controls in places to ensure this issue does not reoccur moving forward.
have taken added controls in places to ensure this issue does not reoccur moving forward.
Year audit will be completed on time, ensuring greater efficiency and accountability moving forward.
Year audit will be completed on time, ensuring greater efficiency and accountability moving forward.
Finding 508392 (2023-002)
Significant Deficiency 2023
Views of Responsible Officials: In 2024, Think of Us took steps to address this issue by appointing new executive leadership, including a President and Fractional CFO and engaging a proven accounting firm with demonstrated expertise in nonprofit accounting.
Views of Responsible Officials: In 2024, Think of Us took steps to address this issue by appointing new executive leadership, including a President and Fractional CFO and engaging a proven accounting firm with demonstrated expertise in nonprofit accounting.
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