EIN: 391763109
UEI: GSA_MIGRATION
Audited by: JOHNSON BLOCK AND COMPANY, INC.
Oversight agency: 10 [Department of Agriculture]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 6, 2022. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 6, 2022 (1426 days ago).
What is a management decision? →The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff.
Show full finding ▾Hide full finding ▴Finding #2021-001 ? Limited Segregation of Duties (Prior year Finding #2020-002) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff.
Finding #2021-001 ? Limited Segregation of Duties (Prior year Finding #2020-002) Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff. Contact Person: Kathy Rice Anticipated Completion: 4/30/2022
2020-002
FAC accepted this audit on March 29, 2021 — management decision was due September 29, 2021.
The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff.
Show full finding ▾Hide full finding ▴Finding #2020-002 ? Limited Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff.
Finding #2020-002 ? Limited Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff. Contact Person: Kathy Rice Anticipated Completion: 4/30/2021
2019-002
Athens Apartments (Borrower ID and Project Number 13-065-218395680-033) maintains its primary replacement reserve with the Illinois Housing Development Authority (IHDA). Athens Apartments had three withdrawals during 2020, totaling $13,077, from its replacement reserve account that were approved and disbursed by IHDA. However, USDA Rural Development was not part of that approval process. Criteria: The Rural Development handbook requires that disbursements from the reserve for replacement account be authorized by Rural Development. Cause: Athens Apartments? IHDA loan also requires that a reserve for replacement be maintained. Athens Apartments? went through the appropriate approval process with IHDA, however, USDA was not part of the upfront approval process. ABTK, Inc.?s system of internal control allowed for the disbursements to be made without having a written approval from Rural Development. Effect: Without proper internal controls and approvals, disbursements could be made that are not in compliance with Rural Development requirements. Inconsistencies can arise between Rural Development?s project reserve checkbook authorization (FIN 2100) report and the bank and general ledger activity. Recommendation: Ensure approval procedures are in place and followed surrounding replacement reserve withdrawals. Response: For the three withdrawals during 2020, we will send RD the reserve request and supporting documentation to obtain an after the fact approval. In the future, we will request approval from RD upfront prior to any disbursements being made.
Show full finding ▾Hide full finding ▴Finding #2020-003- #10.415 Replacement Reserve Cash Disbursements Condition: Athens Apartments (Borrower ID and Project Number 13-065-218395680-033) maintains its primary replacement reserve with the Illinois Housing Development Authority (IHDA). Athens Apartments had three withdrawals during 2020, totaling $13,077, from its replacement reserve account that were approved and disbursed by IHDA. However, USDA Rural Development was not part of that approval process. Criteria: The Rural Development handbook requires that disbursements from the reserve for replacement account be authorized by Rural Development. Cause: Athens Apartments? IHDA loan also requires that a reserve for replacement be maintained. Athens Apartments? went through the appropriate approval process with IHDA, however, USDA was not part of the upfront approval process. ABTK, Inc.?s system of internal control allowed for the disbursements to be made without having a written approval from Rural Development. Effect: Without proper internal controls and approvals, disbursements could be made that are not in compliance with Rural Development requirements. Inconsistencies can arise between Rural Development?s project reserve checkbook authorization (FIN 2100) report and the bank and general ledger activity. Recommendation: Ensure approval procedures are in place and followed surrounding replacement reserve withdrawals. Response: For the three withdrawals during 2020, we will send RD the reserve request and supporting documentation to obtain an after the fact approval. In the future, we will request approval from RD upfront prior to any disbursements being made.
Finding #2020-003- #10.415 Replacement Reserve Cash Disbursements Condition: Athens Apartments (Borrower ID and Project Number 13-065-218395680-033) maintains its primary replacement reserve with the Illinois Housing Development Authority (IHDA). Athens Apartments had three withdrawals during 2020, totaling $13,077, from its replacement reserve account that were approved and disbursed by IHDA. However, USDA Rural Development was not part of that approval process. Criteria: The Rural Development handbook requires that disbursements from the reserve for replacement account be authorized by Rural Development. Cause: Athens Apartments? IHDA loan also requires that a reserve for replacement be maintained. Athens Apartments? went through the appropriate approval process with IHDA, however, USDA was not part of the upfront approval process. ABTK, Inc.?s system of internal control allowed for the disbursements to be made without having a written approval from Rural Development. Effect: Without proper internal controls and approvals, disbursements could be made that are not in compliance with Rural Development requirements. Inconsistencies can arise between Rural Development?s project reserve checkbook authorization (FIN 2100) report and the bank and general ledger activity. Recommendation: Ensure approval procedures are in place and followed surrounding replacement reserve withdrawals. Response: For the three withdrawals during 2020, we will send RD the reserve request and supporting documentation to obtain an after the fact approval. In the future, we will request approval from RD upfront prior to any disbursements being made. Contact Person: Kathy Rice Anticipated Completion: 4/30/2021
2019-003
FAC accepted this audit on October 14, 2020 — management decision was due April 14, 2021.
The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff.
Show full finding ▾Hide full finding ▴Finding #2019-002 ? Limited Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff.
Finding #2019-002 ? Limited Segregation of Duties Condition: The available office staff precludes a proper segregation of duties in the control areas reviewed. Effect: Because of the lack of segregation of duties, errors or irregularities could occur and not be detected on a timely basis. Cause: The condition is due to limited staff available. Criteria: Internal controls should be in place that provide adequate segregation of duties. Generally, a system of internal control contemplates separation of duties such that no individual has responsibility to execute a transaction, have physical access to the related assets, and have responsibility or authority to record the transaction. Recommendation: Procedures should be implemented segregating duties among different employees. Management should continue to maintain a working knowledge of matters relating to the Organization?s operations. Response: The control deficiency has been discussed with the Organization?s management and while we agree with the finding, we do not believe it is cost effective to hire additional staff for the purpose of segregating duties. We will, however, continue to explore options for segregating duties that utilize the existing staff. Contact Person: Kathy Rice Anticipated Completion: Not Applicable
Athens Apartments (Borrower ID and Project Number 13-065-218395680-033) maintains its primary replacement reserve with the Illinois Housing Development Authority (IHDA). Athens Apartments had two withdrawals during 2019, totaling $7,218, from its replacement reserve account that were approved and disbursed by IHDA. However, USDA Rural Development was not part of that approval process. Criteria: The Rural Development handbook requires that disbursements from the reserve for replacement account be authorized by Rural Development. Cause: Athens Apartments? IHDA loan also requires that a reserve for replacement be maintained. Athens Apartments? went through the appropriate approval process with IHDA, however, USDA was not part of the upfront approval process. ABTK, Inc.?s system of internal control allowed for the disbursements to be made without having a written approval from Rural Development. Effect: Without proper internal controls and approvals, disbursements could be made that are not in compliance with Rural Development requirements. Inconsistencies can arise between Rural Development?s project reserve checkbook authorization (FIN 2100) report and the bank and general ledger activity. Recommendation: Ensure approval procedures are in place and followed surrounding replacement reserve withdrawals. Response: For the two withdrawals during 2019, we will send RD the reserve request and supporting documentation to obtain an after the fact approval. In the future, we will request approval from RD upfront prior to any disbursements being made.
Show full finding ▾Hide full finding ▴Finding #2019-003- #10.415 Replacement Reserve Cash Disbursements: Condition: Athens Apartments (Borrower ID and Project Number 13-065-218395680-033) maintains its primary replacement reserve with the Illinois Housing Development Authority (IHDA). Athens Apartments had two withdrawals during 2019, totaling $7,218, from its replacement reserve account that were approved and disbursed by IHDA. However, USDA Rural Development was not part of that approval process. Criteria: The Rural Development handbook requires that disbursements from the reserve for replacement account be authorized by Rural Development. Cause: Athens Apartments? IHDA loan also requires that a reserve for replacement be maintained. Athens Apartments? went through the appropriate approval process with IHDA, however, USDA was not part of the upfront approval process. ABTK, Inc.?s system of internal control allowed for the disbursements to be made without having a written approval from Rural Development. Effect: Without proper internal controls and approvals, disbursements could be made that are not in compliance with Rural Development requirements. Inconsistencies can arise between Rural Development?s project reserve checkbook authorization (FIN 2100) report and the bank and general ledger activity. Recommendation: Ensure approval procedures are in place and followed surrounding replacement reserve withdrawals. Response: For the two withdrawals during 2019, we will send RD the reserve request and supporting documentation to obtain an after the fact approval. In the future, we will request approval from RD upfront prior to any disbursements being made.
Finding #2019-003- #10.415 Replacement Reserve Cash Disbursements: Condition: Athens Apartments (Borrower ID and Project Number 13-065-218395680-033) maintains its primary replacement reserve with the Illinois Housing Development Authority (IHDA). Athens Apartments had two withdrawals during 2019, totaling $7,218, from its replacement reserve account that were approved and disbursed by IHDA. However, USDA Rural Development was not part of that approval process. Criteria: The Rural Development handbook requires that disbursements from the reserve for replacement account be authorized by Rural Development. Cause: Athens Apartments? IHDA loan also requires that a reserve for replacement be maintained. Athens Apartments? went through the appropriate approval process with IHDA, however, USDA was not part of the upfront approval process. ABTK, Inc.?s system of internal control allowed for the disbursements to be made without having a written approval from Rural Development. Effect: Without proper internal controls and approvals, disbursements could be made that are not in compliance with Rural Development requirements. Inconsistencies can arise between Rural Development?s project reserve checkbook authorization (FIN 2100) report and the bank and general ledger activity. Recommendation: Ensure approval procedures are in place and followed surrounding replacement reserve withdrawals. Response: For the two withdrawals during 2019, we will send RD the reserve request and supporting documentation to obtain an after the fact approval. In the future, we will request approval from RD upfront prior to any disbursements being made. Contact Person: Kathy Rice Anticipated Completion: October 31, 2020
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