EIN: 431836344
UEI: QFAQNRZLMNX5
Audited by: KPM CPAs, LLC
Oversight agency: 14 [Department of Housing and Urban Development]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 1, 2026. 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 November 1, 2026 (58 days from today).
What is a management decision? →FAC accepted this audit on May 1, 2025 — management decision was due November 1, 2025.
Boone County Senior Citizen Services Corporation DBA The Bluffs did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0 Cause: Boone County Senior Citizen Services Corporation DBA The Bluffs’ written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Boone County Senior Citizen Services Corporation DBA The Bluffs could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend Boone County Senior Citizen Services Corporation DBA The Bluffs draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures. The board anticipates approving written policies and procedures for cash management in May 2025.
Show full finding ▾Hide full finding ▴Identification of a Repeat Finding: This is a repeat finding from the immediate previous audit, 2023-002. Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E – Cost Principals. Condition: Boone County Senior Citizen Services Corporation DBA The Bluffs did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0 Cause: Boone County Senior Citizen Services Corporation DBA The Bluffs’ written policies and procedures were not updated to include required Uniform Guidance policies. Effect: Boone County Senior Citizen Services Corporation DBA The Bluffs could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend Boone County Senior Citizen Services Corporation DBA The Bluffs draft and adopt written procedures in accordance with Uniform Guidance requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures. The board anticipates approving written policies and procedures for cash management in May 2025.
Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures. Management expects to present the policies to the board for approval at the May 2025 board meeting.
2023-002
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
Prior year surplus cash was not deposited into the residual receipts account on a timely basis. Questioned Costs: $0Cause: Boone County Senior Citizen Services Corporation DBA The Bluffs was aware of the requirement but management oversight resulted in the failure to separately deposit these funds.Effect: Surplus cash deposits into the residual receipts account were delinquent in accordance with HUD requirements. Recommendation: We recommend Boone County Senior Citizen Services Corporation DBA The Bluffs establish procedures to ensure that required deposits of surplus cash are made on a timely basis after the calendar year end.Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and made the required deposit in October 2023. Management is in process of incorporating procedures to ensure that all required surplus cash deposits are made timely in the future. There was no required deposit for calendar year 2023.
Show full finding ▾Hide full finding ▴Criteria: HUD Handbook 4370.2, Financial Operations and Accounting Procedures for Insured Multifamily Projects, states that the regulatory agreement required that all surplus cash available at the end of the annual fiscal period to be deposited in the residual receipts account within 60 days after the end of the fiscal year.Condition: Prior year surplus cash was not deposited into the residual receipts account on a timely basis. Questioned Costs: $0Cause: Boone County Senior Citizen Services Corporation DBA The Bluffs was aware of the requirement but management oversight resulted in the failure to separately deposit these funds.Effect: Surplus cash deposits into the residual receipts account were delinquent in accordance with HUD requirements. Recommendation: We recommend Boone County Senior Citizen Services Corporation DBA The Bluffs establish procedures to ensure that required deposits of surplus cash are made on a timely basis after the calendar year end.Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and made the required deposit in October 2023. Management is in process of incorporating procedures to ensure that all required surplus cash deposits are made timely in the future. There was no required deposit for calendar year 2023.
Management agrees with the finding and made the required deposit in October 2023. Management is in process of incorporating procedures to ensure that all required surplus cash deposits are made timely in the future. There was no required deposit for calendar year 2023.
Boone County Senior Citizen Services Corporation DBA The Bluffs did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0Cause: Boone County Senior Citizen Services Corporation DBA The Bluffs’ written policies and procedures were not updated to include required Uniform Guidance policies.Effect: Boone County Senior Citizen Services Corporation DBA The Bluffs could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend Boone County Senior Citizen Services Corporation DBA The Bluffs draft and adopt written procedures in accordance with Uniform Guidance requirements.Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures.
Show full finding ▾Hide full finding ▴Criteria: Uniform Guidance requires written procedures for cash management and determining the allowability of costs in accordance with Subpart E – Cost Principals. Condition: Boone County Senior Citizen Services Corporation DBA The Bluffs did not have written procedures for cash management (2 CFR 200.302(b)(6)) and allowable costs determination (2 CFR 200.302(b)(7)) in accordance with Uniform Guidance requirements. Questioned Costs: $0Cause: Boone County Senior Citizen Services Corporation DBA The Bluffs’ written policies and procedures were not updated to include required Uniform Guidance policies.Effect: Boone County Senior Citizen Services Corporation DBA The Bluffs could enter into a transaction that is not in compliance with Uniform Guidance requirements. Recommendation: We recommend Boone County Senior Citizen Services Corporation DBA The Bluffs draft and adopt written procedures in accordance with Uniform Guidance requirements.Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures.
Management agrees with the finding and is in process of developing and implementing the appropriate policies and procedures.
FAC accepted this audit on September 23, 2024 — management decision was due March 23, 2025.
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
FAC accepted this audit on November 16, 2022 — management decision was due May 16, 2023.
FAC accepted this audit on September 23, 2024 — management decision was due March 23, 2025.
FAC accepted this audit on October 7, 2020 — management decision was due April 7, 2021.
2019-003 Mortgage Insurance Nursing Homes ? CFDA No. 14.129 U.S. Department of Housing and Urban Development HUD Project No. 085-43094 Program Year 2019 Criteria or Specific Requirement ? Reporting ? 24 CFR Section 232.1009 ? Management shall submit financial status reports, containing reliable financial data, quarterly as required by HUD. Condition ? The Bluffs did not complete monthly and year-end closing processes timely for a portion of 2019. The Bluffs began completing monthly closing processes timely upon outsourcing its billing function and a portion of its monthly bookkeeping function to a third party. Questioned Costs ? None Context ? In 2019, three of the four required quarterly reports were submitted after the due date required by HUD. Effect ? The Bluffs? 2019 quarterly financial statements were not submitted timely. Cause ? The Bluffs experienced significant turnover in its business office during 2019. Due to the lack of appropriately skilled employees serving in the Finance Director and Biller roles for a portion of the year, business office functions, including billing and collecting accounts receivable, cash disbursements, account reconciliations, and preparation of monthly financial statements were not completed or were not completed timely. Identification as a repeat finding ? Repeat finding, see finding 2018-004. Recommendation ? Management should implement procedures to appropriately address turnover in key business office positions to ensure compliance requirements are met. View of Responsible Officials and Planned Corrective Actions ? Turnover in the key positions could be related to the inability to enforce oversight and accountability of spending habits, staffing turnover expense and other items that affect the cash flow. Without accountability of all departments, the cash flow strains can cause turnover in the finance department. The board of directors will support oversight and accountability performed by the Executive Director to obtain the desired financial goals. The Executive Director will initiate this oversight and make continual changes and improvements as needed to prevent financially draining problems (total employee turnover, outsourcing, spending and collections). Deadlines and checklists are set up to ensure that monthly financial closing is expected to take place on or before the 20th of every month. The Finance Director shall complete accounts payable, receivable, and other postings and initiate the close of the month prior to the 20th. The Finance Director shall maintain a monthly checkoff list that includes timely submission of financials to HUD, the Board of Directors and other required entities. Person Responsible: Donna Bowers, LNHA, Executive Director Jill Dulaban, Finance Director Timeframe: Correction has already been implemented.
Show full finding ▾Hide full finding ▴2019-003 Mortgage Insurance Nursing Homes ? CFDA No. 14.129 U.S. Department of Housing and Urban Development HUD Project No. 085-43094 Program Year 2019 Criteria or Specific Requirement ? Reporting ? 24 CFR Section 232.1009 ? Management shall submit financial status reports, containing reliable financial data, quarterly as required by HUD. Condition ? The Bluffs did not complete monthly and year-end closing processes timely for a portion of 2019. The Bluffs began completing monthly closing processes timely upon outsourcing its billing function and a portion of its monthly bookkeeping function to a third party. Questioned Costs ? None Context ? In 2019, three of the four required quarterly reports were submitted after the due date required by HUD. Effect ? The Bluffs? 2019 quarterly financial statements were not submitted timely. Cause ? The Bluffs experienced significant turnover in its business office during 2019. Due to the lack of appropriately skilled employees serving in the Finance Director and Biller roles for a portion of the year, business office functions, including billing and collecting accounts receivable, cash disbursements, account reconciliations, and preparation of monthly financial statements were not completed or were not completed timely. Identification as a repeat finding ? Repeat finding, see finding 2018-004. Recommendation ? Management should implement procedures to appropriately address turnover in key business office positions to ensure compliance requirements are met. View of Responsible Officials and Planned Corrective Actions ? Turnover in the key positions could be related to the inability to enforce oversight and accountability of spending habits, staffing turnover expense and other items that affect the cash flow. Without accountability of all departments, the cash flow strains can cause turnover in the finance department. The board of directors will support oversight and accountability performed by the Executive Director to obtain the desired financial goals. The Executive Director will initiate this oversight and make continual changes and improvements as needed to prevent financially draining problems (total employee turnover, outsourcing, spending and collections). Deadlines and checklists are set up to ensure that monthly financial closing is expected to take place on or before the 20th of every month. The Finance Director shall complete accounts payable, receivable, and other postings and initiate the close of the month prior to the 20th. The Finance Director shall maintain a monthly checkoff list that includes timely submission of financials to HUD, the Board of Directors and other required entities. Person Responsible: Donna Bowers, LNHA, Executive Director Jill Dulaban, Finance Director Timeframe: Correction has already been implemented.
Finding 2019-003 Recommendation ? Management should implement procedures to appropriately address turnover in key business office positions to ensure compliance requirements are met. Comments and Corrective Action Planned - Turnover in the key positions could be related to the inability to enforce oversight and accountability of spending habits, staffing turnover expense and other items that affect the cash flow. Without accountability of all departments, the cash flow strains can cause turnover in the finance department. The Board of directors will support oversight and accountability performed by the Executive Director to obtain the desired financial goals. The Executive Director will initiate this oversight and make continual changes and improvements as needed to prevent financially draining problems (total employee turnover, outsourcing, spending and collections). Deadlines and checklists are set up to ensure that monthly financial closing is expected to take place on or before the 20th of every month. The Finance Director shall complete accounts payable, receivable, and other postings and initiate the close of the month prior to the 20th. The Finance Director shall maintain a monthly checkoff list that includes timely submission of financials to HUD, the Board of Directors and other required entities. Person Responsible: Donna Bowers, LNHA, Executive Director Jill Dulaban, Finance Director Timeframe: Correction has already been implemented.
2018-004
2019-004 Mortgage Insurance Nursing Homes ? CFDA No. 14.129 U.S. Department of Housing and Urban Development HUD Project No. 085-43094 Program Year 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? 24 CFR Section 232.545 ? Management shall not, without prior written consent, encumber any of the mortgaged property or personal property of the project. Condition ? Management entered into a note payable with a bank during 2019, secured by certain accounts, inventory, and equipment, without obtaining prior written consent from HUD. During 2019, the note was paid in full by The Bluffs. Questioned costs ? None Context ? HUD consent was not obtained prior to encumbering personal property of the project. Effect ? The Bluffs encumbered personal property without obtaining prior written consent from HUD. Cause ? The Bluffs experienced significant turnover in its business office during 2019. Due to the lack of appropriately skilled employees serving in the Finance Director and Biller roles for a portion of the year business office functions, including billing, and collecting accounts receivable, cash disbursements, account reconciliations, and preparation of monthly financial statements were not completed timely. The combination of these issues caused significant cash flow constraints which management believes required additional funds to continue operating The Bluffs. Identification as a repeat finding ? Repeat finding, see finding 2018-005. Recommendation ? Management should implement procedures to appropriately address turnover in key business office positions to ensure controls continue to function appropriately. View of Responsible Officials and Planned Corrective Actions ? The Board of directors shall continue to support and assist enforcement of financial decisions made by the Executive Director that directly relate to improved budget controls (payroll expense, turnover, agency use, spending controls, outsourcing expense, dietary contract expense, also, billing completion and collection as well as revenue loss prevention, and census improvement). Healthy financial management and budget controls will improve the cash flow issues and concerns of the finance department thereby reducing turnover in those areas. When there is turnover with the Finance Director or Executive Director, the new director(s) shall review all accounting policies and procedures within 30 days. A policy and procedure have been drafted and approved by the Board of Directors that deters the Board of Directors, Executive Director, or Finance Director from incurring debts or loans without proper consents from HUD, and other obligatory agencies. Person Responsible: Donna Bowers, LNHA, Executive Director Jill Dulaban, Finance Director Timeframe: Correction has already been implemented.
Show full finding ▾Hide full finding ▴2019-004 Mortgage Insurance Nursing Homes ? CFDA No. 14.129 U.S. Department of Housing and Urban Development HUD Project No. 085-43094 Program Year 2019 Criteria or Specific Requirement ? Special Tests and Provisions ? 24 CFR Section 232.545 ? Management shall not, without prior written consent, encumber any of the mortgaged property or personal property of the project. Condition ? Management entered into a note payable with a bank during 2019, secured by certain accounts, inventory, and equipment, without obtaining prior written consent from HUD. During 2019, the note was paid in full by The Bluffs. Questioned costs ? None Context ? HUD consent was not obtained prior to encumbering personal property of the project. Effect ? The Bluffs encumbered personal property without obtaining prior written consent from HUD. Cause ? The Bluffs experienced significant turnover in its business office during 2019. Due to the lack of appropriately skilled employees serving in the Finance Director and Biller roles for a portion of the year business office functions, including billing, and collecting accounts receivable, cash disbursements, account reconciliations, and preparation of monthly financial statements were not completed timely. The combination of these issues caused significant cash flow constraints which management believes required additional funds to continue operating The Bluffs. Identification as a repeat finding ? Repeat finding, see finding 2018-005. Recommendation ? Management should implement procedures to appropriately address turnover in key business office positions to ensure controls continue to function appropriately. View of Responsible Officials and Planned Corrective Actions ? The Board of directors shall continue to support and assist enforcement of financial decisions made by the Executive Director that directly relate to improved budget controls (payroll expense, turnover, agency use, spending controls, outsourcing expense, dietary contract expense, also, billing completion and collection as well as revenue loss prevention, and census improvement). Healthy financial management and budget controls will improve the cash flow issues and concerns of the finance department thereby reducing turnover in those areas. When there is turnover with the Finance Director or Executive Director, the new director(s) shall review all accounting policies and procedures within 30 days. A policy and procedure have been drafted and approved by the Board of Directors that deters the Board of Directors, Executive Director, or Finance Director from incurring debts or loans without proper consents from HUD, and other obligatory agencies. Person Responsible: Donna Bowers, LNHA, Executive Director Jill Dulaban, Finance Director Timeframe: Correction has already been implemented.
Finding 2019-004 Recommendation ? Management should implement procedures to appropriately address turnover in key business office positions to ensure controls continue to function appropriately. Comments and Corrective Action Planned - The Board of directors shall continue to support and assist enforcement of financial decisions made by the Executive Director that directly relate to improved budget controls (payroll expense, turnover, agency use, spending controls, outsourcing expense, dietary contract expense, also, billing completion and collection as well as revenue loss prevention, and census improvement). Healthy financial management and budget controls will improve the cash flow issues and concerns of the finance department thereby reducing turnover in those areas. When there is turnover with the Finance Director or Executive Director, the new director(s) shall review all accounting policies and procedures within 30 days. A policy and procedure have been drafted and approved by the Board of Directors that deters the Board of Directors, Executive Director, or Finance Director from incurring debts or loans without proper consents from HUD, and other obligatory agencies. Person Responsible: Donna Bowers, LNHA, Executive Director Jill Dulaban, Finance Director Timeframe: Correction has already been implemented.
2018-005
FAC accepted this audit on September 29, 2019 — management decision was due March 29, 2020.
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on October 2, 2018 — management decision was due April 2, 2019.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on June 20, 2017 — management decision was due December 20, 2017.
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