Corrective Action Plans

Finding 1206079 (2025-005)

Material Weakness 2025

MN

Allowable Costs / Cost Principles § 200.430

2025-05 Allowability of Payroll Expenditures (repeat finding see 2025-02} Federal Agency- US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compl...

2025-05 Allowability of Payroll Expenditures (repeat finding see 2025-02} Federal Agency- US Department of Housing and Urban Development Continuum of Care Program -Assistance Listing# 14.267 Hennepin County Contract HS00001366 Year ended June 30, 2025 Material Weakness in Internal Control over Compliance, Noncompliance Other Matter Recommendation - Controls be strengthened to ensure the accuracy and completeness of payroll documentation and additional training be provided to staff involved in the payroll process to ensure policies and procedures are followed. Personnel files should include complete and approved documentation of employee pay rates and verified final allocations to programs. Payroll documentation should include an after-the-fact determination of actual hours worked in each program or function of Agate Housing and Services, Inc. Corrective action -Agate Housing and Services, Inc. implemented a new payroll system on January 1, 2025 which incorporates built-in authorization controls and requires all employees to submit time based on actual hours worked in each program or function of the agency where required and by contract allocation method where approved. Management has also reviewed the pay-rate discrepancy identified during the audit and has taken corrective action to ensure the employee was compensated accurately. Going forward, management will perform periodic reviews to confirm pay rate changes are properly documented and that all payroll entries align with approved personnel records. Name of contact person responsible for corrective action - Donna Rapacz, Chief Operating Officer Completion date - Management implemented the above procedure as of January 1, 2025.

View Audit 398002

Finding 1206071 (2025-002)

Material Weakness 2025

Learn

CT

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Significant Deficiency

Major Federal Programs Significant Deficiency in Internal Control over Compliance and Other Matter Description of Finding During our testing, we noted LEARN did not have adequate documentation of internal controls designed to ensure vendors were not suspended or debarred. Statement of Concurrence or...

Major Federal Programs Significant Deficiency in Internal Control over Compliance and Other Matter Description of Finding During our testing, we noted LEARN did not have adequate documentation of internal controls designed to ensure vendors were not suspended or debarred. Statement of Concurrence or NonConcurrence Management agrees with this finding. Our corrective action plan is detailed below. Corrective Action Management has initiated corrective measures to strengthen internal controls over compliance. LEARN reviewed the existing procedure which outlines the steps to review vendor suspension/disbarment. The Business Office communicated the procedure to all staff with responsibilities for creating purchase orders. In addition, the Business Office reviewed all existing purchase orders over $20k and reviewed those vendors for suspension/disbarment. See attached for LEARN’s purchasing policy and the related procedure document. Name of Contact Person Mike Belden, CFO Projected Completion Date June 30, 2026

View Audit 397969

Finding 1206041 (2025-001)

Material Weakness 2025

Monte Vista Community Center Housing Authority, Inc.

CO

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Finding 2025-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture (Repeat of Finding 2024-001) Compliance Requirement: Eligibility, Program Income Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization s...

Finding 2025-001: Rural Rental Housing Loans Assistance Listing Number: 10.415 U.S. Department of Agriculture (Repeat of Finding 2024-001) Compliance Requirement: Eligibility, Program Income Type of finding: Internal Control Over Compliance (significant deficiency) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to ensure a review process is established through adequate segregation of duties. The Organization should consider assessing and realigning the duties and responsibilities of the Executive Director, Administrative Assistant, and Alamosa Property Manager to provide for a review process of tenant eligibility determinations and the monthly housing assistance payment requests for the Sierra Vista Alamosa Housing Complex. Action Taken: This finding was from the actions of the pervious on-site manager, concerning the Alamosa Complex only. Sierra Vista/Alamosa Complex has already implemented the internal control concerning compliance in house. Priscilla and Alonzo will make sure that all internal compliance issues are segregated and check by at least 2 persons in the office, and if needed, the Executive Director can request viewing of internal control procedures as well. Alonzo and Priscilla prepare and review along with signatures of the review and approval dates of internal affairs. "This institution is an equal opportunity provider." If there are questions regarding this plan, please call the responsible party at (719)852-5505. Sincerely yours, Corinna Garcia Executive Director Monte Vista Community Center Housing Authority, Inc.

View Audit 397889

Finding 1205928 (2025-002)

Material Weakness 2025

Accessible Residences, Inc. 113-Hd003

TX

HUD Housing Programs Allowable Costs / Cost Principles Cash Management

Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifica...

Special Tests – Significant Deficiency in Internal Controls over Compliance (Utility Allocation – Section 811 Program) Management Response Management acknowledges that utility allocation errors occurred in a limited number of instances due to a miscalculation in the allocation spreadsheet. Specifically, utility expenses were allocated among four tenants instead of five occupied tenants, resulting in an overallocation of utility costs to certain residents. The error was due to an input/calculation issue within the allocation spreadsheet and not a deficiency in the underlying allocation methodology. The organization’s documented utility allocation policy requires that total utility costs be allocated equally among occupied tenants, which is consistent with HUD requirements. Management has evaluated the exceptions identified and determined that the issue was isolated to specific instances of spreadsheet error rather than a systemic failure of the allocation methodology. Corrective Actions Implemented / To Be Implemented • The utility allocation spreadsheet will be corrected to ensure that the total number of occupied tenants is accurately reflected in the allocation calculation. • A two-level review control will be implemented over utility allocations. The Leasing Assistant/Clerk will prepare the allocation, and the Leasing Manager will independently verify accuracy prior to finalization. • Verification will include tenant count validation to the rent roll or occupancy report, recalculation of the per-tenant allocation, and confirmation that total allocations agree to the original utility invoice. • Allocation schedules will be supported by rent roll or occupancy documentation. • A standardized checklist will be implemented for monthly allocation procedures. • Any identified allocation errors will be promptly corrected to ensure tenants are not overcharged. Training Training on utility allocation procedures will be conducted by May 1, 2026, for leasing staff and management, with annual refresher training. Responsible Staff: Leasing Assistant/Clerk – Preparation Leasing Manager – Review and verification Controller – Oversight Chief Executive Officer (CEO) – Final accountability Implementation Date: Corrective actions are being implemented immediately upon identification of the finding. Ongoing monitoring will occur monthly.

View Audit 397748

Finding 1205910 (2025-003)

Material Weakness 2025

Midland Area Agency on Aging

NE

Allowable Costs / Cost Principles Cash Management Material Weakness

Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure meal counts are correctly accumulated and reported and in accordance with the requirem...

Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure meal counts are correctly accumulated and reported and in accordance with the requirements of the Uniform Guidance.

View Audit 397719

Finding 1205909 (2025-002)

Material Weakness 2025

Midland Area Agency on Aging

NE

Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure expenses are allocated correctly and in accordance with the requirements of the Unifor...

Views of Responsible Officials and Planned Corrective Actions: The Agency is committed to properly tracking and allocating Federal expenditures. The Agency will create adequate internal control processes to ensure expenses are allocated correctly and in accordance with the requirements of the Uniform Guidance.

View Audit 397719

Finding 1205903 (2025-005)

Material Weakness 2025

Cairo School District No. 1

IL

Allowable Costs / Cost Principles Cash Management Equipment & Real Property Management

Name of Contact Person: Pamela Rizkallah, Superintendent. Recommendation: We recommend that the District only charge costs that are allowable under the grant agreement. We also recommend that the District contact ISBE to discuss if the District will need to return the funds reimbursed by the Illinoi...

Name of Contact Person: Pamela Rizkallah, Superintendent. Recommendation: We recommend that the District only charge costs that are allowable under the grant agreement. We also recommend that the District contact ISBE to discuss if the District will need to return the funds reimbursed by the Illinois School Board of Education for these unallowable expenditures. Corrective Action: The District will ensure that all costs charged to the Title I grant are allowable per the grant agreement going forward. Proposed Completion Date: Immediately.

View Audit 397705

Finding 1205893 (2025-004)

Material Weakness 2025

Maritime Academy of Toledo

OH

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

The district Business Manager has implemented a system whereby copies of all invoices will be emailed to the Treasurer for approval before invoices are paid from any State, Local or Federal Funds. This will help prevent the district from using Federal funds for unallowable costs or activities. This ...

The district Business Manager has implemented a system whereby copies of all invoices will be emailed to the Treasurer for approval before invoices are paid from any State, Local or Federal Funds. This will help prevent the district from using Federal funds for unallowable costs or activities. This process will help ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.

View Audit 397689

Finding 1205892 (2025-003)

Material Weakness 2025

Maritime Academy of Toledo

OH

Allowable Costs / Cost Principles Reporting

Establish a consistent process for maintaining accurate documentation to support student withdrawals, graduation cohorts, and attendance by regularly reviewing EMIS data related to enrollment, attendance and graduation.. The attendance team, an administrator, and the EMIS coordinator will conduct mo...

Establish a consistent process for maintaining accurate documentation to support student withdrawals, graduation cohorts, and attendance by regularly reviewing EMIS data related to enrollment, attendance and graduation.. The attendance team, an administrator, and the EMIS coordinator will conduct monthly reviews of current data to ensure accuracy, compliance, and timely corrections.

View Audit 397689

Finding 1205834 (2025-003)

Material Weakness 2025

Highland Falls-Fort Montgomery Central School District

NY

Allowable Costs / Cost Principles Significant Deficiency

Finding & Recommendation 2025-003 - Compliance and Significant Deficiency in Internal Control over compliance with activities allowed or unallowed, allowable costs/cost principles: During testing of the payroll expenditures for the Special Education Cluster, it was found the District’s required payr...

Finding & Recommendation 2025-003 - Compliance and Significant Deficiency in Internal Control over compliance with activities allowed or unallowed, allowable costs/cost principles: During testing of the payroll expenditures for the Special Education Cluster, it was found the District’s required payroll certifications were incomplete for 4 of 13 employees paid in the program. The errors were for lack of signatures or dating issues by the supervisory reviewer. It was recommended the District’s written procedures of internal control with respect to program requirements be followed to ensure the District is in compliance at all times. This finding for Fiscal Year ending June 30, 2025, is related to the following program:  Federal Agency: US Department of Education; passed through NYS Dept. of Education  Program Name: Special Education Cluster  AL# 84.027 and 84.173 Management Response, Root Cause & Corrective Action: The district concurs and understands the importance of properly maintaining accurate and complete documentation related to the Special Education Cluster programs. The root cause was insufficient internal controls to ensure the process for proper completion of payroll certifications was being followed. The process will be followed in the future and starting April 6, 2026, Assistant Superintendent Christopher Carballo will review per pay period payroll certifications with Payroll Clerk Michele Drossos-Yorke to ensure accuracy and completeness with all properly dated and signed by both the employee and supervisor. These changes will be implemented starting May 1, 2026.

View Audit 397571

Finding 1205827 (2025-009)

Material Weakness 2025

Dillard University

LA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.430

Payroll The University acknowledges the finding related to discrepancies between payroll charges, personnel action forms, and time and effort reporting. We understand the requirement that all salary and wage charges to federal awards must be supported by accurate records and internal controls in acc...

Payroll The University acknowledges the finding related to discrepancies between payroll charges, personnel action forms, and time and effort reporting. We understand the requirement that all salary and wage charges to federal awards must be supported by accurate records and internal controls in accordance with Uniform Guidance §200.430. Corrective Actions 1. Alignment of Personnel Actions and Payroll Distribution: The University will implement additional review steps to ensure that labor distribution reports match the approved personnel action forms before payroll is charged to the grant. Any discrepancies must now be corrected before processing. 2. Strengthened Time and Effort Verification: Time and effort reports must now be reviewed and reconciled against the percentages authorized on personnel action forms. Reports that do not match will be returned to departments for correction before certification. 3. Enhanced Internal Controls and Documentation: A standardized monthly reconciliation process will be established to ensure consistency between personnel records, effort reporting, and payroll charges. 4. Staff Training: Training will be provided to fiscal managers, the Office of Research and Sponsored Programs, human resources, and payroll personnel on Uniform Guidance requirements, proper effort reporting, and documentation standards. 5. Periodic Monitoring: Supervisory reviews will be conducted to ensure continued compliance and to identify discrepancies proactively. The University believes these corrective measures will strengthen internal controls and ensure that payroll charges to federal programs are accurate, allowable, and properly documented.

View Audit 397569

Finding 1205824 (2025-007)

Material Weakness 2025

Dillard University

LA

Period of Performance Subrecipient Monitoring Allowable Costs / Cost Principles § 200.403

Allowable Costs / Period of Performance The University acknowledges the finding related to expenditures recorded outside the approved period of performance and the missing supporting documentation for one transaction. We recognize that all federally funded costs must be both allowable and incurred w...

Allowable Costs / Period of Performance The University acknowledges the finding related to expenditures recorded outside the approved period of performance and the missing supporting documentation for one transaction. We recognize that all federally funded costs must be both allowable and incurred within the designated performance period, and that proper documentation must be retained for audit purposes. Corrective Actions 1. Improved Period-of-Performance Verification: The University has strengthened its review procedures to ensure all expenses are confirmed as occurring within the applicable grant period before being charged to the award. Both grants management and accounting staff now verify dates prior to posting. 2. Enhanced Documentation Requirements: A shared electronic repository is being used to ensure all supporting documents are uploaded and retained before any expenditure is approved. Transactions submitted without documentation are now automatically rejected. 3. Staff Training: Relevant staff have received targeted training on allowable-cost rules, documentation standards, and period-of-performance requirements under Uniform Guidance. 4. Ongoing Monitoring: Periodic internal reviews will be conducted to verify continued compliance and ensure that all costs charged to federal awards are timely, appropriate, and fully supported, and charged within the required time periods. The University believes these actions address the issues noted and will strengthen internal controls over federal expenditures moving forward.

View Audit 397569

Finding 1205799 (2025-002)

Material Weakness 2025

Western States Air Resources Council

NM

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.400 § 200.68

2025-002 Corrective Action: We will correct the application of indirect costs and reduce the very next future request for reimbursement by the overcharged indirect costs. We have also changed the circumstances that caused the limitation to be overlooked related to this specific contract.

View Audit 397529

Finding 1205789 (2025-006)

Material Weakness 2025

Elko County School District

NV

Reporting Special Tests & Provisions Allowable Costs / Cost Principles § 200.303

Finding 2025-006 Finding Summary: Pursuant to 20 USC 2011h, the District is required to report graduation rate data for all public high schools for the District for each graduating cohort. To remove a student from the cohort, the District must confirm, in writing, that the student transferred out, e...

Finding 2025-006 Finding Summary: Pursuant to 20 USC 2011h, the District is required to report graduation rate data for all public high schools for the District for each graduating cohort. To remove a student from the cohort, the District must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. Elko County School District did not have sufficient internal controls to ensure all documentation for the removal of students from the cohort was maintained. Corrective Action Plan: The District will provide training to all registrars and create a consistent form that will be available to all school sites for tracking purposes Responsible Individual: Ray Smith Director of Special Education Anticipated Completion Date: June 2026

View Audit 397520

Finding 1205787 (2025-004)

Material Weakness 2025

Elko County School District

NV

Allowable Costs / Cost Principles Eligibility Reporting § 200.303

Finding 2025-004 Finding Summary: Elko County School District did not have sufficient internal controls to ensure eligibility determinations of Title I fund amounts disbursed were being appropriately followed. Corrective Action Plan: The grants department will update allocation procedures to ensure ...

Finding 2025-004 Finding Summary: Elko County School District did not have sufficient internal controls to ensure eligibility determinations of Title I fund amounts disbursed were being appropriately followed. Corrective Action Plan: The grants department will update allocation procedures to ensure equitable distribution of Title I funds to all eligible schools in rank order by low-income student count. Responsible Individual: Megan Cox Grant Manager Anticipated Completion Date: June 2026

View Audit 397520

Finding 1205758 (2025-002)

Material Weakness 2025

ILEARN SCHOOLS, INC.

NJ

Allowable Costs / Cost Principles Cash Management Internal Control / Segregation of Duties § 200.305 § 200.403 § 200.414

iLearn Schools, Inc. notes that the excess reimbursement of $85,425 was identified, properly recorded as a grant advance liability, and not recognized as revenue or expense in the current year. Going forward, all reimbursement requests will be based on actual allowable direct costs incurred. Managem...

iLearn Schools, Inc. notes that the excess reimbursement of $85,425 was identified, properly recorded as a grant advance liability, and not recognized as revenue or expense in the current year. Going forward, all reimbursement requests will be based on actual allowable direct costs incurred. Management will establish written procedures for indirect cost recovery, implement a formal review and reconciliation process prior to submission, and provide staff training on Uniform Guidance requirements. These corrective actions will be in place for the fiscal year ending June 30, 2026. Responsible Official: Mr. Coban, Chief Financial Officer

View Audit 397494

Finding 1205697 (2025-003)

Material Weakness 2025

Miles College

AL

Allowable Costs / Cost Principles Cash Management § 200.305 § 200.430

Finding 2025-003 - U.S. Department of Education (USO), TRIO Programs (Significant Deficiencies): Information on the federal program - Student Support SeNices, FAL No. 84.042A, June 30, 2025; Ronald McNair Program, FAL No. 84.217A, June 30, 2025. Under 2 CFR 200.305, non-Federal entities must request...

Finding 2025-003 - U.S. Department of Education (USO), TRIO Programs (Significant Deficiencies): Information on the federal program - Student Support SeNices, FAL No. 84.042A, June 30, 2025; Ronald McNair Program, FAL No. 84.217A, June 30, 2025. Under 2 CFR 200.305, non-Federal entities must request Federal funds only for allowable program costs that have been incurred, and must maintain contemporaneous supporting documentation demonstrating: a. Actual, allowable expenditures existed at the time Federal funds were drawn; and b. Records supporting the nature and timing of those expenditures were on file and readily available. These requirements ensure 1. Corrective Action Description a. The College now mandates that GS drawdown requests include approved documentation stored on the accounting drive, effective July 31, 2025. b. Time and Effort reports must be submitted monthly with supervisor sign-off before reaching the Office of Sponsor Programs, showing 100% time allocation. Any changes will require a Personnel Action Form and administrative approval signatures. c. showing 100% time allocation. Any changes will require a Personnel Action Form and administrative signatures of approval. 1. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu 2. Implementation Timeline This procedure took effect as of July 31, 2025. 3. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. 4. Disagreement with the Finding None

View Audit 397405

Finding 1205695 (2025-002)

Material Weakness 2025

Miles College

AL

Student Financial Aid Cash Management Allowable Costs / Cost Principles § 200.305

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Oppo...

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Teachers Education Assistance for College(TEACH),FAL No. 84.379, June 30, 2025. Under 2 CFR 200.305 and the U.S. Department of Education's cash management requirements at 34 CFR 668.162, institutions must draw down Title IV funds only for expenditures 1. Corrective Action Description The College now requires all drawdowns to include supporting documentation of the funds requested from GS, along with sign-offs on preparation and approval. Supporting documents are stored securely on the College's accounting drive for easy access. 2. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu a. Implementation Timeline This procedure took effect as of July 31, 2025. b. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. c. Disagreement with the Finding None

View Audit 397405

Finding 1205669 (2025-008)

Material Weakness 2025

City of South Gate

CA

Allowable Costs / Cost Principles § 200.430

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to the Housing Choice Voucher (HCV) Program under CFDA 14.871 must be supported by recordsthat accurately reflect actual work performed, as required under 2 ...

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to the Housing Choice Voucher (HCV) Program under CFDA 14.871 must be supported by recordsthat accurately reflect actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of using predetermined allocation percentages to distribute payroll across multiple funding sources did not fully satisfy the federal standards for documenting actual time worked on HCV-eligible activities. Management notes that the projected questioned costs of $214,045 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City will coordinate with HUD to determine the appropriate resolution of these questioned costs. The corrective actions outlined in Finding 2025-007 apply equally to the HCV Program. Specifically: 1. Actual Time Reporting: All Housing Authority employees who perform HCV program activities are required to document actual hours worked per program activity on their timesheets, effective immediately. 2. Discontinuation of Fixed Allocations: Predetermined allocation percentages will no longer serve as the basis for payroll charges to the HCV Program. All charges must be supported by actual time records. 3. Timesheet System and Training: Housing Authority staff will be included in the system enhancement and training initiatives described in Finding 2025-007, with particular emphasis on documentation standards under the HCV Program's applicable requirements4. Quarterly Internal Compliance Reviews: HCV payroll charges will be included in the Accounting & Finance Division's quarterly compliance reviews, with findings reported to the City Manager and the Housing Authority Director.

View Audit 397378

Finding 1205667 (2025-007)

Material Weakness 2025

City of South Gate

CA

Allowable Costs / Cost Principles § 200.430

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior pr...

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of distributing payroll costs using predetermined allocation percentages for employees working across multiple programs did not fully satisfy federal requirements for documenting actual time expended on CDBG-eligible activities. Management notes that the projected questioned costs of $217,355 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City isprepared to work with HUD to determine the appropriate resolution of these questioned costs. The City is implementing the following corrective actions: 1. Actual Time Reporting: Effective immediately, all employees who charge any portion of their time to federal grant programs—including CDBG—are required to document actual hours worked on each program or activity in their timesheets. Time entries must correspond to specific program activities and must be reviewed and certified by the employee's supervisor each pay period. 2. Discontinuation of Fixed Allocation Percentages: The City is eliminating the use of predetermined payroll allocation percentages as the basis for charging personnel costs to federally funded programs. Future payroll charges to federal awards will be based exclusively on actual documented hours, in compliance with 2 CFR 200.430(i). 3. Staff Training: The City will provide mandatory training to all employees who charge time to federal programs, supervisors responsible for timesheet review, and payroll staff. Training will cover the requirements of 2 CFR 200.430, the City's updated time documentation procedures, and the consequences of noncompliance.4. Quarterly Internal Compliance Reviews: Beginning in Q1 of FY 2025-26, the Accounting & Finance Division will conduct quarterly reviews of payroll charges to all federal programs to confirm that expenditures are supported by compliant time records. Results will be reported to the applicable department directors.

View Audit 397378

Finding 1205587 (2025-001)

Material Weakness 2025

El Valor Corporation

IL

Allowable Costs / Cost Principles

General Disbursement Allocation Recommendation: We recommend the Organization emphasize compliance with their established policies and procedures related to maintaining appropriate up-to-date supporting documentation for cash disbursements. Explanation of disagreement with audit finding: There is no...

General Disbursement Allocation Recommendation: We recommend the Organization emphasize compliance with their established policies and procedures related to maintaining appropriate up-to-date supporting documentation for cash disbursements. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action taken in response to finding: Management will enhance existing policies and procedures to strengthen monitoring of disbursement documentation and allocation records to ensure they are updated as changes occur. Name of the contact person responsible for corrective action: Jillian Gonzalez, Executive Director Planned completion date for corrective action plan: Implementation began immediately and will be ongoing.

View Audit 397281

Finding 1205563 (2025-001)

Material Weakness 2025

Narragansett Bay Commission

RI

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Narragansett Bay Commission Corrective Action Plan For the Fiscal Year Ended June 30, 2025 NBC acknowledges and concurs with the finding 2025-001 in the Fiscal Year 2025 Single Audit of the Narragansett Bay Commission conducted by Bacon & Company LLC. The Bucklin Point Wastewater Treatment Facility ...

Narragansett Bay Commission Corrective Action Plan For the Fiscal Year Ended June 30, 2025 NBC acknowledges and concurs with the finding 2025-001 in the Fiscal Year 2025 Single Audit of the Narragansett Bay Commission conducted by Bacon & Company LLC. The Bucklin Point Wastewater Treatment Facility Digester Complex Improvements “the Project”) has been funded by state revolving fund loan proceeds from the Rhode Island Infrastructure Bank (RIIB) and a Department of Energy grant. NBC’s contracting for civil projects has procedures in place to ensure the inclusion of all applicable Federal requirements as it relates to the use of RIIB funds. Although the Project followed Federal requirements as it relates to RIIB funds, NBC did not have appropriate controls in place to verify that applicable construction contracts for the Project included additional Federal requirements related to compliance with the Build America, Buy America Act as ostensibly required by the Department of Energy grant agreement. NBC has subsequently verified and received certification from the Project’s prime contractor that the Project satisfies Build America, Buy America Act requirements. Corrective Action Plan: In order to ensure that all applicable grant agreement terms are satisfied, NBC has hired a grant administrator to centralize all grant related activities within the Finance Division. NBC intends to develop additional procedures in conjunction with the acceptance and execution of a grant agreement to accomplish the following: 1) Coordinate with applicable Cost Center (as grant recipient) to verify that NBC has the ability to comply with the terms of the grant agreement, and 2) Create a comprehensive checklist of key obligations, including reporting deadlines, allowable costs, matching requirements, and special conditions and verify continued compliance on a regular interval, and 3) Limit award of contracts, expenditure of funds for grant funded projects, and reimbursement requests for grant funds until grant administrator verifies compliance with applicable terms and conditions. Anticipated Completion Date- May 31, 2026 Contact Person – Kevin McDonald, Chief Financial Officer

View Audit 397248

Finding 1205540 (2025-003)

Material Weakness 2025

THE NETWORK OF BEHAVORIAL HEALTH PROVIDERS, INC.

TX

Allowable Costs / Cost Principles Reporting

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing #: 21.027, Contract #: 220163. Condition and context: In testing 40 nonpayroll transactions, we...

Finding #2025-003 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing #: 21.027, Contract #: 220163. Condition and context: In testing 40 nonpayroll transactions, we found one instance of an unallowable cost for a late fee charged to the grant and 2 instances of transactions recognized in the incorrect fiscal year. Additionally, 1 out of 9 payroll transactions were incorrectly allocated resulting in the understatement of payroll charged to the grant. Recommendation: Amend NBHP’s policies and procedures to include independent review of allowability of cost and payroll allocations. Planned corrective action: NBHP will modify its policies and procedures to include independent review of transaction for allowability and accuracy. Responsible officer: Lisa Albert, Executive Director. Estimated completion date: April 30, 2026.

View Audit 397225

Finding 1205539 (2025-002)

Material Weakness 2025

THE NETWORK OF BEHAVORIAL HEALTH PROVIDERS, INC.

TX

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Subrecipient Monitoring

Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing #: 21.027, Contract #: 220163. Condition and context: In testing 1 out of 6 vendors subject to ...

Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Treasury, COVID-19 Coronavirus State and Local Fiscal Recovery Funds, Assistance Listing #: 21.027, Contract #: 220163. Condition and context: In testing 1 out of 6 vendors subject to procurement, NBHP had not verified and documented that the Houston Health Department was not suspended or disbarred. Recommendation: Amend the procurement policy to require verification that person or organization is not suspended or disbarred. Planned corrective action: NBHP will modify its procurement policy to include verification that persons or organizations are not suspended or disbarred. Responsible officer: Lisa Albert, Executive Director. Estimated completion date: April 30, 2026.

View Audit 397225

Finding 1205536 (2025-001)

Material Weakness 2025

Lindenhurst Union Free School District

NY

Allowable Costs / Cost Principles § 200.430

2025-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Title I Grants to Local Educational Agencies ALN: 84.010A Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for...

2025-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Title I Grants to Local Educational Agencies ALN: 84.010A Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with the documentation standards prescribed by Subpart E, 2 CFR §200.430; the amount of one employee’s actual payroll charged to the Title I federal award was less than the allocation percentage on the periodic certification reports that were signed by the employee’s supervisor. Planned Corrective Action: The District will adopt procedures that ensure that appropriate documentation for time and effort will be used to support costs charged to the federal award, and comply with Subpart E, 2 CFR §200.430. Responsible Contact Person: Mr. William Ludeker Assistant Superintendent for Business Lindenhurst Union Free School District 350 Daniel Street Lindenhurst, New York 11757 Anticipated Completion Date: June 30, 2026.

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