Corrective Action Plans

Finding 1223912 (2025-001)

Material Weakness 2025

DC

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.403 § 200.405

The Society of American Foresters has enhanced their exis􀆟ng expense recogni􀆟on controls for event-related invoices by reques􀆟ng more detailed vendor invoices that clearly iden􀆟fy the event and applicable service period, implemen􀆟ng addi􀆟onal review for vendors with recurring or overlapping billing ...

The Society of American Foresters has enhanced their exis􀆟ng expense recogni􀆟on controls for event-related invoices by reques􀆟ng more detailed vendor invoices that clearly iden􀆟fy the event and applicable service period, implemen􀆟ng addi􀆟onal review for vendors with recurring or overlapping billing arrangements, and reinforcing current invoice review procedures to ensure that the period of benefit is adequately documented, par􀆟cularly for transac􀆟ons occurring near year-end. These enhancements are intended to further strengthen the Society’s already effec􀆟ve control environment and support consistent and accurate recogni􀆟on of event expenses in accordance with federal requirements and GAAP.

View Audit 407320

Finding 1223881 (2025-004)

Material Weakness 2025

Paterson Board of Education

NJ

Eligibility Questioned Costs Allowable Costs / Cost Principles

Condition/Finding: There were instances in which payroll timesheets and resolutions authorizing payroll expenseswere not available for review at the time of audit. Recommendation:The District should ensure that all payroll timesheets and resolutions authorizing payroll expenses are available for rev...

Condition/Finding: There were instances in which payroll timesheets and resolutions authorizing payroll expenseswere not available for review at the time of audit. Recommendation:The District should ensure that all payroll timesheets and resolutions authorizing payroll expenses are available for review at the time of audit. Method of Implementation: The district will improve the filing and retention of payroll timesheets and resolutions authorizing payroll expenses for federal programs. All payroll documentation will be properly maintained and made readily available for review at the time of audit.

View Audit 407311

Finding 1223880 (2025-003)

Material Weakness 2025

Golden House, Inc.

WI

Allowable Costs / Cost Principles § 200.403

Finding 2025-003: Lack of Authorization for Expenses - The Organization is currently updating their approval process and including an additional approval form. This form will require accounts payable staff to verify that the expense has appropriate signatures before any federal grants are charged.

View Audit 407307

Finding 1223818 (2025-002)

Material Weakness 2025

Union College

NY

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.303 § 200.414

Federal Agency: Various Federal Program: Research and Development Cluster Assistance Listing Number: Various Federal Award Numbers: Various Finding No.: 2025-002 Corrective Action Plan: To address the finding, the College will continue to implement a corrective action plan to strengthen internal con...

Federal Agency: Various Federal Program: Research and Development Cluster Assistance Listing Number: Various Federal Award Numbers: Various Finding No.: 2025-002 Corrective Action Plan: To address the finding, the College will continue to implement a corrective action plan to strengthen internal controls over the application of indirect cost rates to federally funded awards. Although corrective actions were initiated following the prior year's finding, the College has identified opportunities to enhance the review and monitoring of indirect cost rate calculations to ensure consistent compliance with Uniform Guidance. Going forward, the accounting group, in collaboration with the Office of Sponsored Programs, will maintain the current federally negotiated indirect cost rates, apply approved rates to applicable awards, and perform periodic reviews to verify that the correct rates are consistently applied. Timeline for Implementation of Corrective Action Plan: The College will finalize written procedures governing the application and review of indirect cost rates, implement a documented review process for indirect cost calculations prior to posting, and provide guidance to employees responsible for grant accounting. These actions will be completed by September 30, 2026. Management will periodically monitor compliance to ensure indirect cost rates are applied accurately and in accordance with federal requirements.

View Audit 407295

Finding 1223766 (2025-003)

Material Weakness 2025

Family & Childcare Resources of Northeast Wisconsin, Inc.

WI

Allowable Costs / Cost Principles Reporting

The Organization is aware of the requirements and will attempt to compile the information necessary to assure its compliance with this in the future.

View Audit 407242

Finding 1223692 (2025-003)

Material Weakness 2025

Lapeer County

MI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Significant Deficiency § 200.403

2025-003 ACTIVITES ALLOWED/ALLOWABLE COST PRINCIPLES Planned Corrective Action: This CMHSP will strengthen its grant financial management procedures. Finance staff will verify that all indirect cost calculations comply with the approved grant budget and the requirements of the federal award before i...

2025-003 ACTIVITES ALLOWED/ALLOWABLE COST PRINCIPLES Planned Corrective Action: This CMHSP will strengthen its grant financial management procedures. Finance staff will verify that all indirect cost calculations comply with the approved grant budget and the requirements of the federal award before indirect costs are charged to the grant. A grant expenditure tracking process will be established to monitor direct and indirect costs against the approved budget throughout the grant period. The Chief Financial Officer will review indirect cost calculations and budget-to-actual expenditures monthly to ensure expenditures remain within approved budget limitations and comply with applicable federal regulations and grant requirements. This CMHSP will create grant management policies and procedures, outside of the County of Lapeer’s grant management policy, to include documented reviews of indirect cost calculations, monthly budget monitoring, and supervisory approval of grant expenditures to ensure compliance with federal awards. Responsible Party: Emma McQuillan, Chief Financial Officer Anticipated Completion Date: 09/30/2026

View Audit 407192

Finding 1223673 (2025-002)

Material Weakness 2025

Bakerripley

TX

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: Department of Health and Human Services, Assistance Listing #: 93.575 – Childcare and Development Block Grant (CCDF Cluster), Passed through Houston-Galveston Area Council, Contract Number: 13410 and 200...

Finding #2025-002 – Significant Deficiency and Other Noncompliance. Applicable federal programs: Department of Health and Human Services, Assistance Listing #: 93.575 – Childcare and Development Block Grant (CCDF Cluster), Passed through Houston-Galveston Area Council, Contract Number: 13410 and 20020, Contract Year: 10/01/24 – 09/30/25, 10/01/25 - 09/30/26, Assistance Listing #: 93.596 – Child Care Mandatory and Matching Funds of the Child Care and Development Fund (CCDF Cluster), Passed through Houston-Galveston Area Council, Contract Number: 13410 and 20020, Contract Year: 10/01/24 – 09/30/25, 10/01/25 - 09/30/26, Department of Agriculture, Assistance Listing #: 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program (SNAP Cluster), Passed through Houston-Galveston Area Council, Contract Number: 20020, Contract Year: 10/01/25 - 09/30/26. Condition and context: During our testing of 40 federal and state payments to childcare providers under the Houston-Galveston Area Council contract, we noted that 1 childcare provider was paid at an incorrect provider rate resulting in an overpayment of $9.10. Recommendation: Re-emphasize training of personnel and adherence to BakerRipley’s and TWC’s policies and procedures. Corrective action: BakerRipley will re-emphasize training of personnel and adherence to BakerRipley’s and TWC’s policies and procedures. Responsible officer: Neil Hanson. Estimated date of completion: December 31, 2026

View Audit 407173

Finding 1223640 (2025-012)

Material Weakness 2025

Canadian County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

View Audit 407153

Finding 1223639 (2025-010)

Material Weakness 2025

Canadian County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties

We will work to implement a Risk Assessment plan over federal grants. We will implement controls to make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compli...

We will work to implement a Risk Assessment plan over federal grants. We will implement controls to make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compliance supplement to work from.

View Audit 407153

Finding 1223628 (2025-001)

Material Weakness 2025

Town of Stoughton

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Town agrees with this finding. We understand that while the total project budget was correct, $324, 641 for the Park St. Sewer Main, the project was accidentally listed as a current expense instead of a past expense. Corrective Action Plan: To fix this and make sure it does not happen again, the...

The Town agrees with this finding. We understand that while the total project budget was correct, $324, 641 for the Park St. Sewer Main, the project was accidentally listed as a current expense instead of a past expense. Corrective Action Plan: To fix this and make sure it does not happen again, the Town will take the following steps: Before sending any future reports to the federal government, the Finance Department will match the report numbers directly to the Town's official accounting records (the general ledger). A second person in the finance department will review and sign off on the report before it is submitted. We will save copies of the accounting records and the signed approval forms to show future auditors. Planned Implementation Date of Corrective Action: September 1, 2026 Person Responsible for Corrective Action: Town Accountant/ Finance Director

View Audit 407123

Finding 1223623 (2025-002)

Material Weakness 2025

Indiana Diaper Bank, Inc.

IN

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.430

Finding 2025-02 Insufficient Documentation of Personnel Expenses Condition: The Organization charges a material amount of payroll-related costs to its major federal program. However, for 7 months of the year, it did not maintain sufficient documentation to support the level of effort charged to the ...

Finding 2025-02 Insufficient Documentation of Personnel Expenses Condition: The Organization charges a material amount of payroll-related costs to its major federal program. However, for 7 months of the year, it did not maintain sufficient documentation to support the level of effort charged to the award, as required by federal regulations. While staff members are required to complete timesheets, the format did not capture the level of detail needed to substantiate payroll allocations to federal programs. Additionally, there was no formal process for supervisory review and approval of these timesheets. Although no overcharges or double-dipping were identified, the lack of adequate documentation results in known and likely questioned costs due to noncompliance with documentation requirements. A new system was implemented in August 2025 which improved the deficiencies and compliance matters for the remainder of the year. Corrective Actions Taken or Planned: The Organization started using features within Gusto beginning in August 2025 that capture employee name, pay period, hours worked by funding source, detailed notes (if applicable) and supervisory approval. The Organization trained all staff whose salaries are charged in whole or in part to grants on documentation and time allocation requirements. Monthly timesheets charged to grants are reviewed before submission for reimbursement. All timesheets require approval by a supervisor before payroll is processed and the final payroll requires two approvals by the CEO. Accounting Manager and/or the Development Manager. The Organization will conduct quarterly internal reviews to ensure compliance and adjust as needed.

View Audit 407121

Finding 1223613 (2025-004)

Material Weakness 2025

Municipality of Corozal

PR

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.510

Management's Response and Corrective Action Plan Fiscal Year 2025 Single Audit Finding Reference: 2025-001 & 2025-004 o Classification: Material Weakness in Internal Control Over Financial Reporting / Compliance o Target Completion Date: 120 Days (from the issuance of the final audit report o Respon...

Management's Response and Corrective Action Plan Fiscal Year 2025 Single Audit Finding Reference: 2025-001 & 2025-004 o Classification: Material Weakness in Internal Control Over Financial Reporting / Compliance o Target Completion Date: 120 Days (from the issuance of the final audit report o Responsible Officials: Finance Director, Director of Information Systems and the Municipal Advisor Management's Response & Corrective Action Plan: Concurrence with the Findings: The Management of the Municipality of Corozal concurs with the conditions and recommendations outlined in Findings 2025-001 and 2025-004 We acknowledge that the recent migration of our core accounting system compromised the system's operational and technical capacity to generate balanced trial balances, reconcile subsidiary ledgers, and streamline the automatic production of the Schedule of Expenditures of Federal Awards (SEFA). Corrective Actions to be Implemented: To resolve these deficiencies systematically and ensure full compliance with Government Auditing Standards and the Uniform Guidance (2 CFR 200), the Municipality will execute the following action plan within a strict 120-day timeframe: 1. System Re-alignment & Expert Remediation (Led by: Director of Information Systems and the Municipal Advisor): The Municipality will immediately retain specialized software implementation engineers and municipal accounting consultants to trace the migration mapping errors. This team will re-align the platform's database structure to correct the corrupted historical financial data and prior-period balances. 2. Opening Balance Reconstruction (Led by: Finance Director & Municipal Advisor): A formal data-clearing project will be established to reconstruct, cross-reference, and validate all opening balances transferred from the legacy system against the prior year's audited financial statements to restore data integrity. 3. Interim Manual Tracking for Federal Programs (Led by: Finance Director): To address the risks highlighted in Finding 2025-004 the Finance Department will immediately implement an interim manual spreadsheet tracking matrix. This will ensure all federal expenditures across all active Assistance Listings (ALN) are manually reconciled with federal drawdowns and physical invoices until the core accounting database is completely functional. 4. Closing Controls & Migration Policies (Led by: Joint Committee): We will design and implement rigid monthly closing routines and formal trial balance reviews. Furthermore, we will establish strict IT transition frameworks requiring dual-system running periods and mandatory data-integrity sign-offs before any future application or ledger upgrades are deployed. Should you have any questions or require additional information, please do not hesitate to contact the undersigned at (787) 859-3060, ext. 1703. Sincerely Jose A Rivera Miranda Finance Director

View Audit 407087

Finding 1223598 (2025-002)

Material Weakness 2025

The Women's Safe House

MO

Allowable Costs / Cost Principles Cash Management Eligibility § 200.403

View of Responsible Officials and Corrective Actions: We agree with the auditor's recommendation. Although the referenced invoices were reviewed by the CEO from the vendor for eligibility and reasonableness upon receipt of the automatic e-mailed invoice, there was no procedure to print and retain th...

View of Responsible Officials and Corrective Actions: We agree with the auditor's recommendation. Although the referenced invoices were reviewed by the CEO from the vendor for eligibility and reasonableness upon receipt of the automatic e-mailed invoice, there was no procedure to print and retain this documentation in the accounting files for Instacart invoices. Effective June 1, 2026, each month the Director of Finance will compare a checklist of all credit charges to the physical copies prior to filing and obtain any missing invoices as part of the monthly closing process.

View Audit 407064

Finding 1223592 (2025-002)

Material Weakness 2025

Metropolitan Development Council

WA

Questioned Costs Special Tests & Provisions Allowable Costs / Cost Principles

See pdf of corrective action plan

View Audit 407034

Finding 1223583 (2025-001)

Material Weakness 2025

Upham's Corner Health Committee, Inc.

MA

Allowable Costs / Cost Principles § 200.430

Health Center Program – Assistance Listing No. 93.224 Recommendation: Management should implement a formal time and effort reporting process that ensures payroll costs charged to federal awards are supported by contemporaneous documentation of actual work performed, requires retention of historical,...

Health Center Program – Assistance Listing No. 93.224 Recommendation: Management should implement a formal time and effort reporting process that ensures payroll costs charged to federal awards are supported by contemporaneous documentation of actual work performed, requires retention of historical, point-in-time allocation records for each payroll period (e.g., version-controlled or archived reports), and includes a documented review and approval process that compares allocation percentages to employee attestations or activity reports to validate the reasonableness and accuracy of costs charged to the grant. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management concurs with the finding. To address this issue, the Organization intends to fund all staff on payroll at one hundred percent of salaries and benefits to minimize the risk that allowable costs are misstated and not in compliance with 2 CFR 200.430. Name(s) of the contact person(s) responsible for corrective action: Chief Financial Officer or their designee. Planned completion date for corrective action plan: July 1, 2026

View Audit 407018

Finding 1223573 (2025-002)

Material Weakness 2025

Desoto Parish Police Jury

LA

Subrecipient Monitoring Allowable Costs / Cost Principles Questioned Costs

Management will ensure that inspections are documented in each tenant file and will utilize the PHA-Web alert system to monitor any past due inspections and will conduct inspections and upload the file to the HUD PIC System. The HUD Supervisor will use the comment sections on the NSPIRE form and not...

Management will ensure that inspections are documented in each tenant file and will utilize the PHA-Web alert system to monitor any past due inspections and will conduct inspections and upload the file to the HUD PIC System. The HUD Supervisor will use the comment sections on the NSPIRE form and note any deficiencies. If there are no deficiencies, the file will state in the comment section that there are no deficiencies and reference the area’s positive outcome.

View Audit 406999

Finding 1223559 (2025-001)

Material Weakness 2025

Clay Counth Health Department

MO

Allowable Costs / Cost Principles

Corrective Action Plan Management will review and revise policies and procedures related to verifying that correct actual wage rates and related benefits are used to request reimbursements from federal awards. Person Responsible for Implementation: Sarah Unruh, Program Manager of Accounting. Telepho...

Corrective Action Plan Management will review and revise policies and procedures related to verifying that correct actual wage rates and related benefits are used to request reimbursements from federal awards. Person Responsible for Implementation: Sarah Unruh, Program Manager of Accounting. Telephone (816) 595-4269, Email sunruh@clayhealth.com Implementation Date: Implementation of the corrective action plan has been implemented as policies and procedures have been updated and revised. In addition, the Health Center has informed and has been working with the Missouri Department of Health. The April 2026 reimbursement request was modified and corrected for the errors.

View Audit 406955

Finding 1223545 (2025-001)

Material Weakness 2025

Vesta Germantown, Inc.

MD

HUD Housing Programs Reporting Questioned Costs

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406910

Finding 1223544 (2025-001)

Material Weakness 2025

Vesta Thirteen, Inc.

MD

HUD Housing Programs Reporting Questioned Costs

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406909

Finding 1223543 (2025-001)

Material Weakness 2025

Vesta Twelve, Inc.

MD

HUD Housing Programs Reporting Questioned Costs

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406908

Finding 1223542 (2025-001)

Material Weakness 2025

Vesta Enteka, Inc.

MD

HUD Housing Programs Reporting Questioned Costs

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406907

Finding 1223541 (2025-001)

Material Weakness 2025

Vesta Severn, Inc.

MD

HUD Housing Programs Reporting Questioned Costs

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406906

Finding 1223540 (2025-002)

Material Weakness 2025

Vesta Forest, Inc.

MD

HUD Housing Programs Reporting Questioned Costs

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406905

Finding 1223538 (2025-001)

Material Weakness 2025

Vesta Riverdale, Inc.

MD

HUD Housing Programs Reporting Allowable Costs / Cost Principles

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406904

Finding 1223537 (2025-001)

Material Weakness 2025

Vesta Charles, Inc.

MD

HUD Housing Programs Reporting Allowable Costs / Cost Principles

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. Th...

Condition: The audit identified multiple instances in which expenses processed through the centralized operating account were not allocated to the appropriate HUD insured projects. Certain costs were charged to incorrect entities or to projects that did not receive the benefit of the expenditure. These misallocations occurred across multiple fiscal years. The costs were determined to be immaterial to the financial statements overall. Cause: Insufficient internal controls over transaction coding and allocation within the centralized operating account resulted in errors. Supervisory review was inconsistent, and periodic reconciliations were not performed at a level sufficient to detect and correct misallocations. Corrective Action Plan: Management acknowledges the finding and has taken steps to strengthen internal controls and ensure accurate project level reporting in accordance with HUD Handbook 4370.2. 1. Enhanced Supervisory Review Management has implemented a mandatory supervisory review and approval process for all postings from the centralized operating account. Updated procedures require documentation supporting allocation decisions and verification that expenses benefit the appropriate project. Implementation Status: Implemented January 2026; ongoing. 2. Periodic Reconciliations Supervisory review of transactions are now performed to confirm that expenses are charged to the correct project. A periodic cross project allocation review has been established to ensure consistency and compliance with HUD requirements. Implementation Status: Implemented January 2026; ongoing. 3. Correction of Prior Year Misallocations A detailed review of prior year postings is underway to identify misallocated expenses. Adjusting journal entries will be recorded during Fiscal Year 2026 to reclassify expenses to the appropriate projects. Implementation Status: In progress; expected completion during FY 2026. 4. Improvements to Allocation Methodology and Coding Controls The address based allocation logic that contributed to the errors has been corrected. System controls now require project specific coding at the point of entry. Staff have received updated training on proper allocation procedures and HUD requirements. Implementation Status: Completed December 2025; training ongoing. Anticipated Completion Date: All corrective actions will be fully implemented by the end of Fiscal Year 2026.

View Audit 406903

Corrective Action Plans

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