Corrective Action Plans

Finding 565359 (2023-003)

Significant Deficiency 2023

NE

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

Condition: Certain underlying support related to the VOCA Victim Assistance Formula Grant did not agree to amounts charged to the grant. Supporting information and records indicated more funds were spent by the Organization than were charged to the grant. Planned Corrective Action: Management will ...

Condition: Certain underlying support related to the VOCA Victim Assistance Formula Grant did not agree to amounts charged to the grant. Supporting information and records indicated more funds were spent by the Organization than were charged to the grant. Planned Corrective Action: Management will review its processes, procedures and controls to ensure that reconciliation and review of grant reimbursement requests and supporting underlying documentation occurs in future periods. Planned Completion Date: Ongoing Person Responsible: Kim Reed, VP of Finance

View Audit 359201

Finding 565325 (2023-002)

Significant Deficiency 2023

The Wayside House, Inc. and Subsidiary

MN

Allowable Costs / Cost Principles § 200.403

Management agrees with the auditors' finding and will take action to implement controlling procedures over federal programs.

View Audit 359149

Finding 565317 (2023-001)

Significant Deficiency 2023

Assabet Valley Regional Technical High School

MA

Questioned Costs Period of Performance Allowable Costs / Cost Principles

Department of Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Finding 2023-001 – Career and Technical Education - Perkins CFDA No. 84.048 Condition: During our test of controls over compliance it was noted that there are expenditur...

Department of Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Programs Finding 2023-001 – Career and Technical Education - Perkins CFDA No. 84.048 Condition: During our test of controls over compliance it was noted that there are expenditures charged to the Career and Technical Education - Perkins for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Criteria: The Period of Performance for the Career and Technical Education Perkins Program – 2023 Skills USA was September 15, 2022 through August 31, 2023 & Career and Technical Education Perkins Program – Equitable Access Grant was August 19, 2022 – August 31, 2023. Context: During our test of expenditures and review of the general ledger against the Career and Technical Education Program Perkins 2023 Skills USA grant as it is related to compliance it was noted that a payroll for the pay period of 8/14/22 – 8/27/22 was charged to the grant for services prior to the grant start date of September 15, 2022 and thus would be outside the period of performance and an unallowable cost. During our test of expenditures and review of the general ledger against the Career and Technical Education Perkins Program Equitable Access grant as it is related to compliance it was noted that an invoice charged to the grant was for services provided on August 8, 2022 & August 9, 2022 and that was charged to the grant for services prior to the grant start date of August 19, 2022 and thus would be outside the period of performance and an unallowable cost. Effect: Assabet Valley RTHS was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned costs for the payroll charged to the Career and Technical Education Perkins Program 2023 Skills USA grant whose service period was prior to the grant start date of September 15, 2022 in the amount of $5,321.54. Questioned costs for the invoice charged to the Career and Technical Education Perkins Program Equitable Access grant whose service period was prior to the grant start date of August 19, 2022 in the amount of $1,872.00. Cause: Grant should have been amended Identification as a Repeat Finding: N/A Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that payroll and expenditures charged to the grants are within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Responsible for Corrective Plan: Maria Silva, Director of Business Operations Estimated Completion Date: 12/31/2024 Action Taken: The District agrees with the recommendation and will work with those writing the grants.

View Audit 359144 Questioned Costs: $1

Finding 565316 (2023-003)

Material Weakness 2023

Assabet Valley Regional Technical High School

MA

Questioned Costs Period of Performance Allowable Costs / Cost Principles

Department of Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Finding 2023-003 – Education Stabilization Fund – ESSER III AL No. 84.425U Condition: During our test of controls over compliance it was noted that there are expenditures ch...

Department of Education Noncompliance and Material Weakness Related to Internal Control over Compliance of the Major Program Finding 2023-003 – Education Stabilization Fund – ESSER III AL No. 84.425U Condition: During our test of controls over compliance it was noted that there are expenditures charged to the Education Stabilization Fund – ESSER III for services outside of the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Criteria: The Period of Performance for the Education Stabilization Fund – ESSER III was October 4, 2021 through September 30, 2024. Context: During our test of expenditures and review of the general ledger against the Education Stabilization Fund – ESSER III grant as it is related to compliance it was noted that the School paid in full a four year lease from 3/1/23 to 2/28/27 and charged 10/1/23 to 2/28/27 to the Education Stabilization Fund – ESSER III grant in the amount of $190,869 and thus the period from 10/1/24 to 2/28/27 would be outside the period of performance and thus would not be an allowable cost. Effect: Assabet Valley RTHS was not in compliance with the period of performance requirement as set forth by the Massachusetts Department of Elementary and Secondary Education. Questioned Costs: Questioned costs charged to the Education Stabilization Fund – ESSER III grant whose service period was beyond the grant end date of September 30, 2024 was in the amount of $135,005. Cause: Grant should have been amended Identification as a Repeat Finding: N/A Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that expenditures charged to the grant is within the period of performance as set forth by the Massachusetts Department of Elementary and Secondary Education. Responsible for Corrective Plan: Maria Silva, Director of Business Operations Estimated Completion Date: 12/31/2024 Action Taken: The District agrees with the recommendation and will work with those writing the grants.

View Audit 359144 Questioned Costs: $1

Finding 565315 (2023-002)

Significant Deficiency 2023

Assabet Valley Regional Technical High School

MA

Questioned Costs Allowable Costs / Cost Principles

Department of Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Finding 2023-002 – Education Stabilization Fund – ESSER III AL No. 84.425U Condition: During our test of controls over compliance it was noted that an employee’s payroll...

Department of Education Noncompliance and Significant Deficiency Related to Internal Control over Compliance of the Major Program Finding 2023-002 – Education Stabilization Fund – ESSER III AL No. 84.425U Condition: During our test of controls over compliance it was noted that an employee’s payroll charged to the Education Stabilization Fund – ESSER III major program was for services that was not included as part of the grant application/budget. Criteria: Costs charged to the major program should meet the requirements as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Context: During our review of payroll charged to the major program it was noted that one of the employees charged to the grant was for work as a School Adjustment Counselor that was charged to the Instructional Staff budget of the grant, which does not support the services charged. Thus the payroll expense would be unallowable. Effect: Assabet Valley RTHS was not in compliance with the allowable costs/ cost principals requirement as set forth by the Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles). Questioned Costs: $76,676.89 Cause: Grant should have been amended Identification as a Repeat Finding: 2022-001 Recommendation: We recommend the Assabet Valley RTHS follow procedures to ensure that payroll expenditures charged to the grant is allowable costs as set forth by Uniform Guidance 2 CFR Part 200, subpart E (Cost Principles) Responsible for Corrective Plan: Maria Silva, Director of Business Operations Estimated Completion Date: 12/31/2024 Action Taken: The District agrees with the recommendation and will work with those writing the grants.

View Audit 359144 Questioned Costs: $1

Finding 565301 (2023-004)

Material Weakness 2023

City of Madison

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2023-004 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy McGee Contact Phone Number and Email Address: 812-265-8300, mmcgee@madison-in.gov Views of Responsible Officials: We concur with the finding regardi...

FINDING 2023-004 Finding Subject: Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Mindy McGee Contact Phone Number and Email Address: 812-265-8300, mmcgee@madison-in.gov Views of Responsible Officials: We concur with the finding regarding errors in Coronavirus Fund reporting. Description of Corrective Action Plan: Historically, the city has not had a centralized position who would be responsible for grant compliance and reporting. Individual department heads were responsible for comp0lying with each awarded grant for their own area of responsibility. In spring of 2025, a new Project & Grant Manager position was created and filled by a qualified individual. The responsibilities of the position include data collection and analysis, project management, grant coordination, information management and compliance monitoring and reporting. Anticipated Completion Date: The new position referenced above has been filled and is in operation as of April 8th 2025.

View Audit 359138

Finding 565063 (2023-003)

Material Weakness 2023

City of South Portland, Maine

ME

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Management’s Response/Corrective Action Plan: The School Department has had turnover in positions that have had oversight and direct involvement in this process. In some cases, the established process was followed as constructed; however, in others, gaps in coverage are clearly exposed. The School D...

Management’s Response/Corrective Action Plan: The School Department has had turnover in positions that have had oversight and direct involvement in this process. In some cases, the established process was followed as constructed; however, in others, gaps in coverage are clearly exposed. The School Department agrees that the management of important documents has been inconsistent. In the future, the School Department will be assigning the management of these documents to positions where turnover is less likely to occur and a more consistent process is maintained.

View Audit 358995

Finding 565062 (2023-004)

Material Weakness 2023

City of South Portland, Maine

ME

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Management’s Response/Corrective Action Plan: The School Department has had turnover in positions that have had oversight and direct involvement in this process. In some cases, the established process was followed as constructed; however, in others, gaps in coverage are clearly exposed. The School D...

Management’s Response/Corrective Action Plan: The School Department has had turnover in positions that have had oversight and direct involvement in this process. In some cases, the established process was followed as constructed; however, in others, gaps in coverage are clearly exposed. The School Department agrees that the management of important documents has been inconsistent. In the future, the School Department will be assigning the management of these documents to positions where turnover is less likely to occur and a more consistent process is maintained.

View Audit 358995

Finding 564787 (2023-002)

Significant Deficiency 2023

Lifetime Independence for Everyone, Inc. and Subsidiary

TX

Questioned Costs Allowable Costs / Cost Principles Significant Deficiency § 200.303 § 200.405

Auditor's Recommendation: The auditor recommends the Organization enhance the design of its control activities and procedures over the allocation percentage forms used throughout the year to ensure the staff know how to apply percentages and are using the correct approved allocation form for the per...

Auditor's Recommendation: The auditor recommends the Organization enhance the design of its control activities and procedures over the allocation percentage forms used throughout the year to ensure the staff know how to apply percentages and are using the correct approved allocation form for the period in the year. Management’s Response: A process was implemented in fiscal year 2024 to address this issued and included the following: • The allocation form was updated and is now clearly labeled with the period and type of expense for which it applies. • The Executive Director communicated the revision of all forms to staff involved in the allocation process, followed by a training session to ensure understanding and proper application of the form. • A monthly review of the process, whereby allocation forms were audited for current updates and application consistency. Due date of completion: August 31, 2024 Responsible Official: Executive Director, Michelle Crain

View Audit 358843 Questioned Costs: $1

Finding 564156 (2023-005)

None 2023

Special Education District of Lake County

IL

Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No.: 2023-005 Condition: SEDOL did not have sufficient support showing approved alloca􀆟ons for salary and benefits for individuals whose payroll costs were par􀆟ally claimed under federal grants. Plan: Management will implement a process to properly document, review and monitor alloca􀆟on of p...

Finding No.: 2023-005 Condition: SEDOL did not have sufficient support showing approved alloca􀆟ons for salary and benefits for individuals whose payroll costs were par􀆟ally claimed under federal grants. Plan: Management will implement a process to properly document, review and monitor alloca􀆟on of personnel costs. An􀆟cipated Date of Comple􀆟on: 6/30/2026 Name of Contact Person: Dr. Stephen Johns, Co-Interim Assistant Superintendent

View Audit 358321

Finding 564152 (2023-003)

Material Weakness 2023

Special Education District of Lake County

IL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No.: 2023-003 Condi􀆟on: SEDOL submited grant expenditure reports for reimbursement without having sufficient support for expenditures claimed, resul􀆟ng in reimbursements greater than allowable costs. Plan: Management will implement a process to properly budget, track and monitor grant expend...

Finding No.: 2023-003 Condi􀆟on: SEDOL submited grant expenditure reports for reimbursement without having sufficient support for expenditures claimed, resul􀆟ng in reimbursements greater than allowable costs. Plan: Management will implement a process to properly budget, track and monitor grant expenditures and create an improved review and oversight process. An􀆟cipated Date of Comple􀆟on: 6/30/2026 Name of Contact Person: Dr. Stephen Johns, Co-Interim Assistant Superintendent

View Audit 358321 Questioned Costs: $1

Finding 564087 (2023-004)

None 2023

Sanford Housing Authority

NC

Questioned Costs HUD Housing Programs Subrecipient Monitoring

2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. ...

2023-004 Activities Allowed or Unallowed – Interprogram Activity Public and Indian Housing – CFDA Number 14.850 Other Matters, Questioned Costs Condition: The Authority has loaned monies from the Public and Indian Housing Program to the COCC. As of September 30, 2023 these loans totaled $349,352. Recommendation: The Authority should develop a plan based on budgeting and monitoring of COCC expenses to have the ability to reimburse funds to the Public and Indian Housing Program. Action Taken: To restore financial integrity and ensure proper use of COCC funds, the Authority will take the following actions: 1. COCC Optimization and Budget Reform: Develop and implement a proper, balanced COCC budget that reflects actual operating costs and allocates shared services appropriately. Establish budget accountability protocols, including monthly budget-to-actual reviews and variance reporting to the CFO, CEO, and Board. 2. Training and Capacity Building: Provide training for finance staff on COCC operations, HUD’s Asset Management model, and best practices for cost allocation and shared services. Engage external consultants to support financial modeling and long-term sustainability planning for RAD and LIHTC properties. 3. Shared Services Agreement: Formalize a Consulting and Shared Services Agreement to ensure that COCC services are appropriately billed and reimbursed by other programs. Monitor inter-program transactions to ensure compliance with HUD’s financial management requirements. 4. Salary Allocation and Cost Tracking: Conduct a salary allocation study to ensure that staff time is distributed adequately across programs. Implement time-tracking tools and cost allocation methodologies that align with HUD guidance and OMB Uniform Guidance. Effective Date: June 3, 2025 Contact Information Dr. Michael C. Threatt, Chief Executive Officer Sanford Housing Authority 317 Chatham Street Sanford, North Carolina 27330 (919) 776-7655

View Audit 358177 Questioned Costs: $1

Finding 563841 (2023-004)

Significant Deficiency 2023

Global Fund to End Modern Slavery

DC

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

2023-004 – Allowable Costs relating to Time and Effort and Internal Controls Management’s Corrective Action Plan: Management agrees with the Federal award finding identified in the audit. We acknowledge that a few timesheets and spreadsheets were missing from appropriate files during a two-month p...

2023-004 – Allowable Costs relating to Time and Effort and Internal Controls Management’s Corrective Action Plan: Management agrees with the Federal award finding identified in the audit. We acknowledge that a few timesheets and spreadsheets were missing from appropriate files during a two-month period of transition at the Fund, while maintaining that proper allocation process was followed up to the point of record keeping. The Fund understands the reasons for the missing timesheets and that these cases were unique and not indicative of the normal and prevalent internal control over the completion and approval of timesheets. The allocation of payroll for the months tested were based on the consistent and correct application of the payroll costs allocation methodology however in a limited number of cases the allocation spreadsheets weren’t properly saved. After announcement of dissolution, there was considerable staff turnover and rapid transition which created challenges and delays. We did maintain an effective control environment. This has been resolved. Management is saving allocation spreadsheets, and other required documentation as per policy on an ongoing basis.

View Audit 358064

Finding 563619 (2023-003)

Material Weakness 2023

Dallam Hartley Counties Hospital District

TX

Questioned Costs Allowable Costs / Cost Principles Cash Management

Contact Information: Sharon Hunt, Interim Chief Financial Officer, Dallam Hartley Counties Hospital District Audit Finding Reference Number: 2023-003 Planned Corrective Action: DHCHD has contracted with another payroll provider. Human Resources staff will work with the payroll provider to ensure th...

Contact Information: Sharon Hunt, Interim Chief Financial Officer, Dallam Hartley Counties Hospital District Audit Finding Reference Number: 2023-003 Planned Corrective Action: DHCHD has contracted with another payroll provider. Human Resources staff will work with the payroll provider to ensure that appropriate documentation regarding pay amounts and other essential payroll and personnel data is maintained on each employee. Anticipated Completion Date: Completed as of October 1, 2024

View Audit 357940 Questioned Costs: $1

Finding 563611 (2023-001)

Material Weakness 2023

Mental Health Resource of Texas, Inc.

TX

Questioned Costs Internal Control / Segregation of Duties Allowable Costs / Cost Principles

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update:...

I. VIA HOPE 2023 MANAGEMENT CORRECTIVE ACTION PLAN: ► BACKGROUND: CONTINUATION, ADDRESS MULTI-YEAR FRAUD: STRENGTHEN INTERNAL CONTROLS: Management and staff continue to work with the insurance carrier and local law enforcement agencies to restore funds and strengthen its internal controls. ► Update: History and Board Actions: In FY 2021, Via Hope experienced a significant loss of revenue due to the ending of contracts from its two primary funding streams – the Health and Human Services Commission and the Hogg Foundation for Mental Health. This loss of revenue resulted in the Board recommending and approving the reduction of staff and the departure of the CEO. In FY 2022, the Board recommended and approved the termination of its Accounts Manager and the former Board Chairman stepped in to voluntarily manage the finances until the organization could make other arrangements. The former chairman stepped down from his role and an election of officers was held to install a new Chair. By January 2022, with new revenue coming into the organization, the Board selected a new CEO and in December 2022, a new accounts manager was hired. Once the new accounts manager began reconciling the accounts, a pattern of questionable expenditures became evident with PayPal and other accounts. The CEO and staff informed the Board of what appeared to have happened and recognizing its fiduciary responsibility, the Board approved the engagement of a forensic audit by an external audit firm, The Wesley Peachtree Group (WPG) of Atlanta, Georgia. The forensic audit resulted in findings that fraudulent activity in the amount of $233,000 was likely to have occurred. As a result, the CEO was instructed to file an insurance claim with Frost Insurance. To process the claim, Frost required the involvement of law enforcement which was approved by the Board. Formal investigations were launched and remain ongoing with the Austin Police Department and the Travis County District Attorney's office. Recently, law enforcement met with the Board and provided an update on the investigation. Subsequently, the CEO was requested to follow up with the insurance carrier and state regulatory agencies to ensure the prompt receipt of its insurance claim from PayPal and other potential sources. II. FINDINGS AND RECOMMENDATIONS: Finding 2023-001 - Internal Control Deficiencies (Material Weakness) a) Time and Effort, Payroll and Human Resource Forms and Contracts - In response to the finding, Management will require monthly Time and Effort reports for each employee, develop new human resource forms, and update staff contracts at the beginning of the fiscal year. b) Drawdowns and Written Approvals - With the addition of the new Finance staff member in January 2025, management will initiate a written approval process. All payroll adjustments, drawdowns, credit card purchases, and payments will require invoices, receipts, and written approvals before payment is made. The Accounting Manager will also work with the CEO to ensure that staff provide receipts promptly and that journal entries are recorded on a monthly basis. c) Receipts, Written Approvals, PP&E Schedule - Receipts and written approvals were addressed in Response (C). While the organization maintains an equipment log, we will establish a formal Property, Plant, and Equipment Schedule (PP&E), particularly noting equipment purchased with federal funds. d) Segregation of Duties - Management has begun the process of interviewing qualified staff to segregate duties in the Finance office. This will ensure that one individual will no longer be responsible for handling funds, payments, reconciliations, and General Ledger (GL) postings. The individual will be in place by January 2025.

View Audit 357888 Questioned Costs: $1

Finding 562147 (2023-013)

Significant Deficiency 2023

Libson Regional School District

NH

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

2023-013 Document Policies and Procedures over Federal Awards (Significant Deficiency) Management’s Response: We do have policies and procedures for Federal Awards that need to be tweaked to assure the work is done as required. We will have this in place in the first part of 25-26. Name of Contact...

2023-013 Document Policies and Procedures over Federal Awards (Significant Deficiency) Management’s Response: We do have policies and procedures for Federal Awards that need to be tweaked to assure the work is done as required. We will have this in place in the first part of 25-26. Name of Contact Person and Completion Date: Toni Butterfield Anticipated Completion Date – 12/31/2025

View Audit 357779

Finding 561745 (2023-003)

Material Weakness 2023

Klawock Cooperative Association

AK

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

Klawock Cooperative Association has switched its contract accountant. They will work closely with management to close out the books and records timely including the accuracy and completeness of the Schedule of Federal Awards and be better rained in identifying, recording and administering funds that...

Klawock Cooperative Association has switched its contract accountant. They will work closely with management to close out the books and records timely including the accuracy and completeness of the Schedule of Federal Awards and be better rained in identifying, recording and administering funds that are provided directly to its subrecipients.

View Audit 357376

Finding 561431 (2023-004)

Material Weakness 2023

Community Resource Center, Inc.

CO

Questioned Costs Allowable Costs / Cost Principles Cash Management

As noted in the finding, the significant staff turnover and financial constraints during the audit period caused some disruption in our ability to provide the necessary documentation for certain transactions. In light of this, we have developed and implemented a corrective action plan to ensure full...

As noted in the finding, the significant staff turnover and financial constraints during the audit period caused some disruption in our ability to provide the necessary documentation for certain transactions. In light of this, we have developed and implemented a corrective action plan to ensure full compliance with 2 CFR 200, grant agreements, and cost principles going forward. 1. Strengthening Documentation Procedures: o Community Resource Center, Inc. has committed to implementing a process in which all transactions will be supported by actual invoices and all reimbursement requests will be submitted with corresponding supporting documentation. This will include both the original invoices and any other necessary backup materials. o Community Resource Center, Inc. is working with a financial consultant (start date on November 1, 2024), to audit and refine the financial systems, with particular emphasis on improving the accuracy and transparency of our documentation processes. The financial consultant will also assist in ensuring that all future costs align with the requirements of the funding agency and the OMB guidelines. 2. Review and Update of Internal Controls: o In response to the finding, Community Resource Center, Inc. has begun revising internal controls to ensure that adequate checks and balances are in place, especially in times of staff turnover. This includes designing more robust systems for tracking and documenting all costs related to grants, ensuring that all documentation is easily accessible for audit and review purposes. o A dedicated team will be assigned to monitor compliance with the internal control processes, and we will conduct regular internal reviews to verify that supporting documentation for all transactions is complete, timely, and accurate. 3. Contingency Planning for Staff Turnover: o Recognizing the impact of turnover, Community Resource Center, Inc. is formalizing a contingency plan for future staff changes. This plan will include clear guidance on the retention and transfer of all financial records, as well as designating backup staff with sufficient training and authority to oversee and maintain compliance with all financial requirements. We will also implement cross-training for key financial personnel to ensure continuity and consistency in the event of unexpected departures. 4. Ongoing Staff Training: o Community Resource Center, Inc. is committed to providing ongoing training to staff responsible for financial reporting and compliance. This will ensure that all staff involved in grant transactions understand the requirements set forth in 2 CFR 200 and other applicable regulations. Community Resource Center, Inc. will also work with the financial consultant to identify and address any skill gaps within the team. 5. Monitoring and Audit of Corrective Actions: o Community Resource Center, Inc. will establish regular internal monitoring and audits of these corrective actions to ensure they are being followed effectively. This will include periodic spot-checks of transaction documentation to ensure completeness and accuracy, as well as regular reviews of our internal controls and procedures to ensure their ongoing effectiveness.

View Audit 357014 Questioned Costs: $1

Finding 561278 (2023-003)

Significant Deficiency 2023

Housing Authority of the City of Renton

WA

HUD Housing Programs Allowable Costs / Cost Principles Eligibility

Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed...

Prior RHA administrative staff were not getting the PHA’s Single Audit completed nor submitted by the deadline. RHA was 3 years behind when the new CEO took over on March 31, 2023. FY2020, FY2021 and FY2022 were not completed and submitted. By the time that these three were caught up, completed and submitted, that pushed FY2023 Audit to be late. The audit for FY2023 should be completed by the end of April 2025 and then we will be on task to start FY2024 in May and completed by the deadline of September 30, 2025. Then, RHA will stay on task and get these completed within its deadline timeline.

View Audit 356918

Finding 561273 (2023-003)

Material Weakness 2023

Knott County Fiscal Court

KY

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.306 § 200.318 § 200.329

Prepared by: Kevin Jacobs Date Prepared: 7-3-24 Person Responsible for Corrective Action Plan: Kevin Jacobs Jeff Dobson Anticipated Completion Date: 7-3-24 Official's Response: To be clear the documents had to be presented to FEMA to get reimbursement, this was done. The Fiscal Court will ende...

Prepared by: Kevin Jacobs Date Prepared: 7-3-24 Person Responsible for Corrective Action Plan: Kevin Jacobs Jeff Dobson Anticipated Completion Date: 7-3-24 Official's Response: To be clear the documents had to be presented to FEMA to get reimbursement, this was done. The Fiscal Court will endeavor to make sure the FEMA files are updated and complete after FEMA reimbursement.

View Audit 356900 Questioned Costs: $1

Finding 561180 (2023-002)

Material Weakness 2023

The Association of State Wetland Managers, Inc. Dba National Association of Wetland Managers

ME

Allowable Costs / Cost Principles

Statement of Condition: Internal control weakness - documentation of approval over allowable costs could not be located for select expenses, and ineffective control procedures over posting of approved indirect cost rate allocation. Criteria: National Association of Wetland Managers’ internal control...

Statement of Condition: Internal control weakness - documentation of approval over allowable costs could not be located for select expenses, and ineffective control procedures over posting of approved indirect cost rate allocation. Criteria: National Association of Wetland Managers’ internal control policies and procedures, indirect cost negotiation agreement, and the Uniform Guidance. Cause: Procedures are in place requiring supervisory approval of documentation before costs are coded to grants, but procedures were not performed on all invoices. Also, ineffective control procedures over posting of indirect payroll cost allocation as indicated by compliance finding. Corrective Action Plan: Contact person: Marla Stelk, Executive Director Corrective action to be taken: NAWM does not believe that corrective action is required for this finding. NAWM has strong procedures in place requiring supervisory approval of documentation before costs are coded to grants. In some circumstances, invoices are emailed to the Executive Director, who approves them by giving instructions regarding payment over email. Email approvals are maintained as record of this internal control. In our digital world with the ability to work remotely, there are times when the Executive Director and Accounting Manager are not physically located in the same office space. However, this does not diminish the strength of our internal controls for review and approval of allowable costs. However, as recommended above, NAWM has hired a professional financial consultant to review our indirect cost accounting procedures, make recommendations to improve our processes, and assist in implementation of these recommendations. Anticipated completion date: End of current fiscal year (December 31, 2025)

View Audit 356793

Finding 561179 (2023-001)

None 2023

The Association of State Wetland Managers, Inc. Dba National Association of Wetland Managers

ME

Allowable Costs / Cost Principles

Statement of Condition: Compliance over allowable cost, including application of the indirect cost rate supplied by the United States Department of the Interior. Approved provisional rate of 26.3% not used. Instead, allocation based upon prior month’s payroll. Criteria: The Uniform Guidance, indirec...

Statement of Condition: Compliance over allowable cost, including application of the indirect cost rate supplied by the United States Department of the Interior. Approved provisional rate of 26.3% not used. Instead, allocation based upon prior month’s payroll. Criteria: The Uniform Guidance, indirect cost negotiation agreement, and National Association of Wetland Managers’ internal control policies and procedures. Cause: Management’s misunderstanding of accounting application of the provisional rate method. Corrective Action Plan: Contact person: Marla Stelk, Executive Director Corrective action to be taken: As noted above, NAWM provides the negotiated Indirect cost rates to the Funding Agency at the time when the project budget is developed. Subsequent billing of the indirect cost is based on the time spent on the project. Within six (6) months after year end, a final indirect cost rate proposal is submitted based on actual costs. Billings and charges to contracts and grants are adjusted if the final rate varies from the provisional rate. If the final rate is greater than the provisional rate and there are no funds available to cover the additional indirect costs, NAWM may not recover all indirect costs. Conversely, if the final rate is less than the provisional rate, NAWM is required to pay back the difference to the funding agency. However, as recommended above, NAWM has hired a professional financial consultant to review our indirect cost accounting procedures, make recommendations to improve our processes, and assist in implementation of these recommendations. Anticipated completion date: End of current fiscal year (December 31, 2025)

View Audit 356793

Finding 561098 (2023-005)

Significant Deficiency 2023

Public Health Institute of Metropolitan Chicago

IL

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Reporting § 200.430

Condition: We identified an instance in which a timesheet was not signed off by applicable supervisor and there was no evidence of review. In addition, another instance was identified in which a timesheet was not complete and was missing hours worked. Corrective Action Taken or Planned: Management ...

Condition: We identified an instance in which a timesheet was not signed off by applicable supervisor and there was no evidence of review. In addition, another instance was identified in which a timesheet was not complete and was missing hours worked. Corrective Action Taken or Planned: Management plans to reiterate the applicable policy and ensure timesheets are prepared, reviewed and contain the appropriate approvals. Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Karen Reitan, President and Chief Executive Officer Management Response: Management concurs with the finding.

View Audit 356735

Finding 561088 (2023-003)

Material Weakness 2023

Aid for Aids of Nevada

NV

Allowable Costs / Cost Principles § 200.303

2023-003 Internal Controls System Over Allowable Costs. – U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to main...

2023-003 Internal Controls System Over Allowable Costs. – U.S. Department of Housing and Urban Development, Housing Opportunities for Persons with AIDS, Assistance Listing Number 14.241, Passed Through the City of Las Vegas, Nevada. Criteria: As defined in 2 CFR 200.303, auditee is required to maintain a system of internal control over compliance designed to provide reasonable assurance that federal award transactions executed are in compliance with the terms and conditions of the federal award. Funds utilized under the Housing Opportunities for Persons with AIDS program are required to be expended on costs consistent with those outlined in 2 CRF 200 Subpart E – Cost Principles, and within the core service categories outlined in the grant agreement. Condition: Of the fourteen request for reimbursement (RFR) forms prepared and submitted to the grantor in order to receive reimbursement for expenditures during the year, seven were not reviewed and signed by the Executive Director. AFAN has designed a control such that a review of each RFR is performed to ensure expenditures are for allowable costs and allowable activities allowed for under the grant. However, this control was not performed consistently. Cause: The internal control system over the assessment of allowable costs was not operating effectively. A review of requests for reimbursement was either not performed or documentation was not maintained to support the appropriateness of expenses allocated to the grant. Context: Management failed to consistently perform an internal control to address the risk of improper expenses being reimbursed by the Organization’s grant. Effect: Not performing a review over the documents and allocations supporting requests for reimbursement for the grant increases the risk that inappropriate costs could be submitted for reimbursement which could be a violation of the terms of the federal grant agreement. Repeat Finding: No Recommendation: We recommend management design and implement a system of internal controls whereby a review of costs and the related supporting schedules being submitted for reimbursement are reviewed on a consistent basis and management ensures proper documentation of this review is maintained to support the performance of the control. Views of Responsible Officials and Planned Corrective Actions: Management will implement a control whereby the Executive Director will review and sign all requests for reimbursement prepared by the Finance Manager for submission. The Executive Director will ensure all backup is included and that all direct costs are approved and allowable prior to submission. Payroll related reimbursements will be reviewed to ensure the individuals included and allocation amongst grants are appropriate and the allocations agree to the final payroll records.

View Audit 356711

Finding 561086 (2023-001)

None 2023

Moses H Cone Memorial Hospital Operating Corporation, Inc.

NC

Questioned Costs Allowable Costs / Cost Principles

We have revised the calculation of the Paid Annual Leave award and verified that it uses the pay rates in effect at the time of the award for all employees. We confirmed that no other expenses for the COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (“Provider Relief F...

We have revised the calculation of the Paid Annual Leave award and verified that it uses the pay rates in effect at the time of the award for all employees. We confirmed that no other expenses for the COVID‐19 Provider Relief Fund and American Rescue Plan (ARP) Rural Distribution (“Provider Relief Fund”) reporting involved costs subject to similar point in time report parameters. The change to this cost item does not impact the full utilization of the Provider Relief Fund due to the presence of other expenses in the same category along with unreimbursed expenses and unused lost revenues remaining after the funds were exhausted. The discrepancy was due to imprecise instructions in the request for information. In the future, such ad hoc requests and the responsive reports will be verified by the Executive Director of Corporate Accounting before use.

View Audit 356706 Questioned Costs: $1

Corrective Action Plans

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