Corrective Action Plans

Management will be requesting that all applicable funding sources allow the agency to utilize the fully forgiven PPP funds in accordance with the justification outlined above. Management asserts that the use of PPP funds was reasonable, necessary, and consistent

View Audit 414641

Finding 1240012 (2023-003)

Material Weakness 2023

MOBILE COMMUNITY ACTION, INC.

AL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

with maintaining organizational solvency during an unprecedented period of financial constraint.

View Audit 414641

Finding 1237750 (2023-010)

Material Weakness 2023

Fremont County School District No. 21

WY

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

2023-010 Reporting - Title I, Impact Aid and ESSER Grants - Repeat Finding Individual responsible: Business Manager and Federal Grants Director Anticipated completion date: FY 2026 Corrective action plan: At this point in time the ESSER funds are no longer available, so there will not be any other d...

2023-010 Reporting - Title I, Impact Aid and ESSER Grants - Repeat Finding Individual responsible: Business Manager and Federal Grants Director Anticipated completion date: FY 2026 Corrective action plan: At this point in time the ESSER funds are no longer available, so there will not be any other documentation going forward. However, with other grants the processes have changed. Since FY 2022 an accounting firm was hired to catch the school district up on grant requests. This accountant requested funds on a quarterly basis. On July 1, 2025, the District hired a Federal Grants director to work with the Business Manager to complete the grant catch up process and to create a system that documents each expenditure and timing of the requests. Once the system is in place cash requests will be completed monthly.

View Audit 412646

Finding 1237749 (2023-009)

Material Weakness 2023

Fremont County School District No. 21

WY

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

2023-009 Unsupported Expenditures - Title I, Impact Aid, and ESSER Grants - Repeat Finding Individual responsible: Business Manger and Federal Grants Director Anticipated completion date: FY 2026 Corrective action plan: The District acknowledges the deficiencies in documentation and reporting for fe...

2023-009 Unsupported Expenditures - Title I, Impact Aid, and ESSER Grants - Repeat Finding Individual responsible: Business Manger and Federal Grants Director Anticipated completion date: FY 2026 Corrective action plan: The District acknowledges the deficiencies in documentation and reporting for federal grant expenditures. At this time, ESSER funds are no longer available; therefore, additional supporting documentation for those programs will not be developed. However, the District has implemented corrective actions to imporve processes over other federal programs going forward. Since fiscal year 2022, the District engaged an external accounting firm to assist with grant reporting and cash request processes. This firm implemented a process to request funds on a quarterly basis and assisted in organizing available grant information. Effective July 1, 2025, the District hired a Federal Grants Director to work in cordination with the Business Manager to complete the grant reconciliation process and implement formal procedures for tracking grant expenditures and cash requests. These procedures include maintaining documentation for each expenditure, tracking the timing and support for drawdowns, and ensuring that all activity is properly recorded and supported. Upon full implementation of these procedures, the Distirct will transition to submitting cash requests on a monthly basis and maintaining complete and accessible documentation to support all reported amounts. The District expects these improvements to resolve the finding for current and future federal programs.

View Audit 412646

Finding 1237736 (2023-005)

Material Weakness 2023

Ka Mana O Na Helu

HI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.403

Material Weakness Finding No. 2023-005: Allowable Costs/Cost Principles U.S. Department of Housing and Urban Development Passed Through the State of Hawaii Department of Human Services Emergency Solutions Grant Program Coronavirus Federal Assistance Listing Number 14.231 Criteria Pursuant to the Uni...

Material Weakness Finding No. 2023-005: Allowable Costs/Cost Principles U.S. Department of Housing and Urban Development Passed Through the State of Hawaii Department of Human Services Emergency Solutions Grant Program Coronavirus Federal Assistance Listing Number 14.231 Criteria Pursuant to the Uniform Guidance, 2 CFR 200.403, Allowable Costs, costs must be necessary, reasonable, and adequately documented to be allowable under federal awards. Futhermore, 2 CFR, 200.303 states that the non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the award in compliance with federal statutes and regulations. Condition We noted that during 2023, KMNH’s chief executive officer performed accounting functions including recording cash disbursement transactions and reconciliation of the monthly bank statement balances to the cash balances in the general ledger. In addition, there was no evidence of a supervisory review of supporting documentation for expenditures. Cause Due to the limited number of employees, there is not only a lack of consistent supervisory review of supporting documentation of expenditures, but also a lack of segregation of duties to ensure that disbursement transactions are accurately recorded and are compliant with the Uniform Guidance allowable costs/cost principles. Effect Without proper segregation of duties and supervisory review of supporting documentation of expenditures, there is a reasonable possibility that a material misstatement of KMNH’s expenditures of federal awards will not be prevented or detected and corrected on a timely basis. Recommendation We recommend that KMNH engage an accountant to provide relevant services and to implement a supervisory review process of supporting documentation of expenditures and to develop appropriate policies and procedures to ensure proper segregation of duties. Corrective Action Responsible Party: Director of Operations KMNH agrees with the finding and recommendation and will continue its efforts to hire a bookkeeper.

View Audit 412644

Finding 1236790 (2023-016)

Material Weakness 2023

US Helping Us, People Into Living, Inc.

DC

Reporting Allowable Costs / Cost Principles

o Calculate provisional indirect costs monthly. o Perform year-end indirect cost reconciliation. o Record true-up adjustments before financial statements are finalized. o Review indirect cost calculations prior to submitting federal reports. o Maintain documentation supporting all indirect cost calc...

o Calculate provisional indirect costs monthly. o Perform year-end indirect cost reconciliation. o Record true-up adjustments before financial statements are finalized. o Review indirect cost calculations prior to submitting federal reports. o Maintain documentation supporting all indirect cost calculations.

View Audit 412274

Finding 1236769 (2023-013)

Material Weakness 2023

US Helping Us, People Into Living, Inc.

DC

Allowable Costs / Cost Principles

o Require employees whose salaries are allocated to multiple funding sources to complete periodic certifications. o Maintain documentation supporting actual work performed. o Review payroll allocations regularly to ensure costs charged to federal awards are accurate. o Require management review and ...

o Require employees whose salaries are allocated to multiple funding sources to complete periodic certifications. o Maintain documentation supporting actual work performed. o Review payroll allocations regularly to ensure costs charged to federal awards are accurate. o Require management review and approval of payroll allocations. o Maintain supporting documentation for payroll charges to federal awards. o Provide training regarding time and effort reporting requirements.

View Audit 412274

Finding 1236741 (2023-010)

Material Weakness 2023

US Helping Us, People Into Living, Inc.

DC

Allowable Costs / Cost Principles Cash Management Reporting

o Establish formal procedures for the preparation, review, and approval of federal drawdown requests. o Require drawdowns to be supported by documented eligible expenditures. o Require management review and approval of drawdown requests prior to submission. o Reconcile drawdown requests to expenditu...

o Establish formal procedures for the preparation, review, and approval of federal drawdown requests. o Require drawdowns to be supported by documented eligible expenditures. o Require management review and approval of drawdown requests prior to submission. o Reconcile drawdown requests to expenditures and accounting records. o Maintain documentation supporting drawdown calculations and approvals. Periodically review cash management practices for compliance with federal requirements.

View Audit 412274

Finding 1236732 (2023-009)

Material Weakness 2023

US Helping Us, People Into Living, Inc.

DC

Allowable Costs / Cost Principles Reporting

o Implement grant-specific tracking within the accounting system. o Establish separate project codes for each federal award. o Perform monthly reconciliations between grant expenditures, reimbursement requests, and accounting records. o Review grant activity regularly to ensure expenditures are accu...

o Implement grant-specific tracking within the accounting system. o Establish separate project codes for each federal award. o Perform monthly reconciliations between grant expenditures, reimbursement requests, and accounting records. o Review grant activity regularly to ensure expenditures are accurately recorded and reported. o Maintain supporting documentation for all expenditures charged to federal awards. o Conduct periodic management reviews to ensure compliance with federal reporting requirements.

View Audit 412274

Finding 1236692 (2023-003)

Material Weakness 2023

Little Rock Workforce Development Board

AR

Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.403 § 200.405 § 200.414

Finding #2023-003: Management has not established a written cost allocation plan or policy as required by Uniform Guidance. Specifically, the Organization lacks documented procedures that define direct and indirect costs, describe how costs will be identified and classified, outline the methodology ...

Finding #2023-003: Management has not established a written cost allocation plan or policy as required by Uniform Guidance. Specifically, the Organization lacks documented procedures that define direct and indirect costs, describe how costs will be identified and classified, outline the methodology used to allocate indirect costs among active federal awards, and address the application of the 10% de minimis indirect cost rate. As a result, there is no formal framework to support the consistent allocation of costs to federal programs or to demonstrate compliance with federal requirements. Response: Management acknowledges and accepts the finding and recommendation. Management will work to ensure a proper written cost allocation policy as required by the Uniform Guidance is established by December 31, 2026.

View Audit 412237

Finding 1236689 (2023-001)

Material Weakness 2023

Little Rock Workforce Development Board

AR

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.331

Finding #2023-001: Management is responsible for ensuring compliance with certain provisions of laws, regulations, contracts, and grant agreements. An ongoing investigation by a state agency on the WIOA program for the 2020, 2021 and 2022 program years has alleged the Organization operated without a...

Finding #2023-001: Management is responsible for ensuring compliance with certain provisions of laws, regulations, contracts, and grant agreements. An ongoing investigation by a state agency on the WIOA program for the 2020, 2021 and 2022 program years has alleged the Organization operated without a legally binding agreement for operator services for more than 10 months after the expiration of the previous contract. In addition, there was not sufficient documentation to support the allocation basis of certain expenditures charged to WIOA. Response: Management acknowledges and accepts the finding and recommendation. Management will work to ensure proper policies and procedures are established and followed to ensure future reporting under the appropriate guidance by December 31, 2026.

View Audit 412237

Finding 1236575 (2023-002)

Material Weakness 2023

COVATION CENTER INC

PA

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

Incomplete Documentation – Material Weakness Condition: During testing of the Center's activities, one (1) of the nine (9) disbursements selected for testing did not have an application checklist that was reviewed and approved prior to awarding and disbursement of funds. Corrective Action Planned: T...

Incomplete Documentation – Material Weakness Condition: During testing of the Center's activities, one (1) of the nine (9) disbursements selected for testing did not have an application checklist that was reviewed and approved prior to awarding and disbursement of funds. Corrective Action Planned: The Center will implement a standardized pre-disbursement checklist for all award applications, requiring that the checklist be fully completed, reviewed, and signed by an authorized reviewer before any funds are awarded or disbursed. No disbursement will be processed without a completed checklist on file. This step will be incorporated into the Center's written internal control procedures. Name(s) of Contact Person(s) Responsible for Corrective Action: Kendy Alvarez, Grant Program Manager; Stephanie Desaulniers, Executive Director Anticipated Completion Date: December 31, 2026

View Audit 412125

Finding 1229969 (2023-003)

Material Weakness 2023

Northwoods Stewardship Center

VT

Allowable Costs / Cost Principles § 200.430

View of responsible officials and planned corrective action: NorthWoods management will train Program Directors to add a USFW code to their current time sheet tracking for all USFWS activities in September 2025. This will be reviewed regularly in current time sheet review procedures for accuracy. Se...

View of responsible officials and planned corrective action: NorthWoods management will train Program Directors to add a USFW code to their current time sheet tracking for all USFWS activities in September 2025. This will be reviewed regularly in current time sheet review procedures for accuracy. Semi-annually, program director match contributions will be reconciled from time sheet reports with the general ledger for USFW agreements by the Business Manager, and reviewed by the Program Directors. Northwoods management will obtain a review of matching contributions documentation procedures from a qualified non-profit accountant.

View Audit 411190

Finding 1229677 (2023-013)

Material Weakness 2023

Municipality of Anchorage, Alaska

AK

Allowable Costs / Cost Principles § 200.303

Allowable Costs – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The Municipality has begun implementing enhanced grant compliance review procedures to ensure expenditures are allowable, adequately supported, and incurred within the applicable pe...

Allowable Costs – Noncompliance and Significant Deficiency in Internal Control Over Compliance Corrective Action Plan: The Municipality has begun implementing enhanced grant compliance review procedures to ensure expenditures are allowable, adequately supported, and incurred within the applicable period of performance. Standardized documentation, supervisory review, and monitoring procedures will be incorporated into routine grant administration. Management will evaluate the effectiveness of these controls through completion of a full audit cycle. Anticipated Completion Date June 30, 2027

View Audit 410871

Finding 1229423 (2023-002)

Material Weakness 2023

Neighborhoods, Inc. of Battle Creek

MI

Allowable Costs / Cost Principles Material Weakness Reporting

Finding 2023-002: Internal Control Over Financial Reporting – Internal Control Evidence Management’s Response Now that disbursements are 100% in-house, the President & CEO provides final written approval on all timecards and payables. Chairman of the Loan & Finance Committee remotely reviews journal...

Finding 2023-002: Internal Control Over Financial Reporting – Internal Control Evidence Management’s Response Now that disbursements are 100% in-house, the President & CEO provides final written approval on all timecards and payables. Chairman of the Loan & Finance Committee remotely reviews journal entries in accounting software monthly. Contact Person Responsible for Corrective Action: Whitney Wardell Anticipated Completion Date: 7/1/2024

View Audit 410819

Finding 1229212 (2023-003)

Material Weakness 2023

City of Jacksonville Arkansas

AR

Allowable Costs / Cost Principles § 200.430

Finding #2023-003 – Statement of Condition: During our testing of payroll costs charged to ALN 97.036, we identified one instance in which employee's payroll cost was calculated using an incorrect pay rate. As a result, the payroll expenditure charged to the federal program was overstated. Response:...

Finding #2023-003 – Statement of Condition: During our testing of payroll costs charged to ALN 97.036, we identified one instance in which employee's payroll cost was calculated using an incorrect pay rate. As a result, the payroll expenditure charged to the federal program was overstated. Response: Management concurs with the finding and will enhance its payroll review procedures to verify that payroll costs charged to federal awards are calculated using the correct authorized pay rates. The matter was corrected by December 31, 2024

View Audit 410701

Finding 1229118 (2023-004)

Material Weakness 2023

YWCA Dayton

OH

Allowable Costs / Cost Principles Special Tests & Provisions

The organization is in the process of updating its policies to outline the required documentation on the rent reasonableness forms and the documentation retention requirements for the rent reasonableness forms.

View Audit 410608

Finding 1229114 (2023-002)

Material Weakness 2023

YWCA Dayton

OH

Allowable Costs / Cost Principles Eligibility

The organization is in the process of updating its policies to outline the required documentation on the intake forms and the documentation retention requirements for the intake forms.

View Audit 410608

Finding 1228735 (2023-005)

Material Weakness 2023

Activate Work Inc.

CO

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.308

Action Taken in Response to Finding: Budget-to-actual comparisons began in 2024 and were subsequently standardized and incorporated into Financial Policies and Procedures. As of 2026, budget-to-actual comparisons are performed on a monthly basis as part of the month-end (EOM) close, prior to the pre...

Action Taken in Response to Finding: Budget-to-actual comparisons began in 2024 and were subsequently standardized and incorporated into Financial Policies and Procedures. As of 2026, budget-to-actual comparisons are performed on a monthly basis as part of the month-end (EOM) close, prior to the preparation and submission of Federal reimbursement requests. This ensures that: • Expenditures are reviewed against approved grant budgets prior to reimbursement • Variances are identified and evaluated • Costs charged to Federal awards align with approved budgets and allowable use requirements Additionally, Budget and Program Revisions and Allowable Use of Funds policies were incorporated into the Financial Policies and Procedures to formalize requirements for budget compliance and modification. Control Enhancement: A standardized budget-to-actual review has been implemented across all applicable Federal awards. This process: • Compares actual expenditures to approved grant budgets on a monthly basis • Identifies variances requiring review or correction • Ensures expenditures are aligned with budget categories and allowable cost requirements • Requires budget review prior to submission of reimbursement requests Monitoring & Review: • Budget-to-actual comparisons are performed monthly as part of EOM close • Initial review is completed by Finance • Secondary review is performed by the Director of Finance & Operations • Program staff are engaged as needed to validate alignment with program activities • Any required budget modifications are identified and addressed prior to reimbursement Testing & Validation: • Beginning in June 2026, quarterly internal reviews will be conducted to validate that budget monitoring controls are operating effectively • Testing will confirm that: o Budget-to-actual reviews are completed consistently o Variances are appropriately identified and addressed o Reimbursements align with approved budgets Documentation & Evidence: • Budget-to-actual reports maintained in Teams / Sharepoint • Supporting documentation for budget revisions retained • Approval and review evidenced via email/workflow/sign-off Control Owner(s): • Director of Finance & Operations • Finance Team Responsible Party: Director of Finance & Operations, with executive oversight by the Chief Executive Officer Anticipated Completion Date: All corrective actions will be implemented by June 30, 2026. Ongoing monthly monitoring and quarterly validation will continue. Status: • Budget-to-actual comparisons (limited): Implemented 2024 • Standardized monthly workflow (EOM close): Implemented April 2026 • Policy integration into Financial Policies and Procedures: Completed May 2026 • Quarterly internal reviews will be conducted to validate that budget monitoring controls are operating effectively: June 2026

View Audit 410398

Finding 1228734 (2023-004)

Material Weakness 2023

Activate Work Inc.

CO

Allowable Costs / Cost Principles Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.307 § 200.403

Action Taken in Response to Finding: Financial practices addressing program income were in place; however, processes were formalized to ensure full compliance with 2 CFR §200.307. ActivateWork developed and implemented a Program Income Policy as part of its Financial Policies and Procedures, adopted...

Action Taken in Response to Finding: Financial practices addressing program income were in place; however, processes were formalized to ensure full compliance with 2 CFR §200.307. ActivateWork developed and implemented a Program Income Policy as part of its Financial Policies and Procedures, adopted May 2026. As of March 2026, a standardized program income tracking and reconciliation is performed monthly as part of the month-end (EOM) close. This process includes: • Identification and tracking of program income by funding source • Application of program income to actual allowable expenses • Mapping of Federal reimbursement requests to underlying expenses to ensure program income is applied prior to reimbursement • Validation that no duplication of funding occurs between program income and Federal reimbursements These enhancements establish a structured and auditable framework for program income tracking, application, and compliance. Control Enhancement: Program income is tracked and recorded within a standardized Excel-based tool (Program Income vs. Unreimbursed Cost Analysis) and applied in accordance with federal requirements. A standardized program income tracker: • Applies program income to actual expenses • Links expenses to reimbursement requests • Ensures program income is fully utilized prior to requesting Federal reimbursement, unless otherwise specified by award terms • Prevents duplication of income and reimbursement Monitoring & Review: • Program income tracking is reviewed monthly as part of the EOM close process • Review is performed by the Senior Accountant • A secondary review is performed by the Director of Finance & Operations to validate completeness and compliance • Any discrepancies are identified and resolved prior to reimbursement submission Testing & Validation: • Beginning in June 2026, quarterly internal reviews will be conducted to validate program income tracking and application • Testing will confirm that: o Program income is accurately recorded o Program income is applied prior to reimbursement o No duplication of funding exists • Results will be documented and tracked for remediation Documentation & Evidence: • Program income tracker maintained in Teams / SharePoint • Supporting documentation tied to underlying expenses Control Owner(s): • Director of Finance & Operations • Finance Team Responsible Party: Helen Young Hayes, Founder / Chief Executive Officer, in coordination with the Director of Finance & Operations and Finance Staff Anticipated Completion Date: All corrective actions will be implemented by June 30, 2026. Ongoing monthly monitoring, reconciliation, and quarterly validation will continue. Status: • Program Income Policy: Implemented May 2026 • Program income tracking process: Implemented April 2026 • Monthly reconciliation and application (EOM Close): Implemented May 2026 • Quarterly internal reviews will be conducted to validate program income tracking and application: June 2026.

View Audit 410398

Corrective Action Plans

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