Corrective Action Plans

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

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 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

Special Tests & Provisions Allowable Costs / Cost Principles Eligibility

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

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 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 406910

Finding 1223544 (2025-001)

Material Weakness 2025

Vesta Thirteen, 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 406909

Finding 1223543 (2025-001)

Material Weakness 2025

Vesta Twelve, 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 406908

Finding 1223542 (2025-001)

Material Weakness 2025

Vesta Enteka, 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 406907

Finding 1223541 (2025-001)

Material Weakness 2025

Vesta Severn, 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 406906

Finding 1223540 (2025-002)

Material Weakness 2025

Vesta Forest, 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 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

Finding 1223536 (2025-001)

Material Weakness 2025

Vesta Pelden, 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 406902

Finding 1223535 (2025-001)

Material Weakness 2025

Vesta Four, 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 406901

Finding 1223534 (2025-001)

Material Weakness 2025

Vesta Three, 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 406900

Finding 1223532 (2025-001)

Material Weakness 2025

Vesta's Hearth, 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 406899

Finding 1223530 (2025-002)

Material Weakness 2025

Vesta Housing, 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 406898

Finding 1223529 (2025-003)

Material Weakness 2025

The Salvation Army Chicago City Fund

IL

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

Finding 2024‐002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Condition: For individuals charged to this program who also have time charged to other programs there were no timesheets or other evidence to support the allocation to the program was based on actual time incurre...

Finding 2024‐002: Allowable Costs/Cost Principles (Material Weakness and Noncompliance) Condition: For individuals charged to this program who also have time charged to other programs there were no timesheets or other evidence to support the allocation to the program was based on actual time incurred to the program but was instead based on the budgeted amounts for those individuals. Corrective Action Planned: Recommendation: Policies and procedures should be implemented to ensure that employee timekeeping and the salary and wage allocations to the federal award are appropriately documented and accurately reflect the level of effort of work performed. Objective: To establish an environment of internal controls and accountability within the Chicago Area Command Finance and Social Services teams specific to the following: Required Action: Ensure appropriate policies and procedures are created and implemented and that accurate documentation is in place to assume responsibility and accountability to meet or exceed expectations. Social Services - Implement and document a process for all individuals assigned to multiple contracts to keep time logs of hours worked on each, with a monthly review that the hours align with the budgeted amounts. In the event hours diverge, workload will be adjusted or a budget adjustment will be requested. Finance - Implement and document a process to conduct an internal spot check at least quarterly by selecting a sample of time sheets from various contracts to ensure that proper procedures and documentation have been implemented and tracked appropriately. Meet with Social Services at least quarterly to confirm time log status for all programs administered by Chicago City Fund. Anticipated Completion Date: August 31, 2026 Name of Contact Person Responsible for the Plan: Shari Koehler, Divisional Chief Finance and Technology Director

View Audit 406895

Finding 1223516 (2025-003)

Material Weakness 2025

Community Health & Social Services Center, Inc.

MI

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

2025-003 – Material Weakness and Material Noncompliance – Cash Management – Cash Request Recommendation We recommend that the organization implement and enforce policies and procedures, to ensure that all federal fund requests are supported by documented, allowable expenditures. Staff responsible fo...

2025-003 – Material Weakness and Material Noncompliance – Cash Management – Cash Request Recommendation We recommend that the organization implement and enforce policies and procedures, to ensure that all federal fund requests are supported by documented, allowable expenditures. Staff responsible for grant management should receive training in federal compliance requirements, and all reimbursement requests should be reviewed and approved by a qualified financial officer prior to submission. Action Taken CHASS management concurs with the audit findings and will put the following corrective action plan in place to mitigate this finding in the future: Implement separation of expenditures that are funded by grants will be recorded only related to that grant. Implementation of separating only revenue and expenditures to draw down grants will be reflected in general ledger for those grants. Implementation of grant 999 to reflect all other expenditures and revenues that are not covered by the grants. Staff will receive training in federal compliance requirements, and all reimbursement. Reconciliation of grants will be done at least once a quarter by grant clerk and will submit documentation of findings to CFO/ designated staff individuals. The CFO will only draw down funds when the general ledger supports the grant expenses. Monthly general ledgers will serve as backup documentation. CEO approval is required before any drawdown is completed. Responsible Parties: Feliz Valbuena, Chief Executive Office and Angela Salgado, Interim Chief Financial Officer

View Audit 406870

Finding 1223510 (2025-002)

Material Weakness 2025

El Paso County

CO

Student Financial Aid Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have be...

During the 2025 audit, the auditors discovered that a secondary review of eligibility determinations did not occur in a timely manner. The lack of internal control opened the possibility that an individual was incorrectly determined to be eligible to receive benefits and this error would not have been identified or corrected in a timely manner. Federal Regulations establish requirements for internal control over compliance with Federal program requirements. 2 CFR Section 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance the entity is managing the award in compliance with Federal statutes, regulations, and the terms and conditions of the award. These requirements include the design, implementation, and operation of control activities to ensure compliance with applicable compliance requirements, including eligibility. As eligibility is a key compliance requirement identified in the OMB Compliance Supplement, the County is required to implement a review process and system of internal controls that allows management or employees, in the normal course of performing their assigned functions, to prevent, or detect and correct, errors or noncompliance in eligibility determinations on a timely basis. The Department of Human Services (DHS) has implemented a monthly review process to audit a random sample of the IV-E cases. The review includes verification of timely and accurate determinations, client information, supporting documentation, and system entries, with results documented and approved by the reviewer. DHS Division leadership will monitor compliance to ensure the reviews are conducted each month. DHS believes this additional review procedure will provide the needed internal controls over IV-E determination.

View Audit 406864

Corrective Action Plans

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