Corrective Action Plans

Finding 561829 (2024-005)

None 2024

PR

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.112 § 200.334 § 200.430

As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Establish clear guidelines for the creation, storage, access, updating, and disposal of records. b. Define retention periods in accordance with legal requirements. c. Develop periodic m...

As a corrective measure, BGCPR will take the following actions and will anticipate completing on June 30, 2025: a. Establish clear guidelines for the creation, storage, access, updating, and disposal of records. b. Define retention periods in accordance with legal requirements. c. Develop periodic monitoring procedures to verify record completeness and compliance. d. Implement scheduled internal reviews and standardized checklists. e. Assign specific responsibilities to Human Resources personnel for policy enforcement.

View Audit 357482

Finding 561786 (2024-001)

Material Weakness 2024

Boys & Girls Clubs of Benton and Franklin Counties

WA

Allowable Costs / Cost Principles Material Weakness

Federal grants will be recorded in Paycom (our payroll software) showing hours worked on a specific grant (with staff clocking in/out based on time worked) rather than adjustments made to the GL.

View Audit 357442

Finding 561760 (2024-002)

Significant Deficiency 2024

Altarum Institute and Subsidiaries

MI

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

2024-002 – Indirect Costs Auditor Description of Condition and Effect. During our testing of indirect cost rates we observed that overhead was included in the Institute's indirect cost rate reimbursement calculation for one out of the Institute's three indirect cost calculations (the general and adm...

2024-002 – Indirect Costs Auditor Description of Condition and Effect. During our testing of indirect cost rates we observed that overhead was included in the Institute's indirect cost rate reimbursement calculation for one out of the Institute's three indirect cost calculations (the general and administrative calculation). As a result of this condition, the Institute did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Institute review its policies and procedures in regard to the review of the calculation of indirect costs reimbursement to ensure that it conforms with the approved indirect cost rate and all provisions of the indirect cost rate approved by the Institute's cognizant agency. Corrective Action. Altarum’s indirect rate agreement with the Federal government is a provisional rate agreement, meaning the rates and their bases are not yet finalized. Under FAR Subpart 42.7, Altarum has the flexibility to propose the rates, and their bases provided we comply with the FAR. The following FAR clauses address flexibility:  Indirect Cost Rates: Under FAR 42.703-1, companies must accumulate indirect costs in logical groupings and allocate them using a base that reflects the benefits accruing to cost objectives. This ensures fairness and consistency in cost allocation.  Flexibility: FAR Subpart 42.7 provides flexibility in cost allocation methods, particularly under FAR 42.705 (Final Indirect Cost Rates). This section allows companies to adjust indirect cost allocation methods in response to significant changes in business operations or other relevant circumstances.  Certification: The requirement for contractors to certify their indirect cost proposals is detailed in FAR 42.703-2 (Certificate of Indirect Costs). This ensures compliance with applicable regulations and establishes the validity of the cost proposals. In June 2024, Altarum submitted a certified indirect rate proposal utilizing the total cost input method, excluding subrecipients over $25,000, as the base for our general and administrative (G&A) cost pool. This base was chosen to reflect the benefits accruing to those cost objectives. The accompanying proposed rate Altarum submitted reflected this calculation. Our provisional G&A rate was approved at the percentage that included overhead in our G&A base. However, the narrative in our provisional nonprofit rate agreement did not accurately reflect our proposal, as it inadvertently included the term "total direct costs" when describing the base for the G&A rate. For the fiscal year 2024, Altarum incorporated overhead costs into the base of the associated general and administrative cost rate as certified in our proposal to the Federal government in June 2024. To address the discrepancy between the provisional rate agreement, our proposal, and our system, we sought guidance from our cognizant agent at US Department of Health and Human Services (HHS). In discussions, Altarum was advised to update the allocation base as part of our next proposal package submission, June 2025. Additionally, we were advised that the reviewer from HHS will update the allocation base when finalizing the indirect cost rates for fiscal year 2024. Altarum will follow the advice of HHS and resolve the discrepancies in the rate agreement later this year. Responsible Person. Denise Sturm Anticipated Completion Date. 6/30/2025 – submissions to Federal government; final resolution subject to DHHS's review of our submissions.

View Audit 357424 Questioned Costs: $1

Finding 561753 (2024-005)

Significant Deficiency 2024

Change Happens!

TX

Allowable Costs / Cost Principles Special Tests & Provisions HUD Housing Programs

Finding #2024-005 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract...

Finding #2024-005 – Significant Deficiency and Other Noncompliance. Applicable federal program: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract year: 07/01/23 – 06/30/24, Contract #5NU62PS924649-04-00, Contract year: 07/01/24 – 06/30/25. Condition and context: During our testing of 40 client case files, we noted one HIV positive client where there was no documentation of declined referrals sent to Disease Intervention Specialists. Recommendation: Re-emphasize procedures to ensure proper retention of referral documentation. Planned corrective action: The HIV/Wellness program previously contracted an external health professional to review positive files for quality management. The program temporarily transitioned between health professionals to support the need for more frequent reviews. Steps missed by internal staff were identified but were not identified during the quality management transition as timely reviews were not conducted. Program leadership has taken action to review policies and procedures to include HIV positive client support timelines. An additional procedure has been added which requires faxing client forms to local health department using secure steps provided by the local health department. Faxed forms are placed in client file and will serve as proof of referral and date referred. An additional review of files for proper documentation has been added and will be performed by medical student interns. Responsible officer: Kelva Clay, CPO. Estimated completion date: Completed.

View Audit 357417

Finding 561752 (2024-004)

Significant Deficiency 2024

Change Happens!

TX

Questioned Costs Allowable Costs / Cost Principles Period of Performance

Finding #2024-004 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contrac...

Finding #2024-004 – Significant Deficiency and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract year: 07/01/23 – 06/30/24, Contract #5NU62PS924649-04-00, Contract year: 07/01/24 – 06/30/25. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-03-03, Contract year: 08/27/23 – 08/26/24, Contract #NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Children’s Health Insurance Program, Assistance Listing #93.767, Contract #2Y2CMS331859-02-05, Contract year: 07/01/23 – 06/30/25. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPS, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPU, Contract year: 09/01/23 – 08/31/24. Condition and context: During our testing of payroll, non-payroll and indirect cost pool transactions, we identified the following exceptions: Controls over allowable cost compliance – all major programs. In a sample of 59 non-payroll transactions tested for internal controls over compliance: One instance of annual advertising contract charged in full rather than establishing a prepaid expense for the eleven months after Civic Heart’s year-end of August 31, 2024. The applicable grant period is July 1, 2023 through June 30, 2025 and thus, only one month, or approximately $417, was outside the period of performance (AL #93.767 Children’s Health Insurance Program). One instance of $2,700 charged to wrong program. Allowable costs of the Navigator program were charged to Connecting Kids program due to coding to the wrong class code in the general ledger. (AL#93.767 Children’s Health Insurance Program (Connecting Kids). In a sample of 135 payroll transactions tested for internal controls over compliance: Four instances of errors in the amount of costs charged to class code due to a clerical error in the payroll allocation spreadsheet. (AL #93.959 Block Grants for Prevention and Treatment of Substance Abuse and AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based). Other non-compliance: AL #93.767 Children’s Health Insurance Program: In a sample of 40 payroll or vendor charges, one instance of non-compliance with allowable cost compliance ($417). AL #93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges: In a sample of 42 payroll or vendor charges, one instance of non-compliance with allowable cost compliance ($2,700). AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based: In a sample of 40 payroll or vendor charges, two instances of non-compliance with allowable costs due to charge to the wrong program. Controls over period of performance – all major programs. In a sample of 56 vendor transactions and 4 pay periods with grant beginning or ending dates during the audit period, we found: 13 instances of charging vendor costs to the wrong grant period. One instance of charging payroll costs to the wrong grant period. Other non-compliance: AL #93.332 Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges: In a sample of 14 vendor charges tested, we found 4 exceptions for charging to the wrong grant period (approximately $3,120). AL #93.939 HIV Prevention Activities Non-Governmental Organizational Based. In a sample of 27 vendor charges tested, we found 4 exceptions for charging to the wrong grant period (approximately $480). In a sample of four pay periods tested, we found one exception for charging costs to the wrong grant period (approximately $5,350). AL# 93.959 Block Grants for Prevention and Treatment of Substance Abuse. In a sample of 25 vendor charges tested, we found 5 exceptions for charging to the wrong grant period (approximately $660). Recommendation: Emphasize adherence to established policies and procedures to ensure maintenance of payroll spreadsheets and reviews of coding for all transactions. Planned corrective action: Adherence to established policies and procedures will be strengthened by providing additional training when onboarding accounting staff, as well as additional oversight to the disbursement and payroll process. New accounting staff will be more thoroughly trained on established policies and procedures, including accruals, proper financial statement period recognition, grant award period of performance, tracking of grant activities using class codes, and allowable cost requirements. In addition, the CFO will ensure sufficient time is dedicated to reconciling payroll spreadsheets, payroll allocations, period of performance, and payroll accruals. Salaries and wages charged to the grant are now based on actual work performed determined by hours submitted by employee and approved by the applicable supervisor; this new control should assist in mitigating posting errors related to incorrect grants and grant periods. Responsible officer: Angelica Castillo, CFO. Estimated completion date: June 30, 2025.

View Audit 357417 Questioned Costs: $1

Finding 561751 (2024-003)

Material Weakness 2024

Change Happens!

TX

Allowable Costs / Cost Principles

Finding #2024-003 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract yea...

Finding #2024-003 – Material Weakness and Other Noncompliance. Applicable federal programs: U. S. Department of Health and Human Services, Direct Federal Funding, HIV Prevention Activities Non-Governmental Organizational Based, Assistance Listing #93.939, Contract #6NU62PS924649-03-03, Contract year: 07/01/23 – 06/30/24, Contract #5NU62PS924649-04-00, Contract year: 07/01/24 – 06/30/25. U. S. Department of Health and Human Services, Direct Federal Funding, Cooperative Agreement to Support Navigators in Federally-Facilitated Exchanges, Assistance Listing #93.332, Contract #NAVCA210403-03-03, Contract year: 08/27/23 – 08/26/24, Contract #NAVCA240482-01-00, Contract year: 08/27/24 – 08/26/25. U. S. Department of Health and Human Services, Direct Federal Funding, Children’s Health Insurance Program, Assistance Listing #93.767, Contract #2Y2CMS331859-02-05, Contract year: 07/01/23 – 06/30/25. U. S. Department of Health and Human Services, Passed through Texas Health and Human Services Commission, Block Grants for Prevention and Treatment of Substance Abuse, Assistance Listing #93.959, Contract #HHS000539700204 YPI, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPS, Contract year: 09/01/23 – 08/31/24, Contract #HHS000539700204 YPU, Contract year: 09/01/23 – 08/31/24. Condition and context: Time and effort reporting is based on the amount reflected in the budget rather than actual time spent on the program. Additionally, the allocation of certain shared costs are impacted as they are charged to the program based on the direct salary percentages. Repeat of finding #2023-001. Recommendation: Provide training to ensure that salaries and wages charged to federal programs are supported by personnel activity reports based on actual time worked. Planned corrective action: Management implemented new controls and procedures in June 2024 to fully comply with time and effort reporting as required by Uniform Guidance. Salaries and wages charged to the grant are now based on actual work performed determined by hours submitted by employee and approved by the applicable supervisor. Policies and procedures have been updated to include this required process to ensure that the allocation methodology used to allocate costs between programs reflect the actual relative benefit to the grant. Responsible officer: Angelica Castillo, CFO. Estimated completion date: Completed.

View Audit 357417

Finding 561686 (2024-004)

Material Weakness 2024

Wilsona School District

CA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.439

Corrective Action Plan and Views of Responsible Officials The project was identified in District plans and executed immediately prior to the change in administrative leadership. After review it was noticed that prior capital approval was not obtained prior execution of the project. Applications were...

Corrective Action Plan and Views of Responsible Officials The project was identified in District plans and executed immediately prior to the change in administrative leadership. After review it was noticed that prior capital approval was not obtained prior execution of the project. Applications were subsequently submitted and under review by the CDE at the time of this report preparation. The District acknowledges and has provided professional development with staff, so all are aware of dealing with items that are obtained with federal funds. Pending final answer regarding the prior approval by the CDE will determine the next action of the District.

View Audit 357316 Questioned Costs: $1

Finding 561678 (2024-003)

Significant Deficiency 2024

Jericho Road Ministries D/b/a Jericho Road Community Health Center

NY

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

During the fiscal year June 30, 2025, the finance department and purchasing department led by Veronica Koller, CFO will work together to revise the current procurement policy to ensure it complies with Uniform Guidance.

View Audit 357305

Finding 561663 (2024-002)

Material Weakness 2024

Marysville School District No. 25

WA

Allowable Costs / Cost Principles Subrecipient Monitoring

The district understands the importance of internal controls regarding time and effort reporting using federal funds. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI time and effort requirements. The Executive Director of Finance & Opera...

The district understands the importance of internal controls regarding time and effort reporting using federal funds. The district has implemented stronger internal controls in order to reconcile and comply with federal and OSPI time and effort requirements. The Executive Director of Finance & Operations will review Time & Effort required to ensure accuracy. Anticipated date to complete the corrective action: 08/31/2025

View Audit 357294

Finding 561662 (2024-001)

Significant Deficiency 2024

Capital Region Transportation Planning Agency

FL

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

The City of Tallahassee is committed to ensuring compliance with all grant requirements associated with the awards received from both Federal and State of Florida partners. The City was awarded $15 million from the Federal Transit Authority and $1 million from the State of Florida for the construc...

The City of Tallahassee is committed to ensuring compliance with all grant requirements associated with the awards received from both Federal and State of Florida partners. The City was awarded $15 million from the Federal Transit Authority and $1 million from the State of Florida for the construction of the Southside Transit Center (STC). An additional $4 million was included from local sources. The issue noted came to light when the State directed City staff to request reimbursement at 5% of total costs rather than the original method of direct charging certain costs. As a result, the allocations across funding sources were updated to reflect this change in methodology. City staff immediately began the recalculation of expenditures and future budget allocations tasks and is in the process of adjusting the grant project accounting. The 3/31/25 quarterly performance and financial reports will reflect the adjustments. The next draw down of funds will include adjustments for the over reimbursement that occurred as of 9/30/24. We anticipate this process to completed by 5/30/25. Finally, the Grants Management Division has added steps to its business process to ensure compliance with match requirements and staff have begun implementation of the new process.

View Audit 357287

Finding 561624 (2024-001)

Material Weakness 2024

Central Kitsap School District No. 401

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Scott McDaniel, Executive Director of Business and Operations or Lara Christopherson, As...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Scott McDaniel, Executive Director of Business and Operations or Lara Christopherson, Assistant Director of Business and Payroll P.O. Box 8 Silverdale, WA 98383 (360) 662-1650 Corrective action the auditee plans to take in response to the finding: 1. Student Supports Office Manager will ensure each staff member requiring time and effort certification is provided with the correct time and effort forms for semiannual or monthly certifications. 2. Student Supports Office Manager tracks time and effort certifications monthly on a spreadsheet; checking for completion, verifying the correct form was used, correctly dated by all parties, and returned within 30 days following the end of the reporting period. The Departmental Administrator will be notified if an employee has not returned a time and effort certification so they can follow-up and address the deficiency. 3. Student Supports Office Manager will review completed time and effort certifications on a monthly basis with the departmental administrator. 4. Student Supports will develop a time and effort training regarding procedures and the importance of completing time and effort certifications. This will ensure all required staff members understand what they need to report and why we need it completed. Time and effort training and detailed instructions will be provided at the beginning of each school year. Anticipated date to complete the corrective action: 09/30/2025

View Audit 357231

Finding 561617 (2024-001)

Material Weakness 2024

Kalama School District

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kalama School District September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Reg...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Kalama School District September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The District’s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Name, address, and telephone of District contact person: James Capen, Director of Business Services 548 China Garden Rd. Kalama, WA 98625 360-673-5282 Corrective action the auditee plans to take in response to the finding: The Kalama School District has collected all time and effort documentation for the 2024-2025 fiscal year and will continue to review grant requirements and collect time and effort as required. Anticipated date to complete the corrective action: 12/31/2024

View Audit 357230

Finding 561574 (2024-001)

Material Weakness 2024

Wellpinit School District No. 49

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

The District acknowledges the finding regarding noncompliance with federal wage rate requirements under the Davis-Bacon Act for a federally funded construction project. At the time, the District was unaware of the $2,000 threshold triggering these requirements and did not include the necessary wage ...

The District acknowledges the finding regarding noncompliance with federal wage rate requirements under the Davis-Bacon Act for a federally funded construction project. At the time, the District was unaware of the $2,000 threshold triggering these requirements and did not include the necessary wage rate provisions in the contract or collect certified payroll reports. To address this, the District is: • Updating procurement and contracting procedures to include Davis-Bacon Act requirements • Providing staff training on federal wage rate compliance • Implementing procedures to ensure proper contract language and weekly certified payroll collection • Establishing monitoring processes to verify ongoing compliance These actions will strengthen internal controls and ensure adherence to all applicable federal requirements moving forward.

View Audit 357204

Finding 561517 (2024-001)

None 2024

Servicios De La Raza, INC

CO

Allowable Costs / Cost Principles Reporting

In January 2025, management contracted with experienced consultants to support timely reporting of federal grants in the future.

View Audit 357127

Finding 561513 (2024-001)

Significant Deficiency 2024

Seattle School District No. 1

WA

School Nutrition Programs Allowable Costs / Cost Principles Eligibility

In response to this finding, the Culinary Services department under the guidance of the Operations team in SPS has made the following adjustments and changes to business practices: 1. The PLE tool has been formally integrated into the annual budgeting process to ensure routine compliance with this ...

In response to this finding, the Culinary Services department under the guidance of the Operations team in SPS has made the following adjustments and changes to business practices: 1. The PLE tool has been formally integrated into the annual budgeting process to ensure routine compliance with this guidance and accurate financial planning. 2. If a price increase is deemed necessary, it will undergo a thorough review and approval through the SPS board governance process. This will include a landscape review of meal prices in other districts in the Puget Sound region as well as similarly scaled districts nationally. This structured approach guarantees alignment with strategic objectives while maintaining transparency and accountability. 3. As of May 2025, the Culinary Services department under the direction of the Operations department will be taking action on a price increase for school lunches beginning for the 2025-26 school year with annual reviews scheduled for subsequent years.

View Audit 357117

Finding 561512 (2024-003)

Material Weakness 2024

Stedman-Wade Health Services, Inc.

NC

Allowable Costs / Cost Principles Material Weakness

The organization will conduct a comprehensive reconciliation of all salary expenses claimed under both the Provider Relief Fund (PRF) and the Employee Retention Tax Credit (ERTC). Overlapping or potentially duplicated costs will be adjusted as needed in coordination with legal and compliance advisor...

The organization will conduct a comprehensive reconciliation of all salary expenses claimed under both the Provider Relief Fund (PRF) and the Employee Retention Tax Credit (ERTC). Overlapping or potentially duplicated costs will be adjusted as needed in coordination with legal and compliance advisors.

View Audit 357109

Finding 561503 (2024-003)

Material Weakness 2024

Village of Lisbon

LA

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

Corrective Action Planned: The accounting records for the federal award revenues and expenditures have been properly maintained for 2025. Person Responsible for Corrective Action: Alisha Middleton, Clerk. Anticipated Completion Date: December 31, 2025.

View Audit 357080

Finding 561500 (2024-002)

Significant Deficiency 2024

Berlin Retirement Homes, Inc.

MA

Questioned Costs Allowable Costs / Cost Principles

Three different people were in the role of accounts payable during the year causing added strain to proper invoice review. This position has since been filled and the importance of reviewing invoices for proper allocation has been communicated. Additionally, all inaccurate charges were corrected.

View Audit 357074 Questioned Costs: $1

Finding 561475 (2024-001)

Material Weakness 2024

North Mason School District No. 403

WA

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

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal Title I eligibility requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective actio...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal Title I eligibility requirements. Name, address, and telephone of District contact person: Dan King 250 E Campus Dr. Belfair, WA 98528 (360) 277-2107 Corrective action the auditee plans to take in response to the finding: The district is strengthening its internal controls for monitoring the Per Pupil Expenditure (PPE) to match higher poverty concentration in its schools by the following: 1. Developing and utilizing an Excel Spreadsheet as a “PPE Tool” to allocate funds appropriately a. The PPE Tool will be a shared working document between the Business Office, Human Resources, and Title I Coordinator, b. The PPE Tool will be utilized when applying for the 2025-2026 Consolidated Grant and all future Consolidated Grant applications; and, c. The PPE Tool will be used when completing budgetary reviews at cabinet meetings. These measures will be implemented going forward as internal controls for ensuring compliance with eligibility requirements for Title I funding. Anticipated date to complete the corrective action: Beginning July 2025 when the District will be completing the Consolidated Grant application in the Education Grants Management System (EGMS).

View Audit 357060

Finding 561408 (2024-003)

Material Weakness 2024

Castle Rock School District No. 401

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Castle Rock School District No. 401 September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code ...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Castle Rock School District No. 401 September 1, 2023 through August 31, 2024 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-003 Finding caption: The District did not have adequate internal controls and did not comply with federal wage rate requirements. Name, address, and telephone of District contact person: Gloria Dupree, CSBS, CSBO Director of Fiscal Services Castle Rock School District 600 Huntington Ave S Castle Rock, WA 98611 Phone: 360.501.3132 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). • Provide a check list for finance, facilities, and procurement staff on Davis-Bacon compliance requirements, including how to access and apply wage determinations from SAM.gov. • Require all contractors and subcontractors on federally funded projects to sign certifications of compliance with federal wage laws. • Implement a checklist for federal construction projects. Provide training to all relevant staff on reviewing and verifying certified payroll reports. Anticipated date to complete the corrective action: 06/30/2025

View Audit 356985

Finding 561399 (2024-002)

Material Weakness 2024

St. Charles Parish Housing Authority

LA

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs

Corrective Action Plan Finding: Finding 2024-002-Internal Controls Inadequate for Disbursements-Allowable Costs Condition: Good internal controls should be in place to make sure that disbursements are for eligible payments, are correctly classified, and are timely paid. Good controls ensure that ...

Corrective Action Plan Finding: Finding 2024-002-Internal Controls Inadequate for Disbursements-Allowable Costs Condition: Good internal controls should be in place to make sure that disbursements are for eligible payments, are correctly classified, and are timely paid. Good controls ensure that there is proper, documented review of all of these functions. Records should be maintained in an order that is conducive to efficient and timely summarizing by the outside fee accounting firm. Unaudited financial statements should be produced on a timely basis, and reviewed timely by the board of commissioners. Corrective Action Planned We will comply with the auditor’s suggestions. Person responsible for corrective action: Jedidiah Jackson, E.D. Telephone: (985) 785-2601 St. Charles Parish Housing Authority Fax: (985) 785-6238 200 Boutte Estates Dr. Boutte, LA 70039 Anticipated Completion Date- September 30, 2025

View Audit 356963 Questioned Costs: $1

Finding 561398 (2024-001)

Material Weakness 2024

St. Charles Parish Housing Authority

LA

HUD Housing Programs Allowable Costs / Cost Principles

ST. CHARLES PARISH HOUSING AUTHORITY________________________________________PHONE: 985-785-2601 ·FAX:985-785-6238· 200 BOUTTE ESTATES DRIVE ·BOUTTE, LA 70039-0448 ________________________________________ HOUSING AUTHORITY OF ST. CHARLES PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER...

ST. CHARLES PARISH HOUSING AUTHORITY________________________________________PHONE: 985-785-2601 ·FAX:985-785-6238· 200 BOUTTE ESTATES DRIVE ·BOUTTE, LA 70039-0448 ________________________________________ HOUSING AUTHORITY OF ST. CHARLES PARISH, LOUISIANA CORRECTIVE ACTION PLAN YEAR ENDED SEPTEMBER 30, 2024 Corrective Action Plan Finding: Finding 2024-001-Insufficent Restricted Cash and Deficit in Unrestricted Net Position-Allowable Costs Condition: HUD designates the Housing Choice Voucher advances to be in two categories: (a)-strictly to be used for HAP payments and (b)-to be used to pay for all non-HAP payment expenses identified with the HCV program. The (b) portion is considered Unrestricted HAP equity. When this number is a negative, this means that the HCV program has spent more than it should have. At September 30, 2024, the deficit as shown on page 11, of the Statement of Net Position, is $103,785. Corrective Action Planned I am Jedidiah Jackson. I was hired as Executive Director and started July 1, 2024. I believe that many of the issues noted in this audit have been corrected and I am working on the remaining issues. Person responsible for corrective action: Jedidiah Jackson, E.D. Telephone: (985) 785-2601 St. Charles Parish Housing Authority Fax: (985) 785-6238 200 Boutte Estates Dr. Boutte, LA 70039 Anticipated Completion Date- September 30, 2025

View Audit 356963

Finding 561391 (2024-002)

Significant Deficiency 2024

Town of Plainville, Connecticut

CT

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

Finding 2024-002 Description of Finding Significant Deficiency in Internal Control over Compliance, and Other Matter Statement of Concurrence or Nonconcurrence The Town concurs. Corrective Action The Town agrees with this finding and will ensure the Board of Education department heads and Director...

Finding 2024-002 Description of Finding Significant Deficiency in Internal Control over Compliance, and Other Matter Statement of Concurrence or Nonconcurrence The Town concurs. Corrective Action The Town agrees with this finding and will ensure the Board of Education department heads and Director of Operations sign all invoices. Name of Contact Person Robert Buden, Director of Finance Completion Date May 20, 2025

View Audit 356956

Finding 561390 (2024-001)

Significant Deficiency 2024

Opp City Board of Education

AL

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.326

Item 2024‐001 – Special Tests and Provisions – Wage Rate Requirements (Repeat) Recommendation: 2 CFR 200.303 requires the non-Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non- Federal entity is managing t...

Item 2024‐001 – Special Tests and Provisions – Wage Rate Requirements (Repeat) Recommendation: 2 CFR 200.303 requires the non-Federal entity to “(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non- Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.” 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Linda Harper, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management has already communicated with all current contractors and subcontractors regarding the wage rate requirements for contracts in progress and has implemented additional procedures for future projects effective October 1, 2024. These additional procedures include the Chief School Financial Officer (CSFO), Linda Harper, reviewing all proposed construction contracts for inclusion of the prevailing wage rate clause as part of the bid process prior to expenditures being made. The CSFO will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.

View Audit 356950 Questioned Costs: $1

Finding 561206 (2024-001)

Material Weakness 2024

College Place School District No. 250

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

College Place Public Schools will take the following steps to prevent future noncompliance with time-and-effort documentation requirements: 1. Clarify Procedures: District leadership has revised internal protocols for documenting staff funded by federal grants, including fixed-schedule and semiannua...

College Place Public Schools will take the following steps to prevent future noncompliance with time-and-effort documentation requirements: 1. Clarify Procedures: District leadership has revised internal protocols for documenting staff funded by federal grants, including fixed-schedule and semiannual reporting procedures. (Already corrected effective September 2024) 2. Staff Training: Business office and program staff will be retrained in by July 31, 2025 on federal documentation standards, including OSPI Bulletin 048-17. (Completion by July 31, 2025) 3. Internal Review: A quarterly review process is now in place to ensure proper documentation is collected and retained for all federally funded personnel. (Already corrected effective September 2024) Grant Transition Oversight: All funding transitions (e.g., ESSER to TFCCLC) will now require a pre-transition compliance review by Director of Business Services and CPPS Payroll Specialist to avoid misaligned timelines and documentation gaps. (Completion by July 31, 2025)

View Audit 356827

Corrective Action Plans

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