Corrective Action Plans

Finding 1181444 (2024-005)

Material Weakness 2024

Community Action Committee of the Lehigh Valley, Inc. and Subsidiaries

PA

Eligibility Subrecipient Monitoring Allowable Costs / Cost Principles

U.S. Department of Agriculture 2024-005 • Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 1 out of the 21 agencies tested which distributed TEFAP commodit...

U.S. Department of Agriculture 2024-005 • Material Weakness in Internal Control over Compliance Food Distribution Cluster– Assistance Listing No. 10.569 Condition: During our testing, we identified there was no monitoring performed for 1 out of the 21 agencies tested which distributed TEFAP commodities during fiscal year 2024. Recommendation: The Organization should prioritize the timely monitoring of participating agencies to allow for changes in food distributions if any ineligible participants are discovered. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization developed a schedule to complete monitoring and created a checklist to ensure that all documentation is in the appropriate folder. In addition, the organization began conducting internal audits to ensure the developed processes are being followed. Name(s) of the contact person(s) responsible for corrective action: Dawn Godshall, Executive Director Planned completion date for corrective action plan: Planned completion date is May 2026.

View Audit 392710

Finding 1181340 (2024-006)

Material Weakness 2024

Neighborhood Defender Service, Inc.

NY

Allowable Costs / Cost Principles § 200.403

NDS will implement a time study process to determine the appropriate allocation of staff time to federally funded programs due to limitations in the payroll system. This will replace the prior flat-rate allocation method and ensure salary charges to federal grants are supported by documented time an...

NDS will implement a time study process to determine the appropriate allocation of staff time to federally funded programs due to limitations in the payroll system. This will replace the prior flat-rate allocation method and ensure salary charges to federal grants are supported by documented time and actual work performed, consistent with Uniform Guidance requirements. Human Resources will maintain documentation of approved pay rates for audit and compliance purposes Management expects to have this implemented by April 30, 2026. The process is being monitored by Anthonia Ibe, Chief Financial Officer.

View Audit 392557

Finding 1180866 (2024-006)

Material Weakness 2024

City of South Gate

CA

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

Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are revi...

Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are reviewed, bi-weekly, by payroll and adjusted to reflect actual hours as they relate to a specific activity. The City was able to hire a permanent accountant hiring who will provide additional oversight of these processes ensuring that hours worked are both reported correctly on the timesheets and are following the funding allocations that are approved by the grant.

View Audit 392505

Finding 1180864 (2024-005)

Material Weakness 2024

City of South Gate

CA

Allowable Costs / Cost Principles § 200.430

Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are revi...

Management acknowledges the importance of ensuring that payroll costs charged to the program are consistent between the payroll system and the employee’s timesheet. The City continues to monitor its internal control process to ensure thorough review procedures are being followed. Timesheets are reviewed, bi-weekly, by payroll and adjusted to reflect actual hours as they relate to a specific activity. The City was able to hire a permanent accountant hiring who will provide additional oversight of these processes ensuring that hours worked are both reported correctly on the timesheets and are following the funding allocations that are approved by the grant.

View Audit 392505

Finding 1180833 (2024-004)

Material Weakness 2024

Maine School Administrative District No. 75

ME

Allowable Costs / Cost Principles § 200.302 § 200.403

Finding 2024-004 Internal control weakness over activities allowed/allowable costs Name of responsible official: Evan Howard – Business Manager Corrective action: With stabilized staffing in place, management is currently updating the District’s federal funds procurement and compliance policies to a...

Finding 2024-004 Internal control weakness over activities allowed/allowable costs Name of responsible official: Evan Howard – Business Manager Corrective action: With stabilized staffing in place, management is currently updating the District’s federal funds procurement and compliance policies to address Uniform Guidance requirements related to allowable and unallowable costs. In conjunction with this effort, management will design and implement internal control procedures to ensure that expenditures charged to grants are reviewed for allowability prior to payment. These procedures will include documented review and approval processes, supervisory oversight, and periodic monitoring to ensure ongoing compliance. Anticipated completion date: June 30,2026

View Audit 392493

Finding 1180830 (2024-003)

Material Weakness 2024

Maine School Administrative District No. 75

ME

Allowable Costs / Cost Principles Procurement, Suspension & Debarment § 200.302 § 200.317 § 200.318 § 200.327 § 200.430

Finding 2024-003 Material Weakness in Internal Control over Compliance Name of responsible official: Evan Howard – Business Manager Corrective action: The municipality is in the process of reviewing roles, responsibilities, and job descriptions to ensure appropriate segregation of duties and proper ...

Finding 2024-003 Material Weakness in Internal Control over Compliance Name of responsible official: Evan Howard – Business Manager Corrective action: The municipality is in the process of reviewing roles, responsibilities, and job descriptions to ensure appropriate segregation of duties and proper internal controls, in accordance with the Corrective Action Plan. The plan has not yet been formally adopted. Anticipated completion date: June 30,2026

View Audit 392493

Finding 1180717 (2024-003)

Material Weakness 2024

Children's Place Association

IL

Allowable Costs / Cost Principles

Management recognizes that the payroll software transition and the absence of formally documented procedures governing payroll data preservation and time-and-effort reporting resulted in gaps in compliance. Specifically, legacy payroll and timesheet data were not fully preserved prior to system migr...

Management recognizes that the payroll software transition and the absence of formally documented procedures governing payroll data preservation and time-and-effort reporting resulted in gaps in compliance. Specifically, legacy payroll and timesheet data were not fully preserved prior to system migration, and payroll allocations were, for a period, based on budgeted estimates rather than actual time worked. Management started implementing corrective actions to address both the immediate documentation gaps and the underlying internal control weaknesses. 1. Time-and-Effort Documentation System CPA transitioned to a new standardized payroll and time-reporting system in early 2024, which requires all employees whose compensation is charged in whole or in part to federal awards to document actual time worked, as follows: o Currently employees record time by department and program activity. o In December 2025, management is configuring the payroll system to allow employee time allocations down to the individual contract level. o Time reporting will be based on actual hours worked, not budgeted or estimated percentages and replace prior budget-based allocation methodologies. o Timesheets are reviewed and approved by supervisors on a bi-weekly basis and are maintained as part of CPA’s official payroll and accounting records. Management will establish guidelines and document formal procedures to ensure full data preservation prior to any future system migrations, including payroll, HR, or financial systems. These procedures include: o A mandatory pre-migration data inventory and archival checklist, approved by Finance and IT leadership o Secure retention of legacy payroll, timesheet, and personnel records in accordance with CPA’s record-retention policy o Verification testing to confirm data completeness and accessibility before decommissioning any legacy system o Written approval by the Chief Financial Officer prior to system cutover

View Audit 392373

Finding 1179687 (2024-002)

Material Weakness 2024

American Museum of Science and Energy Foundation, Inc.

TN

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.400

As part of the proposal negotiations for the federal program, initial discussions with the sponsoring office of the federal program included a limitation for allowable compensation for employees that were not the Executive Director. Although the limitation was intended to be removed from the final a...

As part of the proposal negotiations for the federal program, initial discussions with the sponsoring office of the federal program included a limitation for allowable compensation for employees that were not the Executive Director. Although the limitation was intended to be removed from the final agreement, the budgeted requested salaries were not updated. The Assistance Agreement has been modified to remove any such limitation prospectively beginning with Modification 0015 in April 2024. Implementation Date – April 2025

View Audit 392153

Finding 1179584 (2024-001)

Material Weakness 2024

MONTACHUSETT VETERANS OUTREACH CENTER, INC.

MA

Allowable Costs / Cost Principles Cash Management § 200.403

2024-001– Allowable Costs – Internal Control over Payroll and Non-Payroll Costs Programs 64.024 Veteran Affairs Homeless Providers Grant and Per Diem Program 64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Responsible Officials Stephanie Marchetti, Executive Director Cynthia...

2024-001– Allowable Costs – Internal Control over Payroll and Non-Payroll Costs Programs 64.024 Veteran Affairs Homeless Providers Grant and Per Diem Program 64.055 Staff Sergeant Parker Gordon Fox Suicide Prevention Grant Program Responsible Officials Stephanie Marchetti, Executive Director Cynthia Newsham, Director of Finance Plan Detail Based on the on the findings, the Executive Director and Director of Finance will review the organizational policies and procedures and create a cost allocation plan based on employment status. Once finalized the cost allocation plan will be reviewed and approved by the board of directors, who approve any policy changes before they are implemented. Anticipated Completion Date June 30, 2025

View Audit 391970

Finding 1179531 (2024-006)

Material Weakness 2024

Restoration Christian Ministries

CO

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.302 § 200.305 § 200.317 § 200.318 § 200.327

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiat...

Finding Number: 2024-006 Finding Title: Financial Policies and Procedures Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302(b)); Allowable Costs (2 CFR §200.403-405); Procurement (2 CFR §200.317-327); Cash Management (2 CFR §200.305); Travel Costs (2 CFR §200.475) Note: Organization has existing Conflict of Interest policy in compliance with 2 CFR §200.318(c)(1). Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization will establish formalized accounting policies and procedures that adhere to the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Comprehensive Policy Manual Development • Action: Engage consultant or work with Contract Accountant to develop comprehensive written financial policies and procedures manual addressing all Uniform Guidance requirements, including: (a) Allowable costs (2 CFR §200.403-405); (b) Procurement (2 CFR §200.317-327); (c) Cash management (2 CFR §200.305); (d) Travel costs (2 CFR §200.475); (e) Time and effort documentation; (f) Equipment management; (g) Subrecipient monitoring; (h) Financial reporting; and (i) Record retention. Ensure policies address financial management system requirements under 2 CFR §200.302. Tailor policies to Organization's all-volunteer structure. [Note: Organization already has Conflict of Interest policy complying with 2 CFR §200.318(c)(1).] • Responsible Person/Title: Board Treasurer with Contract Accountant • Anticipated Completion Date: April 30, 2026 Corrective Action #2: Board Approval and Adoption • Action: Present draft policies to full Board of Directors for review and input. Board will formally adopt policies by resolution. Document approval in Board meeting minutes. • Responsible Person/Title: Board President • Anticipated Completion Date: May 31, 2026 Corrective Action #3: Dissemination and Training • Action: Distribute approved policies to all Board members and Contract Accountant. Conduct training session for Board members and Contract Accountant on new policies and procedures. Board members and Contract Accountant will sign acknowledgment of receipt and understanding. Make policies readily accessible (e.g., shared drive, Board portal). • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026 Corrective Action #4: Implementation Tools and Support • Action: Develop templates, forms, and tools to support policy implementation. Create workflow diagrams and checklists for common transactions. Establish Board Treasurer as primary resource for policy implementation questions. • Responsible Person/Title: Board Treasurer and Contract Accountant • Anticipated Completion Date: July 31, 2026 Corrective Action #5: Annual Policy Review Process • Action: Schedule annual review of policies to ensure continued Uniform Guidance compliance. Update policies as needed for regulatory or organizational changes. Submit material policy changes to full Board for approval. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: Annually, beginning June 2027 Corrective Action #6: Governance Structure Assessment • Action: Board will evaluate establishing Audit Committee or combined Finance/Audit Committee to provide enhanced oversight of financial management, internal controls, and federal compliance. If Board size prohibits separate committee, designate at least two Board members with specific oversight responsibilities. • Responsible Person/Title: Board President • Anticipated Completion Date: June 30, 2026

View Audit 391915

Finding 1179529 (2024-005)

Material Weakness 2024

Restoration Christian Ministries

CO

Reporting Allowable Costs / Cost Principles § 200.302

Finding Number: 2024-005 Finding Title: Insufficient Accounting to Track Federal Grant Expenditures Federal Program Information: • Federal Agency: Department of the Treasury • Assistance Listing Number (ALN): 21.027 • Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Compliance...

Finding Number: 2024-005 Finding Title: Insufficient Accounting to Track Federal Grant Expenditures Federal Program Information: • Federal Agency: Department of the Treasury • Assistance Listing Number (ALN): 21.027 • Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Financial Management and Standards of Financial Management Systems (2 CFR §200.302) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization is in process of implementing a project based ledger and procedures to ensure federal expenditures are properly coded so they are readily identifiable. Corrective Action Plan: Corrective Action #1: Project-Based Accounting System Implementation • Action: Implement project-based accounting system assigning unique project codes to each federal award. Configure general ledger to separately track revenues and expenditures by federal program. Establish cost centers or fund codes specific to federal programs. Board Treasurer will approve system modifications. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: March 31, 2026 Corrective Action #2: Chart of Accounts Restructuring • Action: Redesign chart of accounts to include distinct account codes for federal program expenditures. Create account code structure identifying: (a) funding source, (b) program/project, and (c) expense category. Document structure and provide to Board Treasurer. Board will formally approve revised chart of accounts. • Responsible Person/Title: Contract Accountant • Anticipated Completion Date: February 28, 2026 Corrective Action #3: Expense Coding Procedures • Action: Develop written procedures for charging costs to federal programs, including documentation requirements. Implement procedures for allocating shared costs where applicable. Require all federal program expenditures coded with appropriate project/grant identifiers at time of transaction entry. Board Treasurer will review and approve expense allocation methodology. • Responsible Person/Title: Contract Accountant • Anticipated Completion Date: March 31, 2026 Corrective Action #4: Training and Implementation Support • Action: Provide training to Contract Accountant on new account structure and federal award tracking requirements. Ensure Contract Accountant has access to technical resources and support. Consider engaging consultant to assist with initial implementation. • Responsible Person/Title: Board Treasurer • Anticipated Completion Date: April 30, 2026 Corrective Action #5: Monthly Reconciliation and Monitoring • Action: Contract Accountant will perform monthly reconciliations of federal program expenditures by grant. Generate monthly expenditure reports by federal award for Board Treasurer review. Compare recorded expenditures to grant budgets and terms to identify irregularities. Board Treasurer will report federal grant expenditure status to full Board monthly. • Responsible Person/Title: Contract Accountant and Board Treasurer • Anticipated Completion Date: April 30, 2026 (initial); Ongoing monthly thereafter

View Audit 391915

Finding 1179526 (2024-003)

Material Weakness 2024

Restoration Christian Ministries

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.214 § 200.317 § 200.327 § 200.332

Finding Number: 2024-003 Finding Title: Subrecipient Monitoring Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Speci...

Finding Number: 2024-003 Finding Title: Subrecipient Monitoring Federal Program Information: • Federal Agency: Department of Housing and Urban Development; Department of the Treasury • Assistance Listing Numbers (ALN): 14.251 and 21.027 • Federal Program Names: Economic Development Initiatives—Special Project, Neighborhood Initiative and Neighborhood Stabilization Program; Coronavirus State and Local Fiscal Recovery Funds Compliance Requirement: Subrecipient Monitoring (2 CFR §200.332(d)); Procurement Standards (2 CFR §200.317-200.327); Suspension and Debarment (2 CFR §200.214) Questioned Costs: $0 Repeat Finding: No Management's Response: The Board of Directors of Restoration Christian Ministries agrees with the finding. The Organization has partnered with a firm to administer the development of the project and was unaware of its responsibilities to monitor the subrecipient. The Organization is in process of implementing procedures to ensure the subrecipient complies with the requirements of the Uniform Guidance. Corrective Action Plan: Corrective Action #1: Subrecipient Monitoring Policy Development • Action: Develop and adopt written subrecipient monitoring policies and procedures complying with 2 CFR §200.332. Include specific requirements for reviewing procurement policies, suspension/debarment procedures, and other compliance areas. Define monitoring activities, frequency, and documentation requirements. Board will formally approve policy by resolution. • Responsible Person/Title: Board President with Contract Accountant • Anticipated Completion Date: February 15, 2026 Corrective Action #2: Pre-Award Risk Assessment Process • Action: Implement pre-award risk assessment for all subrecipients. Require subrecipients to provide documentation of procurement policies and debarment procedures prior to executing subaward agreements. Board Treasurer will review and approve subrecipient policies for Uniform Guidance compliance before subaward execution. • Responsible Person/Title: Board President • Anticipated Completion Date: February 28, 2026 (initial); Ongoing for new subawards Corrective Action #3: Ongoing Monitoring Program • Action: Board will designate Board member or engage consultant to conduct annual reviews of subrecipients verifying procurement and suspension/debarment compliance. Require subrecipients to submit documentation of debarment checks for all vendors. Review subrecipient procurement transactions on sample basis. Designated monitor will report findings to full Board quarterly. • Responsible Person/Title: Board-designated monitor • Anticipated Completion Date: March 31, 2026 (initial monitoring); Ongoing annually thereafter Corrective Action #4: Technical Assistance to Subrecipient • Action: Provide training and technical assistance to current subrecipient to develop compliant procurement policies and debarment procedures. Engage consultant if needed. Create guidance materials and templates. Schedule quarterly meetings between Board representative and subrecipient. • Responsible Person/Title: Board President • Anticipated Completion Date: March 31, 2026 Corrective Action #5: Monitoring Documentation System • Action: Maintain comprehensive monitoring files documenting all activities, findings, and corrective actions. Board President will report monitoring results to full Board quarterly. • Responsible Person/Title: Board President • Anticipated Completion Date: March 31, 2026 (system implementation); Ongoing

View Audit 391915

Finding 1179403 (2024-008)

Material Weakness 2024

Recreation & Park Commission for Parish of East Baton Rouge

LA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.318

View of Responsible Official: A written SOP was developed for determining allowable costs and procurement requirements in accordance with the applicable CFR to guide key finance staff with responsibility for federally eligible expenditures. Anticipated Completion Date: April 30, 2026 Responsible Con...

View of Responsible Official: A written SOP was developed for determining allowable costs and procurement requirements in accordance with the applicable CFR to guide key finance staff with responsibility for federally eligible expenditures. Anticipated Completion Date: April 30, 2026 Responsible Contact Person: Rhonda Williams, Financial Director

View Audit 391806

Finding 1179000 (2024-008)

Material Weakness 2024

City of Stockton

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Special Tests & Provisions

2024-008 – Special Tests and Provisions – Internal Control and Compliance over Obligation, Expenditure, Payment Requirements City’s Corrective Action Plan: The Department concurs with this finding. The City has since implemented policies and procedures to ensure timely issuance of award letters to s...

2024-008 – Special Tests and Provisions – Internal Control and Compliance over Obligation, Expenditure, Payment Requirements City’s Corrective Action Plan: The Department concurs with this finding. The City has since implemented policies and procedures to ensure timely issuance of award letters to satisfy the 180-day obligation requirement, and processing of payments within 30 days of receipt of complete documentation, or to document the reason payment cannot be processed. Staff will continue to follow and improve compliance with these established processes and procedures to ensure timely contract execution and payment processing. While unforeseen circumstances may occasionally cause delays, such instances will be documented and addressed promptly. Responsible Person: Director of Economic Development, Housing Manager Expected Implementation Date: March 12, 2024

View Audit 391415

Finding 1178991 (2024-004)

Material Weakness 2024

City of Stockton

CA

Allowable Costs / Cost Principles § 200.430

2024-004 – Allowable Costs/Cost Principles – Internal Control over Payroll Expenditures City’s Corrective Action Plan: The City accepts the finding, which resulted from the implementation of a new ERP system for position control, benefits, and payroll that began in 2024 and was completed in 2025. To...

2024-004 – Allowable Costs/Cost Principles – Internal Control over Payroll Expenditures City’s Corrective Action Plan: The City accepts the finding, which resulted from the implementation of a new ERP system for position control, benefits, and payroll that began in 2024 and was completed in 2025. To address the identified conditions, the City will strengthen internal controls over federal payroll allocations by implementing documented reconciliation and review procedures, regularly validating system configuration and allocation files, and establishing processes to identify and correct duplicate or unusual benefit postings. The finding appears to be based on salary charges from two staff members whose time was charged to ESG-related accounts that were not part of their original salary allocation setup. Charging time to accounts outside of original salary allocations is not atypical across City departments and is a common practice when staff responsibilities or work assignments cross funding sources. Executive-time was designed to allow this flexibility so that time charged accurately reflects how staff time is spent. In this instance, the two staff members performed ESG-related activities, and time was charged accordingly to reflect actual work performed. Cross-department internal controls for federal payroll expenditure processing and reporting will be updated, with revisions expected to be completed and tested by 2027. Responsible Person: Payroll & Department(s) Administering Grants Expected Implementation Date: Fiscal Year 2026

View Audit 391415

Finding 1177943 (2024-001)

Material Weakness 2024

Lorain County General Health District

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.302 § 200.328 § 200.329

Now that Treasury Portal is updated with all obligations the County will utilize Oracle reporting to input all remaining expenditures in the applicable quarterly report.

View Audit 391349

Finding 1177813 (2024-005)

Material Weakness 2024

Rocky Mountain Innovation Initiative d/b/a Innosphere Ventures

CO

Allowable Costs / Cost Principles § 200.430

Management will implement procedures to ensure payroll costs charged to federal awards are supported by after-the-fact documentation of actual time worked, in compliance with 2 CFR §200.430(i). Employees whose time is allocated to multiple programs will be required to complete time and effort report...

Management will implement procedures to ensure payroll costs charged to federal awards are supported by after-the-fact documentation of actual time worked, in compliance with 2 CFR §200.430(i). Employees whose time is allocated to multiple programs will be required to complete time and effort reporting. Payroll processing will include documented review and approval by separate individuals to strengthen internal controls and ensure accurate allocation of personnel costs.

View Audit 391159

Finding 1177736 (2024-002)

Material Weakness 2024

Refugee Support Services of the Carolinas, Inc.

NC

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Cash Management

Management Response: Management acknowledges that certain expense and salary allocations were not fully aligned with the approved grant budgets, primarily due to staffing transitions and evolving program priorities. These changes temporarily impacted the consistency of allocation methods and review ...

Management Response: Management acknowledges that certain expense and salary allocations were not fully aligned with the approved grant budgets, primarily due to staffing transitions and evolving program priorities. These changes temporarily impacted the consistency of allocation methods and review processes. methods and review processes. Planned Corrective Action: Management has implemented monthly reconciliations between expense allocations and the approved budgets to ensure ongoing accuracy and compliance. An ORR tracking sheet is now used to verify expenditure allocations against current budgeted amounts prior to each reimbursement submission, ensuring that all costs are allowable, properly supported, and aligned with approved grant budgets. Name of Contact Person: Anna Eaton, Executive Director

View Audit 391134

Finding 1177707 (2024-004)

Material Weakness 2024

Burke County Board of Education

GA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.303 § 200.403

All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval.

View Audit 391130

Finding 1177706 (2024-002)

Material Weakness 2024

Burke County Board of Education

GA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.303 § 200.403 § 200.415

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by personnel in charge of the grant to ensure proper approvals are maintained.

View Audit 391130

Finding 1177697 (2024-001)

Material Weakness 2024

Burke County Board of Education

GA

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.318 § 200.320 § 200.403

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with...

The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Expenditures related to the grant will be reviewed by the Director in charge of the grant to ensure proper approvals are maintained and packing slips are submitted with the invoice for payment. In the event a packing slip is not received, a note will be included to indicate such. All journal entries related to the grant will be submitted by the Finance Director to the Director in charge of the grant for approval. The School District will review established internal controls and procedures with pertinent staff to ensure all are being followed. Procurement transactions related to the grant will be reviewed by the Director in charge of the grant to ensure proper supervisor review and approvals are maintained. The Director in charge of the grant will review and update the current procedures to ensure that the required procurement methods are properly identified and followed and that required procurement documentation is properly identified, safeguarded, and retained.

View Audit 391130

Finding 1177674 (2024-012)

Material Weakness 2024

Southeast New Mexico College

NM

Allowable Costs / Cost Principles § 200.303 § 200.430

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on Au...

Recommendation We recommend the College develop and implement adequate policies and procedures to ensure charging of expenses for allowability are based off approved amounts. Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy and Procedure Development The institution will revise or develop written policies and procedures to ensure compliance with 2 CFR §200.430. The revised procedures will include: • Detailed requirements for supporting documentation for payroll costs. • Clear guidance on time and effort reporting. • Procedures for periodic payroll reconciliation between payroll records and grant charges. Staff Training Training will be provided for payroll, grants accounting, and department personnel involved in charging payroll costs to federal awards to ensure understanding and compliance with the new procedures. Payroll Reconciliation A process will be established to reconcile payroll charges to the grant with actual payroll records at least quarterly, with reviews and approvals documented. Effort Certification Employees whose salaries are charged to federal grants will be required to complete effort certifications, which will be reviewed and retained per federal guidelines. Monitoring and Review Grant accounting and payroll offices will implement an annual review process to ensure continued compliance and address any gaps or errors identified. Due Date of Completion: August 31, 2025 Responsible Part(ies) Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Restricted Funds Manager, Payroll Manager

View Audit 391086

Finding 1177673 (2024-011)

Material Weakness 2024

Southeast New Mexico College

NM

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Significant Deficiency § 200.302 § 200.305

Recommendation We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs Management Response Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit repo...

Recommendation We recommend the College establish the required written procedures for federal monies and have them available to all personnel who work with federal programs Management Response Corrective Action Unfortunately, due to the untimely completion and release of the June 30, 2023 audit report (released on August 8, 2025 - over two years after the end of the June 30, 2023 fiscal year audit), the College did not have the opportunity to review and begin a timely process of addressing a majority of the audit findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the June 30, 2023 audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward. It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit. Corrective Action Taken / Planned: Policy Development • The institution will develop comprehensive written policies and procedures to address compliance requirements related to 2 CFR 200, Subparts D and E of the Uniform Guidance and approved by institutional leadership by July 31, 2025. Policy Review and Approval • Draft policies will be reviewed by VP of Business and Finance and approved by institutional leadership by August 31, 2025. Training • Relevant personnel will be trained on the new policies and procedures to ensure consistent understanding and compliance. Implementation • The institution will fully implement the new procedures by August 31, 2025, and will ensure all departments involved with federal awards are following them. Ongoing Review: • Policies and procedures will be reviewed annually, and updates will be made as necessary to ensure continued compliance with federal regulations. Date of Completion: August 31, 2025 Responsible Parties Vice President for Business and Finance (or appropriate official), Dean of Business and Finance, Director of Finance, Restricted Funds Manager

View Audit 391086

Finding 1177643 (2024-007)

Material Weakness 2024

Jackson County

OH

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Period of Performance § 200.403

The Sheriff’s Office has separated from the person who oversaw these grants. New procedures have been implemented, and the Chief Deputy is now involved in overseeing these grants as well.

View Audit 391060

Finding 1177046 (2024-007)

Material Weakness 2024

County of Delta

MI

Allowable Costs / Cost Principles Cash Management Procurement, Suspension & Debarment § 200.303

2024-007: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: Delta County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) ...

2024-007: Material Weakness and Noncompliance – Written Policies Required by the Uniform Guidance Statement of Condition/Criteria: Delta County does not have written policies and procedures to implement the requirements of 2 CFR section 200 for the administration of federal awards. 2 CFR 200.303(a) establishes that the auditee must establish and maintain effective internal controls over the federal awards that provide assurance that the entity is managing the federal awards in compliance with federal statutes, regulations, and the conditions of the federal award. Planned Corrective Action: County management will develop written policies and procedures for grants. Contact person responsible for corrective action: Emily DeSalvo, County Administrator Anticipated Completion Date: March 2026

View Audit 390939

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