Corrective Action Plans

Finding 1215424 (2024-003)

Material Weakness 2024

Fasd United Inc.

DC

Subrecipient Monitoring Allowable Costs / Cost Principles

The Organization reduced the indirect rate charged to the grant to the de minimis 10% during 2024.

View Audit 402036

Finding 1215179 (2024-003)

Material Weakness 2024

Abilities Network, Inc.

MD

Allowable Costs / Cost Principles § 200.303 § 200.407

Allowability Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: The auditors recommend the Organization design, implement, and monitor internal controls over allocations as well as maintain source documentation to support amounts charged to the grant. Explanation ...

Allowability Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: The auditors recommend the Organization design, implement, and monitor internal controls over allocations as well as maintain source documentation to support amounts 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 will review the current internal controls over allocations and source documentation to identify any gaps or weaknesses and develop a plan to address any identified gaps or weaknesses, including updating policies and procedures as necessary. Management will also communicate the updated policies and procedures to all relevant employees and provide training as needed. Monitoring and testing procedures will be implemented to ensure that the updated policies and procedures are being followed. There will also be regular reviews and updates to the policies and procedures as needed to ensure ongoing effectiveness. Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness.

View Audit 401848

Finding 1215074 (2024-004)

Material Weakness 2024

HOUSING AUTHORITY OF THE CITY OF LITTLE ROCK, ARKANSAS

CA

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

Finding 2024-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, Public Housing Capital Fund Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, 14.872, and 21.01...

Finding 2024-004 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster, Public and Indian Housing Program, Public Housing Capital Fund Program, and Coronavirus Relief Fund Assistance Listing Numbers: 14.871, 14.879, 14.850, 14.872, and 21.019 Material Noncompliance Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance Criteria: The Authority must maintain complete and accurate accounts and other records for the program in accordance with HUD compliance requirements. Condition: The Authority did not maintain complete and accurate accounts and other records in accordance with HUD compliance requirements regarding Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Eligibility, Reporting, and Special Tests and Provisions. Context: The Authority was unable to provide requested documentation at the time of audit to properly test the HUD compliance requirements. Known Questioned Costs: Unknown Cause: There is a material weakness in internal controls over compliance related to the maintenance of tenant files, wait lists, inspection reports and other records. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster and Public and Indian Housing Program are in material non- compliance with the compliance requirements of the program. Recommendation: We recommend that the Authority implement a process whereby Authority documents are stored and safeguarded to ensure compliance with the Uniform Guidance and the compliance supplement. View of Responsible Officials and Corrective Actions: The Authority experienced significant turnover in employees during the year and as a result certain source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows its internal control over compliance processes and procedures related to the Housing Voucher Cluster, Public and Indian Housing Program and Public Housing Capital fund Program to remedy the aforementioned deficiencies. Bryant McClellan, CFO, will be responsible to implement this corrective action by December 31, 2025.

View Audit 401788

Finding 1215022 (2024-012)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles

Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs ...

Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs against program requirements and other relevant background documentation. For finding 2024-012, Cayuga will review relevant lease terms and program requirements. If, upon full evaluation, Cayuga Centers concurs that such costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. For steps to resolve the underlying control deficiency asserted or implied in this finding, please see Cayuga Centers’ response to Findings 2024-001 through 006 above.

View Audit 401760

Finding 1215021 (2024-011)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles

Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs ...

Cayuga Centers will confer with its auditors to ensure it has a full list of general ledger (GL) transactions regarding which these findings are asserted. For finding 2024-011, Cayuga Centers will assess whether each transaction does, in fact, represent a capital cost and will assess all such costs against program requirements and other relevant background documentation. For finding 2024-012, Cayuga will review relevant lease terms and program requirements. If, upon full evaluation, Cayuga Centers concurs that such costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. For steps to resolve the underlying control deficiency asserted or implied in this finding, please see Cayuga Centers’ response to Findings 2024-001 through 006 above.

View Audit 401760

Finding 1215020 (2024-010)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles

As discussed above Cayuga Centers has engaged grants management advisors who will assist in evaluating this specific finding. To the extent that the finding merely asserts that indirect cost bases were improperly calculated in prior periods, please see Cayuga Centers’ response and actions steps with...

As discussed above Cayuga Centers has engaged grants management advisors who will assist in evaluating this specific finding. To the extent that the finding merely asserts that indirect cost bases were improperly calculated in prior periods, please see Cayuga Centers’ response and actions steps with respect to findings 2024-001 through 006. If, upon full evaluation, Cayuga Centers concurs that indirect costs were improperly charged, it will address the matter with its primary funding agency as part of broader resolution of any unallowable costs.

View Audit 401760

Finding 1215019 (2024-009)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles § 200.449

Cayuga Centers does not fully understand the scope of this asserted finding. It will, however, work with its auditors to fully assess this finding. As discussed above, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted findings. To the exte...

Cayuga Centers does not fully understand the scope of this asserted finding. It will, however, work with its auditors to fully assess this finding. As discussed above, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted findings. To the extent that the costs referenced in this finding are unallowable, Cayuga Centers will address the matter with its primary funding agency as part of broader resolution of any unallowable costs. To the extent this finding asserts control failures, please see Cayuga Centers’ response to Findings 2024-005 and 006 above.

View Audit 401760

Finding 1215018 (2024-008)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the...

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the drawdown process generally, Cayuga Centers has established a review protocol requiring that draws include only qualified expenditures incurred or expected within three business days. All draw requests require dual approval from both finance and program staff. A centralized draw request log is being maintained, including supporting documentation and reconciliation records. With respect to Finding 2024-008, Cayuga Centers does not entirely agree with the auditors’ assertion that accrued vacation expense was improperly included in draw requests. Under certain circumstances, costs of paid time off may be treated as incurred based on PTO earned, rather than PTO-paid. See 2 C.F.R. § 200.431(b). Cayuga Centers will further evaluate this asserted finding with the grants management advisors described above. To the extent there may be any compliance discrepancy, Cayuga Centers will take further appropriate action.

View Audit 401760

Finding 1215017 (2024-007)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Cash Management Allowable Costs / Cost Principles

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the...

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of these asserted findings in conjunction with Findings 2024-005 and 006 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. With respect to the drawdown process generally, Cayuga Centers has established a review protocol requiring that draws include only qualified expenditures incurred or expected within three business days. All draw requests require dual approval from both finance and program staff. A centralized draw request log is being maintained, including supporting documentation and reconciliation records. With respect to Finding 2024-008, Cayuga Centers does not entirely agree with the auditors’ assertion that accrued vacation expense was improperly included in draw requests. Under certain circumstances, costs of paid time off may be treated as incurred based on PTO earned, rather than PTO-paid. See 2 C.F.R. § 200.431(b). Cayuga Centers will further evaluate this asserted finding with the grants management advisors described above. To the extent there may be any compliance discrepancy, Cayuga Centers will take further appropriate action.

View Audit 401760

Finding 1215016 (2024-006)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles Reporting Cash Management

This finding is, in part, due to a gap in adequate personnel and oversight within the Finance Department for a brief period of time. As stated above, Cayuga Centers has contracted for Chief Financial Officer and Controller services as a near-term measure to fill gaps and improve processes. Further, ...

This finding is, in part, due to a gap in adequate personnel and oversight within the Finance Department for a brief period of time. As stated above, Cayuga Centers has contracted for Chief Financial Officer and Controller services as a near-term measure to fill gaps and improve processes. Further, Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding in conjunction with Finding 2024-005 to ensure any perceived deficiencies are addressed to the satisfaction of Cayuga Centers’ primary federal funder. The new Finance Team leadership have reinstated use of the class system in our general ledger to allocate direct costs to specific programs and clearly separate non-reimbursable expenses. Monthly reconciliations will be performed to ensure qualifying costs align with cash draw requests. Accounting staff have or will receive targeted training on cost allocation principles and documentation standards to support this effort.

View Audit 401760

Finding 1215015 (2024-005)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding and address it accordingly. Cayuga Centers has also begun the process of working with its main federal funder regarding this item and will coordinate closely with that funder in res...

Cayuga Centers has engaged grants management advisors who will assist in evaluating the scope of this asserted finding and address it accordingly. Cayuga Centers has also begun the process of working with its main federal funder regarding this item and will coordinate closely with that funder in resolving it. As an immediate action step, Cayuga Centers is reinforcing training for all grant management personnel, emphasizing the distinction between allowable and unallowable costs. The Training Department is developing a virtual curriculum to issue to all required staff. A pre-approval process was introduced for all grant-funded expenditures, and program managers will be required to certify compliance before expenses are submitted for reimbursement.

View Audit 401760

Finding 1215013 (2024-003)

Material Weakness 2024

Cayuga Home for Children, Inc. D/b/a Cayuga Centers

NY

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Cayuga Centers has changed key leadership positions and contracted in the near-term for Chief Financial Officer and Controller services. The new leadership team is working transparently to resolve internal control issues asserted in the audit report. To prevent future instances of management overrid...

Cayuga Centers has changed key leadership positions and contracted in the near-term for Chief Financial Officer and Controller services. The new leadership team is working transparently to resolve internal control issues asserted in the audit report. To prevent future instances of management override, Cayuga Centers has implemented standardized procedures to ensure grant expenditures are properly classified in our financial system. Each transaction are supported by detailed documentation, including invoices, receipts, and grant-specific identifiers. Individuals responsible for grant oversight will undergo mandatory training to deepen their understanding of grant requirements, allowable costs, and reporting obligations. Additionally, Cayuga Centers is working to ensure open communication between staff and the Board. Under new leadership, the agency continues to enforce its Non-Retaliation Policy (Whistleblower). The Acting President’s office is establishing quarterly “Grant Compliance Forums” for employees to raise concerns related to grant administration.

View Audit 401760

Finding 1214965 (2024-002)

Material Weakness 2024

Ecumenical Social Action Committee, Inc.

MA

Reporting Allowable Costs / Cost Principles

Improve Controls over the Preparation of the Schedule of Expenditures of Federal of Awards Department’s Response: Management is in agreement with the recommendation and has updated their policy subsequent to year-end. Views of Responsible Offices and Corrective Action Plan: Management agrees with th...

Improve Controls over the Preparation of the Schedule of Expenditures of Federal of Awards Department’s Response: Management is in agreement with the recommendation and has updated their policy subsequent to year-end. Views of Responsible Offices and Corrective Action Plan: Management agrees with this and will implement the below to its financial policies and procedures manual: Post-Award Procedures - After an award has been made, the following steps shall be taken: 1.Verify the specifications of the grant or contract. The finance department shall review the terms, time periods, award amounts and expected expenditures associated with the award. A CFDA (Catalog of Federal Domestic Assistance) number shall be determined for each award. All reporting requirements under the contract or award shall be summarized. 2.Create new general ledger account numbers. New accounts shall be established for the receipt and expenditure categories in line with the grant or contract budget. 3.Gather documentation. A file is established for each grant or contract. The file contains the proposal, all correspondence regarding the grant or contract, the final signed award document and all reports submitted to the funding sources. 4.Management will prepare a SEFA and share with the auditor to determine when the schedule is presented fairly in all material respects in relation to the financial statements as a whole. Name of Responsible Person: Peg Drisko, CEO Projected Implementation Date: May 2026

View Audit 401734

Finding 1214775 (2024-003)

Material Weakness 2024

Black Mesa Community School

AZ

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Material Weakness

2024-003: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Noncompliance, Material Weakness Condition: The school lacked adequate internal controls over its accounting disbursements to ensure that a) all financial activities were properly processed and recorded and b...

2024-003: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Type of Finding: Noncompliance, Material Weakness Condition: The school lacked adequate internal controls over its accounting disbursements to ensure that a) all financial activities were properly processed and recorded and b) the School remained in compliance with federal requirements. Context: During our review of the school’s accounting records and internal controls, as well as through management inquiry, we noted the following: • For two of 25 accounts payable transactions tested out of the 15.044 grant, the School did provide adequate documentation to support the allowability of the expenditure. • For three of 25 accounts payable transactions tested out of the 15.046 grant, the School did provide adequate documentation to support the allowability of the expenditure. Repeat Finding: Repeated and modified. Action planned in response to the finding: The Principal will conduct an internal review of records management practices to verify that all accounts payable disbursements are properly supported. This evaluation will include random checks of purchase orders and their complete supporting documentation, once per month, to ensure accuracy, compliance, and integrity in financial operations. Keep all documents audit ready, at all times. Planned completion date for a corrective action plan: June 30, 2025 Name of the contact person responsible for corrective action: Marie Rose, Principal | Lynnette Greyeyes, Business Manager

View Audit 401513

Finding 1214708 (2024-004)

Material Weakness 2024

DEFENSORES DE LA CUENCA INC

MD

Allowable Costs / Cost Principles Cash Management Reporting

Corrective Action Plan: Management acknowledges that federal grant revenue was recorded based on reimbursement timing rather than when related expenditures were incurred. To address this, the organization will implement procedures to ensure grant revenue is recognized in accordance with accrual acco...

Corrective Action Plan: Management acknowledges that federal grant revenue was recorded based on reimbursement timing rather than when related expenditures were incurred. To address this, the organization will implement procedures to ensure grant revenue is recognized in accordance with accrual accounting principles, aligning revenue with the period in which eligible expenditures are incurred. A year-end cutoff review will be performed to identify and record any receivables for incurred but unreimbursed costs. Additionally, grant tracking schedules and reconciliation processes will be enhanced to ensure accurate and timely revenue recognition. Responsible Official: Abel Olivo, Executive Director, with support from the outsourced accounting firm Anticipated Completion Date: December 31, 2025

View Audit 401471

Finding 1214684 (2024-003)

Material Weakness 2024

City of Texas City, Texas

TX

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302 § 200.303

Duplicate Payments to Vendors Condition Duplicate vendor payments occurred due to inadequate segregation of duties and inconsistent invoice naming conventions. Corrective Action Plan The Accounts Payable unit will strengthen internal controls to prevent duplicate payments and ensure compliance with ...

Duplicate Payments to Vendors Condition Duplicate vendor payments occurred due to inadequate segregation of duties and inconsistent invoice naming conventions. Corrective Action Plan The Accounts Payable unit will strengthen internal controls to prevent duplicate payments and ensure compliance with federal cost principles. Actions include: • Enforcing segregation of duties within the AP workflow. • Implementing standardized invoice naming conventions. • Requiring secondary review for all grant-related invoices. • Conducting quarterly post-payment audits to detect and correct errors. • Implementing ERP system enhancements to flag potential duplicates. • Hiring an AP Manager to manage and improve the AP processes. Responsible Staff Chief Financial Officer (CFO) Target Completion Date June 30, 2026

View Audit 401408

Finding 1214670 (2024-002)

Material Weakness 2024

Access to Advanced Health Institute

WA

Allowable Costs / Cost Principles § 200.303

􀀫􀁎􀁓􀁉􀁎􀁓􀁌􀀅􀀗􀀕􀀗􀀙􀑛􀀕􀀕􀀖􀀟 Significant deficiency in internal controls over financial reporting related to the recognition of grant and contract receivables and inventory Contact Person NAME: Keeley Foley PHONE: 206.381.0883 E-Mail: keeley.foley@aahi.org Explanation and Specific Reasons for Disagreement with...

􀀫􀁎􀁓􀁉􀁎􀁓􀁌􀀅􀀗􀀕􀀗􀀙􀑛􀀕􀀕􀀖􀀟 Significant deficiency in internal controls over financial reporting related to the recognition of grant and contract receivables and inventory Contact Person NAME: Keeley Foley PHONE: 206.381.0883 E-Mail: keeley.foley@aahi.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned Access to Advanced Health Institute’s (AAHI’s) response to the recommendation: 1. Engage Escalon Financial Services to review/update policies and procedures for grant receivable recognition per GAAP (FASB ASC 958) and Uniform Guidance (distinguish unconditional versus conditional grants, proper cutoff/revenue recognition) 2. Implement quarterly independent review of year-end receivable balances and revenue entries by Escalon. 3. Conduct training for finance staff on GAAP grant recognition (completion tracked via signed attendance sheets) (Escalon is GAAP trained and certified) 4. Test 100% of material grant receivables at next fiscal year-end close for proper recognition (Ensure process is full proof and no deviations of process in prior fiscal year occurred) 5. In addition, AAHI will implement controls over recognition of inventory Responsible party: Escalon with Operations Director and Keeley Foley(oversight) Anticipated Completion Date May 2026 􀀫􀁎􀁓􀁉􀁎􀁓􀁌􀀅􀀗􀀕􀀗􀀙􀑛􀀕􀀕􀀗􀀟 Significant deficiency in internal control over compliance and compliance as it relates to allowable costs and activities Contact Person NAME: Keeley Foley PHONE: 206.381.0883 E-Mail: keeley.foley@aahi.org Explanation and Specific Reasons for Disagreement with the Audit Finding or That Corrective Action is not Required (if Applicable) No disagreement. Corrective Action Planned AAHI’s response to the recommendation: 1. Formalize written policies and procedures for allowable costs per 2CFR 200 Subpart E (necessary, 206.381.0883 222 5th Ave N, Seattle,WA 98109 www.aahi.org reasonable, allocable, documented). 2. Require pre-expenditure requisition approval by Principal Investigator (PI) for all grant-related expenses (tracked in project management system). 3. Mandate dual review and recertification of invoices and drawdowns: PI and Director of Operations (documented sign-off required before payment/submission) 4. Perform monthly compliance reconciliations (grant budget vs. actual expenditures) with variance resolution documented. 5. Deliver annual training, and otherwise as needed, to PIs and staff on allowable/unallowable costs (tracked via attendance and quiz scores above 80%) 6. Conduct quarterly internal monitoring of 25% sample of grant expenses for allowability and compliance. Responsible party: Keeley Foley (oversight), Director of Operations (daily enforcement), Escalon (support) Anticipated Completion Date May 2026

View Audit 401404

Finding 1214636 (2024-001)

Material Weakness 2024

Davis Citizens Coalition Against Violence

UT

Allowable Costs / Cost Principles § 200.302 § 200.403

Audit Finding: 2024-001 Non-Material Non-Compliance – Allowable Costs and Activities; 2024-002 Revenue Recognition – Material Weakness Corrective Actions: This plan outlines the steps to address the staffing shortage and implement necessary controls to ensure financial statement accuracy and complia...

Audit Finding: 2024-001 Non-Material Non-Compliance – Allowable Costs and Activities; 2024-002 Revenue Recognition – Material Weakness Corrective Actions: This plan outlines the steps to address the staffing shortage and implement necessary controls to ensure financial statement accuracy and compliance. Phase 1: Immediate Actions Prioritize Key Hires: The immediate priority is to recruit and hire a Controller with significant non-profit accounting experience. This individual will be crucial in designing and implementing the necessary internal controls. 1. Interim Support (If Needed): While searching for permanent staff, explore options for interim accounting support through a consulting firm or temporary staffing agency specializing in non-profit organizations. This can provide immediate assistance with critical tasks and help bridge the gap until permanent staff are in place and sufficiently trained. 2. Documented Job Descriptions: Develop detailed job descriptions for the Controller, Senior Accountant, and Staff Accountant positions. These descriptions should clearly outline the required qualifications, responsibilities, and reporting lines. Emphasis should be placed on experience with non-profit accounting principles (GAAP), fund accounting, and relevant regulations. 3. Recruitment Strategy: Implement a robust recruitment strategy that includes: ○ Posting job openings on relevant job boards (e.g., Idealist, LinkedIn, specialized non-profit job sites). ○ Networking with professional organizations (e.g., state non-profit associations, accounting professional groups). ○ Partnering with recruitment agencies specializing in non-profit finance. Phase 2: Staffing and Implementation 1. Hire Controller: Complete the recruitment process and hire a qualified Controller with proven non-profit accounting experience. 2. Hire Senior Accountant: Once the Controller is in place, begin the recruitment process for a Senior Accountant to support the Controller and manage day-to-day accounting operations. Experience with fund accounting and grant management is highly desirable. 3. Hire Staff Accountants: Recruit and hire the necessary number of Staff Accountants to handle transaction processing, reconciliations, and other accounting tasks. 4. Control Design and Implementation: The Controller, in collaboration with the Senior Accountant, will be responsible for designing and implementing the necessary internal controls. This includes: ○ Segregation of duties (e.g., authorization, custody, recording). ○ Approval processes for expenditures and journal entries. ○ Regular reconciliations of bank accounts and other key accounts. ○ Documentation of accounting policies and procedures. Phase 3: Review and Monitoring (Ongoing) 1. Training: Provide comprehensive training to all finance staff on non-profit accounting principles, internal controls, and the organization's specific policies and procedures. 2. External Review (Optional): Consider engaging an external accounting firm to review the implemented controls and provide recommendations for improvement. This can provide an independent assessment of the effectiveness of the controls. 3. Regular Monitoring: The Controller will be responsible for regularly monitoring the effectiveness of the internal controls and reporting any deficiencies to the Executive Director and the Board of Directors. 4. Policy Updates: The Controller will ensure that accounting policies and procedures are reviewed and updated regularly to reflect changes in regulations and best practices. Responsible Parties: ● Executive Director (Todd Hixson) : Overall responsibility for implementation of the plan. ● Board of Directors: Oversight and approval of the plan and budget. ● Controller: Responsible for designing, implementing, and monitoring internal controls. Timeline: Phases 1 and 2 were completed as of January 2025. As noted above, phase 3 is an ongoing process. Regular progress updates have been and will continue to be provided to the Executive Director, Finance Steering Committee, and the Board of Directors as appropriate. This Corrective Action Plan demonstrates Safe Harbor Crisis Center’s commitment to addressing the identified control deficiencies and strengthening its financial management practices. By implementing this plan, the agency will be better positioned to ensure financial accountability, transparency, and compliance in service of the mission.

View Audit 401337

Finding 1214622 (2024-001)

Material Weakness 2024

WABASH TELEPHONE COOPERATIVE INC

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Cash Management § 200.302 § 200.303

Finding 2024-001 Allowable Cost Principles and Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance Assistance Listing Number 21.029 While Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, we recognize the need for ...

Finding 2024-001 Allowable Cost Principles and Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance Assistance Listing Number 21.029 While Wabash currently maintains informal procedures for coding and reviewing invoices and payroll records, we recognize the need for a formalized, written policy governing expenditures charged to federal awards. To address identified material weaknesses, Wabash is committed to implementing a comprehensive written policy by June 30, 2026. This policy will formalize the coding, review, and reporting processes for all federal expenditures. Key improvements will include: • Enhanced Internal Controls: We will establish a clear segregation of duties to ensure oversight and accuracy. • Timely Reporting: We are refining our payroll allocation process. Previously, payroll expenditures were withheld pending budget verification, which occasionally led to reporting delays. New controls will ensure that all expenditures, including payroll, are reported within the required quarterly timeframes. • Monitoring: The Controller will oversee the development of these procedures and remain responsible for ongoing monitoring and compliance. These steps will ensure our financial practices meet federal standards and provide rigorous oversight of project funds. Contact person(s): Cheryl Gaither, Controller Justin Gephart, Chief Operating Officer

View Audit 401306

Finding 1214504 (2024-002)

Material Weakness 2024

Home Start INC

CA

Reporting Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.510

Management acknowledges that a formalized process to identify and track federal expenditures for SEFA preparation was not in place during the audit period. Steps have since been taken to improve tracking and reporting of federal expenditures throughout the year. With a stable accounting team in plac...

Management acknowledges that a formalized process to identify and track federal expenditures for SEFA preparation was not in place during the audit period. Steps have since been taken to improve tracking and reporting of federal expenditures throughout the year. With a stable accounting team in place since September 2024, management has increased oversight and accountability for grant coding and federal award identification. Additionally, the implementation of Blackbaud Financial Edge in FY2027 will allow for more precise tracking of funding sources, including the ability to segment federal and non-federal expenditures within programs and generate SEFA-ready reports. These improvements will enable the Organization to prepare a complete and accurate SEFA prior to the start of future audits and ensure compliance with Uniform Guidance requirements. Actions Taken - Established internal processes to identify and track federal expenditures throughout the fiscal year - Increased review procedures over grant coding and funding source classification - Assigned responsibility for SEFA preparation and review prior to audit fieldwork - Initiated implementation of Blackbaud Financial Edge to automate and enhance federal reporting capabilities

View Audit 401203

Finding 1214459 (2024-011)

Material Weakness 2024

City of Sycamore, Georgia

GA

Allowable Costs / Cost Principles

The City will design and implement controls to ensure that the costs of goods and services charged to federal awards are allowable and in accordance with the applicable cost principles.

View Audit 401171

Finding 1214458 (2024-010)

Material Weakness 2024

City of Sycamore, Georgia

GA

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

The City will design and implement controls to ensure that federal awards are expended only for allowable activities.

View Audit 401171

Finding 1214455 (2024-007)

Material Weakness 2024

City of Sycamore, Georgia

GA

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

The City has will develop written procedures for determining the allowability of costs in accordance with 2 CFR 200, Subpart E—Cost Principles and the terms and conditions of the Federal award.

View Audit 401171

Finding 1214333 (2024-002)

Material Weakness 2024

Access to Advanced Health Institute

WA

Allowable Costs / Cost Principles § 200.303

Significant deficiency in internal control over compliance and compliance as it relates to allowable costs and activities. Federal Agency: All awards within the Research and Development Cluster Program Title: All awards within the Research and Development Cluster Assistance Listing Number: All award...

Significant deficiency in internal control over compliance and compliance as it relates to allowable costs and activities. Federal Agency: All awards within the Research and Development Cluster Program Title: All awards within the Research and Development Cluster Assistance Listing Number: All awards within the Research and Development Cluster Award Number: All awards within the Research and Development Cluster Award Period: All awards within the Research and Development Cluster Criteria 2 U.S. Code of Federal Regulations (CFR) 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards Section 200.303 requires that each recipient of federal awards “Establish, document, and maintain effective internal control over the Federal award that provides reasonable assurance that the recipient is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.” Condition/Context for Evaluation During our audit, we tested nonpayroll costs charged to the federal awards for adherence to necessary compliance requirements and internal control over compliance requirements. Out of 25 sample selections, we noted the following related to seven sample items: - Five of seven sample items selected involved overcharges to the grants. All five showed management approval for the incorrect amounts. - One of seven sample items selected had no supporting documentation. - One of seven sample items had no management approval. Questioned Costs $1,790 Effect or Potential Effect AAHI may have charged unallowable or incorrect costs to the federal awards. Repeat Finding No. Recommendation We recommend AAHI implement the necessary internal controls to (1) ensure documentation is retained to support costs spent on federal awards and (2) ensure all costs are properly approved and for the correct amounts. Views of Responsible Officials of Auditee Management concurs with the finding and has provided the accompanying corrective action plan.

View Audit 400998

Finding 1214257 (2024-002)

Material Weakness 2024

Gary Public Transportation Corporation

IN

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

Finding 2024-002 Information on the federal program: Federal Agency: Federal Transportation Administration Pass-Through Entity: N/A Federal Program: Federal Transit Cluster Assistance Listing Number: 20.507 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs – Cost Principles...

Finding 2024-002 Information on the federal program: Federal Agency: Federal Transportation Administration Pass-Through Entity: N/A Federal Program: Federal Transit Cluster Assistance Listing Number: 20.507 Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs – Cost Principles Audit Findings: Material Weakness Criteria: 2 CFR 200.403 establishes principles and standards for determining costs for federal awards carried out through grants, cost reimbursement contracts, and other agreements with state and local governments. To be allowable, under federal awards, cost must meet certain criteria: a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. c) Be consistent with policies and procedures that apply uniformly to both federally financed and other activities of the non-Federal entity. d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally financed program in either the current or a prior period. g) Be adequately documented. h) Cost must be incurred during the approved budget period. Additionally, 2 CFR 200.303 indicates that non-Federal Entities receiving Federal awards must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the nonfederal entity is managing the Federal award in compliance with Federal statutes, regulations and terms and conditions of the Federal award. The Corporation should have controls in place to document that salaries and overtime paid with federal funds were allowable. Timecards supporting hours worked should be approved and pay rates reviewed. Condition and Context: A summary of allowable charges for the grant was prepared for submission. Within the sample of 42, we noted that 9 timecards for bus operators did not have documented review. Documented review was implemented in September 2024. All instances of the error were prior to September 2024. We also noted 1 timecard showed 2 hours more than reflected on the pay register, resulting in a net underpayment. Views of Responsible Officials and Planned Corrective Actions: Management acknowledges the finding. Each department is responsible for ensuring proper timecard records with approval are maintained. A documented review process for bus operators was implemented over timecard records in September 2025. Payroll is responsible for ensuring that the appropriate number of hours are paid to each employee. Additional review will be performed prior to issuance of pay checks to ensure that the appropriate number of hours are being paid.

View Audit 400977

Corrective Action Plans

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