Corrective Action Plans

Finding 1190773 (2024-001)

Material Weakness 2024

PA

Allowable Costs / Cost Principles Subrecipient Monitoring

Management Responses: We acknowledge that prior to this audit, CASA relied on summary-level expense reports from subrecipients under the PCCD grant and did not consistently verify underlying invoices. The established oversight also included the following efforts: 1) the individual previously respons...

Management Responses: We acknowledge that prior to this audit, CASA relied on summary-level expense reports from subrecipients under the PCCD grant and did not consistently verify underlying invoices. The established oversight also included the following efforts: 1) the individual previously responsible for invoicing did review submissions for reasonableness against the approved budget, 2) subrecipients were advised to maintain detailed back-up for all expenses, and 3) the Coalition Director regularly visited subrecipient sites to observe work being completed and to meet and observe personnel covered by the grant. However, we acknowledge this process did not meet the full requirements of the Uniform Guidance. While prior audits were not performed under Government Auditing Standards , management notes that the agency has received federal funding since 2016 with no history of previous management-related findings. The identified grant in this finding was a pilot project and the first time the agency has managed subrecipients. Corrective Actions Already Taken: CASA has engaged a new contracted accounting firm with a wider breadth of experience and expertise. CASA has completed an internal restructuring to provide increased opportunity for oversight and review of contracted financial services. CASA has adopted a new review protocol requiring verification of all supporting documentation for subrecipient reimbursements. The Operations Manager now performs a detailed review of invoices, approvals, and alignment with allowable costs prior to releasing funds. Planned Actions: Subrecipient Monitoring Policy: CASA will implement a policy immediately that includes: A standardized invoice review checklist (verifying vendor, date, amount, and allowability). Documentation of management approvals and sign-offs. Monitoring visits or virtual reviews for subrecipients by Coalition Director or Operations Director. Communication: CASA will issue written guidance to all subrecipients outlining documentation requirements and timelines.

View Audit 395075

Finding 1187255 (2024-003)

Material Weakness 2024

Town of Brookline

MA

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

Audit Finding Reference: 2024-003 Improve Internal Controls Over Procurement Planned Corrective Action: The Town will review and revise its procurement procedures to ensure that federal requirements under the Uniform Guidance are followed for all federally funded transactions. For future federally f...

Audit Finding Reference: 2024-003 Improve Internal Controls Over Procurement Planned Corrective Action: The Town will review and revise its procurement procedures to ensure that federal requirements under the Uniform Guidance are followed for all federally funded transactions. For future federally funded contracts, the Town will maintain documentation demonstrating adherence to Uniform Guidance procurement requirements, including appropriate justifications for exemptions. The Town will ensure program staff are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: February 2, 2026

View Audit 394853

Finding 1187253 (2024-006)

Material Weakness 2024

Town of Brookline

MA

Allowable Costs / Cost Principles § 200.430

Audit Finding Reference: 2024-006 Improve Documentation and Controls over Allowable Costs Planned Corrective Action: The Town will implement and enforce procedures to ensure all employees whose salaries or wages are charged to federal grants maintain and retain appropriate time and effort documentat...

Audit Finding Reference: 2024-006 Improve Documentation and Controls over Allowable Costs Planned Corrective Action: The Town will implement and enforce procedures to ensure all employees whose salaries or wages are charged to federal grants maintain and retain appropriate time and effort documentation, including timesheets for hourly staff and semi-annual certifications for salaried staff, in compliance with Uniform Guidance. Management has made staff aware of the Time and Effort reporting requirements associated with Federal grants and will work with grant managers and finance department staff to ensure this requirement is implemented during Fiscal 2026; on or about March 18th.

View Audit 394853

Finding 1187247 (2024-005)

Material Weakness 2024

Town of Brookline

MA

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

Audit Finding Reference: 2024-005 Improve Procurement Procedures Planned Corrective Action: The Town will revise its internal controls over procurement to ensure compliance with Uniform Guidance requirements, regardless of state law exemptions. The Town will ensure adequate documentation is retained...

Audit Finding Reference: 2024-005 Improve Procurement Procedures Planned Corrective Action: The Town will revise its internal controls over procurement to ensure compliance with Uniform Guidance requirements, regardless of state law exemptions. The Town will ensure adequate documentation is retained for all federally funded procurements, and that procurement staff and grant managers are trained on the distinction between federal and state procurement requirements. Planned Implementation Date of Corrective Action: Management has made staff aware of the Federal procurement requirements associated with Federal grants and will work with grant managers, finance and procurement department staff to ensure this requirement is implemented in fiscal year 2026; on or about March 18, 2026.

View Audit 394853

Finding 1187240 (2024-003)

Material Weakness 2024

Rebuilding Together South Sound

WA

Allowable Costs / Cost Principles Material Weakness

This is a reiteration of Finding 2024-002. Please refer to corrective action plan under Finding 2024-002. Management will review procedures and adopt a system to adequately document and retain approval of disbursements.

View Audit 394851

Finding 1182297 (2024-004)

Material Weakness 2024

The Order of Fishermen Ministry Head Start Program, Inc.

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

TOFMHS concurs with the finding. There was turnover in the finance department, moving forward TOFMHS will implement adequate and sufficient internal controls to ensure that approvals charged to the grant are reviewed and approved by authorized members of TOFMHS. Responsible Person: Fiscal Officer/Pr...

TOFMHS concurs with the finding. There was turnover in the finance department, moving forward TOFMHS will implement adequate and sufficient internal controls to ensure that approvals charged to the grant are reviewed and approved by authorized members of TOFMHS. Responsible Person: Fiscal Officer/Program Director Completion Date: January 1, 2025

View Audit 393724

Finding 1182052 (2024-002)

Material Weakness 2024

Summitview Child & Family Services

CA

Allowable Costs / Cost Principles § 200.302

Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice a...

Planned Corrective Action: The Organization will implement and reinforce a comprehensive system for retaining all invoices, payment records, and supporting documentation associated with federal awards. Additionally, the Organization will create and maintain a clear record retention policy. Invoice and Payment Documentation: • All invoices related to the federal program will be promptly reviewed and approved by the appropriate personnel to ensure they reflect allowable costs under the specific terms and conditions of the award. • Management will establish clear procedures for the proper recording and classification of payments, ensuring that they are linked directly to the corresponding federal program expenses. • All supporting documentation (e.g., purchase orders, contracts, receipts) will be retained in electronic formats within the accounting system, in accordance with the Organization’s record retention policy, ensuring availability for future audits or reviews. Retention and Accessibility: • The Organization will maintain a secure, organized filing system for all invoices and payments, ensuring that each record is easily accessible for audit purposes. This system will include electronic records that are stored in a centralized database, with restricted access to authorized personnel. • Retained invoices and payment documentation will be kept for the full duration required by federal regulations, typically for a period of at least seven years after the final expenditure report for the federal award has been submitted, or as otherwise required by the specific federal agency. Periodic Reviews and Monitoring: • To ensure ongoing compliance, Management will perform periodic reviews of federal program expenditures and documentation. This will include random sampling of invoices and payment records to confirm that they are complete, accurate, and in compliance with federal regulations. • In the event of any discrepancies or issues identified during these reviews, Management will take immediate corrective action to address the issue and prevent recurrence. By maintaining thorough records of all invoices and payments, the Organization aims to not only comply with federal audit requirements but also to ensure transparency, accountability, and sound financial management of federal funds.

View Audit 393401

Finding 1181895 (2024-002)

Material Weakness 2024

Athol-Royalston Regional School District

MA

Allowable Costs / Cost Principles § 200.302 § 200.403

Retain Supporting Documentation for Journal Entries (Material Weakness, Compliance Finding) Planned Corrective Action Effective March 1, 2026, the District implemented procedures requiring that all journal entries include appropriate supporting documentation prior to posting in the accounting system...

Retain Supporting Documentation for Journal Entries (Material Weakness, Compliance Finding) Planned Corrective Action Effective March 1, 2026, the District implemented procedures requiring that all journal entries include appropriate supporting documentation prior to posting in the accounting system. Supporting documentation can range from invoices, written explanations describing the purpose of the entry, and calculations. The accounting system has been changed so all entries have supervisory review and approval. The Business Offi ce has established a standardized review process to ensure journal entries affecting federal programs are properly supported and retained within the District’s fi nancial records. Documentation will be maintained electronically to ensure availability for audit and internal review. The Business Offi ce will also provide guidance to staff responsible for fi nancial reporting and grant accounting regarding the requirement to maintain adequate documentation for journal entries in accordance with Uniform Guidance fi nancial management requirements. Periodic internal reviews will be conducted to ensure compliance with these procedures. Name of Contact Person and Completion Date Nancy J. Konisky, Business Manager Completion Date: Implemented March 1, 2026

View Audit 393198

Finding 1181835 (2024-002)

Material Weakness 2024

Jacksonville Housing Authority

TX

Allowable Costs / Cost Principles HUD Housing Programs § 200.302

Establish dual authorization for all disbursements >$500. • Require approval documentation for all payments. • Monthly review of check registers and reconciliations by Board Treasurer or Board President. • Revise Finance Policy Manual to reflect new procedures.

View Audit 393101

Finding 1181620 (2024-008)

Material Weakness 2024

North Valley County Water and Sewer District

MT

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

The Board of Directors for the district will be monitoring all filing to be able to account for documentation available within the district. Also, there will be implementing document control procedures for all costs and invoices within the district.

View Audit 392890

Finding 1181459 (2024-007)

Material Weakness 2024

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

PA

Allowable Costs / Cost Principles Period of Performance Material Weakness § 200.403

U.S. Department of Health and Human Services • Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending da...

U.S. Department of Health and Human Services • Material Weakness in Internal Control over Compliance Community Service Block Grant – Assistance Listing No. 93.569 Condition: During our testing, we noted there were several salary expenditures charged to the grant based on the payroll period ending date, however the costs were incurred for the period 12/23/23 - 1/5/24, which the first nine days were prior to the start of the period of performance. Recommendation: The Organization should work with the federal agency to provide additional documentation or justification for the expenses, or to adjust the budget or funding limits to ensure that all expenses are within the approved period of performance. It is important to address any period of performance findings as soon as possible to avoid potential penalties or repayment obligations. The Organization should also review its process of entering invoices and payroll related expenses into the accounting software to ensure the correct period is used for federal expenditures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The Organization will strengthen internal controls over the recording of grant-related invoices and payroll expenditures by requiring expenses to be recorded based on the actual date services are incurred rather than invoice date or payroll period end date. Finance staff will be retrained on period-of-performance requirements for federal programs, and a secondary review will be implemented for all federal grant postings to verify proper timing prior to submission for reimbursement or drawdown. 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 June 30, 2025.

View Audit 392710

Finding 1181456 (2024-006)

Material Weakness 2024

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

PA

Allowable Costs / Cost Principles Eligibility School Nutrition Programs

Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.568 and 10.565 Condition: The Organization does not have formal procedures in place to determine the Seco...

Significant Deficiency in Internal Control over Compliance The Emergency Food Assistance Program (Administrative); Commodity Supplemental Food Program (Administrative)– Assistance Listing No. 10.568 and 10.565 Condition: The Organization does not have formal procedures in place to determine the Second Harvest Food Bank expenses incurred during the fiscal year that should be allocated to the TEFAP/CSFP administrative revenue received. The Organization has historically recognized revenue based on when cash is received which is not appropriate. Recommendation: We recommend the allocation of allowable costs and activities be completed at a minimum on a quarterly basis. Also, any direct expenses related to program activities should be recorded to the respectiveidentifying program fund number within the accounting software. The amount of revenue recognized for the programs should be reflected of the expenses incurred up to the administrative funds received from the respective funders. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: The organization will implement a standard allocation to be completed on a quarterly basis at the minimum. This process will be reviewed by management to ensure implementation. 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 June 2026.

View Audit 392710

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

Corrective Action Plans

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