Corrective Action Plans

Finding 1160254 (2024-004)

Material Weakness 2024

CA

Questioned Costs Allowable Costs / Cost Principles § 200.403

Strengthen compliance efforts and mitigate risk, staff will consult a qualified third-party professional before executing any transaction that may be unallowable, ensuring adherence to funding. If unallowable expenses are identified, staff will quickly coordinate with the appropriate state agency to...

Strengthen compliance efforts and mitigate risk, staff will consult a qualified third-party professional before executing any transaction that may be unallowable, ensuring adherence to funding. If unallowable expenses are identified, staff will quickly coordinate with the appropriate state agency to resolve issue.

View Audit 370633 Questioned Costs: $1

Finding 1160241 (2024-001)

Material Weakness 2024

City of Zillah

WA

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

Corrective action the auditee plans to take in response to the finding: The City will take the following corrective actions: 1. Enforce Policy 2021-05 – Staff will be required to follow existing procurement policy provisions for federally funded contracts. 2. Verification Procedures – For all federa...

Corrective action the auditee plans to take in response to the finding: The City will take the following corrective actions: 1. Enforce Policy 2021-05 – Staff will be required to follow existing procurement policy provisions for federally funded contracts. 2. Verification Procedures – For all federally funded contracts of $25,000 or more, the City will verify and document contractor status through: o Written contractor certifications, and/or o Inclusion of suspension/debarment clauses in contracts, and/or o Review of contractor status in SAM.gov before award. 3. Recordkeeping – The Clerk/Treasurer’s office will maintain centralized records of all verification documentation. 4. Staff Training – Finance and Public Works staff will receive refresher training on Policy 2021-05 and federal procurement requirements. 5. Oversight – The City Administrator will conduct quarterly reviews of procurement files to confirm compliance. Anticipated date to complete the corrective action: • Centralized documentation – Implemented immediately for all new federally funded contracts. • Staff training – To be completed by December 31, 2025 • Quarterly oversight reviews – Beginning Q1 2026.

View Audit 370630

Finding 1160221 (2024-004)

Material Weakness 2024

Transylvania County

NC

Allowable Costs / Cost Principles Reporting Significant Deficiency § 200.512

Finding 2024-004: Name of Contact Person: Meagan O’Neal Management Response: The new Finance Director, hired in October 2023, immediately began reviewing staff assignments to analyze for improvements in efficiency while keeping separation of duties secure, while also completing the FY23 audit. This ...

Finding 2024-004: Name of Contact Person: Meagan O’Neal Management Response: The new Finance Director, hired in October 2023, immediately began reviewing staff assignments to analyze for improvements in efficiency while keeping separation of duties secure, while also completing the FY23 audit. This review allowed restructuring tasks to improve efficiency and the ability to set up new processes. The finance director has utilized help from NC Association of County Commissioner staff as well as UNC School of Government courses to continue to update processes and improve upon the quality of data provided. The occurrence of Hurricane Helene and the Spring wildfires in Transylvania County impacted staff capacity to complete the FY24 audit however now that it is complete we will be diligently working to have FY25 information submitted quickly. Notes have been added to the process documents to ensure all steps are taken when submitting the data collection form to the Federal Audit Clearinghouse once future audits are completed by the firm. Proposed Completion Date: Immediately.

View Audit 370605

Finding 1160214 (2024-001)

Material Weakness 2024

Bighorn Valley Health Center, Inc.

WA

Special Tests & Provisions Allowable Costs / Cost Principles Material Weakness

Corrective action planned: In reviewing audit finding 2024-001, it was determined that the primary cause for the misapplication of the sliding fee was the need for increased training and oversight. One Health has since taken steps to enhance sliding fee policy and procedure training for all staff, w...

Corrective action planned: In reviewing audit finding 2024-001, it was determined that the primary cause for the misapplication of the sliding fee was the need for increased training and oversight. One Health has since taken steps to enhance sliding fee policy and procedure training for all staff, with a focus on Intake and Patient Financial Services staff. One Health also intends to review individual performance of staff by implementing peer and supervisory audits of sliding fee scale applications and data entry. Identification of consistent errors has led to enacting accountability measures to allow for additional coaching and follow-up. Additionally, One Health has reviewed EMR processes and functionality to ensure ease and clarity of data entry to eliminate opportunities for human error. Anticipated completion date: December 31, 2025 Contact person responsible for corrective action: Emily Faricy Associate Vice President - Finance

View Audit 370598

Finding 1160203 (2024-002)

Material Weakness 2024

City of Manhattan, Kansas

KS

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

Management’s Response/Corrective Action Plan (Unaudited): Management acknowledges the finding. For the transaction tested, the original contract was approved in 2021, and we initially intended to use the general fund as a source of payment. The City has reviewed and updated its procedures to require...

Management’s Response/Corrective Action Plan (Unaudited): Management acknowledges the finding. For the transaction tested, the original contract was approved in 2021, and we initially intended to use the general fund as a source of payment. The City has reviewed and updated its procedures to require that documentation behind the analysis of the type of procurement steps be saved in the contract file. Staff will be retrained on these requirements to ensure documentation is consistently maintained for all covered transactions in accordance with federal guidelines. Planned Completion Date: These modifications are being implemented immediately. Contact Person Responsible for Correction Action: Finance Director

View Audit 370568

Finding 1160191 (2024-017)

Material Weakness 2024

Town of Jonesboro

LA

Questioned Costs Allowable Costs / Cost Principles

The Town of Jonesboro acknowledges this audit finding and concurs with the conclusion that a duplicate payment occurred in connection with the use of $53,786 in funds from the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program. The duplicate payment resulted from the same expenditure ...

The Town of Jonesboro acknowledges this audit finding and concurs with the conclusion that a duplicate payment occurred in connection with the use of $53,786 in funds from the Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program. The duplicate payment resulted from the same expenditure being reimbursed by a second federal program that was not designated as a major program. While this incident was unintentional and due to a lack of centralized grant tracking at the time, the Town has taken corrective action to prevent such issues from occurring in the future. Specifically: 1. Implementation of a Grant Award Management System: The Town is currently deploying a formal grant tracking and reconciliation system that will provide centralized oversight of all grant awards, expenditures, and reimbursements. This system is designed to prevent overlapping or duplicative claims across funding sources and will be supported by enhanced documentation and review protocols. 2. Internal Controls and Policy Enhancements: In response to this finding, the Town has updated its grant management policies and internal accounting procedures to include specific verification steps prior to submitting reimbursement requests. These policies now require: o Cross-checking all grant reimbursements against prior or pending claims, o Documenting funding source allocation for each expenditure, o Requiring dual review by finance and grants administration staff. 3. Staff Training and Grant Oversight: Personnel involved in grant administration and finance have received and will continue to receive training on federal allowable cost principles under 2 CFR Part 200, Subpart E. The Town is committed to maintaining compliance with all federal funding requirements and is actively working to reinforce accountability and transparency in its use of public funds. The Town will coordinate with the appropriate federal and state authorities to resolve any remaining discrepancies and, if necessary, return funds that have been deemed ineligible or duplicated.

View Audit 370560 Questioned Costs: $1

Finding 1160150 (2024-002)

Material Weakness 2024

Sullivan County

NH

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

2024-002 Improve Controls and Documentation Over Reporting (Material Weakness – Compliance, Internal Control over Compliance) “During our testing of a sample of two of the quarterly expenditure reports utilizing the Governor’s Office for Emergency Relief and Recovery (GOFERR) funding, we noted the f...

2024-002 Improve Controls and Documentation Over Reporting (Material Weakness – Compliance, Internal Control over Compliance) “During our testing of a sample of two of the quarterly expenditure reports utilizing the Governor’s Office for Emergency Relief and Recovery (GOFERR) funding, we noted the following issues: • The Q1 report included $2,534,152 of expenditures that were attributable to a subsequent period as well as a typographical error in the cumulative total expenditure amount; • The Q2 report included $8,636,710 in duplicative expenditures that were also reported in Q1 as well as a typographical error in the cumulative total expenditure amount; and • Formula discrepancies were noted in both Q1 and Q2 reports, resulting in inaccurate calculations. During our testing of the annual project and expenditure report under the direct portion of ARPA funding we noted a material discrepancy between cumulative expenditures per the general ledger and the amount reported of $94,749. The County attributed these discrepancies to a transition to a new summary process designed to increase reporting efficiency. All reported expenditures were valid and appropriately documented based on testing over allowable costs.” Manager’s Statement of Concurrence or Nonconcurrence: The County recognizes there was discrepancy identified between the GOFERR reporting for the ARPA funding and the County’s general ledger. The discrepancy was a result of changes in reporting requirements and data entry errors that did not reflect an actual discrepancy of project costs or missing funds. The issue was used as an opportunity to improve the County’s internal financial tracking by having the Finance Department support the Facilities and Operations Department with an added reconciliation process to verify the reporting is accurate. The reporting requirements have been better clarified since the inception of the reporting model and seems more stabilized. Corrective Action: The worksheet used to track and calculate the data has been updated. Where possible, formulas have been simplified and streamlined to better match the reporting requirements and use corrected timeframes. The remnant data from earlier iterations that catered to earlier requirements, or understanding of those requirements has been removed. When general ledger data entry requests are delivered to the Finance Department they will be accompanied by the worksheet as supporting documentation so that an added reconciliation may be performed.

View Audit 370532

Finding 1160124 (2024-001)

Material Weakness 2024

Mount Vernon School District No. 320

WA

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

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal requirements for allowable activities. Name, address, and telephone of District contact person: Jennifer Larson, Executive Director of Finance 124 E. Lawrence Street Mou...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls and did not comply with federal requirements for allowable activities. Name, address, and telephone of District contact person: Jennifer Larson, Executive Director of Finance 124 E. Lawrence Street Mount Vernon, WA 98273 360-428-6110 Corrective action the auditee plans to take in response to the finding: The district concurs with the finding and has taken corrective action. The employee referenced in the findings is no longer employed by the district. Throughout the months-long investigation performed by OSPI, the district worked to implement changes in our internal controls to ensure strong oversight of Migrant Education Program (MEP) grant compliance, including the eligibility determination process. Changes to internal controls include: • A monthly audit of the families who were visited that month. • A trained program recruiter will conduct the eligibility interviews and home visits. • Recruiter will work with regional trained recruiter for support. • A spot check audit of students determined to be eligible district program director. • Monthly logs from staff identifying students they worked with and services provided. • Monthly meetings between MEP district director and MEP regional program manager to ensure ongoing grant compliance. • Monthly meetings with MEP Parent Advisory Committee for ongoing feedback of services provided. • Appropriate staff including the program director are required to attend Migrant grant training provided by OSPI. We thank OSPI and the Washington State Auditor’s Office for their work and collaboration. We will continue regular monitoring of the Migrant Education Program in the Mount Vernon School district to ensure compliance with all program requirements and only eligible students are being served. Anticipated date to complete the corrective action: August 31, 2025

View Audit 370525

Finding 1160043 (2024-001)

Material Weakness 2024

Gulf Coast Transit District

TX

Allowable Costs / Cost Principles Cash Management

Finding Number: 2024‐001 Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program; State Formula Grants for Rural Areas Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District ...

Finding Number: 2024‐001 Federal Program Name: Federal Transit Cluster Assistance Listing Numbers: 20.507, 20.526 State Program Names: State Urbanized Area Formula Program; State Formula Grants for Rural Areas Contact Person: Ted Ross, Executive Director Updated Corrective Action Plan: The District continues to strengthen its grant management framework through policy development and improved procedures. Actions to include: Improved documentation of grant expense allocation Updated purchasing procedures consistent with federal and state compliance expectations Enhanced tracking of expenditures to specific programs and funding streams These measures have been incorporated into the district’s comprehensive Finance and Administration Policy, with staff training to be ongoing. Certification The Gulf Coast Transit District affirms that all corrective actions noted above are actively corrected or are being addressed. Additional documentation or clarification will be provided to auditors upon request.

View Audit 370494

Finding 1160040 (2024-002)

Material Weakness 2024

Strasburg-Franklin Local School District

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

The District will review the process for identifying and reporting federal expenditures on the SEFA.

View Audit 370491

Finding 1159894 (2024-002)

Material Weakness 2024

City of Nashua

NH

Questioned Costs Period of Performance Subrecipient Monitoring § 200.308 § 200.309 § 200.403

Corrective Action Plan – Federal Funds Review and Processing Audit Finding Reference: Response to Finding 2024-002: Improvement Control Over Period of Performance for Federal Awards Name of Contact Person and Completion Date: Krystal De Gray, COO of Nashua School District 09-22-2025 Planned Correcti...

Corrective Action Plan – Federal Funds Review and Processing Audit Finding Reference: Response to Finding 2024-002: Improvement Control Over Period of Performance for Federal Awards Name of Contact Person and Completion Date: Krystal De Gray, COO of Nashua School District 09-22-2025 Planned Corrective Action: The Nashua School District acknowledges the finding related to the control over the period of performance for federal awards (Finding 2024-002). In response, the district will develop and implement a formal internal procedure to ensure that all purchases funded by federal awards are both placed and received within the established period of performance. This procedure will include appropriate review, documentation, and oversight to maintain compliance with federal grant regulations. To further strengthen internal controls, the Nashua School District will implement a procedure limiting purchases to occur no later than 15 days prior to the grant’s end date. Additionally, all necessary services must be received and completed prior to the expiration of the grant period. Mario Andrade Krystal De Gray Superintendent Chief Operating Officer

View Audit 370436 Questioned Costs: $1

Finding 1159877 (2024-002)

Material Weakness 2024

Lubbock County Hospital District D/b/a University Medical Center

TX

Questioned Costs Allowable Costs / Cost Principles

Finding 2024-002 Information on the federal program: Federal Program Name: Mental and Behavioral Health Education and Training Grants Federal Agency: U.S. Department of Health and Human Services Federal Assistant Listing and Title Number: 93.732 Award Year: January 1, 2024 to December 31, 2024 Crite...

Finding 2024-002 Information on the federal program: Federal Program Name: Mental and Behavioral Health Education and Training Grants Federal Agency: U.S. Department of Health and Human Services Federal Assistant Listing and Title Number: 93.732 Award Year: January 1, 2024 to December 31, 2024 Criteria or Specific Requirement: Activities Allowed/Unallowed and Allowable Costs/Cost Principles (Pub. L. No. 116-136, 134 Stat. 563 and Pub. L. No. 116-139, 134 Stat. 622 and 623) Condition: The District should only charge and be reimbursed by the grant for allowable expenditures based on the grant agreement. Correction Action Planned: We were using verbal guidance around meals, specifically page 84 of HHS Grants Policy Statement which states as follows under Consumer/ Provider Board Participation: “Allowable in accordance with applicable program regulations. When not specifically authorized by program regulations, only the following costs are allowable with OPDIV prior approval: The reasonable costs of necessary meals furnished by the recipient to consumer or provider participants during scheduled meetings if not reimbursed to participants as per diem or otherwise.” The conference in question was held outside some participants shift time so light refreshments were provided. However, in order to ensure compliance with the Notice of Award Terms and Conditions Grant Specific Term #5, the University Medical Center will not submit unallowable meal costs and provide refresher for existing grant Program Managers to ensure they understand the terms and conditions to avoid unallowable costs and discuss the terms and conditions with the HRSA Grants Management Specialist and Project Officer if questions arise. Contact Person (s) Responsible for Corrective Action: Aaron Davis, VP & Chief Experience Officer Anticipated Completion Date: The Corrective Action will be implemented by October 31, 2025 in response to the auditors’ recommendation.

View Audit 370418 Questioned Costs: $1

Finding 1159861 (2024-007)

Material Weakness 2024

Opportunities Credit Union

VT

Allowable Costs / Cost Principles HUD Housing Programs Internal Control / Segregation of Duties

Management acknowledges the oversight and agrees with the recommendation. At the time of the finding, the Credit Union had not established written policies and procedures specific to the administration of the CDFI ERP program, which was required under the grant agreement. However, this finding relat...

Management acknowledges the oversight and agrees with the recommendation. At the time of the finding, the Credit Union had not established written policies and procedures specific to the administration of the CDFI ERP program, which was required under the grant agreement. However, this finding relates to the pre-merger entity’s administration of the CDFI ERP program. Since the merger, the current Credit Union is no longer a member of the CDFI Fund and therefore does not participate in federal programs subject to these requirements. Accordingly, the development of written policies and procedures related to federal grant administration is no longer applicable. To address the finding: • The issue has been documented as part of merger due diligence. • Management has confirmed that no further actions are required, as the current Credit Union does not administer CDFI or federal grant programs. CU1 will prepare adequate policies and procedures if it becomes applicable in the future. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)

View Audit 370401

Finding 1159859 (2024-005)

Material Weakness 2024

Opportunities Credit Union

VT

Allowable Costs / Cost Principles

Management acknowledges the error and agrees with the recommendation to strengthen documentation controls. While written approval was ultimately obtained from CDFI to cover the full $412,728 in expenditures, the Credit Union recognizes that contemporaneous documentation should have been maintained p...

Management acknowledges the error and agrees with the recommendation to strengthen documentation controls. While written approval was ultimately obtained from CDFI to cover the full $412,728 in expenditures, the Credit Union recognizes that contemporaneous documentation should have been maintained prior to incurring costs above the allowable limit. It should be noted that this expenditure and related documentation issue occurred prior to the recent merger. Following the merger, the current Credit Union is no longer a member of the CDFI Fund, and therefore the CDFI ERP reporting and expenditure requirements are no longer applicable. To address the finding, CU1 has: • Obtained written approval from CDFI to retroactively authorize the full expenditures incurred. • Documented the issue and corrective steps as part of merger due diligence. As CDFI Fund membership and related restrictions no longer apply post-merger, no further corrective actions are necessary. Expected Completion Date – Completed Responsible Parties – Wendy Gorevan, CFO (FAFCU pre-merger) and Scott McDonald, CFO (post-merger)

View Audit 370401

Finding 1159800 (2024-003)

Material Weakness 2024

City of Akron, Ohio

OH

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.308 § 200.309 § 200.403

2024-003 The City charged costs that were incurred prior to the beginning of the period of performance of the grant. Helen Tomic, Long Range Planning Manager December 31, 2025 The City will implement control procedure to prevent the charging of costs before the period of performance.

View Audit 370339 Questioned Costs: $1

Finding 1159760 (2024-001)

Material Weakness 2024

Connecticut Harm Reduction Alliance, Inc.

CT

Allowable Costs / Cost Principles Cash Management Reporting

Management will continue to request invoices from vendors in a timely manner. In the event a vendor fails to provide such invoice management will make reasonably estimate of expense to be accrued at year-end.

View Audit 370326

Finding 1159731 (2024-002)

Material Weakness 2024

Seward Association for the Advancement of Marine Science

AK

Allowable Costs / Cost Principles Reporting Matching / Level of Effort / Earmarking § 200.303 § 200.430

To address the identified deficiency, SAAMS will revise its payroll procedures to require that all payroll batch reports consistently include employee name, program charged, amounts charged to each program, hours, and pay rate. A standardized reporting format will be developed to ensure completeness...

To address the identified deficiency, SAAMS will revise its payroll procedures to require that all payroll batch reports consistently include employee name, program charged, amounts charged to each program, hours, and pay rate. A standardized reporting format will be developed to ensure completeness and consistency of information. In addition, SAAMS will update its policies to clearly describe the review objectives and responsibilities of staff conducting payroll reviews. Training will be provided to relevant staff to ensure proper understanding and execution of the updated procedures. These measures will ensure payroll reviews are accurate, effective, and aligned with best practices. Completion Date: September 30, 2026 Responsible Person: Dr. Wei Ying Wong, CEO, SAAMS

View Audit 370314

Finding 1159690 (2024-003)

Material Weakness 2024

The Family Conservancy, INC

KS

Questioned Costs Allowable Costs / Cost Principles § 200.403

Corrective Action Plan Identifying Number: 2024-003 Finding: The Agency did not properly allocate indirect costs during the fiscal period in which the corresponding direct costs were incurred, resulting in an indirect cost rate exceeding the de minimis rate for a portion of the 2024 fiscal period. C...

Corrective Action Plan Identifying Number: 2024-003 Finding: The Agency did not properly allocate indirect costs during the fiscal period in which the corresponding direct costs were incurred, resulting in an indirect cost rate exceeding the de minimis rate for a portion of the 2024 fiscal period. Corrective Actions Taken or Planned: The Agency concurs with the finding. To correct the cause and ensure compliance with Uniform Guidance requirements for indirect costs, the following actions will be implemented: 1. Establish Written Indirect Cost Procedures – Develop and document procedures to ensure indirect costs are consistently calculated at the approved de minimis rate per the federal grant award on total direct costs during the performance period. 2. Implement Pre-Posting Review – Require a supervisory review of indirect cost calculations before charges are recorded to the general ledger and before grant reimbursements are submitted. We have implemented new procedures to ensure that indirect costs are included in each invoice for reimbursement. 3. Staff Training – Provide training for grants and finance staff on indirect cost requirements, the proper application of the de minimis rate, and reconciliation processes in accordance with 2 CFR 200.414(f). 4. Quarterly Reconciliations – Implement quarterly reconciliations of indirect costs applied to grants to confirm rates are applied correctly and consistently throughout the fiscal year. 5. Continuity Controls – Assign responsibility for indirect cost oversight to both a primary and a backup staff member to ensure consistency during periods of management turnover. Contact Person Responsible for Corrective Action: Fred Timberlake, Vice President of Finance Isha Martin, Controller/Grant Finance Manager Anticipated Completion Date: • New procedures: June 15, 2025 • Written procedures in place: December 31, 2025 • Staff training completed: January 31, 2026 • Supervisory review and reconciliations implemented: Beginning with January 2026 close

View Audit 370280 Questioned Costs: $1

Finding 1159689 (2024-002)

Material Weakness 2024

The Family Conservancy, INC

KS

Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Corrective Action Plan Identifying Number: 2024-002 Finding: The Agency did not verify that one particular vendor was not suspended or debarred when it entered into a contract with the vendor who received $25,000 or more in federal grant funds. Corrective Actions Taken or Planned: 1. Review of Vendo...

Corrective Action Plan Identifying Number: 2024-002 Finding: The Agency did not verify that one particular vendor was not suspended or debarred when it entered into a contract with the vendor who received $25,000 or more in federal grant funds. Corrective Actions Taken or Planned: 1. Review of Vendor Requirement Checks a formal review will be implement to review the procurement contract reviews and verification performed prior to any expenditures related to the contract are performed. 2. Training and Vendor Requirement Checks- Provide training to all procurement staff on federal grant compliance requirements, including performance and documentation of the suspension/debarment verification via SAM.gov prior to entering into a contract. 3. Ongoing Monitoring – The VP of Finance will provide updates to senior leadership and the Finance Committee. Contact Person Responsible for Corrective Action: Gino Taylor, Vice President of People, Culture, & Equity Fred Timberlake, Vice President of Finance Isha Martin, Controller/Grant Finance Manager Anticipated Completion Date: ● Written procedures in place: September 30, 2025 ● Staff training completed: October 31, 2025 ● Audit completion: December 31, 2025

View Audit 370280

Finding 1159688 (2024-001)

Material Weakness 2024

The Family Conservancy, INC

KS

Questioned Costs Allowable Costs / Cost Principles § 200.403

Corrective Action Plan Identifying Number: 2024-001 Finding: Expenditure was identified for one invoice with a 2023 service period that was improperly recorded, and reimbursed, as an expenditure in 2024, indicating improper expense recognition in accordance with US GAAP. Corrective Actions Taken or ...

Corrective Action Plan Identifying Number: 2024-001 Finding: Expenditure was identified for one invoice with a 2023 service period that was improperly recorded, and reimbursed, as an expenditure in 2024, indicating improper expense recognition in accordance with US GAAP. Corrective Actions Taken or Planned: The Agency concurs with the finding. To correct the cause and ensure compliance with 2 CFR 200.403(e), the following actions will be implemented: 1. Establish Written Cutoff Procedures – Formal written procedures will be developed for reviewing service dates and supporting documentation prior to posting expenditures in the general ledger. These procedures will specifically address Uniform Guidance period-of-performance requirements. 2. Implement Supervisory Review – All expenditures charged to federal awards will undergo supervisory review at period-end. The review will confirm that expenses are recorded in the proper performance period before submission for reimbursement. Effective June 2025, the Vice President of Finance and the Controller performed a retrospective review of 2024 expenses to confirm that they were allocated to the correct reporting period. This supervisory review has continued into the current reporting period with no exceptions noted. 3. Staff Training – Grants and finance staff will receive focused training on Uniform Guidance cost principles, proper expenditure cutoff, and documentation standards to ensure consistent application. Staff training will include review of the finding and leadership will highlight the importance of verifying the correct reporting period for each entry. 4. Continuity Controls – To address turnover risk, responsibility for cutoff procedures will be assigned to both a primary and a backup staff member to provide coverage and reduce errors caused by staff changes. 5. Ongoing Monitoring – The VP of Finance will review quarterly grant compliance checklists and provide updates to senior leadership and the Finance Committee. Contact Person Responsible for Corrective Action: Fred Timberlake, Vice President of Finance Isha Martin, Controller/Grant Finance Manager Anticipated Completion Date: • Management supervisory review procedures: June 15, 2025 • Written cutoff procedures in place: December 31, 2025 • Staff training completed: January 31, 2026

View Audit 370280 Questioned Costs: $1

Finding 1159641 (2024-003)

Material Weakness 2024

Town of Dauphin Island

AL

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.302

The Town will take immediate steps to further ensure that grant funds, especially those that include federal funds, will be maintained separately in a separate bank account when grants require such actions for compliance. The grant funds will be tracked separately in their own funds or cost centers ...

The Town will take immediate steps to further ensure that grant funds, especially those that include federal funds, will be maintained separately in a separate bank account when grants require such actions for compliance. The grant funds will be tracked separately in their own funds or cost centers using the new due-to due-from procedures. In addition, our staff is currently researching a variety of software programs in order to strengthen our in-house grant management procedures to maintain full compliance. The Town will also consider hiring additional personnel and/or soliciting the services of a professional grant manager to further assist with future grant opportunities, particularly those involving grant funds.

View Audit 370259

Finding 1159584 (2024-001)

Material Weakness 2024

Franklin County Technical School District

MA

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles § 200.308 § 200.309 § 200.403

Audit Finding Reference: 2024-001 Description of Finding: The audit revealed that grant expenditures were incurred outside the authorized performance period, resulting in non-compliance with grant regulations and potential cost disallowance. Planned Corrective Action • Conduct a comprehensive assess...

Audit Finding Reference: 2024-001 Description of Finding: The audit revealed that grant expenditures were incurred outside the authorized performance period, resulting in non-compliance with grant regulations and potential cost disallowance. Planned Corrective Action • Conduct a comprehensive assessment of existing procedures to identify gaps that led to noncompliance with grant regulations. • Ensure timely submission of grant applications. • Implement enhanced oversight and monitoring processes for all grant-related expenditures to ensure alignment with policy 2 CFR 200.1. • Maintain detailed documentation of all award dates and expenditures to provide a clear compliance record. • Ensure all documentation is easily accessible and systematically organized for audit purposes. • Ensure pre-award costs are allowable only to the extent they would have been allowable if incurred after the effective date and only with written approval from the Federal awarding agency (as per 2 CFR 200.458). • Establish a process for obtaining and documenting written approval for pre-award costs. • Provide comprehensive training on compliance with Uniform Grant Guidance to all relevant staff. • Review and update policies and procedures related to grant expenditures regularly to ensure they are current and compliant with federal regulations. • Assign accountability for monitoring and reporting compliance to specific roles within the organization. The Business Manager, Elizabeth Bouchard, will be responsible for implementing this plan beginning with the Fiscal Year 2026 grant cycle. As of September 2025, non-compliance issues have been identified and addressed, documentation has been maintained to track award dates, and training has been provided to designated roles within the District. In addition, procedures to maintain detailed documentation of all award dates and expenditures to ensure a clear compliance record have been shared with all District Administrators utilizing grant funds.

View Audit 370226 Questioned Costs: $1

Finding 1159572 (2024-002)

Material Weakness 2024

Toole County

MT

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

Finding 2024-002: Transit Grants. Federal Award Numbers: 113057, 113061, 113052, 113093 Response: Toole County on behalf of Northern Transit Interlocal will implement and set up different expenditure and revenue codes to identify the grants and the expenditure of the grant funds.

View Audit 370216

Finding 1159462 (2024-002)

Material Weakness 2024

City of Aledo

IL

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Period of Performance § 200.302

City of Aledo Program Specific Audit Recommendation 2024-001 We recommend that the Organization review the requirements of 2 CFR Section 200.302 to develop allowable cost, activity, and period of performance activities to be followed. Management Response: The organization recognizes the importance o...

City of Aledo Program Specific Audit Recommendation 2024-001 We recommend that the Organization review the requirements of 2 CFR Section 200.302 to develop allowable cost, activity, and period of performance activities to be followed. Management Response: The organization recognizes the importance of having written policies and procedures to ensure cost are allowed and reasonable for the federal program. To address this finding, the agency has implemented the following corrective actions:  Review requirements of 2 CFR Section 200.302 as it relates to internal controls and financial management  Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocation, efforts of personnel, fringe benefits and indirect charges for allowability, adherence to cost principles, accuracy, and completeness  Create documented policies and procedures that details how the grantee will review and approve invoices, cost allocations, efforts of personnel, fringe benefits and indirect charges to ensure they were incurred during the period of performance Responsible Staff: City Official Implementation Date: October 1,2025 90

View Audit 370207

Finding 1159461 (2024-005)

Material Weakness 2024

Wadena County

MN

Allowable Costs / Cost Principles Material Weakness

Medical Assistance – Assistance Listing No. 93.778 Recommendation: The County should ensure it has proper controls in place to document the review of all required reports for the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in...

Medical Assistance – Assistance Listing No. 93.778 Recommendation: The County should ensure it has proper controls in place to document the review of all required reports for the program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will enact a process to ensure all reports are received and approved prior to the reporting deadline. Name(s) of the contact person(s) responsible for corrective action: Heather Olson Auditor/Treasurer, Amie Gendron Administrative Services Supervisor Planned completion date for corrective action plan: December 31, 2025

View Audit 370195

Corrective Action Plans

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