Corrective Action Plans

Finding 1170541 (2023-008)

Material Weakness 2023

PA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

The County Human Services department noted that the service providers were paid at their negotiated rates agreed upon by contract terms, however no reconciliation was completed for the remainder eligible cost adjustments to the service providers for the fiscal year ended June 30, 2023. The County Hu...

The County Human Services department noted that the service providers were paid at their negotiated rates agreed upon by contract terms, however no reconciliation was completed for the remainder eligible cost adjustments to the service providers for the fiscal year ended June 30, 2023. The County Human Services department will complete the reconciliation of the service providers costs reports for the fiscal year ended June 30, 2024 before March 2025.

View Audit 383805

Finding 1169749 (2023-002)

Material Weakness 2023

City of Bay St. Louis, Mississippi

MS

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring

The City will continue to work with the grant administrator who is managing the grant for the funding agency. The Administration will only submit invoices once for reimbursement and identify which invoices are local funding versus grant funding to avoid this in the future.

View Audit 382844

Finding 1169431 (2023-002)

Material Weakness 2023

Comanche County Medical Center

TX

Questioned Costs Cash Management Reporting

We are in receipt of the Findings Required to be Reported by Government Auditing Standards, regarding Reporting. Management agrees with the finding. After correcting the calculation of expenses to include reimbursement from other sources, the Hospital still has sufficient lost revenues and expenses ...

We are in receipt of the Findings Required to be Reported by Government Auditing Standards, regarding Reporting. Management agrees with the finding. After correcting the calculation of expenses to include reimbursement from other sources, the Hospital still has sufficient lost revenues and expenses to cover the amount of provider relief funding received. Management will perform a detailed analysis of the reporting requirements in accordance with the final guidelines set by HRSA for future reporting periods. As deemed necessary, the Hospital will modify policies and procedures over federal grant reporting The CFO, Hong Wade, will be responsible to ensure this is accomplished. The corrective action plan will be implemented by December 31, 2025.

View Audit 382372

Finding 1168849 (2023-004)

Material Weakness 2023

City of Upper Sandusky

OH

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.302 § 200.328 § 200.329

The City will work to ensure all reports for grant funding are completed.

View Audit 381205

Finding 1168343 (2023-006)

Material Weakness 2023

City of Abbeville, Georgia

GA

Cash Management Matching / Level of Effort / Earmarking § 200.302 § 200.305

The City will develop written procedures to implement the requirements of 2 CFR § 200.305 Payment.

View Audit 380157

Finding 1168060 (2023-003)

Material Weakness 2023

Marshfield Clinic Health System, Inc.

WI

Questioned Costs Allowable Costs / Cost Principles Cash Management § 200.303

Finding 2023-003 Name of Contact Person: Debra Hansen, Finance Project Manager – Grants and Gifts Corrective Action Plan: Effective January 1, 2025, MCHS, Inc was acquired by Sanford Health. MCHS grants accounting and grants management staff joined the Sanford Health’s Office of Grants team by June ...

Finding 2023-003 Name of Contact Person: Debra Hansen, Finance Project Manager – Grants and Gifts Corrective Action Plan: Effective January 1, 2025, MCHS, Inc was acquired by Sanford Health. MCHS grants accounting and grants management staff joined the Sanford Health’s Office of Grants team by June 2025 and have been trained and have fully implemented Sanford Health procedures by September 2025, such that the Sanford Health system of controls now extend to MCHS. Specifically with these changes, grants management and accounting duties have also transitioned to the MCHS grant team which extends Sanford Health’s systems of control to MCHS to ensure accurate and timely completion of the Schedule. Completion Date: September 30, 2025.

View Audit 379692

Finding 1168045 (2023-002)

Material Weakness 2023

Marshfield Clinic Health System, Inc.

WI

Allowable Costs / Cost Principles Cash Management Significant Deficiency § 200.303

Finding 2023-002 Name of Contact Person: Debra Hansen, Accounting Manager – Grants and Gifts Corrective Action Plan: Management concurs with the recommendation and will collaborate with Travel Department and other Administrative staff to strengthen controls and implement supervisory review and docum...

Finding 2023-002 Name of Contact Person: Debra Hansen, Accounting Manager – Grants and Gifts Corrective Action Plan: Management concurs with the recommendation and will collaborate with Travel Department and other Administrative staff to strengthen controls and implement supervisory review and documented approval of employee reimbursed expenditures charged to externally sponsored programs. It can be noted that, subsequent to sample testing, the one transaction in question was reviewed by Management and deemed an allowable cost.Completion Date: December 31, 2024

View Audit 379692

Finding 1167797 (2023-001)

Material Weakness 2023

Hearth Homes of Waterbury, INC

CT

Questioned Costs Cash Management HUD Housing Programs

U.S. Department of Housing & Urban Development 20 Church Street, 10th floor Hartford, CT 06103 Elderly Housing Management, Inc. respectfully submits the following corrective action plan for Hearth Homes of Waterbury, Inc. (HUD PROJECT NO. Ol 7-EE108) year ended June 30, 2023, which was audited by: B...

U.S. Department of Housing & Urban Development 20 Church Street, 10th floor Hartford, CT 06103 Elderly Housing Management, Inc. respectfully submits the following corrective action plan for Hearth Homes of Waterbury, Inc. (HUD PROJECT NO. Ol 7-EE108) year ended June 30, 2023, which was audited by: Bailey, Moore, Glazer, Shaefer & Proto LLP 16 Lunar Drive Woodbridge, CT 06525 The sole finding from the 6/30/2023 schedule of findings and questions costs is discussed below and numbered consistently with the numbers assigned in the schedule. FINDINGS- FINANCIAL STATEMENT AUDIT NONE FINDINGS - FEDERAL AW ARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Finding number 2023-001: 14.157 Supportive Housing for the Elderly Condition: The Project requested and received approval for reimbursement of the same invoice twice. Recommendation: Funds totaling $4,134 be returned to the replacement reserves as soon as possible. Action Taken: On November 25, 2025, a check in the amount of $4,134.00 was cut from the operating account. The funds have subsequently been returned to the replacement reserve account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please call Sabine Cox at (203-230-4809 ext. I 005)

View Audit 379091

Finding 1167719 (2023-004)

Material Weakness 2023

Defensewerx

FL

Cash Management

We agree with the recommendations offered and at the time of this report have established updated policies and procedures to address the finding while considering appropriate measures for operating programs that our government partners require to be on a cost reimbursement basis. We have addressed t...

We agree with the recommendations offered and at the time of this report have established updated policies and procedures to address the finding while considering appropriate measures for operating programs that our government partners require to be on a cost reimbursement basis. We have addressed this finding to our government partners. The majority of our government partners fund in monthly or quarterly increments. Periodically we update our government partners on program funds that have been used or those funds that are excess.

View Audit 378959

Finding 1167392 (2023-008)

Material Weakness 2023

State of Kosrae

FM

Cash Management

Finding 2023-008: This is for Pohnpei Community Health Centers. 1) For 2 of 2 items tested. We noted that total expenditures reported in documentary support submitted by the State for drawdown requests do not match the initial amounts requested, approved, and received by the awarding agency. We are ...

Finding 2023-008: This is for Pohnpei Community Health Centers. 1) For 2 of 2 items tested. We noted that total expenditures reported in documentary support submitted by the State for drawdown requests do not match the initial amounts requested, approved, and received by the awarding agency. We are aware that the expenditure reports furnished to us are not the originals that would have accompanied the State’s initial request for reimbursement from the awarding agency. It does not appear that the original supporting expenditure reports were retained. 2) The State does not appear to have a policy or adopted standard methodology for monitoring 93.224 programmatic cash needs and scheduling regular drawdowns. Root Cause Analysis 1) The State’s documentary retention controls over programmatic drawdowns need improvement 2) The State has not established a policy or standard operating procedure for monitoring 93.224 programmatic cash needs and scheduling regular drawdowns. Corrective Actions 1) Strengthen its controls over documentary retention for drawdowns. Retain expenditure reports for the basis of drawdowns at the time of filing and ensure there is appropriate explanatory documentation retained for any special reconciling items. 2) Establish clear policies and procedures for monitoring cash needs, performing drawdowns, and retaining documentation of drawdowns. Responsible Parties For CAP 1, Director of DOTA and the Chief of Finance For CAP 2, Director of DOTA and the Chief of Finance Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.

View Audit 378399

Finding 1167385 (2023-004)

Material Weakness 2023

State of Kosrae

FM

Cash Management Special Tests & Provisions Subrecipient Monitoring

Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision...

Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision. For 11 (or 23%) of 49 personnel records tested under the Compact Sector Education and Supplemental Education grants, no documentation was available to show that the annual performance evaluation had been performed. Root Cause Analysis • For advance payments, either concurrence was not obtained, or documentation was not retained; and a lack of familiarity with specific grant conditions may have contributed to the noncompliance. • For evaluations, documentation retention controls over personnel files were inadequate. Corrective Actions • For the health grants, if advance payments are necessary, the State should (a) use general fund advances with later reimbursement; (b) establish a letter of credit; or (c) obtain prior OIA concurrence. • For the Education and Supplemental Education grants, the State should strengthen controls to ensure annual evaluations are completed and retained in personnel files. Responsible Parties For bullet point one: Director of Health and his administrative officers Director of DOTA, certification and payable section For bullet point two: Director of Education and Personnel Managers Timeline Verification of Effectiveness Conduct regular assessments to ensure the effective implementation of the aforementioned action plans.

View Audit 378399

Finding 1166940 (2023-014)

Material Weakness 2023

State of Kosrae

FM

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

• Strengthen monitoring controls to verify period of performance, including obligation/incurrence and liquidation timelines. • Collaborate with grantors to clarify and document allowable liquidation periods for drawdowns. • Implement systematic filing of supporting documents for easy retrieval. • No...

• Strengthen monitoring controls to verify period of performance, including obligation/incurrence and liquidation timelines. • Collaborate with grantors to clarify and document allowable liquidation periods for drawdowns. • Implement systematic filing of supporting documents for easy retrieval. • Note: Drawdowns conducted in close collaboration with grantors, confirming compliance with agreed terms. 9/30/2026 Ms. Senny Phillip, Asst. Secretary of Investment & International Financing Email: senny.phillip@gov.fm

View Audit 377993

Finding 1166939 (2023-013)

Material Weakness 2023

State of Kosrae

FM

Cash Management

• Review all files for completeness before submission to auditors starting FY2024 audit onward. • Enhance file organization for deeper reviews and systematic access to drawdown reports, invoices, and payments. • Note: Re-review located >90% of cited "missing" documents; underlying support was availa...

• Review all files for completeness before submission to auditors starting FY2024 audit onward. • Enhance file organization for deeper reviews and systematic access to drawdown reports, invoices, and payments. • Note: Re-review located >90% of cited "missing" documents; underlying support was available. Management believed all requested files were provided. 9/30/2026 Ms. Christina Elnei, Asst. Secretary of National Treasury Email: christina.elnei@dofa.gov.fm

View Audit 377993

Finding 1166937 (2023-020)

Material Weakness 2023

State of Kosrae

FM

Cash Management Subrecipient Monitoring § 200.208 § 200.305

• Review all files for completeness before submission to auditors starting FY2024 onward. • Enhance systematic filing and accessibility of drawdown reports and supporting documentation. • Note: Re-review located >90% of cited "missing" documents; underlying support was available. Tagging is not mand...

• Review all files for completeness before submission to auditors starting FY2024 onward. • Enhance systematic filing and accessibility of drawdown reports and supporting documentation. • Note: Re-review located >90% of cited "missing" documents; underlying support was available. Tagging is not mandatory. 12/15/25 (SPAF submitted) / Ongoing 09/30/26 Ms. Christina Elnei, Asst. Secretary of National Treasury Email: christina.elnei@dofa.gov.fm

View Audit 377993

Finding 1166493 (2023-008)

Material Weakness 2023

County of Plumas

CA

Subrecipient Monitoring Cash Management Reporting § 200.327 § 200.328

Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Compliance) We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Management's Response: The County concurs with the fi...

Epidemiology and Laboratory Capacity for Infectious Diseases (ELC) (Compliance) We recommend that management establish and enforce procedures to ensure all required federal financial and progress reports are submitted by the applicable due dates. Management's Response: The County concurs with the findings; Responsible Individual: Nicole Reinert, Public Health Director; Corrective Action Plan: Administrative staff will schedule out all required report dates in the Outlook calendar at least three weeks before the due date to keep responsible parties informed of deadlines. These set reminders will ensure timely submissions. The Department Head will review the submission process to eliminate congested workflow to ensure efficiency and identify any tasks that can be automated or improved. Regular check-ins will take place to discuss the status of ongoing reports.; Anticipated Completion Date: June 30, 2026.

View Audit 377492

Finding 1166286 (2023-003)

Material Weakness 2023

Hill Country Community Clinic, Inc.

CA

Cash Management Questioned Costs

Current leadership and Management has implemented robust policies and procedures to ensure compliance with federal drawdown requirements. Currently, all drawdowns are based on 1/12th of the approved annual budget and are fully supported by actual expenditures recorded in the General Ledger. These ex...

Current leadership and Management has implemented robust policies and procedures to ensure compliance with federal drawdown requirements. Currently, all drawdowns are based on 1/12th of the approved annual budget and are fully supported by actual expenditures recorded in the General Ledger. These expenditures exceed the amount of the monthly drawdown, ensuring we are not drawing funds in advance. Previous acceleration of drawdowns in prior years was not aligned with best practices and stemmed from poor cash flow management and inadequate internal controls. Our corrective action plan directly addresses these issues through strengthened oversight and improved fiscal discipline. Furthermore, in alignment with the Department of Health and Human Services’ “Defend the Spend” (DOGE) initiative, all drawdowns are now required to be substantiated by actual, documented expenses reflected in the General Ledger.

View Audit 377361

Finding 1165680 (2023-022)

Material Weakness 2023

City of Jackson, Mississippi

MS

Cash Management Subrecipient Monitoring Significant Deficiency

Action Taken: The City has implemented new policies and procedures regarding grant reimbursements including, but not limited to, the creation of a grants unit. All activities regarding reimbursements are required to be reviewed and approved by a designee of the City’s CFO and other employees as iden...

Action Taken: The City has implemented new policies and procedures regarding grant reimbursements including, but not limited to, the creation of a grants unit. All activities regarding reimbursements are required to be reviewed and approved by a designee of the City’s CFO and other employees as identified. In addition, any project associated with outside funding has gone through or will go through a reconciliation process to evaluate its current standing, including all related receivables and payables, and will continue to do so monthly. The City is working to ensure all invoices are paid within a timely manner of the related award advances and according to application of Federal and State regulations.

View Audit 376388

Finding 1164633 (2023-003)

Material Weakness 2023

Net Treatment Services, Inc. D/b/a Net Community Care

PA

Questioned Costs Student Financial Aid Cash Management

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E & Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing Numbers: 93.658 & 93.645 Federal Award Identification Number and Year: 21-20016 (2023) & 21-20017 (2023) Award Period: J...

Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Foster Care Title IV-E & Stephanie Tubbs Jones Child Welfare Services Program Assistance Listing Numbers: 93.658 & 93.645 Federal Award Identification Number and Year: 21-20016 (2023) & 21-20017 (2023) Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Material Weakness in Internal Control over Compliance and Cash Management Recommendation: We recommend that management ensure that all invoices are based on actual expenses incurred and that there is a review an approval process of invoices before submission. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Aciton take in response to finding: Management has implemented a policy which requires each invoice to be based only on actual expenses incurred for the period and prohibits the use of a straight-line calculation to draw down funds. Invoices are also approved by the CFO prior to submission for reimbursement. Name of contact person responsible for corrective action: Regan Kelly, CEO of NorthEast Treatment Cetners, Inc. (215) 451-7000 Planned completion date for corrective action plan: January 31, 2024

View Audit 374235 Questioned Costs: $1

Finding 1163587 (2023-007)

Material Weakness 2023

SEMILLITAS DE AMOR INC

PR

Cash Management Allowable Costs / Cost Principles § 200.305

Finding 2023-007 – Payroll and Cash Management Deficiencies Responsible official: Executive Director and Accountants Corrective action planned: Management acknowledges that the same payroll and cash management deficiencies identified in the 2023 audit also occurred during 2024 and part of 2025. Spec...

Finding 2023-007 – Payroll and Cash Management Deficiencies Responsible official: Executive Director and Accountants Corrective action planned: Management acknowledges that the same payroll and cash management deficiencies identified in the 2023 audit also occurred during 2024 and part of 2025. Specifically, when federal cash balances were insufficient, payroll was paid temporarily from private funds, followed by the issuance of federal checks to employees for reimbursement purposes. During the 2025 audit, management recognized this as a recurring and systemic deficiency. A formal Cash Management and Interfund Transfer Policy is now being drafted and will be approved by the Board by February 2026. This policy will require: 1. Payroll to be processed directly from the federal account when possible. 2. Temporary transfers from private funds to be documented as interfund advances, with full repayment recorded upon reimbursement. 3. Prohibition of issuing duplicate payroll checks to employees. 4. Reconciliation of all interfund transfers within ten (10) business days after reimbursement. The organization will also implement a dual-authorization process for interfund transactions and establish a monthly reconciliation checklist to be completed by accounting staff and reviewed by the Executive Director. Monitoring: Monthly payroll and cash reconciliations will be reviewed by the Executive Director, and External Accountant. Evidence of reconciliations and approvals will be retained for audit purposes. Target completion date: March 31, 2026 Status: New finding – corrective actions in process.

View Audit 373330

Finding 1163337 (2023-008)

Material Weakness 2023

State of Kosrae

FM

Cash Management

Finding 2023-008: This is for Pohnpei Community Health Centers. 1) For 2 of 2 items tested. We noted that total expenditures reported in documentary support submitted by the State for drawdown requests do not match the initial amounts requested, approved, and received by the awarding agency. We are ...

Finding 2023-008: This is for Pohnpei Community Health Centers. 1) For 2 of 2 items tested. We noted that total expenditures reported in documentary support submitted by the State for drawdown requests do not match the initial amounts requested, approved, and received by the awarding agency. We are aware that the expenditure reports furnished to us are not the originals that would have accompanied the State’s initial request for reimbursement from the awarding agency. It does not appear that the original supporting expenditure reports were retained. 2) The State does not appear to have a policy or adopted standard methodology for monitoring 93.224 programmatic cash needs and scheduling regular drawdowns. Root Cause Analysis 1) The State’s documentary retention controls over programmatic drawdowns need improvement 2) The State has not established a policy or standard operating procedure for monitoring 93.224 programmatic cash needs and scheduling regular drawdowns. Corrective Actions 1) Strengthen its controls over documentary retention for drawdowns. Retain expenditure reports for the basis of drawdowns at the time of filing and ensure there is appropriate explanatory documentation retained for any special reconciling items. 2) Establish clear policies and procedures for monitoring cash needs, performing drawdowns, and retaining documentation of drawdowns. Responsible Parties For CAP 1, Director of DOTA and the Chief of Finance For CAP 2, Director of DOTA and the Chief of Finance Timeline Verification of Effectiveness Conduct regular assessments to ensure the implementation of the aforementioned action plans.

View Audit 372843

Finding 1163330 (2023-004)

Material Weakness 2023

State of Kosrae

FM

Cash Management Special Tests & Provisions Subrecipient Monitoring

Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision...

Finding 2023-004: For 1 (or 1%) of 60 transactions tested, aggregating $1,187,753 out of $19,516,462 in program expenditures, the State made an advance payment using sector grant funds. No documentation was provided to evidence prior grantor agency concurrence to waive the specific special provision. For 11 (or 23%) of 49 personnel records tested under the Compact Sector Education and Supplemental Education grants, no documentation was available to show that the annual performance evaluation had been performed. Root Cause Analysis • For advance payments, either concurrence was not obtained, or documentation was not retained; and a lack of familiarity with specific grant conditions may have contributed to the noncompliance. • For evaluations, documentation retention controls over personnel files were inadequate. Corrective Actions • For the health grants, if advance payments are necessary, the State should (a) use general fund advances with later reimbursement; (b) establish a letter of credit; or (c) obtain prior OIA concurrence. • For the Education and Supplemental Education grants, the State should strengthen controls to ensure annual evaluations are completed and retained in personnel files. Responsible Parties For bullet point one: Director of Health and his administrative officers Director of DOTA, certification and payable section For bullet point two: Director of Education and Personnel Managers Timeline Verification of Effectiveness Conduct regular assessments to ensure the effective implementation of the aforementioned action plans.

View Audit 372843

Finding 1162745 (2023-004)

Material Weakness 2023

Consortium of Universities for the Advancement of Hydrologic Science, Inc.

MA

Cash Management § 200.305 § 200.35

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Certain 2023 draws were processed as advances outside grant guidelines, although these draws were properly recorded as advances payable...

Statement of Concurrence or Nonconcurrence: CUAHSI agrees with the finding and recommendation. CUAHSI Corrective Action: Action by CUAHS! impacting audit year 2023: Certain 2023 draws were processed as advances outside grant guidelines, although these draws were properly recorded as advances payable in the accounting records. Corrective actions to processes and responsibilities impacting subsequent years: CUAHSI considers this finding resolved. A written drawdown procedure is now in place, requiring two-tier preparation and review, and, for working-capital advances, written approval from the prime funder. When the non-compliance was identified, CUAHSI suspended all NSF draws (late March 2023) until new controls were implemented. On 15 June 2023, CUAHSI completed its first draw under the revised policy. Name of Contact Person: • Jordan S Read, Chief Executive Officer • Telephone: (339)933-4660 • Email: jread@cuahsi.org Projected Completion Date: NA; is complete

View Audit 372370

Finding 1162341 (2023-003)

Material Weakness 2023

School Board City of Richmond

VA

Subrecipient Monitoring Cash Management Reporting

Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency...

Views of Responsible Officials and Planned Corrective Action: According to Appendix: American Rescue Plan CSLFRF HVAC Replacement and Improvement Grant Assurances of the 2021 CSLFRF HVAC Application it is stated the LEA/grantee assures: IX. It will submit such reports to the state educational agency as the state educational agency and Secretary may require to enable the state educational agency and the Secretary to perform their duties under the program; The LEA has also submitted an official correspondence to the Auditors from the Commonwealth of Virginia Department of Education’s Director of the Office of Federal Pandemic Relief Programs stating the following: On April 25, 2023, the Virginia Department of Education conducted monitoring to ensure that certain federally funded programs and activities supported with Elementary and Secondary School Emergency Relief (ESSER) formula grants; ESSER and Governor’s Emergency Education Relief (GEER) state setaside grants; and Coronavirus State and Local Fiscal Recovery Fund (CSLFRF) HVAC grants were implemented as stipulated by law. These federally funded programs were reviewed as operated by Richmond City Public Schools. Furthermore, RPS is a subrecipient. As such it is our stance that RPS was not required to create or submit quarterly financial activity reports to US Treasury. We were also not required to submit quarterly financial reports to the recipient (i.e. the Commonwealth of Virginia). Instead, RPS regularly submitted expenditures for reimbursement to VDOE on a nearly monthly basis via OMEGA. We also maintained financial records (invoices, GL transactions) via AS400 and LINQ and conducted annual single audits as required by the Single Audit Act & 2 CFR part 200, subpart F. We also complied with all monitoring activities conducted by VDOE. In turn, VDOE (the award recipient) used these artifacts to create and submit its quarterly financial reports to US Treasury, as required by statute. For more evidence of this "passthrough" structure of reporting, see the attached SLFRF Compliance and Reporting Guidance published by US Treasury and Updated October 2025 Part 2 Section B (p. 21-22) for a detail of which entities are required to submit quarterly reports. The following recipients are required to submit quarterly Project and Expenditure Reports: - States and U.S. territories - Tribal governments that are allocated more than $30 million in SLFRF funding - Metropolitan cities and counties with a population that exceeds 250,000 residents Coronavirus State and Local Fiscal Recovery Funds C - Metropolitan cities and counties with a population below 250,000 residents that are allocated more than $10 million in SLFRF funding - NEUs [Non-Entitlement Units of Government] that are allocated more than $10 million in SLFRF funding RPS does not fall into any of the aforementioned categories. We humble ask that you reconsider this finding.

View Audit 372148

Finding 1162216 (2023-001)

Material Weakness 2023

Northeast Iowa Workforce Development Board

IA

Cash Management Equipment & Real Property Management Internal Control / Segregation of Duties

We will review policies and procedures for disbursements to ensure that all payments have an evidenced independent review prior to payment. We plan to implement these changes January 1, 2026.

View Audit 372029

Finding 1161991 (2023-001)

Material Weakness 2023

Center for Educational Innovation, Inc.

NY

Questioned Costs Cash Management Subrecipient Monitoring § 200.303 § 200.305

Management believes that in order to ensure that the amount being drawn down are timely and more accurate to the amounts being drawn upon, management is in the process of developing a more formal policy whereby the general ledger will be formally closed on a monthly basis and all amount will be reco...

Management believes that in order to ensure that the amount being drawn down are timely and more accurate to the amounts being drawn upon, management is in the process of developing a more formal policy whereby the general ledger will be formally closed on a monthly basis and all amount will be reconciled to the ledger. Once all amounts are proven, then the drawdown amounts will be initiated with the proper documentation attached.

View Audit 371855 Questioned Costs: $1

Corrective Action Plans

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