Corrective Action Plans

Finding 1217526 (2025-003)

Material Weakness 2025

CA

Eligibility Significant Deficiency Internal Control / Segregation of Duties

2025-003 Eligibility Finding Type: Significant deficiency in Internal Controls over Compliance and Compliance Federal Program Title and AL Number: The Food Distribution Cluster (10.565, 10.568, 10.569). Criteria: Per Title 7 CFR § 247.8, to apply for or to be recertified for CSFP benefits, the appli...

2025-003 Eligibility Finding Type: Significant deficiency in Internal Controls over Compliance and Compliance Federal Program Title and AL Number: The Food Distribution Cluster (10.565, 10.568, 10.569). Criteria: Per Title 7 CFR § 247.8, to apply for or to be recertified for CSFP benefits, the applicant or caretaker of the applicant must be informed of his or her rights and responsibilities, in accordance with § 247.12, the local agency must ensure that the applicant or caretaker signs the application form. Condition and context: As part of our eligibility testing, and in order to determine compliance with the requirements, we verified that the CSFP participants had completed and signed applications or recertifications prior to receiving food distributions. For four out of 32 non-statistical samples, the application was completed but did not have the participants' signature. Cause: The Food Bank did not have controls in place to ensure the participant signatures were received prior to providing food assistance to the individual. Effect: The Food Bank was not able to demonstrate compliance with Title 7 CFR § 247.8. Questioned Costs: None Repeat finding: No Recommendation: We recommend the Food Bank implement controls to ensure CSFP applications and recertifications are signed by the applicant prior to the individual receiving food. Views of responsible officials and planned corrective actions: Management concurs with the finding and recommendation. Please see the attached corrective action plan. Management Response and Planned Corrective Action: Criteria: Per Title 7 CFR § 247.8, to apply for or to be recertified for Commodity Supplemental Food Program (“CSFP”) benefits, the applicant or caretaker of the applicant must be informed of his or her rights and responsibilities, in accordance with § 247.12, the local agency must ensure that the applicant or caretaker signs the application form. The Los Angeles Regional Food Bank (“Food Bank”) has submitted a request to “Oasis Insights”, the Food Bank’s software vendor utilized for CSFP, to reinstate mandatory field validation, or a “hard stop”, on CSFP applications to prevent case progression or assistance issuance when required signatures have not been captured. The Food Bank will verify that the mandatory field validation feature has been reinstated. Additionally, the Food Bank’s CSFP Program Manager will ensure that all Food Bank employees responsible for overseeing CSFP will be provided with retraining in the area of CSFP eligibility requirements. The Director of Compliance and Administration will verify that CSFP applications through Oasis are unable to progress forward without a required signature and that the aforementioned CSFP eligibility training has been completed. The Food Bank will complete these corrective actions on or before June 30, 2026. Individuals responsible for corrective action: Elizabeth Cervantes – Sr. Director of Product Acquisition and Agency Relations 323.974.0073 Hilda Ayala – Sr. Director of Programs and Policy 323.353.0114 Steven Meisberger – Chief Financial Officer 323.318.0319

View Audit 403667

Finding 1217374 (2025-002)

Material Weakness 2025

Ho-Chunk Housing and Community Development Agency, Inc.

WI

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

Finding 2025-002 – Eligibility Assistance Listing No. 14.867 – Indian Housing Block Grant Condition: Pursuant to testing of eligibility and internal controls over eligibility, auditors noted the following control deficiency and noncompliance: • Two tenants did not have an annual recertification. • O...

Finding 2025-002 – Eligibility Assistance Listing No. 14.867 – Indian Housing Block Grant Condition: Pursuant to testing of eligibility and internal controls over eligibility, auditors noted the following control deficiency and noncompliance: • Two tenants did not have an annual recertification. • One tenant’s rent calculation did not match the lease agreement. Recommendation: We recommend that the Agency strengthen its internal controls over eligibility to monitor all relevant information and documentation affecting the eligibility process. Corrective Action Plan: • Ledger created to track recertification dates and completions- already in place • Supervisor will email occupancy of any incomplete recerts monthly • Tenant Files of completed recerts checked quarterly to verify all docs required are in file • TS Staff will verify that the rent calculation form and Lease rent amount are accurate and Entered on lease properly. Name of Contact Person Responsible for Corrective Action Plan: Patti Emery TS Supervisor Anticipated Completion Date: August 1, 2026

View Audit 403579

Finding 1217349 (2025-004)

Material Weakness 2025

Catahoula Parish School Board

LA

Eligibility Internal Control / Segregation of Duties

Reference # and title: 2025-004 Controls and Compliance over Title I Targeting (Eligibility) Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department o...

Reference # and title: 2025-004 Controls and Compliance over Title I Targeting (Eligibility) Federal program and specific federal award identification: AL Number Award Year FEDERAL GRANTER/ PASS THROUGH GRANTOR/PROGRAM NAME United States Department of Education; passed through Louisiana Department of Education Title I 84.010A 2025 Criteria or specific requirement: Title I, Part A of the Elementary and Secondary Education Act of 1965, as amended by Every Student Succeeds Act, requires eligibility to be determined based on the number of children ages 5 through 17 from low-income families. School Board management is required to review all total enrollment and low-income families’ data to ensure that the underlying data includes only students ages 5 through 17 and to certify that the eligibility calculations are complete and accurate. Condition found: Title I management completes and submits the Title I Targeting online to the Louisiana Department of Education (LDOE). The LDOE pre-populates the enrollment and number of low-income students in the Title I Targeting; however, these numbers are required to be reviewed and changed, if necessary, by the School Board. In reviewing the underlying data in determining eligibility for each school, it was noted that the School Board did not remove those students under age 5, which resulted in the ranking of schools to not be accurate. Corrective action planned: The School Board was unaware of the data file used needed to be reviewed; however, we will only include the accurate age band moving forward. Person responsible for corrective action: Mr. Eric Chauvin, Supervisor - Student Records, Technology & Transportation 200 Bushley Street Phone: (318) 744-5727 Harrisonburg, LA 71340 Fax: (318) 744-9221 Anticipated completion date: This is expected to be completed October 2025.

View Audit 403541

Finding 1217335 (2025-002)

Material Weakness 2025

The Salvation Army Golden State Division

CA

Eligibility HUD Housing Programs Significant Deficiency

Finding 2025-002- Eligibility- Significant Deficiency in Internal Controls over Compliance and Non-Compliance Federal Program: Home Investment Partnerships Program (HOME) Assistance Listing Number: 14.239 Year(s): 2025 Federal Agency: Department of Housing and Urban Development (HUD) Pass-Through Ag...

Finding 2025-002- Eligibility- Significant Deficiency in Internal Controls over Compliance and Non-Compliance Federal Program: Home Investment Partnerships Program (HOME) Assistance Listing Number: 14.239 Year(s): 2025 Federal Agency: Department of Housing and Urban Development (HUD) Pass-Through Agencies: Idaho Housing and Finance Association Responsible Party: Jeanne Stromberg, Major - Divisional Finance Secretary-Cascade Division 916-501-6374 RESPONSE: Management will implement a review and approval process to ensure all documentation for applications is maintained in the file and that all applications that are eligible tor participation are properly approved. Effective Date: November 2026

View Audit 403529

Finding 1217310 (2025-002)

Material Weakness 2025

Arisa Health INC

AR

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Contacts: Brian Lutz, VP of Accounting; Rob Busteed, Director of Accounting Contact Phone Numbers: 479-967-5570 Ext. 2013; 479-725-5117 Audit Period Ending: June 30, 2025 2025-002: The Corporation did not perform procedures to ensure vendors used in covered transactions were not suspended, debarred,...

Contacts: Brian Lutz, VP of Accounting; Rob Busteed, Director of Accounting Contact Phone Numbers: 479-967-5570 Ext. 2013; 479-725-5117 Audit Period Ending: June 30, 2025 2025-002: The Corporation did not perform procedures to ensure vendors used in covered transactions were not suspended, debarred, or otherwise excluded. Management concurs with the finding. Arisa has subsequently received a signed certification from the subcontractor dated 4/20/2026 indicating that the vendor was not debarred, suspended, or otherwise excluded from participation in federal assistance programs. For future federal awards, Arisa will collect a certification from the subcontractor/vendor indicating compliance with this requirement. Completion date: Beginning with May 2026 invoices, certifications are required to be included.

View Audit 403483

Finding 1217297 (2025-001)

Material Weakness 2025

Palm Beach County Housing Authority

FL

HUD Housing Programs Eligibility

Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over tenant recertifications to ensure: • Form HUD-50058 and supporting eligibility documentation are current, complete, and properly maintained for all tenants ...

Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 Recommendation: We recommend the Authority strengthen internal controls over tenant recertifications to ensure: • Form HUD-50058 and supporting eligibility documentation are current, complete, and properly maintained for all tenants • Timely processing of tenant move-outs and termination of HAP payments • Ongoing monitoring procedures to identify and promptly resolve instances of continued payments after program exit, including timely recovery of any overpayments Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PBCHA will conduct a review of the participant records to ensure Form HUD-50058 submissions and supporting eligibility documentation are attached, complete and accurate. Staff will use the Yardi Compliance Dashboard to monitor compliance, track processing timelines, and perform ongoing quality-control reviews. The agency will strengthen procedures for processing move-outs and program terminations through tracking mechanisms and supervisory oversight. Staff will receive training on HUD requirements related to tenant exits, terminations, and HAP processing. PBCHA will also perform monthly reconciliations of HAP payments, HUD-50058 terminations, and moveout records to identify and correct improper payments. These actions will help ensure accurate records, timely termination of assistance, prevention of overpayments, and compliance with HUD requirements. Name of the contact person responsible for corrective action: Yvette Bembry Planned completion date for corrective action plan: December 31, 2026

View Audit 403465

Finding 1217263 (2025-001)

Material Weakness 2025

Maple City Health Care Center, Inc.

IN

Procurement, Suspension & Debarment Eligibility § 200.214

2025-001 PROCUREMENT, SUSPENSION & DEBARMENT Condition: We identified an instance where the Organization did not verify the suspension and debarment status of a vendor prior to awarding the vendor a federal contract. Documentation of verification through SAM.gov or equivalent methods could not be pr...

2025-001 PROCUREMENT, SUSPENSION & DEBARMENT Condition: We identified an instance where the Organization did not verify the suspension and debarment status of a vendor prior to awarding the vendor a federal contract. Documentation of verification through SAM.gov or equivalent methods could not be provided by management. Subsequent review of SAM.gov indicated no instances of suspended or debarred vendors used on the project funded with federal awards. Recommendation: We recommend the Organization ensure the staff involved with procuring contracts using federal awards are aware of the federal requirement, including the already established policies that the Organization has regarding such requirements. Corrective Action Plan: The contract associated with this finding was signed on January 24, 2025, before the 2024 financial audit was finished, so before the organization made changes to their procurement policy. Since then, the organization has reviewed its existing procurement policy, and updated it as necessary and will ensure that for future projects, the procurement policy will be carefully followed, including verification through SAM.gov. Staff involved in projects and procurement will receive training regarding the policies and the federal guidelines for federally funded projects. Contact Person Responsible: Interim Director of Finance /CFO Completion date: June 30, 2025

View Audit 403417

Finding 1217212 (2025-002)

Material Weakness 2025

South Seven Senior Village

WA

Eligibility Significant Deficiency

Management Response: Management concurs with the findings. OlyCAP recognizes the importance of maintaining complete and accurate tenant eligibility documentation to demonstrate compliance with HUD program requirements. The missing background verification documentation identified during the audit app...

Management Response: Management concurs with the findings. OlyCAP recognizes the importance of maintaining complete and accurate tenant eligibility documentation to demonstrate compliance with HUD program requirements. The missing background verification documentation identified during the audit appears to be the result of incomplete lease up processes at project inception in 2005. While management believes eligibility determinations were appropriately made, supporting documentation was not obtained in the early period of the project. Corrective Action Plan: 1. OlyCAP has implemented a standardized tenant file checklist identifying all required eligibility and compliance documentation, including background verification records, income documentation, lease agreements, and other required tenant file components. 2. Housing program staff has been trained on file documentation requirements, records retention standards, and file review procedures. 3. Management conducted a comprehensive review in 2024 of all current tenant files to identify missing documentation. 4. Supervisory file reviews are conducted on all tenant files at lease up using the standardized checklist to verify that required documentation is complete and maintained in accordance with program requirements. These corrective actions are intended to strengthen internal controls over tenant eligibility documentation and ensure ongoing compliance with HUD requirements. Anticipated Completion Date: July 1, 2026 Responsible officials: .Executive Director .Housing Director .Housing Program Managers .Compliance and Quality Assurance Staff

View Audit 403348

Finding 1217198 (2025-002)

Material Weakness 2025

Milton-Union Exempted Village School District

OH

School Nutrition Programs Eligibility

The staff member responsible for completing the verification process—Accounts Payable—will attend the required training/webinar to ensure full compliance with USDA regulations. Accounts Payable will complete training specifically covering the proper procedures and requirements for the verification p...

The staff member responsible for completing the verification process—Accounts Payable—will attend the required training/webinar to ensure full compliance with USDA regulations. Accounts Payable will complete training specifically covering the proper procedures and requirements for the verification process, as outlined by the State Agency and USDA guidelines. Documentation on the completed training will be retained on file and made available upon request. In addition to training, both Accounts Payable and Operations Manager are signed up to receive the Ohio Ed Updates SNP Items of Interest. This corrective action is being taken promptly to address the findings and to prevent future occurrences. The district is committed to ensuring all staff involved in child nutrition programs are appropriately trained and fully understand their responsibilities.

View Audit 403326

Finding 1217195 (2025-001)

Material Weakness 2025

Dowagiac Housing Commission

MI

HUD Housing Programs Eligibility Material Weakness

Housing Choice Vouchers – CFDA 14.871 Recommendation: The Commission should consider reviewing its current policy regarding rent certifications. The Commission should ensure all persons involved in the certification process are properly trained and understand regulations in order to accurately ident...

Housing Choice Vouchers – CFDA 14.871 Recommendation: The Commission should consider reviewing its current policy regarding rent certifications. The Commission should ensure all persons involved in the certification process are properly trained and understand regulations in order to accurately identify errors. Additionally, the Commission should implement a thorough second party review of annual certifications to verify accuracy. Action Taken: Management will implement stronger controls over tenant files including a more thorough second party review. Anticipated Completion Date of Action: August 31, 2025

View Audit 403316

Finding 1217194 (2025-001)

Material Weakness 2025

Jackson Local School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

The District will pull a sample of 5% of applicants entered into the Payschools system as of October 31 and perform an independent eligibility determination. Once the eligibility determination has been completed, we will compare it to the eligibility determination made by the Payschools system and n...

The District will pull a sample of 5% of applicants entered into the Payschools system as of October 31 and perform an independent eligibility determination. Once the eligibility determination has been completed, we will compare it to the eligibility determination made by the Payschools system and note any discrepancies.

View Audit 403312

Finding 1217192 (2025-004)

Material Weakness 2025

Johnston County

NC

Eligibility Internal Control / Segregation of Duties Material Weakness

Corrective Action Plan For the Year Ended June 30, 2025 Finding: 2025-003 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-004 Inaccurate Resources Entry Name of contact person: Corrective Action: Section III - Federal Award Findings and Q...

Corrective Action Plan For the Year Ended June 30, 2025 Finding: 2025-003 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-004 Inaccurate Resources Entry Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs Darren Phillips, Quality Assurance and Program Integrity Supervisor We are building a training slideshow presentation to provide tenured caseworkers refresher training for all of the Internal Error findings. This will cover Incorrect Resources, Incorrect Income, Incorrect HH and Residency issues. The SSI expartes that were in error have been completed as of 12/10/2025. We will cover the use of NCFAST reports to ensure that they are worked in a timely manner. A greater emphasis will be placed during training of new hires in the areas of the errors found. Supervisors will provide policy updates and review the income and recertification policies in the Monthly Unit Meetings. The Medicaid Division Director will meet with the Medicaid supervisors to address the untimely reviews and put a plan into place to work them in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. Training will be provided by 2/28/2026 for all Medicaid personnel. Darren Phillips, Quality Assurance and Program Integrity Supervisor We are currenty building a training slideshow presentation to provide tenured caseworkers refresher training on how to update income on cases. The training will cover Self-Employment, the use of pay stubs and pulling income from OVS and TWN. The training will cover both error findings, Incorrect Income and Inadequate Request for Income. A greater emphasis will be placed on the training of new hires for the areas of the errors found. A Desk Reference will be created to assist caseworkers with their duties. Supervisors will provide policy updates and review the income and recertification policies in their Monthly Unit Meetings. The Medicaid Director will meet with the Medicaid Supervisors to discuss the Untimely Reviews to ensure that cases are completed in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. 230

View Audit 403310

Finding 1217191 (2025-003)

Material Weakness 2025

Johnston County

NC

Eligibility Internal Control / Segregation of Duties Material Weakness

Corrective Action Plan For the Year Ended June 30, 2025 Finding: 2025-003 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-004 Inaccurate Resources Entry Name of contact person: Corrective Action: Section III - Federal Award Findings and Q...

Corrective Action Plan For the Year Ended June 30, 2025 Finding: 2025-003 Inaccurate Resources Entry Name of contact person: Corrective Action: Proposed Completion Date: Finding: 2025-004 Inaccurate Resources Entry Name of contact person: Corrective Action: Section III - Federal Award Findings and Question Costs Darren Phillips, Quality Assurance and Program Integrity Supervisor We are building a training slideshow presentation to provide tenured caseworkers refresher training for all of the Internal Error findings. This will cover Incorrect Resources, Incorrect Income, Incorrect HH and Residency issues. The SSI expartes that were in error have been completed as of 12/10/2025. We will cover the use of NCFAST reports to ensure that they are worked in a timely manner. A greater emphasis will be placed during training of new hires in the areas of the errors found. Supervisors will provide policy updates and review the income and recertification policies in the Monthly Unit Meetings. The Medicaid Division Director will meet with the Medicaid supervisors to address the untimely reviews and put a plan into place to work them in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. Training will be provided by 2/28/2026 for all Medicaid personnel. Darren Phillips, Quality Assurance and Program Integrity Supervisor We are currenty building a training slideshow presentation to provide tenured caseworkers refresher training on how to update income on cases. The training will cover Self-Employment, the use of pay stubs and pulling income from OVS and TWN. The training will cover both error findings, Incorrect Income and Inadequate Request for Income. A greater emphasis will be placed on the training of new hires for the areas of the errors found. A Desk Reference will be created to assist caseworkers with their duties. Supervisors will provide policy updates and review the income and recertification policies in their Monthly Unit Meetings. The Medicaid Director will meet with the Medicaid Supervisors to discuss the Untimely Reviews to ensure that cases are completed in a timely manner. A review of the Recertification process for Family and Children's Medicaid in terms of timeliness and pending notices will also be accomplished. 230

View Audit 403310

Finding 1216985 (2025-004)

Material Weakness 2025

Montgomery County, North Carolina

NC

Reporting Cash Management Eligibility

Name of Contact Person: Kris Hernandez, Director of Social Services Corrective Action: The County has worked with NCDHHS to correct errors in the audit and they have issued a revised notice. The County has further achieved eligibility accuracy rates of 100% in both standards as a result of the immed...

Name of Contact Person: Kris Hernandez, Director of Social Services Corrective Action: The County has worked with NCDHHS to correct errors in the audit and they have issued a revised notice. The County has further achieved eligibility accuracy rates of 100% in both standards as a result of the immediate accuracy improvement approach taken with OCPI audit staff. “Kudos to your staff on the improvements” has been a forwarded comment. Date of completion: September 25, 2025

View Audit 403292

Finding 1216764 (2025-002)

Material Weakness 2025

Planned Parenthood North Central States

MN

Internal Control / Segregation of Duties Eligibility Significant Deficiency

Title X – Assistance Listing No. 93.217 Recommendation: We recommend management review its patient intake process to ensure income and household size is properly verified, the control is adequately documented and retained in accordance with organizational policies and program requirements. Explanati...

Title X – Assistance Listing No. 93.217 Recommendation: We recommend management review its patient intake process to ensure income and household size is properly verified, the control is adequately documented and retained in accordance with organizational policies and program requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: With our recent transition from NextGen to Epic, PPNCS is establishing a new process to ensure patient income and household size are accurately identified and documented in our medical records system. With the enhanced functionalities available in Epic, patients now have the ability to pre-register for appointments via e-Check In. This eliminates reliance on the formerly manual process of patients documenting their income and household size on the registration form (B209) which staff would then enter into the medical records system. In addition, PPNCS will continue to perform internal audits, ensuring that the information provided via e-Check In is accurately reflected in the medical records system. PPNCS’s Standard Operating Procedure will be updated to reflect these changes by July 1, 2026. Name of the contact person responsible for corrective action: Randy Drager, CFO Planned completion date for corrective action plan: July 1, 2026

View Audit 403225

Finding 1216751 (2025-001)

Material Weakness 2025

Warren Gardens Housing Cooperative Company, Inc.

MA

Eligibility HUD Housing Programs Matching / Level of Effort / Earmarking § 200.303

2025-001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Section 8 Project-Based Cluster Responsible Official: Ernestine Carter, President Plan Detail: Management will strengthen procedures over tenant documents and income calculations. Corrective acti...

2025-001 – Eligibility Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Section 8 Project-Based Cluster Responsible Official: Ernestine Carter, President Plan Detail: Management will strengthen procedures over tenant documents and income calculations. Corrective actions will include retraining property management staff on HUD income determination and verification requirements and implementing a supervisory review process to verify income calculations prior to tenant eligibility approval.

View Audit 403209

Finding 1216745 (2025-001)

Material Weakness 2025

Rowan County Housing Authority

NC

HUD Housing Programs Eligibility

According to 24 CFR 982.503(d) (3), "A PHA may establish exception payment standard amounts between 110 percent and 120 percent of the applicable FMR for such duration as HUD specifies by notice upon notification to HUD that the PHA meets at least one of the following criteria: (i) Fewer than 75 per...

According to 24 CFR 982.503(d) (3), "A PHA may establish exception payment standard amounts between 110 percent and 120 percent of the applicable FMR for such duration as HUD specifies by notice upon notification to HUD that the PHA meets at least one of the following criteria: (i) Fewer than 75 percent of the families to whom the PHA issued tenant‐based rental vouchers during the most recent 12‐month period for which there is success rate data available have become participants in the voucher program; (ii) More than 40 percent of families with tenant‐based rental assistance administered by the agency pay more than 30 percent of adjusted income as the family share; or (iii) Such other criteria as the Secretary establishes by notice." Additionally, The PHA must determine that the rent to the owner is reasonable at the time of initial leasing. Also, the PHA must determine reasonable rent during the term of the contract (a) before any increase in the rent to owner, and (b) at the HAP contract anniversary if there is a 10 percent decrease in the published Fair Market Rent in effect 60 days before the HAP contract anniversary. The PHA must maintain records to document the basis for the determination that rent to owner is a reasonable rent (initially and during the term of the HAP contract) (24 CFR sections 982.4, 982.54(d)(15), 982.158(f)(7), and 982.507). For 2023, the Authority was approved by HUD to use 120% FMRs. During the audit, we found that the Authority's approved payment standards for 2024 continued to use 120% of the HUD's FMR standard. They were using this without continued approval from HUD. During the audit, the auditor selected 40 tenants to test for eligibility and special tests. Out of the 40, 13 tenants on the 50058 used the 120% payment standard. Management continued to use the 120% threshold after the HUD approval had expired. The Authority did not get required approval to continue beyond 2023 to use the 120% FMR threshold. The Authority used incorrect FMR's to approve payments for HAP. This resulted in more HAP expense and revenue because tenants were housed in housing over the hUD approved 120% FMR rate. The Auditor recommends the Auhtority return to the 110% threshold approved by HUD.

View Audit 403190

Finding 1216557 (2025-001)

Material Weakness 2025

Edison Local School District

OH

School Nutrition Programs Eligibility Matching / Level of Effort / Earmarking

Going forward, Edison Local Schools Eligibility process to determine Free/Reduced/Denied Status of applications submitted for the National School Lunch Program are: All applications collected at Edison Local School will be reviewed prior to the data entered into pay schools to ensure the application...

Going forward, Edison Local Schools Eligibility process to determine Free/Reduced/Denied Status of applications submitted for the National School Lunch Program are: All applications collected at Edison Local School will be reviewed prior to the data entered into pay schools to ensure the applications have all the information and data to make the correct determination. The income eligibility criteria is established by the Ohio Department of Education. The eligibility for paper applications will be made by the food service director and the superintendent is the determining official and each application is reviewed prior to entering this into the POS system, and a free/reduced and benefits issuance reports is compared to ensure all information is correct after it is entered to ensure the determination is correct, additionally annual verification is also done on free/reduced applications.

View Audit 403050

Finding 1216517 (2025-003)

Material Weakness 2025

Clarke University of Dubuque, Iowa

IA

Student Financial Aid Special Tests & Provisions Eligibility

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2024/2025 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2024/2025 P063P201430 Special Tests & Provision...

Student Financial Assistance Program Cluster – Department of Education Federal Financial Assistance Listing/CFDA #84.268 Federal Direct Student Loans - 2024/2025 P268K211430 Federal Financial Assistance Listing/CFDA #84.063 Federal Pell Grant Program - 2024/2025 P063P201430 Special Tests & Provisions: Enrollment Reporting Material Weakness in Internal Control over Compliance and Noncompliance not Considered Material Finding Summary: Fourteen instances were identified where the enrollment status reported to the National Student Clearing House did not match the student’s actual enrollment status. Responsible Individuals: Robert Hoover, Director of Financial Aid and Kristi Bagstad, Registrar Corrective Action Plan: The University will strengthen controls over enrollment reporting by implementing a reconciliation process that includes sampling of enrollment statuses prior to submission. In addition, procedures will be updated to ensure reports are submitted within required timeframes. A secondary review of enrollment files will be conducted prior to submission, and staff will receive training on reporting requirements. Periodic reviews will be performed to monitor ongoing compliance and accuracy. Anticipated Completion Date: August 1, 2026/ongoing

View Audit 402999

Finding 1216501 (2025-001)

Material Weakness 2025

Las Vegas - Clark County Urban League

NV

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.302 § 200.303

As noted, the Program was taken over by State subsequent to year end, and all employees that ran the program are no longer with the Organization. While we did maintain copies of records, accessibility with current staff is difficult and we expected the State would provide us with previous documentat...

As noted, the Program was taken over by State subsequent to year end, and all employees that ran the program are no longer with the Organization. While we did maintain copies of records, accessibility with current staff is difficult and we expected the State would provide us with previous documentation transitioned to them which, unfortunately, they have not. Going forward if any programs are terminated we will make sure previous documentation is maintained, categorized and current staff are able to access any records easily.

View Audit 402993

Finding 1216500 (2025-003)

Material Weakness 2025

City of Seal Beach

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.318 § 200.403 § 200.405

The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consist...

The City has taken steps to strengthen internal controls over the CDBG program. The City will additionally implement formalized procedures requiring, centralized project files containing procurement documentation, cost support, and project eligibility records, document procurement procedures consistent with Uniform Guidance requirements, including cost/price analysis and justification for contractor selection, collection and review of Davis-Bacon documentation, including wage determinations and certified payrolls, when applicable, verification that required permits are obtained prior to construction and retention of inspection and completion documentation, and secondary review by City staff to ensure all required documentation is complete prior to project closeout. Additionally, the City will provide training to staff involved in CDBG program administration. Responsible Persons: Community Development Director Date of Implementation: Initiate FY 2025-26 with ongoing monitoring into FY 2026-27

View Audit 402990

Finding 1216497 (2025-003)

Material Weakness 2025

Aurora East School District 131

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

2025-003: Allocating Funds to Eligible School Attendance Areas and Schools Condition: The district’s approved Title I application established school-level building allocations under Title I Targeting Step 5 using a per-pupil allocation methodology based on low-income counts. The district should docu...

2025-003: Allocating Funds to Eligible School Attendance Areas and Schools Condition: The district’s approved Title I application established school-level building allocations under Title I Targeting Step 5 using a per-pupil allocation methodology based on low-income counts. The district should document school-level expenditures to verify that the per-pupil allocation is followed. The district does not have effective controls to monitor school-level expenditures for compliance with approved Title I building allocations. Six of the 20 schools overspent their allocation by approximately $554,000. The other schools were under their allocations as a result. Corrective Action Planned: The district is working with ISBE to ensure that our site-based resource allocations align with the district’s budget. Name of the Contact Person Responsible for Corrective Action: Mr. Daniel Ulrich, Executive Direct of Finance/ District Accountants/Auditor, Judy Freeman, District Accounts Grant Auditor, Chanbopha Loera Anticipated Completion Date: July 1st 2026.

View Audit 402987

Finding 1216459 (2025-004)

Material Weakness 2025

Casita Park Housing Development Fund Corporation

NY

Eligibility HUD Housing Programs

EIV’s should not be an issue moving forward as the HUD issue was resolved. For the tenants who certified late they didn’t provide their documentation on time to close it out. We will continue to follow up with residents in between their 30-60-90 days to ensure their recertification is completed befo...

EIV’s should not be an issue moving forward as the HUD issue was resolved. For the tenants who certified late they didn’t provide their documentation on time to close it out. We will continue to follow up with residents in between their 30-60-90 days to ensure their recertification is completed before the deadline.

View Audit 402962

Finding 1216446 (2025-002)

Material Weakness 2025

Boardman Local School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

The Food Service Supervisor will verify that PaySchools contains the correct income eligibility guidelines provided by ODEW for the current school year. These income determination charts will be verified twice annually, prior to application submissions and again midway through the school year. In ad...

The Food Service Supervisor will verify that PaySchools contains the correct income eligibility guidelines provided by ODEW for the current school year. These income determination charts will be verified twice annually, prior to application submissions and again midway through the school year. In addition, the District will randomly sample 10% of portal applications entered in PaySchools to ensure eligibility determinations were processed correctly in accordance with program income eligibility requirements. The annual verification process conducted in November will further confirm the accuracy of selected applications. Documentation of these reviews will be maintained in spreadsheet format and printed, signed, and dated by the Food Service Supervisor by November 15 of each school year.

View Audit 402957

Finding 1216369 (2025-001)

Material Weakness 2025

Dwight Way Housing, Inc.

CA

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

DWIGHT WAY HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Dwight Way Housing, Inc. respectfully submits the following corrective action plan for the ye...

DWIGHT WAY HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Dwight Way Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Dwight Way should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Unanticipated staff shortages created gaps in performance of annual recertifications at this location. New staff has since been hired in the Regional Manager role and the Director role. Both new employees are providing greater oversight and visiting the property regularly to track progress. In addition to our permanent staffing efforts, we have deployed a Property Operations Specialist to bring recertifications current at Dwight Way. This specialist is focused specifically on compliance tasks and critical deadlines. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and now conducts monthly progress meetings with management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 402913

Corrective Action Plans

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