Corrective Action Plans

Finding 538745 (2024-002)

Material Weakness 2024

Housing Authority of the City of Martinsburg

WV

Eligibility Procurement, Suspension & Debarment Cash Management

Finding 2024-002 – Documentation of Costs and Vendor Invoices – Financial Reporting and Internal Controls ALN 14.850 & 14.871– Noncompliance & Material Weakness Recommendation: We recommend that the Authority amend policies and procedures to better facilitate effective purchasing controls. A clear ...

Finding 2024-002 – Documentation of Costs and Vendor Invoices – Financial Reporting and Internal Controls ALN 14.850 & 14.871– Noncompliance & Material Weakness Recommendation: We recommend that the Authority amend policies and procedures to better facilitate effective purchasing controls. A clear audit trail should be maintained to ensure proper approval, as well as documentation to support the allowability and eligibility of costs. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will enhance our internal controls over purchasing and Develop detailed procedures for creating, approving, and managing purchase orders. Name(s) of the contact person(s) responsible for corrective action: Navonya Kolani, Executive Director Planned completion date for corrective action plan: September 30, 2025.

View Audit 349460

Finding 538720 (2024-001)

Significant Deficiency 2024

Anderson Community School Corporation

IN

Internal Control / Segregation of Duties Eligibility Significant Deficiency § 200.303

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Pam Storm Contact Phone Number and Email Address: 765-641-2160 (Pstorm@acsc.net) Views of Responsible Officials: We concur with the finding. Description of C...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Pam Storm Contact Phone Number and Email Address: 765-641-2160 (Pstorm@acsc.net) Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: For eligibility, the federal grants director will prepare the PE report and enrollment and poverty data, and will give to the Assistant Superintendent for review and approval via signature. Anticipated Completion Date: December 31, 2025

View Audit 349447

Finding 538674 (2024-004)

Material Weakness 2024

City of Baldwin Park

CA

Subrecipient Monitoring Eligibility HUD Housing Programs

2024-004 - Special Tests – Internal Control and Compliance over Housing Quality Standards Inspections (Material Weakness) Condition: During the Fail Inspection Testing, we found five (5) instances out of nine (9) in which the City did not conduct the Housing Quality Standards (HQS) failed inspecti...

2024-004 - Special Tests – Internal Control and Compliance over Housing Quality Standards Inspections (Material Weakness) Condition: During the Fail Inspection Testing, we found five (5) instances out of nine (9) in which the City did not conduct the Housing Quality Standards (HQS) failed inspection follow-up in a timely manner. Specifically: • For two (2) samples, the reinspection was not performed within 30 days of the failed inspection, and the deficiencies were not confirmed to be resolved within the required timeframe. • For one (1) sample, the inspection checklist indicated a failed inspection, while the inspector erroneously documented and processed it as a passed inspection, meaning o reinspection was performed. • For one (1) sample, the reinspection was not performed, and no documentation was found to verify the follow-up inspection. We also noted one (1) additional instance out of forty (40) samples from Eligibility Cross Testing where the failed inspection did not have any record of a follow-up reinspection. Management concurs. Corrective Actions: Staff will continue to utilize consulting services to complete the necessary HQS inspections during the staff turnover. The City will also strengthen the internal controls for inspections to complete them timely and within compliance. Name of Responsible Person: Ron Garcia, Director of Community Development Ryan Mulligan, Housing Manager

View Audit 349408

Finding 538658 (2024-002)

Significant Deficiency 2024

Culver-Stockton College

MO

Student Financial Aid Special Tests & Provisions Eligibility

The College implemented a policy on January 1, 2025, that clearly defines the proper enrollment status for the various programs offered. The policy has been reviewed by respective administrators. The staff member that is submitting student enrollment data to NSLDS has been trained accordingly. In a...

The College implemented a policy on January 1, 2025, that clearly defines the proper enrollment status for the various programs offered. The policy has been reviewed by respective administrators. The staff member that is submitting student enrollment data to NSLDS has been trained accordingly. In addition, reports have been created to check the accuracy of enrollment data prior to submission.

View Audit 349400

Finding 538643 (2024-008)

Material Weakness 2024

Jemez Mountain School District

NM

Questioned Costs Eligibility

Corrective Action Plan 2024-008 [2023-006] – Improper Certification of Impact Aid (Material Weakness and Material Non-Compliance) Repeated Federal Program Information: Funding Agency: U. S. Department of Education Title: Impact Aid Federal Assistance Listing: 84-041 Passthrough: State of NM Public E...

Corrective Action Plan 2024-008 [2023-006] – Improper Certification of Impact Aid (Material Weakness and Material Non-Compliance) Repeated Federal Program Information: Funding Agency: U. S. Department of Education Title: Impact Aid Federal Assistance Listing: 84-041 Passthrough: State of NM Public Education Department Award Year: 2024 Responsible Official’s Plan: The district Superintendent, Federal Programs Manager and Lybrook principal have received training from Impact Aid in identifying eligible students. The recommended process will be used when submitting the next funding application. Specific corrective action plan for finding: The 2025 application was submitted using the process outlined in the corrective action plan. Timeline for completion of corrective action plan: June 2025 Employee positions responsible for meeting the timeline: Superintendent-Loren Cushman Principal-Arsenio Jacquez Federal Programs Manager-Patricia Cordova

View Audit 349366 Questioned Costs: $1

Finding 538527 (2024-068)

Significant Deficiency 2024

State of Maine

ME

Allowable Costs / Cost Principles Eligibility Internal Control / Segregation of Duties § 200.303

Department: Health and Human Services Title: Internal control over Medicare Part B premium payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The MaineCare Program management team will work with the Data Team to explore opportunities to improve...

Department: Health and Human Services Title: Internal control over Medicare Part B premium payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The MaineCare Program management team will work with the Data Team to explore opportunities to improve the report to reduce duplication of effort and improve overall efficiency and effectiveness of the review. The MaineCare Program management team will review relevant guidance material, clarify expectations and adjust standard operating procedures for further efficiency and oversight improvements. Completion Date: June 30, 2025 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

View Audit 349360

Finding 538516 (2024-063)

Material Weakness 2024

State of Maine

ME

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303 § 200.403

Department: Health and Human Services Title: Internal control over the Foster Care – Title IV-E and Adoption Assistance – Title IV-E eligibility and benefit determination process needs improvement Questioned Costs: Known: ALN 93.658 $4,647 ALN 93.659 $9,367 Likely: Undeterminable Statu...

Department: Health and Human Services Title: Internal control over the Foster Care – Title IV-E and Adoption Assistance – Title IV-E eligibility and benefit determination process needs improvement Questioned Costs: Known: ALN 93.658 $4,647 ALN 93.659 $9,367 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Title IV-E Program Manager will continue to educate and train the FRS on the proper completion of the Title IV-E initial determination checklists for their FRS files, including the importance of signing off on those checklists for the initial determinations that they have completed. The Title IV-E Program Manager will conduct quarterly quality assurance (QA) reviews in the District that this issue was found, randomly pulling 10 cases to ensure compliance. When FRS staff conduct QA reviews, they will continue to be advised to monitor if signatures are present on the Title IV-E initial determination checklist. Reviewing if a checklist is signed is an existing question within our internal QA review document. The Department will establish a work group to identify the challenges of managing overpayments made to foster parents and to develop a process to minimize this problem. The Department will finalize and receive approval of the protocol/process form managing overpayments. The Department will implement the new overpayments management procedures. Completion Date: March 26, 2025, March 31, 2025, July 1, 2025, September 1, 2025, and November 1, 2025 respectively Agency Contact: Robert Blanchard, Associate Director, OCFS, DHHS, 207-624-7955

View Audit 349360 Questioned Costs: $1

Finding 538503 (2024-057)

Significant Deficiency 2024

State of Maine

ME

Internal Control / Segregation of Duties Eligibility Reporting § 200.303

Department: Health and Human Services Title: Internal control over TANF performance reporting procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review and update ACF 199/209 system processes within Office for Family Indep...

Department: Health and Human Services Title: Internal control over TANF performance reporting procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will review and update ACF 199/209 system processes within Office for Family Independence to enhance existing procedures to ensure that the information reported on the ACF-199 and ACF-209 reports is accurate and complete prior to submission to the Federal government. This will include modifying the existing Standard Operating Procedure as necessary. Completion Date: June 30, 2025 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207- 592-1481

View Audit 349360

Finding 538499 (2024-053)

Material Weakness 2024

State of Maine

ME

Internal Control / Segregation of Duties Special Tests & Provisions Eligibility § 200.303

Department: Health and Human Services Title: Internal control over Income Eligibility and Verification System procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will develop a standard operating procedure to include processing ...

Department: Health and Human Services Title: Internal control over Income Eligibility and Verification System procedures needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department will develop a standard operating procedure to include processing of State Wage Information Collection Agency reports beginning July of 2024. This work will be assigned to a TANF team member. Completion Date: June 30, 2025 Agency Contact: Ian Yaffe, Director, Office for Family Independence, DHHS, 207-592-1481

View Audit 349360

Finding 538464 (2024-040)

Significant Deficiency 2024

State of Maine

ME

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

Department: Labor Title: Internal control over UI overpayments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has filed a defect ticket with the helpdesk. In the process of finalizing scope, analyzing solution. System chan...

Department: Labor Title: Internal control over UI overpayments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department has filed a defect ticket with the helpdesk. In the process of finalizing scope, analyzing solution. System changes anticipated to be resolved. The Department will monitor parameters to confirm overpayments are set up correctly. An SOP documenting these monitoring parameters is in process. The Department will add system parameters to run an extract once a quarter for review and validate overpayment system functionality. Test that rules are functioning per the MDOL solution. The Department has notified the Division of Administrative Hearings and staff training will be completed. Completion Date: December 21, 2025, June 30, 2025, September 30, 2025, and March 31, 2025, respectively Agency Contact: Suzan McKechnie Director, Bureau of Unemployment Compensation, DOL, 207-621-5126

View Audit 349360

Finding 538462 (2024-039)

Significant Deficiency 2024

State of Maine

ME

Eligibility Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

Department: Labor Title: Internal control over UI claim payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department concluded a system build in January 2025 to implement controls to prevent repetitive waivers. Completion Date: March 30, 2...

Department: Labor Title: Internal control over UI claim payments needs improvement Questioned Costs: None Status: Corrective action in progress Corrective Action: The Department concluded a system build in January 2025 to implement controls to prevent repetitive waivers. Completion Date: March 30, 2025 Agency Contact: Suzan McKechnie, Director, Bureau of Unemployment Compensation, DOL, 207-621-5126

View Audit 349360

Finding 538428 (2024-031)

Material Weakness 2024

State of Maine

ME

Questioned Costs Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.555 $1,605 ALN 10.582 $9,535 ALN 10.559 $117,259 Likely: Undeterminable Status: Corrective action in progress Corrective Action: Child Nutrition ...

Department: Education Title: Internal control over CNC claim reimbursements needs improvement Questioned Costs: Known: ALN 10.555 $1,605 ALN 10.582 $9,535 ALN 10.559 $117,259 Likely: Undeterminable Status: Corrective action in progress Corrective Action: Child Nutrition Services will create a procedure for reviewing applications and making sure they are approved prior to participation. For the Summer Food Service Program (SFSP), the Child Nutrition Services will create an additional application, outside of CNPWeb to further assess non-congregate operations and eligibility to prevent duplicative services. Child Nutrition Services has submitted a ticket to create an edit check on the SFSP Application to ensure that all specific eligibility information is submitted. Child Nutrition Services will create a procedure to address that session specific information is received prior to claim approval for sites. Child Nutrition Services will require a site sheet for SFSP applications for each location and each enrollment period. Child Nutrition Services will submit a ticket to CNPWeb to allow for documentation to be added to the site information sheet when revisions are made to the system. Child Nutrition Services will add documentation to the activities tab, while we wait for the enhancement to be completed. Child Nutrition Services will create a procedure to ensure that allocations to schools fall between $50.00 - $75.00. Child Nutrition Services has provided training to the National School Lunch Program reviewers on the Fresh Fruit and Vegetable Program questions within the Administrative Review process to ensure that those questions are asked during the Administrative Review. Completion Date: May 1, 2025, first and fourth items, April 1, 2025, second, fifth, sixth, and seventh items, June 1, 2025, third item, March 1, 2025, eight item, and February 10, 2025, for nineth item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

View Audit 349360 Questioned Costs: $1

Finding 538423 (2024-030)

Material Weakness 2024

State of Maine

ME

Questioned Costs School Nutrition Programs Allowable Costs / Cost Principles § 200.303

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.559 $628,924 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will create procedures for Application Approvals with site classification, ...

Department: Education Title: Internal control over CNC eligibility needs improvement Questioned Costs: Known: ALN 10.559 $628,924 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will create procedures for Application Approvals with site classification, eligibility and non-congregate plan requirements. The Department will develop procedures for Revisions on Claims and Applications. For the Summer Food Service Program, the Department will request an edit check enhancement in CNPWeb to add actual enrollment be added to claims. Completion Date: May 1, 2025, first and second item, and May 1, 2026, third item Agency Contact: Jane McLucas, Director of Child Nutrition, DOE, 207-624-6880

View Audit 349360 Questioned Costs: $1

Finding 538394 (2024-022)

Material Weakness 2024

State of Maine

ME

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303 § 200.403

Department: Health and Human Services Title: Internal control over SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: ALN 10.551 $12,335 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will automate the i...

Department: Health and Human Services Title: Internal control over SNAP eligibility determinations and benefit calculations needs improvement Questioned Costs: Known: ALN 10.551 $12,335 Likely: Undeterminable Status: Corrective action in progress Corrective Action: The Department will automate the issuance of the TANF funded resource guide at Application and Recertification (existing ticket AO-4039). (Business Technology Lead) The Department will keep SNAP applications from being opened in batch runs such as mid-month and end-of-month mass change. (Business Technology Lead) The Department will provide updated training/reminders about start and end dating records including income records to retain the information used for benefit runs. (Training Team and Senior SNAP Program Manager) Completion Date: August 31, 2025, first item, and September 30, 2025, second and third items Agency Contact: Michael E. Downs, Senior Program Manager — SNAP, DHHS, 207-592- 4850

View Audit 349360 Questioned Costs: $1

Finding 538305 (2024-001)

Significant Deficiency 2024

Marymount Manhattan College

NY

Student Financial Aid Special Tests & Provisions Eligibility

Name of contact person: Katie Langan, Interim Vice President for Academic Affairs / Dean of the Faculty Corrective action: With respect to the published program length issues, Marymount Manhattan College (the "College") agrees with this finding and will make appropriate changes to ensure that the N...

Name of contact person: Katie Langan, Interim Vice President for Academic Affairs / Dean of the Faculty Corrective action: With respect to the published program length issues, Marymount Manhattan College (the "College") agrees with this finding and will make appropriate changes to ensure that the National Student Loan Data System ("NSLDS") records for program length are based on years, correcting the earlier issue of basing program length on weeks. With respect to the program begin date supporting documenation issue, the College agrees with this finding and will take appropriate actions to correct this issue. These actions will include reinforcing the importance of maintaining documentation and providing adequate secure storage facilities for paper records. With respect to the program start date issue, the College agrees with this finding and will take appropriate corrective actions. These actions will include the creation of a committee consisting of representatives from Registrar, Advisement, Financial Aid, IT, and Business Office to review where inforemtion is stored in the software and ensure it is properly included in the upload to the National Student Clearinghouse ("NSC"), who in turn transmits the information to NSLDS. With respect to the inaccurate CIP code, the College agrees with this finding and will take corrective actions by implementing a double-check process to verify CIP codes before uploading them to NSC, who in turn transmits the information to NSLDS. Proposed completion date: June 30, 2025

View Audit 349334

Finding 538253 (2024-008)

Material Weakness 2024

East Noble School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-008 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Title I Grants to Local Education Agencies – Eligibility Contact Person Responsible for Corrective Action: Holly Singleton, Heidi Moreno Contact Phone Number and Email Address: 260-347-2502 hsingleton@eastnob...

FINDING 2024-008 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Title I Grants to Local Education Agencies – Eligibility Contact Person Responsible for Corrective Action: Holly Singleton, Heidi Moreno Contact Phone Number and Email Address: 260-347-2502 hsingleton@eastnoble.net , hmoreno@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: When the Grants Coordinator and Deputy Treasurer work on completing the Title I Application, they will cross reference the pre-populated numbers provided by the DOE with the DEX report from the October 1st count date. If the numbers are both accurate, they will both sign documentation verifying that the numbers matched. If there is a discrepancy with the numbers, East Noble will reach out to the DOE representative. Anticipated Completion Date: July 1st, 2025 or when the next Title 1 Application is initiated

View Audit 349240

Finding 538225 (2024-004)

Material Weakness 2024

East Noble School Corporation

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-004 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Child Nutrition Cluster- Internal Controls Contact Person Responsible for Corrective Action: Brian Leitch, Holly Singleton and Roger Urick Contact Phone Number and Email Address: 260-347-2502 bleitch@eastnobl...

FINDING 2024-004 (Section III-Federal Award Findings and Questioned Costs) Finding Subject: Child Nutrition Cluster- Internal Controls Contact Person Responsible for Corrective Action: Brian Leitch, Holly Singleton and Roger Urick Contact Phone Number and Email Address: 260-347-2502 bleitch@eastnoble.net, hsingleton@eastnoble.net rurick@eastnoble.net Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The monthly meal reimbursement claims are calculated by the Food Service Director (Roger Urick) with documentation from Meal Magic. The document is printed and reviewed by the Deputy Treasurer (Holly Singleton). Both parties sign the report, and it is recorded. Reimbursement is submitted by the Food Service Director (Roger Urick). Once reimbursement is received, the Deputy Treasurer (Holly Singleton) gives updates to the Food Service department to verify that the amounts received match the amounts requested. The Director of Food Service uses the Federal Income Guidelines to input into the Meal Magic software. The Deputy Treasurer oversees him inputting the information and they both sign the documentation verifying the numbers in the system. When the Director of Food Service downloads the direct certification monthly and enters them into Meal Magic, a report will be ran by the Food Service secretary to verify that the certified students were properly processed. Documentation of the state’s report and the meal magic report will be signed and retained as evidence. Anticipated Completion Date: The corrective action plan regarding reporting has been established since the 2023-2024 fiscal year. The corrective action plan regarding eligibility will be established immediately.

View Audit 349240

Finding 538217 (2024-001)

None 2024

Trustees of Amherst College

MA

Student Financial Aid Eligibility Reporting

Finding No. 2024-001 Enrollment reporting Sponsoring Agency: Department of Education Cluster: Student Financial Assistance Award Names: Pell Grant Program and Federal Direct Student Loans Award Number: Not applicable Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loa...

Finding No. 2024-001 Enrollment reporting Sponsoring Agency: Department of Education Cluster: Student Financial Assistance Award Names: Pell Grant Program and Federal Direct Student Loans Award Number: Not applicable Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numbers: 84.063 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable We acknowledge the finding. Two of the three records were processed prior to the start of the effective leave period. Transmission to the NSC occurs at the start of the term, following add/drop. The third record was processed during the student's study away program, whose enrollment extended further in the academic calendar than Amherst. The end of term processing to NSC had just occurred. Amherst College has a set reporting schedule and controls configured with the NSC for enrollment reporting to NSLDS. Exceptions (in the case of a study away schedule that varies from the College schedule) are highly unusual. Jesse Barba, Director of Institutional Research and Registrar Services, will notify the Office of Financial Aid and Office of Student Affairs when the subsequent term reporting to NSC has occurred. We implemented a new control where any exceptions to leave processing following this date will be sent to NSC as a separate file and will be monitored by Nancy Brownfield, Financial Aid Counselor, to confirm the reporting to NSLDS. Nancy Brownfield will confirm the timely update from NSC to NSLDS or will make the update directly to NSLDS. Contact Person: Gail Holt, Dean of Financial Aid (413) 542-2296

View Audit 349236

Finding 538184 (2024-001)

Significant Deficiency 2024

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Eligibility

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV - Eligibility Recommendation: We recommend that the Authority reviews its internal controls and policies over HUD’s tenant eligibility requirements to ensure all documentation is ...

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV - Eligibility Recommendation: We recommend that the Authority reviews its internal controls and policies over HUD’s tenant eligibility requirements to ensure all documentation is maintained at the time of recertification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On June 30, 2024, Virginia Housing implemented a comprehensive quality control process (previously submitted to HUD) designed to improve oversight and ensure compliance with HUD requirements. This policy was introduced following the audit review; therefore, it was not applicable to the 60 files reviewed by the audit team. As part of this initiative, Virginia Housing adopted a detailed checklist system to guide the recertification process. This checklist outlines each step, establishes clear deadlines, and assigns responsibility to designated staff to promote accuracy, accountability, and timely completion. Virginia Housing is also committed to maintaining staff proficiency through comprehensive training initiatives. Annual training is provided in partnership with Nan McKay to ensure both Virginia Housing and Local Housing Authority (LHA) staff adhere to consistent income calculation practices. In addition, all LHA staff were required to complete specialized training in 2024 on HCVP Specialist duties, HQS Inspections, and HCVP Program Management. To further support staff development, Virginia Housing will conduct a series of on-site training sessions from March 2025 through November 2025. These sessions will cover key topics such as HCVP Specialist Training, HCVP/PH Rent Calculation, Fair Housing and Reasonable Accommodations, Customer Service and Engagement, and HCVP program management and oversight. In preparation for the Housing Opportunity Through Modernization Act (HOTMA) implementation, Virginia Housing has updated its Administrative Plan to align with the required changes, including those related to income and asset determinations. To ensure staff readiness, Virginia Housing’s Program Compliance Officers (PCOs) attended a two-day HOTMA Summit in February 2024, equipping them with the knowledge needed to effectively implement these changes. Of the 60 files tested one (1) did not have proper supporting documentation for expenses/deductions reported on the HUD-50058, Virginia Housing. The local agent has corrected this file as of March 21, 2025. Virginia Housing remains committed to maintaining compliance, improving internal controls, and ensuring all staff are equipped with the tools and knowledge necessary to uphold program integrity. Name(s) of the contact person(s) responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: December 31, 2025

View Audit 349205 Questioned Costs: $1

Finding 538172 (2024-004)

Material Weakness 2024

Nevada Community School District

IA

School Nutrition Programs Eligibility Reporting

Response and Corrective Action Plan: The District will implement a process to retain all documentation of eligibility in the program as outlined by the Iowa Department of Education and Office of Management and Budget.

View Audit 349198

Finding 538155 (2024-001)

Significant Deficiency 2024

Union Local School District

OH

Allowable Costs / Cost Principles Eligibility Program Income

The District will ensure eligibility calculations on submitted applications are properly performed. The District will be more attentive to the list of free and reduced students and will ensure the students have an approved application on file. The District has been in touch with Payschools and both ...

The District will ensure eligibility calculations on submitted applications are properly performed. The District will be more attentive to the list of free and reduced students and will ensure the students have an approved application on file. The District has been in touch with Payschools and both entities are on the same page moving forward.

View Audit 349174

Finding 538148 (2024-001)

Significant Deficiency 2024

Western North Carolina Aids Project, Inc.

NC

Eligibility Significant Deficiency

2024-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on client DNSE 1 – Incorrect amount of support provided to DNSE, and 1 – Missing documentation of leas...

2024-001 – Eligibility for Housing Assistance Condition: During the testing of tenant files, certain documentation deficiencies were noted as summarized below: 1 – Incorrect Rental Calculation on client DNSE 1 – Incorrect amount of support provided to DNSE, and 1 – Missing documentation of lease contract for client AGFA Corrective Action: Section 1 RE: Incorrect Rental Calculation & Incorrect amount of support paid to landlord: WNCAP will continue utilizing the eligibility checklist implemented with the 2022 corrective action plan, as it has resulted in the significant reduction of errors, as evidenced by the continued improvement in comparison to previous audits. The incorrect calculation referenced in this finding was due to a typo, which resulted in an overpayment. To catch simple human errors such as this in the future, management will update the rent calculation worksheet to include reminders to double check data entry in fields that are easy to transpose. Management will also update the recertification process to add the following additional steps: The Data Technician will also review the rent calculation worksheet and the supporting documentation to ensure the amounts in the supporting document(s) match the entry in the worksheet; the Housing Coordinator will conduct a randomized audit of at least two rent calculation worksheets each month. Section 2 RE: Missing documentation of lease contract. WNCAP management will confer with state grant monitors to create and implement a zero-tolerance policy that abates payments immediately if a landlord or client does not provide the documents necessary for recertification in a timely manner. Unfortunately, this will likely result in some evictions and may jeopardize WNCAP’s ability to recruit landlords in a highly competitive market, but there is no guidance on any alternatives that would preserve housing stability as long as possible while still being considered compliant. Evidence of the improvements made by management is reflected by the significant decrease in the number of deficient records compared to the FY2022-23 audit: 2022-23 Total Deficient Eligibility Records: 8 2023-24 Total Deficient Eligibility Records: 3 WNCAP expects to see continued improvement in subsequent audits.

View Audit 349159

Finding 538108 (2024-001)

Material Weakness 2024

Town of Narragansett Housing Authority

RI

HUD Housing Programs Subrecipient Monitoring Eligibility

Auditee’s Response and Planned Corrective Action Upon notification of the FYE June 30, 2024, audit deficiency, the NHA Executive Director immediately implemented a file checklist system for annual and interim recertifications for ALL client files. The checklist clearly presents income calculations –...

Auditee’s Response and Planned Corrective Action Upon notification of the FYE June 30, 2024, audit deficiency, the NHA Executive Director immediately implemented a file checklist system for annual and interim recertifications for ALL client files. The checklist clearly presents income calculations – clearly identifying all income sources to include paystubs, award letters and 3rd party authentic documents, bank statements and EIV as income verifications and noting all qualified minor child and medical expenses utilized to determine accurate calculations of annual and monthly adjusted income. The NHA Executive Director also reviewed the files in question (along with randomly selected files) to assure the accuracy of Housing Assistance Payment calculations. HCV staff attended a recent training course for the recertification process on Wednesday February 5, 2025. Planned Implementation Date of Corrective Action: June 30, 2025 Person Responsible for Corrective Action: Cheryl Hartnett, Acting Executive Director

View Audit 349137

Finding 538091 (2024-001)

Material Weakness 2024

South Dearborn Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility § 200.303

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Janet Platt, Director of Curriculum and Instruction Contact Phone Number and Email Address: 812.926.2090, janet.platt@sdcsc.k12.in.us Views of Responsibl...

FINDING 2024-001 Finding Subject: Title I Grants to Local Educational Agencies - Eligibility Contact Person Responsible for Corrective Action: Dr. Janet Platt, Director of Curriculum and Instruction Contact Phone Number and Email Address: 812.926.2090, janet.platt@sdcsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The Title I Director will verify our enrollment from the prior year October ADM count and have it reviewed and signed off by another staff member. For the non-pubs, the Title I Director will require student rosters as well as poverty information. This information will then be reviewed and signed off on. Anticipated Completion Date: June 2025

View Audit 349120

Finding 538084 (2024-001)

Significant Deficiency 2024

Spencer-Owen Community Schools

IN

School Nutrition Programs Internal Control / Segregation of Duties Eligibility § 200.303

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thoro...

FINDING 2024-001 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Annette Brown Contact Phone Number and Email Address: 812-829-2233 annettebrown@socs.k12.in.us Views of Responsible Officials: We concur with this finding that a more thorough and more fully documented process should be in place and that it needs to cover the full school year and not be done just the one time towards the beginning of the year. Description of Corrective Action Plan: The􀀃Technology􀀃and􀀃Food􀀃Service􀀃Reporting􀀃Assistant􀀃(TFSRA)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃the􀀃initial􀀃processing􀀃of􀀃applications􀀃and􀀃 Direct􀀃Certification􀀃(DC). The􀀃Claims/Deputy􀀃Treasurer􀀃(C/DT)􀀃is􀀃the􀀃one􀀃who􀀃does􀀃a􀀃random􀀃check􀀃on􀀃applications􀀃to􀀃confirm􀀃that􀀃eligibility􀀃is􀀃applied􀀃 accurately. This􀀃check􀀃should􀀃happen􀀃four􀀃(4)􀀃times􀀃a􀀃year: 1. Around􀀃the􀀃Fall􀀃Membership􀀃Count􀀃Day􀀃(first􀀃few􀀃days􀀃in􀀃October)􀀃 2. Christmas􀀃Break􀀃(around)􀀃 3. Spring􀀃Break􀀃(around)􀀃 4. First􀀃part􀀃of􀀃May􀀃 The􀀃TFSRA􀀃will􀀃put􀀃the􀀃list􀀃of􀀃students􀀃and􀀃their􀀃eligibility􀀃from􀀃the􀀃food􀀃service􀀃software􀀃(currently􀀃Titan)􀀃at􀀃the􀀃point􀀃of􀀃each􀀃 check.􀀃The􀀃first􀀃pull􀀃of􀀃students􀀃in􀀃October􀀃will􀀃be􀀃all􀀃students􀀃while􀀃the􀀃subsequent􀀃pulls􀀃will􀀃be􀀃for􀀃the􀀃dates􀀃between􀀃the􀀃 previous􀀃pull􀀃and􀀃that􀀃date􀀃with􀀃the􀀃intention􀀃of􀀃catching􀀃any􀀃new􀀃students􀀃or􀀃new􀀃student􀀃eligibility. The􀀃C/DT􀀃will􀀃select􀀃a􀀃random􀀃sampling􀀃of􀀃students􀀃to􀀃verify.􀀃They􀀃will􀀃work􀀃with􀀃the􀀃TFSRA􀀃to􀀃look􀀃at􀀃the􀀃records􀀃in􀀃Titan􀀃for􀀃 applications􀀃and􀀃CNPWeb􀀃for􀀃the􀀃DC􀀃students􀀃to􀀃see􀀃applications􀀃or􀀃the􀀃DC􀀃eligibility􀀃as􀀃appropriate.􀀃Forms􀀃will􀀃be􀀃printed􀀃or􀀃 screen􀀃shot􀀃to􀀃create􀀃a􀀃file􀀃that􀀃will􀀃be􀀃saved􀀃by􀀃both􀀃parties. Anticipated Completion Date: March 14, 2025

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