Corrective Action Plans

Finding 1230140 (2024-052)

Material Weakness 2024

State of Nevada

NV

Internal Control / Segregation of Duties Special Tests & Provisions Procurement, Suspension & Debarment § 200.303

Finding: 2024-052: DETR does not have written procedures for verifying, before engaging the services of a provider and at least annually thereafter, whether provides have valid medical licenses and are not currently excluded, suspended, or barred from participation in federal or federally assisted p...

Finding: 2024-052: DETR does not have written procedures for verifying, before engaging the services of a provider and at least annually thereafter, whether provides have valid medical licenses and are not currently excluded, suspended, or barred from participation in federal or federally assisted programs; and whose license to provide health care is not currently lawfully revoked or suspended by any state licensing authority for reasons of fraud, abuse, or professional misconduct. In addition, DETR has an individual assigned to this task as part of the position’s job duties. However, there is no evidence of monitoring by someone other than the individual (segregation of duties and oversight) that this procedure was followed and the results were appropriate. Recommendation: DETR develop written policies and procedures over this process and implement a review and monitoring procedure to ensure the task has been completed accurately and timely. Corrective Action: Contact: Brett Martinez bjmartinez@detr.nv.gov, Jana Vaughn Jana.Vaughn@ssa.gov, Arturo Martinez a-martinez@detr.nv.gov DETR has completed the corrective actions associated with this finding. Written procedures have been developed and implemented to document the required verification steps. In addition, oversight controls have been established to ensure proper segregation of duties. These controls include supervisory monitoring to confirm that the assigned staff member performs the required verifications and that the results are appropriate and fully documented. This corrective action is complete.

View Audit 411357

Finding 1230123 (2024-037)

Material Weakness 2024

State of Nevada

NV

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

Finding 2024-037: Reporting The Division of Public and Behavioral Health (DPBH) did not have adequate internal controls to ensure quarterly fiscal reports were reviewed by a person other than the preparer and that certain information reconciled to underlying supporting documentation. Nevada Division...

Finding 2024-037: Reporting The Division of Public and Behavioral Health (DPBH) did not have adequate internal controls to ensure quarterly fiscal reports were reviewed by a person other than the preparer and that certain information reconciled to underlying supporting documentation. Nevada Division of Public and Behavioral Health response: The Nevada Division of Public and Behavioral Health accepts this finding and will initiate corrective action as described below. Corrective Action: The Division of Public and Behavioral Health will enhance internal controls to ensure the Quarterly Fiscal Reports are reconciled to underlying supporting documentation and are reviewed by an individual independent of the preparation of the reports. Date of Completion: August 2026 Responsible Party: Kagan Griffin, Health Program Manager II Kailynn Griffith, Health Program Manager II If you have any questions, please contact Kori Kendall, Auditor III at 775-684-3228 or by email at k.kendall@health.nv.gov.

View Audit 411357

Finding 1230108 (2024-034)

Material Weakness 2024

State of Nevada

NV

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

Finding #2024-034 - Education Stabilization Fund, 84.425 Reporting - Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: We recommend NDE implement internal controls to identify required information to be reporte...

Finding #2024-034 - Education Stabilization Fund, 84.425 Reporting - Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. NDE Response Due to rapid turnover, changes in assigned personnel, and inconsistent file architecture, NDE has struggled to ensure that source documentation is labeled and retained appropriately. Corrective Action NDE shall document standards for data and reporting, to include required standards for policies and procedures and business rules, to support the development of new and/or temporary reporting requirements in alignment with all relevant internal controls. NDE shall implement internal control monitoring specific to compliance with the data and reporting standards. Responsible Parties and Anticipated Completion Date Student Investment Division, Office of Division Compliance; May 1, 2027. Please reach out to Jenni Hood at sidcompliance@doe.nv.gov with any questions.

View Audit 411357

Finding 1230107 (2024-033)

Material Weakness 2024

State of Nevada

NV

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding #2024-033 - Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking - Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: We recommend NDE implement internal controls to ensure main...

Finding #2024-033 - Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking - Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. NDE Response In alignment with efforts under findings 2023-034 and 2024-030, regarding maintenance of effort, the Department has worked to develop policies and procedures, business rules, and consistent data and reporting practices across reports. Corrective Action NDE shall document standards for data and reporting, to include required standards for policies and procedures and business rules, to support the development of new and/or temporary reporting requirements in alignment with all relevant internal controls. NDE shall implement internal control monitoring specific to Maintenance of Effort. Responsible Parties and Anticipated Completion Date Student Investment Division, Office of Division Compliance; November 1, 2026. Please reach out to Jenni Hood at sidcompliance@doe.nv.gov with any questions.

View Audit 411357

Finding 1230036 (2024-005)

Material Weakness 2024

Valley Health Associates

CA

Subrecipient Monitoring Material Weakness Reporting § 200.512

Planned Corrective Action: Valley Health Associates will ensure accounting methods are consistent and include proper documentation. And, immediately ensure reports are submitted in a timely manner for the Medi-caid program.

View Audit 411282

Finding 1230031 (2024-003)

Material Weakness 2024

SC UPLIFT COMMUNITY OUTREACH

SC

HUD Housing Programs Internal Control / Segregation of Duties

Finding 2024-003 - Segregation of Duties Fiscal Year Finding Initially Occurred: FY 2024 (Initial Finding) Name of Federal Agency: U. S. Department of Housing and Urban Development (HUD) Award Year: 2021 and 2024 Criteria or specific requirement: Statements on Auditing Standards, Communicating Inter...

Finding 2024-003 - Segregation of Duties Fiscal Year Finding Initially Occurred: FY 2024 (Initial Finding) Name of Federal Agency: U. S. Department of Housing and Urban Development (HUD) Award Year: 2021 and 2024 Criteria or specific requirement: Statements on Auditing Standards, Communicating Internal Control Related Matters Identified in an Audit, require the auditor to report on whether the Society has appropriate segregation of duties relating to all aspects of its bookkeeping and accounting procedures. Good internal control requires a complete separation of duties with respect to handling and recording transactions No one person should have access to both physical assets and the related accounting records or to all phases of a transaction. Condition: There is an absence of an absolute segregation of duties in the accounting process due primarily to an accounting department that lacks the size and resources to function in an ideal manner that could assist in reducing the likelihood of a material misstatement. Cause of condition: Limited available staff, coupled with the size of the Society, and prohibitive costs currently prevent an absolute segregation of duties. The Society believes the cost far outweighs the perceived benefits. Potential effect of condition: The lack of an absolute segregation of duties weakens the Society's internal control structure's ability to absolutely prevent and/or detect possible misstatements or compliance issues through second-party independent verification for safeguarding of assets, potential material misstatement, and safeguarding of assets within the Society's financial statements. Recommendation: We understand that the added costs of providing an absolute segregation of duties will, in most cases, outweigh the projected benefits of the added controls, and therefore, may be considered unjustified. However, we are obligated by recently adopted auditing standards to bring this condition to the attention of management and the Board. Those charged with governance are obligated to consider the validity of these comments in light of the circumstances surrounding this condition and respond as they consider necessary. Their response may very well entail acceptance and continuance of this condition as the best perceived alternative under the circumstances. Response of responsible SC UpLift Official: Absolute separation of duties is rarely, if ever, seen within small to medium-sized organizations simply because of the lack of a cost-benefit justification for the added segregation of duties. In the absence of absolute segregation of duties, we implore mitigating controls that reduce the likelihood of material misstatement. We believe that the added costs of providing an absolute segregation of duties will far outweigh the projected benefits of the added controls, and therefore, consider it as unjustifiable.

View Audit 411275

Finding 1230029 (2024-001)

Material Weakness 2024

SC UPLIFT COMMUNITY OUTREACH

SC

Internal Control / Segregation of Duties HUD Housing Programs Reporting

Finding 2024-001 - Internal Controls Over Accounting and Financial Reporting Fiscal Year Finding Initially Occurred: FY 2024 (Initial Finding) Name of Federal Agency: U. S. Department of Housing and Urban Development (HUD) Award Year: 2021, 2023, and 2024 Criteria or specific requirement: Under the ...

Finding 2024-001 - Internal Controls Over Accounting and Financial Reporting Fiscal Year Finding Initially Occurred: FY 2024 (Initial Finding) Name of Federal Agency: U. S. Department of Housing and Urban Development (HUD) Award Year: 2021, 2023, and 2024 Criteria or specific requirement: Under the Uniform Guidance (2 CFR Part 200), non-Federal entities that receive Federal awards must maintain an accounting and financial management system that provides adequate internal control, accountability, and reporting. Generally Accepted Accounting Principles (GAAP) require revenues and expenses to be recognized in the period in which they are earned or incurred. Assets, liabilities, and net assets should be accurately recorded and reported as of the applicable reporting date. Organizations should maintain effective controls to ensure proper period-end cutoff and accurate financial reporting. Condition: During our audit, we identified material accounting errors in accounts receivable, equity investments, property and equipment, accumulated depreciation, construction in progress, accounts payable, and the classification of net assets with donor restrictions, where account balances were not recorded, were recorded improperly, or improperly classified. With respect to revenues and expenses, we identified transactions that were recorded in accounting periods other than those in which the underlying economic events occurred. Specifically, some revenues and expenses that should have been reported in the 2023 accounting year were recorded in the 2024 accounting year, Another condition related to this finding is that accounting personnel do not close the books at year-end each year. This condition required SC UpLift's management to engage the services of a third-party Certified Public Accountant (CPA) to correct the underlying accounting records before year-end financial statements could be prepared. The accounting records required approximately 30 adjusting, reclassifying, or correcting journal entries, to get the accounting records ready for financial reporting. Cause of condition: The primary cause of this condition appears to be a lack of skill, knowledge, experience, and training of accounting personnel with respect to GAAP, and governmental bookkeeping, accounting, and financial reporting requirements. A secondary cause of this condition may be a lack of supervisory oversight and review of accounting transactions by a knowledgeable individual. Potential effect of condition: The potential effect of this condition is the possible material misstatement of interim and/or year-end financial reporting. Management may make decisions using inaccurate financial information, which could negatively affect SC Uplift's ability to secure additional funding for its programs. Section II - Financial Statement Findings (continued) Finding 2024-001 - Internal Controls Over Accounting and Financial Reporting (continued) Fiscal Year Finding Initially Occurred: FY 2024 (Initial Finding) Recommendation: We recommend Management strengthen daily accounting, and period-end closing and review procedures to ensure all transactions are recorded in the appropriate accounting period. Recommended actions include: 1. Implementing formal cutoff procedures for revenue, expense, asset, and liability transactions; 2. Strengthening supervisory review and approval of period-end journal entries and reconciliations; 3. Performing timely reconciliations of significant balance sheet accounts; 4. Providing training to accounting personnel regarding period recognition requirements and accounting cutoff principles; and 5. Establishing documented review controls to verify the completeness and accuracy of period-end financial reporting. Response of Responsible SC UpLift Official: Management of SC UpLift Community Outreach, Inc. acknowledges and understands the audit finding regarding financial reporting and year-end accounting procedures. We appreciate the auditor's recommendations and are committed to strengthening our accounting and financial reporting processes to ensure continued compliance with Generally Accepted Accounting Principles (GAAP), Uniform Guidance (2 CFR Part 200), and nonprofit financial reporting standards. As a small nonprofit organization with limited administrative resources, SC UpLift has consistently sought to maintain sound financial management practices by engaging qualified Certified Public Accountants (CPAs) to assist with our accounting and financial reporting. However, due to the financial constraints common among small nonprofit organizations, we have not always been able to retain those services on a continuous basis because of the associated costs. This was SC UpLift's first Single Audit, and we recognize that the increased reporting requirements associated with federal funding require additional expertise, stronger internal controls, and more formalized year-end closing procedures. We have already engaged a third-party CPA to assist with the preparation of the 2024 audited financial statements and will continue working closely with both our bookkeeper and CPA throughout the upcoming fiscal year to improve our financial reporting processes. Specifically, management will: • Develop and implement formal month-end and year-end closing procedures. • Perform timely reconciliations of all significant balance sheet accounts. • Strengthen supervisory review of journal entries, reconciliations, and financial reports. • Ensure revenues, expenses, assets, and liabilities are recorded in the proper accounting period. • Continue utilizing the expertise of our third-party CPA to review financial records, provide guidance on GAAP compliance, and assist with staff training and implementation of best practices. Management believes these corrective actions will significantly strengthen our internal controls over financial reporting and reduce the likelihood of similar findings in future audits. We are committed to continuous improvement and maintaining financial records that accurately reflect the organization's financial position while meeting all applicable federal and nonprofit reporting requirements. Target Completion Date: December 31, 2026

View Audit 411275

Finding 1229813 (2024-003)

Material Weakness 2024

Coquille Watershed Association

OR

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Recommendation: We recommend that the Organization establish and implement formal payroll rate documentation and approval controls. At a minimum, management should maintain documentation to support all initial salary/wage rates and subsequent rate changes; require documented approval by an appropria...

Recommendation: We recommend that the Organization establish and implement formal payroll rate documentation and approval controls. At a minimum, management should maintain documentation to support all initial salary/wage rates and subsequent rate changes; require documented approval by an appropriate supervisor, executive, or governing body designee before pay rate changes are entered into the payroll system; restrict access to the master rate spreadsheet and maintain version history or change logs, and require independent review of all pay rate changes before payroll is processed. Corrective action planned: At the end of 2025, the Organization began providing letters from the director to staff when any pay rate changes occurred. The board will provide such a letter to the director when the director’s rate changes. The Organization already had and continues to provide offer letters upon hiring staff that includes the initial rate. Payroll is now run by the Operations Manager and sent for approval by the Executive Director. Pay rate is reviewed as part of the submission process. Persons responsible for corrective action: Justin Queen, Executive Director Date by which the corrective action will be completed: Complete

View Audit 411097

Finding 1229774 (2024-001)

Material Weakness 2024

Iglesia De Dios Pentecostal, M.i.

PR

Reporting Internal Control / Segregation of Duties § 200.512

Corrective Action: Iglesia de Dios Pentecostal, M.I. has implemented procedures to strengthen its audit planning and federal compliance process to ensure that future program-specific audit reporting packages are submitted within the deadlines established by 2 CFR §200.512(a).S pecifica lly, manageme...

Corrective Action: Iglesia de Dios Pentecostal, M.I. has implemented procedures to strengthen its audit planning and federal compliance process to ensure that future program-specific audit reporting packages are submitted within the deadlines established by 2 CFR §200.512(a).S pecifica lly, management will: 1. Establish an annual compliance calendar identifying all federal reporting deadlines, including the due date for submission of the program-specific audit reporting package to the Federal Audit Clearinghouse (FAC). 2. Begin the auditor procurement or engagement renewal process sufficiently in advance of the fiscal year-end to allow adequate time for audit planning, fieldwork, report issuance, and timely submission of the reporting package. 3. Assign responsibility to a designated management official to monitor compliance with the audit timeline, communicate periodically with the independent auditor regarding the status of the engagement, and ensure that all required documentation is submitted on time. 4. Review the compliance calendar periodically throughout the year and document management's monitoring activities to ensure all critical milestones are met. Management believes these measures will significantly reduce the risk of future delays and will promote continued compliance with federal audit reporting requirements

View Audit 411063

Finding 1229712 (2024-028)

Material Weakness 2024

Republic of the Marshall Islands

MH

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303

Condition 1: ELC Program Leads complete and submit Work Plan Progress Reports through the ELC CAMP as required by the grant. To monitor compliance, ELC will notify the Ministry of Finance of submitted reports and provide MOF with view-only access to relevant files and supporting documentation as nee...

Condition 1: ELC Program Leads complete and submit Work Plan Progress Reports through the ELC CAMP as required by the grant. To monitor compliance, ELC will notify the Ministry of Finance of submitted reports and provide MOF with view-only access to relevant files and supporting documentation as needed. Condition 2: The ELC Program Leads completes the required financial reports in ELC CAMP using information provided by the MOF Fiscal Officer and submits the reports through ELC CAMP and GrantSolutions. ELC will notify MOF of each submission to support compliance monitoring. To strengthen the process, MOF and MOHHS will establish a formal reporting process. MOHHS will maintain a tracking tool with required reports, reporting periods, due dates, and submission status, and share it with MOF. MOF will have access to ELC CAMP and the MOHHS GrantSolutions account to retrieve reports as needed.

View Audit 410889

Finding 1229708 (2024-024)

Material Weakness 2024

Republic of the Marshall Islands

MH

Cash Management Internal Control / Segregation of Duties § 200.303

The fiscal officers of the MOF Budget Division have strengthened their review of expenditures prior to disbursements and started to conduct weekly evaluation and monitoring of draw downs.

View Audit 410889

Finding 1229699 (2024-021)

Material Weakness 2024

Republic of the Marshall Islands

MH

Period of Performance Internal Control / Segregation of Duties § 200.303

The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with fundi...

The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements. The Ministry acknowledges, however, that the process still requires human input and oversight. As a result, there remains a risk that expenditures may be processed or incurred outside the approved funding period due to human error. The Ministry will reinforce and continue to strengthen its review and monitoring procedures to minimize this risk and ensure expenditures are charged to the appropriate funding period.

View Audit 410889

Finding 1229698 (2024-020)

Material Weakness 2024

Republic of the Marshall Islands

MH

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

PSS response: Management concurs with the finding. At the time of the FY2024 audit, the Public School System (PSS) calculated the Maintenance of State Financial Support (MFS) using the gross salaries of locally funded Special Education administrative staff and teachers. While management believes tha...

PSS response: Management concurs with the finding. At the time of the FY2024 audit, the Public School System (PSS) calculated the Maintenance of State Financial Support (MFS) using the gross salaries of locally funded Special Education administrative staff and teachers. While management believes that only allowable State-funded salary expenditures were included in the calculation, the supporting documentation and reconciliation to the underlying accounting records were not maintained in sufficient detail to fully support the reported MFS amount. The Ministry of Finance has implemented a Special Purpose Grant (SPG) code to improve the identification and reporting of all expenditures. Management will also develop and implement written procedures defining the responsibilities for preparing, reviewing, and approving the annual MFS calculation. These procedures will require the retention of supporting payroll reports, reconciliation to the accounting records, and documentation identifying the employees included in the calculation, their funding sources, and any personnel changes that occurred during the fiscal year. Beginning in FY2027, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that the MFS calculation is adequately supported, reconciled to the accounting records, and prepared in accordance with IDEA requirements before submission. Any deficiencies identified during these reviews will be communicated promptly to management for corrective action. Management expects these corrective actions to be fully implemented by the end of FY2027.

View Audit 410889

Finding 1229695 (2024-017)

Material Weakness 2024

Republic of the Marshall Islands

MH

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

Condition 1 Public School System management concurs with the finding. While annual performance evaluations were completed for many grant-funded employees, PSS did not consistently maintain sufficient documentation to demonstrate that all required evaluations had been completed in accordance with the...

Condition 1 Public School System management concurs with the finding. While annual performance evaluations were completed for many grant-funded employees, PSS did not consistently maintain sufficient documentation to demonstrate that all required evaluations had been completed in accordance with the grant requirements. Beginning in FY2027, PSS has implemented the Orange HR Management System, which provides an electronic process for completing, approving, and storing employee performance evaluations. This system creates a centralized electronic record and audit trail, making it easier to monitor compliance and retrieve documentation for audit purposes. In addition, the Finance and Audit Compliance Specialist will conduct periodic compliance reviews to verify that all required evaluations are completed and properly documented before the close of each fiscal year. Condition 2 FY2024 Appropriation was a continuation of FY2023 and did not reflect the new Compact yet since negotiations were still ongoing at the time. The $2.5million matching was clarified with the US DOI team in March 2026, to be appropriated in FY2027. The MOF has not drawn down against this grant.

View Audit 410889

Finding 1229691 (2024-013)

Material Weakness 2024

Republic of the Marshall Islands

MH

Period of Performance Internal Control / Segregation of Duties § 200.303

The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with fundi...

The Bisan system includes functionality to control expenditures within a specified funding period, typically the Budget Period or Period of Performance. These are the Start Date, End Date and Closing Date in each SPG code setup. The Ministry utilizes this feature to help ensure compliance with funding requirements. The Ministry acknowledges, however, that the process still requires human input and oversight. As a result, there remains a risk that expenditures may be processed or incurred outside the approved funding period due to human error. The Ministry will reinforce and continue to strengthen its review and monitoring procedures to minimize this risk and ensure expenditures are charged to the appropriate funding period.

View Audit 410889

Finding 1229680 (2024-002)

Material Weakness 2024

36 DEGREES NORTH CO.

OK

Significant Deficiency Internal Control / Segregation of Duties

Pay Rate Approval Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Significant Deficiency Condition: During fieldwork, we noted that pay rate approvals from early in the audit period were not available. The audit period spanned from 2021 through 20...

Pay Rate Approval Federal Program: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Significant Deficiency Condition: During fieldwork, we noted that pay rate approvals from early in the audit period were not available. The audit period spanned from 2021 through 2024 for this program, and during that time the Organization had migrated HR services to a new vendor. The documentation from the previous vendor was no longer available for audit. While these procedures had been performed, the approvals of pay rate changes could not be documented. Corrective Action Plan: For the transactions where a signed approval could not be produced, the approved pay rates are reflected in the payroll system and the related positions and salaries were included in the funderapproved grant budgets, and management believes the control operated as intended. The original documentation for the oldest items was not retained through prior HR and payroll system changes and is no longer available. Corrective action is already implemented: all pay-rate changes now require a signed Employee Status Change Form approved by the employee's manager and the HR representative, with Board approval for CEO compensation, before payroll is finalized, and we maintain a complete, auditready document set going forward. Responsible Official: DaMon Jackson, EVP, Finance and Infrastructure Anticipated Completion Date: Targeting resolution by December 31, 2025

View Audit 410875

Finding 1229418 (2024-003)

Material Weakness 2024

MICHIGAN FOUNDERS FUND

MI

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Reporting

Remediation Steps Completed: In advance of this finding, MFF began remediation for this issue starting in 2024, through key hires, and extended in 2025 with the development of a full suite of financial and procurement policies. The steps taken are as follows: • A new Executive Director was hired on ...

Remediation Steps Completed: In advance of this finding, MFF began remediation for this issue starting in 2024, through key hires, and extended in 2025 with the development of a full suite of financial and procurement policies. The steps taken are as follows: • A new Executive Director was hired on May 1, 2024 to run the organization. • A full-time Impact Manager was hired on December 9, 2024 to oversee grant management, reporting, and compliance. • A new contract finance and accounting firm and contract Financial Officer was selected and engaged in February 2025 for regular and ongoing financial management, accounting, and oversight. • A full-time Operations Director was hired on August 21, 2025 to oversee organizational systems development and management. • A full suite of financial and procurement policies was drafted in the Fall of 2025 with input and guidance from the Financial Officer, Impact Manager, and Executive Director and informed by procurement standards as described in 2 CFR Part 200, Subpart D. • The Financial and Procurement Policies were formally adopted by the Michigan Founders Fund Board of Directors on June 15, 2026. • The Financial and Procurement Policies were implemented organization-wide on July 15, 2026. Implementation, Monitoring, and Sustainability of the Corrective Action: To ensure this corrective action is implemented and remains effective beyond initial adoption, MFF built the following monitoring controls: The Financial Officer and Impact Manager will follow a documented monthly close checklist that applies the newly adopted Financial and Procurement Policies consistently across all federal awards, ensuring transactions are coded, reviewed, and approved using the same process each month. • For every cost charged to a federal award, MFF will retain evidence of review and approval — including approver name, date, and basis for allowability. This evidence will be centrally filed by grant/award number to support ready retrieval during monitoring or audit. • The Executive Director, Financial Officer, and Impact Manager will conduct a quarterly review of internal controls over compliance with all staff and contractors who have a role in federal award administration. • The Financial and Procurement Policies are scheduled for internal review at least annually, with the next review scheduled for July 1, 2027, or sooner if required. o All staff and board members with purchasing authority will receive training on the new Financial and Procurement Policies at the time of adoption; training is repeated annually and incorporated into new-hire onboarding. o The Executive Director has been designated as the official with overall responsibility for procurement-policy compliance; the Operations Director is responsible for day-to-day monitoring and enforcement of the policy, including maintenance of complete procurement files. • MFF will maintain a written internal controls procedures manual, distinct from the Boardadopted policies, that documents the step-by-step mechanics of compliance processes (e.g., approval routing, filing conventions, reporting deadlines). • These monitoring activities will be reviewed by the Executive Director and Financial Officer on a quarterly basis, with any unresolved control deficiencies escalated to the Board within 60 days of identification. Anticipated Completion Date: September 2026 Contact Person: Rishi Moudgil, Executive Director Contact Phone Number: (313) 338-8292

View Audit 410809

Finding 1229287 (2024-001)

Material Weakness 2024

Philadelphia Legal Assistance Center, Inc.

PA

Eligibility Internal Control / Segregation of Duties

Corrective Action Plan Provided by Management: Philadelphia Legal Assistance Center, Inc. (PLA) agrees with the finding. In November 2024, PLA hired a Legal Compliance Specialist whose full-time job is to review open and closed cases for compliance mistakes. The Legal Compliance Specialist did not h...

Corrective Action Plan Provided by Management: Philadelphia Legal Assistance Center, Inc. (PLA) agrees with the finding. In November 2024, PLA hired a Legal Compliance Specialist whose full-time job is to review open and closed cases for compliance mistakes. The Legal Compliance Specialist did not have time to review every case closed in 2024. However, the Legal Compliance Specialist has been reviewing cases all year in 2025 and catching issues with missing citizenship attestations, which should reduce the chances of a case being reported to LSC without the documentation required by 45 C.F.R. 1626. In the summer of 2025, we required all case handlers to watch compliance training videos and answer multiple-choice questions to test their knowledge. The videos and questions included content related to 45 C.F.R. 1626. We plan to require staff to complete a similar training process in 2026, which will include additional content related to 45 C.F.R. 1626 compliance.

View Audit 410765

Finding 1229234 (2024-004)

Material Weakness 2024

City of Cherokee

IA

Reporting Internal Control / Segregation of Duties

A policy and procedure will be established to ensure the annual Project and Expenditure Report is reviewed and reconciled prior to submission.

View Audit 410733

Finding 1229233 (2024-003)

Material Weakness 2024

City of Cherokee

IA

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

The City will develop a formal process for tracking all federal expenditures and take steps to learn when those expenditures trigger additional audit requirements.

View Audit 410733

Finding 1229087 (2024-001)

Material Weakness 2024

Housing Authority of the City of Pittsburgh

PA

Eligibility HUD Housing Programs Internal Control / Segregation of Duties

Re: Corrective Action Plan - 2024 Audit To: United States Department of Housing and Urban Development From: Housing Authority of City of Pittsburgh, (HACP) Action: Respectfully submits the following Corrective Action Plan for the year-end December 31,2024. Name and address of independent public acco...

Re: Corrective Action Plan - 2024 Audit To: United States Department of Housing and Urban Development From: Housing Authority of City of Pittsburgh, (HACP) Action: Respectfully submits the following Corrective Action Plan for the year-end December 31,2024. Name and address of independent public accounting firm: Maher Duessel, CPA’s 503 Martindale Street, Suite 600 Pittsburgh, PA 15212 Audit period: January 1, 2024 - December 31, 2024 The findings from the December 31, 2024, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the number assigned in the schedule. Finding 2024-001 U.S. Department of Housing and Urban Development Moving to Work Demonstration Program - ALN 14.881 Eligibility and Reporting Repeat Finding from 2021(2021-001), 2022(2022-001), and 2023 (2023-001) Maher Duessel Finding Condition: During our review of 40 tenant files prepared by the Housing Authority of the City of Pittsburgh (Authority) as part of the biennial reexamination process, we noted a lack of functioning internal controls which led to the below exceptions in our testing. We noted four instances where a tenant recertification using the HUD-50058, Family Report (Form) (which provides eligibility and reporting information) was not completed, on a timely basis. We also noted one instance where other documentation to support the reporting and eligibility assessment as part of completion of the HUD-50058 was not provided. This includes items such as support for income calculation and medical deductions. These exceptions indicate a lack of functioning internal controls and oversight to ensure compliance with HUD requirements related to timely and accurate tenant recertifications. HACP Management Response/Action Taken: Action Taken: The HACP will continue to monitor and train staff regarding processes and procedures, to include and not limited to the Housing and Urban Development’s (HUD) hierarchy of income verification. As noted in previous responses, the HACP continues to experience challenges in hiring and retaining staff as a result of the complexity of the Housing Choice Voucher (HCV) Program. In fiscal year (FY) 2024, the HCV Department had a significant turnover in both line and managerial staff. The HACP promoted an aggressive hiring plan to attract new talent to fill vacant positions due to the great resignation that the HACP, along with other national Agencies, continue to experience. In addition, the HACP has adopted the policy of hiring more staff than needed in the event of turnover. The HACP will continue to utilize the Internal Compliance (IC) Department to review recertifications and compile audit report cards based on the accuracy of recertifications reviewed. The audit report cards are used as an additional management tool to determine whether additional training is needed for staff and the department in general. The HACP continues to: • Send notices regarding re-certifications 120 days in advance of the due date, o Send 10-day notices for missing AR documents o Send 30-day notices when there is no or insufficient response to the 10 day notice sent • Require Managers to review reports to assure timely submission of re-certifications, • Utilize the IC Department to review and sample files from the Occupancy and the HCV portfolio, • Offer periodic staff training on re-certification, • Offer participants the use of technology to complete paperwork In addition to the above noted internal controls, the HACP will institute Bob.ai in FY 2026 as an additional tool to notify both the participant and the HACP staff when the recertifications are due and provide notification of missing documents. The One Stop Shop (OSS) is staffed with three (3) full-time staff members to receive information from participants and landlords to provide timely customer service. In July of 2024, the OSS was equipped with computers for the public to access HACP staff virtually. The use of the computers allows staff to interact with participants regarding minor issues without having the staff physically come to the OSS, thus saving time and money for both the external customer and the Authority. The opening of the One Stop Shop has been successful in receiving the public and responding to concerns.

View Audit 410568

Finding 1229079 (2024-010)

Material Weakness 2024

City of Laconia

NH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.403

Planned Corrective Action: All purchase orders will be approved by an Administrator and the Business Administrator. The current software allows for and audit path of approval, changes will be made to include the above practice in accordance with City and School District policy. Name of Contact Perso...

Planned Corrective Action: All purchase orders will be approved by an Administrator and the Business Administrator. The current software allows for and audit path of approval, changes will be made to include the above practice in accordance with City and School District policy. Name of Contact Person: Dawn Cilley, Business Administrator dcilley@laconiaschools.org Anticipated completion date: September 30, 2026 Example of Planned Corrective Action: School ERP Pro software will be adjusted for an approval path including an Administrator and The Business Administrator.

View Audit 410535

Finding 1229038 (2024-012)

Material Weakness 2024

City of Emporia

VA

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Cash Management

The City has strengthened its review and approval procedures for federally funded expenditures to ensure appropriate management oversight prior to payment. Vendor invoices and reimbursement requests are now reviewed and approved by City management before payment is processed, and employee timesheets...

The City has strengthened its review and approval procedures for federally funded expenditures to ensure appropriate management oversight prior to payment. Vendor invoices and reimbursement requests are now reviewed and approved by City management before payment is processed, and employee timesheets charged to federal awards require supervisory approval prior to payroll processing. These procedures reinforce compliance with the City's expenditure approval process and provide additional oversight to ensure allowable costs are properly reviewed and approved before reimbursement or payment. These procedures have been implemented and will be followed for all federally funded expenditures on an ongoing basis.

View Audit 410498

Finding 1228925 (2024-001)

Material Weakness 2024

Comhar, Inc. and Affiliates

PA

Internal Control / Segregation of Duties HUD Housing Programs

Subject: Compliance with HUD Replacement Reserve Monthly Deposit Requirement Issue Identified: HUD regulations require that deposits into the Replacement Reserve account be made on a monthly basis. Our agency has historically made annual lump-sum deposits, which is not in compliance with HUD guideli...

Subject: Compliance with HUD Replacement Reserve Monthly Deposit Requirement Issue Identified: HUD regulations require that deposits into the Replacement Reserve account be made on a monthly basis. Our agency has historically made annual lump-sum deposits, which is not in compliance with HUD guidelines. Corrective Actions 1. Change in Deposit Frequency Action: Transition from an annual deposit schedule to a monthly deposit schedule in accordance with HUD requirements. Responsible Party: CFO and Accounting Manager Timeline: Effective May 1, 2025, monthly deposits will begin. Verification: Monthly entries and bank confirmations will be reviewed by Accounting. 2. Implementation of Automated Transfers Action: Establish and schedule automated monthly bank transfers to the Replacement Reserve account. Responsible Party: Accounting Manager in collaboration with Banking Institution Timeline: Setup completed by 04/15/2025. First automated transfer on 05/01/2025. Verification: Confirmation of automation setup from the bank and successful execution of first transfer. 3. Monthly Notifications to Fiscal Personnel Action: Create an automated monthly email notification system to alert key fiscal personnel of each deposit, including the amount and confirmation of receipt. Responsible Party: Budget & Reimbursement Manager Timeline: Notification system live by 05/01/2025. Verification: Email log confirming monthly communications sent to fiscal team. Ongoing Monitoring and Compliance The Accounting Manager will review monthly bank statements to verify timely and accurate deposits. The Controller will incorporate verification into monthly closing procedures.

View Audit 410443

Finding 1228920 (2024-013)

Material Weakness 2024

Twin Oaks Juvenile Development, Inc.

FL

Student Financial Aid Subrecipient Monitoring Reporting § 200.303

Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing...

Twin Oaks will establish procedures for the review of all program reports prior to submission to the grantors, as well as documentation of that review. We have reduced significantly the amount of time to generate accurate reports but there may be more issues in 2025 due to the timing of establishing these procedures. Felecia Read will be responsible for making sure these are completed and documented.

View Audit 410428

Corrective Action Plans

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