Corrective Action Plans

Finding 538349 (2024-007)

Significant Deficiency 2024

Hood College of Frederick, Maryland and Affiliates

MD

Student Financial Aid Allowable Costs / Cost Principles Significant Deficiency § 200.303

Identifying Number: Finding No. 2024-007 – Student Credit Balances from Title IV Awards Finding: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. T...

Identifying Number: Finding No. 2024-007 – Student Credit Balances from Title IV Awards Finding: When Title IV funds are credited to a student account and they exceed the amount of tuition and fees, food and housing, and other authorized charges assessed the student, a credit balance is created. The institution must pay the resulting credit balance directly to the student or parent borrower within 14 days after (1) the first day of class of a payment period if the credit balance occurred on or before that day, or (2) the balance occurred if that was after the first day of class. The College does not have a control in place with physical indication of review over refund process for student credit balances. Corrective Actions Taken or Planned: Responsible Official: Judy Byrd, Controller Anticipated Completion Date: April 1, 2025 View of Responsible Individuals: Once the student refunds are imported to the accounting software, the Refund Export Log report along with the Charge/Credit Import report will be given to Controller/Director of Finance. The AP Coordinator will deliver the student refund checks to Controller/Director of Finance. The Controller/Director of Finance will compare the refund log list against the actual printed checks to verify that all checks have been printed. A signature and date on the refund log report will indicate that the review was completed and that all required refund checks have been printed. Signed report and backup will be stored in the AP files under the title “Student Refunds”.

View Audit 349356

Finding 538320 (2024-002)

Material Weakness 2024

The Phalen Leadership Academy - Indiana, Inc.

MA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring § 200.303

2024-002 Special Tests and Provisions Recommendation: We recommend that for future construction contracts financed by federal education funds PLA verify that subcontractors comply with prevailing wage requirements. Explanation of disagreement with audit finding: There is no disagreement with the aud...

2024-002 Special Tests and Provisions Recommendation: We recommend that for future construction contracts financed by federal education funds PLA verify that subcontractors comply with prevailing wage requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: PLA will train operations and business office staff on the compliance requirements under Davis-Bacon to ensure construction contracts are entered into with qualified contractors and obtain and retain appropriate certified payroll documentation during the construction period. Name(s) of the contact person(s) responsible for corrective action: Jeffrey Larkins, Director of Finance & Accounting; Javier Dimas, Vice-President of Operations; Martha Arellano, Procurement Manager and Buyer. Planned completion date for corrective action plan: January 30, 2025.

View Audit 349344 Questioned Costs: $1

Finding 538307 (2024-001)

Significant Deficiency 2024

Meals on Wheels of the Monterey Peninsula, Inc.

CA

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.403 § 200.405 § 200.430

Finding Number: 2024-001 Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure Allocation: Controller and/or bookkeeper will allocate expenditures based on the number of meals prepared each month a...

Finding Number: 2024-001 Planned Corrective Action: Meals on Wheels of the Monterey Peninsula (MOWMP) will address the finding by taking the steps outlined below: 1. Expenditure Allocation: Controller and/or bookkeeper will allocate expenditures based on the number of meals prepared each month and the percentage of meals prepared for each program and funding. Yearly reviews of the allocation process will be conducted to ensure accuracy and relevance. Adjustments may be made based on changes in meal demand, program requirements, funding sources, or other factors affecting meal preparation costs. 2. Payroll Reporting: On a yearly basis, Managers and/or Directors will allocate the amount of time each employe works based on tasks performed and the amount of time worked on federal award activities. This allocation will be expressed as a percentage of total work hours performed. Periodic adjustments to time allocations may be necessary to reflect changes in project priorities, staffing levels, or other factors affecting workload distribution. Person Responsible for Corrective Action Plan: Leadership Oversight – Christine Winge, Executive Director Operational Oversight – Kay Smith, Controller Anticipated Date of Completion: MOWMP will complete the Corrective Action Plan by June 1, 2024 and these new policies and procedures will be in full effect throughout fiscal year 2025 and beyond. We will continue to review effectiveness and make changes as necessary.

View Audit 349343 Questioned Costs: $1

Finding 538270 (2024-001)

Significant Deficiency 2024

Citizens Medical Center

TX

Reporting Internal Control / Segregation of Duties

Finding Number: 2024-001 Finding Name: Reporting Finding Summary: The Medical Center had discrepancies between the amounts reported in the quarterly progress reports and the actual expenditures. Specifically, the amounts reported in the progress reports did not accurately reflect the total expe...

Finding Number: 2024-001 Finding Name: Reporting Finding Summary: The Medical Center had discrepancies between the amounts reported in the quarterly progress reports and the actual expenditures. Specifically, the amounts reported in the progress reports did not accurately reflect the total expenditures incurred during the reporting period by $368,111. CLIENT PLANNED ACTION: The Medical Center agrees with the finding. The issue was identified by management in the following quarter, corrected, and the correct progress report was resubmitted. Going forward, we have established policies and procedures to review the progress reports prior to submission. CLIENT RESPONSIBLE PARTY: Duane Woods, Chief Financial Officer COMPLETION DATE: March 31, 2024

View Audit 349285

Finding 538263 (2024-003)

None 2024

The Housing Authority of Lafourche Parish

LA

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Non-compliance with the Davis-Bacon Act Capital Fund Program – Assistance Listing No. 14.872; Grant Period - Fiscal Year-Ended September 30, 2024 Corrective Action The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the ...

Non-compliance with the Davis-Bacon Act Capital Fund Program – Assistance Listing No. 14.872; Grant Period - Fiscal Year-Ended September 30, 2024 Corrective Action The Authority will attain weekly certified payrolls from contractors as applicable for all federally funded contracts subject to the Davis-Bacon Act. The Authority’s Executive Director, Erial Branch, has assumed the responsibility of executing this corrective action as of April 30, 2025.

View Audit 349247

Finding 538259 (2024-001)

Significant Deficiency 2024

University of Hartford

CT

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking

2024-001 Student Financial Assistance Cluster – Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. A...

2024-001 Student Financial Assistance Cluster – Federal Assistance Listing No. 84.038 Recommendation: We recommend the University evaluate is procedures and policies around recordkeeping and retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management of the University agrees with the finding. We do have policies and procedures in regard to recordkeeping and retention of Perkins loan documents. Active, Assigned and Retired Perkins loans are maintained in a locked, fireproof container in the Bursar office. The repayment schedules are electronically kept in our borrower files with Heartland ECSI. The cancellation and deferment request for each Perkins loan made are electronically kept in our borrower files with Heartland ECSI. We typically retain original or true and exact copies of Master Promissory Notes (MPN). In some cases, the MPN may have been returned to the student during their entrance counseling. The Perkins loan program expired September 30, 2017. We are currently in the process of Assigning the remaining borrowers to close out our Perkins Loan Program. We are working as quickly and efficiently as possible. Staff availability will determine the completion date for this process. Name(s) of the contact person(s) responsible for corrective action: Diane Purcell, Bursar Senior Accountant, (860) 768-4361 Planned completion date for corrective action plan: June 30, 2025 If the United States Department of Education has questions regarding this plan, please call Elaine Daly, Assistant Vice President for Finance & Controller at 860-768-4652 or Katherine Presutti, Director of Student Financial Aid at 860-768-4300.

View Audit 349245

Finding 538255 (2024-001)

Significant Deficiency 2024

Princeton Theological Seminary

NJ

Special Tests & Provisions Student Financial Aid Reporting

To: PKF O’Connor Davies LLP, U.S. Department of Education From: Princeton Theological Seminary Jean Hall, Vice President for Finance & CEO Date: March XX, 2025 Subject: Princeton Theological Seminary - Corrective Action Plan for the Year Ending June 30, 2024 2024-001 Special Tests an...

To: PKF O’Connor Davies LLP, U.S. Department of Education From: Princeton Theological Seminary Jean Hall, Vice President for Finance & CEO Date: March XX, 2025 Subject: Princeton Theological Seminary - Corrective Action Plan for the Year Ending June 30, 2024 2024-001 Special Tests and Provisions – Enrollment Reporting Federal Assistance Listing Number: 84.268, 84.038, and 84.033 Name of Program or Cluster: Student Financial Aid Cluster Agency: U.S. Department of Education Criteria: Princeton Theological Seminary (the “Seminary”) is required to update students’ statuses on the National Student Loans Data System (“NSLDS”) website if they graduate, withdraw or have an increase/decrease in attendance level during the year within 60 days of the date the Seminary becomes aware of the change in enrollment status. Condition: The Seminary did not submit an accurate status change notification to the NSLDS website for two out of eleven students sampled from a total population of 110 students who graduated, withdrew or had an increase/decrease in attendance level during the year. Cause: Management oversight. Effect: Noncompliance with OMB federal grant compliance requirements. Questioned Costs: None. Repeat Finding: Yes. Recommendation: The Seminary should properly follow its policies and procedures over enrollment reporting to ensure that all status changes are submitted to the NSLDS website accurately and within the required timeframe. Views of Responsible Officials: Princeton Theological Seminary’s management acknowledges these two errors and agrees with the requirement to update students’ enrollment status changes as they occur and in a timely manner. The Seminary’s policy mandates reporting every thirty (30) days, and in these two occurrences, that did not happen. We will review all current student files to ensure compliance. Our Corrective Action Plan to prevent further errors includes implementing a monitoring and verification process of the reporting through the National Student Clearinghouse to the National Student Loan Data System (NSLDS). Further, our Registrar’s office will be required to promptly review and resolve any discrepancies noted in the NSLDS or National Student Clearinghouse error reporting.

View Audit 349243

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 538199 (2024-006)

Significant Deficiency 2024

Virginia Housing Development Authority

VA

HUD Housing Programs Reporting Significant Deficiency

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – HAP Register and PIC Submissions Recommendation: We recommend that the Authority review its internal controls over the HAP process to ensure the correct amounts are paid each month. We recommend that the Authority review its pr...

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – HAP Register and PIC Submissions Recommendation: We recommend that the Authority review its internal controls over the HAP process to ensure the correct amounts are paid each month. We recommend that the Authority review its process for uploading data to PIC to ensure each recertification gets submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Virginia Housing is committed to ensuring accurate and timely data submission to HUD’s Public and Indian Housing Information Center (PIC) system. Virginia Housing acknowledges that staffing challenges, at Virginia Housing and HUD Field Offices, including the turnover of key personnel, contributed to gaps in the PIC data submission process. To address this issue, Virginia Housing has hired new systems staff to restore capacity and strengthen internal controls over data management. The new staff will focus on improving data management procedures, enhancing system oversight, and ensuring timely submission of all required recertifications. Of the files not located in PIC, six (6) have since been submitted in PIC as of March 11, 2025. Virginia Housing will continue to work toward a resolution for the seventh file. Additionally, Virginia Housing will implement quality control measures to verify that all recertifications are properly uploaded to PIC. This will include the development of clear protocols for tracking submission status, conducting regular audits of uploaded data, and ensuring staff are trained on updated procedures. 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: September 30, 2025

View Audit 349205

Finding 538196 (2024-005)

Significant Deficiency 2024

Virginia Housing Development Authority

VA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Waiting List Recommendation: We recommend that the Authority review its internal controls over the waiting list process to ensure all documentation is maintained at the time each applicant is selected from the waiting list. Ex...

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Waiting List Recommendation: We recommend that the Authority review its internal controls over the waiting list process to ensure all documentation is maintained at the time each applicant is selected from the waiting list. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Virginia Housing is committed to strengthening its internal controls over the waiting list process to ensure all required documentation is properly maintained at the time each applicant is selected. To address this concern, Virginia Housing has been conducting a comprehensive review of its current procedures to identify gaps and implement improvements that align with HUD requirements. As part of this effort, Virginia Housing is actively developing standardized documents and processes for all LHAs to promote consistency and enhance compliance. This initiative includes the creation of detailed job aids and reference materials such as quick reference guides and flowcharts. These resources are designed to improve staff understanding of proper waiting list procedures, reinforce documentation requirements, and reduce errors. 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

Finding 538193 (2024-004)

Significant Deficiency 2024

Virginia Housing Development Authority

VA

HUD Housing Programs Significant Deficiency Internal Control / Segregation of Duties

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Quality- Control Inspections Recommendation: We recommend that the Authority review its process over quality control inspections to ensure they are completed timely. Explanation of disagreement with audit finding: There is no ...

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Quality- Control Inspections Recommendation: We recommend that the Authority review its process over quality control inspections to ensure they are completed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has taken proactive steps to enhance its inspection process to ensure compliance with HUD requirements. As part of these efforts, quality control plans have been implemented to ensure the timely and accurate completion of required inspections. In addition, the authority has taking action hiring a Housing Quality Officer to provide oversight of the inspection process (both previously shared with HUD). However, these plans were introduced after the audit review period and, therefore, were not applicable to the files reviewed by the audit team. As noted above, the Authority has contracted the services of a third-party vendor to complete all inspections, including quality control inspections. This partnership aims to improve the efficiency and effectiveness of inspections, ensuring that required corrections are made promptly. Full implementation of the third-party inspection services is scheduled to begin on April 1, 2025, with the Authority conducting ongoing oversight to ensure the vendor's adherence to HUD standards and required quality control policies. 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: May 1, 2025

View Audit 349205

Finding 538190 (2024-003)

Significant Deficiency 2024

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Significant Deficiency

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – HQS Annual and Failed Inspections Recommendation: We recommend that the Authority reviews its processes over annual and failed inspections to ensure that they are completed timely and in compliance with HUD’s requirements. We r...

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – HQS Annual and Failed Inspections Recommendation: We recommend that the Authority reviews its processes over annual and failed inspections to ensure that they are completed timely and in compliance with HUD’s requirements. We recommend the Authority review their procedures to ensure they are following up that the tenants or landlords are making corrections timely or properly abating HAP for the unit until corrections are made. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority has taken proactive steps to enhance its inspection process to ensure compliance with HUD requirements. As part of these efforts, quality control plans have been implemented to ensure the timely and accurate completion of required inspections. In addition, the authority has taking action hiring a Housing Quality Officer to provide oversight of the inspection process (both previously shared with HUD). However, these plans were introduced after the audit review period and, therefore, were not applicable to the files reviewed by the audit team. To further address concerns regarding the timeliness and follow-up of annual and failed inspections, the Authority has contracted with a third-party vendor to manage all inspection activities. This partnership aims to improve the efficiency and effectiveness of inspections, ensuring that required corrections are made promptly. Full implementation of the third-party inspection services is scheduled to begin on April 1, 2025, with the Authority conducting ongoing oversight to ensure the vendor's adherence to HUD standards and internal quality control measures. 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: May 1, 2025

View Audit 349205 Questioned Costs: $1

Finding 538187 (2024-002)

Significant Deficiency 2024

Virginia Housing Development Authority

VA

Questioned Costs HUD Housing Programs Significant Deficiency

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Reasonable Rent Recommendation: We recommend that the Authority reviews its process over reasonable rent determination to ensure that it is performed timely (before the effective date of the rent payment) and that the approved ...

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Reasonable Rent Recommendation: We recommend that the Authority reviews its process over reasonable rent determination to ensure that it is performed timely (before the effective date of the rent payment) and that the approved rent is properly carried forward to the HUD-50058 and HAP contract/HAP contract amendment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As noted above, as part of its comprehensive quality control process (previously submitted to HUD), Virginia Housing developed and implemented a detailed checklist system to guide each step of the annual and interim reexamination processes, including rent reasonableness documentation. This policy was introduced after the audit review; therefore, it was not applicable to the files reviewed by the audit team. In addition, during this fiscal year, Virginia Housing has been actively developing standardized documents and processes for all LHAs to promote consistency and compliance. This initiative includes the creation of job aids and reference materials such as quick-reference guides and flowcharts to support staff in following correct procedures. These resources will be designed to improve staff understanding, streamline processes, and reduce errors. Of the 100 files reviewed, four contained rent reasonableness determination documentation dated after the effective date. While this remains non-compliant, Virginia Housing views this as a positive indication of progress compared to previous audit findings. This improvement reflects the successful implementation of enhanced quality control measures, which have increased LHA file reviews and improved the correction of deficiencies. To further support staff development and ensure continued compliance, Virginia Housing will provide 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. 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 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 538164 (2024-002)

Material Weakness 2024

Adams Central Community Schools

IN

Equipment & Real Property Management Internal Control / Segregation of Duties § 200.313

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S...

Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Equipment and Real Property Management Audit Findings: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Equipment and Real Property Management Requirements compliance requirements. Context: The School Corporation expended $2,799,607 on building renovations which was charged to the ESSER II (84.425D) and ESSER III (84.425U) grant awards. It was noted these capital asset acquisitions were not reported on the capital asset listing for the School Corporation as of June 30, 2024. Additionally, we noted the School Corporation’s capital asset listing did not contain all the required information, including the source of funding for the property, outlined in the criteria above. Contact Person Responsible for Corrective Action: Dawn Cook, Corporation Treasurer; Joel Mahaffey, Superintendent Contact Phone Number: (260) 692-6193 Description of Corrective Action Plan: Business Office personnel will ensure that federally funded capital assets are included in the capital asset listing for ACCS. Further, the capital asset list will clearly identify any equipment or projects that were supported by federal funding. Anticipated Completion Date: Implementation is immediately.

View Audit 349196

Finding 538162 (2024-001)

Material Weakness 2024

Adams Central Community Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Yea...

Information on the federal program: Subject: Education Stabilization Fund – Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425D210013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Findings: Material Weakness, Material Noncompliance, Qualified Opinion Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. Context: For the three projects sampled for Davis-Bacon requirements, the School Corporation did not obtain the weekly payroll reports certifications from the companies that performed renovations on the School Corporation. Therefore, no review was performed to ensure that pay rates complied with the federal wage rate requirements. The total amount disbursed and reported on the SEFA during the audit period is $2,799,607 and the labor portion was not determinable by the School Corporation. Contact Person Responsible for Corrective Action: Dawn Cook, Corporation Treasurer; Joel Mahaffey, Superintendent Contact Phone Number: (260) 692-6193 Description of Corrective Action Plan: When utilizing federal funding for capital projects, ACCS will require and retain evidence that contractors, subcontractors, and other relevant agents comply with the federal wage rate requirements set forth in the Davis-Bacon Act. Anticipated Completion Date: Implementation is immediately.

View Audit 349196

Finding 538160 (2024-003)

Significant Deficiency 2024

Central Regional Education Association

ND

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

Contact Person – Luke Schaefer Corrective Action Plan – Improving monitoring and implement new procedures to properly segregate accounting functions as much as possible for the small size of the Association. Completion Date – June 30, 2025

View Audit 349193

Finding 538159 (2024-001)

Material Weakness 2024

Mooreland Independent School District #2

OK

Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking

All future construction projects exceeding a cost of $2,000.00 and funded through Federal monies will adhere to the Davis-Bacon Act requirements. Procedures have been put in place with flyers, information documents , and checklists to determine eligibility and requirements of all expenditures. The...

All future construction projects exceeding a cost of $2,000.00 and funded through Federal monies will adhere to the Davis-Bacon Act requirements. Procedures have been put in place with flyers, information documents , and checklists to determine eligibility and requirements of all expenditures. The Superintendent is in charge of ensuring compliance.

View Audit 349183

Finding 538149 (2024-001)

Significant Deficiency 2024

Sanders Unified School District No. 18

AZ

Internal Control / Segregation of Duties Special Tests & Provisions Significant Deficiency

CORRECTIVE ACTION PLAN U.S. Department of Education | Arizona Department of Education Sanders Unified School District No. 18 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of find...

CORRECTIVE ACTION PLAN U.S. Department of Education | Arizona Department of Education Sanders Unified School District No. 18 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS— FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS 2024-001 WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: N/A Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Condition/Context: Wage certificates were not maintained for construction projects exceeding $2,000 or other minor remodeling projects during the current year. Documentation was not maintained to support contracts included the proper wage rate clauses. Criteria: According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Corrective Action: The District will ensure the proper wage rate language is included in all contracts for construction and minor remodeling projects exceeding $2,000. In addition, wage rate certifications will be received when necessary and reviewed to ensure they adhere to wage rate requirements. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Barbara Baca, Business Manager

View Audit 349162

Finding 538144 (2024-105)

Significant Deficiency 2024

Navajo County

AZ

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

Concur. To help ensure the County’s policies and procedures include a process for reconciling budgeted payroll allocations to actual time spent on grant activities and provide sufficient documentation to support the actual time worked on the grant program, the County has revised its process for trac...

Concur. To help ensure the County’s policies and procedures include a process for reconciling budgeted payroll allocations to actual time spent on grant activities and provide sufficient documentation to support the actual time worked on the grant program, the County has revised its process for tracking the actual time spent on grant activities in order to provide sufficient documentation to support the actual time worked on the grant program and a reconciliation process to adjust these charges to reflect the actual effort expended on the grant projects. The recommended solutions include strengthening its comprehensive internal control policies and procedures to ensure that payroll costs charged to federal award are accurate, allowable, and properly supported. Additionally, the County will implement a process to reconcile the budgeted payroll allocation with actual time spent on grant activities. The County’s goal is to meet and complete recommendations by the end of fiscal year 2025-26.

View Audit 349149 Questioned Costs: $1

Finding 538141 (2024-104)

Significant Deficiency 2024

Navajo County

AZ

Internal Control / Segregation of Duties Cash Management Reporting

Concur. Due to key vacant positions and the inability to fill these positions, the required reports were not completed and submitted on time during the fiscal year ending June 30, 2024. During the current fiscal year, the County has been successful in recruiting these positions and will ensure that ...

Concur. Due to key vacant positions and the inability to fill these positions, the required reports were not completed and submitted on time during the fiscal year ending June 30, 2024. During the current fiscal year, the County has been successful in recruiting these positions and will ensure that the timely and accurate reports are submitted. In addition, policies and procedures will be documented on reporting requirements to ensure that they are performed on a timely basis.

View Audit 349149

Finding 538132 (2024-101)

Significant Deficiency 2024

Navajo County

AZ

Questioned Costs Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

Concur. To help ensure the County’s policies and procedures include a process for reconciling budgeted payroll allocations to actual time spent on grant activities and provide sufficient documentation to support the actual time worked on the grant program, the County has revised its process for trac...

Concur. To help ensure the County’s policies and procedures include a process for reconciling budgeted payroll allocations to actual time spent on grant activities and provide sufficient documentation to support the actual time worked on the grant program, the County has revised its process for tracking the actual time spent on grant activities in order to provide sufficient documentation to support the actual time worked on the grant program and a reconciliation process to adjust these charges to reflect the actual effort expended on the grant projects. The recommended solutions include strengthening its comprehensive internal control policies and procedures to ensure that payroll costs charged to federal award are accurate, allowable, and properly supported. Additionally, the County will implement a process to reconcile the budgeted payroll allocation with actual time spent on grant activities. The County’s goal is to meet and complete recommendations by the end of fiscal year 2025-26.

View Audit 349149 Questioned Costs: $1

Finding 538106 (2024-002)

Significant Deficiency 2024

Avera Health

SD

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

Department of Health and Human Services Federal Financial Assistance Listing #97.036 COVID-19 Provider Relief Funds and American Rescue Plan (ARP) Rural Distribution Activities Allowed and Allowable Costs Significant Deficiency in Internal Control over Compliance Finding Summary: Our testing over...

Department of Health and Human Services Federal Financial Assistance Listing #97.036 COVID-19 Provider Relief Funds and American Rescue Plan (ARP) Rural Distribution Activities Allowed and Allowable Costs Significant Deficiency in Internal Control over Compliance Finding Summary: Our testing over activities allowed and allowable costs identified instances where the monthly census data for one of the physical locations included within the calculation of contracted labor related to COVID-19 which includes multiple locations was not able to be agreed directly to monthly census data obtained from the Organization as part of the audit process. Responsible Individuals: Jamie Schaefer, John Neth Corrective Action Plan: The organization will review and strengthen the controls surrounding activities allowed and allowable costs compliance. Specifically, Avera Health will update its process of using census data reporting in grant projects as the census data is a live data set within the Avera system. For future projects of this nature, the Organization will download a copy of the data set to a calculation support folder so that it has an exact record of the data used in the various grant calculations and the exact data can be referenced later if the live data set changes. Anticipated Completion Date: June 30, 2025

View Audit 349132

Finding 538104 (2024-001)

Significant Deficiency 2024

Avera Health

SD

Allowable Costs / Cost Principles Period of Performance Significant Deficiency § 200.303

Department of Justice Federal Financial Assistance Listing #16.582 Activities Allowed and Allowable Costs, Period of Performance Significant Deficiency in Internal Control over Compliance Finding Summary: Our testing over activities allowed and allowable costs and period of performance identified ...

Department of Justice Federal Financial Assistance Listing #16.582 Activities Allowed and Allowable Costs, Period of Performance Significant Deficiency in Internal Control over Compliance Finding Summary: Our testing over activities allowed and allowable costs and period of performance identified five employee timecards that were not reviewed and approved by an individual other than the employee. Responsible Individuals: Jamie Schaefer, John Neth Corrective Action Plan: The organization will review and strengthened the controls surrounding activities allowed and allowable costs as well as period of performance compliance. Avera Health has updated its enterprise resource planning system to Workday, which utilizes an effort certification system. Within the effort certification system, Individuals will self-report/certify their time, the certification will then route to the specific grant management staff instead of the cost center supervisor. Anticipated Completion Date: June 30, 2025

View Audit 349132

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