Corrective Action Plans

Finding 1218150 (2025-001)

Material Weakness 2025

West Elk Unified School District No. 282

KS

Internal Control / Segregation of Duties Subrecipient Monitoring

Management recognized the importance of timely bank reconciliations and accurate financial reporting. The District has implemented procedures requiring all bank reconciliations to be completed and reviewed within 30 days of month-end. A reconciliation checklist has been established to ensure all bal...

Management recognized the importance of timely bank reconciliations and accurate financial reporting. The District has implemented procedures requiring all bank reconciliations to be completed and reviewed within 30 days of month-end. A reconciliation checklist has been established to ensure all balance sheet accounts are reviewed and reconciled monthly. Management will also perform periodic reviews of the general ledger throughout the year to identify and correct discrepancies before year-end. In addition, the District will provide additional training to accounting personnel regarding month-end closing procedures and financial reporting requirements.

View Audit 404340

Finding 1218147 (2025-006)

Material Weakness 2025

Columbia Gorge Community College

OR

Questioned Costs Procurement, Suspension & Debarment Student Financial Aid § 200.303

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of...

Recommendation: We recommend that the college review its processes and internal controls related to SAP and ensure procedures are in place to ensure students who are not meeting SAP requirements are properly identified and disbursed aid in accordance with the institution’s SAP policy. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Since December 2025, the College has worked with the SIS Managed Services team (Anthology now Ellucian) to update its SAP policy and ensure compliance with federal regulations. The new SAP policy was fully implemented effective during the Winter 2026 term. As an internal control, at the end of each term when SAP is evaluated, the results are pre-screened by the Coordinator of Financial Aid with oversight from the Director of Financial Aid to ensure accuracy before results are posted live in the system. Additionally, the College has clarified its understanding of Anthology’s treatment of students who are newly enrolled at the College or who have changed into a different program version. These students are designated with a not-calculated SAP which represents a blank or null status until the conclusion of the term when the students receive a passing or failing grade and can be evaluated by the SAP standards. Steps also have been taken to ensure that prior enrollments are linked to ensure integrity of the application of SAP standards based on the cumulative pace, GPA and maximum timeframe. As a further measure to ensure the integrity of awarding Title IV funds only to eligible students, the College has placed students with prior ineligible SAP statuses in a hold group within the SIS and identified these students as not meeting Disbursement Approval Criteria (DAC) thus causing any attempt to disburse funds to them to fail. Name(s) of the contact person(s) responsible for corrective action: Sarajane Viemeister and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218138 (2025-002)

Material Weakness 2025

Columbia Gorge Community College

OR

Internal Control / Segregation of Duties Questioned Costs Student Financial Aid § 200.303

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to ...

Recommendation: We recommend the college review the requirements and implement an internal process and control to specifically monitor the outstanding Title IV funded checks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: On a monthly basis, as part of the bank reconciliation process, the Business Office generates a report of outstanding student refund checks and reviews it for uncashed items. Uncashed Title IV checks are recorded on a tracking log noting check number, issue date, and amount. When a check remains uncashed for 120 days, the Business Office contacts the student to confirm receipt or determine whether a reissue is needed, and the outreach is documented on the log. The monthly review and log are signed and dated by the preparer; co-signed by the Vice President of Administrative Services, and documentation is retained including months in which no exceptions are noted. At the conclusion of the monthly review process, an email with subject line: Uncashed Refund Checks is forwarded to the Financial Aid Office which includes a spreadsheet listing the students with uncashed refund checks or a note that there were no records for that particular month. Any Title IV check that remains uncashed is canceled by the Business Office. Within 5 - 7 business days of receiving the notification from the Business Office, the Financial Aid Office will notify the third-party servicer, Global Financial Aid Services (herein after referred to as Global) through their established reporting mechanism (GARP) to ensure the funds are returned to the Department of Education no later than 240 days after the date of issuance, as required by 34 CFR 668.164(h). Name(s) of the contact person(s) responsible for corrective action: Sam Draper and Denise Reid-Strachan. Planned completion date for corrective action plan: June 30, 2027.

View Audit 404328

Finding 1218098 (2025-002)

Material Weakness 2025

City of Wentzville, Missouri

MO

Subrecipient Monitoring Material Weakness Reporting

Management has implemented changes to the preparation and review process for grant reporting. Management will continue to evaluate its controls regarding current federal awards and requirements to ensure that accurate information is captured, reported, and maintained. Anticipated completion date: Al...

Management has implemented changes to the preparation and review process for grant reporting. Management will continue to evaluate its controls regarding current federal awards and requirements to ensure that accurate information is captured, reported, and maintained. Anticipated completion date: Already implemented and all final grant expenditures included in final annual report for reporting period ending March 31, 2026.

View Audit 404277

Finding 1218097 (2025-001)

Material Weakness 2025

City of Wentzville, Missouri

MO

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Management will continue to evaluate its controls concerning current federal awards and requirements to ensure that accurate information is captured and reported. Anticipated completion date: Already implemented and all final grant expenditures included in final annual report for reporting period en...

Management will continue to evaluate its controls concerning current federal awards and requirements to ensure that accurate information is captured and reported. Anticipated completion date: Already implemented and all final grant expenditures included in final annual report for reporting period ending March 31, 2026.

View Audit 404277

Finding 1218096 (2025-004)

Material Weakness 2025

Union-North United School Corporation

IN

Subrecipient Monitoring Material Weakness Reporting § 200.302 § 200.328

The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying details. The Director of Grants will make sure this is done in a timely manner to comply with the reporting...

The Director of Grants will continue to prepare the reports and then the Superintendent and Corporation Treasurer will review and sign off on the reports to ensure they agree to the underlying details. The Director of Grants will make sure this is done in a timely manner to comply with the reporting deadlines for each fiscal year.

View Audit 404274

Finding 1218094 (2025-003)

Material Weakness 2025

Union-North United School Corporation

IN

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

The Superintendent, Corporation Treasure, Director of Grants, and the Director of Facilities and or/ Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and or/ Director of Technology will tag the equipment and notify the ...

The Superintendent, Corporation Treasure, Director of Grants, and the Director of Facilities and or/ Director of Technology will monitor equipment purchases larger than $5,000. Once the purchase is made, the Director of Facilities and or/ Director of Technology will tag the equipment and notify the Director of Grants, Treasurer, and Superintendent when the fixed asset inventory is completed and updated.

View Audit 404274

Finding 1218047 (2025-002)

Material Weakness 2025

West Central Nebraska Joint Housing Authority

NE

Internal Control / Segregation of Duties Special Tests & Provisions Eligibility

Finding 2025-002: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the inter...

Finding 2025-002: We agree with the finding. The Authority is relatively small with limited administrative staff. Further, the Board of Commissioners is a volunteer oversight board and not a managing board and does not have the time or expertise to provide the necessary services to correct the internal control deficiencies noted. The Board had reviewed the issue and determined that there are no additional procedures which can be reasonably done to eliminate the deficiencies and accepts them.

View Audit 404211

Finding 1217973 (2025-003)

Material Weakness 2025

City of Hawarden, Iowa

IA

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

2025-003 Material Weakness in Internal Control over Compliance - Review of Project Costs U.S. Department of Homeland Security Federal Emergency Management Agency Passed through State of Iowa Department of Homeland Security & Emergency Management Federal Assistance Listing Number (ALN): 97.036 Federa...

2025-003 Material Weakness in Internal Control over Compliance - Review of Project Costs U.S. Department of Homeland Security Federal Emergency Management Agency Passed through State of Iowa Department of Homeland Security & Emergency Management Federal Assistance Listing Number (ALN): 97.036 Federal Award Year: 2024 Compliance Requirement: Allowable costs/Cost Principles; Internal Control over Compliance Criteria - The Uniform Guidance requires the City to establish and maintain effective internal control over compliance for federal awards, including controls to reasonably ensure that costs charged to federal programs are allowable, properly supported, and comply with applicable federal requirements and the terms and conditions of the award. Condition - The City did not have adequately designed and implemented review controls over certain material project costs included in reimbursement requests submitted to FEMA. Our testing identified that key review procedures intended to verify the eligibility, accuracy, and supporting documentation of project costs were not consistently performed or evidenced for certain large-dollar transactions. Cause - The condition resulted from insufficient formalization and documentation of review procedures, as well as inadequate segregation of duties and oversight for the review of high dollar project costs prior to submission to FEMA. Effect - The absence of effective review controls over material project costs increases the risk that ineligible, unsupported, or incorrectly calculated costs could be included in reimbursement requests without timely detection and correction. This deficiency is considered a material weakness in internal control over compliance for the FEMA Public Assistance program. Recommendation - We recommend that the City design and implement formal, documented review procedures over material project costs included in FEMA reimbursement requests. These procedures should include defined review responsibilities, documentation of the review performed, and supervisory oversight to ensure that all high-dollar or complex transactions are reviewed for eligibility, accuracy, and adequate supporting documentation before submission. Views of Responsible Officials� Management agrees with the finding.

View Audit 404165

Finding 1217970 (2025-001)

Material Weakness 2025

THE RESOURCE ENVIRONMENT FOR UNDERPRIVILEGED GROUPS ENTERPRISE, INC.

CA

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

Management acknowledges that the audit for fiscal year ended June 30, 2025, was not completed and filed with the Federal Clearinghouse in a timely manner. We are working with the auditor to upload the audit the Federal Clearinghouse ASAP. We have taken steps that will ensure an earlier financial clo...

Management acknowledges that the audit for fiscal year ended June 30, 2025, was not completed and filed with the Federal Clearinghouse in a timely manner. We are working with the auditor to upload the audit the Federal Clearinghouse ASAP. We have taken steps that will ensure an earlier financial close, hence earlier audits and anticipated that the fiscal June 30, 2026, will be uploaded to the Federal Clearinghouse by the due date. Yvonne Watson, Director of Finance, will be responsible for the implementation of this CAP. We expect the upload and certification to be complete by close of business on June 19, 2026

View Audit 404147

Finding 1217966 (2025-002)

Material Weakness 2025

Wahupa Educational Services INC

CA

Reporting Internal Control / Segregation of Duties § 200.303 § 200.512

We will ensure that the financial records are maintained on a current basis, reconciled timel and audited going forward.

View Audit 404137

Finding 1217953 (2025-007)

Material Weakness 2025

Opportunities Industrialization Center, INC

NC

Reporting Internal Control / Segregation of Duties § 200.302 § 200.510

Classification Material Weakness Responsible Official Chief Financial Officer Anticipated Completion Date December 31, 2026 Management Response Management concurs with the finding. OIC will formalize federal award tracking and SEFA preparation procedures to ensure federal expenditures are complete, ...

Classification Material Weakness Responsible Official Chief Financial Officer Anticipated Completion Date December 31, 2026 Management Response Management concurs with the finding. OIC will formalize federal award tracking and SEFA preparation procedures to ensure federal expenditures are complete, accurate, and readily identifiable by program. Corrective Action Plan 1. Assign grant codes and Assistance Listing Number identifiers within the accounting system to track federal expenditures by award, funding source, and program. 2. Prepare quarterly SEFA reconciliations to the general ledger, grant records, reimbursement requests, and supporting documentation. 3. Incorporate a SEFA preparation checklist into year-end closing procedures and submit the draft SEFA to the Audit Committee before audit fieldwork. Management will monitor corrective action progress and provide periodic updates to executive leadership, the Finance Committee, Audit Committee, and Board of Directors until all findings are remediated. Management believes these actions will strengthen internal controls, improve audit readiness, and reduce the risk of future findings.

View Audit 404115

Finding 1217948 (2025-006)

Material Weakness 2025

Opportunities Industrialization Center, INC

NC

Reporting Internal Control / Segregation of Duties Questioned Costs § 200.302 § 200.303

Classification Material Weakness Responsible Official Chief Financial Officer and Chief Health Operations Officer Anticipated Completion Date March 31, 2027 Management Response Management concurs with the finding. OIC will strengthen revenue cycle controls to improve patient service revenue recognit...

Classification Material Weakness Responsible Official Chief Financial Officer and Chief Health Operations Officer Anticipated Completion Date March 31, 2027 Management Response Management concurs with the finding. OIC will strengthen revenue cycle controls to improve patient service revenue recognition, accounts receivable valuation, write-off governance, and billing system reconciliations. Corrective Action Plan 1. Transition from a flat encounter-based revenue estimate to a net realizable value methodology that incorporates contractual allowances, sliding fee discounts, implicit price concessions, and allowance for doubtful accounts. 2. Perform monthly documented reconciliations between EPIC, eClinicalWorks, Sage MIP, patient receivables, gross charges, adjustments, collections, write-offs, and general ledger balances. 3. Require documented management review and approval of accounts receivable aging, collectability analyses, write-offs impacting the general ledger, and revenue cycle dashboard reporting.

View Audit 404115

Finding 1217927 (2025-001)

Material Weakness 2025

Agency for Substance Abuse Prevention, Inc.

AL

Internal Control / Segregation of Duties Subrecipient Monitoring

Management of The Agency for Substance Abuse Prevention, Inc. hereby submits the following corrective action plan in response to the single audit findings for the fiscal year ending September 30, 2025: Finding 2025-001 – Segregation of Duties: Description of Finding: The auditor found that duties we...

Management of The Agency for Substance Abuse Prevention, Inc. hereby submits the following corrective action plan in response to the single audit findings for the fiscal year ending September 30, 2025: Finding 2025-001 – Segregation of Duties: Description of Finding: The auditor found that duties were not segregated in a number of areas where small adjustments to the policies of the Entity could help to further facilitate this important control. Statement of Concurrence or Nonconcurrence: Management concurs with this finding. Corrective Action: Management has issued written policies and required training of all employees that handle financial transactions and will continually evaluate processes to find ways to segregate duties where possible. Management and the board of directors will continue to oversee operations closely requiring approvals for all transactions.

View Audit 404065

Finding 1217923 (2025-001)

Material Weakness 2025

Fisk University

TN

Internal Control / Segregation of Duties Questioned Costs Procurement, Suspension & Debarment

2025-001: Internal Controls Over Disbursement Approvals Action Taken/Planned: The University acknowledges the control deficiencies identified related to disbursement approval documentation for federal awards. While policies requiring multi-level approvals are formally established, management recogni...

2025-001: Internal Controls Over Disbursement Approvals Action Taken/Planned: The University acknowledges the control deficiencies identified related to disbursement approval documentation for federal awards. While policies requiring multi-level approvals are formally established, management recognizes that consistent execution and documentation of these controls were not fully adhered to in all instances. Management will formally re-communicate federal disbursement approval requirements to all relevant personnel, i ncluding principal investigators, department heads, and finance staff. This will include mandatory training sessions on federal compliance and approval protocols and distribution of updated written procedures outlining required approval l evels and documentation standards. To reduce reliance on manual processes, the University will configure the financial system/workilow to require multiple l evels of electronic approval prior to payment processing and restrict disbursement processing until all required a pprovals are completed and documented within the system. Management will implement ongoing monitoring procedures to ensure compliance, including monthly reviews of a sample of federal disbursements by the Controller's Office or Grants Accounting, quarterly compliance reporting to the CFO and senior leadership, and documentation of review results and corrective follow-up actions. Anticipated Completion Date/Date Completed: This will be implemented immediately with an anticipated completion date of June 30, 2026

View Audit 404057

Finding 1217914 (2025-001)

Material Weakness 2025

Generations United, Inc.

DC

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

Views of Responsible Officials: Management acknowledges that a formal internal review and approval process over Federal drawdowns was not in place during the audit period, particularly for the more frequent drawdowns that moved from monthly to weekly. The change in drawdown practices, including perf...

Views of Responsible Officials: Management acknowledges that a formal internal review and approval process over Federal drawdowns was not in place during the audit period, particularly for the more frequent drawdowns that moved from monthly to weekly. The change in drawdown practices, including performing draws on a more frequent basis, was implemented in response to managing cash flow and external risks.Management notes that oversight was performed on a periodic basis, specifically each quarter end. Starting in May 2026, one financial party will calculate the Federal pull amount using actual costs and a 10% indirect rate, the Executive Director will review and sign off, and the Director of Grandfamilies & Kinship Support Network will initiate pulling funds from the Federal system.

View Audit 404036

Finding 1217913 (2025-004)

Material Weakness 2025

Abilities Network, Inc.

MD

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.309

Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the a...

Period of Performance Child Care and Development Block Grant – Assistance Listing No. 93.575 Recommendation: We recommend that the Organization design, implement, monitor and maintain evidence over internal controls. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will assign responsibility for maintaining source documentation to a specific individual or team and develop a system for organizing and storing source documentation, such as a centralized electronic database. Monitoring and testing procedures will be implemented to ensure that source documentation is being maintained and is readily accessible. Lastly, there will be regular reviews and updates to the system for organizing and storing source documentation as needed to ensure ongoing effectiveness. Name of the contact person responsible for corrective action: Lyn Elliot, CEO Planned completion date for corrective action plan: 7/1/2026

View Audit 404035

Finding 1217903 (2025-001)

Material Weakness 2025

Marion County Housing Authority

OR

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

1. Implementation of Formal Written Policy MCHA implemented a comprehensive Tenant File Review Policy and Procedure in November 2025. The policy: • Establishes mandatory monthly file review requirements • Defines standardized file selection methodology • Requires consistent documentation of all revi...

1. Implementation of Formal Written Policy MCHA implemented a comprehensive Tenant File Review Policy and Procedure in November 2025. The policy: • Establishes mandatory monthly file review requirements • Defines standardized file selection methodology • Requires consistent documentation of all reviews • Assigns clear roles and responsibilities for oversight and implementation • Requires reviews to be completed monthly without exception, regardless of workload or competing priorities 2. Review Frequency and File Selection • A minimum of 14 tenant files per month are reviewed: o 7 files from the prior month (retrospective review) o 7 files from the upcoming/proactive review group • Files are selected through a randomized process within Compliance Manager, ensuring: o Representation across annual reexaminations, interim reexaminations, and new admissions o A consistent and unbiased sampling of program activity 3. Standardized Review Procedures All file reviews are conducted using a uniform, HOTMA-compliant audit checklist, requiring verification of: • Income and asset calculations • Third-party verification documentation • Required HUD forms and signatures • Accuracy of subsidy determinations (TTP, HAP, utility allowance) • Proper application of payment standards and program requirements 4. Documentation and Internal Control Measures MCHA established a centralized internal tracking system (Excel-based) to document and monitor all file reviews and corrections. • The tracking log: o Is accessible to Case Managers for visibility o Has restricted editing access limited to the Compliance Manager and HCV Program Manager • The log includes: o File selected and review date o Identified deficiencies o Date file is submitted for audit o Date file is returned for correction o Date corrections are completed and formally signed off This process ensures: • A complete audit trail of all reviews and corrections • Separation of duties • Data integrity and accountability 5. Correction and Verification Process • All identified deficiencies must be corrected within established timeframes • Corrections may include: o File documentation updates o Participant or owner follow-up • No file is closed until: o Corrections are verified o Compliance is confirmed by management o Final sign-off is documented 6. Oversight and Accountability • The Program Manager is responsible for: o Overall oversight of the policy and procedures o Ensuring monthly compliance with review requirements o Confirming all deficiencies are resolved prior to closure • The Compliance Manager is responsible for: o Execution and implementation of the review process o Conducting detailed file audits o Maintaining and controlling the tracking log o Monitoring and documenting all correction activity This structure ensures clear segregation of duties, accountability, and consistent oversight. 7. Staff Training and Acknowledgment • All Case Managers received formal training in November 2025 • Each staff member signed a written acknowledgment confirming: o Receipt of the policy o Understanding of requirements • Documentation has been: o Provided to the auditors o Retained for compliance verification Status of Corrective Action Corrective actions were fully implemented in November 2025 and are currently in effect. Planned Completion Date Completed – November 2025 Responsible Officials • HCV Program Manager – Oversight and compliance monitoring • Compliance Manager – Implementation and audit execution Conclusion MCHA believes the corrective actions implemented fully address the identified deficiency. The Authority has established formal written policies, strengthened internal controls, and implemented a structured and sustainable monitoring process. These measures ensure: • Consistent and timely tenant file reviews • Documented tracking and accountability of corrections • Ongoing compliance with HUD program requirements MCHA is confident that these controls prevent recurrence of the issues identified in this finding.

View Audit 404023

Finding 1217832 (2025-003)

Material Weakness 2025

Buckner International and Subsidiaries

TX

Questioned Costs Reporting Significant Deficiency

Corrective Action Plan Program Managers responsible for submitting Performance Reports must copy the appropriate Contract Administrator, Director of Contracts, Accountability & Risk Management and the Director of Transition Services on all correspondence related to report submissions. When an extens...

Corrective Action Plan Program Managers responsible for submitting Performance Reports must copy the appropriate Contract Administrator, Director of Contracts, Accountability & Risk Management and the Director of Transition Services on all correspondence related to report submissions. When an extension is needed, the Program Manager will request written approval from TWC. If an unexpected delay occurs, the Program Manager will notify TWC in writing and confirm the anticipated submission date to support compliance with reporting deadlines. Program Managers will also create tasks and calendar reminders for all applicable reporting and billing due dates. Person(s) Responsible: Bekah Coggins, Director of Transition Services Anticipated Completion Date: Effective May 4, 2026, and onward

View Audit 403954

Finding 1217831 (2025-002)

Material Weakness 2025

Buckner International and Subsidiaries

TX

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these r...

Corrective Action Plan In August 2025, Buckner updated billing policies and procedures related to reporting requirements. Each month, the Finance Administrator generates invoice and General Ledger reports that capture all transitions charged to the contract during the billing period. Because these reports reflect actual amounts posted to internal accounts rather than estimated expenditures, they are used to cross-reference program expenses and support billing submissions. Buckner also implemented additional levels of review to ensure the Program Manager completes billing documentation accurately, the Program Director reviews followed by final review by the Finance Administrator. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective August 20, 2025, and onward

View Audit 403954

Finding 1217830 (2025-001)

Material Weakness 2025

Buckner International and Subsidiaries

TX

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calcula...

Corrective Action Plan In June 2025, Buckner began billing based on actual time worked to better align with state requirements. In January 2026, the Finance Administrator implemented a revised timecard template that requires supervisor time-stamped approval and includes protected formulas to calculate allocations and reduce errors. Each month, the Finance Administrator calculates allocations based on time worked, provides them to the Program Director for billing, and reviews state billing submissions to confirm accuracy. Person(s) Responsible: Stefani Turner, Finance Administrator Bekah Coggins, Director of Transition Services Anticipated Completion Date Effective June 20, 2025, and onward

View Audit 403954

Finding 1217821 (2025-001)

Material Weakness 2025

Virginia Foundation for Community College Education

VA

Questioned Costs Cash Management Internal Control / Segregation of Duties

View of Responsible Officials The Foundation is of the opinion that finding number 2025-001 for Cash Management is not applicable to the Equipment for Skilled Trades Training Programs as part of the Virginia Infrastructure Academy under ALN 84-116Z as requests for advance payments were limited to th...

View of Responsible Officials The Foundation is of the opinion that finding number 2025-001 for Cash Management is not applicable to the Equipment for Skilled Trades Training Programs as part of the Virginia Infrastructure Academy under ALN 84-116Z as requests for advance payments were limited to the minimum amounts needed and were timed with actual, immediate cash requirements to carry out the purpose of the approved programs and projects. With regards to College and Career Success for Foster Youth through Work-based Learning Opportunities and Coaching Support under ALN 84-116Z, the Foundation was notified by the U.S. Department of Education on September 12, 2024, that unused principal be returned. On September 25, 2024, the funds in the amount of $753,800 were refunded by wire transfer. This was the only notification the Foundation received from the U.S. Department of Education; no other notification was received regarding other advance payments made during the fiscal year. With regards to Improving the Quality of Early Childhood Educators under ALN 84-116Z, the Foundation did not receive any notification from the U.S. Department of Education requesting that advance payments be returned. In all instances of advance payments, the Foundation maintained funds in interest bearing accounts as outlined in the respective agreements for the three federal awards. With regards to the requests for advances that were made on a quarterly basis, the respective agreements for the three federal awards do not explicitly outline a timeframe for advance payments, nor did these advances trigger the federal government’s threshold for excessive drawdown. Estimated quarterly advance payments were made from the uncertainty of the U.S. Department of Education clawing back award funding while ensuring sufficient cash on hand to support approaching distributions to students and colleges and mitigating risk to the Foundation covering respective distributions with its own funds. Brown Edwards shared the suggested interpretation is a one-to-three-day timeframe between drawdown and distribution. Action taken: The Foundation calculated advance payment balances as of November 4, 2025, and issued respective returns to the U.S. Department of Education on November 5, 2025. Subsequent drawdowns have been made on a reimbursement basis. Action planned: The Foundation will revise its policies and procedures for requesting federal funds to ensure that requests for advance payments be limited to the minimum amounts needed and be timed with actual, immediate cash requirements to carry out the purpose of approved programs and projects. Specific steps: The Foundation will develop and implement a written policy requiring a documented review of immediate cash needs before any federal fund drawdown request is submitted and establishing a process to request funds on a reimbursement basis or just-in-time advance basis to align drawdowns with actual disbursements. Responsibility: The Chief Operating Officer and Finance Manager will work to draft the policy and will bring it to the Audit Committee for review and approval. Timeline: Policy approved and implemented by February 2026.

View Audit 403931

Finding 1217749 (2025-001)

Material Weakness 2025

Housing Authority of the County of Lebanon

PA

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions

Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Plan, Uniform Guidance and the compliance supplement. Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the audito...

Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure compliance with the Plan, Uniform Guidance and the compliance supplement. Authority's Response and Planned Corrective Action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Section 8 Housing Choice Vouchers Program to ensure that established internal control policies included within the Plan are being followed. Daniel Lyons, Executive Director, is responsible for implementing this corrective action by June 30, 2026.

View Audit 403900

Finding 1217747 (2025-004)

Material Weakness 2025

Phoenix Indian Center

AZ

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.512

At the start of each fiscal year, the Finance Director will prepare a submission timeline working backward from the March 31 FAC deadline, establishing interim milestones for year-end close, draft financial statement preparation, management review, and auditor fieldwork. Progress against the submiss...

At the start of each fiscal year, the Finance Director will prepare a submission timeline working backward from the March 31 FAC deadline, establishing interim milestones for year-end close, draft financial statement preparation, management review, and auditor fieldwork. Progress against the submission timeline will be monitored by the CEO and reported to the Board of Directors on a quarterly basis. Management will engage its external auditors earlier in the process and ensure adequate finance staffing is maintained prior to the fiscal yearend close.

View Audit 403879

Finding 1217738 (2025-003)

Material Weakness 2025

Trellis Co.

MN

Subrecipient Monitoring HUD Housing Programs Reporting

Finding 2025-003 – Untimely Return of Security Deposits Name of contact person: Lisa Fischer, (Chief Operating Officer) Corrective action: Management agrees with the finding and has implemented procedures to monitor tenant move-outs, document amounts due to former tenants, and issue refund checks in...

Finding 2025-003 – Untimely Return of Security Deposits Name of contact person: Lisa Fischer, (Chief Operating Officer) Corrective action: Management agrees with the finding and has implemented procedures to monitor tenant move-outs, document amounts due to former tenants, and issue refund checks in a timely manner. Proposed completion date: Management has corrected the finding.

View Audit 403859

Corrective Action Plans

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