Corrective Action Plans

Finding 1159421 (2024-001)

Material Weakness 2024

NY

Special Tests & Provisions Subrecipient Monitoring Eligibility

Health Resources and Services Administration Brooklyn Plaza Medical Center, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2024. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: December 31, 2024 The findings from the Decemb...

Health Resources and Services Administration Brooklyn Plaza Medical Center, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2024. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: 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. FINDINGS – FEDERAL AWARDS PROGRAM AUDIT U.S. Department of Health and Human Services, COVID-19 Health Center Program Cluster (Assistance Listing Number 93.224/93.527) FAIN # H8000410, H8N53897, and H8L50850 for 2024 Finding 2024-001 – Special Tests and Provisions MATERIAL WEAKNESS Recommendation We recommend that proper training be given to employees at registration to ensure that the sliding fee discounts be monitored and reviewed by a supervisor on a periodic basis to ensure compliance with the sliding fee scale. In addition, management should conduct internal audits to ensure the sliding fee is calculated properly. Action Taken Corrective action for this finding was put in place in September 2024 We agree with the auditors finding. We acknowledge that, within the current audit sample of 57 patient files, 2 were found to contain instances of noncompliance with the Sliding Fee Scale (SFS) requirements. We recognize the importance of full compliance and remain firmly to continuous improvement in this area. It is important to note that this represents a significant improvement from the prior year’s audit. The identification of only 2 errors out of 57 patients’ files selected highlights the effectiveness of the corrective actions plan we implemented in response to the previous finding. Corrective Actions and Improvements Implemented: 1. Staff Training- Following the prior audit, front desk staff received additional training emphasized accurate application of SFS policies, required documentation, and proper income verification protocols. 2. Internal Auditing- Beginning in September 2024, The CEO designated the Compliance Officer to conduct daily audits of SFS related documentation. These real time audits help identify and correct issues promptly, with findings continuously incorporated into staff training programs. While we are encourage with the progress made, we remain focused on achieving full compliance and will continue to refine our processes and training to meet that goal. If the Health Resources and Services Administration has questions regarding this plan, please call Daniel Desire, Chief Financial Officer at 718-596-9800, ext 226. Sincerely yours, Daniel Desire, CFO

View Audit 370146

Finding 1159417 (2024-004)

Material Weakness 2024

Supports to Encourage Low Income Families INC

OH

Reporting Internal Control / Segregation of Duties

In October 2024, immediately after the above-referenced fraud was committed, SELF created a new policy with tighter internal controls in regard to ACH payments. The new policy requires multiple staff members to verify any banking information (in multiple ways) before any such payment can be initiate...

In October 2024, immediately after the above-referenced fraud was committed, SELF created a new policy with tighter internal controls in regard to ACH payments. The new policy requires multiple staff members to verify any banking information (in multiple ways) before any such payment can be initiated. The new policy was approved shortly thereafter by the organization’s board. SELF also contracted with a digital security company to train all employees about digital threat awareness including fraud and phishing attempts, specifically via email. As part of these new practices, all employees are required to participate in monthly training.

View Audit 370141

Finding 1159415 (2024-001)

Material Weakness 2024

Gowest Foundation

WA

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

It should be noted that distribution of funds under this program terminated on December 31, 2024; no new loans will be originated. The Foundation will implement the recommended actions as appropriate in future programs that may be similar to this one.

View Audit 370140 Questioned Costs: $1

Finding 1158306 (2024-006)

Material Weakness 2024

Mount Sinai Health System, Inc.

NY

Student Financial Aid Allowable Costs / Cost Principles Reporting

Finding 2024-006 L. Reporting Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees with the finding that FISAP was not c...

Finding 2024-006 L. Reporting Information on the federal program: Grantor: Department of Education Program Name: Student Financial Assistance Cluster Assistance Listing No.: Various Views of responsible officials and planned corrective actions: Management agrees with the finding that FISAP was not correctly populated. Management has since corrected the data and submitted a revised FISAP. Management notes there was turnover in the PSON’s Office of Student Financial Aid during the year and an employee was not properly trained on the FISAP preparation. Training has since been implemented and new employees in the department will be trained accordingly. Names of responsible official: Denis Donegan Vice President of Finance, Mount Sinai Health System Denis.donegan@mountsinai.org Projected completion date: The project is expected to complete by December 31, 2025.

View Audit 370128

Finding 1158246 (2024-001)

Material Weakness 2024

Providence St. Joseph Health

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303

Management concurs with KPMG’s assessment that the risk assessment and monitoring control activities were not sufficiently designed to ensure adequate segregation of duties or to provide evidence of control operation. These gaps were primarily due to limited staffing and processes that have not evol...

Management concurs with KPMG’s assessment that the risk assessment and monitoring control activities were not sufficiently designed to ensure adequate segregation of duties or to provide evidence of control operation. These gaps were primarily due to limited staffing and processes that have not evolved to meet all compliance requirements. Management will implement new control policies and procedures that ensure proper segregation of duties and introduce review mechanisms at a sufficient level of precision to detect and prevent noncompliance. These policies and procedures will be implemented by December 31, 2025.

View Audit 370126

Finding 1158224 (2024-001)

Material Weakness 2024

Housing Authority of the City of Yakima

WA

HUD Housing Programs Reporting Internal Control / Segregation of Duties § 200.512

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Authority has reviewed and updated its financial reporting and closing processes and controls he preparation of the final trial balances and related schedules...

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Authority has reviewed and updated its financial reporting and closing processes and controls he preparation of the final trial balances and related schedules. As part of this process, we will create a year-end checklist with deadlines established and set up status meetings to monitor the progress. Name(s) of the contact person(s) responsible for corrective action: Lowel Kruger, Executive Director. Planned completion date for corrective action plan: December 31, 2024

View Audit 370115

Finding 1158222 (2024-004)

Material Weakness 2024

The Family Place

TX

Reporting Internal Control / Segregation of Duties § 200.320

Auditor’s Recommendation: “We recommend management implement internal controls to ensure ﬁnancial reports are submitted accurately, with supporting documentation retained.” Management response: The Family Place has reviewed its ﬁnancial reporting procedures and concurs with the ﬁnding. During the au...

Auditor’s Recommendation: “We recommend management implement internal controls to ensure ﬁnancial reports are submitted accurately, with supporting documentation retained.” Management response: The Family Place has reviewed its ﬁnancial reporting procedures and concurs with the ﬁnding. During the audit period, staffing deﬁciencies in grants management and compliance oversight contributed to supporting documentation of ﬁnancial reports submitted not having been retained. In 2025, The Family Place created a new internal compliance department and hired a Grants Manager to provide dedicated oversight of grant drawdowns and reporting. These changes, together with updated procedures and training, are designed to ensure all future ﬁnancial reports comply with Uniform Guidance requirements and supporting documentation is retained. Corrective actions: The Executive Leadership Team has prioritized strengthening reporting controls and has already implemented several measures: The newly hired Grants Manager and internal compliance department are responsible for reviewing and approving all ﬁnancial reports to conﬁrm that expenditures have been incurred and liquidated prior to request. Finance sta􀀁 and program managers are being trained on reporting requirements under 2 CFR 200.320. All ﬁnancial reports will be reconciled to the general ledger with supporting documentation and will be reviewed by the Grants Manager and The Chief Financial Officer or Chief Executive Officer before submission. These processes will receive additional oversight by the Chief Financial Officer, the Chief Executive Officer, and the Board of Trustees. Responsible parties for corrective actions: The Grants Manager, working within the internal compliance department, will have direct responsibility for ensuring ﬁnancial reports are accurate and supporting documentation is retained. The Chief Financial Officer will review and approve reconciliations prior to drawdown. The Chief Executive Officer, Tiffany A. Tate, with assistance from the newly established Compliance Department, will conﬁrm timely compliance and will receive regular status updates. Separately, the Chief Financial Officer will report progress to the Audit & Finance Committee of the Board of Trustees. Anticipated completion date: The new internal compliance department and Grants Manager began operating together in September 2025. Full compliance monitoring is currently in place.

View Audit 370113

Finding 1158217 (2024-002)

Material Weakness 2024

The Family Place

TX

Procurement, Suspension & Debarment Cash Management Reporting § 200.303

Auditor’s Recommendation: “We recommend management ensure sufficient staffing and oversight to abide by internal processes and procedures which require prior approval of expenditures and reports prior to drawdown or submission.” Management response: The Family Place has reviewed its award compliance...

Auditor’s Recommendation: “We recommend management ensure sufficient staffing and oversight to abide by internal processes and procedures which require prior approval of expenditures and reports prior to drawdown or submission.” Management response: The Family Place has reviewed its award compliance procedures and concurs with the ﬁnding. During the period, responsible departments—including the ﬁnance and accounting and human resources teams—experienced unexpected turnover, a signiﬁcant shortage of staffing, and a time reporting system conversion. As a result, certain compliance procedures were not performed consistently and timely, resulting in unintentional noncompliance with respect to allowable costs, cash management, and reporting controls. Corrective actions: The Executive Leadership Team reviewed the staffing needs of the ﬁnance and accounting and human resources teams in 2024. Hiring and training staff to achieve a full team was established as key objectives for the Executive Leadership Team in early 2025. As of September 2025, all vacant positions in both teams have either been ﬁlled or have been posted and are in active hiring process. The Chief Financial Officer and Chief of Human Resources have reviewed all internal procedures related to award compliance and will ensure that compliance is timely and well documented going forward. Speciﬁcally, the Chief Financial Officer will ensure that purchase orders, invoices, ﬁnancial reports, and performance reports are completed, reviewed, and approved prior to submission and funding. These processes will have additional oversight by the Chief Executive Officer, with assistance from the newly established Compliance Department, and the Board of Trustees. Responsible parties for corrective actions: The Chief Financial Officer will have direct responsibility for award compliance and will be supported by Chief of Human Resources. The Chief Executive Officer, Tiffany A. Tate, with assistance from the newly established Compliance Department, will conﬁrm that compliance occurs on a timely basis and prior to submission and funding. Separately, the Chief Financial Officer will report on progress to the Audit & Finance Committee of the Board of Trustees. The Executive Leadership Team will be responsible for ensuring the ﬁnance and accounting and human resources teams achieve and maintain full staffing levels. Anticipated completion date: The organization is actively implementing the corrective actions by ensuring sufficient staffing as mentioned above and training to ensure prior approval of all grant reports and drawdown requests. As of October 1, 2025, all grant reports will be appropriately approved and documented as such.

View Audit 370113

Finding 1158192 (2024-006)

Material Weakness 2024

Atrium Health, Inc.

NC

Student Financial Aid Cash Management Period of Performance

Corrective Action Plan: Atrium Health CMHA management in the future will ensure that all correspondence, including notes from review meetings and approvals of key decisions, will be documented and retained as part of the support records for FEMA related awards. Proposed Completion Date: No further a...

Corrective Action Plan: Atrium Health CMHA management in the future will ensure that all correspondence, including notes from review meetings and approvals of key decisions, will be documented and retained as part of the support records for FEMA related awards. Proposed Completion Date: No further action is required until future needs arise for Atrium Health CMHA to obtain FEMA funding awards at which time management will ensure all documentation supporting the process and key decisions are retained.

View Audit 370096

Finding 1158176 (2024-002)

Material Weakness 2024

Philadelphia Industrial Development Corporation

PA

Internal Control / Segregation of Duties Material Weakness Reporting

2024-002 – Incorrect Filing of Form ED-209 to the EDA Management inaccurately reported balances on Form ED-209 to the EDA. This inaccurate reporting is due to a lack of management review over the reported amounts. Per the ED-209 report, PIDC had $6,048,775 of principal outstanding on loans as of Dec...

2024-002 – Incorrect Filing of Form ED-209 to the EDA Management inaccurately reported balances on Form ED-209 to the EDA. This inaccurate reporting is due to a lack of management review over the reported amounts. Per the ED-209 report, PIDC had $6,048,775 of principal outstanding on loans as of December 31, 2024; however, per the supporting documentation only $5,048,775 of principal outstanding on loans was recorded within the financial statements as of December 31, 2024. Corrective Action During 2024, PIDC initiated an EDA loan to a borrower in the amount of $1,000,000. While the loan was committed at December 31, 2024, the loan was never disbursed. We will establish a dedicated oversight team of existing personnel to monitor the reporting process and to ensure reconciliation of our loan portfolio system. Furthermore, we will streamline our reporting processes by conducting a thorough review and implementing necessary changes. Ongoing training for portfolio management staff on new techniques and software tools will be initiated and continue on a regular basis. Regular progress reviews will be conducted to address quality issues promptly. By implementing these corrective actions, we aim to prevent inaccurate reporting Individual Responsible for Corrective Action Plan Lawrence McComie SVP & Chief Credit Officer 215-496-8145 Anticipated Completion Date: 30 days from issuance, management will file an updated ED-209 report to the EDA.

View Audit 370094

Finding 1158174 (2024-002)

Material Weakness 2024

Washington Tourism Alliance

WA

Subrecipient Monitoring Reporting Significant Deficiency

FINDING 2024-002 – Reporting; Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance The grant contract conditions require that applicable reports be filed quarterly. State of Washington Tourism initially submitted performance reports monthly, but in Q4 of 2024 adju...

FINDING 2024-002 – Reporting; Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance The grant contract conditions require that applicable reports be filed quarterly. State of Washington Tourism initially submitted performance reports monthly, but in Q4 of 2024 adjusted the performance reports to quarterly in accordance with award agreement timeframe. The Accounting Manager will complete the report and provide documented support at the end of each quarter in the future. The reports will be reviewed, approved, and submitted by the Director of Strategic Partnership and Tourism Development. These changes took effect April 2025.

View Audit 370086

Finding 1158173 (2024-001)

Material Weakness 2024

Washington Tourism Alliance

WA

Allowable Costs / Cost Principles Cash Management Significant Deficiency

Finding 2024-001 – Allowable Costs Payroll; Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance State of Washington Tourism did not maintain supporting documentation for payroll amounts charged to the Economic Adjustment Assistance Grant. We conducted calculation...

Finding 2024-001 – Allowable Costs Payroll; Significant Deficiency in Internal Control over Compliance and Instance of Noncompliance State of Washington Tourism did not maintain supporting documentation for payroll amounts charged to the Economic Adjustment Assistance Grant. We conducted calculations and provided supporting documentation noting $27,387 in operations underbilled to the grant. Prior to these audit findings, we have implemented controls and procedures to document dedicated hours worked on the grant and supporting payroll details. The Accounting Manager will provide payroll details with supporting documentation, and the Director of Strategic Partnership and Tourism Development will review/approve dedicated hours and operations expense worksheet. These changes took effect April 2025.

View Audit 370086

Finding 1158148 (2024-003)

Material Weakness 2024

Chrysalis Center

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.302 § 200.403 § 200.430

Management will evaluate systems and processes to ensure time tracking procedures meet the standards outlined in the Uniform Guidance.

View Audit 370071

Finding 1158145 (2024-002)

Material Weakness 2024

YMCA of Metropolitan Fort Worth

TX

Material Weakness Reporting Significant Deficiency

Response: The YMCA of Metropolitan Fort Worth has strengthened its review process to ensure all required federal grant reports are submitted by the established deadlines. Reports will be prepared and reviewed at least one week prior to the required submission date. A compliance calendar will be main...

Response: The YMCA of Metropolitan Fort Worth has strengthened its review process to ensure all required federal grant reports are submitted by the established deadlines. Reports will be prepared and reviewed at least one week prior to the required submission date. A compliance calendar will be maintained and monitored by the Finance Department. All reports will undergo supervisory review by a staff member other than the preparer before submission. Date of Completion: September 30, 2025 Person Responsible to Ensure Completion: Kristen Lee, Chief Finance & Administration Officer

View Audit 370064

Finding 1158130 (2024-003)

Material Weakness 2024

Lansing Economic Area Partnership, Inc.

MI

Reporting Internal Control / Segregation of Duties Significant Deficiency

2024-003 – Grant Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, Small Business Support Hubs Program passed through the Michig...

2024-003 – Grant Reporting Finding Type. Immaterial Noncompliance/Significant Deficiency in Internal Control over Compliance (Reporting). Program. Coronavirus State and Local Fiscal Recovery Funds; U.S. Department of Treasury; ALN 21.027, Small Business Support Hubs Program passed through the Michigan Strategic Fund. Auditor Description of Condition and Effect. Although we were able to review the quarterly reporting due during the fiscal year, we initially noted that the reports quarterly totals did not add up to the year-to-date totals, and total cost for the year reported, as well as quarterly totals, did not agree to the general ledger or the Schedule of Expenditures of Federal Awards. Management was able to subsequently correct these errors. Additionally, it was noted that there was no formal review and approval process over the completion and submission of the grant reports. As a result of this condition, the Organization reported inaccurate amounts to the grant pass-through agency. Auditor Recommendation. We recommend that the Organization base all grant financial reporting on general ledger detail of costs and that the reporting be reconciled to the Schedule of Expenditures of Federal Awards at year-end. In addition, all reports should be reviewed and approved by appropriate personnel prior to submission. Corrective Action. LEAP will be following the recommendation of basing all grant financial reporting on general ledger detail of costs and being more diligent in reconciling that ledger to the Schedule of Expenditures of Federal Awards at year-end. Further all reports moving forward will be reviewed and approved by CFO and COO in addition to the department head who is compiling with their team. LEAP’s modifications to its Grants Management SOP in 2025 are designed to also cover grant reporting process per Uniform Guidance requirements. This grant reporting issue too will be covered in the content of LEAP’s training for all management team members set to occur in August. Responsible Person. Tony Klisch, LEAP CFO Anticipated Completion Date. August 31, 2025

View Audit 370048

Finding 1158125 (2024-003)

Material Weakness 2024

Tulsa Community Foundation

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency § 200.318 § 200.326

Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement po...

Description of Finding: The Foundation and its affiliates did not ensure proper documentation was retained regarding its procurement process. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will adopt a procurement policy in accordance with UGG 2 CFR 200.318 through 200.327 and will collaborate more closely with project partners of federal grants to ensure documentation requirements for the procurement process are adhered to and work to centralize grant documentation for all awards. This will be in tandem with establishing effective internal controls as per Uniform Guidance 2 CFR 200.303. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and centralization of grant documentation to be established by December 31, 2025.

View Audit 370045

Finding 1158124 (2024-002)

Material Weakness 2024

Tulsa Community Foundation

OK

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting

Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely ...

Description of Finding: The Foundation and its affiliates did not ensure proper performance reporting was completed for individual grants. Statement of Concurrence or Nonconcurrence: Tulsa Community Foundation agrees with this finding. Corrective Action: The Foundation will collaborate more closely with project partners of federal grants to establish reporting deadlines and monitor individual reporting requirements throughout the year. This will be in tandem with establishing effective internal controls as per UGG 2 CFR 200.303. The Foundation will take steps to ensure that all required reports are submitted in a timely manner and all relevant documentation and evidence of reports’ submissions are retained in an effective manner. To support this corrective action, the Foundation has hired an experienced senior accountant to strengthen internal capacity. The qualified senior accountant will oversee federal grants and ensure ongoing compliance with internal controls and help to prevent recurrence of the issue. Name of Contact Person: Kristin Karlin, Controller Projected Completion Date: The Foundation projects the new policy documentation to be complete and the process for internal monitoring documentation to be established by December 31, 2025.

View Audit 370045

Finding 1158094 (2024-003)

Material Weakness 2024

Acupuncture and Integrative Medicine College, Berkeley

CA

Student Financial Aid Reporting Significant Deficiency

As of today, September 29, 2025, the organization has fully implemented procedures in Populi to update enrollments to actual final status within the required 30 days. This data will be reported to our third-party servicer RGM in real-time. The academic and administrative teams review these reports.

View Audit 370038

Finding 1158093 (2024-002)

Material Weakness 2024

Acupuncture and Integrative Medicine College, Berkeley

CA

Student Financial Aid Material Weakness Internal Control / Segregation of Duties

Over the past two months in August and September, the board has reviewed the budget and the organization has sharply reduced staff and facility costs at both the Austin and Berkeley campuses. This will ensure that the organization qualifies for at least a 1.0 on the composite score and qualify for a...

Over the past two months in August and September, the board has reviewed the budget and the organization has sharply reduced staff and facility costs at both the Austin and Berkeley campuses. This will ensure that the organization qualifies for at least a 1.0 on the composite score and qualify for a letter of credit alternative or provisional certification alternative to meet the fiscal responsibility requirements through the 2025 fiscal year audit. As of today, September 29, 2025, expense reductions have been implemented.

View Audit 370038

Finding 1158088 (2024-001)

Material Weakness 2024

Manhattan Housing Authoirty

KS

Reporting Internal Control / Segregation of Duties

Finding 2024-001 Criteria: The Authority did not maintain adequate internal controls over financial reporting. Condition: During audit testing we noted the following:  The Authority recorded a prior period adjustment in order to correct misstatements of deferred inflows of resources and leases rece...

Finding 2024-001 Criteria: The Authority did not maintain adequate internal controls over financial reporting. Condition: During audit testing we noted the following:  The Authority recorded a prior period adjustment in order to correct misstatements of deferred inflows of resources and leases receivable.  Numerous adjusting entries were required to present the Authority's financial statements in accordance with GAAP. Cause: Controls were not fully executed to ensure that the Authority recorded and reported financial data consistently and reliably in accordance with generally accepted accounting principles. Effect: The Authority required an immoderate number of adjustments in order to report accurate results in accordance with generally accepted accounting principles. Auditors' Recommendation: We recommend the Authority implement their internal controls; specifically, the Authority should ensure they are performing monthly procedures whereby financial statements and general ledger accounts are reviewed for accuracy and reconciled to their subsidiary ledgers. Authority Response and Planned Corrective Action: The Authority agrees with the findings and is in process of assessing and modifying internal controls to avoid similar issues. The Authority will reconcile the statement of financial position and other key account balances on an ongoing and periodic basis. The Authority will also reconcile account balances following any large and unusual adjusting entries. Aaron Estabrook, Executive Director, is responsible for implementing this corrective action by December 31, 2025.

View Audit 370029

Finding 1158084 (2024-003)

Material Weakness 2024

Native Village of Point Hope

AK

Material Weakness Reporting Internal Control / Segregation of Duties

Finding 2024-003 Late Reporting and Noncompliance with Reporting Requirements Type of Finding: Material weakness in internal control over compliance and material noncompliance. Name of Contact: Adela Lane, Executive Director. Corrective Action Plan: 1. Update and formalize policies and procedures: •...

Finding 2024-003 Late Reporting and Noncompliance with Reporting Requirements Type of Finding: Material weakness in internal control over compliance and material noncompliance. Name of Contact: Adela Lane, Executive Director. Corrective Action Plan: 1. Update and formalize policies and procedures: • Action: Conduct a comprehensive review and update of the Administrative Manual Systems, Chapter III: Financial Management, focusing specifically on all sections related to Uniform Guidance (UG) reporting. This includes procurement, reporting, and subrecipient monitoring requirements. • Details: o Develop and document detailed, step-by-step procedures for each UG reporting requirement. o Ensure all policies reflect the most current version of the UG, including the 2024 revisions. o Secure formal approval of the revised manual from tribal leadership. 2. Standardize and conduct mandatory staff training: • Action: Develop and implement a structured, mandatory training program for all staff involved in federal grant management, including finance, administrative, and program personnel. • Details: o Content: The training will cover the revised UG policies, focusing on reporting deadlines, documentation requirements, and proper internal controls. o Onboarding: The Executive Director will meet with all new permanent staff within their first two weeks of employment to review these protocols and emphasize the importance of compliance. o Ongoing Training: Conduct annual refresher training for all relevant staff to address any new changes or best practices. 3. Enhance monitoring and oversight: • Action: Establish a robust system of internal oversight to ensure continuous compliance with UG reporting requirements. • Details: o Regular Reviews: The Executive Director will implement a schedule of regular reviews of financial records to confirm that all supporting documentation for federal awards is correctly attached and reports are filed accurately and on time. o Reporting Checklist: Create and use a standardized checklist for each federal award to ensure all specific reporting requirements are met prior to submission. o Audit Readiness: Perform periodic internal compliance checks or "mock audits" to identify and correct potential issues before an external audit. 4. Strengthen documentation and audit trail: • Action: Improve the organization and accessibility of all documentation required for UG reporting to facilitate a clear and defensible audit trail. • Details: o Centralized Record-keeping: Establish a centralized, secure digital location for all federal award documents, including grant agreements, financial reports, and supporting records. o Documentation Protocol: Implement a protocol requiring all relevant personnel to upload and correctly label all necessary documentation immediately after a transaction is completed. 5. Designate responsibility and accountability: • Action: Clearly assign responsibility for each UG compliance task to specific individuals to eliminate confusion and ensure accountability. • Details: For each grant, a lead financial staff member will be designated as the primary point of contact responsible for ensuring all UG reporting and documentation requirements are met. The Executive Director will oversee this process. Proposed Completion Date: Ongoing, Starting Early 2026.

View Audit 370023

Finding 1158059 (2024-002)

Material Weakness 2024

Stone Lake Woods, Inc.

MI

HUD Housing Programs Internal Control / Segregation of Duties Reporting

Management will implement a formal tracking system and internal calendar reminders to ensure timely submission of audited financial statements in accordance with HUD requirements.

View Audit 370012

Finding 1158052 (2024-001)

Material Weakness 2024

Healthy Relationships California

CA

Questioned Costs Internal Control / Segregation of Duties Material Weakness

The Organization concurs with the finding and has begun implementing corrective action to address the identified issues, including enhancing internal controls and strengthening review procedures to ensure more accurate and timely financial reporting going forward.

View Audit 370000 Questioned Costs: $1

Finding 1158050 (2024-001)

Material Weakness 2024

Semo Electric Cooperative

MO

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness

2024-001 Material Weakness in Internal Control A. Comments on Findings and Recommendations: We concur with the auditor’s findings and recommendations regarding reporting of project expenses and unidentified errors in project reconciliations completed by staff. B. Actions Taken or Planned: Management...

2024-001 Material Weakness in Internal Control A. Comments on Findings and Recommendations: We concur with the auditor’s findings and recommendations regarding reporting of project expenses and unidentified errors in project reconciliations completed by staff. B. Actions Taken or Planned: Management concurs. Large fiber installation project still in process at year-end. Subsequent reconciliations have been completed. Controls and other project processes have been improved to ensure more timely reconciliation of material charge-outs to the timing of the installation of material. Anticipated completion date: Completed Contact information for this finding: Amanda Burnett, Chief Financial Officer, 573-471-5821

View Audit 369998

Finding 1158021 (2024-001)

Material Weakness 2024

Center for Black Excellence and Culture

WI

Procurement, Suspension & Debarment Internal Control / Segregation of Duties

2024-001 Accounting Policies and Financial Review Corrective Action Plan The Center for Black Excellence and Culture Inc has drafted an accounting policies and procedures document that will be reviewed and approved by the Board of Directors by December 31, 2025. Person(s) Responsible: Janine Stephen...

2024-001 Accounting Policies and Financial Review Corrective Action Plan The Center for Black Excellence and Culture Inc has drafted an accounting policies and procedures document that will be reviewed and approved by the Board of Directors by December 31, 2025. Person(s) Responsible: Janine Stephens Hale, Chief Administrative Officer Timing for Implementation: No later than December 31, 2025.

View Audit 369989

Corrective Action Plans

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