Corrective Action Plans

Finding 1172131 (2025-007)

Material Weakness 2025

NC

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Material Weakness and Nonmaterial Noncompliance – Eligibility and Special Tests: In...

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Temporary Assistance for Needy Families Federal Assistance Listing Number: 93.558 Material Weakness and Nonmaterial Noncompliance – Eligibility and Special Tests: Income Eligibility and Verification System Finding 2025-007 Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination, and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) An OVS inquiry must be completed and agreed to information reported in NC FAST. b) For the month of application, Work First cash assistance payments are prorated from the date of application, with the date of application being day one. c) All Work First applicants must provide a Social Security number or apply for a Social Security number if they do not have one. d) Parents and step-parents who apply for children must be included in the case with the child, unless they are otherwise ineligible. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 25 program participants selected for testing a) There were two instances where the OVS query was not run at the time of the determination. b) There was one instance where a hearing extension was incorrectly prorated. c) There was one instance where the social security number was not verified. d) There was one instance where kinship was not documented. Lastly, the following are the results of 60 program participants tested for control testing: a) There were three instances where the County did not remediate the errors identified within their internal review timely. b) There was one instance where a participant received benefits for one month where they should not have. c) There was one instance where incorrect forms were sent to a participant. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: The Economic Services Division (ESD) Quality and Training Specialist will conduct a 25% sample review of all ongoing cases. Errors identified during these reviews will be documented and communicated to both the Social Services Supervisor and the assigned Eligibility Specialist for correction within a defined timeframe. Failure to comply with correction timelines will result in corrective action. Case Review and Error Notification • ESD Sr. Quality and Training Specialist will review 25% of all ongoing cases. • Errors will be documented on checking sheets and emailed to both the supervisor and the assigned Eligibility Specialist. • Corrections must be completed within 5 business days of notification. Corrective Action • If corrections are not completed within the extended timeframe: o Corrective Action will be initiated in accordance with departmental performance management protocols. Responsible Individuals: Sarah Carter, Tatyenne Rone, Karl Parisien, Denize Cuff (Sr. Quality and Training Specialist), Danisa Concepcion (Quality and Training Supervisor), Staphon Snelling (Training & Development Manager), Scott Fritz (Social Services Manager), Program Supervisors Anticipated Completion Date: To be completed monthly. Training: Training Completion Required for the Following Quality Review Errors: • Ensure the OVS inquiry is completed, and that the information aligns with data reported in NC FAST. • Understand that Work First cash assistance payments are prorated from the application date, which is considered Day One. • Confirm that all Work First applicants must provide a valid Social Security number or apply for one if not already obtained. • Review and apply the rules of kinship, specifically regarding parents and stepparents. Additionally, train supervisors and eligibility specialists on the importance of timely resolution of quality sampling errors and how delays can impact audit outcomes. Responsible Individuals: Sr. Quality & Training Specialists, Quality & Training Supervisor, Training & Development Manager. Anticipated Completion Date: An email will be sent by the Staff Development Unit to the Eligibility Specialist with errors by January 2026, and in-person training will be completed by February 2026.

View Audit 385263

Finding 1172123 (2025-005)

Material Weakness 2025

Mecklenburg County

NC

Questioned Costs Subrecipient Monitoring Eligibility

Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Eligibility Finding 2025-005 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective...

Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Eligibility Finding 2025-005 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Questioned Costs: None Effect: Failure to promptly remediate errors identified during internal review increases the risk that program participants may receive benefits or incur costs that do not comply with program requirements, potentially resulting in noncompliance and questioned costs. Cause: The County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: The WIC Sr. Quality and Training Specialist conducts quarterly monitoring by observing staff and completed random chart reviews. However, due to retrospective nature of audits significant time elapses between the occurrence of the error and its identification. Late corrections in the crossroads system will compromise data integrity and disrupt some of the certification processes in crossroads. Crossroads also lacks the ability to alert supervisors of missing documentation which in turn creates a huge administrative burden to monitor missing documentation in real time. WIC program leadership will create a policy that will address documentation standards. WIC staff will be instructed not to alter the original entry, instead a correction addendum will be documented to acknowledge missing data. WIC program will continue to provide policy refreshers every quarter to address these findings and provide staff updated information. WIC supervisors will review the quarterly audits results with their staff and ensure staff follow the standards set by the department leadership. The following the phases of the corrective action plan will be completed by March 31st, 2026. Phase 1: Review of Federal and State Guidelines Phase 2: Creation of Document Standard Policy Phase 3: Implementation of new documentation standards policy. Anticipated Completion Date: March 31st, 2026 Responsible Person(s): Ali Raza, WIC Director

View Audit 385263

Finding 1172121 (2025-003)

Material Weakness 2025

Mecklenburg County

NC

Allowable Costs / Cost Principles Subrecipient Monitoring Significant Deficiency

Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Allowable Costs/Costs Principles Repeat Finding 2025-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must esta...

Program Name: Special Supplemental Nutrition Program for Women, Infants, and Children Federal Assistance Listing Number 10.557 Significant Deficiency – Allowable Costs/Costs Principles Repeat Finding 2025-003 Criteria: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: There were 3 out of 40 samples tested where clear and consistent documentation of a control over allowable costs and activities was not present. Effect: Without consistent documentation and adherence to departmental policy for approving allowable costs, there is an increased risk that unallowable expenditures may be charged to the program, potentially resulting in noncompliance with federal requirements and questioned costs. Questioned Costs: None. Cause: The departmental policy to approve expenditure documents as an allowable cost for the program was not followed. Recommendation: The County should consistently follow departmental policy by ensuring all expenditure documents for the program are properly reviewed and approved as allowable costs before being approved for payment and maintain clear documentation of controls over program activities to support compliance with federal requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Correction Action Plan: Program leadership will collaborate with the County Finance Team to ensure departmental policy is followed when purchases are made using WIC Federal funds. Internal purchase approval documents will be created to enhance the approval workflow. All purchases will be submitted to the WIC Program Director for approval. The program Director and the Sr. Admin Assistant will review the orders and ensure they are allowable items per the NC State WIC program guidelines. A shared folder will be created to save the purchase order forms, and the invoices to ensure Mecklenburg County Health Department Policy A-13, Retention of Administrative Documents is followed. The following the phases of the corrective action plan will be completed by March 1st, 2026. Phase 1: Review of Federal and State Guidelines Phase 2: Mecklenburg County Procurement Policy Review Phase 3: Creation and Implementation of new internal purchase approval processes. Phase 4: Staff Training Anticipated Completion Date: March 1st, 2026 Responsible Person(s): Ali Raza, WIC Director

View Audit 385263

Finding 1172120 (2025-002)

Material Weakness 2025

Mecklenburg County

NC

Eligibility Internal Control / Segregation of Duties Questioned Costs

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health an...

U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Medical Assistance Federal Assistance Listing Number: 93.778 U.S. Department of Health and Human Services Pass-through Entity: North Carolina Department of Health and Human Services Program Name: Children's Health Insurance Program Federal Assistance Listing Number: 93.767 Material Weakness and Nonmaterial Noncompliance - Eligibility Finding 2025-002 - Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The County should have adequate documentation for each participant that supports each eligibility determination, and the information entered into NCFAST. We noted several errors related to the following compliance criteria: a) Self-attestation wages should be compared to information in NC FAST. b) All countable resources should be confirmed and recalculated and ensure they are computed accurately in NC FAST. c) The caseworker should prepare and submit a DMA-5097 form in the case of incompatible income verification and self-attestation income as described in the Eligibility Review Document. d) Citizenship should be documented within NCFAST. e) Household information should be entered correctly into NCFAST. Condition: The following are the results of nonmaterial noncompliance noted for each criteria listed above out of the 124 program participants selected for testing: a) There were six instances where the participants self-attest wages did not agree to the wages entered into NC FAST. b) There was one instance where the countable resources were inaccurate within NC FAST. c) There were five instances where the income was incompatible between the income verification and self-attestation income but no DMA-5097 was sent. d) There was one instance where the participant's citizenship was not documented in NCFAST. e) There was one instance where the participant's household size was entered incorrectly into NCFAST. Lastly, there were 6 instances out of 60 program participants tested for control testing where the County did not remediate the errors identified within their internal review timely. Context: There were 8 out of 124 unique participants tested with the errors noted above. Questioned Costs: We noted no federal questioned costs for the County as the State of North Carolina makes all benefit payments to participants directly. Due to split eligibility determinations between the Counties and the State of North Carolina for Medicaid, we found $25,105 in benefit payments made by the State of North Carolina to ineligible participants based on an improper eligibility determinations at the County related to three individuals in item "a" above. Effect: By not having the required documentation in the files or information being incorrectly documented, eligibility cannot be readily substantiated and there is a risk the County could provide funding to individuals who are not eligible. Cause: County oversight when performing reviews over applications. Additionally, the County does not have a formal process in place to ensure issues identified during the review process are appropriately corrected on a consistent and timely basis. Recommendation: Although these issues will occur from time to time considering the volume of case files, the County should review their processes to ensure proper supporting documentation of eligibility is maintained within each case file. Additionally, Mecklenburg County should consider implementing a formal policy for the requirements of having documentation corrected within a specific timeframe once identified and monitored throughout the year for adherence to the policy. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: Performance Improvement Strategy: The County has identified specific opportunities to strengthen accuracy and consistency in eligibility case documentation. While overall performance has improved, with total errors reduced from 14 the prior audit period to 8 in the current period, continued focus is necessary to further reduce errors and sustain compliance across case files. The Economic Services Division Strategies are as follows: • Social Services Supervisors will conduct targeted reviews of identified error trends, emphasizing policy application, documentation completeness, and process standardization to ensure consistent eligibility determinations across the program. • The Economic Services Division's Staff Development Unit will continue to quality sample cases to promote accuracy and accountability. • Social Service Supervisors, in coordination with Medicaid Social Services Managers will coach staff based on audit findings, monitor trends and ensure required corrections are completed within 5 business days of notification. • Failure to complete corrections within the approved timeframe will result in corrective action to both the Social Services Supervisor and the assigned Eligibility Specialist in accordance with departmental performance management protocols. • Supervisory staff will ensure all updates to the Quality Sampling Tracking Log are finalized no later than the 20th calendar day of the subsequent month to support timely monitoring, trend analysis, and corrective action. These actions are designed to strengthen internal controls, support staff performance and maintain compliance with applicable state and federal requirements. Responsible lndividual(s): Kim Konior, Lynn Martin (Medicaid Program Managers), Staphon Snelling (Training and Development Manager), Danisa Concepion, Donnie Munson (Quality and Training Supervisors), and Social Services Medicaid Supervisors. Anticipated Completion Date: Ongoing Training: The Economic Services Division's Staff Development Unit will review the Single Audit findings and develop targeted training for staff responsible for determining Medicaid eligibility, as well as their supervisors and managers. This training will specifically address the errors identified in the audit and will be delivered by the end of March 2026. In addition, Staff Development will provide quarterly training to Medicaid eligibility staff, supervisors, and managers based on error trends identified through quality sampling conducted by the unit. To ensure effectiveness, a structured training approach will be used: • A pre-test will assess staffs current understanding of relevant policies. • The County will deliver targeted training materials tailored to address identified gaps. • A post-test will be developed, with a minimum passing score of 90%. This approach will allow the County to: • Measure knowledge gained through the training • Track training completion, identify staff who have or have not completed the training • Ensure consistent understanding and application of policy across the team Staff who do not achieve the required score will receive additional refresher training to reinforce key concepts and ensure compliance. Responsible lndividual(s): Staphon Snelling (Training and Development Manager), Danisa Concepion, and Donnie Munson (Quality and Training Supervisors), and Sr. Quality and Training Specialists (Medicaid). Anticipated Completion Date: March 31, 2026

View Audit 385263

Finding 1172102 (2025-003)

Material Weakness 2025

Conemaugh Township Area School District

PA

Cash Management Subrecipient Monitoring Matching / Level of Effort / Earmarking

2025-003 Distance Learning and Telemedicine – ALN No. 10.855 Compliance: Name of contact person – Brandon Studer, Business Manager Recommendation: We recommend management contact the Grantor to determine necessary actions in response to the excessive interest earned on federal funds, including the p...

2025-003 Distance Learning and Telemedicine – ALN No. 10.855 Compliance: Name of contact person – Brandon Studer, Business Manager Recommendation: We recommend management contact the Grantor to determine necessary actions in response to the excessive interest earned on federal funds, including the potential return of earnings to the grant agency. Action Taken: Management agrees with the recommendation and will contact the Rural Utilities Service to determine whether excess interest earned on the funds is due back to the agency. Proposed Completion Date: March 31, 2026

View Audit 385240

Finding 1172093 (2025-001)

Material Weakness 2025

Mt. Hood Community College

OR

Special Tests & Provisions Questioned Costs Student Financial Aid

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 3 students did not receive a timely notification of their award from ...

Finding 2025-001 Federal Agency Name: U.S. Department of Education Program Name: Student Financial Assistance Cluster Federal Financial Assistance Listing: 84.007, 84.033, 84.063, 84.268 Finding Summary: In testing of 60 students, 3 students did not receive a timely notification of their award from the District. Corrective Action Plan: To address missed disbursement notifications, the Financial Aid team identified affected students and sent the required notices, including an official explanation from the Director of Financial Aid. The issue was traced to a system malfunction during the SU24 term, which has since been resolved by implementing a process that alerts IT and the Director if notification counts do not match disbursement records. The notification script has been enhanced to track missing letters over the previous 30 days, and IT has established a weekly audit comparing sent notifications to disbursement records for accuracy. Additionally, coding updates in the CX system now ensure all disbursements are properly captured, regardless of the date entered by Financial Aid, thereby preventing similar oversights in the future. Responsible Individual(s): Christopher Natelborg Anticipated Completion Date: December 2025

View Audit 385231

Finding 1172045 (2025-002)

Material Weakness 2025

Tell City-Troy Township School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

FINDING 2025-002 Finding Subject: COVID-19- Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: State Board of Accounts has asserted that the school corporation did not ensure that the contractor for the elementary building’s roofing project, whic...

FINDING 2025-002 Finding Subject: COVID-19- Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: State Board of Accounts has asserted that the school corporation did not ensure that the contractor for the elementary building’s roofing project, which was partially funded through a federal ESSER grant, had paid prevailing wage rates on this project. Contact Person Responsible for Corrective Action: Debra Elder, Treasurer and John Scioldo, Superintendent Contact Phone Number and Email Address: 812-547-3300; debbie.elder@tellcity.k12.in.us and john.scioldo@tellcity.k12.in.us Views of Responsible Officials: We concur with the finding.. Description of Corrective Action Plan: While we will agree that the school corporation did not physically have on file and/or review the detailed certified payroll timesheets from Eskola, the awarded contractor for the project, the school corporation had hired in good faith Universal Design Associates (UDA) to manage all facets of the project. UDA has managed other capital improvements on the school’s campus, and their services have been exemplary. A school corporation of our size simply does not have the manpower, resources or expertise to oversee a project of this size, and therefore we rely on the hired project manager/architectural design company to ensure all federal Davis-Bacon wage scale requirements and the construction project as a whole are being fully followed, in addition to their close oversight of the day-to-day project management. The Application to Pay statements for payment to Eskola were provided by, and assumably thoroughly reviewed by, UDA. These pay applications obviously included payment for payroll, again assumably of which UDA checked certified payroll for federal wage compliance. The project was completed in the spring of 2025, and therefore this is no longer an issue. We have determined as a result of this finding that the current school administration will not consider funding future capital projects with federal grants due to the complexities of the involved federal compliance requirements. Anticipated Completion Date: N/A – Based on Corrective Action Plan

View Audit 385149

Finding 1171975 (2025-002)

Material Weakness 2025

Spokane Guild School & Neuromuscular Center

WA

Matching / Level of Effort / Earmarking Reporting

HRSA Grant Self-Reporting Memo Deficiencies, Investigation, Reporting and Corrective Actions January 15, 2026 RE: Grant Number (FAIN): CE152520, under Assistance Listing Number: 93.493, Award Number: CE1HS52520-01-06 (the “Grant”) Federal Award Date: 9/21/2023 Grant Title: Community Project Funding/...

HRSA Grant Self-Reporting Memo Deficiencies, Investigation, Reporting and Corrective Actions January 15, 2026 RE: Grant Number (FAIN): CE152520, under Assistance Listing Number: 93.493, Award Number: CE1HS52520-01-06 (the “Grant”) Federal Award Date: 9/21/2023 Grant Title: Community Project Funding/Congressionally Directed Spending - Construction Grantee: Spokane Guilds’ School (Unique Entity ID: DZJ5TZ4LGWH3, EIN: 91-0863163) (d/b/a Joya Child & Family Development “Joya”) 1016 N Superior St. Spokane, WA 99202 Grantee Contact: Colleen Fuchs, Executive Director Grant Purposes: Alteration and Renovation to Existing Facility, and related Equipment and other costs, to create Joya’s Neurodevelopmental Research & Training Institute Grant Amount (Per Notice of Award, Section 31. Approved Budget): e. Equipment $ 690,195.00 h. Construction/Alteration and Renovation $ 2,377,431.00 i. Other $ 117,114.00 Total Direct Costs $ 3,184,740.00 Less: Cost Sharing or Matching $ 184,740.00 Total Amount of Federal Share $ 3,000,000.00 Background: Joya’s facility was constructed from March 2021 to June 2022, and funded via private charitable contributions received from donors and a loan from Joya’s bank. The facility was placed in service in June, 2022 for a total approximate cost of $13.0 million. The facility is utilized by Joya, a 501(c)(3) non-profit organization, to house programs that provide physical, occupational, speech and other therapies to children with neurological and developmental delays, primarily from birth to three years of age. In Fall of 2022, Joya applied for a $3.0 million grant from HRSA to improve its facility to include a Neurodevelopmental Research & Training Institute and expand its services. The Grant was awarded to Joya, and Joya awarded a construction contract to the General Contractor who had completed its facility in 2022. The facility improvements were substantially completed in 2025. As of the date of this memo, approximately $123,000 remains available to Joya under the Grant. Procedural Deficiencies: 1. Competitive Bid (Eide Bailly Finding # 2025-001): In April 2025, during a selfreview of Joya’s compliance with 45 CFR Sections 75.326 to 75.335, specifically the required procurement procedures, management discovered that Joya’s procurement procedures were deficient in the following specific area. Joya’s policies and procedures did not require public notice to be issued regarding a competitive bidding process for the facility improvements, specifically the construction contract award, as required in the CFR. The contract was awarded to the same contractor who had recently constructed the original facility, as the contractor possessed critical knowledge of the facility along with the requisite skills to perform the improvements. However, market cost information (obtained through a public bid process) was not available. Further, a sample of nine transactions (out of 43 total transactions) indicated that contracts for three vendors between $10,000 and $250,000 required Joya to follow simplified acquisition procedures and obtain rate quotations in advance of procurement. 2. Proportion of Federal to Non-Federal Share (Eide Bailly Finding # 2025-002): Later in 2025, Joya engaged its independent CPA firm, Eide Bailly to audit its financial statements, and as part of that, to issue an opinion on its internal controls over financial reporting and on compliance with certain provisions of laws, regulations, contracts and grant agreements. During its review, the CPA firm discovered that Joya’s procedures regarding matching/cost sharing were deficient. Joya’s policies and procedures did not have su􀆯icient internal controls to ensure that grant funds were drawn down following the required proportion of (i) the Federal Share of Grant funds in proportion to (ii) the Cost Sharing/Matching Grant funds. Following a review of Joya’s financial records, it was determined that Joya’s contribution of its Non-Federal Share of improvement costs was approximately $12,000 lower than the amount required by the defined contract proportion, through June 30, 2025. Self-Investigation and Reporting: Joya’s investigation and specifically its review of the Grant requirements and the CFR language in April 2025, along with its seeking an independent review of its internal controls resulted in identifying both procedural deficiencies described above. Corrective Actions: The following corrective actions to address the Procedural Deficiencies have all been completed, as further described below. 1. Joya’s Director of Business and Accounting (B. Judge) timely notified its independent CPA firm, Eide Bailly, which described the internal control deficiencies in its qualified opinion to its Independent Auditor’s Report on Internal Control and Compliance for the year ended June 30, 2025. The CPA firm did not qualify its separate opinion to Joya’s Audited Financial Statements for the year ended June 30, 2025. 2. In April 2025, Joya’s Director of Business and Accounting (B. Judge) sought technical guidance and approval from Joya’s board of directors and its independent CPA firm. By June 2025, Mr. Judge had updated Joya’s policies and procedures to include the required internal controls described above. 3. Joya’s Director of Business and Accounting (B. Judge) engaged MACC Estimating Group, an independent construction estimation firm in Liberty Lake, WA, to obtain an itemized cost estimate for the facility improvements funded by the grant. The independent results issued on June 24, 2025 were only 6% higher than the awarded contractor bid. Joya’s management believes this provides a reasonable market cost for its awarded project. 4. On April 18, 2025, Joya’s Director of Business and Accounting (B. Judge) emailed HRSA sta􀆯 members A. Glasser and C. Barnes, o􀆯icially notifying HRSA of its procurement policy deficiencies. HRSA (A. Glasser, Grants Management Specialist) responded via email on April 18, 2025, asking about the procurement process Joya ultimately used, and informing Joya as follows: “At this time, all HRSA conditions for award CE1HS52520 have been met, and you are free to draw down funds from document number 23CE1HS52520 in the Payment Management System. However, please ensure that the terms outlined on the Notice of Award dated 9/21/23 are followed. If you have specific questions regarding these terms, I am happy to discuss further.” Joya has received no further correspondence from HRSA on the matter. 5. Joya’s Director of Business and Accounting (B. Judge) continued to monitor its procurement process and proportional cost sharing to remain in compliance with 45 CFR Sections 75.326 to 75.335. Specifically, Joya’s Accounting Policies were updated in 2025 to include the following internal controls, as reviewed and amended from time to time: “If a purchase is funded in whole or in part by a Federal Grant, any related procurement or payment must comply with Federal Grant Procurement policies and applicable Federal Regulations under 2 CFR §§ 200.317– 200.327, including, but not limited to: • Following allowable procurement methods (micro-purchase, small purchase, sealed bids, competitive proposals, or noncompetitive proposals) • Obtaining multiple quotes when required and providing public notice requesting sealed competitive bids for expenditures over $250,000 • Avoiding conflicts of interest • Ensuring that contractors have not been suspended or debarred • Documenting the basis for selection and price reasonableness • Ensuring that Joya monitors expenditures to ensure that it maintains the appropriate proportion of Federal Share of Grant funds in proportion to the Cost Sharing/Matching Grant funds”. 6. In February 2025, Joya received a private grant in the amount of $178,000 from a private donor, which served as 96% of the required shared/matching funds Joya required for the entire Grant. These and other Joya funds are su􀆯icient to meet 100% of the required shared/matching funds.

View Audit 385069

Finding 1171967 (2025-001)

Material Weakness 2025

Children's Hospital of Philadelphia

PA

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.430

2025-001 – Direct Costs-Compensation Grantor: Centers for Disease Control and Prevention - Aids Activity and Coordinating Office (AACO), National Institute of Health Award Name: High Impact HIV Prevention and Surveillance Programs, Research and Development Assistance Listing Number: 93.940, 93.838 A...

2025-001 – Direct Costs-Compensation Grantor: Centers for Disease Control and Prevention - Aids Activity and Coordinating Office (AACO), National Institute of Health Award Name: High Impact HIV Prevention and Surveillance Programs, Research and Development Assistance Listing Number: 93.940, 93.838 Assistance Listing Title: HIV Prevention Activities Health Department Based, Lung Diseases Award Year: July 1, 2024 to June 30, 2025 Award Numbers: CP4043 and CP5043 (2220536), 1OT2HL161847-01 Management’s Views and Corrective Action Plan Management acknowledges the finding related to delayed effort report certification. We recognize the importance of timely and accurate effort reporting as well as ensuring compliance with federal and institutional requirements. Children’s Hospital of Philadelphia Research Institute has implemented a new Effort Compensation Compliance system for effective July 1, 2025. This new system will enhance monitoring of timely effort certifications through automated reminders and greater transparency. With this implementation, training and reference materials will be provided to all personnel involved in effort reporting to ensure they understand the importance of timely certification and the potential impact of delays on grant compliance.

View Audit 385042

Finding 1171934 (2025-003)

Material Weakness 2025

City of Wells, Nv

NV

Reporting Cash Management Significant Deficiency § 200.303

Finding Summary: 2 CFR Part 200 (Uniform Guidance) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award. Eide Bailly noted two out of five reimbursement requests had no evidence of approval. Responsible Individuals: Samantha Nance, City C...

Finding Summary: 2 CFR Part 200 (Uniform Guidance) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award. Eide Bailly noted two out of five reimbursement requests had no evidence of approval. Responsible Individuals: Samantha Nance, City Clerk Corrective Action Plan: Create a checklist for all reimbursement request procedures to include prepared by and approved by signatures with every request. Anticipated Completion Date: Immediately

View Audit 384971

Finding 1171859 (2025-001)

Material Weakness 2025

Local Area of Labor Development Southwest

PR

Matching / Level of Effort / Earmarking

Reportable Condition: See Condition 2025-001 Recommendation We recommend the Local Area monitoring the earmarking procedures for the Youth Program on a quarterly basis to ensure that at the end of the to two years meet the requirement establish. If deviations or failure to meet the earmark are noted...

Reportable Condition: See Condition 2025-001 Recommendation We recommend the Local Area monitoring the earmarking procedures for the Youth Program on a quarterly basis to ensure that at the end of the to two years meet the requirement establish. If deviations or failure to meet the earmark are noted, communications must be generated to youth program staff to take corrective actions before the elapse of the funding period. Action Taken The Executive Director has begun meetings with staff to establish a short-term plan to discuss strategies to increase the number of youth participants in the Program. In addition, at these meetings, the Executive Director has instructed the Program Executive and Program Manager to maintain control over the budget allocated and the activities to be carried out and to coordinate the planning of future activities. With regard to the Finance Area, the Financial Director is instructed that at least every two months or at the request of the Assistance Manager submit the “Encumbrance Budget Report” to see the changes in budget and be able to make decisions related to changes in the approved budget by the Labor Department Program. In the meetings to be held, the results obtained and the status of the activities carried out in order to be accountable for the actions carried out must be reported. This to maintain continuous monitoring of the program, before the end of the validity of the funds. We expect to comply with the requirements this next year.

View Audit 384821

Finding 1171691 (2025-005)

Material Weakness 2025

Cumberland Community Unit School District 77

IL

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking

The District will design and implement internal control procedures over the District's accounting processes to remedy this issue.

View Audit 384704

Finding 1171684 (2025-003)

Material Weakness 2025

South Gibson School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Amy Silva Contact Phone Number and Email Address: 812-753-4230 amy.silva@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corr...

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Amy Silva Contact Phone Number and Email Address: 812-753-4230 amy.silva@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation has designated the Director of Special Education as the primary monitor responsible for overseeing nonpublic proportionate share expenditures. The Corporation Treasurer will provide the Director of Special Education and the Assistant Superintendent with a monthly budget-to-actual expenditure report for all active grants with nonpublic proportionate share requirements. This report will track the remaining unspent balance. The Director of Special Education will meet monthly with nonpublic school administrators to review the remaining fund balances, ensure services are being rendered, and project future expenditures. A final reconciliation will be performed within 30 days of each grant's end date to confirm all required funds were spent or a waiver was successfully obtained. Anticipated Completion Date: March 1, 2026

View Audit 384700

Finding 1171679 (2025-014)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed ...

Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed subgrant agreements to confirm that the correct Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) appear in the agreement. • This review will exclude Interagency Agreements with City agencies since they are not considered subrecipients, but as the prime recipient, the City of Baltimore. • This review will also exclude any agreements related to projects classified under Expenditure Category (EC) 6.1 in ARPA SLFRF guidance. According to Frequently Asked Questions (FAQs) issued by the U.S. Department of Treasury, this EC does not give rise to a subrecipient relationship, therefore UEI information is not required. • For any subgrant agreements with an incorrect or missing UEI or FAIN, the Recovery Office will submit a single memorandum that presents correct UEIs and FAIN to the Board of Estimates (BOE) to ensure that the official record has correct UEI and FAIN information. We believe there is a direct conflict between Treasury guidance and 2 CFR 200 regarding the requirement for active SAM.gov registration. Treasury does not require subrecipients to maintain an active SAM.gov registration and instead permits the use of alternative screening questions in lieu of an active registration. Treasury does not collect individualized subrecipient data for subawards at or below $50,000. Each of these three awards are at or below that threshold, therefore the SAM.gov information, including the subrecipient UEI, registration, or the alternative screening questions, were not collected. The total amount of funding for the three identified subrecipients combined is $100,000. The Recovery Office will require that all subrecipients fully register in SAM.gov. The Recovery Office will require that agencies provide a 30-day window to allow all subrecipients to fully register or funds will be withheld until the subrecipient can fully register to demonstrate the organization is not suspended or debarred. In those cases where the Recovery Office is unable to withhold disbursements for noncompliant subrecipients, the Recovery Office will issue a Corrective Action Plan or issue a finding in the subrecipient's closeout letter. For any grants that expired, if payments occurred outside the period of performance, and did not have written justification for and approval of an extension to the allowable closeout period, the Recovery Office will require that the agency to take the agreement back to the Board of Estimates for a retroactive extension. In certain cases, such as when extended monitoring or implementation of corrective action items go beyond the period of performance, a payment may be made outside of the allowable closeout period. According to 2 CFR 200.344c, "The recipient must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must liquidate all financial obligations incurred under a subaward no later than 90 calendar days after the conclusion of the period of performance of the subaward (or an earlier date as agreed upon by the pass-through entity and subrecipient). When justified, the Federal agency or pass-through entity may approve extensions for the recipient or subrecipient." In these cases, the Recovery Office will assure there is written justification for the extension on liquidating all financial obligations. Contact Person: Elizabeth Tatum, Director Completion Date: June 30, 2026

View Audit 384683

Finding 1171578 (2025-019)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Questioned Costs Reporting § 200.303

Finding 2025-019 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: To address reporting finding...

Finding 2025-019 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

View Audit 384683

Finding 1171561 (2025-018)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025...

Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

View Audit 384683

Finding 1171560 (2025-017)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Questioned Costs Reporting § 200.303

Finding 2025-017 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-027 Auditee’s Corrective Action Plan: To address reporting fin...

Finding 2025-017 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-027 Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

View Audit 384683

Finding 1171506 (2025-013)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengt...

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengthen internal controls, MOED will establish separate grant worktags for all parts of the grant award to ensure the grant reference number is unique within the Workday award setup. UEI Subaward Validation: As a corrective action, Contracts Specialist training has been updated to require verification and documentation of the sub-recipient’s Unique Entity Identifier (UEI) through SAM.Gov as part of the subaward setup process. MOED will require grant staff to familiarize themselves with Administrative Manual policy 413- 21 Federal Grant Registration and Unique Entity Identifier, which requires UEI verification and identification in the City’s financial system of record for all subrecipients. Subrecipient Monitoring: MOED does maintain a standardized sub-recipient monitoring checklist designed to ensure subawards are administered in compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward as well as relevant supporting documentation. FY2025 subrecipient monitoring was not scheduled in accordance with the monitoring timeframes outlined in the terms and conditions of the grant award. Management acknowledges this oversight and will ensure that all subrecipient monitoring is scheduled and conducted timely in accordance with the monitoring timeframes outlined in the award. Review of Subrecipient Single Audit Report: MOED performs a review of subrecipient Single Audit reports during the technical proposal evaluation and confirms the subrecipient’s inclusion on the State of Maryland’s Eligible Training Provider List (ETPL). Due to document volume size, this documentation has not historically been included in BOE-approved subrecipient agreements or retained within Workday award files. As a corrective action, MOED will formally incorporate ETPL verification into subrecipient agreements. Single Audit reports will be retained separately from the BOE approval package and uploaded to the applicable Grant Award record in Workday to ensure consistent documentation and accessibility. MOED will utilize the GMO’s subrecipient monitoring templates provided on the centralized SharePoint Grants Management platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reports are completed. Additionally, MOED will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOED will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. MOED will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: September 30, 2026

View Audit 384683

Finding 1171505 (2025-012)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Questioned Costs Reporting § 200.303

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting ...

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting controls to ensure all required fiscal reports are submitted timely and in accordance with the grantor’s established timetable. This corrective action includes formal distribution of the grantor’s fiscal reporting schedule to responsible staff, implementation of internal calendar tracking for all fiscal reporting deadlines, and enhanced monitoring procedures to ensure deadlines are met and escalated when necessary. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: June 30, 2026

View Audit 384683

Finding 1171473 (2025-010)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.330 § 200.331 § 200.332 § 200.501

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and ...

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026

View Audit 384683

Finding 1171472 (2025-009)

Material Weakness 2025

City of Baltimore, Maryland

MD

Reporting Matching / Level of Effort / Earmarking Questioned Costs § 200.303

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal contro...

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal controls over federal reporting to ensure accuracy, completeness, and compliance with HUD and Uniform Guidance requirements. Specifically, MOHS will implement a documented reconciliation process requiring all HOPWA expenditures reported in the Federal Financial Report (FFR) to be reconciled to the general ledger prior to regular submission, with supervisory review and approval documented. MOHS will establish a formal reporting calendar and standardized checklist to ensure timely preparation, review, and submission of all required HUD reports, including the FFR, Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting (FSRS), and the Consolidated Annual Performance and Evaluation Report (CAPER). • Written procedures will be developed to clearly define staff roles and responsibilities for federal reporting and FFATA compliance, including identification of reportable first-tier subawards and documentation of FSRS submissions. MOHS will also provide targeted training to program and fiscal staff responsible for federal reporting and will conduct periodic internal monitoring to verify compliance with 2 CFR §200.303 and 2 CFR Part 170. MOHS will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. • Per the GMO’s guidance, MOHS will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: June 30, 2026

View Audit 384683

Finding 1171413 (2025-008)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Questioned Costs HUD Housing Programs § 200.303

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, t...

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, the Consolidated Planning Division has been conducting a widespread effort to ensure programmatic compliance with all City and Federal requirements. To date, it has prioritized: • Reducing the grant’s at-risk financial exposure from approximately $28M in FY23 to $1.03M in FY25. • Implemented moving all NPO operating contracts to the same Period of Performance (July 1 – June 30 of the grant year) to ensure timely expenditure of funds and reduce compliance burden on staff. • Implemented the use of a form agreement approval process for the Board of Estimates (BOE) which reduced the lag time for contract execution and subsequent reimbursement from over 12 months, to approximately 2 months once the executed grant agreement has been received from HUD and approved by the BOE. • Standardized required subrecipient activity reporting and requests for reimbursement in Neighborly (the City’s reporting system of record for the CDBG grant program) to a quarterly basis. • Required all supporting documentation be submitted and reviewed quarterly to eliminate the possibility of overpayment or reimbursement for ineligible activities. • Hired a Director of CDBG finance to improve fiduciary and compliance oversight of federal funds. • Ensured the HUD-required Cash-on-Hand report is entered into a new screen in HUD’s system of record - Integrated Disbursement and Information System (IDIS) - (reporting that was previously collected through Federal Financial Report (FFR)/Standard Form 425 (SF-425) on a timely basis. Corrective Action Plan: • A new Director of CDBG Finance will be hired before the end of FY26. • The new Director of CDBG Finance will be provided training to complete the Cash on Hand Report and will cross-train additional staff on the completion of this report to ensure redundancy. • Supporting documents will be kept on the divisional shared drive in a clearly named subfolder. Contact Person: Mary Correia, Deputy Commissioner David Fielder, Assistant Commissioner Completion Date: June 30, 2026

View Audit 384683

Finding 1171367 (2025-002)

Material Weakness 2025

Sheltercare

OR

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustmen...

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustment, and has prepared a written procedure to follow for preparation of the SEFA. --Person Responsible: Phoebe Benjamin, Associate Finance Director --Date Implemented: 1/1/2026

View Audit 384658

Finding 1171320 (2025-005)

Material Weakness 2025

Eastern Greene Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.208 § 200.303

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4...

FINDING 2025-005 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Contact Person Responsible for Corrective Action: Superintendent and Title I Program Director Mr. Todd Tanksley Contact Phone Number and Email Address: 812-849-4481 – tanksleyto@mitchell.k12.in.us Views of Responsible O􀆯icial: We concur with the finding. Description of Corrective Action Plan The School Corporation has implemented enhanced internal control procedures to ensure compliance with Assessment System Security requirements and applicable state and federal regulations. E􀆯ective immediately, the School Corporation will: 1. Require all employees who administer, handle, or have access to secure test materials to complete annual assessment security training in accordance with the Indiana Assessment Policy Manual. 2. Require all such employees to sign the Indiana Testing Security and Integrity Agreement annually by an established deadline. INDIANA STATE BOARD OF ACCOUNTS 34 3. Establish a standardized process to collect, review, and retain signed testing security agreements at the building level. 4. Maintain a centralized tracking log of all employees required to complete training and sign agreements. 5. Conduct an annual verification review to ensure that all required documentation is complete prior to the testing window. 6. Retain all assessment security training documentation and signed agreements in accordance with federal record retention requirements under 2 CFR 200.334. Planned Evidence of Correction The School Corporation will maintain the following documentation as evidence of corrective action: ● Annual assessment security training agendas and attendance record ● Signed Indiana Testing Security and Integrity Agreements for all applicable sta􀆯 ● Centralized tracking logs indicating completion of training and agreement signatures ● Building-level verification checklists signed and dated by administrators ● Written internal procedures related to assessment system security compliance Anticipated Completion Date Implemented and ongoing beginning with the FY2026 assessment cycle.

View Audit 384594

Finding 1171316 (2025-003)

Material Weakness 2025

Eastern Greene Schools

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Descript...

FINDING 2025-03 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Dr. Emily Dykstra Contact Phone Number and Email Address: 812-849-4481 / dykstrae@mitchell.k12.in.us Views of Responsible Officials: “We concur with the finding.” Description of Corrective Action Plan: Mitchell Community Schools will utilize time and effort logs to track time that personnel spend working with non-public students. These logs will be turned into the Director of Special Education at the end of each school year, so that they will be available for future audits. A time and effort log template will be created by March 6, 2026 to be utilized with personnel for future IDEA grants. Anticipated Completion Date: March 6, 2026

View Audit 384594

Corrective Action Plans

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