Corrective Action Plans

Finding 1157228 (2024-002)

Material Weakness 2024

Cirbn, LLC

IL

Procurement, Suspension & Debarment Material Weakness

Suspension and Debarment Recommendation: We recommend that for all federal funded grants CIRBN perform the required suspension and debarment verification, including implementing the necessary policies and internal controls over this process. Explanation of disagreement with audit finding: There is n...

Suspension and Debarment Recommendation: We recommend that for all federal funded grants CIRBN perform the required suspension and debarment verification, including implementing the necessary policies and internal controls over this process. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: We will implement the necessary controls to ensure we perform the required suspension and debarment verification in the future. Name(s) of the contact person(s) responsible for corrective action: Mark DeKeersgieter Planned completion date for corrective action plan: September 2025

View Audit 369530

Finding 1157171 (2024-003)

Material Weakness 2024

Transition Resource Action Center

TX

Allowable Costs / Cost Principles Cash Management Material Weakness § 200.430

The exceptions resulted from delays in updating payroll/timekeeping systems and insufficient documentation to support allocation changes. To correct this, TRAC has implemented a Position Control Update process: any change to an employee’s grant allocation must be documented on a Position Control Upd...

The exceptions resulted from delays in updating payroll/timekeeping systems and insufficient documentation to support allocation changes. To correct this, TRAC has implemented a Position Control Update process: any change to an employee’s grant allocation must be documented on a Position Control Update form, signed by the Finance Director, and entered into the payroll system within 5 business days of the change. Additionally, the Finance team performs monthly reconciliations between timecards, payroll registers, and the general ledger to ensure that payroll charges are accurate and properly supported before being billed to grants. Completion Date: October 1, 2025. Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations

View Audit 369477

Finding 1157170 (2024-002)

Material Weakness 2024

Transition Resource Action Center

TX

Allowable Costs / Cost Principles HUD Housing Programs Material Weakness § 200.430

At the time of the audit period, TRAC was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. As of September 2024, TRAC implemented employee and supervi...

At the time of the audit period, TRAC was newly independent from CitySquare and had not yet integrated supervisor approval of timecards into its internal control systems. This gap contributed to missing approvals during the transition year. As of September 2024, TRAC implemented employee and supervisor approvals of timecards within the time keeping system. Additionally, the organization has and will continue to implement a thorough review process that will include the following:  Employee acknowledgement of their individual grant allocation  Employee approval of their timecard  Manager acknowledgment of their individual grant allocation as well as the allocation of each employee they supervise  Manager approval of each employee’s timecard  The finance team will review each timecard individually prior to charging salary costs to grants. This process ensures that time and effort documentation is complete, approved, and compliant with federal and state requirements. Compliance with this policy will be monitored monthly by the Finance Director to ensure continued adherence.Completion Date: October 1, 2025.Responsible Parties: Nicole Binkley, Chief Executive Officer Josh Runnels, Director of Finance and Operations

View Audit 369477

Finding 1157117 (2024-003)

Material Weakness 2024

International Association of Forensic Nurses, Inc.

MD

Material Weakness Reporting

Action Taken: The Association has eliminated the third-party accounting firm, which has eliminated challenges related to communication and follow-up. The Association has restructured its staff finance team to ensure appropriate segregation of duties and greater efficiency and accuracy in managing fi...

Action Taken: The Association has eliminated the third-party accounting firm, which has eliminated challenges related to communication and follow-up. The Association has restructured its staff finance team to ensure appropriate segregation of duties and greater efficiency and accuracy in managing financial processes. Further, the Association has implemented standardized monthly reconciliation procedures for all accounts. These procedures create opportunities for the timely identification and resolution of discrepancies. There is a documented monthly close, review and approval process that involves an initial review by the finance team, including the Senior Finance Director. In addition, team leads, who are responsible for overseeing departmental budgets, also conduct a monthly review and note discrepancies that require correction. Finally, the COO and CEO conduct a review of monthly departmental reports and monthly financial statements prior to them being presented to the Association Board’s Finance Committee for further review.

View Audit 369419

Finding 1157106 (2024-001)

Material Weakness 2024

International Association of Forensic Nurses, Inc.

MD

Questioned Costs Internal Control / Segregation of Duties Material Weakness

Action Taken: Upon the discovery of fraud in 2024, Management took immediate action to address the issue and prevent future occurrences. Actions taken in 2024 include: • Improved the segregation of duties between the approval and recording of all expense transactions. • Automated the uploads of cred...

Action Taken: Upon the discovery of fraud in 2024, Management took immediate action to address the issue and prevent future occurrences. Actions taken in 2024 include: • Improved the segregation of duties between the approval and recording of all expense transactions. • Automated the uploads of credit card transactions directly into the accounting system to prevent any manual manipulation and reconciled the transactions to the statements. • Updated the Association policies around vendor management and allowable/non allowable operating expenses. • The employee was terminated prior to discovering the fraud.

View Audit 369419 Questioned Costs: $1

Finding 1156998 (2024-003)

Material Weakness 2024

Town of Clinton

MA

Subrecipient Monitoring Material Weakness Reporting § 200.328

Finding 2024-003 – As of the March 31, 2024 reporting date, the Town reported projects approved by the Select Board as obligated rather than purchases, contracts and agreements that met the Federal criteria of an obligation. The Projects and Expenditure report for the period ending March 31, 2024 wa...

Finding 2024-003 – As of the March 31, 2024 reporting date, the Town reported projects approved by the Select Board as obligated rather than purchases, contracts and agreements that met the Federal criteria of an obligation. The Projects and Expenditure report for the period ending March 31, 2024 was not filed until March 25, 2025. Corrective Action Planned: The Projects and Expenditure report for period ending March 31, 2024 was filed after the deadline due to a technological issue preventing access to the portal that was documented with both the U.S. Treasury and Login.gov Helpdesk. A new managed service provider working for the Town of Clinton was successful in correcting the issue for a timely filing of the 2025 report and all State and Local Fiscal Recovery Fund (SLFRF) projects were obligated by the 12/31/24 deadline. Completion Date: April 30, 2025 Contact: Michael J. Ward, Town Administrator

View Audit 369308

Finding 1156923 (2024-006)

Material Weakness 2024

Northeast Iowa Workforce Development Board

IA

Material Weakness Reporting

Management will ensure all requested information is available for the auditor in order to facilitate timely completion of the audit by March 31.

View Audit 369256

Finding 1156907 (2024-003)

Material Weakness 2024

Central Minnesota Council on Aging

MN

Matching / Level of Effort / Earmarking Material Weakness Reporting

Older Americans Act Title III – Assistance Listing No. 93.044, 93.045, 93.053 Recommendation: The Organization should review and approve reports before submitting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Ma...

Older Americans Act Title III – Assistance Listing No. 93.044, 93.045, 93.053 Recommendation: The Organization should review and approve reports before submitting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review the financial reports that are prepared by staff before submitting the report and will document that review/approval. Name(s) of the contact person(s) responsible for corrective action: Lori Vrolson, Executive Director Planned completion date for corrective action plan: 12/31/25

View Audit 369244

Finding 1156872 (2024-004)

Material Weakness 2024

State of Missouri

MO

Cash Management Material Weakness Reporting

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Department of Social Services – MO HealthNet Division Audit Finding Number: 2024-004 - Medicaid and CHIP Receipt Controls Name of the contact person responsible for corrective action: Andrea Smith Anticipate...

State of Missouri Single Audit Corrective Action Plan Year Ended June 30, 2024 State Agency: Department of Social Services – MO HealthNet Division Audit Finding Number: 2024-004 - Medicaid and CHIP Receipt Controls Name of the contact person responsible for corrective action: Andrea Smith Anticipated completion date for corrective action: June 30, 2025 Recommendation: The DSS through the MHD continue to review, strengthen, and enforce internal controls over Medicaid and CHIP receipts. The MHD should restrict user access within the MMIS for FORU accounting personnel and adequately segregate asset custody and receipt recording duties from accounts receivable duties, or perform documented supervisory reviews of MMIS entries and changes made by employees whose duties are not segregated. In addition, the MHD should establish procedures to account for all cash control numbers to ensure all receipts are deposited or returned to senders. DSS Response: DSS agrees with the auditor’s recommendation. The Corrective Action Plan includes the department’s planned actions to address the finding. Corrective action planned is as follows: MHD has implemented a process to document supervisory reviews of the Finance Manual Checks Quarterly report to ensure segregation of duties in HealthTrack/AHS. This process began in August 2024. As a result of clarification on the finding during the FY24 audit, additional information has been added to the Finance Manual Check Quarterly report to include transactions the FORU Manager performed in the AHS system. This change was requested beginning in March 2025 and will be in use as soon as the report is available for review. MHD will continue to perform the audit of clerk ID ad hoc reports to review any segregation of duties within the MMIS. MHD implemented a process to ensure all cash control numbers in HealthTrack/AHS are accounted for by establishing a new cash control number (CCN) sequence, exclusive to manual checks logged within the FORU. This resolved the issue of cash control numbers for participant checks occurring out of sequence due to AHS running files in the background at the same time checks are being logged. This portion of the implementation occurred in August 2024. During the FY24 audit, MHD received further clarification and is implementing a review of a monthly report containing missing and unused cash control numbers for provider checks in eMMIS. This will be compared to a file updated by the Accounts Assistant with the daily cash control numbers used. FORU will use the monthly report to document reasons for any unused or skipped CCNs. This process is being completed monthly beginning March 2025.

View Audit 369219

Finding 1156809 (2024-002)

Material Weakness 2024

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Special Tests & Provisions

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial S...

Finding 2024-002: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – N. Special Tests and Provisions - Housing Quality Standards Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Special Tests and Provisions. Criteria: HQS Inspections. Per the Authority's HCV Admin Plan, the PHA must inspect the unit leased to a family biennially in order to determine if the unit meets HQS standards, and the PHA must conduct quality control re-inspections. The PHA must prepare a unit inspection report (24 CFR sections 982.158(d) and 982.405(b)). These inspection reports are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management there were inspection reports that were unavailable for examination at the time of audit. Context: Of a sample size of thirty-six (36) units, three (3) units did not have biennial HQS inspections performed timely. Our sample size is statistically valid. Known Questioned Costs: $75,684 Cause: There is a material weakness in internal controls over the compliance for the special tests and provisions type of compliance related to HQS inspections. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Choice Vouchers Programs are in material non-compliance with the with the special tests and provisions type of compliance related to HQS inspections. Recommendation: We recommend the Authority design and implement internal control procedures over HQS inspections that will reasonably assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority has recognized the material weakness in the Section 8 Housing Choice Vouchers and Emergency Housing Vouchers programs and will implement internal control procedures that will ensure compliance with federal regulations. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2025.

View Audit 369190 Questioned Costs: $1

Finding 1156808 (2024-001)

Material Weakness 2024

Housing Authority of the County of Marin

CA

Questioned Costs HUD Housing Programs Internal Control / Segregation of Duties

Financial Statement Findings Findings 2024-001 and 2024-002 listed below are also financial statement findings which are required to be reported in accordance with Government Auditing Standards. Federal Award Findings and Questioned Costs Finding 2024-001: Federal Agency: U.S. Department of Housing ...

Financial Statement Findings Findings 2024-001 and 2024-002 listed below are also financial statement findings which are required to be reported in accordance with Government Auditing Standards. Federal Award Findings and Questioned Costs Finding 2024-001: Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Numbers: 14.871, 14.879, 14.EHV Noncompliance – E. Eligibility – Tenant Files Non Compliance Material to the Financial Statements: Yes Material Weakness in Internal Control over Compliance for Eligibility Criteria: Tenant Files. The PHA must do the following: As a condition of admission or continued occupancy, require the tenant and other family member to provide necessary information, documentation, and releases for the PHA to verify income eligibility (24 CFR sections 5.230, 5.609, and 982.516). These files are required to be maintained and available for examination at the time of audit. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were documents that were unavailable for examination at the time of audit. Context: There are approximately 2,533 units. Of a sample size of thirty-six (36) tenant files, the following was noted: • Verification of income was unable to be recalculated in 4 files • Verification of assets was unable to be provided in 1 file • HUD 50058 annual recertification was not filed timely in 2 files • Citizen Declaration Section 214 form was unable to be provided in 9 files Our sample size is statistically valid. Known Questioned Costs: $84,235 Cause: There is a material weakness in the Housing Voucher Cluster in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that assures the program is in compliance. Effect: The Housing Voucher Cluster Programs are in material non-compliance with the eligibility type of compliance related to the maintenance of tenant files. Recommendation: We recommend the Authority design and implement internal control procedures over the maintenance of tenant files that will assure compliance with the Uniform Guidance and the compliance supplement. Views of responsible officials and planned corrective action: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Kathleen Wyatt, Director of Housing Operations, will be responsible to implement this corrective action by December 31, 2025.

View Audit 369190 Questioned Costs: $1

Finding 1156795 (2024-001)

Material Weakness 2024

Mzc Foundation Inc.

GA

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Eligibility § 200.303 § 200.320

Recommendation: We recommend the Foundation strengthen its policies and procedures to ensure procurement is adequately documented for the goods and services purchased in accordance with Uniform Guidance and other federal guidelines, including simplified acquisition procedures for purchases above the...

Recommendation: We recommend the Foundation strengthen its policies and procedures to ensure procurement is adequately documented for the goods and services purchased in accordance with Uniform Guidance and other federal guidelines, including simplified acquisition procedures for purchases above the micro-purchase threshold ($10,000). Grantee Response and Corrective Action Plan 2024-001: In response to the audit finding under 2 CFR Section 200.320 regarding the necessity to have and use documented procurement procedures for acquisition of goods and services under a federal award or a sub‐award, it is acknowledged that the Foundation did not previously have a formal policy specifically addressing procurement. Recognizing the importance of formalizing these practices into policy, we are committed to developing and implementing a comprehensive policy that explicitly addresses procurement. In line with our recent enhancements in internal controls, including the engagement of a Finance Manager in 2024, this policy will reinforce our ongoing efforts to uphold the highest standards of compliance and accountability in all our operations. Responsible Parties: Allie Kelly, Executive Director Anticipated Correction Date: December 31, 2025

View Audit 369173

Finding 1156646 (2024-002)

Material Weakness 2024

Boys & Girls Clubs of Central Mississippi, Inc.

MS

Cash Management Material Weakness

The Organization's management has determined that they received additional funding that was not requested by them. The Organization has discussed this with the granting agency and will pay the excess funds back.

View Audit 369003

Finding 1156630 (2024-004)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: Th...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend the Authority implements controls to ensure abatement is timely for units that do not correct the cited HQS deficiencies within the required timeframe. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will conduct Quality Control on 20% of failed inspections on a biweekly basis to ensure abatements are not missed before the cutoff date of the 27th of each month. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 1/31/2026

View Audit 368975

Finding 1156627 (2024-003)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Special Tests & Provisions Material Weakness

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Explanation of disagreement with audit finding: There is no disagre...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure that documentation is maintained in accordance with rent reasonableness requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will audit files for the correct methodology used in determining rents and ensure rents are reasonable on a monthly basis. In addition, HAKC has contracted a QC audit to review 100% of the files. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/31/2026

View Audit 368975

Finding 1156624 (2024-002)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

HUD Housing Programs Material Weakness Reporting

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action t...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure HUD-50058 recertifications are uploaded to PIC. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC will monitor the monthly SEMAP Indicator report and monitor the PIC dashboard to ensure all 50058 errors are corrected and uploaded in a timely manner. HAKC will also pull the ADHOC from PIC to verify the records. HAKC will continue working with the HUD PIC coach monthly to correct all errors. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 4/30/2026

View Audit 368975

Finding 1156621 (2024-001)

Material Weakness 2024

Housing Authority of Kansas City, Missouri

MO

Eligibility Material Weakness Internal Control / Segregation of Duties

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Explanation of disagreement with audit finding: There is no disagreem...

Housing Voucher Cluster-Assistance Listing No. No. 14.871 and 14.879 Recommendation: We recommend that the Authority implements controls to ensure the tenant files include all required documentation at the time of recertification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: HAKC has moved to mass annual recertification appointments to address the program delinquency and inspect files for required documentation; the recertifications will be completed and processed ensuring all documentation has been received in the file. HAKC will perform a QC sample on a monthly basis to address the files and ensure proper documentation. In addition to QC samples, the HAKC has awarded a QC contract to audit 100% of the files. HAKC will complete the initial process and complete ongoing compliance reviews. Name(s) of the contact person(s) responsible for corrective action: Lisa Earnest, Director of Housing Choice Voucher Program Planned completion date for corrective action plan: 12/31/2026

View Audit 368975

Finding 1156618 (2024-004)

Material Weakness 2024

Hendricks County

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.1 § 200.303

FINDING 2024-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of ...

FINDING 2024-004 Finding Subject: Covid-19 – Coronavirus State and Local Fiscal Recovery Funds – Reporting Findings: Material Weakness, Other Matters Contact Person Responsible for Corrective Action: Ann Stark Contact Phone Number and Email Address: 317-745-9315 / astark@co.hendricks.in.us Views of Responsible O􀆯icials: We concur with the findings. Description of Corrective Action Plan: The Grant Administrator will monitor all claims that will be used for the quarter and send them to the reporting agent to report after the quarter ends. She will be diligent to track any claims coming in outside of that quarter so that reporting is accurate. She will provide the reporting agent with all claims relevant to that quarter’s report. Anticipated Completion Date: This will be done quarterly starting with the quarter ending on September 30th, 2025. The Grant Administrator will submit these claims to the reporting agent one week after the quarter ends. The Financial Administrator will sign o􀆯 on the LOW report to verify the claims match.

View Audit 368974

Finding 1156504 (2024-001)

Material Weakness 2024

Romulus Housing Commission

MI

Questioned Costs Subrecipient Monitoring Eligibility

Report period: 12/31/2024 Title of result and comment FY24 Audit Corrective Action Plan Contact person Responsible for Sabrina Bollinger Corrective Action: Contact's Phone Number 248-593-4611 Contact's Email Address: sbollinger@fourmidable,com Views of Responsible Official: Management agrees with th...

Report period: 12/31/2024 Title of result and comment FY24 Audit Corrective Action Plan Contact person Responsible for Sabrina Bollinger Corrective Action: Contact's Phone Number 248-593-4611 Contact's Email Address: sbollinger@fourmidable,com Views of Responsible Official: Management agrees with the auditor's finding and will implement the auditor's recommendations. Description of Corrective Action Plan The Commission should implement internal controls over tenant files to ensure accountability. Allcertifications and the required documentation should be maintained in the tenant's current file. Additionally,in order to ensure certifications are performed timely and tenant information is input correctly, theCommission should have a second party review files in a timely manner. Anticipated Completion Date: The plan is to implement the corrective action within six months of the audit date. If applicable: Document reason issue will NOT be corrected with 6 months: N/A

View Audit 368862 Questioned Costs: $1

Finding 1156484 (2024-001)

Material Weakness 2024

Northwest Youth Services

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this pol...

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this policy and procedure to ensure rental rates fall within federal grant compliance requirements at the time of each lease signing or renewal. Documentation of rent reasonableness certification will be performed by NWYS housing staff, reviewed by NWYS housing service leadership, and maintained in the client’s permanent file, as defined in the NWYS Rent Reasonableness Policy. Name(s) of Responsible Party:  NWYS Housing leadership staff – Luis Reyna, Addison Ausley, Daniel Pry Anticipated Completion Date:  9/5/25

View Audit 368841 Questioned Costs: $1

Finding 1156453 (2024-001)

Material Weakness 2024

Connections to Success

MO

Procurement, Suspension & Debarment Material Weakness § 200.214

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Material Weakness in Internal Control Over Compliance – Suspension and Debarment ● Other Matter Recommendation: The Organization should strengthen controls and adherence over their policy and the UG and DOL gui...

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Material Weakness in Internal Control Over Compliance – Suspension and Debarment ● Other Matter Recommendation: The Organization should strengthen controls and adherence over their policy and the UG and DOL guidelines and ensure a control is in place for verifying vendors are not suspended, debarred, or otherwise excluded per UG guidelines prior to use of the vendor. The Organization should ensure these policies are followed for all applicable vendors and that documentation related to these controls are maintained and documented. Views of Responsible Officials: Management agrees with the audit finding. Effective immediately, the Organization will update the Procurement and Vendor Management Policy to explicitly require suspension and debarment checks for all applicable vendors in accordance with 2 CFR 200.214 and 2 CFR Part 180. The Organization is implementing a standardized vendor verification form and will require procurement staff to document SAM.gov checks prior to contracting with any vendor. In addition, all staff involved in procurement will be trained on the updated requirements and documentation procedures. The CEO will perform quarterly monitoring to ensure compliance with federal procurement standards and internal policy. These corrective actions will strengthen internal controls and ensure compliance with federal regulations. Contact information for this finding: If the U.S. Department of Labor has questions regarding this schedule, please call Brandi Janke at (816) 520-4404. Completion Date: September 2025

View Audit 368768

Finding 1156452 (2024-001)

Material Weakness 2024

Unleashing Potential

MO

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.430

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hour...

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hours incurred compared to the estimated amounts by individuals assigned to federal grant programs prior to requesting reimbursement from the funding course. The review will be performed by an individual other than the preparer of the reimbursement request, with knowledge of the federal grant program and will be formally documented.

View Audit 368766

Finding 1156379 (2024-004)

Material Weakness 2024

9/11 Day

CA

Questioned Costs Subrecipient Monitoring Reporting § 200.303 § 200.328 § 200.329

In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a ...

In 2024, 9/11 Day was unaware of this regulation, but agrees with this finding. 9/11 Day has adopted a written policy that shall ensure that all subgrants made are properly compliant with the Federal Funding Accountability and Transparency Act of 2006 (FFATA). All subgrantees will be entered into a centralized tracking log, and for those receiving pass-through funds exceeding $30,000, the required reporting will be completed directly in SAM.gov, which now includes the Federal Subaward Reporting System (FSRS). Each subgrantee’s eligibility will be verified in SAM.gov, with the date and results of the verification recorded, and all supporting documentation retained on file. This corrective action ensures that all subawards are properly logged, reported, and compliant with FFATA requirements.

View Audit 368692 Questioned Costs: $1

Finding 1156352 (2024-003)

Material Weakness 2024

City of Seattle

WA

Subrecipient Monitoring Allowable Costs / Cost Principles HUD Housing Programs

The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of co...

The City acknowledges that it did not close out or document the HQS deficiencies discovered as part of this audit. In recognition of continued growth of the OH housing portfolio, including HOME Program assisted projects, and OH’s capacity to maintain its inspection compliance, OH is in process of contracting with a third-party vendor to complete its annual inspections, including HOME inspections for 2025. The contractor will inspect HUD’s NSPIRE level. With this additional support, OH anticipates it will have the capacity to see that corrections have been completed and documented consistent with the HOME program requirements.

View Audit 368642

Finding 1156346 (2024-004)

Material Weakness 2024

City of Seattle

WA

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

The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) M...

The Department acknowledges this finding. The overage occurred following a period of prolonged vacancy in the contract specialist position and while newly assigned staff were still receiving training. To address this issue, the Department has hired a permanent Federal Grants Management Unit (FGMU) Manager to provide consistent leadership and supervision. The contract specialist receives structured management oversight and ongoing training to strengthen capacity for accurate budget monitoring. In July 2025, the FGMU updated its ESG policies and procedures to incorporate improved controls for earmarking. In addition, the Department has instituted regular training sessions for all staff responsible for federal grant management to reinforce compliance with earmarking and other federal requirements. These corrective actions are designed to strengthen internal controls, provide clearer oversight, and ensure that future expenditures remain within established budget and earmarking limits.

View Audit 368642

Corrective Action Plans

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