Corrective Action Plans

Finding 1216250 (2025-004)

Material Weakness 2025

NH

Material Weakness

Finding 2025-004 Plan: Please see below the new process regarding filling vacancies and completing management duties in a timely manner: Immediate Focus on Vacancies: We are prioritizing the filling of vacant units by having two staff members complete move ins at the same time. Streamlined Recertifi...

Finding 2025-004 Plan: Please see below the new process regarding filling vacancies and completing management duties in a timely manner: Immediate Focus on Vacancies: We are prioritizing the filling of vacant units by having two staff members complete move ins at the same time. Streamlined Recertification Process: We have updated our process to ensure all tenants are recertified in a timely manner. There has been a new system in place to monitor deadlines and improve efficiency. Staffing and Training: We are actively recruiting and training additional staff to ensure these tasks are handled promptly, preventing future delays. These steps will address the backlog of management duties and ensure that all tasks, such as filling vacancies and completing tenant recertifications, are handled in a timely and efficient manner. Completion Date: 8/31/2025 Contact: Jackie Oliveira-Director of Affordable Housing

View Audit 402751

Finding 1216163 (2025-006)

Material Weakness 2025

Barton College

NC

Internal Control / Segregation of Duties Material Weakness Reporting § 200.512

Management acknowledges through our previous responses that this finding is aligned with lack of leadership experience in financial aid. This has been resolved with the hiring of Ruth Casper and the separation of one individual where most of the finding’s evidence associated. Ruth Casper has been gi...

Management acknowledges through our previous responses that this finding is aligned with lack of leadership experience in financial aid. This has been resolved with the hiring of Ruth Casper and the separation of one individual where most of the finding’s evidence associated. Ruth Casper has been given specific direction of expectations and the latitude to enact immediate changes to the Barton College Financial Aid awarding/reporting processes to ensure timely and accurate operations/reporting. All Department of Education and Barton internal deadlines will be adhered to at all times going forward.

View Audit 402646

Finding 1216047 (2025-004)

Material Weakness 2025

Communities in Schools of the Dallas Region, Inc.

TX

Allowable Costs / Cost Principles Cash Management Material Weakness

Finding 2025-004: Allowable Costs – Material Weakness in Internal Controls Over Compliance and Compliance Finding Summary of Finding: Duplicate charges were identified within grant reimbursement submissions across reimbursement periods. Management Response During FY2025, grant reimbursement review p...

Finding 2025-004: Allowable Costs – Material Weakness in Internal Controls Over Compliance and Compliance Finding Summary of Finding: Duplicate charges were identified within grant reimbursement submissions across reimbursement periods. Management Response During FY2025, grant reimbursement review procedures were not sufficiently standardized to consistently identify duplicate charges submitted across reimbursement periods. Management is currently evaluating and formalizing enhanced grant reimbursement review workflows designed to improve consistency of review and reduce the risk of duplicate charges within reimbursement submissions. Planned procedures include reconciliation of reimbursement schedules to the general ledger, review of previously submitted reimbursement activity prior to submission of subsequent requests, and clarification of review responsibilities between management and the outsourced accounting team. Management is in the process of documenting these procedures and plans to implement the enhanced review workflow as soon as practicable. Separately, as part of ongoing remediation and compliance monitoring efforts, management has implemented a recurring quarterly Grant Utilization Review process intended to improve oversight of reimbursement activity, grant utilization, and reconciliation procedures across reimbursement periods. The first review meeting is scheduled for June 2026.

View Audit 402576

Finding 1216046 (2025-002)

Material Weakness 2025

Communities in Schools of the Dallas Region, Inc.

TX

Procurement, Suspension & Debarment Allowable Costs / Cost Principles Material Weakness

Summary of Finding: Supporting documentation for certain grant-related expenditures could not be located during compliance testing. Management Response The Organization maintained procedures requiring supporting documentation for grant-related expenditures during FY2025; however, supporting document...

Summary of Finding: Supporting documentation for certain grant-related expenditures could not be located during compliance testing. Management Response The Organization maintained procedures requiring supporting documentation for grant-related expenditures during FY2025; however, supporting documentation was not consistently centralized or retained in a manner that allowed for efficient retrieval during audit testing. Management has since implemented centralized electronic document retention procedures for invoices, grant support, reimbursement documentation, and related approvals. Responsibilities for maintaining and reviewing grant documentation have been clarified between management and the outsourced accounting team to improve accountability and consistency of execution. In addition, grant reimbursement support is now reviewed prior to submission and retained electronically to strengthen ongoing compliance monitoring and audit support procedures. Management has also developed and implemented a recurring Grant Utilization Review meeting process designed to support periodic review of grant activity, supporting documentation, reimbursement status, and compliance-related matters. The first quarterly review meeting is scheduled for June 2026.

View Audit 402576

Finding 1216045 (2025-001)

Material Weakness 2025

Communities in Schools of the Dallas Region, Inc.

TX

Allowable Costs / Cost Principles Material Weakness Internal Control / Segregation of Duties

Summary of Finding: Documentation evidencing management approval was not available for certain expenditures selected during compliance testing. Management Response The Organization maintained procedures requiring management approval of invoices and expenditures during FY2025; however, documentation ...

Summary of Finding: Documentation evidencing management approval was not available for certain expenditures selected during compliance testing. Management Response The Organization maintained procedures requiring management approval of invoices and expenditures during FY2025; however, documentation evidencing approval was not consistently retained during periods of staffing transition and operational change. Management has since enhanced and centralized invoice approval workflows within Accounting Seed to improve consistency of approval documentation retention. Approval responsibilities have been clarified by department and management level, and supporting approval documentation is now maintained electronically within the accounting workflow system. Management has also reinforced approval and documentation retention expectations with department leadership and accounting personnel and implemented periodic review procedures to improve ongoing compliance with internal policies and grant requirements.

View Audit 402576

Finding 1216037 (2025-006)

Material Weakness 2025

Kilgore Junior College District

TX

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend that management strengthen and formalize internal control procedures over federal awards, including documented reviews, approvals, and reconciliations. We also recommend management provide training to staff ...

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend that management strengthen and formalize internal control procedures over federal awards, including documented reviews, approvals, and reconciliations. We also recommend management provide training to staff responsible for federal program administration to ensure understanding of Uniform Guidance requirements. Lastly, management should establish periodic internal reviews to verify that control activities are consistently performed and documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Due to staff turnover, the loan reconciliation process was performed by the Director of Financial Aid. While the design of the internal controls over the Title IV loan reconciliation process remain accurate, timely, and compliant with federal requirements, Management will formalize procedures to ensure appropriate independent review when the Director completes the reconciliation in the event of staff absences or turnover. Specifically, internal control procedures will require that all reconciliations be reviewed and approved by a qualified supervisor, with documentation retained to evidence both the performance and review of the control. Additionally, the policy will designate appropriate backup personnel to perform the review function in situations where the primary supervisor is unavailable due to absence or staffing changes. Name of the contact person responsible for corrective action: Jackie Kelley, Director of Financial Aid & Scholarship Planned completion date for corrective action plan: June 2026

View Audit 402570

Finding 1216036 (2025-005)

Material Weakness 2025

Kilgore Junior College District

TX

Student Financial Aid Eligibility Material Weakness

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit find...

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Augustana intends to modify the NSC/NSLDS monthly data file to ensure that campus and program enrollment dates are pulled from the appropriate data fields in the student information system. Additionally, Augustana intends to implement a step in the withdrawal process to ensure the change in status is reported accurately and timely. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 30, 2026

View Audit 402570

Finding 1216035 (2025-004)

Material Weakness 2025

Kilgore Junior College District

TX

Student Financial Aid Material Weakness Reporting

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit find...

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Augustana intends to modify the NSC/NSLDS monthly data file to ensure that campus and program enrollment dates are pulled from the appropriate data fields in the student information system. Additionally, Augustana intends to implement a step in the withdrawal process to ensure the change in status is reported accurately and timely. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 30, 2026

View Audit 402570

Finding 1216034 (2025-003)

Material Weakness 2025

Kilgore Junior College District

TX

Student Financial Aid Material Weakness Reporting

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit find...

Student Financial Aid Cluster – Assistance Listing No.: Various Recommendation: We recommend the College evaluate its procedures and policies around reporting enrollment changes to NSLDS to ensure that student information is reported accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: Augustana intends to modify the NSC/NSLDS monthly data file to ensure that campus and program enrollment dates are pulled from the appropriate data fields in the student information system. Additionally, Augustana intends to implement a step in the withdrawal process to ensure the change in status is reported accurately and timely. Name of the contact person responsible for corrective action: John Cage at johncage@augustana.edu Planned completion date for corrective action plan: January 30, 2026

View Audit 402570

Finding 1215939 (2025-001)

Material Weakness 2025

South Kitsap School District No. 402

WA

Subrecipient Monitoring Eligibility Allowable Costs / Cost Principles

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal eligibility requirements. Name, address, and telephone of District contact person: Heather Korten, Director of Business Services 2689 Hoover Ave SE Port Orchard, WA 9836...

Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with federal eligibility requirements. Name, address, and telephone of District contact person: Heather Korten, Director of Business Services 2689 Hoover Ave SE Port Orchard, WA 98366 (360) 874-7015 Corrective action the auditee plans to take in response to the finding: 1. Documented Eligibility Review The District will require a documented eligibility review for each student included on any future CWSD application. This review will verify that each student is both: A dependent of active-duty military personnel; and A student with a qualifying severe disability under CWSD program requirements. 2. Comparison to Impact Aid Source Data Prior to submission, the Business Department will compare the students included on the CWSD application to the District’s source documentation for military-connected students, including data maintained through the U.S. Department of Education Impact Aid process. 3. Secondary Review by Business Services The Business Department will perform an independent secondary review of the CWSD application before submission. The application will not be submitted until Business Services has reviewed and documented agreement between the application data and the District’s supporting eligibility records. 4. Special Services Review of Disability Eligibility and Costs The Special Services Department will remain responsible for identifying students with disabilities who may meet the CWSD criteria and for supporting the special education cost information included in the application. 5. Written Procedures and Sign-Off Requirements The District will establish written procedures identifying the staff responsible for preparing, reviewing, approving, and retaining documentation for the CWSD application. The procedures will require documented review and approval by both Special Services and Business Services prior to submission. 6. Documentation Retention The District will retain supporting documentation for each student included on the application, including military-connected status, disability eligibility support, cost documentation, review checklists, and final application approval. 7. Training and Annual Review Staff involved in preparing or reviewing the CWSD application will review applicable program requirements annually before the application is prepared. Anticipated date to complete the corrective action: June 30, 2026

View Audit 402505

Finding 1215896 (2025-001)

Material Weakness 2025

Blaine School District No. 503

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). District Response Plan for Finding 2025-001 Objective: To strengthen internal controls and ensure that all payroll costs char...

Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). District Response Plan for Finding 2025-001 Objective: To strengthen internal controls and ensure that all payroll costs charged to federal programs, specifically the Special Education Cluster, are supported by adequate, timely, and compliant time-and-effort documentation. 1. Resource Allocation and Personnel Oversight Dedicated Management: In response to the finding that the District did not dedicate necessary time and resources to this area, the District will assign specific staff members to oversee the collection and verification of time-and-effort records. Contact Point: Lynn VanBuskirk will serve as the primary contact for ensuring these corrective actions are implemented and monitored. 2. Documentation Standardization and Protocol To meet federal and OSPI requirements, the District will implement the following documentation standards: Activity-Based Reporting: Implement a dual-track system where employees submit either semiannual certifications (for single-activity work) or monthly personnel activity reports/time sheets (for multi-activity work) as required by the awarding agency. Mandatory Timing: Establish a strict policy that all documentation must be signed and dated after the work has been completed. This ensures the records accurately reflect actual time worked rather than projected schedules. 3. Internal Control Enhancements Compliance Tracking: Develop a tracking system to ensure that the salaries and benefits for all employees charged to federal programs (such as the $398,208 identified in the audit) are backed by signed documentation before costs are finalized. Regulatory Alignment: Align District procedures with the OSPI Addendum to Bulletin 039-24, particularly regarding fixed schedule systems and charging employee compensation to federal grants. Quarterly Reviews: Conduct internal quarterly audits of documentation for the Special Education program cluster (84.027/84.173) to identify and correct potential deficiencies before the annual audit process. 4. Training and Communication Staff Training: Provide mandatory training as needed for all staff funded by federal grants on Title 2 CFR Part 200 (Uniform Guidance) requirements for internal controls and allowable cost principles. Alternative Documentation Policy: While the District successfully used alternative documentation to avoid questioned costs during the 2025 audit, the new policy will emphasize that “alternative” records should not be a substitute for the primary time-and-effort documentation required by law.

View Audit 402481

Finding 1215720 (2025-001)

Material Weakness 2025

Monroe School District No. 103

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

The district will implement a process to create and maintain documentation for supplemental contracts and substitute employees serving in vacant positions that clearly identifies the applicable cost objectives and includes employee signatures. These records will be retained and maintained for audit ...

The district will implement a process to create and maintain documentation for supplemental contracts and substitute employees serving in vacant positions that clearly identifies the applicable cost objectives and includes employee signatures. These records will be retained and maintained for audit purposes.

View Audit 402385

Finding 1215710 (2025-003)

Material Weakness 2025

Marysville School District No. 25

WA

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

The District concurs with the finding and will implement a comprehensive corrective action plan to strengthen internal controls over time-and-effort reporting and ensure full compliance with federal regulations and OSPI guidance, including OSPI Bulletin 039-24. Specifically, the District will: • Con...

The District concurs with the finding and will implement a comprehensive corrective action plan to strengthen internal controls over time-and-effort reporting and ensure full compliance with federal regulations and OSPI guidance, including OSPI Bulletin 039-24. Specifically, the District will: • Conduct a districtwide review of all federally funded positions to ensure appropriate time-and-effort documentation requirements are identified and applied. • Implement standardized procedures for time-and-effort documentation, including the use of semi-annual certifications, monthly personnel activity reports (PARs), or approved fixed schedule systems, as applicable. • Revise and formalize written procedures governing time-and-effort reporting to ensure clarity, consistency, and compliance. • Establish a secondary review process to verify completeness and accuracy of employee classifications and required documentation. • Provide training to applicable staff on time-and-effort requirements and documentation standards. • Implement ongoing monitoring and periodic internal reviews to ensure documentation is completed timely, properly approved, and retained in accordance with requirements. These actions are designed to ensure payroll costs charged to federal programs are fully supported, accurate, and compliant with applicable laws and regulations.

View Audit 402363

Finding 1215706 (2025-004)

Material Weakness 2025

Marysville School District No. 25

WA

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

The District concurs with the finding and will implement a comprehensive corrective action plan to strengthen internal controls over time-and-effort reporting and ensure full compliance with federal regulations and OSPI guidance, including OSPI Bulletin 039-24. Specifically, the District will: • Con...

The District concurs with the finding and will implement a comprehensive corrective action plan to strengthen internal controls over time-and-effort reporting and ensure full compliance with federal regulations and OSPI guidance, including OSPI Bulletin 039-24. Specifically, the District will: • Conduct a districtwide review of all federally funded positions to ensure appropriate time-and-effort documentation requirements are identified and applied. • Implement standardized procedures for time-and-effort documentation, including the use of semi-annual certifications, monthly personnel activity reports (PARs), or approved fixed schedule systems, as applicable. • Revise and formalize written procedures governing time-and-effort reporting to ensure clarity, consistency, and compliance. • Establish a secondary review process to verify completeness and accuracy of employee classifications and required documentation. • Provide training to applicable staff on time-and-effort requirements and documentation standards. • Implement ongoing monitoring and periodic internal reviews to ensure documentation is completed timely, properly approved, and retained in accordance with requirements. These actions are designed to ensure payroll costs charged to federal programs are fully supported, accurate, and compliant with applicable laws and regulations.

View Audit 402363

Finding 1215701 (2025-002)

Material Weakness 2025

Marysville School District No. 25

WA

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

The District concurs with the finding and will implement a comprehensive corrective action plan to strengthen internal controls over time-and-effort reporting and ensure full compliance with federal regulations and OSPI guidance, including OSPI Bulletin 039-24. Specifically, the District will: • Con...

The District concurs with the finding and will implement a comprehensive corrective action plan to strengthen internal controls over time-and-effort reporting and ensure full compliance with federal regulations and OSPI guidance, including OSPI Bulletin 039-24. Specifically, the District will: • Conduct a districtwide review of all federally funded positions to ensure appropriate time-and-effort documentation requirements are identified and applied. • Implement standardized procedures for time-and-effort documentation, including the use of semi-annual certifications, monthly personnel activity reports (PARs), or approved fixed schedule systems, as applicable. • Revise and formalize written procedures governing time-and-effort reporting to ensure clarity, consistency, and compliance. • Establish a secondary review process to verify completeness and accuracy of employee classifications and required documentation. • Provide training to applicable staff on time-and-effort requirements and documentation standards. • Implement ongoing monitoring and periodic internal reviews to ensure documentation is completed timely, properly approved, and retained in accordance with requirements. These actions are designed to ensure payroll costs charged to federal programs are fully supported, accurate, and compliant with applicable laws and regulations.

View Audit 402363

Finding 1215695 (2025-002)

Material Weakness 2025

Home Share 092-Hd017

MN

HUD Housing Programs Internal Control / Segregation of Duties Material Weakness

Supportive Housing for Persons with Disabilities (Section 811) – Assistance Listing No. 14.181 Recommendation: We recommend that management establish and implement a formal internal control to ensure that someone who did not prepare the HAP Voucher reviews them for accuracy before submission. The pr...

Supportive Housing for Persons with Disabilities (Section 811) – Assistance Listing No. 14.181 Recommendation: We recommend that management establish and implement a formal internal control to ensure that someone who did not prepare the HAP Voucher reviews them for accuracy before submission. The preparation and review should be documented with a signature and date to ensure there is a proper audit trail. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will strengthen our internal controls by implementing a formal, documented review process to ensure that all monthly HAP Vouchers receive an independent review prior to submission to HUD. Beginning with the next reporting cycle, our HUD Consultant will be responsible for preparing the monthly HAP Voucher and assembling all supporting documentation. Once prepared, the voucher package will be forwarded to the Contract Accountant for an independent review. The Contract Accountant will verify the accuracy and completeness of the voucher, including agreement to tenant ledgers, mathematical accuracy, proper application of subsidy rules, and consistency with prior month activity. This review will be documented through a dated signature on the voucher cover sheet, establishing a clear audit trail and ensuring appropriate segregation of duties between preparation and review. This control will be incorporated into the monthly close process and performed consistently going forward to ensure accurate, compliant, and fully supported HAP Voucher submissions. Name(s) of the contact person(s) responsible for corrective action: Jes Cuoco Planned completion date for corrective action plan: April 1, 2026

View Audit 402351

Finding 1215693 (2025-001)

Material Weakness 2025

Home Share 092-Hd017

MN

HUD Housing Programs Cash Management Material Weakness

Supportive Housing for Persons with Disabilities (Section 811) – Assistance Listing No. 14.181 Recommendation: We recommend that management establish and implement formal written policies and procedures to ensure surplus cash is either used to pay down debts subject to surplus cash or deposited in t...

Supportive Housing for Persons with Disabilities (Section 811) – Assistance Listing No. 14.181 Recommendation: We recommend that management establish and implement formal written policies and procedures to ensure surplus cash is either used to pay down debts subject to surplus cash or deposited in the residual receipts reserve in a timely manner in accordance with HUD requirements and the project’s Regulatory Agreement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have strengthened our internal controls by implementing a documented audit trail and a formal monthly reconciliation process for all intercompany activity between Home Share and Accord. Each month, the Contract Accountant prepares and submits to the Vice President of Finance a summary of the year to date activity along with the full outstanding intercompany balance, including prior year amounts. The Vice President of Finance reviews this reconciliation against the Home Share account balances to determine the amount that can be transferred to reduce the intercompany liability in accordance with HUD surplus cash requirements. Once the transfer is approved and completed, the Contract Accountant receives confirmation along with a copy of the ACH transaction to document the transaction. This process is performed and documented as part of each month end close to ensure timely, accurate, and compliant surplus cash transfers. Name(s) of the contact person(s) responsible for corrective action: Jes Cuoco Planned completion date for corrective action plan: May 31, 2025

View Audit 402351

Finding 1215686 (2025-002)

Material Weakness 2025

Renton School District No. 403

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

To address this issue and strengthen compliance controls, the District has implemented and will continue the following corrective actions: 1. Standardized Time-and-Effort Procedures The District has revised and standardized procedures for collecting, reviewing, and retaining time-and-effort document...

To address this issue and strengthen compliance controls, the District has implemented and will continue the following corrective actions: 1. Standardized Time-and-Effort Procedures The District has revised and standardized procedures for collecting, reviewing, and retaining time-and-effort documentation for all federally funded employees and substitutes charged to Title I and other federal programs. 2. Training and Guidance District staff responsible for payroll processing, federal program oversight, and school-level administration will receive annual training regarding federal time-andeffort requirements, including requirements for semiannual certifications, personnel activity reports, signature and date requirements, and retention expectations. 3. Centralized Monitoring and Review The District has updated its centralized review process to verify that all required timeand- effort documentation is completed accurately and retained timely before payroll expenditures are finalized and charged to federal programs. This review includes periodic monitoring by Business Services and Program staff. 4. Tracking and Documentation Controls The District is updating its tracking mechanisms, including standardized forms, submission deadlines, and periodic compliance checklists, to ensure required certifications are collected and retained for all applicable employees each reporting period. 5. Ongoing Compliance Monitoring District management will conduct periodic internal reviews of federally funded payroll documentation throughout the fiscal year to ensure continued compliance and to promptly address any deficiencies identified. The District expects these corrective actions to strengthen internal controls and ensure ongoing compliance with federal and OSPI requirements for time-and-effort documentation.

View Audit 402334

Finding 1215673 (2025-005)

Material Weakness 2025

Oakland County, Michigan

MI

HUD Housing Programs Material Weakness Reporting § 200.307

Reporting of Prior Year Program Income Auditor Description of Criteria, Condition, and Effect: In accordance with 2 CFR § 200.307, program income must be used in accordance with the terms and conditions of the federal award and must be accounted for and reported accurately. Recipients are required t...

Reporting of Prior Year Program Income Auditor Description of Criteria, Condition, and Effect: In accordance with 2 CFR § 200.307, program income must be used in accordance with the terms and conditions of the federal award and must be accounted for and reported accurately. Recipients are required to reconcile program income received and expended during the grant period to ensure it is used for allowable purposes and properly reflected in financial reports. Failure to reconcile and report program income may result in noncompliance with federal grant regulations and could impact the allowability of costs charged to the award. The County recognized a substantial amount of program income during the fiscal year ended September 30, 2025, for program income that was received in prior periods but incorrectly reported as unearned over many years. It is unclear what portion of this prior year unearned revenue was reported to the Department of Housing and Urban Development ("HUD") through the Integrated Disbursement and Information System ("IDIS") now that the revenue has been properly recognized in the general ledger. The County has a risk of inaccurately reporting program income to HUD. The County is also exposed to an increased risk noncompliance could occur and not be prevented or detected by the County's internal controls. Auditor Recommendation: We recommend the County review its prior year records to determine which portion of the currently recognized revenue has already been reported to HUD. Additionally, the County's Neighborhood and Housing Development ("NHD") department should coordinate with HUD to establish the appropriate approach for reporting and expending this program income going forward. Corrective Action: An in-depth review of all program income activity dating back to 1995 is currently underway within both the general ledger and the IDIS system. The purpose of this review is to determine the total amount of program income received and reported to HUD. Upon completion of the review, the County will collaborate with HUD to determine the appropriate use and expenditure of the identified funds in accordance with applicable program requirements. Responsible Persons: Khadija Walker-Fobbs Neighborhood and Housing Development Officer, Curtis Smith, Chief, Neighborhood and Housing Development and Brian J. Lefler, Chief Financial Officer Anticipated Completion Date: September 2026

View Audit 402331

Finding 1215654 (2025-004)

Material Weakness 2025

Oakland County, Michigan

MI

Reporting Material Weakness

Inaccurate Reporting/Lack of Independent Review and Approval of Reporting (Repeat) Auditor Description of Criteria, Condition, and Effect: Recipients of federal awards are required to report periodically on financial information, as specified by the grant agreement. Reported information should be su...

Inaccurate Reporting/Lack of Independent Review and Approval of Reporting (Repeat) Auditor Description of Criteria, Condition, and Effect: Recipients of federal awards are required to report periodically on financial information, as specified by the grant agreement. Reported information should be supported by the entity’s accounting records and subjected to an independent review and approval prior to submission in order to detect and correct any errors or omissions. Additionally, the PR-26 financial summary reports are submitted as part of the Consolidated Annual Performance Evaluation Report (CAPER) and should be properly reconciled to present all inflows and outflows of resources related to the program including the appropriate unexpended balance. During our audit procedures over the County's CDBG reporting, we noted that none of the reports were subject to an independent review and approval prior to submission in order to detect and correct potential errors or omissions until partway through the year under audit. We also noted that the PR-26 was submitted as required, but contained financial data that did not agree to the County's underlying accounting records. Expenditures were properly reported for the year under audit, but it was identified that the County had incorrectly reported its unexpended balance going back to 2020, when the unexpended balance was not properly carried over from the 2019 report to the 2020 report. This resulted in an incorrect unexpended balance which presented as a net negative unexpended balance in the current year report. The County submitted inaccurate reporting in its PR-26 that was inconsistent with other financial reports submitted and with the County's general ledger. The County is also exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the County's internal controls until controls are consistently implemented across fiscal years. Auditor Recommendation: We recommend that the County implement necessary internal controls to ensure that proper review and approval is documented and reports agree to accounting records. Financial information being submitted to outside entities should be reviewed and approved by the Financial Services department to ensure that it is in agreement with the County's general ledger and consistent with other required financial reporting. Corrective Action: Management acknowledges that financial reporting requires enhanced controls and reconciliation procedures. A review of detailed reconciliation steps will be conducted to identify areas within current processes where regular reviews can be implemented to ensure accuracy and completeness. The County plans to implement this process by July FY2026, which will provide two full quarters of reviewed and monitored activity prior to year-end reporting. Responsible Persons: Khadija Walker-Fobbs Neighborhood and Housing Development Officer, Curtis Smith, Chief, Neighborhood and Housing Development and Brian J. Lefler, Chief Financial Officer Anticipated Completion Date: September 2026

View Audit 402331

Finding 1215545 (2025-001)

Material Weakness 2025

La Center School District

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE La Center School District No. 101 September 1, 2024 through August 31, 2025 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of F...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE La Center School District No. 101 September 1, 2024 through August 31, 2025 This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-001 Finding caption: The District did not have adequate internal controls and did not comply with time and effort requirements. Name, address, and telephone of District contact person: Gary McGarvie, Business Manager PO Box 1840 La Center, WA 98629 (360) 263-2131 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). As a new Business Manager completing year-end processes for the first time, I mistakenly overlooked attaching the semi-annual Time & Effort certification forms to the timesheets for our classified staff. While the District did maintain completed timesheets for all staff throughout the year, the formal Time & Effort certification documentation was not completed as required for federal grant compliance. To correct this and prevent it from happening again, the District has since implemented a more structured process to ensure Time & Effort documents are properly completed. This includes attaching semi-annual certification forms directly to timesheets for classified staff and sending certification forms to certificated staff twice a year. This process will ensure that the dollars being spent from federal grants are being used accurately and in accordance with federal requirements. Anticipated date to complete the corrective action: This process has already been implemented and we should not have this issue happen moving forward.

View Audit 402209

Finding 1215471 (2025-002)

Material Weakness 2025

Community Council of Idaho, Inc.

ID

Equipment & Real Property Management HUD Housing Programs Material Weakness § 200.302 § 200.512

Management’s Response Community Council of Idaho, Inc. acknowledges the finding related to untimely reconciliations, material audit adjustments, and delayed financial statement issuance. Management agrees that improvements are necessary to strengthen internal controls over financial reporting, ensur...

Management’s Response Community Council of Idaho, Inc. acknowledges the finding related to untimely reconciliations, material audit adjustments, and delayed financial statement issuance. Management agrees that improvements are necessary to strengthen internal controls over financial reporting, ensure timely account reconciliations, and improve the overall financial close and audit preparation process. Management recognizes that turnover within the business office during the audit year significantly impacted continuity, institutional knowledge, and the timely completion of reconciliations and closing procedures. Subsequent to year end, management has initiated corrective actions designed to improve financial reporting accuracy, accountability, and timeliness. Corrective Actions to Be Implemented 1. Implementation of Formal Monthly Closing Procedures Management will implement a standardized monthly financial close process with defined timelines, responsibilities, and review procedures. The monthly close process will include: Completion of all balance sheet reconciliations, Review of grant and contract revenue accounts, Review of property and equipment activity, Reconciliation of debt schedules, Reconciliation of pharmaceutical inventory balances, Recording of depreciation and interest expense, and Verification that all material journal entries are posted timely. A monthly close checklist will be developed and maintained to ensure consistency and accountability. 2. Timely Reconciliation of Grant and Contract Accounts Management will strengthen procedures surrounding grant and contract accounting to ensure receivables and revenue are reconciled monthly and supported by appropriate documentation. Actions include: Reconciling grant receivable balances to supporting reimbursement requests and funding agency records, Reviewing deferred revenue and earned revenue calculations monthly, Investigating and resolving variances timely, and Implementing supervisory review of grant reconciliations. 3. Enhanced Review and Oversight Controls Management will implement additional review controls over financial reporting and account reconciliations. These controls will include: Documented supervisory review and approval of reconciliations, Review of significant or unusual journal entries, Periodic review of financial statements and supporting schedules by senior finance leadership, and Earlier audit preparation and interim review procedures to identify issues prior to year end. 4. Strengthening Staffing and Organizational Structure Management and executive leadership have evaluated the operational needs of the business office and have taken steps to improve staffing stability and oversight capacity. Actions include: Clarifying accounting roles and responsibilities, Enhancing cross-training within the finance department, Providing additional training related to grant accounting and reconciliations, Utilizing external resources or consultants, as needed, to support complex accounting areas and transition periods. 5. Improvement of Clinic Reporting Processes Management will continue evaluating clinic reporting systems and procedures to ensure operational growth is adequately supported by accounting and financial reporting processes. This includes: Improving coordination between clinic operations and accounting, Standardizing reporting procedures, Evaluating system-generated reports for accuracy and completeness, and Implementing additional reconciliation and review controls related to clinic financial activity. 6. Audit Readiness and Timeliness Improvements Management will establish an audit preparation timeline with interim deadlines to support timely completion of the annual audit and compliance with federal reporting deadlines. The organization will: Prepare schedules and reconciliations in advance of audit fieldwork, Conduct periodic internal reviews of audit support documentation, Improve coordination with external auditors throughout the year, and Monitor progress toward required reporting deadlines. Contact Person Responsible for Corrective Action: Implementation oversight will be shared among executive leadership, finance management, program leadership, and those charged with governance. Anticipated Completion Date: Corrective actions began subsequent to year end and are expected to be substantially implemented during fiscal year 2026, with ongoing monitoring and refinement thereafter.

View Audit 402110

Finding 1215463 (2025-006)

Material Weakness 2025

Delta Research and Educational Foundation

DC

Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking § 200.430

Views of Responsible Officials: All the Foundation's employees now complete an excel timesheet that is then submitted to their supervisor for review and approval. Payroll is processed only after all employee timesheets are approved and received by the Senior Accountant who processes payroll.

View Audit 402102

Finding 1215405 (2025-003)

Material Weakness 2025

Association House of Chicago

IL

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

MATERIAL WEAKNESS Finding 2025-003 – Allocation and Documentation of Payroll Costs Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, ...

MATERIAL WEAKNESS Finding 2025-003 – Allocation and Documentation of Payroll Costs Recommendation: Management should develop a process whereby payroll costs allocated to federal grants; are supported by a system of internal controls which provides reasonable assurance that the charges are accurate, allowable and properly allocated, reasonably reflect the total activity for which the employee is compensated and support the distribution of the employee’s wages among specific activities or cost objectives if the employee woks on more than one federally funded program. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: As corrective action, management implemented a new system to track time and effort effective July 1, 2025, using the Forms Assembly platform for federally funded DHS programs. For other grants, the Agency has continued to maintain supporting time and effort documentation through Excel-based records. Management recognizes that the implementation of the Forms Assembly system has presented operational challenges, particularly due to the need to reconcile information separately with the payroll system. As a result, since October 2025, management has been evaluating and vetting alternative systems that can fully integrate time and effort reporting with payroll processing. Beginning in fiscal year 2027, the Agency plans to implement a new integrated software solution that will record employee time, grant allocations, and payroll information within a single system integrated directly with payroll processing. Management believes this integrated approach will strengthen internal controls, improve the accuracy and timeliness of reporting, reduce manual reconciliation processes, and enhance compliance with federal time and effort requirements. Name of contact person responsible for corrective action: Margarita Rosas, Chief Financial Officer Planned completion date for corrective action plan: June 30, 2026

View Audit 401983

Finding 1215393 (2025-002)

Material Weakness 2025

Council of Spanish Speaking Organizations, Inc.

PA

Allowable Costs / Cost Principles Student Financial Aid Material Weakness

Material Weakness in Internal Control over Compliance and Compliance - Allowable Costs Condition: During our testing of allowable costs, we identified IT-related expenses totaling $111,669 that were charged to the major program for services that were not performed by the vendor and for which the ent...

Material Weakness in Internal Control over Compliance and Compliance - Allowable Costs Condition: During our testing of allowable costs, we identified IT-related expenses totaling $111,669 that were charged to the major program for services that were not performed by the vendor and for which the entity did not receive any benefit. These costs were subsequently reimbursed to Concilio by the funder. Recommendation: We recommend that management strengthen internal controls over vendor payments and grant billings to ensure that only costs for services actually rendered and properly supported are charged to federal awards. Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has initiated corrective actions to strengthen internal controls over vendor payments, procurement, and grant billing processes. Upon discovery of the issue, management reviewed the affected transactions and ensured reimbursement of the questioned costs to the funding agency. Procedures have been enhanced to require appropriate documentation and supervisory approval confirming that services are properly rendered prior to payment and charging of costs against awards. In addition, management has strengthened vendor oversight and contract monitoring processes, including improved verification of invoices against contractual deliverables and supporting documentation. The Compliance functions have been enhanced to include periodic reviews of program expenditures, and additional staff training will be provided on allowable cost requirements, compliance standards, and documentation expectations to prevent recurrence of similar issues. Name of the contact person responsible for corrective action: Asif Mehmood, Chief Financial Officer asif.mehmood@elconcilio.net (215)627-3100 Planned completion date for the corrective action plan: June 30, 2026

View Audit 401940

Corrective Action Plans

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