Corrective Action Plans

Finding 1166112 (2025-002)

Material Weakness 2025

South Sioux City Community Schools District #11

NE

Questioned Costs Significant Deficiency

Processes have been implemented to improve and maintain documentation for grant reimbursement requests so overclaiming federal funds does not occur.

View Audit 376904

Finding 1166110 (2025-001)

Material Weakness 2025

Ken-Crest Housing PA 2001, Inc.

PA

Special Tests & Provisions Questioned Costs HUD Housing Programs

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2001, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and add...

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 2001, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting ﬁrm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The ﬁndings from the June 30, 2025 schedule of ﬁndings and questioned costs are discussed below. The ﬁndings are numbered consistently with the number assigned in the schedule. Signiﬁcant Deﬁciency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.

View Audit 376903

Finding 1166108 (2025-001)

Material Weakness 2025

Ken-Crest Housing Del Ii, Inc.

PA

Special Tests & Provisions Questioned Costs HUD Housing Programs

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DEL II, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and addr...

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DEL II, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting ﬁrm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The ﬁndings from the June 30, 2025 schedule of ﬁndings and questioned costs are discussed below. The ﬁndings are numbered consistently with the number assigned in the schedule. Signiﬁcant Deﬁciency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.

View Audit 376902

Finding 1166106 (2025-003)

Material Weakness 2025

Housing Authority of the City of Paterson

NJ

Internal Control / Segregation of Duties Questioned Costs Eligibility

Finding 2025-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Inte...

Finding 2025-003 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Public and Indian Housing Program Federal Catalog Numbers: 14.850 Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Internal Control over Compliance for Eligibility Finding 2025-003 (continued) 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 and the Authority failed to properly calculate the tenant's rent payments using documentation from third party income verification. Context: There are approximately 834 units. Of a sample size of twenty three (23) tenant files, the following was noted: Original Applications were missing in thirteen (13) files. Citizenship Declarations were missing in five (5) files. Verification of income was missing in eight (8) files. The Authority also failed to properly calculate the rent payments of four (4) tenants by not utilizing documentation from third party income verification. Our sample size is statistically valid. Cause: There is a material weakness in internal controls over the compliance for the eligibility type of compliance related to the maintenance of tenant files and the calculation of rent. The Authority has not properly considered, designed, implemented, maintained and monitored a system of internal controls that reasonably assures the program is in compliance. Recommendation: We recommend the Authority design and implement internal control procedures that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority's response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public and Indian Housing Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

View Audit 376899

Finding 1166105 (2025-002)

Material Weakness 2025

Housing Authority of the City of Paterson

NJ

HUD Housing Programs Internal Control / Segregation of Duties Questioned Costs

Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: ...

Finding 2025-002 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Federal Catalog Numbers: 14.871 & 14.EHV Noncompliance – N. Special Tests and Provisions – Housing Quality Standards Non Compliance Material to the Financial Statements: No Significant deficiency in Internal Control over Compliance for Special Tests and Provisions Finding 2025-002 (continued) Criteria: Housing Quality Standards Inspections. The PHA must inspect the unit leased to a family at least annually to determine if the unit meets Housing Quality Standards (HQS) 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. For units that fail inspection the PHA must correct all life threatening HQS deficiencies within 24 hours and all other deficiencies within 30 days. Condition: Based upon inspection of the Authority’s files and on discussion with management, there were units that were not inspected within the annual inspection period. Additionally, there were units that failed inspections and did not pass reinspection within 30 days without penalty. Context: There are approximately two thousand seven hundred fifty six (2,756) units. Of a sample size of thirty seven (37) files, three (3) annual inspections, were not completed in a timely manner. Additionally, there are approximately one thousand two hundred forty seven (1,247) units with failed inspections. Of a sample size of twenty five (25) units with failed inspections, four units (4) unit did not pass reinspection within 30 days. Housing assistance payments were not abated nor was the tenant relocated. Our sample size is statistically valid. Cause: The Authority did not perform timely annual inspections and follow up to failed inspections in accordance with program requirements. Effect: The Housing Voucher Cluster Program is in 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 that will reasonably assure compliance related to HQS inspections in accordance with the Uniform Guidance and the compliance supplement. Authority's Response: 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 related to HQS inspections are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

View Audit 376899

Finding 1166104 (2025-001)

Material Weakness 2025

Housing Authority of the City of Paterson

NJ

HUD Housing Programs Internal Control / Segregation of Duties Questioned Costs

Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871 & 14.EHV Noncompliance – E. Eligibility - Tenant Files Non Compliance Material to the Financial Statements: Yes Material weakness in Int...

Finding 2025-001 Federal Agency: U.S. Department of Housing and Urban Development Federal Program Titles: Housing Voucher Cluster Assistance Listing Number: 14.871 & 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). Finding 2025-001 (continued) 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 and the Authority included income that was miscalculated during the annual recertification. Context: Of a sample size of thirty-seven (37) tenant files, the following information was unavailable for examination at the time of audit: • Original application was missing in one (1) file • Citizenship declaration was missing in one (1) file • Signed lease was missing in one (1) file • Verification of income was missing in four (4) files • HUD form 50058 was not timely filed for one (1) file In addition, three (3) tenants' annual recertifications (HUD-50058 form) included income that was miscalculated. Our sample size is statistically valid. Cause: There is a material weakness 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 and designed a system of internal controls that reasonably assures the program is in compliance. Effect: The Housing Voucher Cluster program is 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 that will reasonably assure eligibility compliance with the Uniform Guidance and the compliance supplement. Authority Response: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster Program to ensure that established internal control policies are being followed on a timely basis. Views of responsible officials and planned corrective action: Ms. Irma Gorham, Executive Director is responsible to remedy the deficiency by March 31, 2026.

View Audit 376899

Finding 1166103 (2025-001)

Material Weakness 2025

Ken-Crest Housing De 2003, Inc.

PA

Special Tests & Provisions Questioned Costs HUD Housing Programs

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DE 2003, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and add...

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing DE 2003, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting ﬁrm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The ﬁndings from the June 30, 2025 schedule of ﬁndings and questioned costs are discussed below. The ﬁndings are numbered consistently with the number assigned in the schedule. Signiﬁcant Deﬁciency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.

View Audit 376898

Finding 1166101 (2025-001)

Material Weakness 2025

Ken-Crest Housing PA 99, Inc.

PA

Special Tests & Provisions Questioned Costs HUD Housing Programs

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 99, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and addre...

Person Responsible for Corrective Action: Chief Financial Officer CORRECTIVE ACTION PLAN U.S. Department of Housing and Urban Development Ken-Crest Housing PA 99, Inc. ("the Organization") respectfully submits the following corrective action plan for the report dated December 3, 2025. Name and address of independent public accounting ﬁrm: WithumSmith+Brown, P.C. 1835 Market Street, 3rd Floor Philadelphia, PA, 19103 Audit period: July 1, 2024 – June 30, 2025 The ﬁndings from the June 30, 2025 schedule of ﬁndings and questioned costs are discussed below. The ﬁndings are numbered consistently with the number assigned in the schedule. Signiﬁcant Deﬁciency-Special Tests and Provisions – Project Funds Finding 2025-001 – Project funds are not held in an interest-bearing account. This is a repeat finding from June 30, 2024 (Finding 2004-001). 2025-001 Recommendation: We recommend that the Corporation utilize an interest-bearing account for project funds in accordance with HUD requirements. Action Taken: Although Ken-Crest Housing Del II, Inc. did not use an interest-bearing account for project funds during the year ended June 30, 2025, in July 2025, management opened an interest-bearing account and all Project funds were transferred into that account. Date of Completion: July 2025 Follow up on Prior Year’s Findings and Questioned Costs: Finding 2024-001 was not resolved during 2025, therefore, it has been reported as finding 2025-001 for the year ended June 30, 2025. In July 2025, management resolved this finding as all Project funds were transferred into an interest-bearing account. If the U.S. Department of Housing and Urban Development has questions regarding this plan, please contact Arthur Anderson, CFO at Arthur.anderson@kencrest.org.

View Audit 376897

Finding 1165916 (2025-002)

Material Weakness 2025

Pcc Community Wellness Center

IL

Questioned Costs Subrecipient Monitoring

Recommendation: Management should consider increasing the frequency of its self-reviews of sliding fee encounters, increasing the frequency of when patient portal updates are being reviewed and approved, and/or provide additional training for front desk staff regarding the collection and verificatio...

Recommendation: Management should consider increasing the frequency of its self-reviews of sliding fee encounters, increasing the frequency of when patient portal updates are being reviewed and approved, and/or provide additional training for front desk staff regarding the collection and verification of patient information for each patient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: See matrix below Name(s) of the contact person(s) responsible for corrective action: Hiren Patel, CFO Planned completion date for corrective action plan: See matrix below Finding 2025-002 / ACTION STEP 1 / ACTION STEP 2 / ACTION STEP 3 / ACTION STEP 4 Assigned / RCM Leaders / Executive Leaders / Patient Care Reps (PCRs) / Practice Managers / Enrollment Specialist/RCM Leaders Resources needed / Annual Federal Poverty Level (FPL) update issued no later than February of each year, given by federal government / Supporting financial documentation for all patients/applications / Athena (EHR system) / Audit tracking tools, EHR reports Actions to be taken / Audit EHR system to ensure timely update by EHR each year; updated internal QRG and distribute to Operations front-staff leaders and Compliance Update patient level amounts based on approval by Executive Leaders- as needed / Complete review of supporting financial documentation for each patient/application Upload documentation in EHR to support approval/disapproval-update EHR accordingly 85% collections of patient levels at time of service / Practice Manager Audits 25 SFS claims to ensure all documentation has been received, uploaded and reviewed accurately / Enrollment Specialist reviews patient account during self-pay collection efforts for all that have outstanding balances; ensures all have supporting documents aligning with approval, notifies RCM leaders monthly of inaccurate findings RCM Leaders audit 50-60 accounts quarterly to cover all sites Progress indicated at benchmark / Implement workflow / Implement workflow / Implement **NEW**Workflow / Implement workflow Completion date / February of each year / February 2026 / February 2026 / February 2026 Evidences of improvement / Reporting to ensure alignment / Monthly audit / Monthly audit / Monthly/Quarterly audit

View Audit 376823

Finding 1165891 (2025-001)

Material Weakness 2025

Shenandoah Valley School District

PA

Internal Control / Segregation of Duties Questioned Costs School Nutrition Programs

Corrective Action Plan The Shenandoah Valley School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. F...

Corrective Action Plan The Shenandoah Valley School District respectfully submits the following corrective action plan for the year ended June 30, 2025. The findings from the Single Audit Report Year Ended June 30, 2025 included in the schedule of findings and questioned costs are discussed below. Finding 2025-001: Activities Allowed – Child Nutrition Cluster Contact Person: Anthony Demalis, Business Manager Recommendation: The District should follow its established internal control procedures over activities allowed requirements. Action: Since this was an inadvertent clerical error, District will continue to review its’ internal control procedures over payroll and established procedures to ensure employee pay rates show signs of approval prior to payroll being processed. Date for Completion: December 1, 2025

View Audit 376814

Finding 1165860 (2025-001)

Material Weakness 2025

Neighborhood Housing Services of Chicago, Inc. and Related Entities

IL

Allowable Costs / Cost Principles Questioned Costs Cash Management § 200.303

Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which...

Condition: The Organization did not review period end reimbursement requests for costs that had been expended and requested in prior months. The lack of proper review resulted in the Organization charging duplicate costs of $95,294. Planned Corrective Action: The CFO maintains a payout tracker which is updated every time a vendor payout is made and tracks that payment to the reimbursement request and the final payment by the pass-through agency. This process ensures that a payout is not included in a payout request multiple times. The Staff Accountant also maintains a tracker of all reimbursement requests to track with the program budgets and for inclusion in the MIP accounting system. In addition, new personnel are involved in the process with a more formal approval and authorization process implemented. The Organization’s staff has communicated these duplicate requests to the appropriate personnel at the granting agency and are coordinating the repayment of the excess funds as determined by the granting agency. Contact person responsible for corrective action: Tom Sakos, Chief Financial Officer, and Jenny Cuitiva, Accounting Manager Anticipated Completion Date: May 1, 2025 for implementing controls and November 30, 2025 for communicating with the granting agency.

View Audit 376751

Finding 1165859 (2025-002)

Material Weakness 2025

American Film Institute

CA

Student Financial Aid Eligibility Questioned Costs

Corrective action has been completed. The Institute determined at the start of Academic Year 24-25 that transitioning to a third-party provider of financial aid solutions would be in its best interest. This engagement provides a team of professional financial aid operations and student service speci...

Corrective action has been completed. The Institute determined at the start of Academic Year 24-25 that transitioning to a third-party provider of financial aid solutions would be in its best interest. This engagement provides a team of professional financial aid operations and student service specialists, allowing for enhanced loan counseling and processing services, implementing additional checks and balances, and mitigating the potential for errors such as this incident. The error resulting in the finding was actually identified by the third-party provider, following which AFI immediately returned the erroneously awarded federal funds to G5. Individuals responsible for corrective action: Lang Fredrickson, Chief Financial Officer 323.856.8429

View Audit 376737

Finding 1165846 (2025-001)

Material Weakness 2025

YWCA Evanston/north Shore

IL

Questioned Costs Cash Management Reporting

Condition: YWCA Evanston/North Shore did not submit its fiscal year 2024 Data Collection Form and single audit reporting package to the Federal Audit Clearinghouse within the earlier of nine months following its fiscal year end, or 30 days after receipt of the auditors' report. Corrective Action Tak...

Condition: YWCA Evanston/North Shore did not submit its fiscal year 2024 Data Collection Form and single audit reporting package to the Federal Audit Clearinghouse within the earlier of nine months following its fiscal year end, or 30 days after receipt of the auditors' report. Corrective Action Taken or Planned: Management concurs and plans to submit the June 30, 2024 data collection form and single audit reporting package on or before December 31, 2025. Anticipated Date of Completion: December 31, 2025 Name of Contact Person: Laura Moorehead, Vice President of Finance and Operations Management Response: Management concurs with the finding.

View Audit 376711

Finding 1165832 (2025-003)

Material Weakness 2025

Independent School District No. 361

MN

Questioned Costs Allowable Costs / Cost Principles Cash Management

Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics...

Recommendation: We recommend the District have someone reviewing all Clics reports before they are submitted. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The District will implement policies to ensure the Clics reports are reviewed before submission. Name of the contact person responsible for corrective action: Lauren Syrup, Business Manager Planned completion date for corrective action plan: June 30, 2026

View Audit 376704

Finding 1165812 (2025-001)

Material Weakness 2025

Mount David Housing, Inc.

ME

Questioned Costs Reporting Internal Control / Segregation of Duties

1. Finding 2025-001: a. We concur that material audit adjustments related to accounts receivable, revenue, prepaid assets, fixed assets, accounts payable and other current liabilities, and expenses were needed in order to present the financial statements in accordance with generally accepted account...

1. Finding 2025-001: a. We concur that material audit adjustments related to accounts receivable, revenue, prepaid assets, fixed assets, accounts payable and other current liabilities, and expenses were needed in order to present the financial statements in accordance with generally accepted accounting principles, and are in agreement with the recommendations to implement staff training on monthly and annual procedures over financial close and reporting. b. Action(s) Taken on the Finding: We have posted the adjustments recommended by the auditors. Management will conduct staff training on monthly and annual procedures over financial close and reporting by December 31, 2025.

View Audit 376677

Finding 1165810 (2025-003)

Material Weakness 2025

Baraga Area Schools

MI

Questioned Costs Allowable Costs / Cost Principles Procurement, Suspension & Debarment

2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant ...

2025-003 – UNALLOWABLE COSTS Corrective Action Plan: The School District staff has subsequently reviewed all reimbursements under the Fresh Fruits and Vegetables Program grant and has repaid the funds to the Michigan Department of Education in the amount of $2,178.68. In the future when a new grant is received, the School District will print the grant documents and review them with the necessary employees to ensure they are aware of the allowable and unallowable costs. Additionally, all invoices will be reviewed by the Food Service Director prior to being submitted to the business office for payment. Responsible Party(ies): • Food Service Head Cook Anticipated Completion Date: December 31, 2025

View Audit 376652

Finding 1165792 (2025-003)

Material Weakness 2025

DISCOVERY CENTER GREAT LAKES

MI

Allowable Costs / Cost Principles Questioned Costs

Management understands the deficiency in internal controls related to tracking of grant expenditures. The Center will develop a formal process for tracking grant expenditures by each individual grant.

View Audit 376589

Finding 1165758 (2025-001)

Material Weakness 2025

Southeastern Baptist Theological Seminary, Inc. and Subsidiary

NC

Student Financial Aid Questioned Costs Significant Deficiency

Return of Title IV (R2T4) Calculations Planned Corrective Action: SEBTS will take the following steps to address the failure to properly complete R2T4 calculations and returns: We will redefine an FI grade as “Failure due to inactivity” in the Faculty Handbook and Academic Catalog. Students will ear...

Return of Title IV (R2T4) Calculations Planned Corrective Action: SEBTS will take the following steps to address the failure to properly complete R2T4 calculations and returns: We will redefine an FI grade as “Failure due to inactivity” in the Faculty Handbook and Academic Catalog. Students will earn an FI if they fail the class due to lack of attendance or participation. The Provost will remind faculty during the final Faculty Meeting of each academic semester about the FI grade. The Registrar’s Office will send an email to all Faculty and Faculty Support Specialists during the last week of classes to remind faculty about assigning an FI to students who failed the course due to inactivity. The Instructional Design Office will inform Faculty Support Specialists about the FI grade during scheduled training meetings throughout the semester. The Adjunct Faculty Support Specialist will inform adjunct faculty during the final week of classes about the FI grade. The Registrar’s Office has updated Self Service, so faculty must enter the last date of attendance/participation if they enter an FI or F grade. The Registrar’s Office will use this to audit and only request further details from faculty who assign an F and indicate that a student stopped attending/participating before the end of the semester. The Learning Activity Report will be adjusted so Academic Advising can send a check-in email after 2 weeks of inactivity, a warning email after 3 weeks of inactivity, and the professor can assign an FI after 4 weeks of inactivity. Person Responsible for Corrective Action Plan: David Phillips, Director, Student Resources & Financial Aid Anticipated Date of Completion: 12/19/2025

View Audit 376551

Finding 1165757 (2025-001)

Material Weakness 2025

Cadillac Area Public Schools

MI

Subrecipient Monitoring Cash Management Reporting

This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not al...

This finding is due to the District not having the proper controls in place to prevent, detect, or correct an incorrect monthly meal claim. The month that had the incorrect meal claim used incomplete Z-Reports which resulted in the meal claim being submitted for less than it should have been. Not all dining locations had their final meal counts completed before the meal claim was submitted. The persons responsible for the corrective action are Aaron Burnett, the Food Service Director and Emily Kearney, the Business Manager. The anticipated completion date of the corrective action plan is immediate. The plan for monitoring adherence is the Food Service Director will ensure that all meal counts are final on the Z-Report before the claim requests are made.

View Audit 376550

Finding 1165725 (2025-006)

Material Weakness 2025

Iditarod Area School District

AK

Allowable Costs / Cost Principles Questioned Costs Significant Deficiency § 200.400

Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action form...

Finding 2025-006 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Activities Name of Contact Person: Tamara VanderPool, Payroll Director and Lisa Pearce, Business Manager Root Cause: **Insufficient staffing level. Inconsistent application of the personnel action forms and required documentation for changes to payroll details. Corrective Action Plan: • Clarify roles and responsibilities regarding payroll processing. • Establish a review process of all payroll transactions and documentation. Proposed Completion Date: Fall of 2025.

View Audit 376486

Finding 1165722 (2025-003)

Material Weakness 2025

Bethany Lutheran College, Inc.

MN

Subrecipient Monitoring Questioned Costs Significant Deficiency

Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Pr...

Finding 2025-003: GLBA Repeat Finding 2024-003 Federal Program - Student Financial Assistance Cluster Federal Agency- U.S. Department of Education Pass-Through Entity- Not Applicable Assistance Listing Number - 84.007 - Federal Supplemental Education Opportunity Grants 84.033 - Federal Work-Study Program 84.038 - Federal Perkins Loan Program 84.063 - Federal Pell Grant Program 84.268 - Federal Direct Student Loans Criteria: The Gramm-Leach-Bliley Act (GLBA) requires financial institutions to explain their informationsharing practices to their customers and to safeguard sensitive data (16 CFR 314). institutions are required to develop, implement, and maintain a comprehensive information security program that is written in one or more readily accessible parts. The regulations require the written information security program to include nine elements for institutions with 5,000 or more customers, (16 CFR 314.3(a)). The written information security program (WISP) for institutions with few that 5,000 customers must address seven elements (16 CFR 314.3(a) and 16 CFR 314.6). The elements that an institution must address in its written information security program are at 16 CFR 314.4. At a minimum, the institution's written information security program must address the implementation ofthe minimum safeguards identified in 16 CFR 314.4(c)(l) through (8) including: assess apps developed by the institution. In addition, the written security program provides for the institution to regularly test or otherwise monitor the effectiveness of the safeguards it has implemented (16CFR 314.4(d)). Condition/Context: Under a college's Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned Costs: Not applicable. Cause: There was not a formal process in place to review against all the new GLBA requirements to ensure compliance. Effect: The Corporation's students' personal information could be vulnerable. Recommendation: We recommend the Corporation review each element of GLBA to ensure compliance with all necessary requirements. Corrective Action Plan: Corrective Action Planned: To ensure continued GLBA compliance the Corporation contracted with FRSecure to develop a risk assessment and roadmap which did a system scan for issues, an assessor interviewed staff including IT, HR, Finance Leaders and others to learn more about the current state of overall security program. Compliance with GLBA was part of their review. FRSecure issued an assessment 'Roadmap Plan' for the department to review and the Corporation will implement the results as feasible. Name of the contact person responsible for corrective action: John Sehloff, Director of Information Technology Anticipated Completion Date: June 30, 2026

View Audit 376467

Finding 1165704 (2025-001)

Material Weakness 2025

Comstock Public Schools

MI

Eligibility Questioned Costs Allowable Costs / Cost Principles

Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to fede...

Condition: The School District charged an expenditure to the grant which was incurred in a school building that was not an eligible school building under the award. Planned Corrective Action: Associate Accountant will ensure the Assistant Superintendent’s signature is on all invoices charged to federal grants including the Regional Assistance Grant. The Finance Director will ensure this during the invoice approval process. Finance Director and Assistant Superintendent meet monthly to discuss federal grants which includes the Regional Assistance Grant. Part of this meeting is to discuss known expenditures for federal grants so far this year to ensure they are properly coded and expended. Finance Director will run a general ledger analysis every two months to compare posted grant expenditures to approved grant budgets. Expenditures in question will be discussed at monthly meetings. Any determined to be incorrect will be moved to non-grant accounts via journal entry most likely prepared by Finance Director and approved by Associate Accountant. Contact person responsible for corrective action: RJ Wiersema and Jill Ansel Anticipated Completion Date: 12/31/2025

View Audit 376434

Finding 1165691 (2025-004)

Material Weakness 2025

Priority Trust Credit Union

TX

Questioned Costs Reporting Significant Deficiency

Management agrees with the finding and will establish the recommended procedure outlined in the Schedule of Findings and Questioned Costs.

View Audit 376420

Finding 1165672 (2025-001)

Material Weakness 2025

Marshall Public Schools

MO

Cash Management Questioned Costs School Nutrition Programs

U.S. Department of Education Marshall Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Caleb Petet, Superintendent Marshall Public Schools Independent Public Accoun...

U.S. Department of Education Marshall Public Schools respectfully submits the following Corrective Action Plan for the year ended June 30, 2025. Contact information for the individual responsible for the corrective action: Caleb Petet, Superintendent Marshall Public Schools Independent Public Accounting Firm: Gerding, Korte & Chitwood, P.C., 723 Main Street, Boonville, MO 65233 Audit Period: Year ended June 30, 2025 The findings from the June 30, 2025, Schedule of Findings and Questioned Costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. Significant Deficiency 2025-001 Child Nutrition Cluster Recommendation: We recommend that fund balances should be monitored to ensure that balances remain in line with child nutrition compliance requirements.

View Audit 376342

Finding 1165672 (2025-001)

Material Weakness 2025

Marshall Public Schools

MO

Cash Management Questioned Costs School Nutrition Programs

The Marshall Public School District has been working to utilize excess food service funds in an appropriate and timely manner. Recently, these funds supported significant cooler and freezer replacements and repairs, including work already completed in the new kitchen at our Intermediate School. Addi...

The Marshall Public School District has been working to utilize excess food service funds in an appropriate and timely manner. Recently, these funds supported significant cooler and freezer replacements and repairs, including work already completed in the new kitchen at our Intermediate School. Additional units were repaired or replaced in the fall of 2025. The final remaining capital items include a newly purchased distribution vehicle for mobile meal delivery to sites without kitchens and distribution of commodities delivered to a central site. There will be an additional cooler to be acquired before the end of the 2025 fiscal year for our newly constructed distribution site, as well as other costs at that site for completion of the distribution facility. These purchases support operations in our new distribution building, where commodities are delivered, stored, and distributed from as needed throughout the year. Looking ahead, the district plans to replace movable supplies and equipment throughout the 2025–26 school year. Specifically, we are preparing to add new food service lines with additional points of sale to improve efficiency and decrease wait times, as well as purchase the associated POS licenses. We will also upgrade selected appliances and cabinetry to modernize and improve efficiency in kitchens located in older buildings around the district. In addition, as needed or upon request, we intend to provide further professional development opportunities for our food service staff. Collectively, these actions will ensure that no excess funds remain in the food service account by the end of the current fiscal year.

View Audit 376342

Corrective Action Plans

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