Corrective Action Plans

Finding 1156570 (2024-004)

Material Weakness 2024

NJ

HUD Housing Programs Questioned Costs Significant Deficiency

U.S. Department of Housing and Urban Development 2024-004 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Rent Reasonableness Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Explanation of disagreement with audit find...

U.S. Department of Housing and Urban Development 2024-004 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 – Rent Reasonableness Recommendation: We recommend the Authority implement controls to ensure reasonable rent requirements are met. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. Increased effort with quality control and staff training will be focused in this area to ensure the HUD-50058 and rent determinations match and are clear on the comparable units. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

View Audit 368905 Questioned Costs: $1

Finding 1156568 (2024-002)

Material Weakness 2024

Housing Authority of the City of Omaha

NJ

Questioned Costs HUD Housing Programs Special Tests & Provisions

U.S. Department of Housing and Urban Development 2024-002 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 - Eligibility Recommendation: We recommend the Authority: - Review and revise its eligibility determination procedures to ensure full compliance with HUD regulations. - Train ...

U.S. Department of Housing and Urban Development 2024-002 Housing Voucher Cluster – Assistance Listing No. 14.871 and 14.879 - Eligibility Recommendation: We recommend the Authority: - Review and revise its eligibility determination procedures to ensure full compliance with HUD regulations. - Train staff on proper documentation and verification protocols for tenant income, assets, expenses and overall eligibility. - Conduct a file audit to identify and correct any improperly admitted tenants. - Update its Administrative Plan to reflect accurate eligibility screening procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority will increase oversight in the Section 8 Housing Choice Voucher program to ensure that established internal control policies are being followed. Additional Quality Control personnel have been added in 2025 to review files and confirm calculations. Electronic workflow processes are also being implemented to track regulatory compliance and flag files when not all required processes are completed. Name(s) of the contact person(s) responsible for corrective action: Philisa Smith, HCV Director Planned completion date for corrective action plan: December 31, 2026

View Audit 368905 Questioned Costs: $1

Finding 1156545 (2024-003)

Material Weakness 2024

County of Mifflin

PA

Questioned Costs Reporting Internal Control / Segregation of Duties

Finding 2024-003: Emergency Rental Assistance Program (ERAP). Contact Person: Duane K. McMullen Jr., Director of Fiscal Affairs. Recommendation: The County should establish internal controls procedures over reporting requirements. Response: The County agrees with the finding and will work with the H...

Finding 2024-003: Emergency Rental Assistance Program (ERAP). Contact Person: Duane K. McMullen Jr., Director of Fiscal Affairs. Recommendation: The County should establish internal controls procedures over reporting requirements. Response: The County agrees with the finding and will work with the Human Services Director and Human Services Financial Manager to revise and, where necessary, establish procedures to ensure proper approval by all required parties prior to submission of said reports. Action Planned: Post-audit submission, the County Director of Fiscal Affairs will meet and discuss with the Human Services Director and Human Services Financial Manager all upcoming reporting requirement, and implement reporting procedures that require multiple signatures and approvals, including those required under the reporting guidelines and requirements, and the initials of the County Director of Fiscal Affairs, prior to submission of the subject reports. Date for Completion: December 31, 2025.

View Audit 368886

Finding 1156543 (2024-002)

Material Weakness 2024

Samaritas and Subsidiaries

MI

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

Contact Person(s): Bridgette Zappacosta Corrective Action Planned: Management concurs with the finding. The Organization will strengthen eligibility verification procedures to ensure that only participants meeting the specific award requirements are approved for benefits. This will include: revising...

Contact Person(s): Bridgette Zappacosta Corrective Action Planned: Management concurs with the finding. The Organization will strengthen eligibility verification procedures to ensure that only participants meeting the specific award requirements are approved for benefits. This will include: revising intake and eligibility documentation protocols to require verification and supervisory sign-off that the individual meets the award’s eligibility definition and providing targeted staff training on eligibility requirements under the Refugee Admissions Program. Quarterly internal reviews of eligibility determinations will be conducted, with exceptions reported to management for corrective action. Anticipated Completion Date: December 31, 2025

View Audit 368884 Questioned Costs: $1

Finding 1156539 (2024-001)

Material Weakness 2024

Samaritas and Subsidiaries

MI

Allowable Costs / Cost Principles Period of Performance Questioned Costs

Contact Person(s): Bridgette Zappacosta, CFO Corrective Action Planned: Management concurs with the finding. We acknowledge that expenditures were charged outside of the applicable award period due to timing of invoice receipt and data entry errors. The Organization has reviewed its internal control...

Contact Person(s): Bridgette Zappacosta, CFO Corrective Action Planned: Management concurs with the finding. We acknowledge that expenditures were charged outside of the applicable award period due to timing of invoice receipt and data entry errors. The Organization has reviewed its internal controls and will strengthen procedures to ensure compliance with federal requirements. Specifically, we are revising our grant expenditure procedures, implementing new software which includes additional review controls and is specific to grant reporting, and providing targeted staff training on period of performance compliance. We will also perform quarterly monitoring of federal award expenditures to verify compliance. Anticipated Completion Date: December 31, 2025

View Audit 368884 Questioned Costs: $1

Finding 1156532 (2024-002)

Material Weakness 2024

Cornerstones Inc, Cornerstones Housing Corporation & Rihc Partners, Lp

VA

Questioned Costs Internal Control / Segregation of Duties § 200.303 § 200.334

Management agrees with the recommendation and will implement stronger review processes to ensure proper documentation is in place to support program activities and reports submitted to the grantor. All staff charged with maintaining client documentation will receive updated training on recordkeeping...

Management agrees with the recommendation and will implement stronger review processes to ensure proper documentation is in place to support program activities and reports submitted to the grantor. All staff charged with maintaining client documentation will receive updated training on recordkeeping requirements, supporting documents specifying such requirements, and supports throughout the year to ensure documents are properly maintained and verified. Documents will be reviewed regularly for completeness and specifically cross-checked with quarterly report and invoice information directly by program leadership prior to submission. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.

View Audit 368880 Questioned Costs: $1

Finding 1156531 (2024-001)

Material Weakness 2024

Cornerstones Inc, Cornerstones Housing Corporation & Rihc Partners, Lp

VA

Questioned Costs Eligibility Internal Control / Segregation of Duties § 200.303 § 200.334

anagement agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. All program staff will receive updated training on eligibility requirements, supporting documents to track su...

anagement agrees with the recommendation and will implement stronger processes to ensure that records confirming the eligibility of program participants are obtained and properly maintained. All program staff will receive updated training on eligibility requirements, supporting documents to track such requirements, and supports throughout the year to ensure eligibility requirements are met and documented. Documents will also be reviewed regularly to ensure completeness against eligibility requirements. This process will be led by the Vice President of Family Empowerment and Self Sufficiency with support from operational and compliance staff.

View Audit 368880

Finding 1156516 (2024-002)

Material Weakness 2024

Kama'aina Care, Inc.

HI

Questioned Costs Subrecipient Monitoring Reporting § 200.329

Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.

View Audit 368868

Finding 1156514 (2024-002)

Material Weakness 2024

Texas Biomedical Research Institute

TX

Questioned Costs Procurement, Suspension & Debarment § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texa...

Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Additionally, Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Three of the four procurements noted as findings were, in fact, sole source procurements but lacked timely documentation of sole source rationale. Corrective Action Plan: Texas Biomed made a change in management over the procurement function and hired an experienced and knowledgeable Assistant Director of Supply Chain Management on September 15, 2025 to oversee procurement and ensure compliance with the necessary requirements. To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed will introduce a Purchasing Compliance Program. This program will include training and oversight procedures for the purchasing program. The training will include: new hire training, ongoing quarterly purchasing training for end users and purchasing staff. The purchasing team will maintain training documents and ensure new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures will be performed by the Assistant Director of Supply Chain Management and shall include auditing purchase orders over the micro-purchase threshold to ensure proper documentation is present. The Assistant Director of Supply Chain Management will also lead efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training October 2025 • Quarterly training session January 2026 • Oversight procedures developed November 2025 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: October 31, 2025

View Audit 368866 Questioned Costs: $1

Finding 1156504 (2024-001)

Material Weakness 2024

Romulus Housing Commission

MI

Questioned Costs Subrecipient Monitoring Eligibility

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

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

View Audit 368862 Questioned Costs: $1

Finding 1156495 (2024-001)

Material Weakness 2024

Serve Wyoming, Inc.

WY

Questioned Costs

Implemented corrective actions and updated internal procedures, as outlined in the financial management section of the handbook. Staff have received additional training on proper disbursement procedures, coaching and monitoring. In addition, a full review of all checks for FY25 have been completed a...

Implemented corrective actions and updated internal procedures, as outlined in the financial management section of the handbook. Staff have received additional training on proper disbursement procedures, coaching and monitoring. In addition, a full review of all checks for FY25 have been completed and noted. Going forward, checks will be prepared and submitted to the Executive Director in two expense batches prior to processing by the indepdendent bookkeeper. An additional control step has also been added to the Executive Director's review, requiring the indvidual mailing the checks to verify the presence of two signatures.

View Audit 368857 Questioned Costs: $1

Finding 1156488 (2024-002)

Material Weakness 2024

Transform 1012 N. Main Street

TX

Questioned Costs Reporting Significant Deficiency

2. In response to Finding 2024-002: Reporting – significant deficiency in internal controls over compliance Economic Development Initiative, Community Project Funding and Miscellaneous grants, please note the following: Cause of Internal Control Issue: Transform 1012’s grant reporting procedures inc...

2. In response to Finding 2024-002: Reporting – significant deficiency in internal controls over compliance Economic Development Initiative, Community Project Funding and Miscellaneous grants, please note the following: Cause of Internal Control Issue: Transform 1012’s grant reporting procedures included a verbal approval of reports and therefore, management approval could not be confirmed or reperformed. The effect of this is that bi-annual reporting was not fully documented in accordance with internal control procedures over compliance. Actions To Rectify Internal Control Issue: Management’s Response: Carlos Gonzalez-Jaime, Executive Director, will ensure his written documentation of review and approval of all grant reports is kept on file by using electronic signature to indicate review and approval and storing signed copies of the documentation. • This will be completed by October 31, 2025, for 2025 reports through October 31, 2025. Going forward, signed documentation will be stored within seven days of the report being issued.

View Audit 368849

Finding 1156484 (2024-001)

Material Weakness 2024

Northwest Youth Services

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

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

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

View Audit 368841 Questioned Costs: $1

Finding 1156482 (2024-007)

Material Weakness 2024

Mission Edge San Diego

CA

Allowable Costs / Cost Principles Questioned Costs

Condition Found During allowable cost testing, we noted that there was a lack of internal control over allowable costs. We noted items that did not include proper support, were outside the contract period, or were for the incorrect amount. Corrective Action Plan Continue to verify for every federal ...

Condition Found During allowable cost testing, we noted that there was a lack of internal control over allowable costs. We noted items that did not include proper support, were outside the contract period, or were for the incorrect amount. Corrective Action Plan Continue to verify for every federal charge: allowability, allocability, reasonableness, consistent treatment, and compliance with period of performance. Require source documentation supporting the nature, amount, and purpose. Responsible Person for Corrective Action Plan The Controller for Mission Edge San Diego and Accounting personnel. Implementation of Corrective Action Plan Policy adoption within 30 days of report. Management’s Statement of Concurrence Mission Edge concurs with the findings and has initiated the corrective actions described herein. Management is committed to timely implementation, continuous monitoring, and transparent communication with the pass-through entity, federal agencies, and auditors as required.

View Audit 368823

Finding 1156481 (2024-006)

Material Weakness 2024

Mission Edge San Diego

CA

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

Condition Found During allowable cost testing, it was noted that one of the contracts with the vendors included a rate that exceeded the rate cap without prior approval. Upon inquiry no prior approval was obtained. Corrective Action Plan Before execution, route all vendor and subrecipient agreements...

Condition Found During allowable cost testing, it was noted that one of the contracts with the vendors included a rate that exceeded the rate cap without prior approval. Upon inquiry no prior approval was obtained. Corrective Action Plan Before execution, route all vendor and subrecipient agreements funded by federal awards to Controller/Accounting for verification of allowability, rate caps, prior approvals, and special terms. Additional review during the A/P process ensures compliance. Responsible Person for Corrective Action Plan The Controller for Mission Edge San Diego and Accounting personnel. Implementation of Corrective Action Plan Policy adoption within 30 days of report.

View Audit 368823 Questioned Costs: $1

Finding 1156480 (2024-005)

Material Weakness 2024

Mission Edge San Diego

CA

Questioned Costs Procurement, Suspension & Debarment

During procurement testing, it was noted that Mission Edge did not follow 2 CFR 200 required methods of procurement or its internal procurement policy for the purchase of goods or services using federal funds. Mission Edge did not obtain quotes or bids for certain expenditures as required by its pro...

During procurement testing, it was noted that Mission Edge did not follow 2 CFR 200 required methods of procurement or its internal procurement policy for the purchase of goods or services using federal funds. Mission Edge did not obtain quotes or bids for certain expenditures as required by its procurement policy. In addition, Mission Edge did not verify that vendors were not suspended, debarred, or otherwise excluded from participation in the program. Corrective Action Plan Review and confirm that each Project has Adopted a Uniform Procurement Policy. This policy will address: 1. Micro-purchases, small purchases, sealed bids, competitive proposals, noncompetitive proposals thresholds and methods. 2. Cost/price analysis for procurements above the Simplified Acquisition Threshold. 3. Ensure consistent applicability to fiscally sponsored projects. 4. Mandatory Debarment/Suspension Checks utilizing SAM.gov for all covered transactions and attached required verification to covered transactions. Responsible Person for Corrective Action Plan The Controller of Mission Edge San Diego (policy owner); Project Directors as applicable. Implementation of Corrective Action Plan Policy adoption within 30 days of report.

View Audit 368823 Questioned Costs: $1

Finding 1156477 (2024-002)

Material Weakness 2024

Lifewire

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Questioned Costs § 200.303 § 200.430

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underly...

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underlying the attestations were erroneous. In addition, LifeWire was not able to secure an attestation from a former employee before they departed the organization. In 2025, LifeWire is revising their attestation procedure such that contract-supported staff members will attest to the nature of their work instead of amounts of time to contracts. This will simplify the administrative burden of attestations and reduce opportunities for errors while still meeting our audit and contract funders’ requirements. We anticipate this revised method will be rolled out by the end of Q3-2025. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: Procedure rollout will be completed by the end of Q3-2025. Anticipated full compliance with the requirement will be in evidence through the end of 2025 and beyond.

View Audit 368819

Finding 1156471 (2024-001)

Material Weakness 2024

Emergency Food Network of Tacoma and Pierce County

WA

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

U.S. Department of Agriculture Food Distribution Cluster - The Emergency Food Assistance Program - Assistance Listing No. 10.565, 10.568, 10.569 Recommendation: We recommend that EFN incorporate a system of internal controls that clearly documents the time and effort that each individual employee sp...

U.S. Department of Agriculture Food Distribution Cluster - The Emergency Food Assistance Program - Assistance Listing No. 10.565, 10.568, 10.569 Recommendation: We recommend that EFN incorporate a system of internal controls that clearly documents the time and effort that each individual employee spends on each grant per month. This can be done by tracking and recording the actual hours each employee, regardless of position, spends working on each grant, on their time sheet or with a specific grant code, that specifies how many hours per day were spent on each federal and nonfederal activity. Alternatively, EFN can implement an after-the-fact review procedure to ensure the proper allocation of payroll expenditures to Federal and non-Federal awards, in accordance with 2 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Emergency Food Network (EFN) engaged a new audit firm for the 2024 audit. Before this year the EFN audit was administered by Johnson, Stone Pagano for 9 years. No deficiencies were previously reported or identified during those audits regarding time estimates for employees used for allocations including most of those specifically identified funding sources. In response to the 2024 audit finding by Clifton Larson Allen (CLA) in July of 2025, when the audit was conducted, EFN implemented an immediate individual employee time study that was approved by CLA to meet the recommendation. This time study methodology will be implemented twice per year on an ongoing basis with records retained and available for future audit verification. EFN has received written response from CLA that implementing this method meets all the requested requirements to be in compliance and mitigate future findings on this issue. Name of the contact person responsible for corrective action: Michelle Douglas, CEO Planned completion date for corrective action plan: August 2025 If anyone has questions regarding this plan, please call Michelle Douglas, CEO, at 253-208- 2962.

View Audit 368815 Questioned Costs: $1

Finding 1156466 (2024-001)

Material Weakness 2024

Council Towers Housing Development Fund Corporation

NY

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring

We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.

View Audit 368800 Questioned Costs: $1

Finding 1156461 (2024-001)

Material Weakness 2024

Homeless No More, Inc. 122-Hd085-Wdd-Np

CA

Questioned Costs HUD Housing Programs Reporting

Department of Housing and Urban Development Homeless No More, Inc., HUD Project No. 122-HD085-WDD-NP, respectfully submits the following Corrective Action Plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Suchan & Associates, An Accountancy Corporatio...

Department of Housing and Urban Development Homeless No More, Inc., HUD Project No. 122-HD085-WDD-NP, respectfully submits the following Corrective Action Plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Suchan & Associates, An Accountancy Corporation, 8588 Utica Ave. Suite 100, Rancho Cucamonga, California 91730. Audit Period: January 1, 2024 through December 31, 2024 The finding from the 2024 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. Section A of the Schedule, Summary of Audit Results does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENTS AUDIT None FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING NO. 2024-001 Section 811 (Capital Advance Loan), AL No. 14.181 Recommendation: The Project should fund the replacement reserves shortage as soon as possible and make the required monthly deposits in accordance with the regulatory agreement. Action Taken: As of the current date the delinquent deposits have not been brought up to date due to ongoing cash flow issues. The Project is negotiating for a rent increase and is in the process of renewing its contract with HUD. Once both the rent increase and contract renewal are approved the replacement reserve account will be funded as soon as the HUD assistance payments are received. If you have any questions regarding the plan, please call Dan O’Brien, Treasurer (213) 251-3410. Sincerely, Dan O’Brien Treasurer

View Audit 368785

Finding 1156459 (2024-002)

Material Weakness 2024

Southwestern Christian College

TX

Reporting Questioned Costs Significant Deficiency § 200.328 § 200.329

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the...

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the required reports from the ESF Data Collection System by the suggested deadline of May 19, 2025. Corrective Actions (overseen by the President): 1. Grant Reporting Calendar o A compliance calendar with all DOE reporting deadlines was created in August 2025. o Internal deadlines are set two weeks before federal due dates. o Responsible Official: Director of Grants 2. Dual Review & Submission Tracking o All grant quarterly and annual reports must be reviewed and signed off by the Director of Grants, President, and Comptroller before submission. o Submission confirmations will be saved in the respective grants folder of the electronic filing system. o Responsible Officials: President, Director of Grants & Comptroller 3. Centralized Filing & Audit Readiness o Grant reports (quarterly, annual, and related correspondence) will be stored in the centralized electronic filing system for continuity and audit review. o Responsible Officials: Director of Grants & Business Office 4. Quarterly Compliance Checks o The President and Director of Grants will conduct quarterly compliance reviews to confirm all required reports are submitted timely. o Responsible Officials: President & Director of Grants 5. Time and Effort Reporting in Populi o Effective August 2025, time and effort reporting for all Title IV-funded student workers and grant-funded employees will be completed in Populi, capturing descriptions of duties and percentage of time worked, aligned with payroll and funding sources. o Responsible Officials: Director of Grants & Comptroller/Business Office Completion Date: Reporting calendar implemented August 2025; all future reports will be submitted timely under this protocol. Southwestern Christian College is committed to full compliance with federal regulations and the highest standards of financial accountability. The corrective actions outlined above address both Title IV and HEERF audit findings with immediate steps, ongoing monitoring, and strengthened internal controls. With the implementation of new reconciliation processes, expanded staffing in the Business Office, centralized electronic filing, enhanced verification and reporting protocols, and a structured compliance calendar, SwCC has established sustainable safeguards to prevent recurrence of deficiencies.

View Audit 368771 Questioned Costs: $1

Finding 1156458 (2024-001)

Material Weakness 2024

Southwestern Christian College

TX

Questioned Costs Student Financial Aid

Finding 2024-001: U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiency): Condition (per audit): Non-compliance with Title IV requirements, including missing reconciliations, inaccurate/untimely NSLDS reporting, incomplete Work-Study files, missing refu...

Finding 2024-001: U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiency): Condition (per audit): Non-compliance with Title IV requirements, including missing reconciliations, inaccurate/untimely NSLDS reporting, incomplete Work-Study files, missing refund documentation, incomplete FAFSA verification records, and unavailable FISAP reconciliation documentation. Questioned Costs: $29,087 Corrective Actions (overseen by the President): 1. Monthly Title IV Reconciliations o Beginning August 2025, monthly reconciliations between the Business Office and Financial Aid Office will be conducted and logged in the new centralized electronic filing system in Populi for audit readiness and continuity during staff transitions. o To further strengthen the process, two additional staff members, a new Accounts Payable Manager and Comptroller, with extensive audit and business office management and grants management/reconciliation experience, and has been added to the Business Office. o Reconciliation logs will be retained in the centralized electronic filing system in Populi. o Responsible Official: Comptroller/ Business Office Staff 2. Electronic Filing System o To address missing FISAP, refund, and Work-Study documentation, SwCC implemented an organized electronic filing system in Populi by funding stream, year, and document type. o Includes FISAP, Work-Study timesheets, NSLDS reports, and refund documentation. o Responsible Official: Financial Aid Director and Business Office. 3. Enrollment Reporting to NSLDS o To address untimely/incorrect reporting, weekly enrollment status reports will be submitted through Populi and verified with the Registrar. o SwCC is finalizing its agreement with the National Student Clearinghouse to further improve accuracy. o Responsible Official: Registrar. 4. Work-Study Documentation o To address missing student files, all Work-Study records (award letters, timesheets, disbursement records) will be scanned and retained in each student’s electronic file. o Responsible Official: Financial Aid Director. 5. Refund Documentation o To address missing refund testing documentation, all refund calculations will be cross-verified by the Business Office and Financial Aid Office, and approved by the President before posting. o Records will be stored in the filing system. o Responsible Official: Comptroller/ Business Office and Financial Aid Office 6. FAFSA Verification o To address incomplete verification documentation, SwCC uses a standardized verification checklist. The Populi system does not allow disbursement of student files selected for verification. A manual override is required, and these overrides will continue to be managed within the Office of Financial Aid for disbursement. o Responsible Official: Financial Aid Director. 7. FISAP Retention o To address unavailable FISAP records, annual FISAP submissions will be stored in the electronic filing system for future testing and audit review. o Responsible Official: Comptroller/ Business Office and Financial Aid Office Completion Date: Initial corrective actions completed by August 31, 2025. Ongoing monitoring monthly/quarterly as required.

View Audit 368771 Questioned Costs: $1

Finding 1156452 (2024-001)

Material Weakness 2024

Unleashing Potential

MO

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.430

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

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

View Audit 368766

Finding 1156451 (2024-001)

Material Weakness 2024

Illinois Network of Charter Schools

IL

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member ...

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member - the CSP Grant Manager - to oversee FFATA reporting and maintain a comprehensive log of all qualifying subawards. The CSP Grant Manager will provide training to finance and grants management staff on FFATA reporting requirements and timelines. Joyanna Smith, CPOO, will conduct monthly reviews of subaward activity to ensure all required reporting is completed by the end of the month following the obligation date. FFATA reporting will be incorporated into INCS’s quarterly internal compliance monitoring process to sustain ongoing compliance.

View Audit 368752

Finding 1156450 (2024-002)

Material Weakness 2024

Lincoln Senior Housing, INC

CT

Questioned Costs HUD Housing Programs Cash Management

Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request ...

Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request a waiver if allowed. Views of Responsible Officials and Planned Corrective Actions – Management will calculate an estimated surplus cash calculation amount and deposit them into the residual receipts account within the required time frame. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – Once the funds are received.

View Audit 368750 Questioned Costs: $1

Corrective Action Plans

Filters