Corrective Action Plans

Finding 1182831 (2025-012)

Material Weakness 2025

State of Vermont

VT

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Questioned Costs § 200.303

Reference Number: 2025-012 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Public Service Department Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/202...

Reference Number: 2025-012 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Public Service Department Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/2022 – 12/31/2026) Compliance Requirement: Reporting – Performance Reports Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Department and the Agency review their respective procedures and internal controls to ensure that Quarterly Performance Reports are accurate, are supported by documentation, and that supporting documentation is maintained and is readily available for audit. Views of responsible officials: Management agrees with the finding. Corrective Action Plan The Department of Public Service, the Department of Libraries, and the Department of Forests, Parks, and Recreation will hold a monthly coordination meeting to review program updates, monthly expenditures, reporting processes, and other matters. Notes will be sent out from the monthly meetings within 5 business days. The Department of Public Service will create a review process to be managed by the Financial Director IV. This process will ensure sign-off before reporting is certified and Treasury draws are performed. Scheduled Completion Date of Corrective Action Plan: Monthly Meeting Series Established – 04/15/2026 Full Review process in place – 7/31/2026 Contacts for Corrective Action Plan: Doug Farnham, Vermont State Recovery Office, douglas.farnham@vermont.gov Brittney Wilson, Department of Public Service, brittney.wilson@vermont.gov

View Audit 394235

Finding 1182830 (2025-011)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Reference Number: 2025-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 ...

Reference Number: 2025-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 (4/29/2022 – 4/29/2032) CA0751 (5/1/2023 – 10/1/2028) CA0906 (1/24/2025 – 11/1/2030) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Agency review its procedures and internal controls to ensure that subawards are reported timely and accurately to SAM.gov in no later than the end of the month following the month of issuance or modification. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: VTrans will update procedures to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. As part of this update, the Agency will review the current reporting workflow and clearly define roles, responsibilities, and timelines for FFATA reporting. The updated procedure will include guidance for identifying reportable sub-awards, collecting required data elements, and entering information into the appropriate federal reporting system within the required timeframe. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Diane Bigglestone, Financial Director, diane.bigglestone@vermont.gov

View Audit 394235

Finding 1182828 (2025-009)

Material Weakness 2025

State of Vermont

VT

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

Reference Number: 2025-009 Prior Year Finding: 2024-009; 2023-007 and 2022-016 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) ...

Reference Number: 2025-009 Prior Year Finding: 2024-009; 2023-007 and 2022-016 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) UI370952155A50 (9/1/2021 – 5/22/2025) 23A60UB000019 (8/3/2023 – 5/22/2025) 24A60UD000052 (8/20/2024 – 8/20/2027) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the Department review and enhance its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department has reviewed its procedures and internal controls, and we believe that they adequately require oversight and signoff of all expenditures to ensure that expenditures are adequately reviewed and signed off on. However, there is currently no double check to ensure that the accounting clerks are following these procedures. Department will be adding a secondary check to the procedure to occur at the end of each month to review expenditures for proper coding (cost center, project code and function code) as well as responsible party signoff. Scheduled Completion Date of Corrective Action Plan: May15, 2026 Contacts for Corrective Action Plan: Kristine Murphy, Director, Unemployment Insurance, kristine.murphy@vermont.gov Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182827 (2025-008)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Special Tests & Provisions Eligibility § 200.303

Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2...

Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2025) 24A60UR000093 (1/1/2024 – 9/30/2026) Compliance Requirement: Special Tests and Provisions: UI Reemployment Programs: RESEA Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Department should update its internal controls to ensure that RESEA procedures are followed, that cases are properly documented and appropriate actions are taken when participants fail to meet program requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: In September of 2025, the RESEA program in Vermont was transitioned from the VDOL Unemployment Insurance division to the VDOL Workforce Development division. This transition included a change of supervision for the RESEA Facilitators from a centralized supervisor to supervision by the VDOL American Job Center Regional Managers. Training was provided to these Regional Job Center Managers to help them to support their new RESEA staff. The RESEA Program Administrator will meet with the specific RESEA Facilitator, and the Regional Manager associated with these cases to provide additional technical assistance. This will include on-site visits and virtual follow-up meetings. Additionally, the RESEA Program Administrator is reviewing the current program monitoring plan and will be making some changes to include a quarterly case monitoring requirement for the regional managers in addition to the current monthly Peer Review monitoring. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Jay Ramsey, Director, Workforce Development, jay.ramsey@vermont.gov

View Audit 394235

Finding 1182826 (2025-007)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.308 § 200.309 § 200.403

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027)...

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that, prior to charging costs to the program, they are incurred within an award’s allowable period of performance and that payments are reviewed and approved by a supervisor who has knowledge of costs that are allowable under the program. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department will review its procedures and internal controls and update as necessary to ensure that all expenditures incurred on an award fall within the allowable period of performance. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182825 (2025-006)

Material Weakness 2025

State of Vermont

VT

Internal Control / Segregation of Duties Questioned Costs Material Weakness § 200.303

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A5...

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A55UI000063 (10/1/2023 – 12/31/2026) UI370952155A50 (9/1/2021 – 5/22/2025) 23A60UB000019 (8/3/2023 – 5/22/2025) 23A60UB000024 (4/1/2023 – 5/22/2025) 24A60UD000052 (8/20/2024 – 8/20/2027) UI347462055A50 (8/20/2024 – 8/20/2027) 23A60UD000013 (7/14/2023 – 7/14/2026) 25A60UD000067 (10/1/2024 – 9/30/2027) Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: We recommend that policies and procedures be implemented to ensure that all reports are reviewed by an authorized State official prior to submission and that supporting documentation providing evidence of supervisory review is maintained and available for audit. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: These reports are filed by our Labor Market Information division on behalf of the UI Division. The LMI employee responsible for these reports takes the data from a server/system generated report and enters it into a federal reporting system. Department will review internal controls and update as necessary to ensure that all required reports are filed timely and accurately and that reports are reviewed and approved by authorized State officials prior to submission. From now on the employee responsible for these reports will have their immediate supervisor review both reports to certify and signoff that the submitted report matches the system generated report and that they were submitted timely. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Kristine Murphy, Director, Unemployment Insurance, kristin.murphy@vermont.gov Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182824 (2025-005)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Nu...

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Award Number and Year: B-20-RH-50-0001 (1/17/2022 - 2/1/2029) B-22-RH-50-0001 (3/27/2023 - 9/1/2029) B-23-RH-50-0001 (7/1/2023 - 9/1/2030) B-22-DC-50-0001 (7/1/2022 - 9/1/2029) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: We have developed specific fields in the online grants management system, GEARS to manage the process of input into SAM.GOV of grant agreements and amendments by the execution date. In addition, the SAM.GOV system clearly identifies the “Subaward Date” stating “enter the date you have signed the subaward.” Staff have been trained appropriately on both GEARS and SAM.GOV to ensure the correct Subaward Date is entered. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Ann Karlene Kroll, DHCD Federal Programs Director, annkarlene.kroll@vermont.gov

View Audit 394235

Finding 1182823 (2025-004)

Material Weakness 2025

State of Vermont

VT

Eligibility Reporting Questioned Costs § 200.303

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2...

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2026) 4VT437533 (10/1/2023 – 9/30/2025) Compliance Requirement: Special Tests and Provisions – ADP System for SNAP Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that eligibility case reviews are performed timely, accurately, and are properly documented. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: A majority of the findings from the 2025 audit predate the completion of corrective actions associated with Audit 2024-004. Because the corrective action completion date was April 18, 2025, these issues resulted in repeat findings related to supervisory case reviews. To address this, the 3SquaresVT Food and Nutrition Team will review the findings with ESD Operations and present examples, along with refresher training on the Supervisor Case Review (SCR) process, at the District Directors Meeting on February 11, 2026. In addition, a new column will be added to the SCR tracking spreadsheet to allow supervisors to document the date corrective actions were completed when revisions are required following a review. The refresher training and the updated SCR tracking spreadsheet are expected to prevent the recurrence of these findings during the 2026 Single Audit. Scheduled Completion Date of Corrective Action Plan: February 11, 2026 Contacts for Corrective Action Plan: Jessica Duranleau, ESD Program Manager, jessica.duranleau@vermont.gov Leslie Wisdom, Food and Nutrition Program Director, leslie.wisdom@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

View Audit 394235

Finding 1182821 (2025-003)

Material Weakness 2025

State of Vermont

VT

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1...

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1015 (9/30/2022 – 9/29/2025), AM21DBIVT1011 (9/30/2022 – 9/29/2026), Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency complete implementation of its corrective action plan from the prior year. It should review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported timely to SAM.gov in accordance with FFATA requirements and that all previously issued subawards are reported. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The business office will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “FFATA reportable” upon grant execution in the Agency’s grants and contracts workbook. The Financial Directors will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the appropriate Federal system by the last business day of each month. Scheduled Completion Date of Corrective Action Plan: 4/30/26 Contacts for Corrective Action Plan: Amy Mercier, Financial Director, amy.mercier@vermont.gov Karen Mae Smith, Financial Director, karenmae.smith@vermont.gov

View Audit 394235

Finding 1182820 (2025-002)

Material Weakness 2025

Lehigh University

PA

Special Tests & Provisions Questioned Costs Student Financial Aid

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the...

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.

View Audit 394233

Finding 1182817 (2025-007)

Material Weakness 2025

Circle of Nations School INC

ND

Allowable Costs / Cost Principles Questioned Costs § 200.430

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identifie...

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identified an expenditure where payroll benefits were not paid in accordance with the employment letter. Responsible Individuals: Trevor Gourneau, Superintendent Corrective Action Plan: The School will review internal controls surrounding allowable costs and activities to exsure they are adequate to identify unallowable expenditures. Anticipated Completion Date: June 30, 2026

View Audit 394228

Finding 1182816 (2025-002)

Material Weakness 2025

Southwestern Oregon Community College

OR

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. E...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional staff member will review COD reports before they are submitted via EdConnect. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: April 2026

View Audit 394224

Finding 1182803 (2025-003)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

HUD Housing Programs Internal Control / Segregation of Duties Questioned Costs

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance,...

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance, including improvements to supervisory oversight, tenant file documentation practices, and monitoring procedures to ensure that required certifications, inspections, and voucher submissions are completed accurately, timely, and in accordance with HUD regulations. Action Taken: Rogers Senior has hired a new apartment manager and regional property manager with significant HUD program experience. The new regional property manager is now providing enhanced oversight, including regular review of tenant files, recertification documentation, and HUD voucher submissions to ensure that all required activities are completed timely, accurately, and in accordance with HUD regulations. Management will continue to monitor compliance and strengthen internal processes to prevent recurrence of these issues. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394204

Finding 1182799 (2025-002)

Material Weakness 2025

Loretto Apts at O'Brien Road Hdfc, Inc. (o'brien Rd SR Appts 2)

NY

HUD Housing Programs Questioned Costs

Finding 2025-002: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 (Continued) Recommendation: Our auditor’s recommended that we ensure sufficient operating cash flow to make all required reserve for replacement deposits in the future. Views of management an...

Finding 2025-002: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 (Continued) Recommendation: Our auditor’s recommended that we ensure sufficient operating cash flow to make all required reserve for replacement deposits in the future. Views of management and planned corrective action: Management concurs. The December payment was made on January 9, 2026. Action Taken: The December payment was made on January 9, 2026. Completion Date: January 9, 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821

View Audit 394200

Finding 1182795 (2025-002)

Material Weakness 2025

St. Peter's Italian Church Housing Development Fund Co., Inc.

NY

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Finding 2025-001: U.S. Department of Housing and Urban Development - Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 See Findings – Financial Statement Audit Finding 2025-002: U.S. Department of Housing and Urban D...

Finding 2025-001: U.S. Department of Housing and Urban Development - Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 See Findings – Financial Statement Audit Finding 2025-002: U.S. Department of Housing and Urban Development - Program: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Villa Scalabrini strengthen its overall internal controls surrounding HUD program compliance, including improvements to supervisory oversight, tenant file documentation practices, and monitoring procedures to ensure that required certifications, inspections, and voucher submissions are completed accurately, timely, and in accordance with HUD regulations. Action Taken: Villa Scalabrini has hired a new apartment manager and regional property manager with significant HUD program experience. The new regional property manager is now providing enhanced oversight, including regular review of tenant files, recertification documentation, and HUD voucher submissions to ensure that all required activities are completed timely, accurately, and in accordance with HUD regulations. Management will continue to monitor compliance and strengthen internal processes to prevent recurrence of these issues. Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821. Anticipated Completion Date: March 2026

View Audit 394197

Finding 1182789 (2025-001)

Material Weakness 2025

Hanac, Inc. and Affiliates

NY

Eligibility HUD Housing Programs Questioned Costs

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2025. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 The finding from the June 30, 2025...

CORRECTIVE ACTION PLAN YEAR ENDED JUNE 30, 2025 HANAC, Inc. and Affiliates (HANAC) respectfully submits the following corrective action plan for the year ended June 30, 2025. CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 The finding from the June 30, 2025 consolidated and combined schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None reported. FINDINGS – FEDERAL AWARD PROGRAMS AUDITS Material Weakness FINDING 2025-001 Eligibility U.S. Department of Housing and Urban Development 14.157 Supportive Housing for the Elderly Section 202 Loan Condition: During our testing, we noted that the income verification of tenant eligibility through Enterprise Income Verification (“EIV”) system was not performed timely. Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: Management agrees with the recommendation and has begun to implement the following: • A checklist form will be completed for every certification and signed off once file is approved. • An AR form will be created for the move in, transfer and move out process which is to be attached with proof of payment. Once completed it is to be sent to senior staff for review. • The file setup format and recertification updates will be monitored on a monthly basis. • EIVs are being run according to the frequency provisions related to the type of reports we are annually required to complete as per HUD. • Annual inspections are being scheduled as per Annual Recertifications are being processed. • Bi-weekly meetings will be in place to discuss the results collected with a tracking log on the progress of the project. • Trainings will be scheduled to keep on top of HUD updates/compliance procedures; Yardi software trainings; and in-house trainings covering compliance with the files and Yardi 50059 module. Expected completion date: 07/31/2026 If any cognizant or oversight agency has questions regarding this plan, please call Lola Maroulis, Chief Financial Officer at 212-840-8005, extension 111. Sincerely yours, Lola Maroulis, Chief Financial Officer

View Audit 394172

Finding 1182788 (2025-001)

Material Weakness 2025

Town of Longmeadow

MA

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.308 § 200.309 § 200.403

Audit Finding Reference: 2025-001 Improve Oversight Over Period of Performance of Federal Awards Planned Corrective Action: To address the material weakness regarding the period of performance, the Longmeadow Public Schools will implement the following actions: Procedure Revision: The Longmeadow Pub...

Audit Finding Reference: 2025-001 Improve Oversight Over Period of Performance of Federal Awards Planned Corrective Action: To address the material weakness regarding the period of performance, the Longmeadow Public Schools will implement the following actions: Procedure Revision: The Longmeadow Public Schools will update internal control procedures to require that all invoices charged to federal grants explicitly state the dates of service. Staff pro-cessing invoices against Federal grant funds will be instructed to verify these dates against the au-thorized period of performance listed on the Grant Award Notification before processing payment. Staff Training: The Town will conduct mandatory training for the Special Education Department and central office administrative support staff. This training will focus on 2 CFR §200.309, specif-ically emphasizing that costs are only allowable if incurred during the approved budget period, re-gardless of when the invoice is received or paid. Name of Contact Person: Thomas Mazza, Assistant Superintendent for Finance and Operations, Longmeadow Public Schools, tmazza@longmeadow.k12.ma.us Completion Date: Prior to July 1, 2026

View Audit 394167

Finding 1182755 (2025-001)

Material Weakness 2025

Altus Independent School District #18

OK

Questioned Costs Subrecipient Monitoring Material Weakness

Altus Public Schools' Construction Project Manager and Architects have included Davis Bacon requirements in all bid packages for ongoing projects to ensure the required documentation is being provided and met.

View Audit 394154

Finding 1182753 (2025-010)

Material Weakness 2025

Goreville Unit School District 1

IL

Questioned Costs Eligibility

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District implement procedures to monitor the Maintenance of Effort compliance throughout the year, including during the budgeting process. Corrective Action: We arenow aware of the compliance requirement and wil...

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District implement procedures to monitor the Maintenance of Effort compliance throughout the year, including during the budgeting process. Corrective Action: We arenow aware of the compliance requirement and will monitor the Maintenance of Effort compliance under the Eligibility Standard going forward. Proposed Completion Date: Fiscal year 2026.

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Finding 1182752 (2025-008)

Material Weakness 2025

Goreville Unit School District 1

IL

Questioned Costs Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District check the Excluded Parties List System or collect certifications from the entity for any vendor in which the District expects to spend more than $25,000 of federal grant funds for the year. Corrective A...

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District check the Excluded Parties List System or collect certifications from the entity for any vendor in which the District expects to spend more than $25,000 of federal grant funds for the year. Corrective Action: We were not aware of this requirement, but we will ensure that we comply going forward. Proposed Completion Date: Fiscal Year 2026.

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Finding 1182751 (2025-007)

Material Weakness 2025

Goreville Unit School District 1

IL

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.512

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Corrective Action: The auditors discussed the issue with the District....

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend that all required filings be submitted timely according to the Single Audit Act of 1984 and Title 2 U.S. Code of Federal Regulations guidelines. Corrective Action: The auditors discussed the issue with the District. A new checklist will be used with audit completion to ensure timely submission for the 2026 fiscal year. Proposed Completion Date: Fiscal Year 2026.

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Finding 1182746 (2025-009)

Material Weakness 2025

Goreville Unit School District 1

IL

Questioned Costs Reporting School Nutrition Programs

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Correcti...

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend the District expand their internal controls to require a responsible official to review the daily meal count reports for accuracy prior to submission of the reports to the Illinois State Board of Education. Corrective Action: Daily meal counts will be reviewed by administration on a monthly basis. Proposed Completion Date: Immediately.

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Finding 1182743 (2025-006)

Material Weakness 2025

Goreville Unit School District 1

IL

Questioned Costs Procurement, Suspension & Debarment School Nutrition Programs

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend that all food solicitation include the proper language to ensure that food products comply with the Buy American Provision. Corrective Action: We will ensure this language is included in all food solicitations going...

Name of Contact Person: Jonathan Green, Superintendent. Recommendation: We recommend that all food solicitation include the proper language to ensure that food products comply with the Buy American Provision. Corrective Action: We will ensure this language is included in all food solicitations going forward. Proposed Completion Date: Fiscal Year 2026.

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Finding 1182722 (2025-005)

Material Weakness 2025

State of Mississippi Institutions of Higher Learning

MS

Questioned Costs Subrecipient Monitoring Cash Management § 200.305

Finding Reference: 2025-005 - Cash Management (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director - Student Financial Services & Scholarships (Letherio.h.zeigler@jsums.edu) Corrective Action Planned: During the 2024-2025 award year, there was a change in leadership within the financ...

Finding Reference: 2025-005 - Cash Management (JSU) Responsible Official: Mr. Letherio Zeigler, Executive Director - Student Financial Services & Scholarships (Letherio.h.zeigler@jsums.edu) Corrective Action Planned: During the 2024-2025 award year, there was a change in leadership within the financial aid department near the end of 2024 that disrupted the normal process of reconciliation of funds to be disbursed which caused the delayed drawdowns that were outside the scope of compliance regarding allocation of funds towards student accounts. The Executive has developed a timely process of reconciliation that is in line with federal regulations to ensure that funds will drawdown timely as well as the institution has gone voluntarily to a system with COD in which drawdowns will not occur until COD receives approved response files for Federal Pell grant and Student Loans to ensure there is no delay in drawdowns. Estimated Completion Date: August 1, 2026 Finding Reference: 2025-005 - Cash Management (USM) Responsible Official: Erica Kennedy, Associate Vice President for Research (Erica.kennedy@usm.edu) Corrective Action Planned: USM acknowledges the finding related to cash management timing requirements under 2 CFR §200.305(b). To address the root cause and ensure ongoing compliance, USM will implement the following corrective actions: 1.Maintain standard monthly draw schedule. a.USM has returned to the standard monthly draw schedule, which aligns with the institutional accounting close timeline and supports accurate, reconciled requests. b.This schedule is now designated as the required default for all TRIO drawdowns, and deviations will not be permitted except in documented emergency situations approved at the VP level. 2.Reinforce internal controls linked to monthly draws. a.Existing internal controls, including pre-draw reconciliation, multi-level review, and validation of current/month expenditures, remain in place and are explicitly tied to the monthly schedule. b.Any proposed changes to the draw frequency must undergo formal written approval, including documentation explaining the reason for change and a review of associated compliance risks. 3.Monitoring a.For the next two quarters, the AVPR will conduct spot checks to confirm continued adherence to the monthly schedule and compliance with standard reconciliation procedures. Estimated Completion Date: Corrective actions are completed. The standard monthly draw process was reinstated and fully implemented, effective April 2025.

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Finding 1182717 (2025-004)

Material Weakness 2025

State of Mississippi Institutions of Higher Learning

MS

Student Financial Aid Questioned Costs Significant Deficiency

Finding Reference: 2025-004 - SFA - Special Tests - Disbursements to or on Behalf of Students (JSU) Responsible Official: Adrienne Walls, Bursar 601.979.0320 Adrienne.Walls@jsums.edu Corrective Action Planned: Jackson State University will update internal controls to ensure compliance with 34 CFR 66...

Finding Reference: 2025-004 - SFA - Special Tests - Disbursements to or on Behalf of Students (JSU) Responsible Official: Adrienne Walls, Bursar 601.979.0320 Adrienne.Walls@jsums.edu Corrective Action Planned: Jackson State University will update internal controls to ensure compliance with 34 CFR 668.165 related to required notifications for Direct Loan disbursements. The Bursar’s Office will be responsible for issuing required loan disbursement notifications to students and parents. The Bursar’s Office will work in coordination with the University’s Banner consultant to develop and implement an automated process to identify loan disbursements and trigger required notifications. At this time, system-generated notifications are not active. Until automation is implemented, the University will utilize a manual notification process to ensure compliance. Notifications will include (1) the date and amount of the disbursement, (2) the right to cancel all or a portion of the loan, and (3) the process and timeframe to request cancellation. Policies and procedures will be updated to document the notification process. A pre-disbursement control will be implemented prior to each disbursement cycle to verify that the notification process—manual or automated—is in place and functioning as intended. Monitoring procedures will be established to include weekly reviews of disbursement records and notification logs to ensure notifications are issued timely and accurately. Exceptions identified will be resolved promptly. The Assistant Bursar will serve as the control owner responsible for performing and documenting this review. Staff will receive training on regulatory requirements and updated procedures. A standard notification template has been developed and will be used to support the manual process and future automated communications. These actions address the cause of the finding, which resulted from notifications being inadvertently disabled in the financial aid system, and will strengthen controls to prevent recurrence. Estimated Completion Date: April 30, 2026

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Corrective Action Plans

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