Corrective Action Plans

Finding 1227488 (2025-001)

Material Weakness 2025

NY

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Orga...

The Organization should implement an effective monitoring system to keep track of the compliance calendar, which includes financial reporting deadlines, and automatic reminders in advance of each deadline to aid in properly planning and timing submission of reporting packages. Additionally, the Organization should engage the audit firm well before the fiscal year end. The Organization should establish a timeline with the auditors that aligns with internal deadlines to ensure sufficient time to conduct the audit. Additionally, the Organization should implement a system that will file documents in an organized manner and make them easily accessible to the Organization and auditors. Furthermore, the Organization’s Board of Directors should be more actively engaged in the auditing and reporting process to establish a greater degree of accountability and oversight.

View Audit 409525

Finding 1227485 (2025-001)

Material Weakness 2025

Wellpinit School District No. 49

WA

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

Corrective action the auditee plans to take in response to the finding: Wellpinit School District acknowledges the audit finding regarding the absence of a written methodology for allocating state and local funding and staffing to the high school grade span in compliance with Title I, Part A supplem...

Corrective action the auditee plans to take in response to the finding: Wellpinit School District acknowledges the audit finding regarding the absence of a written methodology for allocating state and local funding and staffing to the high school grade span in compliance with Title I, Part A supplement not supplant requirements. At the time of the audit, the District operated under a partial exemption and believed it was appropriately following guidance from the Office of Superintendent of Public Instruction (OSPI). However, the District did not fully understand that a written methodology was still required for the non-exempt high school grade span. While allocation decisions were made using consistent practices, they were not formally documented in a manner that demonstrates compliance with federal requirements. To address this finding, the District is implementing the following corrective actions: 1. Development and Adoption of a Written Methodology The District is developing a formal, written methodology for allocating state and local funds and staffing to its high school grade span. The methodology will: • Allocate resources based on objective, neutral criteria such as student enrollment, program offerings, and staffing ratios • Ensure each high school receives the state and local resources it would otherwise receive if it were not receiving Title I, Part A funds • Clearly document that Title I status is not considered in the allocation process This methodology will be formally adopted and applied beginning with the next annual budget development cycle. 2. Strengthening Internal Controls The District is establishing internal control procedures to ensure compliance with supplement not supplant requirements, including: • Annual documentation of allocation formulas and staffing decisions • Review and approval of allocations by the Business Manager prior to budget adoption • Maintenance of supporting documentation demonstrating consistent application of the methodology 3. Training and Capacity Building District leadership and business office staff will participate in training on Title I, Part A fiscal requirements, including supplement not supplant provisions and documentation standards, utilizing guidance provided by OSPI and federal program resources. 4. Ongoing Monitoring and Oversight The Business Manager will be responsible for monitoring implementation and ensuring compliance by: • Conducting annual reviews of allocation practices • Verifying that documentation is complete and audit-ready • Updating the methodology as needed to reflect changes in enrollment, programming, or regulatory guidance 5. Implementation Timeline The written methodology and internal control procedures will be finalized prior to the development of the upcoming fiscal year budget and fully implemented for that cycle. Documentation supporting compliance will be retained annually.

View Audit 409521

Finding 1227481 (2025-003)

Material Weakness 2025

Art Academy of Cincinnati

OH

Student Financial Aid Subrecipient Monitoring Eligibility

Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of t...

Condition: During testing of Student Financial Assistance (SFA) eligibility and awarding, the Institution did not consistently apply federal requirements related to Cost of Attendance (COA), financial need determination, and award packaging. Specifically: • One student was awarded aid in excess of the federally allowable COA. • One student’s COA was overstated, which resulted in the student being potentially overawarded. • Six student’s were awarded the incorrect COA based on the grade level reported on the Institutional Student Information Record (ISIR). However, there is no code for year 4 on the ISIR, which resulted in the students receiving year 3 COA. • Two students received aid in excess of their calculated financial need, and the Institution did not maintain documentation supporting the adjustments or exceptions. • One student was enrolled at three quarter time during the fall semester and full time during the spring semester; however, the student received three quarter time Pell Grant disbursements for both semesters, resulting in an underpayment for the spring term and inaccurate Pell reporting. These errors demonstrate inconsistent application of federal awarding rules and insufficient review of eligibility and enrollment status changes. Views of Responsible Officials: AAC officials concur with the audit finding and acknowledge that the identified errors resulted from inconsistencies in the application of federal Student Financial Assistance awarding requirements and insufficient review of student eligibility, Cost of Attendance calculations, financial need determinations, and enrollment status changes. Management has reviewed each of the identified student files and is taking appropriate corrective action, including recalculating awards, making any required adjustments or corrections, and updating reporting where necessary. The AAC has also evaluated the circumstances surrounding the use of Cost of Attendance budgets, including the limitation of the Institutional Student Information Record (ISIR), which does not include a separate code for fourth-year undergraduate students. Procedures are being revised to ensure that staff apply the appropriate institutional Cost of Attendance budget regardless of the ISIR grade level code and that any manual adjustments are adequately documented. Corrective Action Plan: To strengthen internal controls, the AAC will implement enhanced review procedures for financial aid packaging, Cost of Attendance determinations, financial need calculations, enrollment status changes, and Pell Grant disbursements prior to disbursement. In addition, financial aid personnel will receive refresher training on federal awarding requirements, documentation standards, and exception processing. Management believes these corrective actions will improve compliance with federal regulations and reduce the likelihood of similar errors in future award years. Responsible Party: Executive Director of Administration and Finance Completion Date: The corrective action will be developed and implemented during the 2025-2026 fiscal year and will continue to be implemented in the 2026-2027 fiscal year.

View Audit 409518

Finding 1227468 (2025-004)

Material Weakness 2025

City of Albany, Georgia

GA

Reporting Internal Control / Segregation of Duties

Management will implement a process to ensure expenditures/expenses and related balances are properly stated in a timely manner.

View Audit 409493

Finding 1227463 (2025-003)

Material Weakness 2025

City of Albany, Georgia

GA

Reporting Internal Control / Segregation of Duties

Management will implement a process to ensure revenues and related balances are properly stated in a timely manner.

View Audit 409493

Finding 1227459 (2025-007)

Material Weakness 2025

The Institute of World Politics

DC

Internal Control / Segregation of Duties Material Weakness Reporting § 200.512

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management a...

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Uniform Guidance reporting requirements: 1. Establish Formal Single Audit Reporting Procedures • The Institute will develop and maintain written procedures governing the annual Single Audit reporting process, including the preparation, review, approval, and submission of the Data Collection Form and reporting package. Procedures will clearly identify filing deadlines, responsible personnel, required approvals, and submission requirements. 2. Assign Responsibility and Accountability • Management will formally designate responsibility for coordinating the annual audit reporting process, including monitoring auditor requests, gathering required documentation, preparing the Data Collection Form, obtaining management approvals, and ensuring timely submission to the Federal Audit Clearinghouse. 3. Implement an Audit and Compliance Calendar • The Institute will establish a compliance calendar that includes all critical audit and federal reporting deadlines. Key milestones will include audit preparation activities, auditor request completion, draft financial statement review, issuance of the auditor's reports, Data Collection Form preparation, management certification, and FAC submission deadlines. 4. Strengthen Management Review Controls • Management will implement documented review procedures for the reporting package and Data Collection Form prior to submission. Review controls will verify the accuracy, completeness, and timeliness of information reported and ensure compliance with Uniform Guidance requirements. 5. Monitor Audit Requests and Submission Readiness • A tracking mechanism will be implemented to monitor the status of auditor requests, outstanding items, and reporting package preparation throughout the audit process. Periodic status meetings will be conducted to identify potential delays and ensure timely resolution of open items. 6. Maintain Evidence of Filing and Review • The Institute will retain documentation supporting preparation, review, approval, and submission of the Data Collection Form and reporting package, including filing confirmations, management approvals, submission receipts, and related correspondence. 7. Ongoing Oversight and Compliance Monitoring • Senior management will periodically review compliance with federal reporting deadlines and monitor the effectiveness of implemented controls. Any compliance issues identified will be evaluated and addressed promptly to prevent future late filings. Responsible Officials: • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr. Thelbert Snowden Anticipated completion date: The Institute will implement formal reporting procedures, deadline tracking tools, management review controls, and accountability measures by December 31, 2026. These procedures will be incorporated into all future Single Audit reporting cycles.

View Audit 409492

Finding 1227456 (2025-004)

Material Weakness 2025

The Institute of World Politics

DC

Allowable Costs / Cost Principles Material Weakness Reporting

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its intern...

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its internal records and COD system data. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen controls over COD reporting and reconciliation activities. 1. Implementation of Monthly Reconciliation Procedures • The Institute will establish formal monthly reconciliation procedures requiring comparison of: o COD system data to internal financial aid records; o Student financial aid records to the student information system; and o COD activity to the general ledger and related financial reporting records. • The reconciliation process will be designed to verify that all aid originated, disbursed, adjusted, and reported to the Department of Education is complete and accurate. 2. Development of Written Policies and Procedures • Management will develop and maintain formal written policies and procedures governing COD reconciliation activities. These procedures will identify responsible personnel, reconciliation timelines, required documentation, review expectations, and procedures for investigating and resolving discrepancies. 3. Timely Investigation and Resolution of Differences • Any discrepancies identified during the reconciliation process will be reviewed, documented, and resolved timely. Management will maintain documentation explaining the nature of reconciling items, corrective actions taken, and the date of resolution. 4. Documentation and Retention Requirements • The Institute will maintain completed reconciliation workpapers each month, including supporting reports, reconciliations performed, explanations of variances, and documentation of corrective actions taken. Reconciliation records will be retained in accordance with federal record retention requirements. 5. Management Review and Approval • Completed reconciliations will be reviewed by supervisory personnel independent of the preparation process. Evidence of review will be documented through signed and dated approvals, electronic workflow approvals, or other documentation demonstrating that reconciliations were reviewed for completeness and accuracy. 6. Staff Training • Financial Aid and Finance personnel responsible for COD reporting and reconciliation activities will receive training regarding Department of Education requirements, reconciliation procedures, documentation standards, and internal control responsibilities. 7. Ongoing Monitoring and Compliance Oversight • Management will perform periodic monitoring of reconciliation activities to ensure procedures are operating effectively and reconciliations are completed on a timely basis. Compliance results and any significant reconciliation issues will be communicated to senior management and tracked through resolution. Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records (Continued) Responsible Officials: • Director of Financial Aid 0 Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: Formal reconciliation procedures, documentation standards, and management review controls will be fully implemented by December 31, 2026. Monthly reconciliations will be performed and documented on an ongoing basis thereafter.

View Audit 409492

Finding 1227455 (2025-003)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Reporting Special Tests & Provisions

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken o...

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Formal Written Procedures • The Institute will develop and maintain formal written policies and procedures governing NSLDS enrollment reporting. These procedures will clearly define reporting requirements, timelines, responsible personnel, supervisory review responsibilities, and documentation retention requirements to ensure compliance with Department of Education regulations. 2. Establishment of Reporting Calendars and Tracking Controls • Management will implement a formal reporting calendar and tracking mechanism to monitor NSLDS reporting deadlines. The tracking process will identify enrollment status changes requiring reporting and ensure all submissions occur within the required 60-day timeframe. 3. Enhanced Monitoring and Reconciliation Procedures • The Institute will perform periodic reconciliations between student enrollment records and NSLDS submissions to verify that all enrollment status changes have been reported accurately and timely. Any discrepancies identified during reconciliation will be investigated and corrected promptly. 4. Documented Review and Approval Process • Management will require documented evidence of supervisory review for each NSLDS submission. Review documentation will include dated approvals, electronic workflow approvals, or other evidence demonstrating that submissions were reviewed for completeness, accuracy, and timeliness prior to certification. 5. Staff Training and Cross-Training • Financial Aid personnel responsible for enrollment reporting will receive training on NSLDS reporting requirements and internal control procedures. Cross training will be implemented to ensure coverage during staff absences and reduce the risk of reporting delays due to personnel changes. 6. Ongoing Compliance Monitoring • Management will conduct periodic reviews of NSLDS reporting performance and maintain monitoring documentation to verify ongoing compliance with federal requirements. Any exceptions identified will be addressed through corrective action and management follow-up. 7. Oversight and Accountability • The Director of Financial Aid and senior administration will review compliance monitoring results periodically and track remediation efforts until the finding has been fully resolved. Management will maintain documentation supporting the operation of controls and timely reporting activities. Responsible Officials • Director of Financial Aid – Dr Thelbert Snowden • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Registrar (as applicable) – Adele Hartswick Anticipated completion date: The Institute will implement formal policies, reporting calendars, monitoring controls, reconciliation procedures, and review documentation requirements by December 31, 2026. Ongoing compliance monitoring and periodic review activities will continue thereafter.

View Audit 409492

Finding 1227454 (2025-002)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Mana...

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Written Policies and Procedures • The Institute will perform a comprehensive review of all applicable Student Financial Assistance compliance requirements and develop formal written policies and procedures documenting the processes and controls for each material compliance area. Procedures will include the individual responsible, required documentation, review requirements, and retention standards. 2. Documentation of Internal Controls • Management will establish standardized control documentation requirements for all compliance activities. Evidence of review and approval will be maintained through signatures, initials, electronic approvals, checklists, reconciliations, or other documented support sufficient to demonstrate that controls were performed and reviewed. 3. Compliance Monitoring Checklists • The Institute will implement compliance monitoring checklists covering all direct and material compliance requirements identified in the audit, including: o Cash Management o Reporting o Student Eligibility o Student Disbursements o Credit Balance Processing o NSLDS Reporting o Gramm-Leach-Bliley Act Information Security Requirements • The checklists will be completed and reviewed periodically to provide evidence of compliance and supervisory oversight. 4. Training and Cross-Training • Financial Aid and Administrative personnel will receive training on federal student aid compliance requirements, documentation expectations, and internal control responsibilities. Cross training will be performed to mitigate risks associated with employee turnover and ensure continuity of operations. 5. Management Review and Oversight • Management will implement periodic supervisory reviews of compliance activities and supporting documentation to verify controls operating as designed. Results of compliance monitoring activities and any identified deficiencies will be reported to senior administration, and corrective actions will be tracked to completion. 6. Annual Compliance Review • The Institute will conduct an annual review of Student Financial Assistance policies, procedures, and internal controls to ensure continued compliance with Department of Education regulations, Uniform Guidance requirements, and changes in federal program requirements. Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance (Continued) Responsible Officials: • Executive Vice President – Ariane Sweeney • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Compliance and Information Security Personnel, as applicable Anticipated completion date: The written policies and procedures, compliance monitoring tools, and documentation standards will be fully implemented by December 31, 2026. Ongoing monitoring, training, and annual reviews will continue thereafter.

View Audit 409492

Finding 1227453 (2025-001)

Material Weakness 2025

Columbia Borough School District

PA

Subrecipient Monitoring Cash Management Reporting § 200.303

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will...

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.

View Audit 409490

Finding 1227450 (2025-001)

Material Weakness 2025

Search for Common Ground

DC

Reporting Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.302 § 200.303

We will strengthen our controls around reporting of expenses on consolidated SEFA report for our subsidiary and related organizations. We will exclude expenses that exceed the total budget and recommend posting adjustments in the books so that these are not included in grant expenses.

View Audit 409488

Finding 1227383 (2025-008)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Cash Management Allowable Costs / Cost Principles Material Weakness

The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: Octob...

The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: October 31, 2026

View Audit 409469

Finding 1227381 (2025-006)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.331

The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization...

The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization feels that it was able to show the funds that were passed-through to the contractor. Responsible Individual: Chief Financial Officer– Scott Korba Estimated Completion Date

View Audit 409469

Finding 1227380 (2025-005)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

The regulation speaks to submitting quarterly reports within a given time frame. The regulation does not require formal evidence that the required reports were verified before submission. The organization is of the opinion that once complete the CFO reviews the report and verifies before submission....

The regulation speaks to submitting quarterly reports within a given time frame. The regulation does not require formal evidence that the required reports were verified before submission. The organization is of the opinion that once complete the CFO reviews the report and verifies before submission. The organization CEO may review be included in the review process. Responsible Individual: Chief Financial Officer- Scott Korba Estimated Completion Date: End of next quarter – September 2026

View Audit 409469

Finding 1227379 (2025-004)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Under the state of Pennsylvania, contractors doing home repairs in excess of $5000 a year must register with the state of Pennsylvania and receive their Home Improvement Contractor Certification. Applications are reviewed by the Attorney General’s Office , anyone who is debarred is not issued and HI...

Under the state of Pennsylvania, contractors doing home repairs in excess of $5000 a year must register with the state of Pennsylvania and receive their Home Improvement Contractor Certification. Applications are reviewed by the Attorney General’s Office , anyone who is debarred is not issued and HIC Certification. In addition, the Program Director has a list of debarred contractors that he reviews periodically to ensure that contractors are not on the list. The organization will take the auditors recommendation of copying the debarred alphabetical page indicating that the contractor is not on the debarred or suspended listing and placing it in the contractors file. Responsible Individual: Energy Director Zack Porrecca and Housing Director Vickie Bucker Estimated Completion Date: September 30, 2026

View Audit 409469

Finding 1227376 (2025-003)

Material Weakness 2025

County of Hidalgo, Texas

TX

Reporting

Corrective Action Plan – Hidalgo County Urban County Program (UCP) concurs with the recommendation and has taken steps to strengthen its internal controls to ensure the timely preparation, review, submission, and documentation of Section 3 quarterly reports and other State Program reporting requirem...

Corrective Action Plan – Hidalgo County Urban County Program (UCP) concurs with the recommendation and has taken steps to strengthen its internal controls to ensure the timely preparation, review, submission, and documentation of Section 3 quarterly reports and other State Program reporting requirements. The untimely reports identified in the finding occurred during a period of significant personnel turnover within the State Division. Management recognizes that regulatory compliance and reporting continuity should not depend upon the knowledge or availability of any one employee.Accordingly, UCP has begun transitioning from individually maintained deadline tracking to a more centralized and transparent reporting-control process. Approximately six months ago, UCP implemented a requirement that State Programs staff enter all grant-related reporting deadlines and other critical compliance dates into the County/Urban County shared electronic calendar. This calendar is accessible to State Programs staff and management and provides department-wide visibility of upcoming deadlines, thereby reducing reliance on individual calendars or institutional memory. In addition to this existing control, UCP will implement the following measures specifically for Section 3 reporting: • Establish internal preparation deadlines at least 5 calendar days before each required Section 3 submission date. • Assign primary responsibility for preparation and submission of each Section 3 report to the applicable State Grant Coordinator, with supervisory review by the State Programs Manager/Coordinator or other designated supervisor prior to submission. • Designate and cross-train at least one additional State Programs employee as backup personnel for Section 3 reporting to ensure continuity during vacancies, leave, employee transitions, or other absences. • Maintain a centralized reporting log for each applicable grant documenting the reporting period, regulatory or contractual due date, internal preparation deadline, responsible employee, supervisory review date, actual submission date, and confirmation or other evidence of submission. • Maintain supporting Section 3 reporting documentation within the applicable grant's official administrative file in accordance with applicable record-retention requirements. • Include upcoming reporting deadlines as a standing compliance item during State Programs staff meetings so that approaching deadlines, assignments, and outstanding reporting requirements can be reviewed collectively. • Require supervisory follow-up when a report has not reached the review stage by its established internal deadline, allowing management sufficient time to intervene before the external submission deadline. • Periodically review the shared reporting calendar and reporting log to verify that required reports have been submitted timely and that supporting documentation has been retained. These controls are intended to establish multiple levels of accountability—deadline visibility, assigned responsibility, supervisory review, backup coverage, documentation of submission, and management oversight—so that required reporting continues timely despite employee turnover or other staffing changes. UCP will also incorporate Section 3 reporting procedures into written State Programs standard operating procedures and employee cross-training materials so that the reporting process becomes documented institutional knowledge available to current and future staff. Proposed Completion Date - Existing shared calendar control (implemented and currently in use); Remaining corrective measures (September 30, 2026 - Implementation will begin immediately and be incorporated into State Program operating procedures and reporting practices). Contact Person - Steven De La Cruz, Assistant Director, Urban County Program

View Audit 409465

Finding 1227368 (2025-001)

Material Weakness 2025

Housing Initiatives, INC

WI

Internal Control / Segregation of Duties Reporting Equipment & Real Property Management

2025-001 Financial Reporting – Material Adjustments Criteria: Internal controls over financial reporting should be designed and implemented to ensure that financial statements are free from material misstatement, whether due to error or fraud, and that such misstatements are prevented or detected an...

2025-001 Financial Reporting – Material Adjustments Criteria: Internal controls over financial reporting should be designed and implemented to ensure that financial statements are free from material misstatement, whether due to error or fraud, and that such misstatements are prevented or detected and corrected on a timely basis. Condition: During the audit, material audit adjustments were proposed and accepted by management. The adjustments were necessary to correct material misstatements in the financial statements that had not been identified by the organization’s internal control processes. Significant adjustments included: • Recording loan forgiveness, which corrected the overstatement of liabilities and understatement of revenues • Reclassifying HOME program assistance from revenue to deferred loan liability, which corrected the overstatement of revenues and changes in net assets and the understatement of liabilities • Reclassifying development costs from expenses to property and equipment, which corrected the understatement of assets and overstatement of expenses. Cause: The Organization’s internal control processes did not identify or correct these misstatements prior to the audit. This suggests certain review and reconciliation procedures may not be operating effectively. Effect: Financial statements generated from the accounting system and provided to the board may contain error(s), which could potentially affect decision-making and oversight. Auditor’s Recommendation: We recommend that management review and enhance its financial reporting processes, including implementing more robust review procedures and reconciliations, to help ensure that misstatements are identified and corrected prior to the audit. Auditee’s Response: Management agrees with this finding and agrees with the recommendation. Management will evaluate current procedures and implement improvements to strengthen the accuracy and completeness of financial reporting. Contact Person: Brad Hinkfuss Anticipated Completion: December 31, 2026

View Audit 409457

Finding 1227364 (2025-002)

Material Weakness 2025

Town of Highgate, Vermont

VT

Reporting Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.328

The Town of Highgate has endured a significant amount of turnover in the Town Administrator's role. This reporting was a task of the Town Administrator. The Town Treasurer was unaware that the SF-425 reports for the Town's active grant awards were not being filed in a timely fashion. The newly appoi...

The Town of Highgate has endured a significant amount of turnover in the Town Administrator's role. This reporting was a task of the Town Administrator. The Town Treasurer was unaware that the SF-425 reports for the Town's active grant awards were not being filed in a timely fashion. The newly appointed Town Administrator has been made aware we are required to file the SF-425 when a grant award mandates the submission. Corrective action has began, the Town Administrator and Treasurer have been working together to get in compliance with our required reporting across all State and Federal Agencies that have awarded the Town grant funds. Trainings have taken place and the newly hired Administrator is aware of the required reporting and is able to perform this task on time when required.

View Audit 409454

Finding 1227351 (2025-002)

Material Weakness 2025

BOSCOBEL HOUSING AUTHORITY

WI

Reporting Internal Control / Segregation of Duties

Corrective Action Planned: The material misstatements detected as a result of audit procedures were corrected by management. The Authority will review all adjusting entries posted and make all such necessary adjustments in the future. The Executive Director will continue to monitor all financial act...

Corrective Action Planned: The material misstatements detected as a result of audit procedures were corrected by management. The Authority will review all adjusting entries posted and make all such necessary adjustments in the future. The Executive Director will continue to monitor all financial activity and adjust account balances as needed throughout the year and at year end to prevent misstatements. Completion Date: December 31, 2026

View Audit 409432

Finding 1227347 (2025-013)

Material Weakness 2025

Wittenberg University

OH

Student Financial Aid Reporting Subrecipient Monitoring

Condition Summary: The institution's procedures and controls for determining and reporting withdrawal dates to NSLDS were not operating effectively to ensure that the actual effective date of withdrawal was reported accurately and that enrollment status changes were reported timely. Of the forty stu...

Condition Summary: The institution's procedures and controls for determining and reporting withdrawal dates to NSLDS were not operating effectively to ensure that the actual effective date of withdrawal was reported accurately and that enrollment status changes were reported timely. Of the forty student records tested for NSLDS withdrawal reporting, we identified the following: • One student where the effective date of withdrawal was reported as the end of the semester rather than the student's actual withdrawal date. • Six students where the effective date of withdrawal was reported as the date the student was notified rather than the actual effective withdrawal date. • One student where the student's withdrawal was not reported timely and was not included on the first enrollment roster following the withdrawal. Management Response / Corrective Action Plan: Management concurs with this finding. Turnover within the Financial Aid office resulted in a breakdown in the process for timely and accurate submission of reporting enrollment changes within NSLDS. Staff previously responsible for this function are no longer employed at the institution, and the engaged consulting firm has assumed interim responsibility for identifying enrollment status changes and completing NSLDS reporting within the required 60-day period. Responsible Party - Raymond Nault, Interim Director of Student Financial Services Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.

View Audit 409430

Finding 1227345 (2025-010)

Material Weakness 2025

Wittenberg University

OH

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

Condition Summary: The Data Collection Form was submitted to the Federal Audit Clearinghouse after the required deadline, with no documented extension obtained. Management Response / Corrective Action Plan: Management concurs with this finding. The University has implemented a compliance calendar, m...

Condition Summary: The Data Collection Form was submitted to the Federal Audit Clearinghouse after the required deadline, with no documented extension obtained. Management Response / Corrective Action Plan: Management concurs with this finding. The University has implemented a compliance calendar, maintained by the engaged consulting firm, that tracks all federal reporting deadlines, including the DCF submission date, with milestone reminders beginning 60 days in advance of each deadline. Responsibility for final submission has been assigned to the consulting firm for the current cycle to ensure the deadline is met while the University's internal compliance-monitoring function is rebuilt. Responsible Party - Michael DeWees, Vice-President for Finance and Administration Title - Interim oversight: Engaged Consulting Firm Anticipated Completion Date - August 24, 2026 Note: Because the corrective actions described above were substantially implemented during and after the fiscal year 2025 audit period, management anticipates that this condition, or elements of it, may continue to be identified as a finding in the University's fiscal year 2025-2026 single audit. Full operating effectiveness of the revised controls will not be demonstrable until they have been in place for a complete testing cycle.

View Audit 409430

Finding 1227305 (2025-003)

Material Weakness 2025

Nebraska Early Childhood Collaborative

NE

Cash Management Reporting Significant Deficiency § 200.303

U.S. Department of Health and Human Services Federal Financial Assistance Listing #93.600 Head Start Cluster Early Head Start Child Care Partnership Applicable Federal Award Number and Year – 07HP000640-01-00 and 07HP000640-02-00 9/1/2024 – 8/31/2025 and 9/1/2025 – 8/31/2026 Reporting Significant De...

U.S. Department of Health and Human Services Federal Financial Assistance Listing #93.600 Head Start Cluster Early Head Start Child Care Partnership Applicable Federal Award Number and Year – 07HP000640-01-00 and 07HP000640-02-00 9/1/2024 – 8/31/2025 and 9/1/2025 – 8/31/2026 Reporting Significant Deficiency in Internal Control Over Compliance Criteria: CFR 200.303(a) establishes that the auditee must establish and maintain effective internal control over federal awards that provides reasonable assurance that the Organization is managing the federal awards in compliance with federal statutes, regulations and terms and conditions of the federal award. Condition: The Organization was unable to provide adequate documentation of expenditures incurred to support the drawdown of federal awards claimed for reimbursement on an interim basis throughout the reporting period. Corrective Action Plan: At the time of the audit, the new CFO had reviewed its internal processes and has incorporated new procedures and controls over the tracking and submitting of drawdown requests for reimbursement of expenditures incurred under federal awards. All drawdown requests submitted are now reconciled and properly supported by internal records for expenditures incurred during the period being requested. Individual Responsible for Corrective Action: Milton Trabal, Chief Financial Officer Anticipated Completion Date: 2026

View Audit 409416

Finding 1227303 (2025-002)

Material Weakness 2025

Nebraska Early Childhood Collaborative

NE

Reporting Cash Management Material Weakness

U.S. Department of Health and Human Services Federal Financial Assistance Listing #93.600 Head Start Cluster Applicable Federal Award Number and Year – 07HP000640-02-00 9/1/2025 – 8/31/2026 Preparation of Schedule of Expenditures of Federal Awards Material Weakness in Internal Control Over Complianc...

U.S. Department of Health and Human Services Federal Financial Assistance Listing #93.600 Head Start Cluster Applicable Federal Award Number and Year – 07HP000640-02-00 9/1/2025 – 8/31/2026 Preparation of Schedule of Expenditures of Federal Awards Material Weakness in Internal Control Over Compliance Criteria: Proper controls over financial reporting include the ability to prepare the schedule of expenditures of federal awards (Schedule) and accompanying notes to the Schedule in accordance with requirements of the Uniform Guidance. Condition: The Organization’s internal controls over the preparation of the Schedule were not operating effectively. As a result of our audit procedures, misstatements in the Schedule were identified and adjustments to the Schedule were proposed and recorded by management. Corrective Action Plan: Management is in the process of reviewing its accounting processes and procedures over the preparation of the Schedule in order to accurately report federal expenditures incurred during the reporting period. Individual Responsible for Corrective Action: Milton Trabal, Chief Financial Officer Anticipated Completion Date: 12/31/2026

View Audit 409416

Finding 1227302 (2025-001)

Material Weakness 2025

Robbins Children's Programs, Inc.

MA

Reporting § 200.512

Management agrees with the finding and has implemented a revised reporting checklist to ensure compliance going forward.

View Audit 409413

Finding 1227298 (2025-002)

Material Weakness 2025

Columbus Community School District

IA

Internal Control / Segregation of Duties Reporting

The district continues to find solutions to help segregate duties with our minimally staffed central office (business manager, HR director & nutrition director). We modified duties of our building secretaries due to being short staffed. This eliminated an additional check & balance measure added a f...

The district continues to find solutions to help segregate duties with our minimally staffed central office (business manager, HR director & nutrition director). We modified duties of our building secretaries due to being short staffed. This eliminated an additional check & balance measure added a few years ago of the secretary entering receipts into WebLink. The building secretaries continue to write deposit slips & post payment to our student information system. The district’s business manager & HR director will work with board members on the finance & negotiations committee to develop a plan to add more checks & balances to our current operation. We will use the segregation of duties handbook to help with this process.

View Audit 409408

Corrective Action Plans

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