Corrective Action Plans

Finding 1213881 (2025-006)

Material Weakness 2025

IL

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.033, 84.007, and 84.379 Recommendation: We recommend that the College review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagr...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268, 84.033, 84.007, and 84.379 Recommendation: We recommend that the College review the GLBA requirements and ensure their WISP includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The colleges IT department is currently working on ensuring the WISP does include all elements that are required. IMplemention and completion will be conducted and completed for FY26. Name(s) of the contact person(s) responsible for corrective action: Mo Darwish Planned completion date for corrective action plan: July 2026

View Audit 400711

Finding 1213876 (2025-005)

Material Weakness 2025

Vandercook College of Music

IL

Questioned Costs Student Financial Aid Reporting

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.379 Recommendation: We recommend the College reevaluate its procedures, and review policies surrounding controls implemented for COD reporting. Explanation of disagreement with audit finding: There is no disagreement wi...

Student Financial Assistance Cluster – Assistance Listing No. 84.268, 84.063, 84.379 Recommendation: We recommend the College reevaluate its procedures, and review policies surrounding controls implemented for COD reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College is currently implementing a process in which disbursement dates within the SIS matches all dates within COD’s Award Disbursements Information Disbursement Date. This will be done within the Batch record by utilziing the date the batch was processed as “Funds Deposited” instead of the initial “anticipated” award date. The adjustment will ensure that all dates match as the official date the fund was credited to the student’s account. Review of existing prociedures will be conducted regarding the COD disbursement controls. The importance of accurate documentation and actual disbursement dates within the SIS will be emphasized. All disbursmeent dates will be reviewed and reconcilled by the Director of Financial Aid ensuring timely and accurate reporting. Name(s) of the contact person(s) responsible for corrective action: Walter Thompson Planned completion date for corrective action plan: July 2026

View Audit 400711

Finding 1213867 (2025-009)

Material Weakness 2025

TOWN OF SPRUCE PINE

NC

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency § 200.323

The Town will update its finance and procurement procedures to require cost or price analysis for all procurements exceeding the simplified acquisition threshold, including contract modifications. A standard cost or price analysis form will be implemented and required prior to contract approval. Sta...

The Town will update its finance and procurement procedures to require cost or price analysis for all procurements exceeding the simplified acquisition threshold, including contract modifications. A standard cost or price analysis form will be implemented and required prior to contract approval. Staff will be trained on performing and documenting cost and price analyses, including during emergency response situations.

View Audit 400700

Finding 1213864 (2025-006)

Material Weakness 2025

TOWN OF SPRUCE PINE

NC

Allowable Costs / Cost Principles Questioned Costs Subrecipient Monitoring § 200.302 § 200.403

The Town will implement written procedures requiring the development and maintenance of project‑specific budgets for all federal awards, including FEMA emergency response and recovery projects. Project budgets will be prepared in accordance with approved scopes of work and used to monitor expenditur...

The Town will implement written procedures requiring the development and maintenance of project‑specific budgets for all federal awards, including FEMA emergency response and recovery projects. Project budgets will be prepared in accordance with approved scopes of work and used to monitor expenditures throughout the life of the award. The Town will provide training to applicable staff on federal grant budgeting requirements and designate responsibility for budget preparation and monitoring.

View Audit 400700

Finding 1213745 (2025-003)

Material Weakness 2025

Council on Substance Abuse Ncadd

AL

Procurement, Suspension & Debarment Significant Deficiency § 200.303

Due to changes in reimbursement and funding availability, the procurement policy and procedures will be revised to requiring at least one week prior to purchases being made unless there are extenuating circumstances, which will require an explanation on the Purchase Order Form. This policy will be r...

Due to changes in reimbursement and funding availability, the procurement policy and procedures will be revised to requiring at least one week prior to purchases being made unless there are extenuating circumstances, which will require an explanation on the Purchase Order Form. This policy will be reinforced. Expected Completion Date: Effective immediately, May 2026

View Audit 400659

Finding 1213690 (2025-004)

Material Weakness 2025

Colorado Legal Services, INC

CO

Questioned Costs Procurement, Suspension & Debarment Reporting

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization implement a control process to ensure that it complies with its reporting requirements during the grant period. Explanation of Disagreement With Audit Finding: CLS believes that th...

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization implement a control process to ensure that it complies with its reporting requirements during the grant period. Explanation of Disagreement With Audit Finding: CLS believes that this matter would be more appropriately communicated in the management letter rather than presented as part of the overall audit report. Action Taken in Response to Finding: CLS will extend and enforce the verification of these requirements. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: July 2026

View Audit 400608

Finding 1213689 (2025-003)

Material Weakness 2025

Colorado Legal Services, INC

CO

Questioned Costs Significant Deficiency Internal Control / Segregation of Duties

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization implement a control process to ensure that it obtains signed written simple agreements for all staff members who handle cases or matters or are authorized to make decisions about c...

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization implement a control process to ensure that it obtains signed written simple agreements for all staff members who handle cases or matters or are authorized to make decisions about case acceptance where required in accordance with 45 CFR 1620.6. Explanation of Disagreement With Audit Finding: CLS believes that this matter would be more appropriately communicated in the management letter rather than presented as part of the overall audit report. Action Taken in Response to Finding: CLS implemented an onboarding process in 2025 through its HR system, BambooHR, which includes verification of this and other required elements. While this process has been applied to new hires, CLS will extend and enforce the verification of these requirements for employees who joined the organization prior to 2025. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: July 2026

View Audit 400608

Finding 1213688 (2025-002)

Material Weakness 2025

Colorado Legal Services, INC

CO

Questioned Costs Procurement, Suspension & Debarment Significant Deficiency

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization implement a control process to ensure that it obtains LSC prior written approval where required in accordance with 45 CFR 1630.6(b). Action Taken in Response to Finding: With respe...

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization implement a control process to ensure that it obtains LSC prior written approval where required in accordance with 45 CFR 1630.6(b). Action Taken in Response to Finding: With respect to the recommended control process, CLS has an established procedure incorporated within its accounting manual. The organization will reinforce and ensure consistent application of this procedure throughout 2026. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: July 2026

View Audit 400608

Finding 1213608 (2025-001)

Material Weakness 2025

YMCA of Greater Boston

MA

Eligibility Questioned Costs Period of Performance § 200.303

Management will conduct a comprehensive review of existing processes and internal controls related to eligibility determination and documentation to ensure alignment with federal requirements. As part of this effort, management will evaluate the timing and sequencing of required signatures to better...

Management will conduct a comprehensive review of existing processes and internal controls related to eligibility determination and documentation to ensure alignment with federal requirements. As part of this effort, management will evaluate the timing and sequencing of required signatures to better reflect operational realities while maintaining compliance.

View Audit 400545

Finding 1213598 (2025-003)

Material Weakness 2025

Primary Connection Health Care, Inc.

WI

Cash Management Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Allowable Activities and Costs, Cash Management, and Reporting Health Center Cluster – Assistance Listing No. 93.224 Recommendation: We recommend the Clinic develop and implement formal policies and procedures to ensure consistent review and approval over all applicable compliance requirements for f...

Allowable Activities and Costs, Cash Management, and Reporting Health Center Cluster – Assistance Listing No. 93.224 Recommendation: We recommend the Clinic develop and implement formal policies and procedures to ensure consistent review and approval over all applicable compliance requirements for federal programs. This should include but not limited to assigning responsibility for each compliance area, implementing documented review and approval controls (e.g., review of financial reports, cash drawdowns, and grant expenditures), and retaining evidence of review (e.g., sign-offs, checklists, or electronic approvals). Action taken in response to finding: The Clinic has implemented policies and procedures to ensure formal review and approval is documented for each compliance area. Name(s) of the contact person(s) responsible for corrective action: Kim Wieloch, Finance Director Planned completion date for corrective action plan: April 1, 2026.

View Audit 400514

Finding 1213592 (2025-001)

Material Weakness 2025

Access, INC

CA

Reporting Significant Deficiency § 200.512

Management acknowledges the delay in submitting the audit report due to staff capacity limitations. To prevent recurrence, they have established a formal year-end audit planning calendar with interim documentation deadlines and have implemented a structured, pre-audit check-list process to ensure al...

Management acknowledges the delay in submitting the audit report due to staff capacity limitations. To prevent recurrence, they have established a formal year-end audit planning calendar with interim documentation deadlines and have implemented a structured, pre-audit check-list process to ensure all documentation is finalized and reviewed at least 30 days prior to the deadline.

View Audit 400505

Finding 1213584 (2025-002)

Material Weakness 2025

Cedar Unified School District No. 25

AZ

Questioned Costs Reporting Significant Deficiency

2025-002 Single Audit Submission Planned Corrective Action Plan: The District will ensure all supporting documentation is prepared and ready for Auditors. In addition, audit services will be procured with sufficient time to submit the single audit by the required timeline. Anticipated Completion Dat...

2025-002 Single Audit Submission Planned Corrective Action Plan: The District will ensure all supporting documentation is prepared and ready for Auditors. In addition, audit services will be procured with sufficient time to submit the single audit by the required timeline. Anticipated Completion Date: June 30, 2026 Responsible Contact Person: Judy James, Business Manager

View Audit 400494

Finding 1213503 (2025-001)

Material Weakness 2025

Seattle Indian Health Board

WA

Questioned Costs Eligibility Significant Deficiency

Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance) Planned Corrective Action: The Seattle Indian Health Board is implementing enhanced corrective actions to ensure full compliance with Indian Health Service eligibility requiremen...

Finding 2025-001 – Eligibility (Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance) Planned Corrective Action: The Seattle Indian Health Board is implementing enhanced corrective actions to ensure full compliance with Indian Health Service eligibility requirements, specifically related to documentation of Tribal enrollment. While prior corrective actions established foundational training and audit processes, management has identified the need for stronger front-end controls, clearer accountability, and system-based safeguards to prevent recurrence. Seattle Indian Health Board will implement the following actions: 1. Strengthen Front-End Eligibility Controls - Eligibility verification protocols will be updated to require complete Tribal enrollment documentation prior to scheduling non-urgent appointments. - A standardized eligibility checklist will be embedded into intake workflows to ensure all required documentation is identified and collected before services are rendered. 2. System Enhancement and Documentation Tracking - Electronic health record workflows will be enhanced to include required fields and alters for missing eligibility documentation, including Tribal enrollment. - Patients with incomplete eligibility records will be flagged, and services will be limited to allowable scenarios until documentation is obtained. 3. Targeted Training and Competency Validation - All registration and front desk staff will undergo mandatory retraining focused specifically on Tribal enrollment documentation requirements and compliance standards. - Staff competency will be validated through post-training assessments and periodic spot checks. 4. Enhanced Monitoring and Internal Audit - Monthly eligibility audits will be expanded to include a statistically valid sample size and documented review of Tribal enrollment verification. - Audit results will be formally reported to executive leadership, with identified deficiencies tracked through resolution. - Repeat errors or noncompliance will be addressed through corrective coaching and performance management, as appropriate. Management believes these enhanced corrective actions directly address the root cause of the finding by strengthening preventive controls, improving staff competency, and increasing oversight and accountability. Name of Responsible Party: Tempest Dawson, Director of Clinic Operations Anticipated Completion Date: December 31, 2026.

View Audit 400452

Finding 1211193 (2025-005)

Material Weakness 2025

Municipality of Añasco

PR

Subrecipient Monitoring Questioned Costs Period of Performance

In response to the Auditor’s recommendations, the Municipality will establish formal procedures to ensure that all required forms, including Form 90-91, are properly completed, maintained, and submitted in accordance with applicable grant requirements. Additionally, all supporting documentation rela...

In response to the Auditor’s recommendations, the Municipality will establish formal procedures to ensure that all required forms, including Form 90-91, are properly completed, maintained, and submitted in accordance with applicable grant requirements. Additionally, all supporting documentation related to the period of performance for each project will be identified, organized, and maintained, including approved project worksheets, grant award documentation, and related financial records. Furthermore, monitoring mechanisms and periodic reviews will be implemented to ensure ongoing compliance with applicable requirements and the timely availability of required documentation for audit and monitoring purposes.

View Audit 400405

Finding 1211191 (2025-003)

Material Weakness 2025

Municipality of Añasco

PR

Reporting Significant Deficiency § 200.12 § 200.508 § 200.510 § 200.512

The Municipality shall establish procedures, training programs, and internal controls to ensure compliance with the preparation and timely submission of the Single Audit Report to the Federal Audit Clearinghouse, as required by the OMB Super Circular Uniform Guidance and in accordance with the nine-...

The Municipality shall establish procedures, training programs, and internal controls to ensure compliance with the preparation and timely submission of the Single Audit Report to the Federal Audit Clearinghouse, as required by the OMB Super Circular Uniform Guidance and in accordance with the nine-month deadline established therein. In addition, the Department of Finance will monitor the progress of the work, including the preparation of financial statements, as well as the external audit and the single audit, so that for the fiscal year ending June 30, 2026, the reports are submitted by the established deadline of no later than March 31, 2027.

View Audit 400405

Finding 1211188 (2025-002)

Material Weakness 2025

Syntiro

ME

Reporting Questioned Costs Allowable Costs / Cost Principles § 200.302 § 200.403 § 200.405

We agree with the finding and we will be reviewing and implementing the recommendations accordingly. We are committed to ensuring no duplication of costs across reporting periods and compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan ...

We agree with the finding and we will be reviewing and implementing the recommendations accordingly. We are committed to ensuring no duplication of costs across reporting periods and compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.

View Audit 400399

Finding 1211029 (2025-001)

Material Weakness 2025

Kama'aina Care, Inc.

HI

Questioned Costs Subrecipient Monitoring Reporting § 200.329

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

View Audit 400308

Finding 1211018 (2025-003)

Material Weakness 2025

YWCA West Central Michigan

MI

Reporting Significant Deficiency Internal Control / Segregation of Duties § 200.328 § 200.329

Our program leadership are playing a more active role in reporting and compliance and are actively involving directors of programs in the process of reporting.

View Audit 400298

Finding 1210927 (2025-101)

Material Weakness 2025

Community Legal Services

AZ

Questioned Costs Reporting Significant Deficiency

CLS agrees with the finding. Notifications from the Legal Services Corporation regarding report due dates, including the TIG semiannual progress reports, will be forwarded to the responsible party. The responsible party will set a reminder one week before the due date on their calendar, as well as t...

CLS agrees with the finding. Notifications from the Legal Services Corporation regarding report due dates, including the TIG semiannual progress reports, will be forwarded to the responsible party. The responsible party will set a reminder one week before the due date on their calendar, as well as the due date. Due dates for all reports, including the TIG semi-annual progress reports, will be placed on the Operations Grant calendar. An agenda item will be added to the Operations Unit meeting to review the due dates for all reports due the following month.

View Audit 400268

Finding 1210920 (2025-003)

Material Weakness 2025

Family Guidance Center of Alabama, Inc.

AL

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency § 200.317 § 200.327

Corrective Action Plan: A new procurement policy was developed, reviewed, and formally approved by the Board of Directors on January 20, 2026. The policy establishes procurement procedures aligned with industry best practices and strengthens internal controls to ensure transparency, accountability, ...

Corrective Action Plan: A new procurement policy was developed, reviewed, and formally approved by the Board of Directors on January 20, 2026. The policy establishes procurement procedures aligned with industry best practices and strengthens internal controls to ensure transparency, accountability, and compliance with applicable requirements. Individual(s) Responsible: Yolanda Adams Completion Date: Policy was voted on by the board and put into place subsequent to year end.

View Audit 400248

Finding 1210909 (2025-002)

Material Weakness 2025

Family Guidance Center of Alabama, Inc.

AL

Reporting Subrecipient Monitoring Significant Deficiency

Corrective Action Plan: Training and ongoing education initiatives have been implemented to ensure reports are completed and submitted in accordance with established deadlines. The new Chief Financial Officer is actively monitoring report status and accuracy to ensure timely compliance. A defined re...

Corrective Action Plan: Training and ongoing education initiatives have been implemented to ensure reports are completed and submitted in accordance with established deadlines. The new Chief Financial Officer is actively monitoring report status and accuracy to ensure timely compliance. A defined reporting structure has been established to strengthen oversight, accountability, and adherence to all reporting requirements. Individual(s) Responsible: Yolanda Adams Completion Date: Plan has been implemented as of date of audit submission.

View Audit 400248

Finding 1210895 (2025-005)

Material Weakness 2025

Middle MacOupin Health Care Systems and Affiliates

IL

HUD Housing Programs Special Tests & Provisions Significant Deficiency

Federal Agency Name: Department of Housing and Urban Development Program Name: Section 242 – Mortgage Insurance - Hospitals Federal Financial Assistance Listing #: CFDA #14.128 Compliance Requirement: Special Tests and Provisions Finding Summary: During the fiscal year, the Organization entered into...

Federal Agency Name: Department of Housing and Urban Development Program Name: Section 242 – Mortgage Insurance - Hospitals Federal Financial Assistance Listing #: CFDA #14.128 Compliance Requirement: Special Tests and Provisions Finding Summary: During the fiscal year, the Organization entered into two new short term loans. A new loan is identified in the Mortgage Note Insured by HUD as the incurrence of additional indebtedness which, by terms of the agreement, should be approved by HUD in advance of entering into the loan agreement unless the loan meets certain requirements. If those requirements are met, then the Organization just needs to inform HUD of the new loan agreement. Responsible Individuals: Jay Hodges, Chief Financial Officer Corrective Action Plan: Management will enhance internal controls to ensure additional indebtedness is approved by HUD in advance of incurring such indebtedness. Anticipated Completion Date: April 29, 2026

View Audit 400243

Finding 1210827 (2025-003)

Material Weakness 2025

City of Austin

TX

Questioned Costs Reporting Significant Deficiency

Finding 2025-003: ALN 20.106 ABIA FAA, 3-48-0359-067-2021, 3-48-0359-071-2022, 3-48-0359-074-2024, 3-48-0359-073-2024, 3-48-0359-075-2024, 3-48-0359-077-2025, 3-48-0359-078-2025, 3-48-0359-079-2025, U.S. Department of Transportation — Significant Deficiency in Internal Control over Reporting and Fin...

Finding 2025-003: ALN 20.106 ABIA FAA, 3-48-0359-067-2021, 3-48-0359-071-2022, 3-48-0359-074-2024, 3-48-0359-073-2024, 3-48-0359-075-2024, 3-48-0359-077-2025, 3-48-0359-078-2025, 3-48-0359-079-2025, U.S. Department of Transportation — Significant Deficiency in Internal Control over Reporting and Finding of Non-compliance Contact Person – Lyn Estabrook, Deputy Chief, Airport Development Management Response – Concur. The Aviation Department has completed a thorough internal review of its FAA Airport Improvement Program (AIP) and other FAA grant reporting practices in response to the audit’s draft finding. This evaluation saw gaps in documentation and deadline management that contributed to delays and inconsistencies in required FAA performance reporting. While project updates were regularly communicated during monthly ADO coordination meetings and with Airport program wide written monthly reports these updates did not meet the FAA’s formal submission requirement for their written performance reports within 30 days of the close of each reporting period. To address these issues comprehensively and sustainably, the Department has already implemented significant process improvements, including the assignment of a dedicated Project Coordinator, formalization of reporting workflows, and establishment of a centralized reporting repository. The Division has also issued a fully documented FAA Grant Reporting Procedure and implemented annual mandatory training to ensure staff knowledge, consistency, and long-term compliance. These corrective actions are designed to prevent recurrence, enhance accountability, and ensure all future performance reports are completed, submitted, and documented in accordance with FAA requirements. See below write up of the Corrective Action Taken and Planned: 1. Project Coordinator Assigned: A dedicated Project Coordinator (PC) now manages report tracking, deadlines, and documentation control. 2. Annual Mandatory Training: • Training held February 5, 2026 • Annually recurring every October (new fiscal year) • Covers: o FAA forms o Deadlines o Submission requirements o Documentation standards 3. Formal 30 Day Reporting Controls: • Tracker auto calculates deadlines • PMs receive calendar invites and reminders at 21, 14, 7, and 3 days • FAA submissions now require CC to: o Project Coordinator o Airport Deputy Chief (Lyn Estabrook) o CIP Finance Manager (Cathy Brown) • Evidence of sent email placed in centralized repository 4. Centralized Evidence Repository: • All submitted forms, sent emails, and FAA acknowledgments stored in one location • Reduces risk of buried project files • Supports complete, auditable documentation 5. Procedure Issued: The FAA Grant Reporting Procedure has been issued and is now mandatory Division policy. 6. Timeline & Monitoring: • Immediate: Controls implemented in March 2026 • Next 90 Days: Review effectiveness after full quarterly cycle • Ongoing: o Annual training at beginning of the fiscal year o Quarterly internal reviews o Annual procedure update aligned to any FAA changes Estimated Completion – June 30, 2026.

View Audit 400108

Finding 1210811 (2025-002)

Material Weakness 2025

Augustana University Association

SD

Questioned Costs Student Financial Aid Reporting

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is...

National Student Loan Data System (NSLDS) Enrollment Reporting Recommendation: We recommend the University review its reporting procedures to ensure the students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting data wasn’t being sent timely to NSLDS, as a result of process and procedural changes at the University. With new personnel in positions and changing processes, management is confident in data feeding NSLDS within the 60 day period after thorough review of the process overall. This includes a remediation effort of IT data feeds to the NSLDS and the compilation of data. As the enrollment data is not sent on a daily/frequent basis, the next reporting cycle (coming month), the process will be investigated and triaged as necessary. Names of the contact persons responsible for corrective action: Josh Perkins, AVP – Finance/Admin; Kevin Klawonn, Director - IT Planned completion date for corrective action plan: 6/1/2026

View Audit 400089

Finding 1210804 (2025-001)

Material Weakness 2025

Augustana University Association

SD

Questioned Costs Student Financial Aid Reporting

Common Origination & Disbursement (COD) Reporting Recommendation: We recommend the University establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Act...

Common Origination & Disbursement (COD) Reporting Recommendation: We recommend the University establish a process to ensure that all disbursement information is accurately reported to the COD system. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The finding was ultimately caused by a syncing error of a batch job process that sends disbursement data to COD from our legacy (now retired) system that has since been replaced, as of October 2025. This was viewed as a one-off occurrence, not a broader systematic issue. The new system is better configured to accurately report disbursement information accurately. Further, Management has undergone a review of findings, and confirmed batch information is configured to send COD information accurately as of the finding notification date. Names of the contact persons responsible for corrective action: Josh Perkins, AVP – Finance/Admin; Kevin Klawonn, Director - IT Planned completion date for corrective action plan: April 30, 2026

View Audit 400089

Corrective Action Plans

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