Corrective Action Plans

Finding 1205065 (2025-010)

Material Weakness 2025

FL

Eligibility Significant Deficiency Internal Control / Segregation of Duties

High School Diploma or Equivalent Recommendation: We recommend that the District establish policies and procedures to ensure the completeness and accuracy of documentation to support the percentage of students that lack a high school diploma or its equivalent. Explanation of disagreement with audit ...

High School Diploma or Equivalent Recommendation: We recommend that the District establish policies and procedures to ensure the completeness and accuracy of documentation to support the percentage of students that lack a high school diploma or its equivalent. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will provide district-level training for registrar personnel on eligibility thresholds related to reporting ratios, including the percentage of students without a high school diploma or equivalent. Training will include guidance on required documentation, verification steps, and procedures to ensure the completeness and accuracy of supporting records. Updated procedures will be shared with all registrar staff to promote consistency across campuses and ensure compliance with reporting requirements. Responsible party: Registrar, Workforce Education Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: Workforce Education leadership will conduct monthly reviews to confirm that documentation supporting eligibility ratios is complete, accurate, and aligned with established procedures. Any discrepancies identified during monthly reviews will be addressed with registrar staff to ensure ongoing compliance and continuous improvement.

View Audit 396707

Finding 1205064 (2025-009)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Gramm-Leach-Bliley Act Recommendation: We recommend that the District update its written information security program to ensure it includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: ...

Gramm-Leach-Bliley Act Recommendation: We recommend that the District update its written information security program to ensure it includes all required elements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will review and update its written information security program to ensure all required elements are included and fully aligned with applicable state and federal requirements. Updates will be completed and implemented in coordination with the appropriate departments to ensure compliance and ongoing monitoring. Responsible party: Director of Network Operations & Senior Director of Information Services Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: • The Director of Network Operations and Senior Director of Information Services will conduct periodic reviews to verify that updates to the information security program are completed, documented, and implemented as intended. • Progress will be reviewed with relevant departments to ensure ongoing compliance and to address any gaps identified during implementation.

View Audit 396707

Finding 1205063 (2025-008)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Cash Management Material Weakness

240 Day Outstanding Payments Recommendation: We recommend the District implement a review process for outstanding student payments to ensure any that include Title IV funds are refunded to the U.S. Department of Education within 240 days. Explanation of disagreement with audit finding: There is no d...

240 Day Outstanding Payments Recommendation: We recommend the District implement a review process for outstanding student payments to ensure any that include Title IV funds are refunded to the U.S. Department of Education within 240 days. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The Financial Aid Coordinator will create and maintain a SharePoint spreadsheet to effectively track and monitor outstanding student payments. The Workforce Finance Department will support the setup and ensure the spreadsheet aligns with established financial monitoring practices. Responsible party: Financial Aid Coordinator and Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will conduct monthly reviews to ensure the spreadsheet is updated, accurate, and used consistently for monitoring outstanding payments.

View Audit 396707

Finding 1205062 (2025-007)

Material Weakness 2025

School District of Polk County, Florida

FL

Special Tests & Provisions Student Financial Aid Eligibility

Special Tests and Provisions Recommendation: It is recommended that the District strengthen its internal controls over the R2T4 calculation process by implementing a secondary review or quality-assurance check of scheduled clock hours prior to finalizing R2T4 calculations. Staff should receive targe...

Special Tests and Provisions Recommendation: It is recommended that the District strengthen its internal controls over the R2T4 calculation process by implementing a secondary review or quality-assurance check of scheduled clock hours prior to finalizing R2T4 calculations. Staff should receive targeted training on the requirements of 34 CFR § 668.22, particularly regarding the use of scheduled hours in determining earned aid and post-withdrawal disbursement eligibility. Additionally, standardized calculation worksheets or system-generated hour reports should be utilized to reduce reliance on manual entry and minimize the risk of human error. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: Financial Aid Coordinators from both technical colleges will collaborate to review and audit each other's RT24 calculations to ensure accuracy, accountability, and compliance with regulatory requirements. Responsible party: Financial Aid Coordinator Planned completion date for corrective action plan: April 1, 2026 Plan to monitor completion of corrective action plan: Monthly meetings with the Workforce Finance Department will be held to review RT24 calculations, address discrepancies, and confirm ongoing compliance.

View Audit 396707

Finding 1205061 (2025-006)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Eligibility Significant Deficiency

Return to Title IV Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement wit...

Return to Title IV Recommendation: We recommend that a process is put in place to ensure that all students are notified upon withdrawal they may be required to return federal award funds back to the Department of Education. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: The District will develop a letter in FOCUS that would automatically generate and notify all students when they are required to return funds to the Department of Education Responsible party: Financial Aid Coordinator, Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will conduct monthly reviews to confirm the automated notification process is functioning correctly and that required letters are being sent and documented.

View Audit 396707

Finding 1205059 (2025-004)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Title IV Credit Balances Recommendation: We recommend that the District review its policies and procedures for Title IV credit balances to ensure they are paid in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in resp...

Title IV Credit Balances Recommendation: We recommend that the District review its policies and procedures for Title IV credit balances to ensure they are paid in a timely manner. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: District has already implemented a plan by creating a drawdown process to ensure both the Financial Aid Coordinator and the Workforce Finance Department are in communication with each other. The drawdown process ensures that funds are received by the student in a timely manner (within 14 days) Responsible party: Financial Aid Coordinators, District Workforce Finance Department Planned completion date for corrective action plan: Task is completed Plan to monitor completion of corrective action plan: The Financial Aid Coordinator and Workforce Finance Department will hold monthly meetings to review the drawdown process and confirm continued compliance.

View Audit 396707

Finding 1205058 (2025-003)

Material Weakness 2025

School District of Polk County, Florida

FL

Eligibility Significant Deficiency Internal Control / Segregation of Duties

Eligibility Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in ...

Eligibility Recommendation: We recommend that a process be implemented to ensure the proper cost of attendance is used so that amounts awarded do not exceed calculated financial need. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: • The Financial Aid Coordinator will ensure that when a correction is made during the disbursement process a new award letter is created • If a change is made, the Financial Aid Coordinator will enter the required information and print out a new award letter and have the student sign the form. After the form is signed by the student, the Financial Aid Coordinator will have an administrator to verify the with signature • One administrator will attend Financial Aid training to one training session to support legal and regulatory compliance Responsible party: Financial Aid Coordinators, Administrators, Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: The Financial Aid Coordinators, Administrators, and Workforce Finance Department will conduct a monthly review to confirm that revised award letters are issued, signed, verified, and properly documented.

View Audit 396707

Finding 1205057 (2025-002)

Material Weakness 2025

School District of Polk County, Florida

FL

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Documentation of Monthly Reconciliation Recommendation: We recommend the District establish policies and procedures to ensure proper documentation of preparation and review of monthly Title IV reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit fi...

Documentation of Monthly Reconciliation Recommendation: We recommend the District establish policies and procedures to ensure proper documentation of preparation and review of monthly Title IV reconciliations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actions planned in response to finding: • The District will reconcile the institutional records with Pell funds monthly and maintain documentation and preparation of the reconciliation process • The Financial Aid Coordinator will be responsible for creating a SharePoint drive and maintaining the accuracy of the reconciliation process via SharePoint drive • Create a SharePoint so that when we have employee-related transitions, the newly assigned Financial Aid Coordinator will have access Responsible party: Financial Aid Coordinators and Workforce Finance Department Planned completion date for corrective action plan: April 30, 2026 Plan to monitor completion of corrective action plan: • The Financial Aid Coordinators and Workforce Finance Department will conduct a monthly review to confirm reconciliations are completed, documented, and properly approved. • Any issues identified during monthly reviews will be addressed promptly to ensure ongoing compliance.

View Audit 396707

Finding 1205013 (2025-001)

Material Weakness 2025

New London Homeless Hospitality Center, Inc.

CT

Allowable Costs / Cost Principles Cash Management Reporting

While all the costs reported to grantors were fully allowable per our contract, we continued to have some challenges in reflecting these costs in QuickBooks at the detailed level. We have implemented several accounting improvements that have addressed most of the differences between our cost reports...

While all the costs reported to grantors were fully allowable per our contract, we continued to have some challenges in reflecting these costs in QuickBooks at the detailed level. We have implemented several accounting improvements that have addressed most of the differences between our cost reports by contract and QuickBooks. We continue, however, to face challenges in allocating indirect costs (allowed by a contract) down to the level of individual contract accounts in QuickBooks. The second continuing challenge is allocation of certain fringe benefits such as employee savings match and contributions to Health Savings Accounts down to the contract level for staff who work on multiple contracts. In the past month we have added new staff with greater experience in accounting and are implementing new ongoing reviews that will assure that our QuickBooks information remains exactly in sync with our fiscal reports.

View Audit 396681

Finding 1204953 (2025-002)

Material Weakness 2025

Casa Blanca Community School, Inc.

AZ

School Nutrition Programs Subrecipient Monitoring Cash Management

Finding Numbers: 2025‐002 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Eloyce Gillespie, Business Manager Anticipated Completion Date: April 30, 2026 Planned Corrective Action: Casa Blanca Community School has imple...

Finding Numbers: 2025‐002 Program Name/Assistance Listing Title: Child Nutrition Cluster Assistance Listing Numbers: 10.553, 10.555, 10.559 Contact Person: Eloyce Gillespie, Business Manager Anticipated Completion Date: April 30, 2026 Planned Corrective Action: Casa Blanca Community School has implemented a review process to monitor expenditures across all funds. As part of this process, Management has adopted a review process relating to expenditures of all funds to minimize any negative effect on cash for these funds. This review includes a comparison of expenditures to budgets for all funds to ensure that they do not exceed anticipated revenues. Additionally, if it is determined that the program will exceed the anticipated revenue, Management will determine if such overages (negative cash balances) are to be addressed through operating transfers using Indian School Equalization Program funding.

View Audit 396606

Finding 1204950 (2025-001)

Material Weakness 2025

Innovative Health Solutions

CA

Reporting Significant Deficiency Internal Control / Segregation of Duties

Finding 2025-01 Internal Control Over Financial Reporting: Revenue Recognition Management concurs with the finding. The condition cited was an oversight and was missed during the transition process of bringing the accounting function in-house, which was previously outsourced to an outside firm. We w...

Finding 2025-01 Internal Control Over Financial Reporting: Revenue Recognition Management concurs with the finding. The condition cited was an oversight and was missed during the transition process of bringing the accounting function in-house, which was previously outsourced to an outside firm. We will perform a review of all promises to give transactions prior to closing the books to ensure proper revenue recognition.

View Audit 396574

Finding 1204949 (2025-002)

Material Weakness 2025

Innovative Health Solutions

CA

Reporting Cash Management Significant Deficiency

Finding 2025-02 Schedule of Expenditures of Federal Awards. Management concurs with the finding. We will continue to refine our process under GAAP reporting to reduce reconciling items.

View Audit 396574

Finding 1204947 (2025-001)

Material Weakness 2025

Garfield County School District No. 16

CO

Allowable Costs / Cost Principles School Nutrition Programs Cash Management § 200.302 § 200.403

Garfield County School District No. 16 respectfully submits the following corrective action plan for the year ended June 30, 2025. Finding 2025-001 Reporting Significant Deficiency in Internal Control over Compliance and Other Non-Compliance Corrective Action: The District agrees with the finding re...

Garfield County School District No. 16 respectfully submits the following corrective action plan for the year ended June 30, 2025. Finding 2025-001 Reporting Significant Deficiency in Internal Control over Compliance and Other Non-Compliance Corrective Action: The District agrees with the finding related to insufficient supporting documentation for the National School Lunch Program reimbursement claims, as it related to sack lunches/field meals. Personnel Responsible for Corrective Action: Jody Williams, Food Service Director Anticipated Completion Date: The District has corrected this issue as of the date of this report, and now requires formal written requests for all sack lunches/field meals, to ensure counts are properly documented.

View Audit 396571

Finding 1204941 (2025-001)

Material Weakness 2025

Mount Mary University, Inc.

WI

Student Financial Aid Reporting Significant Deficiency

U.S. Department of Education Mount Mary University respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 - June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered co...

U.S. Department of Education Mount Mary University respectfully submits the following corrective action plan for the year ended June 30, 2025. Audit period: July 01, 2024 - June 30, 2025 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT Our audit did not disclose any matters required to be reported in accordance with Government Auditing Standards. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS U.S. Department of Education 2025-001 Student Financial Aid Cluster – Assistance Listing No. 84.063 & 84.268 Recommendation: We recommend that the University reviews withdrawals monthly to ensure that the students are reported correctly to NSC and subsequently to NSLDS. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has submitted and reviewed the four students and have submitted corrections for incorrect statuses and effective dates. Name(s) of the contact person(s) responsible for corrective action: Brian Olson, Vice President of Finance and Administration Planned completion date for corrective action plan: June 30, 2026 *** If the U.S. Department of Education has questions regarding this plan, please call Brian Olson, Vice President of Finance and Administration, at 414-930-3139.

View Audit 396542

Finding 1204927 (2025-001)

Material Weakness 2025

Glen Oaks Community College

MI

Allowable Costs / Cost Principles Reporting Significant Deficiency

Improper Period Recognition of SEFA Expenses Auditor Description of Condition and Effect. During our testing of compliance and related controls, we identified instances where expenses covering service periods extending beyond the fiscal year under audit were recorded in full rather than prorated for...

Improper Period Recognition of SEFA Expenses Auditor Description of Condition and Effect. During our testing of compliance and related controls, we identified instances where expenses covering service periods extending beyond the fiscal year under audit were recorded in full rather than prorated for the portion incurred during the fiscal year. This resulted in an initial overstatement of expenses reported on the Schedule of Expenditures of Federal Awards (SEFA). Initial SEFA amounts were not accurately stated in accordance with accrual accounting requirements. Auditor Recommendation. We recommend the College implement procedures to ensure expenses are recorded in the proper period in accordance with GAAP and Uniform Guidance requirements. Corrective Action. The Controller will review supporting documentation during the completion of the SEFA, which will then be reviewed by a second, qualified individual to ensure GAAP is being followed and that expenses are only being recorded when incurred. Responsible Person. Jennifer Dodson, Controller Anticipated Completion Date. June 30, 2026

View Audit 396536

Finding 1204920 (2025-001)

Material Weakness 2025

Morenci Unified School District No. 18

AZ

School Nutrition Programs Cash Management Eligibility

2025-001 ELIGIBILITY Program: Child Nutrition Cluster CFDA Number: 10.533, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Type of Finding: Noncompliance, significant deficiency in internal control Compl...

2025-001 ELIGIBILITY Program: Child Nutrition Cluster CFDA Number: 10.533, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Type of Finding: Noncompliance, significant deficiency in internal control Compliance Requirement: E. Eligibility Criteria: Federal regulations require participating districts to determine student eligibility for free, reduced price, and paid meals based on household income and household size thresholds established annually by the U.S. Department of Agriculture. Applications must be reviewed and approved using the current income eligibility guidelines and appropriate calculation methods to ensure correct benefit levels. Condition: During testing of 25 student meal applications, we noted 1 instance where the District incorrectly calculated household income relative to household size when determining eligibility status. In these cases, students were approved for free price meals when the income calculations supported reduced meal status. Cause: The District did not have sufficient review controls in place to ensure that eligibility determinations were recalculated or independently verified prior to approval. Effect: As a result of the errors, certain students received free meal benefits for which they were not eligible. This may have resulted in improper program reimbursement claims and indicates that the District’s controls over eligibility determinations were not operating effectively. Questioned Costs: The projected questioned costs related to these errors are not expected to be material; however, the District may have received reimbursement at the free price rate rather than the reduced rate for affected meals. Corrective Action: The District will review their meal application process and implement a more stringent review to ensure eligibility criteria are met based on household income. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Erika Aguallo, Business Manager

View Audit 396523

Finding 1204917 (2025-001)

Material Weakness 2025

City of Madera

CA

Subrecipient Monitoring HUD Housing Programs Period of Performance

Finding 2025-001 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency) Criteria: Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet cri...

Finding 2025-001 Special Tests and Provision – Internal Control and Compliance over Environmental Reviews (Significant Deficiency) Criteria: Title 24 U.S. Code of Federal Regulations sections 58.1, 58.22, 58.34, 58.35, and 570.604 require projects to have an environmental review unless they meet criteria specified in the regulations that would exempt or exclude them from environmental certification requirements. For projects where the environmental review was not performed, a written documentation that the review was not required must be prepared. Condition and Context: The City could not provide support that there was pre-award or post-award review of grant projects to determine if a project requires an environmental review or is categorically excluded from the environmental review requirements. The City did not have adequate internal controls to ensure compliance with the special test – environmental review requirements. Testing was performed over each requirement for the City. Out of a total population of twelve (12) projects, we selected a sample of four (4) projects to test for environmental reviews. Four (4) out of the four (4) projects tested did not have an exemption report prepared in a timely manner. The sample was not intended to be, and was not, a statistically valid sample. City’s Corrective Action Plan: The City will reinforce its standard operating procedure concerning Environmental Reviews (ER) and will reinsure that environmental reviews are properly completed for every awarded grant project. Corrective Action Plan (Continued) Contact person responsible for corrective action: Michael Lima, Finance Director Anticipated completion date: June 30, 2026

View Audit 396513

Finding 1204907 (2025-001)

Material Weakness 2025

Town of Westport, Massachusetts

MA

Subrecipient Monitoring Reporting Significant Deficiency § 200.1

Finding 2025-001 Condition: Expenditures were not reconciled to the general ledger for reporting submitted to the U.S. Department of the Treasury and Bristol County, Massachusetts. Corrective Action Planned: To ensure the accuracy of ARPA reporting, and all Federal Grants, a reconciliation process w...

Finding 2025-001 Condition: Expenditures were not reconciled to the general ledger for reporting submitted to the U.S. Department of the Treasury and Bristol County, Massachusetts. Corrective Action Planned: To ensure the accuracy of ARPA reporting, and all Federal Grants, a reconciliation process will be implemented and followed by all involved. Anticipated Completion Date: April 30, 2026 Contact: Nicole Pearsall, Town Accountant

View Audit 396509

Finding 1204904 (2025-008)

Material Weakness 2025

County of Ventura

CA

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

Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirements...

Program: COVID-19 - Epidemiology and Laboratory Capacity for Infectious Disease (ELC) Assistance Listing No.: 93.323 Federal Grantor: U.S. Department of Health and Human Services Passed-through: California Department of Public Health Award No.: COVID-19ELC114 Award Year: 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Department’s Management Response: VCPH Management agrees with the recommendation for the Department to strengthen its policies and procedures to ensure all required reports are reviewed, approved and retained as evidence in the applicable grant folder. View of Responsible Officials and Corrective Action: VCPH Management will implement a requirement that all applicable reports must include documented review and approval (e.g. email approval, signed cover sheet, or workflow confirmation) before submission and retention of such approval evidence in the applicable grant folder location. Name of Responsible Persons: Maria Macias, Manager, VCPH Rigoberto Vargas, Director, VCPH Implementation Date: April 2026

View Audit 396507

Finding 1204900 (2025-005)

Material Weakness 2025

County of Ventura

CA

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

Program: Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Assistance Listing No.: 14.228 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Pass-Through California Department of Housing and Community Development Award No.: 17-MITP...

Program: Community Development Block Grants/State’s Program and Non-Entitlement Grants in Hawaii Assistance Listing No.: 14.228 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Pass-Through California Department of Housing and Community Development Award No.: 17-MITPPS-21029, 18-DRWD-23003, 21-CDBG-HK-0010 Award Year: 2022, 2024 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Department’s Management Response: Management agrees with the recommendation to revise its procedures to include evidence documenting the individual who reviewed and approved required reports prior to submission. View of Responsible Officials and Corrective Action: a. With regards to the CDBG-CV2 and CDBG-MIT reports managed by the County Executive Office Community Development Division, procedures were revised beginning in April 2025 due to prior year findings 2024-007 and 2024-008 to incorporate documented review and approval requirements for all applicable federally required reports. These enhanced internal controls are being phased in across all relevant reporting processes, with full implementation completed by the end of June 2025. These changes are intended to ensure that evidence of review and approval is consistently retained and that reporting is accurate, complete, and compliant with federal requirements. The reports identified in the finding were completed prior to the stated corrective action. b. With regards to the VC Heal Activity reports managed by Ventura County Workforce Development (VCWD) management, the required reports were prepared by the subrecipient (Career TEAM) using the standardized HCD format and underwent multiple levels of review, the County acknowledges that documentation of the specific individual review and approval prior to submission was not consistently retained. To strengthen internal controls to ensure all required reports include documented evidence of review and approval prior to submission, VCWD management will: • Implement a standardized review and approval protocol requiring documented sign‑off by designated VCWD management prior to submission. • Require Career TEAM to use a formal certification or routing process identifying the preparer and reviewer. • Maintain centralized documentation identifying the report preparer, reviewer/approver, and date of review. • Incorporate these requirements into internal procedures and contractor guidance. • Conduct periodic internal monitoring to verify compliance. Name of Responsible Persons: a. Kimberlee Albers, Deputy Executive Officer b. VCWD staff responsible for the CDBG program Career TEAM (Subrecipient – Report Preparation) Implementation Date: a. April – June 2025 b. April 2026

View Audit 396507

Finding 1204897 (2025-004)

Material Weakness 2025

County of Ventura

CA

Matching / Level of Effort / Earmarking Special Tests & Provisions Significant Deficiency § 200.303 § 200.326

Finding 2025-004 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-05...

Finding 2025-004 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, B-24-UC-06-0507, 95-6000807 Award Year: 2024 Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Department’s Management Response: The County Executive Office agrees with the recommendation to strengthen its internal controls to ensure compliance with wage rate requirements. View of Responsible Officials and Corrective Action: The County Executive Office Community Development Division will conduct a comprehensive review and update of its Federal Labor Standards Policy and Procedure (FLSPP), with completion targeted no later than July 1, 2026. The updated FLSPP will include a requirement for County staff to obtain and retain certified payroll submissions monthly for all construction activities subject to prevailing wage requirements. Although the formal policy update will not be effective until July 1, staff will begin implementing this control immediately. Name of Responsible Persons: Kimberlee Albers, Deputy Executive Officer Tracy McAulay, Housing Solutions Director Ying Vang, Management Analyst (Community Development Block Grant) Michael Skinner, Management Analyst (HOME Investment Partnerships Program) Implementation Date: April 2026

View Audit 396507

Finding 1204890 (2025-003)

Material Weakness 2025

County of Ventura

CA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

Finding 2025-003 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-05...

Finding 2025-003 Program: CDBG-Entitlement/Special Purpose Grants Cluster Assistance Listing No.: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Passed-through: Direct Award and Pass-Through City of San Buenaventura Award No.: B-20-UC-06-0507, B-20-UW-06-0507, B-21-UC-06-0507, B-22-UC-06-0507, B-23-UC-06-0507, B-24-UC-06-0507, 95-6000807 Award Year: 2024 Compliance Requirements: Reporting Type of Finding: Significant Deficiency in Internal Control Over Compliance Department’s Management Response: The County Executive Office Community Development Division agrees with the recommendation to revise its procedures to include evidence to document the individual who reviewed and approved required reports prior to submission. View of Responsible Officials and Corrective Action: Procedures were revised beginning in April 2025 due to prior year findings 2024-007 and 2024-008 to incorporate documented review and approval requirements for all applicable federally required reports. These enhanced internal controls are being phased in across all relevant reporting processes, with full implementation completed by the end of June 2025. These changes are intended to ensure that evidence of review and approval is consistently retained and that reporting is accurate, complete, and compliant with federal requirements. The reports identified in the finding were completed prior to the stated corrective action. Name of Responsible Persons: Kimberlee Albers, Deputy Executive Officer Implementation Date: April – June 2025

View Audit 396507

Finding 1204866 (2025-002)

Material Weakness 2025

Ohio Christian University

OH

Student Financial Aid Cash Management Significant Deficiency

Credit Balances Held Beyond Payment Period Planned Corrective Action: Ohio Christian University has implemented procedures to ensure that all Title IV credit balances are identified and released to students within 14 days of the credit balance occurring, in compliance with federal regulations. The F...

Credit Balances Held Beyond Payment Period Planned Corrective Action: Ohio Christian University has implemented procedures to ensure that all Title IV credit balances are identified and released to students within 14 days of the credit balance occurring, in compliance with federal regulations. The Financial Aid Office will run weekly credit balance reports following each disbursement to identify any student accounts with a Title IV credit balance. These reports will be reviewed jointly by the Financial Aid and Student Accounts offices to confirm eligibility and authorize timely refunds. As an ongoing quality assurance measure, supervisory review will be conducted monthly to verify compliance with the 14-day requirement, and any exceptions will be documented and addressed immediately. Staff training has been enhanced to reinforce regulatory requirements and internal timelines related to credit balance processing. Person Responsible for Corrective Action Plan: Justin Pichey, Director of Financial Aid & Chelsie Hedrick, Senior Accountant Anticipated Date of Completion: This was implemented starting with the Spring 2026 semester.

View Audit 396488

Finding 1204864 (2025-004)

Material Weakness 2025

Gila Crossing Community School

AZ

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Reporting

Finding Number: 2025‐004 Program Name/Assistance Listing Title: Indian School Equalization Program, Special Education Cluster (IDEA) Assistance Listing Number: 84.425, 84.027 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The Schoo...

Finding Number: 2025‐004 Program Name/Assistance Listing Title: Indian School Equalization Program, Special Education Cluster (IDEA) Assistance Listing Number: 84.425, 84.027 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School lacked adequate internal controls over disbursements, journal entries, and payroll. - Efforts to maintain proper supporting documentation for various transactions must improve.Staff training to highlight the importance of following procedures and maintaining supporting documentation for all transactions has already occurred and will be held multiple times in the future. - Two current employees have unusual employment status that makes recalculating their pay difficult; they are part‐time, but on salary.

View Audit 396487

Finding 1204856 (2025-001)

Material Weakness 2025

Gila Crossing Community School

AZ

Special Tests & Provisions Significant Deficiency

Finding Numbers: 2025‐001, 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School did not complete character ...

Finding Numbers: 2025‐001, 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Contact Person: Holena Lebron, Superintendent Anticipated Completion Date: June 30, 2026 Planned Corrective Action: The School did not complete character reinvestigations timely for all employees. - An internal review identified that employee suitability determinations and five‐year reinvestigations were not consistently tracked. - To address this, the administration will review all personnel files to identify employees who are due or overdue for reinvestigation. Any overdue determinations will be completed immediately. A tracking system will be implemented to monitor the five‐year requirement and ensure reinvestigations are completed on time moving forward. Periodic file reviews will also be conducted to maintain compliance.

View Audit 396487

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