Corrective Action Plans

Finding 1163077 (2024-003)

Material Weakness 2024

OR

Reporting Subrecipient Monitoring § 200.508 § 200.510

Finding 2024-003 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 84.010 Grants to Local Education Agencies (Title I) Name of Federal Agency: U.S. Depa...

Finding 2024-003 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 84.010 Grants to Local Education Agencies (Title I) Name of Federal Agency: U.S. Department of Education Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit on an untimely basis, and with values that were not reconciled with the general ledger. Cause: The District staff had insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incorrectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditor's correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following:  SEFA was originally presented for auditors with incorrect information.  SEFA was not presented for auditors on a timely basis.  No reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFA reports. Planned Implementation Date: August 1, 2025 Responsible Person: Director of Business Services, Yamhill County School District No. 8

View Audit 372646

Finding 1163060 (2024-001)

Material Weakness 2024

Town of York

ME

Procurement, Suspension & Debarment Subrecipient Monitoring

Management’s response/corrective action plan: YSD acknowledges the deficiency and attributes it to a lack of knowledge on the part of the Special Education group for this requirement. The appropriate personnel have been notified and have been provided sufficient training materials to address this is...

Management’s response/corrective action plan: YSD acknowledges the deficiency and attributes it to a lack of knowledge on the part of the Special Education group for this requirement. The appropriate personnel have been notified and have been provided sufficient training materials to address this issue. It is, however, possible that since this finding covers only the FY24 fiscal year, that additional violations have occurred in the FY25 fiscal year.

View Audit 372626

Finding 1163018 (2024-001)

Material Weakness 2024

Community Based Public Safety Collective, Inc.

NJ

Subrecipient Monitoring Period of Performance Reporting § 200.512

Auditors Recommendation: CBPSC should ensure that its records are completed and reconciled in a timely manner, so that the single audit can be performed and completed on time, and the reporting package and data collections form can be submitted before the deadline. Corrective Action Plan: Management...

Auditors Recommendation: CBPSC should ensure that its records are completed and reconciled in a timely manner, so that the single audit can be performed and completed on time, and the reporting package and data collections form can be submitted before the deadline. Corrective Action Plan: Management acknowledges that the reporting package and Data Collection Form for the 2023 audit were not filed by the required September 30, 2024 deadline. Management also acknowledges that this finding will appear for the next audit year, however to correct this and prevent recurrence of this issue the organization has implemented the following actions: Established external filing deadlines. Enhanced monitoring and tracking. Assignment of oversight responsibility. Improved coordination with external auditors. Staff Training. Anticipation Completion Date: These corrective actions were initiated in the 2025 fiscal year and will be fully in place for the 2025 audit cycle, ensuring timely submission by September 30. 2026 Management Statement: Management believes these corrective steps will ensure full compliance with federal reporting requirements going forward and prevent recurrence of late submissions. Responsible Individual: Managing Director, Fred Fogg

View Audit 372614

Finding 1163003 (2024-003)

Material Weakness 2024

Barry County, Missouri

MO

Subrecipient Monitoring § 200.1 § 200.331 § 200.332

The County has created a filing system for recipients of SLFRF funds and a calendar set to send reminder notices to get receipts and other information from recipients. The reminders will be set in 3 month increments from the time funds are awarded to recipient. Implementation will begin January 1, 2...

The County has created a filing system for recipients of SLFRF funds and a calendar set to send reminder notices to get receipts and other information from recipients. The reminders will be set in 3 month increments from the time funds are awarded to recipient. Implementation will begin January 1, 2026 with reminder notices set in calendar.

View Audit 372593

Finding 1163001 (2024-001)

Material Weakness 2024

Barry County, Missouri

MO

Subrecipient Monitoring Reporting Cash Management

The County Clerk and Treasurer will work with the accounts payable department to update and create spreadsheets and schedule a mid-year review of SEFA funds and grants. Implementation of spreadsheets is in progress and expected to be fully implemented by June 1, 2026.

View Audit 372593

Finding 1162992 (2024-003)

Material Weakness 2024

Red Lake County

MN

Subrecipient Monitoring

Summary of Corrective Action Previously Reported: The County will take corrective action to ensure compliance with federal subrecipient monitoring requirements and will review its procedures to ensure that all future subrecipient agreements include proper documentation of monitoring activities, incl...

Summary of Corrective Action Previously Reported: The County will take corrective action to ensure compliance with federal subrecipient monitoring requirements and will review its procedures to ensure that all future subrecipient agreements include proper documentation of monitoring activities, including communication of award terms, risk assessments, and verification that funds are expended in accordance with federal requirements. Anticipated Completion Date: December 31, 2025.

View Audit 372590

Finding 1162906 (2024-008)

Material Weakness 2024

City of Peabody

MA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2026, as well as into future periods.

View Audit 372554 Questioned Costs: $1

Finding 1162893 (2024-006)

Material Weakness 2024

City of Peabody

MA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2026, as well as into future periods.

View Audit 372554 Questioned Costs: $1

Finding 1162890 (2024-005)

Material Weakness 2024

City of Peabody

MA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2026, as well as into future periods.

View Audit 372554 Questioned Costs: $1

Finding 1162880 (2024-002)

Material Weakness 2024

City of Hempstead, Texas

TX

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303 § 200.328

Finding 2024-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management agrees with the finding and will establish a formal review and approval process for all Section 3 quarterly and annual reports prepared and submitted by...

Finding 2024-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management agrees with the finding and will establish a formal review and approval process for all Section 3 quarterly and annual reports prepared and submitted by the grant administrator to the Texas General Land Office. Going forward, the City Secretary will review each report for accuracy and completeness prior to submission, and evidence of this review, such as signed approval or email confirmation, will be retained in the grant files. The City anticipates implementing this procedure for all future reporting periods to ensure compliance with federal reporting and internal control requirements. Anticipated Completion Date: December 2025

View Audit 372549

Finding 1162878 (2024-001)

Material Weakness 2024

Portage County

OH

Reporting Subrecipient Monitoring § 200.328

The Mental Health and Recovery Board of Portage County will submit program final expenditures in the GFMS system within the grant close-out reporting period.

View Audit 372539

Finding 1162849 (2024-003)

Material Weakness 2024

Kitsap Rescue Mission

WA

Subrecipient Monitoring Procurement, Suspension & Debarment Cash Management § 200.302

Condition: Management did not retain evidence of the execution of the Organization’s internal controls over the review and or authorization of the payment or reimbursement of credit card charges during the year. Recommendation: Management should document the review and/or authorization of credit car...

Condition: Management did not retain evidence of the execution of the Organization’s internal controls over the review and or authorization of the payment or reimbursement of credit card charges during the year. Recommendation: Management should document the review and/or authorization of credit card charges and reimbursement. Views of responsible officials: The Organization will adopt a new policy on corporate credit cards with the following general provisions. Corporate credit cards may only be issued to the Executive Director and, if approved by the Executive Director, to the heads of shelter operations, and the Organization’s Accountant. All charges shall be made solely for goods or services for the use or benefit of the Organization. Use of the credit card for the purchase of gift cards or recurring automatic transactions can only be made by the Executive Director or the Organization’s Accountant after approval by Executive Director. Receipts shall be provided to the internal accountant monthly by the 5th day of the following month. The internal accountant shall prepare a summary of all charges highlighting any 1) that are not supported by a receipt, or 2) appear questionable, and also an allocation of each charge to the appropriate expense category for financial reporting. The summary and the credit card statement shall be provided to the Executive Director for review and approval. The Executive Director will spot check actual receipt documentation for credit card2 purchases of the Organization’s Accountant and the Shelter Director. In the case of the credit card used by the Executive Director, the summary and statement shall be reviewed and approved by the Treasurer or Board President. Any improper or unsupported transaction shall create a reimbursement obligation by the card holder to the Organization. Misuse of the credit card shall be a cause for discipline in accordance with the employment manual.

View Audit 372514

Finding 1162832 (2024-001)

Material Weakness 2024

The Booker T. Washington Community Center of Auburn, N.y., Inc.

NY

Subrecipient Monitoring Reporting § 200.512

Response: We agree with the finding presented by the auditors. The Organization’s annual financial statements have been delayed due to turn over in staff. The Organization has also hired a new bookkeeper and doesn’t anticipate delays to continue in the future. Responsible Party: Denise Farrington, E...

Response: We agree with the finding presented by the auditors. The Organization’s annual financial statements have been delayed due to turn over in staff. The Organization has also hired a new bookkeeper and doesn’t anticipate delays to continue in the future. Responsible Party: Denise Farrington, Executive Director Estimated Completion: 12/31/25

View Audit 372495

Finding 1162807 (2024-005)

Material Weakness 2024

Green Lake County

WI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.320

Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over susp...

Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants. Name(s) of the contact person(s) responsible for corrective action: Jason Jerome Planned completion date for corrective action plan: December 31, 2025

View Audit 372450

Finding 1162801 (2024-002)

Material Weakness 2024

TOWN OF CHESTER

MA

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

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: The Town plans to draft and adopt policies. Anticipated Completion Date: 12/31/2025 Contact: Andrew Alward, Town Administrator

View Audit 372434

Finding 1162799 (2024-011)

Material Weakness 2024

Micronesian Legal Services Corporation

MP

Internal Control / Segregation of Duties Subrecipient Monitoring

Management’s Response and Corrective Action Plan: MLSC management acknowledges the finding and concurs with the auditor’s recommendation. Management would like to note that MSLC has an existing Petty Cash Policy, which was recently updated and approved by the Board of Directors to ensure full compli...

Management’s Response and Corrective Action Plan: MLSC management acknowledges the finding and concurs with the auditor’s recommendation. Management would like to note that MSLC has an existing Petty Cash Policy, which was recently updated and approved by the Board of Directors to ensure full compliance with LSC Financial Guide §3.2.5 that address the following: • Segregation of duties • Required monthly reconciliation of all petty cash funds • Allowable use of petty cash • Documentation necessary to support each petty cash disbursement • Procedures to follow in the event of overage or shortage in the fund Responsible person: Chief Fiscal Officer, Jocelyn Mallari Corrective action planned: The updated Petty Cash Policy is immediately implemented to strengthen internal control, ensure accountability, and prevent future loss or mismanagement. A monthly petty cash reconciliations for each office is scheduled. These corrective actions will ensure compliance with LSC requirements Anticipated completion date: Completed

View Audit 372427

Finding 1162797 (2024-009)

Material Weakness 2024

Micronesian Legal Services Corporation

MP

Subrecipient Monitoring Significant Deficiency

Management’s Response and Corrective Action Plan: See the response on finding 2024-009

View Audit 372427

Finding 1162796 (2024-008)

Material Weakness 2024

Micronesian Legal Services Corporation

MP

Subrecipient Monitoring Significant Deficiency

Management’s Response and Corrective Action Plan: Management agrees, and has addressed this as follows: Responsible person: Lee Pliscou MLSC Board of Directors approved a revised accounting manual in October 2025 which requires an annual cybersecurity assessment and response in compliance with LSC F...

Management’s Response and Corrective Action Plan: Management agrees, and has addressed this as follows: Responsible person: Lee Pliscou MLSC Board of Directors approved a revised accounting manual in October 2025 which requires an annual cybersecurity assessment and response in compliance with LSC Financial Guide § 2.5.3, together with a formal risk assessment of banking operations to identify and address vulnerabilities, as required by LSC Financial Guide § 3.2.1. Specifically, our cybersecurity policies include the following requirements: ● Perform (and document) an annual risk assessment ● Resolve any risk findings or conclusions ● Maintain physical access controls for servers and storage rooms ● Develop and periodically test an emergency disaster prevention and recovery plan ● Perform regular back up of electronic records and systems stored offsite or in a virtual environment with easy-to-use restoration options ● Formally assign computer and data security responsibilities The risk assessment process: ● Identifies the physical and digital assets susceptible to cyberattacks ● Identifies risks to those assets (risks should be evaluated annually for changes) ● Evaluates the risks (e.g., high, medium, or low) based on likelihood and impact ● Documents the results of the risk assessment, including the development and implementation of appropriate controls Finding 2024-008 LSC Financial Guide § 2.5.3 Electronic Data Processing and Cybersecurity, continued Also, per our new Accounting Manual, MLSC conducts a risk assessment of its electronic banking policies and procedures to identify areas that need additional safeguards and protections. We do this in conjunction with the annual cybersecurity risk assessment. As of November 2025, MLSC has contracted with a consultant to provide such an assessment, and the contractor has delivered a first draft of an assessment. Anticipated completion date: MLSC has already completed the requirement to have policies in compliance with LSC Financial Guide Sections 2.5.3 (Electronic Data Processing and Cybersecurity) and 3.2.1 (Bank accounts). MLSC will complete the annual assessment by February 28, 2026.

View Audit 372427

Finding 1162793 (2024-005)

Material Weakness 2024

Micronesian Legal Services Corporation

MP

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency

Management’s Response and Corrective Action Plan: Management agrees. Responsible person: Executive Director Lee Pliscou Corrective action planned: This has been corrected as of October 2025. MLSC Board of Directors approved a revised MLSC Accounting Manual with updates intended to comply with LSC’s ...

Management’s Response and Corrective Action Plan: Management agrees. Responsible person: Executive Director Lee Pliscou Corrective action planned: This has been corrected as of October 2025. MLSC Board of Directors approved a revised MLSC Accounting Manual with updates intended to comply with LSC’s Financial Guide on cost allocation. In particular, our new cost allocation policy addresses: ● Direct and indirect cost definitions ● Direct cost allocation methodology ● Indirect cost allocation methodology including allocation bases (total direct costs) ● Frequency of allocation (annual) ● Who conducts the allocation and who performs the review (Chief Fiscal Officer, Executive Director) ● Documentation requirements to support the allocation (calculation work papers) ● Reconciliation process related to salaries and wages directly charged to LSC grants and contracts ● Methodology to address “exception for certain indirect costs.” Anticipated completion date: Completed.

View Audit 372427

Finding 1162756 (2024-004)

Material Weakness 2024

Hope Village - Tiny Housing Alternatives, Inc.

WI

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

Finding Number: 2024-004 Failure to Identify Single Audit Requirement Views of Responsible Officials and Corrective Action: The Organization was not explicitly made aware of the Uniform Guidance requirements and mistakenly assumed that since this originated from the state, it was state funding. The ...

Finding Number: 2024-004 Failure to Identify Single Audit Requirement Views of Responsible Officials and Corrective Action: The Organization was not explicitly made aware of the Uniform Guidance requirements and mistakenly assumed that since this originated from the state, it was state funding. The Organization is aware of this situation and will create and implement a formal process to review federal and state expenditures incurred and evaluate whether there are state or federal compliance audit implications for all government grants upon signing the agreement. We will then proactively communicate this with our auditor so that plans can be made to perform the applicable compliance audit. We do not view this as an ongoing deficiency, and we deem our corrective action plan to be one that fully addresses this control deficiency. Name of Responsible Person: Mike Cohoon, Executive Director Projected Implementation Date: December, 2025

View Audit 372385

Finding 1162717 (2024-005)

Material Weakness 2024

Dreaming Out Loud, Inc.

DC

Subrecipient Monitoring Internal Control / Segregation of Duties Cash Management

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. We are going to review, strengthen, and more closely supervise all of our accounting procedures including response time to the Development Team’s requests for reports. We are also engaging in discussions about ...

Views of Responsible Officials: We agree with the auditor’s findings and recommendations. We are going to review, strengthen, and more closely supervise all of our accounting procedures including response time to the Development Team’s requests for reports. We are also engaging in discussions about how and when the Development Team requests information for the needed reports. A Grant Manager has been hired and we hope that Grantseeker, our grant tracking program, can be utilized more effectively which include tracking reporting timelines.

View Audit 372349

Finding 1162696 (2024-001)

Material Weakness 2024

Town of Southold

NY

Subrecipient Monitoring § 200.332

Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requir...

Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requirements at the time of subaward, including the Federal award identification, all compliance requirements, and any additional terms and conditions imposed by the pass-through entity. The Town did not execute a formal subrecipient agreement with Fishers Island Ferry District, to whom federal funds were passed through during the audit period. Specifically, no written agreement was in place outlining the subrecipient’s responsibilities, applicable compliance requirements, or the terms and conditions of the award. Recommendation: We recommend that the Town develop and implement procedures to ensure that formal written subrecipient agreements are executed prior to the disbursement of federal funds. These agreements should contain all elements required by 2 CFR § 200.332(a), including the identification of the federal award, applicable compliance requirements, and any additional terms and conditions. Corrective Action Plan: In coordination with the Supervisor’s office, Town Attorney’s office, and Comptroller’s office, formal subrecipient agreements will be prepared and executed, with adoption of Town Board resolutions, between the Town of Southold and pass-through entities concurrently as Federal grant contracts are awarded, as applicable. Responsible Individual: Albert J. Krupski Jr., Town Supervisor Paul DeChance, Town Attorney Michelle Nickonovitz, Town Comptroller Planned Date of Implementation: Corrective action plan procedures have already been communicated and implemented to ensure that formal written subrecipient agreements with pass-through entities are executed prior to the disbursement of federal funds.

View Audit 372332

Finding 1162689 (2024-005)

Material Weakness 2024

American Indian Higher Education Consortium

VA

Subrecipient Monitoring

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator

View Audit 372326

Finding 1162669 (2024-003)

Material Weakness 2024

American Indian Higher Education Consortium

VA

Reporting Subrecipient Monitoring

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator

View Audit 372326

Finding 1162656 (2024-001)

Material Weakness 2024

The Baltimore Station, Inc.

MD

Reporting Subrecipient Monitoring

1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accura...

1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accuracy prior to submission. 3. Assigned dedicated staff oversight for federal financial reporting, with cross-training implemented to strengthen continuity and mitigate risk in the event of staff turnover. 4. Conducted periodic evaluations of the reporting process, incorporating feedback and lessons learned from prior submissions, monitoring visits, and audit findings to drive ongoing improvements. 5. Reviewed and updated internal financial policies and procedures to align with current federal reporting requirements and best practices, with updates formally documented and disseminated to staff.

View Audit 372318

Corrective Action Plans

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