Corrective Action Plans

Finding 1161451 (2024-002)

Material Weakness 2024

TX

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Management acknowledges that there have been challenges with the preparation of the September 30, 2024 financial statements due mainly to the implementation of a new accounting system in January 2024. Three months’ data was recorded in the legacy software system with nine months in the new system. A...

Management acknowledges that there have been challenges with the preparation of the September 30, 2024 financial statements due mainly to the implementation of a new accounting system in January 2024. Three months’ data was recorded in the legacy software system with nine months in the new system. Additionally, implementation of data from the old system to the new system did not mirror each other due to prior management decisions that were made, and so a software consultant was hired to convert all the newly converted data into the old, legacy format. This created duplicate journal entries that took time to identify and correct. These issues have since been resolved. Closing of future fiscal years should not encounter these same challenges. There were additional challenges with the recording of grants. In fiscal year 2024, management of grants had been mainly decentralized. There was a grants department who was responsible for some grants; a grants position in the County Auditor’s office who was responsible for other grants; and the management of even other grants being outsourced to an outside consultant. The Commissioners Court recognized the issues that this caused, and for fiscal year 2026, the grants department has been disbanded. The function of that department will be centralized with the outside consultant – with management oversight by a county employee. The financial recording will be centralized in the County Auditor’s office by an accountant who will be adequately trained in the accounting for grants. The position is currently being advertised, with a hire date of no later than November 30, 2025 being anticipated.

View Audit 371344

Finding 1161437 (2024-006)

Material Weakness 2024

City of Auburn, Maine

ME

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Management Response/Corrective Action Plan: Additional reports will be run to verify totals before filings of quarterly reports, paying particular attention to end of year and the needed reversal of the prior year payroll accrual. Errors found in reports will be corrected in subsequent records as al...

Management Response/Corrective Action Plan: Additional reports will be run to verify totals before filings of quarterly reports, paying particular attention to end of year and the needed reversal of the prior year payroll accrual. Errors found in reports will be corrected in subsequent records as allowable under Department of Treasury grant reporting guidelines.

View Audit 371295

Finding 1161436 (2024-011)

Material Weakness 2024

City of Auburn, Maine

ME

Subrecipient Monitoring § 200.331 § 200.332

Management Response/Corrective Action Plan: During the audit period, the City monitored subrecipient performance through the review of required supporting documentation submitted with each individual fund requisition and draw request. This process provided assurance that costs charged to the program...

Management Response/Corrective Action Plan: During the audit period, the City monitored subrecipient performance through the review of required supporting documentation submitted with each individual fund requisition and draw request. This process provided assurance that costs charged to the program were eligible and supported. The City also self identified one instance within this process where a consortium member subrecipient did not complete a Single Audit as required. City staff consulted with HUD on this matter and were advised by HUD staff to continue processing payments while HUD worked directly with the subrecipient to bring them back into compliance.

View Audit 371295

Finding 1161415 (2024-011)

Material Weakness 2024

Wittenberg University

OH

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

This finding was related to staff turnover within the various offices involved in the annual A-133 compliance audit as noted in previous findings. The hiring of qualified staff properly trained should avoid this finding going forward. Implementation of the corrective action plan is expected to be co...

This finding was related to staff turnover within the various offices involved in the annual A-133 compliance audit as noted in previous findings. The hiring of qualified staff properly trained should avoid this finding going forward. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

View Audit 371273

Finding 1161411 (2024-009)

Material Weakness 2024

Wittenberg University

OH

Questioned Costs Student Financial Aid Subrecipient Monitoring

The Financial Aid and Registrar’s Offices are refining the withdrawal notification and reconciliation process to ensure that both official and unofficial withdrawals are accurately identified and routed for R2T4 calculation within the required timeframe. All identified cases were reviewed, corrected...

The Financial Aid and Registrar’s Offices are refining the withdrawal notification and reconciliation process to ensure that both official and unofficial withdrawals are accurately identified and routed for R2T4 calculation within the required timeframe. All identified cases were reviewed, corrected, and documented. The funds totaling $31,830 (Direct Loans) and $3,499 (Pell Grants) have been returned, and student accounts were reconciled accordingly. The Financial Aid Office, in coordination with the Information Technology team, is reviewing the SIS configuration to determine why certain Fall 2024 calculations were one day off, despite correct data entry. Adjustments will be made to eliminate any system-level rounding or timestamp discrepancies that could affect future calculations. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

View Audit 371273 Questioned Costs: $1

Finding 1161410 (2024-008)

Material Weakness 2024

Wittenberg University

OH

Subrecipient Monitoring

Wittenberg University will continue to perform a comprehensive review of its current information security program and practices to address the identified deficiencies under the Gramm Leach Bliley Act (GLBA) Safeguards Rule. The Chief Information Officer and Chief Information Security Officer are res...

Wittenberg University will continue to perform a comprehensive review of its current information security program and practices to address the identified deficiencies under the Gramm Leach Bliley Act (GLBA) Safeguards Rule. The Chief Information Officer and Chief Information Security Officer are responsible for overseeing the development and implementation of a documented quality assurance process. These processes will include: • Implementing encryption protocols for all customer data, both at rest and in transit. • Conducting and documenting periodic inventories of sensitive data to ensure accurate tracking and protection. • Enhancing the annual risk assessment process to verify that all required elements are satisfactorily implemented, with clear action steps and follow-up procedures. • Developing and maintaining administrative, technical, and physical safeguards as outlined by GLBA requirements, supported by ongoing staff training and awareness programs. • Establishing continuous monitoring and internal audit procedures to regularly assess compliance and effectiveness of controls, with results reported to senior management. Implementation of these corrective actions will begin immediately, with full completion targeted for 9/30/2026. Progress will be tracked, and any issues identified will be addressed promptly to ensure sustained compliance and mitigate risk of future findings. Responsible Party Candice Santell CIO

View Audit 371273

Finding 1161409 (2024-006)

Material Weakness 2024

Wittenberg University

OH

Student Financial Aid Subrecipient Monitoring Eligibility

The discrepancies identified were the result of inconsistencies between internal student records and data transmitted to COD for Direct Loan origination. These errors occurred due to manual data entry and timing differences between updates made in the institution’s student information system (SIS) a...

The discrepancies identified were the result of inconsistencies between internal student records and data transmitted to COD for Direct Loan origination. These errors occurred due to manual data entry and timing differences between updates made in the institution’s student information system (SIS) and those reflected in COD. Financial Aid staff received refresher training on Direct Loan data accuracy, COD reporting requirements, and verification procedures to ensure consistent documentation and communication between systems. Collaboration with IT Office is underway to establish automated data checks between the SIS and COD files to minimize the risk of future mismatches. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

View Audit 371273

Finding 1161407 (2024-004)

Material Weakness 2024

Wittenberg University

OH

Subrecipient Monitoring Internal Control / Segregation of Duties

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Part...

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

View Audit 371273

Finding 1161400 (2024-010)

Material Weakness 2024

Wittenberg University

OH

Student Financial Aid Subrecipient Monitoring Matching / Level of Effort / Earmarking

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. The Perkins program has ended and it is also likely that any personnel involved in the active years left y...

This finding was related to staff turnover within the financial aid, student accounts and business offices. The hiring of qualified staff properly trained should avoid this error going forward. The Perkins program has ended and it is also likely that any personnel involved in the active years left years ago. We are currently working with UAS to reassign our Perkins portfolio back to the U.S. Department of Education. Implementation of the corrective action plan is expected to be complete by June 30, 2026. Responsible Party Robert Rood Interim Vice President Finance and Administration

View Audit 371273

Finding 1161284 (2024-002)

Material Weakness 2024

Association of Village Council Presidents Regional Housing Authority

AK

Subrecipient Monitoring

Finding 2024-002 Material Weakness in Internal control Over Compliance and Material Noncompliance – Reporting Questioned Programs ALN 15.022 Tribal Self Governance Agencies: Department of Interior Award Numbers GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 G...

Finding 2024-002 Material Weakness in Internal control Over Compliance and Material Noncompliance – Reporting Questioned Programs ALN 15.022 Tribal Self Governance Agencies: Department of Interior Award Numbers GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 Condition Subaward data for all TSG sub-recipients were not reported per the requirements of the Federal Funding Accountability and Transparency Act (FFATA). Status Completed as of September 2025 Management’s Corrective Action Plan AVCP reviewed its policy and procedures to ensure it was current. In addition to policy and procedures review, AVCP drafted flow charts that outline the process and defines roles and responsibility of all employees involved in the process. Finally, AVCP provided training in the subaward policy for employees involved in the subaward process, with emphasis on the FFATA reporting requirements and roles and responsibilities.

View Audit 371211

Finding 1161279 (2024-002)

Material Weakness 2024

New Hampshire Children's Trust

NH

Subrecipient Monitoring Reporting Significant Deficiency § 200.329

Director of Operations & Impact will draft an 18-month reporting deliverables schedule to be reviewed quarterly. The schedule of reporting deliverables will be added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications ...

Director of Operations & Impact will draft an 18-month reporting deliverables schedule to be reviewed quarterly. The schedule of reporting deliverables will be added to a dedicated calendar in SharePoint, shared with the President and programs team staff, and a series of reminders and notifications will be integrated into the system. The system itself will be reviewed every six months going forward to address any technological issues and make recommendations for improved functionality. Planned Implementation Date of Corrective Action: 9/22/25 Person Responsible for Corrective Action: Director of Operations & Impact

View Audit 371198

Finding 1161277 (2024-001)

Material Weakness 2024

New Hampshire Children's Trust

NH

Subrecipient Monitoring § 200.332

Update Financial Policies and Procedures to reflect language surrounding areas of deficiency, specifically listed in 2 CFR 200.332(b). New subrecipients awards will include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, as...

Update Financial Policies and Procedures to reflect language surrounding areas of deficiency, specifically listed in 2 CFR 200.332(b). New subrecipients awards will include: subrecipient’s unique entity identifier, federal award identification number, federal award date, assistance listing title, assistance listing number, dollar amount available under each federal award and assistance listing number at the time of disbursement, and approved indirect cost rate. This was found during the 2023 single-audit, with the corrective action implemented for contracts starting after 7/14/25. Planned Implementation Date of Corrective Action: 7/14/25, will be included in Financial Policies revisions in December 2025. Person Responsible for Corrective Action: Director of Finance

View Audit 371198

Finding 1161175 (2024-004)

Material Weakness 2024

Thornton Township High School District 205

IL

Reporting Subrecipient Monitoring

Condition: The District did not comply with the requirements of filing period, quarterly, and final reports by the due dates set by ISBE. A total of 4 reports were filed late. Plan: The Business Office will install stricter controls over grants and grant reporting to ensure these findings are fixed....

Condition: The District did not comply with the requirements of filing period, quarterly, and final reports by the due dates set by ISBE. A total of 4 reports were filed late. Plan: The Business Office will install stricter controls over grants and grant reporting to ensure these findings are fixed. Due to the late completion date of this audit, the results will not be seen until the FY26 audit. Anticipated Date of Completion: June 30, 2026 Name of Contact Person: Dr. Albert Holmes

View Audit 371179

Finding 1161166 (2024-005)

Material Weakness 2024

City of Perris

CA

Subrecipient Monitoring Reporting

The City has engaged a consultant to, among other CDBG duties, help with the FFATA reporting compliance. The corrective action will be fully implemented during the Fiscal Year 2025/2026 audit. The contact person for this corrective action is Sabrina Chavez Director of Public Services of the City of ...

The City has engaged a consultant to, among other CDBG duties, help with the FFATA reporting compliance. The corrective action will be fully implemented during the Fiscal Year 2025/2026 audit. The contact person for this corrective action is Sabrina Chavez Director of Public Services of the City of Perris.

View Audit 371177

Finding 1161158 (2024-002)

Material Weakness 2024

Walla Walla County

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Walla Walla County is taking significant steps to address the recent audit finding regarding inadequate internal controls for compliance with federal requirements. Development of a New Policy To rectify this issue, the county is committed to formulating a new policy specifically tailored to meet fed...

Walla Walla County is taking significant steps to address the recent audit finding regarding inadequate internal controls for compliance with federal requirements. Development of a New Policy To rectify this issue, the county is committed to formulating a new policy specifically tailored to meet federal standards. This development process is already in motion, with the expected completion date set for December 2025. Enhancing Internal Controls We believe that the new policy will significantly improve our internal controls and ensure full compliance with federal mandates. Training Initiatives Additionally, we will seek training opportunities to increase the knowledge of all staff regarding federal programs and compliance requirements, ensuring adherence to these programs and grants.

View Audit 371174

Finding 1161157 (2024-001)

Material Weakness 2024

Walla Walla County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Walla Walla County employs a decentralized purchasing model. We have implemented training for departments using federally regulated funds to comply with suspension and debarment requirements. Internal controls and processes will be created and/or updated to comply with Federal Suspension and Debarme...

Walla Walla County employs a decentralized purchasing model. We have implemented training for departments using federally regulated funds to comply with suspension and debarment requirements. Internal controls and processes will be created and/or updated to comply with Federal Suspension and Debarment requirements and dispersed to all Departments of the County. The updated procurement policy as mentioned in the corrective action in the Management letter will outline how to handle and follow these requirements. The County will determine which allowable action to be taken in our Internal controls and Procurement policy: 1) check SAM.GOV, 2) make sure the clause is in the contract, 3) sign a suspension and debarment certification. Documentation will be saved and dated to show this requirement was met before the contract has begun.

View Audit 371174

Finding 1161141 (2024-001)

Material Weakness 2024

Grace House INC

MS

Subrecipient Monitoring Cash Management Material Weakness

Views of Responsible Officials and Planned Corrective Action — Grace House has created and will implement the following new controls: a) Every reimbursement request made by any employee will require approval from the Executive Director, Assistant Director, or board of directors vote where appropriat...

Views of Responsible Officials and Planned Corrective Action — Grace House has created and will implement the following new controls: a) Every reimbursement request made by any employee will require approval from the Executive Director, Assistant Director, or board of directors vote where appropriate. b) For rental invoices, the immediate supervisor must approve all rental invoices for payment processing before being submitted to the administrative office. If the immediate supervisor is absent, the invoice must be approved by the Executive Director or Assistant Director. c) When a new client invoice is submitted for approval for an existing approved landlord, the invoice along with the traditional client identifying information will be reviewed by both the immediate supervisor and the Executive Director. d) When a new client invoice is submitted for approval for a new landlord, the invoice will be reviewed by both the immediate supervisor and the Executive Director. Each invoice requires a W9 form to validate the legal name, property records verifying ownership matching the legal name on the W9, a picture ID of the individual listed on the W9, and a copy of the agreement if a property management company is listed on the W9 instead of an individual. e) All new clients and landlords will be researched through an investigative software to prove there is no evidence of false identity. f) Grace House has contracted an independent certified fraud investigator to conduct periodic reviews for compliance with fraud prevention policies at least semiannually but beginning quarterly through 2025.

View Audit 371153

Finding 1161076 (2024-002)

Material Weakness 2024

Zanesville-Muskingum County General Health District

OH

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.420 § 200.476

• ZMCHD will continue to educate staff on time and activity reporting. • ZMCHD will create a process to evaluate staff time and effort reporting to ensure the grant is not being overcharged.

View Audit 371068

Finding 1161057 (2024-004)

Material Weakness 2024

Borderlands Restoration Network

AZ

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.332

● The Organization will develop a policy and procedures that require documentation of subrecipient monitoring for each subrecipient. ● The Organization will redesign the subrecipient contract template to include the federal award identification number and amount of federal funds awarded to each subr...

● The Organization will develop a policy and procedures that require documentation of subrecipient monitoring for each subrecipient. ● The Organization will redesign the subrecipient contract template to include the federal award identification number and amount of federal funds awarded to each subrecipient. ● The Finance Director will distribute the policies and procedures along with the new contract template to all staff that manage grants. ● The Finance Director will train the staff on the new policies and procedures.

View Audit 371025

Finding 1160981 (2024-003)

Material Weakness 2024

Plainview Serenity Center, Inc.

TX

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Corrective Action Plan Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: In response to the finding, management will reinforce its expenditure approval policy by requiring all purchases and payments to have compl...

Corrective Action Plan Explanation of Disagreement with Audit Findings: There is no disagreement with the audit finding. Actions Planned in Response to Finding: In response to the finding, management will reinforce its expenditure approval policy by requiring all purchases and payments to have complete documentation and pre-approval from the appropriate level of management. Will perform quarterly internal audits to ensure ongoing compliance. Official Responsible for Ensuring CAP: Paul Walker, Chief Executive Officer Planned Completion Date for CAP: Immediately Plan to Monitor Completion of CAP: The CEO will convene quarterly meetings with the Finance and Compliance departments to review sampled federal transactions for proper documentation and approval. A compliance checklist will be completed and retained for monitoring.

View Audit 371016

Finding 1160904 (2024-005)

Material Weakness 2024

Platte County, Nebraska

NE

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

The County has discussed and the County Treasurer has developed a procedure to record the federal awards by project and by department. The spreadsheet shall provide the reporting information of expenditures of federal awards and the awards received.

View Audit 370972

Finding 1160886 (2024-007)

Material Weakness 2024

Martin University

IN

Questioned Costs Special Tests & Provisions Student Financial Aid § 200.303

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: During our audit procedures, we noted that the 1 student withdrawal did not have a return to Title IV calculation completed timely as the student officially withdrew 8/29/23 and the calcula...

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.063 Condition: During our audit procedures, we noted that the 1 student withdrawal did not have a return to Title IV calculation completed timely as the student officially withdrew 8/29/23 and the calculation was not completed until 3/24/25. We also noted that the calculation that was performed did not include documentation of the control process to review and approve the calculations prior to changes being made to the student’s award. Auditors’ Recommendation: We recommend the institution maintain proper documentation in accordance with federal grantor requirements and ensure that the documents are readily available for review upon request, including monitoring of students with triggering events that require a return to Title IV calculation to be completed, reviewed, and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

View Audit 370945 Questioned Costs: $1

Finding 1160882 (2024-006)

Material Weakness 2024

Martin University

IN

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring § 200.303

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid in...

United States Department of Education Student Financial Aid Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Condition: Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Auditors’ Recommendation: We recommend the University engage a third party or perform the risk assessment for the two areas required by the Gramm-Leach-Bliley Act that have not been completed and documented and ensure that there are documented safeguards for identified risks. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University has implemented a new SIS and Financial Aid processing system. The new systems are Jenzebar products and are fully compliant. Name(s) of the contact person(s) responsible for corrective action: Qiana Hall, Associate VP of Enrollment Services Planned completion date for corrective action plan: June 30, 2025

View Audit 370945

Finding 1160857 (2024-001)

Material Weakness 2024

Nushagak Electric and Telephone Cooperative, Inc.

AK

Equipment & Real Property Management Subrecipient Monitoring Reporting

Cause: The size and rurality of the Cooperative does not allow for the employment of additional staff to alleviate this condition, as the costs exceed the benefits. Corrective Action Plan: “NETC Management continues to evaluate costs of internally employing resources in comparison with related benef...

Cause: The size and rurality of the Cooperative does not allow for the employment of additional staff to alleviate this condition, as the costs exceed the benefits. Corrective Action Plan: “NETC Management continues to evaluate costs of internally employing resources in comparison with related benefits. Additional efforts shall be placed on implementing additional training and internal controls, as well as working with third party auditors to ensure GAAP compliance.”

View Audit 370943

Finding 1160825 (2024-006)

Material Weakness 2024

School Administrative Unit No. 16

NH

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

The joint baord will adopt policy DAF

View Audit 370927

Corrective Action Plans

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