Corrective Action Plans

Finding 1161630 (2024-003)

Material Weakness 2024

KY

Subrecipient Monitoring

Management acknowledges that there have been deficiencies in processes. The City intends to enhance its internal controls over ARPA reporting. These efforts will be accomplished through improved internal communication and training of staff to ensure proper reporting.

View Audit 371503

Finding 1161578 (2024-002)

Material Weakness 2024

Ryder Village Ii, Inc.

PR

Subrecipient Monitoring HUD Housing Programs Special Tests & Provisions

Finding Number: 2024-002 Finding The entity has a delinquent deposit to the replacement reserve. Cause Recommendation We recommend the Project’s management to evaluate the need of contracting additional personnel to minimize the accounting closing time. We recommend also, establishing monitoring pro...

Finding Number: 2024-002 Finding The entity has a delinquent deposit to the replacement reserve. Cause Recommendation We recommend the Project’s management to evaluate the need of contracting additional personnel to minimize the accounting closing time. We recommend also, establishing monitoring procedures to ensure the compliance of such requirement. Corrective Action Plan The budget of the managing agent is limited so the recommendation of more employees cannot be assumed at this time. However, the Management will be evaluating functions performed by the accountant from which he can be relieved so that more time is left for the activities required in the recommendations. The deposit was made more later due to the cash flow problems mentioned in the previous finding. Housing Program Director will be in charge to monitoring monthly the deposit to the replacement account. Currently the number of vacancies decreased which helped the project financially. Lack of personnel in the accounting department. Only one employee is in-charge of performing the accounting and the closing procedures.

View Audit 371456

Finding 1161575 (2024-002)

Material Weakness 2024

Ryder Assisted Care, Inc.

PR

Subrecipient Monitoring HUD Housing Programs Special Tests & Provisions

The budget of the managing agent is limited so the recommendation of more employees cannot be assumed at this time. However, the Management will be evaluating functions performed by the accountant from which he can be relieved so that more time is left for the activities required in the recommendati...

The budget of the managing agent is limited so the recommendation of more employees cannot be assumed at this time. However, the Management will be evaluating functions performed by the accountant from which he can be relieved so that more time is left for the activities required in the recommendations.

View Audit 371454

Finding 1161561 (2024-001)

Material Weakness 2024

Town of Onancock, Virginia

VA

Procurement, Suspension & Debarment Subrecipient Monitoring

Effective November 1, 2025, the Town of Onancock management will confirm that every vendor used to expend federal funds will be verified to have no restrictions or disbarment. This will be verified using SAM.gov.

View Audit 371439

Finding 1161551 (2024-004)

Material Weakness 2024

Pueblo County Colorado

CO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance progra...

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County obtain certifications from vendors stating their organization is not suspended, debarred, or otherwise excluded from participation in federal assistance programs or document the procedures performed to verify the vendor is not identified as suspended or debarred on SAM. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County has ensured that any entity that receives American Rescue Plan (APRA) funding is registered on SAM.gov before any funds are disbursed by the County. An addendum will be added to new contracts with subrecipients of any Federal funds that will require signed certification from the vendors/contractors related to debarment and registration with SAM.gov. The county will do an annual check for existing subrecipients to ensure they are not subject to suspension or debarment. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 31, 2025

View Audit 371432

Finding 1161548 (2024-003)

Material Weakness 2024

Pueblo County Colorado

CO

Subrecipient Monitoring § 200.303 § 200.331 § 200.332

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subre...

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends that the County review its procedures for communicating information to subrecipients and implement the procedures necessary to ensure information is included in the subrecipient award documents at time of funding and that appropriate monitoring is performed for each subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: For future awards the County will include compliance requirements to subrecipients in the award documents. For previously issued awards, the County will use appropriate subrecipient monitoring procedures to ensure compliance with the grants awarded throughout the remainder of the contract periods. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 1, 2025

View Audit 371432

Finding 1161545 (2024-002)

Material Weakness 2024

Pueblo County Colorado

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.318 § 200.326

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. E...

COVID-19 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) – Assistance Listing No. 21.027 Recommendation: CLA recommends the County follow their internal procurement policy procedures and keep documentation of such procedures to ensure compliance with the federal procurement requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County will implement policies and procedures to ensure that future awards or contracts with expenditures of American Rescue Plan (APRA) funds will follow the procurement guidelines outlined in the US Treasury rules and regulations as well as County procurement policies. Most of the 2024 expenditures were part of contracts that were already in place when the original findings came out in September 2023 so this could not be corrected. Name of the contact person responsible for corrective action: Craig McBrain, Deputy Director of Budget and Finance Planned completion date for corrective action plan: December 31, 2025

View Audit 371432

Finding 1161523 (2024-011)

Material Weakness 2024

Libson Regional School District

NH

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

We are working on policies and procedures to match up to the DAF sections. The procedures and policies are based on the NHED Fact Sheets.

View Audit 371424

Finding 1161505 (2024-002)

Material Weakness 2024

City of Pueblo, Colorado

CO

Subrecipient Monitoring § 200.1

While reviewing the City of Pueblo Schedule of Expenditure of Federal Awards (SEFA), the auditors found that there were subrecipient awards of Federal funding of CDBG and HOME programs, that met the criteria for FFATA reporting, that were not reported. Management acknowledges fault in reporting subr...

While reviewing the City of Pueblo Schedule of Expenditure of Federal Awards (SEFA), the auditors found that there were subrecipient awards of Federal funding of CDBG and HOME programs, that met the criteria for FFATA reporting, that were not reported. Management acknowledges fault in reporting subrecipient awards. The primary cause was lack of awareness of FFATA criteria in reporting requirements. To address these issues, management will ensure staff is trained in reporting criteria and that all reporting is completed within 30 days as required.

View Audit 371422

Finding 1161498 (2024-002)

Material Weakness 2024

Capital Area Community Action Agency, INC

FL

Special Tests & Provisions Subrecipient Monitoring Significant Deficiency

2024-002 Internal Controls Over Compliance - Special Tests and Provisions (Tri-Partite Board) - Community Service Block Grant (CSBG) - CFDA 93.569 - Grant Period Year Ended September 30, 2024 Criteria: In accordance with the requirements of the Program outlined in ALN 93.569 CSBG, and the CSBG Act a...

2024-002 Internal Controls Over Compliance - Special Tests and Provisions (Tri-Partite Board) - Community Service Block Grant (CSBG) - CFDA 93.569 - Grant Period Year Ended September 30, 2024 Criteria: In accordance with the requirements of the Program outlined in ALN 93.569 CSBG, and the CSBG Act at 42 USC 9910, nonprofit organizations administer CSBG through a board. One-third (1/3) of the board members must be chosen in a democratic selection process adequate to assure that these members are representative of the low-income individuals and families served. An additional 1/3 of the board must be public elected and/or appointed officials. Condition: The Agency was unable to meet the 1/3 requirements for the public elected/appointed officials and the 1/3 requirement for low-income individuals and families served during the year ended September 30, 2024. Cause: While the Agency's controls did identify a lack of participation in these areas, they did not include control activities to resolve the non-compliance in a timely manner. Effect: The Agency is out of compliance with the provisions requiring Tri-Partite Board as defined by the CSBG Act at 42 USC 9910. Recommendation: We recommend the Agency recruit board members from the areas identified for compliance with this requirement. Corrective Action Plan: The Capital Area Community Action Agency Board membership fluctuates over time. Sometimes there are several public representatives or their designees on the board. Other times there are several private sector representatives. As a tripartite board, low-income representatives are always on the board. While the numbers are not always equal, the Agency strives to meet the spirit of the law in its recruitment efforts. The Board will work to develop a more robust recruitment method to ensure a balance of representation from the three sectors, as well as the eight counties we serve. We anticipate correcting this finding by the next review period.

View Audit 371414

Finding 1161497 (2024-001)

Material Weakness 2024

Capital Area Community Action Agency, INC

FL

Subrecipient Monitoring Material Weakness Internal Control / Segregation of Duties

2024-001 Improper Payroll Approvals Criteria: In accordance with the Agency’s written internal controls, for employee timesheets, “Supervisors review and approve subordinate’s time at the end of the pay period”. Condition: For 21 of 40 payroll transactions selected for testing during the year under ...

2024-001 Improper Payroll Approvals Criteria: In accordance with the Agency’s written internal controls, for employee timesheets, “Supervisors review and approve subordinate’s time at the end of the pay period”. Condition: For 21 of 40 payroll transactions selected for testing during the year under audit, there was no approval of the employee’s timesheet by a Supervisor. Cause: Control activities relating to payroll timesheet approvals are not functioning properly, and the Agency was unable to provide written supporting documentation of Supervisor approval. Effect: The Agency is not following its documented internal controls relating to payroll timesheet approvals on a consistent basis. Recommendation: We recommend that the Agency adhere to written internal controls and ensure that all employee timesheets are approved at a level higher than the employee themselves. Additionally, we recommend that appropriate documentation of the approvals is retained. Corrective Action Plan: Employees approve their timesheets electronically, and then it moves to the manager for approval. Once approved the HR Manager reviews and makes any necessary corrections. The COO reviews it once corrected and approves the payroll for processing. The HR Manager will continue working with the payroll vendor to see if they could create a special report to use for our audit. We will create a log for the HR Manager and COO to initial to verify they approved the payroll.

View Audit 371414

Finding 1161451 (2024-002)

Material Weakness 2024

Nueces County, Texas

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

Corrective Action Plans

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