Corrective Action Plans

Finding 1161832 (2024-001)

Material Weakness 2024

FORCE Detroit

MI

Subrecipient Monitoring § 200.332

Force Detroit will monitor compliance through: ● Vendors/grantees must submit regular financial and programmatic reports, including expenditures, progress toward goals, and any issues encountered. ● Reports will be reviewed for accuracy, completeness, and alignment with the approved budget and progr...

Force Detroit will monitor compliance through: ● Vendors/grantees must submit regular financial and programmatic reports, including expenditures, progress toward goals, and any issues encountered. ● Reports will be reviewed for accuracy, completeness, and alignment with the approved budget and program plan. ● Site visits to verify program activities, financial management practices, and overall compliance. Findings will be documented, and any deficiencies will trigger the Corrective Action Plan. ● Review of financial and programmatic documentation ● Verification of debarment and good standing with regulatory bodies ○ Vendors/grantees must provide confirmation that they are not debarred, suspended, or otherwise restricted from receiving federal funds.

View Audit 371759

Finding 1161829 (2024-001)

Material Weakness 2024

City of Clarkston

WA

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

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Clarkston January 1, 2024 through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Clarkston January 1, 2024 through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The City did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of City contact person: Rachel Frost 829 5th Street Clarkston, WA 99403 509-758-5541 Corrective action the auditee plans to take in response to the finding: The City completed the process of updating the policy regarding federal procurement and suspension and debarment to ensure compliance with usage of federal funds. This was adopted with Resolution 2025-10 on June 9, 2025. The City will review the procurement policy and standards of conduct policy annually to ensure that federals standards are maintained, and adequate internal controls are in place. Anticipated date to complete the corrective action: Completed June 9, 2025.

View Audit 371752

Finding 1161764 (2024-014)

Material Weakness 2024

Comanche County

OK

Subrecipient Monitoring § 200.1 § 200.303 § 200.329 § 200.344

The Board of County Commissioners will take measures to ensure future compliance with all requirements of federal grants,

View Audit 371699

Finding 1161763 (2024-007)

Material Weakness 2024

Comanche County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that Comanche County receives to ensure that proper internal controls are implemented.

View Audit 371699

Finding 1161762 (2024-006)

Material Weakness 2024

Comanche County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties

The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.

View Audit 371699

Finding 1161710 (2024-003)

Material Weakness 2024

Middle East Broadcasting Networks, Inc.

VA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Views of Responsible Officials: Management understands and agrees. Unfortunately, this issue was identified late into FY24 when the FY23 audit was being completed so the issue persisted into FY24. From the corrective action plans taken from the FY23 audit and desk review, this issue has been address...

Views of Responsible Officials: Management understands and agrees. Unfortunately, this issue was identified late into FY24 when the FY23 audit was being completed so the issue persisted into FY24. From the corrective action plans taken from the FY23 audit and desk review, this issue has been addressed and resolved in early FY25. MBN currently has an SOP regarding fixed assets that is already implemented. To address these concerns, MBN updated the SOP to include a clear process for equipment disposals, specifically for assets with a fair market value over $10,000, in accordance with Uniform Guidance. This update will ensure that all disposals are properly documented, and appropriate notifications are made to USAGM. We would like to confirm that the equipment disposal forms have already been updated to ensure that all necessary responses are reviewed and accurately completed as part of the notification process for disposals. Furthermore, we have strengthened our tracking, reporting and disposal processes to ensure the final disposition of equipment, including salvage value, is appropriately recorded.

View Audit 371654

Finding 1161709 (2024-002)

Material Weakness 2024

Middle East Broadcasting Networks, Inc.

VA

Questioned Costs Subrecipient Monitoring Material Weakness

Views of Responsible Officials: Management agrees and if funding had not stopped, audit fieldwork was originally slated to begin April 1st which would have allowed for timely completion. We fully intend to complete our FY25 audit well before the nine-month deadline.

View Audit 371654

Finding 1161708 (2024-001)

Material Weakness 2024

Middle East Broadcasting Networks, Inc.

VA

Questioned Costs Subrecipient Monitoring Material Weakness § 200.303

Views of Responsible Officials: Management agrees and was fully aware of the situation it found itself in when funding was cut. The Organization was not able to keep enough staff employed during this time to review and correct these errors before the audit fieldwork began. Now that these historical ...

Views of Responsible Officials: Management agrees and was fully aware of the situation it found itself in when funding was cut. The Organization was not able to keep enough staff employed during this time to review and correct these errors before the audit fieldwork began. Now that these historical balances have been corrected, the team undergoes a rigorous month-end close process where these issues will be caught and addressed immediately going forward.

View Audit 371654

Finding 1161630 (2024-003)

Material Weakness 2024

City of Versailles

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

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 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 Questioned Costs Subrecipient Monitoring § 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

Student Financial Aid Questioned Costs 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

Corrective Action Plans

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