Corrective Action Plans

Finding 1205372 (2025-003)

Material Weakness 2025

SC

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303

Finding 2025-003 – Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountabi...

Finding 2025-003 – Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountability and Transparency Act. Specifically, the University did not submit a first-tier subaward agreement/amendment/modification within the required timeframe to the System for Award Management (SAM.gov). The University concurs with the findings and is committed to strengthening its internal controls, procedures, and oversight mechanisms to ensure full compliance with all FFATA reporting requirements moving forward. II. Criteria Under FFATA requirements: • Recipients of federal grants or cooperative agreements must report first-tier subawards of $30,000 or more to SAM.gov. • Reporting must be completed timely and accurately in accordance with federal guidelines. • Institutions must maintain sufficient internal controls to ensure that all reportable subawards are identified, tracked, and submitted within required deadlines. III. Condition The audit determined that a subaward agreement, amendment, or modification meeting FFATA reporting thresholds was not submitted within the required timeframe. This reflects a lapse in the University’s internal processes governing subrecipient monitoring and reporting compliance. IV. Root Cause Analysis The University has identified the following contributing factors: • Inadequate tracking mechanisms for subaward reporting deadlines • Insufficient coordination between Grants Administration and responsible program personnel • Lack of automated alerts and centralized monitoring systems • Gaps in internal review and approval workflows prior to submission • Limited oversight to ensure timely compliance with FFATA requirements V. Corrective Actions and Implementation Plan The University will implement the following corrective measures effective immediately: 1. Internal Audit Oversight and Governance • The Internal Audit function will assume leadership responsibility for overseeing FFATA compliance and subrecipient reporting processes. • Quarterly compliance reports will be prepared and submitted directly to the Vice President and Chief Finance Officer until sustained compliance is achieved. • Internal Audit will conduct periodic reviews and testing of subaward reporting to ensure adherence to federal requirements. 2. Enhanced Tracking and Monitoring Systems • A centralized tracking system will be implemented to monitor all subawards, including thresholds, reporting deadlines, and submission status. • Automated alerts and reminders will be established to notify responsible personnel of upcoming reporting deadlines. 3. Strengthening Policies and Procedures • Standard Operating Procedures (“SOPs”) for FFATA reporting will be updated and formally documented. • Procedures will clearly define roles, responsibilities, timelines, and escalation protocols for noncompliance. • A compliance checklist will be required prior to execution and modification of all subaward agreements. 4. Improved Interdepartmental Coordination • Formal communication protocols will be established between Grants Administration, Principal Investigators, and Finance to ensure timely identification and reporting of subawards. • Designated compliance liaisons will be assigned to ensure accountability across departments. 5. Training and Capacity Building • Mandatory training will be conducted for all staff involved in grants management and subrecipient oversight. • Training will focus on FFATA requirements, reporting timelines, system usage, and compliance expectations. 6. Pre-Submission Review and Quality Assurance • A secondary review process will be implemented prior to submission to SAM.gov to ensure accuracy and completeness. • Documentation supporting all submissions will be retained in a centralized repository for audit and compliance purposes. VI. Timeline for Implementation • Immediate: o Initiate Internal Audit oversight o Implement interim tracking and reporting processes o Begin staff training • Short-Term: o Deploy centralized tracking system and automated alerts o Finalize and implement updated SOPs o Begin quarterly reporting to the Vice President and Chief Finance Officer • Long-Term (Ongoing): o Conduct continuous monitoring and compliance reviews o Maintain quarterly reporting until full and sustained compliance is achieved VII. Monitoring and Ongoing Compliance The Internal Audit function will provide ongoing monitoring and validation of FFATA reporting compliance. Quarterly reports will include status updates, identified issues, corrective actions, and recommendations for continuous improvement. VIII. Conclusion The University is committed to addressing the deficiencies identified in Finding 2025-003 through enhanced oversight, improved processes, and strengthened internal controls. These actions will ensure timely and accurate subaward reporting, uphold compliance with FFATA requirements, and reinforce the University’s commitment to transparency and accountability in federal grant management. Anticipated Completion Date: September 1, 2026

View Audit 397073

Finding 1205370 (2025-101)

Material Weakness 2025

Cochise County

AZ

Subrecipient Monitoring Eligibility Procurement, Suspension & Debarment § 200.303

Cochise County Corrective Action Plan Year ended June 30, 2025 2025-101 Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award number and years: CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Departmen...

Cochise County Corrective Action Plan Year ended June 30, 2025 2025-101 Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award number and years: CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Department of Agriculture Pass-through grantor: Arizona Department of Health Services Compliance requirement: Eligibility Questioned costs: Unknown The County did not perform eligibility certification requirements, resulting in an increased risk of program participants receiving benefits they are not eligible to receive Contact: Barbara Lang Completion date: March 2026 Corrective Action: Cochise County WIC leadership and staff are committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. This audit timeframe produced findings primarily related to issues that have already been corrected through the departure of staff that contributed to the findings (to include the previous Directors), hiring of new staff with a more thorough and comprehensive training plan implemented, and staff effort to retroactively collect all required signatures at subsequent appointments to ensure all WIC clients have current signatures and understanding of Rights & Obligations and Consents for their certification period. We recognize that these new processes were not put into plan until June 2025, due to the timing of the previous audit, and therefore did not reflect on the July 1, 2024 – June 30, 2025 audit period. In addition to the above resolved issues, a new WIC director was hired in September 2025 and new policies and procedures were immediately developed and put into place. These new policies and procedures that serve as our already implemented corrective action plan are as follows: Staff Training a. All staff are required to complete the full ADHS WIC-sponsored live cohort training courses upon hire, and every 3 years of their employment to ensure competencies are maintained over time. b. All staff complete their annual Civil Rights, Conflict of Interest, and Confidentiality upon hire and annually. Last annual training was completed Fall 2025. c. A staff dedicated as Training Coordinator monitors training logs and ensure all training requirements are met, with additional oversight by the WIC Director and the ADHS WIC State office. d. In-person staff meetings are held monthly, with a significant portion of time dedicated to staff training on programmatic expectations to ensure all staff obtain the same information so that tasks are carried out in a standardized method. e. Weekly team huddles to review any timely findings or discuss issues as a group. f. Weekly 1:1’s with each staff to discuss areas where the employee may need additional training or to discuss any deficiencies the WIC manager has noticed, (i.e. note-taking/documentation, single income verifications, chart review findings, etc.). Separation of Duties g. Cert List for Audits report run every 2 weeks for each clinic/staff person to review adherence to Separation of Duties. i. Follow up with certain percentage of clients per policy to assess how the certification went and verify client information. ii. Follow up with staff if any issues are identified. h. Staff have been training on during staff meetings in July 2025, August 2025, October 2025, and during new employee training on how to properly use the HANDS system to ensure the system accurately records who completed the 2nd income verification. i. Revision of Separation of Duties policy and implementation of new “protected time” procedure to ensure there is a staff person available at almost all times of day to complete the 2nd IV. *Since approval of this policy the ADHS WIC state office on 1/5/2026 and implementation of this policy/procedure, the Cert List for Audit report of single-income verifications has decreased substantially (from 60 in 2 weeks, to 5), all with documented reasons why 2nd IV was unable to be obtained during certification appointment and notes verifying 2nd IV was completed on another date. Rights and Obligations and Consent Forms a. All staff received a refresher training on 8/26/25, will be retrained annually, and are regularly reminded to obtain both required signatures at certification b. If staff are unable to obtain digital signatures due to tech issues, they are required to obtain e-document signatures via the clients email, or written signatures the staff then scans into the client file c. Chart reviews and staff observations are completed on a monthly-bimonthly basis to ensure ongoing staff compliance with policy and procedure

View Audit 397064

Finding 1205366 (2025-005)

Material Weakness 2025

City of Alexandria

VA

Subrecipient Monitoring § 200.303 § 200.332 § 200.414

Home Investment Partnerships Program Assistance Listing No. 14.239 Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Explanation ...

Home Investment Partnerships Program Assistance Listing No. 14.239 Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will undertake additional training for departments in FY 2026, to include providing departments with a grants responsibility checklist. Name(s) of the contact person(s) responsible for corrective action: Kevin Greenlief, Director of Finance. Planned completion date for corrective action plan: Q2, 2026.

View Audit 397053

Finding 1205363 (2025-004)

Material Weakness 2025

City of Alexandria

VA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Highway Planning and Construction Assistance Listing No. 20.205 Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor's suspension and debarment status is documented prior to contracting with the vendor. Explanation of disagreement with audit find...

Highway Planning and Construction Assistance Listing No. 20.205 Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor's suspension and debarment status is documented prior to contracting with the vendor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City's Transporation Department erroneously thought the City's Purchasing Department performed the suspension and debarment check. Purchasing reported that since we were riding the contract of another jurisdiction that they rely on that jurisdiction to check for debarment and the other jurisdiction confirmed that they only award contracts to active vendors on the State's eVA system, hence an indication of no debarment). Regardless, the City will conduct additional training in this area for prime award recipients and for Purchasing staff. The City will also check for suspensions and debarment even if riding contracts from other jurisdictions. Name(s) of the contact person(s) responsible for corrective action: Davidia Thompson, Wynndell Bishop, Department of Finance. Planned completion date for corrective action plan: Q2, 2026.

View Audit 397053

Finding 1205361 (2025-003)

Material Weakness 2025

City of Alexandria

VA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation o...

HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation of supporting compliance should be readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting has been completed. New employees will be trained in the procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation will be available for review during the audit period. Name(s) of the contact person(s) responsible for corrective action: Noah Abraham, DCHS Operations Director. Planned completion date for corrective action plan: Complete

View Audit 397053

Finding 1205360 (2025-003)

Material Weakness 2025

Lincoln County Health Department

MO

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

2025-003 Material Weakness Internal Control – Special Tests / Prevailing wages C. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for obtaining certified payrolls as needed in conjunction with construction projects. D. Actions Taken or Planned: Management will requ...

2025-003 Material Weakness Internal Control – Special Tests / Prevailing wages C. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for obtaining certified payrolls as needed in conjunction with construction projects. D. Actions Taken or Planned: Management will request certified payrolls for any future construction contracts as required by federal regulation. Anticipated completion date: Already implemented, ongoing Contact information for this finding: Michelle Walsh, 636-528-6117

View Audit 397052

Finding 1205359 (2025-002)

Material Weakness 2025

Lincoln County Health Department

MO

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

2025-002 Material Weakness Internal Control / Noncompliance – Reporting A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for reporting program personnel cost. B. Actions Taken or Planned: Management will continue to evaluate their controls with respect to current...

2025-002 Material Weakness Internal Control / Noncompliance – Reporting A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for reporting program personnel cost. B. Actions Taken or Planned: Management will continue to evaluate their controls with respect to current federal awards and requirements to insure accurate information captured and reported in accordance with the required timelines by implementing additional oversight. Anticipated completion date: Already implemented, ongoing Contact information for this finding: Michelle Walsh, 636-528-6117

View Audit 397052

Finding 1205357 (2025-001)

Material Weakness 2025

Lincoln County Health Department

MO

Eligibility Subrecipient Monitoring Material Weakness

2025-001 Material Weakness Internal Control / Noncompliance – Eligibility A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for maintaining supporting documentation to provide evidence of LCHD’s compliance with requirements applicable to each program funded under ...

2025-001 Material Weakness Internal Control / Noncompliance – Eligibility A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for maintaining supporting documentation to provide evidence of LCHD’s compliance with requirements applicable to each program funded under Uniform Guidance requirements. B. Actions Taken or Planned: Management implemented changes to the capturing and files maintained for documenting a participant’s eligibility for participation in program services. Management will continue to evaluate their controls with respect to current federal awards and requirements to ensure accurate information captured, reported and maintained. Anticipated completion date: Already implemented, ongoing Contact information for this finding: Michelle Walsh, 636-528-6117

View Audit 397052

Finding 1205356 (2025-003)

Material Weakness 2025

Health Resources in Action, INC

MA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

2025-003 Program Name: Environmental Justice Thriving Communities Grantmaking Program; Assistance Listing Number: 64.615 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements mad...

2025-003 Program Name: Environmental Justice Thriving Communities Grantmaking Program; Assistance Listing Number: 64.615 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements made with federal funds. Disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented additional controls to ensure that each program has documented procedures to submit required reports timely and accurately. The untimely filing of reports in fiscal year 2025 resulted from a change in personnel. During fiscal year 2026, management identified all applicable reporting requirements and assigned responsibility to appropriate personnel. Additional procedures were implemented to ensure reports are reviewed and submitted in accordance with required deadlines. Name of the contact person responsible for corrective action: Beth Doreian, CFO Planned completion date for corrective action plan: March 1, 2026

View Audit 397051

Finding 1205354 (2025-002)

Material Weakness 2025

Health Resources in Action, INC

MA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

2025-002 Program Name: Community-Based Violence Intervention and Prevention Initiative; Assistance Listing Number: 16.045 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements ma...

2025-002 Program Name: Community-Based Violence Intervention and Prevention Initiative; Assistance Listing Number: 16.045 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements made with federal funds. Disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented additional controls to ensure that each program has documented procedures to submit required reports timely and accurately. The untimely filing of reports in fiscal year 2025 resulted from a change in personnel. During fiscal year 2026, management identified all applicable reporting requirements and assigned responsibility to appropriate personnel. Additional procedures were implemented to ensure reports are reviewed and submitted in accordance with required deadlines. Name of the contact person responsible for corrective action: Beth Doreian, CFO Planned completion date for corrective action plan: March 1, 2026

View Audit 397051

Finding 1205329 (2025-003)

Material Weakness 2025

Washington Adventist University

MD

Student Financial Aid Subrecipient Monitoring Significant Deficiency

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WAU agrees with the recommendation to update our formal process to identify and maintain an inventory of data, devices, and systems that support or process customer f...

Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: WAU agrees with the recommendation to update our formal process to identify and maintain an inventory of data, devices, and systems that support or process customer financial aid information. While we currently use the Spiceworks Inventory System to track hardware and software assets and Google Workspace to manage user cloud access and data storage, we acknowledge that a formal, documented inventory process covering all required categories has not yet been fully established. The IT Director has been assigned to develop and document this process within 30 days. We acknowledge this finding and the associated risk arising from the absence of an independent risk assessment. As of March 25, 2026, the University has engaged TeamLogic Cybersecurity to strengthen our managerial, technical, and operational controls and to (1) develop and document a formal, GLBA aligned risk assessment process; (2) conduct annual independent, comprehensive risk assessment of our information systems and data environment; and (3) provide written findings and recommendations. Based on these results, we will implement appropriate safeguards, and institutionalize an annual risk assessment cycle to ensure that risks are consistently identified, assessed, mitigated, and monitored in accordance with GLBA requirements. Name(s) of the contact person(s) responsible for corrective action: Rosalee Pedapudi, IT Director, Information Technology Services Planned completion date for corrective action plan: April 26, 2026

View Audit 397028

Finding 1205305 (2025-002)

Material Weakness 2025

County of Luzerne, Pennsylvania

PA

Subrecipient Monitoring Reporting Significant Deficiency

Condition: The Program's Single Audit and reporting package was delayed for the year ended June 30, 2024 beyond the nine-month due date, as a result of turnover and delays in reconciling federal and state award activity with the Commonwealth. Criteria: Pursuant to the provisions of the Uniform Guida...

Condition: The Program's Single Audit and reporting package was delayed for the year ended June 30, 2024 beyond the nine-month due date, as a result of turnover and delays in reconciling federal and state award activity with the Commonwealth. Criteria: Pursuant to the provisions of the Uniform Guidance, under §200.512(a), the Program is required to complete and submit its Single Audit and related Data Collection Form within nine months of the end of its fiscal period (March 31) of the following year. Root Cause Analysis: The audit for the period ending June 30, 2024 was started in January 2025 and was completed and submitted in June 2025. In accordance with Uniform Guidance, the deadline is March 31st annually to have the audit completed and submitted. To meet this deadline, the year-end close and audit process needs to begin at least two months sooner to achieve this deadline. To address finding 2024-002, we began the audit in October 2025, one month ahead of schedule. Planned Corrective Action Steps: 1. Annually, begin the year-end close in September and start the audit in October. Responsible Party: MHDS Fiscal Director and MHDS Fiscal Unit Timeline for Completion: 1. Action Step #1 – September-November 2026

View Audit 397008

Finding 1205276 (2025-002)

Material Weakness 2025

Zane Trace Local School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management

The District will work with the contractors to get the proper payroll records to meet the prevailing wage requirements agreed upon in the contract.

View Audit 396991

Finding 1205275 (2025-007)

Material Weakness 2025

Roof Above, Inc.

NC

Subrecipient Monitoring Reporting Significant Deficiency

Corrective Action Plan Reporting Finding 2025-007 Roof Above will ensure the review of all grant invoices is documented through the signature of the reviewer on the grant cover sheet. Roof Above will institute a policy that grant invoices will not be submitted without the corresponding review signat...

Corrective Action Plan Reporting Finding 2025-007 Roof Above will ensure the review of all grant invoices is documented through the signature of the reviewer on the grant cover sheet. Roof Above will institute a policy that grant invoices will not be submitted without the corresponding review signature. Contact person responsible for corrective action: Tonya Frye, Chief Financial Officer Anticipated completion date: September 30, 2026

View Audit 396990

Finding 1205264 (2025-003)

Material Weakness 2025

Roof Above, Inc.

NC

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking

Corrective Action Plan Special Tests: Housing Quality Standards Finding 2025-003 Roof Above will document review of the inspection by sending an email to the grants administrator stating the inspection has been reviewed. Contact person responsible for corrective action: Katie Church, Vice President ...

Corrective Action Plan Special Tests: Housing Quality Standards Finding 2025-003 Roof Above will document review of the inspection by sending an email to the grants administrator stating the inspection has been reviewed. Contact person responsible for corrective action: Katie Church, Vice President of Scattered Site Housing Anticipated completion date: June 30, 2026

View Audit 396990

Finding 1205262 (2025-002)

Material Weakness 2025

Roof Above, Inc.

NC

Subrecipient Monitoring Eligibility Material Weakness

Corrective Action Plan Eligibility Finding 2025-002 Roof Above will add signature lines to current client eligibility checklist, to include the name, signature and date for both the person preparing and the person reviewing tenant eligibility. Contact person responsible for corrective action: Katie ...

Corrective Action Plan Eligibility Finding 2025-002 Roof Above will add signature lines to current client eligibility checklist, to include the name, signature and date for both the person preparing and the person reviewing tenant eligibility. Contact person responsible for corrective action: Katie Church, Vice President of Scattered Site Housing Anticipated completion date: June 30, 2026

View Audit 396990

Finding 1205260 (2025-002)

Material Weakness 2025

City of McCall, Idaho

ID

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

THE CITY WILL IMPROVE GRANT EXPENDITURES RECORDKEEPING BY USING CASELLE, OUR ENTERPRISE GENERAL LEDGER (GL) SYSTEM, AS THE PRIMARY SYSTEM OF RECORD FOR TRACKING ALL GRANT-RELATED REVENUE, EXPENDITURES, AND PROJECT ACTIVITY. THE CITY WILL UTILIZE THE CASELLE PROJECT ACCOUNTING MODULE AS THE OFFICIAL ...

THE CITY WILL IMPROVE GRANT EXPENDITURES RECORDKEEPING BY USING CASELLE, OUR ENTERPRISE GENERAL LEDGER (GL) SYSTEM, AS THE PRIMARY SYSTEM OF RECORD FOR TRACKING ALL GRANT-RELATED REVENUE, EXPENDITURES, AND PROJECT ACTIVITY. THE CITY WILL UTILIZE THE CASELLE PROJECT ACCOUNTING MODULE AS THE OFFICIAL GRANT/PROJECT TRACKING MECHANISM AND WILL FORMALIZE A CONSISTENT GRANT ACCOUNTING STRUCTURE WITHIN CASELLE (INCLUDING APPROPRIATE FUND/PROJECT/GRANT CODES AND EXPENDITURE ACCOUNTS) SO THAT GRANT TRANSACTIONS ARE CLEARLY IDENTIFIED, ACCURATELY CODED, AND FULLY SUPPORTED BY DOCUMENTATION. TO ENSURE THE ONGOING ACCURACY OF THE GENERAL LEDGER AND PROJECT RECORDS, THE CITY WILL IMPLEMENT ROUTINE RECONCILIATION AND REVIEW PROCEDURES THAT TIE AMOUNTS RECORDED IN CASELLE (INCLUDING PROJECT ACCOUNTING ACTIVITY) TO SUPPORTING DOCUMENTATION AND REIMBURSEMENT ACTIVITY AND WILL CORRECT ANY MISCODING OR OMISSIONS PROMPTLY. THE CITY WILL ALSO UPDATE WRITTEN GRANT ACCOUNTING PROCEDURES AND PROVIDE TRAINING TO STAFF INVOLVED IN PURCHASING, ACCOUNTS PAYABLE, AND GRANT ADMINISTRATION TO REINFORCE CODING REQUIREMENTS, DOCUMENTATION STANDARDS, AND REVIEW RESPONSIBILITIES.

View Audit 396984

Finding 1205259 (2025-001)

Material Weakness 2025

District School Board of Pinellas County

FL

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring § 200.303

Corrective Action Plan Fiscal Year 2025 Finding Number: 2025-001 – Pell Grant Special Tests and Provisions – NSLDS Reporting The District acknowledges the findings related to NSLDS enrollment reporting and has conducted an internal review of processes, systems, and oversight structures contributing ...

Corrective Action Plan Fiscal Year 2025 Finding Number: 2025-001 – Pell Grant Special Tests and Provisions – NSLDS Reporting The District acknowledges the findings related to NSLDS enrollment reporting and has conducted an internal review of processes, systems, and oversight structures contributing to the finding. To ensure compliance with federal reporting requirements, the District will implement the following corrective actions: 1. Enhanced Review Procedures: The District will strengthen internal controls over enrollment reporting by implementing procedures to ensure all enrollment status changes are accurately recorded, reconciled between internal systems and third-party servicer reports, and submitted to NSLDS within required time frames. Additionally, The District is actively restructuring internal systems and workflows within the department to strengthen oversight, improve accuracy, and ensure timely reporting of enrollment status changes. 2. Training: The District recognizes that staff turnover and inconsistent training contributed to the finding. To address this, the District will implement a comprehensive training plan in partnership with the third-party servicer. 3. Monitoring Controls: The District will formally reestablish expectations with its third-party servicer to ensure all contracted services are implemented. Implementation Timeline: • Enhanced review procedures will be implemented immediately. • The District will implement an ongoing comprehensive training plan in partnership with third-party servicer. • Staff will meet with third-party servicer to re-establish expectations and to ensure compliance with federal reporting requirements before fiscal year-end. Responsible Party: Dr. Dywayne B. Hinds, Sr., Area Superintendent, Dr. Jakub Prokop, Director, PTC- Clearwater, and Dr. Jason Shedrick, Director, PTC-St. Petersburg Anticipated Completion Date: June 30, 2026 Dywayne B. Hinds, Sr., Ed.D. Area Superintendent, Area 3

View Audit 396974

Finding 1205252 (2025-002)

Material Weakness 2025

Mexico Academy and Central School District

NY

Subrecipient Monitoring School Nutrition Programs

10.553, 10.555, 10.559 - Child Nutrition Cluster 2025-002 Net Cash Resources Corrective Action Plan The School Lunch Fund continues to have excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The School District is currently reviewing the equipment...

10.553, 10.555, 10.559 - Child Nutrition Cluster 2025-002 Net Cash Resources Corrective Action Plan The School Lunch Fund continues to have excess fund balance on hand due to the additional reimbursements provided during the COVID-19 pandemic. The School District is currently reviewing the equipment used by the program and will create a plan to use these funds to support the program's infrastructure. Expected Completion Date June 30, 2026 Contact: Jolean Bliss, School Business Executive Mexico Academy and Central School District 16 Fravor Road, Suite A Mexico, NY 13114 (315) 963-8400

View Audit 396945

Finding 1205242 (2025-004)

Material Weakness 2025

Metropolitan School District of Southwest Allen County

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.302 § 200.303 § 200.328 § 200.329

Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School C...

Finding 2025-004 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Participation of Private School Children Summary of Finding: The School Corporation did not provide supporting documentation for the amounts disbursed for Participation of Private School Children. No time sheets or logs were provided to support the hours paid to employees for working with the Private School Children. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement procedures to ensure consistent documentation supporting Title I services provided to non-public school students. All Title I staff providing services to non-public schools will be required to submit consistent, detailed timesheets documenting hours and/or days worked by non-public school, activity, and grant year. Timesheets will be completed, reviewed, and approved prior to payroll processing. The Payroll Manager will not process payroll for Title I non-public services unless the required timesheets are submitted and approved. Approved timesheets will be retained in the payroll files and organized by payroll dates, and will be made available for audit review. Anticipated Completion Date: July 1, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

View Audit 396929

Finding 1205240 (2025-003)

Material Weakness 2025

Metropolitan School District of Southwest Allen County

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, ...

Finding 2025-003 Finding Subject: Title I Grants to Local Educational Agencies - Earmarking Summary of Finding: The School Corporation and we could not verify the unused Homeless set-aside funds were transferred to the next grant award. Contact Person Responsible for Corrective Action: Randi Libby, Chief Operating Officer Contact Phone Number and Email Address: (260)431-2030, rlibby@sacs.k12.in.us Views of Responsible Official: We disagree with the finding. Explanation and Reasons for Disagreement The School Corporation respectfully disagrees with the conclusion that it failed to comply with Title I homeless setaside requirements. Title I, Part A requires local educational agencies to reserve “such funds as are necessary” to serve homeless children and youth (20 U.S.C. § 6313(c)(3)). Neither the statute nor implementing regulations require that homeless set-aside funds be fully expended each fiscal year, nor do they require unspent homeless set-aside funds to be rolled forward and maintained as a cumulative earmark across successive grant years. During the audit period, the School Corporation increased its homeless set-aside allocation each year based on annual needs assessments. The existence of unspent balances is attributable to year-over-year increases in allocation rather than failure to reserve or obligate funds. Requiring the perpetual rollover of unspent homeless set-aside funds would be inconsistent with Title I’s annual reservation framework and would eventually consume the full 15% Title I carryover limitation, a result not contemplated by federal statute or guidance. While the auditors were unable to verify homeless set-aside expenditures to their satisfaction due to documentation and monitoring gaps, the School Corporation does not agree that this constitutes noncompliance with the earmarking requirement itself. The statutory obligation is to reserve funds based on need, which the School Corporation did. Description of Corrective Action Plan: Although the School Corporation disagrees with the compliance conclusion, it recognizes the need to strengthen internal controls and documentation related to Title I set-aside monitoring. Going forward, the School Corporation will implement enhanced procedures to document: • the annual determination of the homeless set-aside amount, • periodic monitoring of expenditures against the approved reservation, and • year-end reconciliation of reserved versus expended funds within each grant year. These procedures are intended to improve audit transparency and documentation while maintaining compliance with Title I statutory requirements. INDIANA STATE BOARD OF ACCOUNTS 31 Preparing today’s learners for tomorrow’s opportunities. Anticipated Completion Date: January 31, 2026 _________________________ _Randi Libby (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

View Audit 396929

Finding 1205238 (2025-002)

Material Weakness 2025

Metropolitan School District of Southwest Allen County

IN

School Nutrition Programs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or dete...

Finding 2025-002 Finding Subject: Child Nutrition Cluster – Internal Controls Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting material noncompliance. Contact Person Responsible for Corrective Action: Erika Horner, Director of Food Service Contact Phone Number and Email Address: (260)431-2030, ehorner@sacs.k12.in.us Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: All direct certification information shall be initiated by the Director of Food Service: pulling the information monthly from CNP Web. The list of students to be directly certified will be printed, signed and dated by the Director of Food Service. Once information is imported into the student management system, the Assistant Food Service Director would then cross reference the printed list of information to benefits assigned in the student management system to ensure accuracy. The Assistant Food Service Director will initial next to the students they spot check on the list. The printed document with signatures of both parties will be retained with the school years applications.􀯗 The Director of Food Service has the responsibility to ensure that all vendors are free from suspension, debarment, or aren’t otherwise excluded. Suspension and debarment documents are to be collected on a yearly basis. If such documents are not available through the SFA Cooperative, it will be the responsibility of the Director of Food Service to acquire them through SAM.gov website or contacting the vendor directly. All documents are to be signed, dated, and retained by school year by both the Director of Food Services and the Asst. Director of Food Services. Anticipated Completion Date: January 31, 2026 _________________________ Randi Libby_ (Signature) _______Chief Operating Officer __ (Title) __________January 7, 2026__________ (Date)

View Audit 396929

Finding 1205215 (2025-002)

Material Weakness 2025

McKendree University

IL

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to prope...

Student Financial Assistance Cluster Federal Direct Loans - Assistance Listing No. 84.268 Recommendation: We recommend the University evaluate controls around monitoring return of Title IV funds to determine changes, either on the electronic processes or review processes that should be made to properly capture return of Title IV funds on a timely basis. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Planned corrective action: Currently, the return of Title IV calculations are done manually and a second person within Financial Aid reviews the calculation. The University is working on a training engagement for the Financial Aid office which will explore the ability to perform the return of Title IV calculations within the ERP system. A second person would continue to review the calculation. Name(s) of the contact person(s) responsible for corrective action: Patrick Michael, Director of Financial Aid If the United States Department of Education has questions regarding this plan, please call Shari Keffer, Vice President for Administration & Finance at 618-537-6838.

View Audit 396879

Finding 1205202 (2025-001)

Material Weakness 2025

Sun Prairie Area School District

WI

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.331 § 200.332

Finding #2025-001: #84.048 -Career and Technical Education - Basic Grants to States Federal Grantor Agency: U.S. Department of Education Compliance Requirement: Subrecipient Monitoring Condition: During our audit procedures, we noted that the District does not have formal, written procedures governi...

Finding #2025-001: #84.048 -Career and Technical Education - Basic Grants to States Federal Grantor Agency: U.S. Department of Education Compliance Requirement: Subrecipient Monitoring Condition: During our audit procedures, we noted that the District does not have formal, written procedures governing subrecipient monitoring. Although the District reviews supporting documentation—such as invoices—submitted by subrecipient schools prior to submitting claims to the Department of Public Instruction (DPI), these practices are not documented in an established policy or procedure. Criteria: Uniform Guidance (2 CFR 200.331–200.332) requires pass-through entities to establish and implement written procedures for monitoring subrecipients to ensure compliance with federal program requirements and achievement of performance goals. Cause: The District has not developed or implemented formal written policies and procedures for subrecipient monitoring. Effect: In the absence of formalized procedures, the District’s monitoring practices may be applied inconsistently, increasing the risk of unallowable costs, noncompliance with federal requirements, or misunderstandings between the District and its subrecipients. This could lead to questioned costs or administrative issues during oversight by DPI or other regulatory bodies. Recommendation: We recommend that the District develop and adopt formal written procedures outlining its subrecipient monitoring activities. These procedures should clearly describe monitoring responsibilities, required documentation, review steps, communication expectations, and follow-up actions. Implementing a formalized process will help ensure consistent oversight and compliance with federal regulations. Grantee Response: The District will develop and implement written procedures that outline the required monitoring steps, documentation standards, communication protocols, and follow-up expectations for subrecipient oversight. These procedures will align with the requirements of Uniform Guidance and DPI expectations.

View Audit 396861

Finding 1205185 (2025-001)

Material Weakness 2025

City of Richardson

TX

Subrecipient Monitoring Special Tests & Provisions Significant Deficiency § 200.326

February 27, 2026 Re: Corrective Action Plan in response to Federal Single Audit Introduction On February 27, 2026, Crowe LLP issued the Independent Auditor’s Report as required and in accordance with the auditing standards generally accepted in the United States of America and the standards applica...

February 27, 2026 Re: Corrective Action Plan in response to Federal Single Audit Introduction On February 27, 2026, Crowe LLP issued the Independent Auditor’s Report as required and in accordance with the auditing standards generally accepted in the United States of America and the standards applicable to financial audits contained in Government Auditing Standards issued by the Controller General. The Corrective Action Plan, submitted by the City of Richardson more specifically, responds to the Report and outlines the City’s corrective action plans to address the finding. We again thank Crowe LLP for their hard work in this matter. This single audit has and will continue to serve as a roadmap for future financial operations. Finding 2025-001: Special Tests – Wage Rate Requirements – Significant Deficiency In two out of seven selections tested for required certified payrolls for contactor or subcontractor work performed during the fiscal year end September 30, 2025, the certified payrolls were not obtained by the City until subsequent to audit fieldwork. In addition, the City did not have internal controls in place to identify that these certified payrolls were not being obtained. Response: The City acknowledges that the required supporting documentation was not available at the time compliance testwork was completed by Crowe LLP. The City recognizes its responsibility to obtain and review certified payroll records from contractors and subcontractors for all laborers working on City grant funded projects to ensure wages and fringe benefits are paid in compliance with the Davis-Bacon Act. Corrective Action Plan: The City has an established Grants Management Policy and quarterly reporting from departments stating compliance with grant requirements. To strengthen compliance and address the documentation deficiency identified in the audit finding, the City will conduct mandatory training sessions with designated grant personnel in each department to reinforce policy requirements, required documentation standards, and applicable federal and state regulations, including certified payroll monitoring requirements where applicable. Training will be completed by June 30, 2026, and will be provided annually thereafter.The City will implement a grant review process that includes a master checklist to assist departments in verifying compliance prior to processing payments. The checklist will include verification that required supporting documentation, including certified payroll records when applicable, has been received, reviewed, and approved. Implementation of this checklist will occur by March 31, 2026. A centralized electronic repository will be established to allow Finance access to grant agreements, supporting documentation and relate records maintained by City departments. This control will be implemented by March 31, 2026. Additional internal controls will be incorporated into the financial software system to ensure that all required supporting documentation is attached and reviewed prior to payment approval. This control will be implemented by March 31, 2026. The City will conduct periodic internal compliance review testing of grants, including verification of required labor compliance documentation where applicable, to confirm ongoing adherence to federal and state regulations. Pre-award and post-award meetings will be held between Finance and the respective grant departments to establish reporting parameters, documentation requirements, monitoring responsibilities and compliance expectations prior to project implementation. When bids are solicited that include grant funding, the City will continue to communicate to all prospective bidders that compliance with all applicable federal and state laws and regulations, including labor standard requirements when applicable, is a condition of award. Bid documents will include a sample copy of the U.S. Department of Labor Davis-Bacon and Related Acts Weekly Certified Payroll form. Contact Person Responsible/Anticipated Completion Date: The Finance Director is responsible for oversight of this corrective action plan, with day-to-day management and implementation delegated to the Assistant Director of Finance. Implementation of these corrective actions is scheduled to begin immediately, with full completion anticipated by June 30, 2026. Once implemented, the procedures will be monitored on an ongoing basis to ensure continued compliance and to prevent recurrence of the finding.

View Audit 396839

Corrective Action Plans

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