Corrective Action Plans

Finding 1214641 (2023-006)

Material Weakness 2023

FM

Subrecipient Monitoring Reporting

Finding No.: 2023-006 Area: Reporting Views of responsible official and planned corrective actions: The Trust has updated its due diligence checklist to include speciﬁc steps to ensure compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. This includes identifying...

Finding No.: 2023-006 Area: Reporting Views of responsible official and planned corrective actions: The Trust has updated its due diligence checklist to include speciﬁc steps to ensure compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. This includes identifying qualifying subawards, collecting required reporting data, and ensuring timely submission of reports. These procedures have been integrated into the Trust’s grant management processes to strengthen internal controls and support full compliance with applicable federal regulations and grantor expectations. Contact Person: Melanie Lawrence Aiseam, Chief Financial Officer Expected Completion Date: The Trust started working on the checklist last year and finalized it in Q4 2025.

View Audit 401348

Finding 1214640 (2023-005)

Material Weakness 2023

Micronesia Conservation Trust

FM

Subrecipient Monitoring Matching / Level of Effort / Earmarking

Finding No.: 2023-005 Area: Level of Effort Views of responsible official and planned corrective actions: Management acknowledges the requirement to comply with the Level of Eﬀort provisions outlined in the grant agreement. Management conﬁrms that the Trust is committed to maintaining adequate syste...

Finding No.: 2023-005 Area: Level of Effort Views of responsible official and planned corrective actions: Management acknowledges the requirement to comply with the Level of Eﬀort provisions outlined in the grant agreement. Management conﬁrms that the Trust is committed to maintaining adequate systems and documentation to demonstrate that all required time, activities, and resources are properly allocated to grant-funded projects. To strengthen compliance, we will continue to ensure that staﬀ maintain accurate timesheets and activity logs, and that these records are reviewed on a regular basis by program and ﬁnance personnel. Management will also conduct periodic oversight reviews to conﬁrm that Level of Eﬀort requirements are being met and properly supported by documentation. Contact Person: Melanie Lawrence Aiseam, Chief Financial Officer Expected Completion Date: The Trust started training last year, and this is ongoing.

View Audit 401348

Finding 1214639 (2023-004)

Material Weakness 2023

Micronesia Conservation Trust

FM

Subrecipient Monitoring Reporting

Finding No.: 2023-004 Area: Reporting Views of responsible official and planned corrective actions: The Trust has updated its due diligence checklist to include speciﬁc steps to ensure compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. This includes identifying...

Finding No.: 2023-004 Area: Reporting Views of responsible official and planned corrective actions: The Trust has updated its due diligence checklist to include speciﬁc steps to ensure compliance with Federal Funding Accountability and Transparency Act (FFATA) requirements. This includes identifying qualifying subawards, collecting required reporting data, and ensuring timely submission of reports. These procedures have been integrated into the Trust’s grant management processes to strengthen internal controls and support full compliance with applicable federal regulations and grantor expectations. Contact Person: Melanie Lawrence Aiseam, Chief Financial Officer Expected Completion Date: The Trust started working on the checklist last year and finalized it in Q4 2025.

View Audit 401348

Finding 1214637 (2023-002)

Material Weakness 2023

Micronesia Conservation Trust

FM

Cash Management Subrecipient Monitoring § 200.305

Finding No.: 2023-002 Area: Cash Management Views of responsible official and planned corrective actions: Management acknowledges the requirements of 2 CFR 200.305(b). Existing cash management procedures are currently under review, and updates will be made to further strengthen compliance with feder...

Finding No.: 2023-002 Area: Cash Management Views of responsible official and planned corrective actions: Management acknowledges the requirements of 2 CFR 200.305(b). Existing cash management procedures are currently under review, and updates will be made to further strengthen compliance with federal requirements. The Trust will ensure that procedures continue to minimize the time between receipt and disbursement of funds and that payments are made in accordance with contract terms. Written procedures will be updated as needed and followed by ﬁnance staﬀ, with ongoing reviews to ensure compliance. Contact Person: Melanie Lawrence Aiseam, Chief Financial Officer Expected Completion Date: The Trust started training in Quarter 4 2024, and is ongoing

View Audit 401348

Finding 1214620 (2023-001)

Material Weakness 2023

Community of Hope, Inc.

FL

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking § 200.303

2023-001 REPORTING Recommendation: Reports prepared by the Executive Director should be reviewed by an independent person to ensure completeness and accuracy. Additionally, the Organization should design a control to ensure reports are submitted in a timely manner in accordance with compliance requi...

2023-001 REPORTING Recommendation: Reports prepared by the Executive Director should be reviewed by an independent person to ensure completeness and accuracy. Additionally, the Organization should design a control to ensure reports are submitted in a timely manner in accordance with compliance requirements. Corrective Action: Community of Hope recognizes that our expansion and growth have made it difficult to maintain full and timely compliance with some reporting criter+B11 ia. As such, we have created a compliance calendar that will alert staff to impending deadlines and requirements. In addition, we recently hired a staff member with compliance being a primary function. She is reviewing grant and policy compliance, making recommendations, and instituting changes to enhance compliance. Responsible party: Drew Warren, Executive Director Date Expected to be Corrected: March 1, 2026

View Audit 401303

Finding 1214594 (2023-009)

Material Weakness 2023

Creek County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.308 § 200.317 § 200.501

It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all e...

It has been brought to our attention that we need an additional policy that covers conflict of interests and govern the performance of its employees engaged in the selection, award, and administration of contracts. We have taken this recommendation and are implementing the proper language, for all employees to acknowledge in our County Handbook. We will strengthen this control and add this be updated yearly, so that all conflict can be disclosed. Creek County prides itself in moving toward complete transparency and holding each employee accountable to disclose all information needed to make a proper selection of purchases. Creek County Clerk’s Office will work with the District Attorney’s Office for proper language.

View Audit 401258

Finding 1213590 (2023-001)

Material Weakness 2023

City of Davis

CA

Subrecipient Monitoring Cash Management Special Tests & Provisions

Finding Reference Number: SA2023-001 Subrecipient Reimbursement Request Documentation AL Number: 20.507, 20.526 Assistance Listing Title: Federal Transit Cluster, Federal Transit - Formula Grants (Urbanized Area Formula Program) Federal Agency: Department of Transportation Federal Award Identificati...

Finding Reference Number: SA2023-001 Subrecipient Reimbursement Request Documentation AL Number: 20.507, 20.526 Assistance Listing Title: Federal Transit Cluster, Federal Transit - Formula Grants (Urbanized Area Formula Program) Federal Agency: Department of Transportation Federal Award Identification Number: CA-2020-214-01, CA-2023-225-00 • Fiscal Year of Initial Finding: 2023 • Name(s) of the contact person: Ryan Chapman, Director of Public Works Engineering & Transportation • Corrective Action Plan: Staff has developed a procedure to improve monitoring of its subrecipients to include a review of required documentation for reimbursement requests. This procedure has been created specifically for the Unitrans grant award but will be expanded to encompass all grant subawards and subrecipients. • Anticipated Completion Date: May 2026

View Audit 400500

Finding 1211145 (2023-001)

Material Weakness 2023

Carestl Health

MO

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303 § 200.328 § 200.329

Recommendation We recommend that management: ▪ Establish a formal reporting calendar outlining all required financial and performance reports, including due dates ▪ Implement procedures to ensure reports are prepared accurately, reviewed, and submitted timely ▪ Maintain documentation of submitted re...

Recommendation We recommend that management: ▪ Establish a formal reporting calendar outlining all required financial and performance reports, including due dates ▪ Implement procedures to ensure reports are prepared accurately, reviewed, and submitted timely ▪ Maintain documentation of submitted reports, including confirmation of submission and supporting schedules ▪ Assign clear responsibility for reporting compliance and implement supervisory review controls ▪ Provide training to relevant personnel on federal reporting requirements Strengthening reporting processes will improve compliance, enhance transparency, and ensure that the organization meets its obligations under federal awards.

View Audit 400354

Finding 1210578 (2023-006)

Material Weakness 2023

The Salvation Army Golden State Division

CA

Subrecipient Monitoring Eligibility Material Weakness

The Division will take steps to ensure sub-recipient agreements are retained and the distribution sites maintain sign-in sheets requiring participants to self-certify they meet the grant eligibility requirements. September 2026 Al Agpoon, Golden State Division Controller

View Audit 399931

Finding 1210558 (2023-005)

Material Weakness 2023

The Salvation Army Golden State Division

CA

Subrecipient Monitoring Material Weakness Internal Control / Segregation of Duties § 200.502

The Division will take steps to ensure that proper evidence of review is maintained for the food distribution records and the sign in sheets. September 2026 Al Agpoon, Golden State Division Controller

View Audit 399931

Finding 1208225 (2023-004)

Material Weakness 2023

Fairbanks Rescue Mission, Inc.

AK

Subrecipient Monitoring

Financial Statement Finding: 2023-004 Material Weakness in Internal Control over Compliance and Noncompliance – Subrecipient Monitoring – Repeat Finding Name and Contact Person: Pete Kelly, Chief Executive Officer Corrective Action: A process will be developed to ensure that there is a review perfor...

Financial Statement Finding: 2023-004 Material Weakness in Internal Control over Compliance and Noncompliance – Subrecipient Monitoring – Repeat Finding Name and Contact Person: Pete Kelly, Chief Executive Officer Corrective Action: A process will be developed to ensure that there is a review performed and documentation retained for all subawardee’s risk assessments through reviewing their status via sam.gov. Proposed Completion Date: March 2027

View Audit 399165

Finding 1207147 (2023-003)

Material Weakness 2023

Williamson County Government

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance

The County will engage in competent consulting services to advise prior to audit findings of any deficiencies in the County's policies, procedures or recording keeping required of the federal funds.

View Audit 398999

Finding 1207146 (2023-002)

Material Weakness 2023

Williamson County Government

IL

Subrecipient Monitoring § 200.208 § 200.332 § 200.338 § 200.425 § 200.501

The County Board is continuously monitoring award recipients and bas a process established that prevents disbursement of fonds until proof of use is provided to the County Board.

View Audit 398999

Finding 1207145 (2023-001)

Material Weakness 2023

Williamson County Government

IL

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

The County Board does not believe the finding is appropriate. The Recipient "partner" was not an elected official at the time of application or award. The funds were utilized to restore a building located in the County and owned by a County resident. The County Board believes that this award falls w...

The County Board does not believe the finding is appropriate. The Recipient "partner" was not an elected official at the time of application or award. The funds were utilized to restore a building located in the County and owned by a County resident. The County Board believes that this award falls within the parameters of economic development, one of the allowable uses of the funds. Again, the Auditor has failed to provide any legal basis for the belief of the Auditing Firm or what legal opinion they relied upon in forming their beliefs.

View Audit 398999

Finding 1206687 (2023-006)

Material Weakness 2023

Homeless Resource Council of the Sierras

CA

Subrecipient Monitoring Cash Management Material Weakness

The Organization agrees with the audit finding. There were gaps in information flow due to staff turnover. The Organization already has a process in place to maintain documentation in a logical manner with adequate access.

View Audit 398809

Finding 1206683 (2023-005)

Material Weakness 2023

Homeless Resource Council of the Sierras

CA

Subrecipient Monitoring Significant Deficiency

We agree with this finding and will document approval for changes in budgets with subgrantees.

View Audit 398809

Finding 1206682 (2023-004)

Material Weakness 2023

Homeless Resource Council of the Sierras

CA

Subrecipient Monitoring § 200.332

We agree with this finding and will include the relevant information in our subawards in the future.

View Audit 398809

Finding 1206592 (2023-002)

Material Weakness 2023

City of North Bend

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214 § 200.317 § 200.327

The City of North Bend acknowledges that a contract utilizing SLFR funds, and awarded to a software vendor, did not include within the contract, a required self-attestation concerning Suspensions and Debarment. The self-attestation was used in lieu of a documented review of the SAM.gov portal for su...

The City of North Bend acknowledges that a contract utilizing SLFR funds, and awarded to a software vendor, did not include within the contract, a required self-attestation concerning Suspensions and Debarment. The self-attestation was used in lieu of a documented review of the SAM.gov portal for suspensions and debarment. This was an oversight of the contract review process. Other contracts issued during the same period included self-attestation language from 2 CFR 200.317 through 2 CFR 200.327. In 2024 and 2025, the Public Works Deputy Director, Contract Specialist, and Capital Staff Accountant ensure adherence to all applicable local, State, and federal procurement laws and regulations as provided in the Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibiting recipients from entering into contracts with suspended or debarred parties. The City of North Bend understands the significance of the finding and immediately took steps to review all subsequent contracts for compliance.

View Audit 398650

Finding 1206351 (2023-003)

Material Weakness 2023

HOUSING AUTHORITY OF THE CITY OF MILWAUKEE

WI

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions

Special Tests and Provisions - SEMAP Housing Voucher Cluster Material Weakness in Internal Controls Material Noncompliance Condition: The Authority was under Troubled Status with HUD for its Housing Choice Voucher program during the 2023 fiscal year. There were multiple fi ndings from HUD with a Cor...

Special Tests and Provisions - SEMAP Housing Voucher Cluster Material Weakness in Internal Controls Material Noncompliance Condition: The Authority was under Troubled Status with HUD for its Housing Choice Voucher program during the 2023 fiscal year. There were multiple fi ndings from HUD with a Corrective Action Plan implemented covering areas typically monitored through SEMAP self-assessment process. A uditor Recommendations: The Authority should evaluate and update its internal control policies and procedures related to HCV compliance requirements. The Authority should continue to work on its Corrective Action Plan with HUD to move out of Troubled Status. Action Taken: On the same note and based on a HUD review of operations, HACM entered into a SEMAP Corrective Action Plan with HUD with the goal to improve the SEMAP performance indicator scores. Via a nationwide Request for Proposal, HACM hired the contractor, CVR Associates, Inc. (CVR) to manage and operate the entire Housing Choice Voucher program for HACM, effective January 2, 2025. This contract is currently overseen by the Acting Secretary- Executive Director and will be overseen by the Chief Operations Officer once a new one is hired. CVR was selected as the contractor in part due to their extensive experience in m anaging similar voucher programs nationwide and on their tools/software that they have developed to manage items, such as quality control testing in the areas such as the items n oted above. CVR provided additional training to staff, prepared new standard operating procedures, a nd perform quality control testing over the course of the entire year. Many of the SEMAP indicators have improved, but some have additional improvement still needed based on the 2025 SEMAP results. When there are issues, the CVR Quality Control team follows up with the staff person to correct the issue, and to provide guidance or additional training with the goal to reduce the error rate in the future. We believe that HACM will be back to being a standard performer or higher in 2026. Name of Responsible Person: Ken Barbeau, Acting Secretary-Executive Director; Chief Operations Officer (once hired); Projected Completion Date: December 31, 2026

View Audit 398376

Finding 1206104 (2023-006)

Material Weakness 2023

Future Ready Five

OH

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

Reference Number: 2023-06 Finding Type: Noncompliance with Uniform Guidance Requirements Description of Finding: 2 CFR section 200.512(a) requires auditees to submit the Single Audit reporting package to the Federal Audit Clearinghouse (FAC) no later than the earlier of: 30 calendar days after recei...

Reference Number: 2023-06 Finding Type: Noncompliance with Uniform Guidance Requirements Description of Finding: 2 CFR section 200.512(a) requires auditees to submit the Single Audit reporting package to the Federal Audit Clearinghouse (FAC) no later than the earlier of: 30 calendar days after receipt of the auditor’s report(s), or 9 months after the end of the audit period. The Organization did not submit the single audit reporting package to the FAC within the required timeframe. The late filing resulted from delays in completing the audit caused by the identification and remediation of internal control matters during the audit process, combined with staff turnover in key financial reporting positions. Failure to timely submit the reporting package causes the Organization to be out of compliance with Uniform Guidance requirements and may result in increased federal oversight, potential sanctions or withholding of federal funds. Statement of Concurrence: Management agrees with the finding. Corrective Action: The organization recognizes that the Single Audit Report will be delayed for the 18-month period ended June 30, 2025, as the deadline to submit is March 31, 2026 and the audit has not yet commenced. The organization will ensure that the Single Audit Report will be submitted by August 31, 2026, and subsequent Single Audit Reports will be submitted by the deadline. Completion Date: August 31, 2026 Name of Contact Person: Maureen Thomas Chief Financial Officer 917-405-7185 maureen@frfive.org

View Audit 398055

Finding 1206101 (2023-003)

Material Weakness 2023

Future Ready Five

OH

Subrecipient Monitoring Reporting

Reference Number: 2023-03 Finding Type: Noncompliance with Major Program Requirement Description of Finding: Franklin County Department of Job and Family Services (the pass-through grantor) requires submission of monthly invoicing within 15 calendar days of each month-end. Additionally, a program re...

Reference Number: 2023-03 Finding Type: Noncompliance with Major Program Requirement Description of Finding: Franklin County Department of Job and Family Services (the pass-through grantor) requires submission of monthly invoicing within 15 calendar days of each month-end. Additionally, a program report is required to be submitted monthly under the subaward agreement. One monthly invoice was identified as being submitted to the pass-through grantor after the deadline. No monthly program report was submitted for December 2023. The reason for the finding is resource constraints and lack of timeliness in the Organization’s cost reconciliation process. The requirement to submit the monthly program report was informally waived by the pass-through grantor. Failure to submit reports timely causes the Organization to be out of compliance with grant requirements. Statement of Concurrence: Management agrees with the finding. Corrective Action: The pass-through grantor informally granted that invoices and program reports be submitted quarterly. The pass-through grantor has since provided formal documentation to the auditors that it has allowed invoices and program reports to be submitted quarterly. Completion Date: February 2026 Name of Contact Person: Maureen Thomas Chief Financial Officer 917-405-7185 maureen@frfive.org

View Audit 398055

Finding 1206065 (2023-005)

Material Weakness 2023

Voices of Tomorrow

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Contact Person: Chief Financial Officer Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. ...

Contact Person: Chief Financial Officer Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. FFATA reporting was not completed for applicable subawards as required under 2 CFR Part 170. Status: Corrective Action Taken Corrective action planned: The revised policy includes tracking of allocation shared cost and perform FFATA review. • Develop and implement a formal FFATA reporting policy. • Confirm FSRS system access and assign reporting responsibility. • Establish a compliance calendar for timely submission. • Complete any outstanding required FFATA filings. • Conduct quarterly review of subawards for FFATA applicability. Anticipated completion date: February 2026

View Audit 397946

Finding 1206062 (2023-002)

Material Weakness 2023

Voices of Tomorrow

WA

Subrecipient Monitoring § 200.332

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Corrective Action Plan For the Year Ended 2023 Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the fi...

Contact Person: Iftin Hagimohamed; Chief Financial Officer Stephanie Sosa: Finance Manager Corrective Action Plan For the Year Ended 2023 Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): Management concurs with the finding. Subaward agreements did not consistently include all required elements under 2 CFR §200.332. Status: Corrective Action Taken Corrective action planned: Management has revised its internal policies and procedures regarding subrecipient monitoring to follow 2 CFR 200.332. Ensure that subward are clearly identified and included in subrecipient agreement. • Develop and adopt a standardized subaward agreement template including Assistance Listing Number, federal award name, award ID, performance period, and required compliance provisions. • Implement a documented subrecipient risk assessment process. • Establish a subrecipient monitoring checklist for invoice review and compliance tracking. • Amend active subaward agreements where required. Anticipated completion date: April 30,2026

View Audit 397946

Finding 1205935 (2023-002)

Material Weakness 2023

Gascosage Electric Cooperative

MO

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.303

The Organization concurs with the finding and management will implement procedures to ensure appropriate internal control procedures are in place for reporting. Management will implement additional internal controls to ensure appropriate segregation of duties between report preparation and review.

View Audit 397805

Finding 1205858 (2023-001)

Material Weakness 2023

Reinvestment Fund, Inc.

PA

Subrecipient Monitoring Reporting

Planned Corrective Action: We have a remediation plan in place to ensure that all past grantees over $30,000 are registered on the website. We are currently waiting to receive the correct FAIN numbers from the United States Department of Agriculture (USDA) for all our awards so we can file the repor...

Planned Corrective Action: We have a remediation plan in place to ensure that all past grantees over $30,000 are registered on the website. We are currently waiting to receive the correct FAIN numbers from the United States Department of Agriculture (USDA) for all our awards so we can file the reports correctly. Once this information is received from the USDA we are ready to submit the required reporting. We have begun reporting for the few FAIN numbers we have that seem to be correct. We have also included FFATA registration as a step in our grants compliance process for the creation of all future HFFI grantees to prevent this finding from re-occurring. Completion date: May 2, 2024 Name of Contact Person: Sara Vernon Sterman, Chief Program Officer

View Audit 397603

Corrective Action Plans

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