Corrective Action Plans

Finding 1182103 (2025-001)

Material Weakness 2025

Howard County Economic Development Authority

MD

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility § 200.213 § 200.303

We agree with the auditor's comments. While we have retroactively searched for suspension and debarment, not all subrecipients were able to finalize their registration on SAM.gov. We determined that 7 of the 27 recipients were confirmed to have no suspension or debarment, totaling $514,450 of the gr...

We agree with the auditor's comments. While we have retroactively searched for suspension and debarment, not all subrecipients were able to finalize their registration on SAM.gov. We determined that 7 of the 27 recipients were confirmed to have no suspension or debarment, totaling $514,450 of the grant total. Our office of Law has drafted and amendment to the agreement that requires the subrecipient certify that they have not been suspended or debarred. We will have each subrecipient sign the amendment. We anticipate completion of this by March 31, 2026.

View Audit 393475

Finding 1182080 (2025-005)

Material Weakness 2025

Delphi Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We con...

FINDING 2025-005 Finding Subject: Special Education Cluster (IDEA) – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026

View Audit 393426

Finding 1182066 (2025-002)

Material Weakness 2025

Delphi Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the ...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension Debarment Contact Person Responsible for Corrective Action: Andrea Miller Contact Phone Number and Email Address: 765-564-2100 ext 1002, millera@delphi.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will implement a standardized procurement checklist documenting the method of procurement, vendor selection, quote comparison, and basis for contract price. The checklist will also have language that requires written justification and approval for any single-source procurement, as well as the date for the required check for suspension and debarment. The documentation for the suspension and debarment will be filed with the procurement checklist. Anticipated Completion Date: June 2026

View Audit 393426

Finding 1182045 (2025-007)

Material Weakness 2025

Wawasee Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or O...

FINDING 2025-007 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Assessment System Security Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Assessment System Security Audit Findings: Material Weakness, Other Matters Summary of Finding: State educational agencies (SEA), in consultation with local educational agencies (LEA), are required to establish and maintain an assessment security system that is valid, reliable, and consistent with relevant professional and technical standards. Within their assessment system, SEAs must have policies and procedures to maintain test security measures and ensure that LEAs implement those policies and procedures. As such, the Indiana Department of Education created and published the Indiana Assessments Policy Manual. As a part of the assessment security, any individual who administers, handles, or has access to secure test materials at the school or school corporation shall complete assessment training and sign a testing security and integrity statement that remains on file in the appropriate building-level office each year. Each individual required to sign the testing integrity agreement shall sign the form by an established date. The School Corporation had a process to provide assessment system security training and to ensure each employee that attended training signed the agreement indicating training was received. However, there was no process in place to ensure that all school employees required to be trained were trained. Contact Person Responsible for Corrective Action: Dr. Rashella Wilfong, Assistant Superintendent / Director of Curriculum and Instruction Contact Phone Number and Email Address: 574-457-3188 x 1901, swilfong@wawasee.k12.in.us 52 INDIANA STATE BOARD OF ACCOUNTS 52 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The Assistant Superintendent will continue to assign the appropriate training modules to School Corporation employees. The Assistant Superintendent will ensure that employees have completed their required training prior to the due date and will retain documentation of the completion. The Superintendent will perform a secondary review of the training log to verify that employees have completed their required training by the due date and the secondary review will be documented with the internal sign-off form created by the School Corporation. Anticipated Completion Date: The planned corrective action will be implemented in March of 2026.

View Audit 393398

Finding 1182043 (2025-006)

Material Weakness 2025

Wawasee Community School Corporation

IN

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Nu...

FINDING 2025-006 Finding Subject: Title I Grants to Local Educational Agencies – Special Tests and Provisions – Annual Report Card, High School Graduation Rate Federal Agency: Department of Education Federal Programs: Title I Grants to Local Educational Agencies CFDA Numbers: 84.010 Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Annual Report Card, High School Graduation Rate Audit Findings: Material Weakness, Other Matters Summary of Finding: The School Corporation is required to report graduation rate data for its public high school using the four-year adjusted cohort rate. To remove a student from the cohort, the School Corporation must confirm the reason for removal in writing. Additionally, required documentation for each removal type must be retained by the School Corporation. The School Corporation did not have effective internal controls to ensure required documentation to support the reason for a student’s removal from the high school graduation cohort for mobility reasons was prepared, reviewed, and retained. Although one person updated the reason for a student’s removal in the Student Information System, and another reviewed the documentation and approved the reason, the control was not sufficient to ensure compliance. Of the seven students tested, the School Corporation provided incorrect supporting documentation to substantiate the removal of two students from the cohort. Contact Person Responsible for Corrective Action: Karissa Stoffel, Student Information Specialist Contact Phone Number and Email Address: 574-457-3188 x 1902, kstoffel@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. 50 INDIANA STATE BOARD OF ACCOUNTS 50 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Description of Corrective Action Plan: The School Corporation has created a position for a Student Information Specialist. The Student Information Specialist will serve as the primary employee responsible for entering and maintaining student data within the student management software system. The Student Information Specialist will gather and review the documentation required for removal of a student from the cohort prior to entering that removal in the student management software. The Student Information Specialist will have the Superintendent and/or Assistant Superintendent review the documentation and software data for accuracy. The reviews will be documented with the internal sign-off form created by the School Corporation. Only after both reviews have been conducted will the Student Information Specialist remove the student from the high school graduation cohort. All documentation will be retained by the School Corporation. Anticipated Completion Date: The planned corrective action will be implemented in March of 2026.

View Audit 393398

Finding 1182039 (2025-004)

Material Weakness 2025

Wawasee Community School Corporation

IN

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

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Number...

FINDING 2025-004 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Procurement and Suspension & Debarment Audit Findings: Significant Deficiency Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls to ensure that vendors were not suspended or debarred prior to entering into a covered transaction. The School Corporation verifies through review of the SAM exclusions each time they begin doing business with a new vendor. However, a second individual does not verify the website has been reviewed. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: The Treasurer will review the SAM exclusion data for each vendor before setting up the vendor information in the accounting software. The review will be indicated by printing the SAM exclusion data and attaching the printout to the vendor W-9 kept on file in the Treasurer’s office. The Treasurer will indicate their review of the exclusion data by their signature/initials on the printout and a secondary employee will review and sign/initial as well to document the second review. Additionally, at the start of each calendar year the Treasurer will review the SAM exclusion data prior to processing any vendor claim to a vendor for that calendar year. The annual exclusion review will be documented by the Treasurer re-printing the SAM exclusion data for the 46 INDIANA STATE BOARD OF ACCOUNTS 46 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation vendor and signing/initialing the printout, and second employee will verify the accuracy by their signature/initials on the printout as well. The updated printout will be attached to the vendor W-9 kept on file in the Treasurer’s office. Anticipated Completion Date: The planned corrective action will be implemented in February of 2026 with any new vendor created in the accounting software. For established vendors, the Treasurer will begin re-verifying the vendor’s exclusion data in SAM prior to processing any vendor claims and creating a spreadsheet to track the most recent SAM verification for each vendor. This corrective action will be implemented by March of 2026.

View Audit 393398

Finding 1182033 (2025-003)

Material Weakness 2025

Wawasee Community School Corporation

IN

School Nutrition Programs Subrecipient Monitoring § 200.303

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (...

FINDING 2025-003 Finding Subject: Child Nutrition Cluster – Eligibility Federal Agency: Department of Agriculture Federal Programs: School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children CFDA Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years (or Other Identifying Numbers): FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Eligibility Audit Findings: Material Weakness, Other Matters Summary of Finding: The School Corporation had not properly designed or implemented an effective system of internal controls over review of individual free and reduced status applications and information management in the Skyward Software System used to determine and maintain eligibility status. Individual Applications The school noted individual applications for both direct certification and income eligible students would be printed and reviewed after the system makes a determination of eligibility status. Out of 40 students tested, no documentation of the review was provided for 34 students. Skyward Software System The School Corporation is required to design controls ensuring computer systems used to maintain student benefit status are secured. Currently, the Skyward system allows all school lunch employees to make changes to student benefit status, and there is no indication or record within the system as to who makes these changes. Additionally, income eligibility guidelines in the system that determine whether students are eligible based on income are updated by the system automatically every year. The school is required to perform annual review to ensure these guidelines are accurate. However, no annual review is done by school corporation staff. Contact Person Responsible for Corrective Action: Rachel Moore, Treasurer Contact Phone Number and Email Address: 574-457-3188 x 1369, rmoore@wawasee.k12.in.us 44 INDIANA STATE BOARD OF ACCOUNTS 44 801 S. Sycamore Street, Syracuse IN 46567 (574) 457-3188 Wawasee Community School Corporation Views of Responsible Officials: Management concurs with the finding. Description of Corrective Action Plan: A School Corporation employee will be designated to receive, review and process each individual application. Applications received digitally via the Skyward Software System will be printed so that a paper copy of each digital application is kept on file. The review of each application will be documented in writing on the paper copy of the application. A second School Corporation employee will perform a secondary review of every application to ensure accuracy of the eligibility determination, and the secondary review will be documented on each application. The eligibility guidelines in the Skyward Software System used to determine student eligibility will be downloaded from the School Nutrition Program’s website prior to July 1 of each year and will be uploaded into the Skyward Software System by the technology department of the School Corporation. After upload is complete, the Food Service Manager will review the data to ensure correct upload and will indicate the review on the sign-off form created by the School Corporation. The sign-off form will be retained to document the review. Anticipated Completion Date: The corrective action with regard to individual applications has already been implemented beginning with the 2025-2026 school year. For the 2025-2026 school year, the Treasurer has done the initial review of each application and the Food Service Manager has done the secondary review to ensure accuracy of each determination. Beginning in the 2026-2027 school year the process will remain the same but with the Food Service Manager performing the initial review and the Treasurer performing the secondary review. The corrective action with regard to the eligibility guidelines in Skyward will be implemented beginning with the upload of data in preparation for the 2026-2027 school year, expected to be in June of 2026.

View Audit 393398

Finding 1182002 (2025-001)

Material Weakness 2025

Scott County Public Water Supply District #4

MO

Procurement, Suspension & Debarment Subrecipient Monitoring

Name of Contact Person: Tim McIntyre, District Manager. Recommendation: Controls should be put into place to ensure the District checks the SAM.gov website before it spends more than $25,000 with a vendor using federal funds. Corrective Action: The District will keep the required documentation movin...

Name of Contact Person: Tim McIntyre, District Manager. Recommendation: Controls should be put into place to ensure the District checks the SAM.gov website before it spends more than $25,000 with a vendor using federal funds. Corrective Action: The District will keep the required documentation moving forward. Proposed Completion Date: Immediately.

View Audit 393383

Finding 1181980 (2025-001)

Material Weakness 2025

Sauk Valley Community College District 506

IL

Student Financial Aid Reporting Special Tests & Provisions

Condition: The audit identified instances in which enrollment status changes for withdrawn students were not reported to the National Student Loan Data System (NSLDS) within the required 60-day timeframe and in some cases the withdrawal date reported did not reflect the student’s actual Last Date of...

Condition: The audit identified instances in which enrollment status changes for withdrawn students were not reported to the National Student Loan Data System (NSLDS) within the required 60-day timeframe and in some cases the withdrawal date reported did not reflect the student’s actual Last Date of Attendance (LDA). Cause: The discrepancies occurred because the academic term end date was used instead of the student’s actual Last Date of Attendance for certain withdrawn students. In addition, in limited cases enrollment status changes for students who did not return for a subsequent term were not reported within the required 60-day window due to the timing of non-returning student reporting cycles. Corrective Action Plan: Sauk Valley Community College will implement revised procedures and additional monitoring controls to ensure that enrollment reporting to NSLDS complies with federal requirements. The College submits enrollment reporting through the National Student Clearinghouse, which transmits enrollment data to NSLDS on the College’s behalf. The College utilizes an internal system to generate enrollment reporting files based on institutional enrollment and withdrawal data. The Registrar reviews the file prior to transmission to the National Student Clearinghouse for submission to NSLDS. Enrollment reporting is currently submitted on a monthly basis. To address the reporting discrepancies identified in the audit, the College will implement the following corrective actions: 1. Accurate Withdrawal Date Reporting Procedures will be updated to ensure that the effective withdrawal date reported to NSLDS reflects the student’s actual Last Date of Attendance (LDA) recorded in institutional records rather than the academic term end date or administrative processing date. 2. Monthly Reconciliation Process The Registrar and Financial Aid Office will perform a monthly reconciliation of institutional withdrawal records to NSLDS enrollment reporting data to confirm that enrollment status changes and withdrawal dates have been reported accurately and within the required reporting timeframe. 3. Monitoring of Potential Unofficial Withdrawals Students who receive all “F” or “W” grades will be reviewed as potential unofficial withdrawals to ensure that the correct Last Date of Attendance is identified and reported when applicable. 4. Monitoring of Non-Returning Students Students who do not return for the summer or fall term following the spring semester will be reviewed by the end of June to determine whether a withdrawal status must be reported to NSLDS. The College will follow the National Student Clearinghouse guidance regarding non-required term enrollment reporting to support accurate status reporting. 5. Ongoing Compliance Oversight Financial Aid and the Registrar will work collaboratively to review enrollment reporting data on an ongoing basis to ensure compliance with federal reporting requirements, including the 60-day reporting requirement for enrollment status changes. 6. Staff Training and Procedural Reinforcement The Registrar and the Financial Aid Office will review NSLDS enrollment reporting guidance and applicable federal requirements with relevant staff to reinforce proper reporting procedures and ensure consistent understanding of withdrawal date reporting requirements and timelines. These procedures will provide additional oversight to ensure that withdrawal dates are reported accurately and that enrollment status changes are transmitted to NSLDS within the required timeframe. Responsible Officials: Jennifer Schultz, Dean of Student Services, Lizzie Harper, Director of Financial Assistance, and Meagan Rivera, Registrar Planned Implementation Date: The revised procedures will be implemented immediately, beginning with the current enrollment reporting cycle, and will continue as an ongoing compliance control.

View Audit 393337

Finding 1181939 (2025-002)

Material Weakness 2025

Rensselaer Central School Corporation

IN

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.309 § 200.461

Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all ...

Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. Corrective Action Plan – Period of Performance Finding (FY 2024) • Improved Internal Controls o Rensselaer Central and Cooperative School Services will implement additional review procedures to ensure all federal grant obligations occur within the allowable grant period and that vendor payments align with the original approved purchase orders. • Verification of Obligation Dates o Fiscal staff will verify that purchase orders, vendor invoices, and final payments reflect an obligatory date that occurs prior to the applicable grant deadline. • Staff Training o Rensselaer Central and Cooperative School Services Fiscal personnel involved in grant management will receive training on federal grant period of performance requirements and proper documentation of obligations. • Monitoring Procedures o Rensselaer Central and Cooperative School Services will conduct periodic reviews of federal grant expenditures to ensure ongoing compliance with grant timelines. • Statement of Isolated Occurrence o Rensselaer Central and Cooperative School Services reviewed the circumstances surrounding this finding and determined that the issue was isolated to fiscal year 2024. Responsible Party and Timeline for Completion: Corrective action plan has been implemented as this finding impacted fiscal year 2024 but did not recur in fiscal year 2025. The Director of Special Education, Cooperative School Services Bookkeeper, and Rensselaer Central Treasurer will oversee the corrective action plan to monitor the eligibility requirements on an ongoing basis.

View Audit 393212

Finding 1181869 (2025-001)

Material Weakness 2025

Young at Heart Resources

MO

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.430

Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individ...

Finding Reference Number: 2025-001 Federal Agency: U.S. Department of Health and Human Services Program Name: Aging Cluster Assistance Listing Number: 93.044/93.045/93.053 Responsible Official: Penny Crawford, Chief Executive Officer; Kelsey Swinderman, Financial Manager Views of Responsible Individuals: The Agency acknowledges the documentation deficiencies identified related to payroll and contract management. These issues were largely due to leadership transitions and changes in operational processes. The Agency has evaluated these gaps and is actively implementing corrective actions to strengthen internal controls and ensure compliance with Uniform Guidance requirements. Corrective Action Plan: Corrective actions currently in progress include: • Standardizing documentation requirements for all employee pay rates, including maintaining supporting documentation within personnel files • Implementing internal review procedures to ensure payroll changes align with Board-approved actions • Centralizing contract management and maintaining all executed service provider agreements in a secure, accessible location • Establishing documentation retention procedures to ensure all supporting records for federal award expenditures are complete and readily available for audit review The Agency is committed to fully resolving these issues and strengthening internal processes to ensure ongoing compliance and accountability. The Agency is implementing enhanced internal control procedures to ensure that all costs charged to federal awards are properly authorized, documented, and maintained in accordance with federal requirements. These improvements include the development of standardized processes for payroll documentation, contract management, and documentation retention. Internal review procedures are also being strengthened to ensure alignment between Board approvals and financial records. Anticipated Completion Date: June 30, 2026

View Audit 393170

Finding 1181865 (2025-004)

Material Weakness 2025

Housing Agency of the City of Beatrice, Nebraska

NE

HUD Housing Programs Subrecipient Monitoring Cash Management

Finding 2025-004- Allowable Activities I agree with the finding and corrective action will be taken by the Executive Director to correct the deficit balance. Benefits will be reviewed for employees of the Housing Agency. Management fees from the Prairie Heights and Prairie Village programs will also...

Finding 2025-004- Allowable Activities I agree with the finding and corrective action will be taken by the Executive Director to correct the deficit balance. Benefits will be reviewed for employees of the Housing Agency. Management fees from the Prairie Heights and Prairie Village programs will also be reviewed. Working with fee accountant on allocations.

View Audit 393156

Finding 1181861 (2025-002)

Material Weakness 2025

Springs Valley Community Schools Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303 § 200.317 § 200.318 § 200.327

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the fi...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Suspension and Debarment Contact Person Responsible for Corrective Action: Felicia Wolfington Contact Phone Number and Email Address: (812) 936-4474 x 1232, fwolfington@svalley.k12.in.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: In the future, the Treasurer will check the SAM exclusion list prior to entering into a covered transaction with federal awarded funds. There will also be a documented, secondary review to ensure the suspension and debarment requirement has been checked. Anticipated Completion Date: 02/04/2026

View Audit 393146

Finding 1181843 (2025-004)

Material Weakness 2025

Municipality of Cayey

PR

Subrecipient Monitoring Reporting Significant Deficiency § 200.302 § 200.328 § 200.329

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – ...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Ronaldo Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Díaz, Finance and Budget Director Phone: (787)738-3211 Original Finding Number: 2025-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: During the testing of reports, the Quarterly Progress Reports of five (5) projects, corresponding to two (2) quarters of fiscal year 2024-2025, were evaluated. It was found that in two (2) projects, the quarterly reports did not match the accounting records or the project documentation. Therefore, for the purposes of this audit, the municipal accounting controls and procedures did not ensure that the reported information was accurate, up-to-date, and fully reconciled with the financial records. In light of the above, the reports will be reconciled with the accounting records, and the discrepancies found will be identified, documented, and adjusted in the system where the error originated, as appropriate. Furthermore, from this point forward, once the Quarterly Reports (QPR) are issued, a copy must be sent to the Program Accountant, the Finance Director, and myself for validation and reconciliation prior to official filing, thus preventing situations like this to occur. This process will form part of the internal control required to ensure that the reported information is accurate, current, complete, and consistent with the accounting records, in accordance with applicable federal requirements. Implementation Date: From March 2026. Full implementation is expected in fiscal year 2026-2027. Responsible Person: Mrs. Natasha Vázquez Federal Programs Director

View Audit 393130

Finding 1181841 (2025-003)

Material Weakness 2025

Municipality of Cayey

PR

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – ...

COMMONWEALTH OF PUERTO RICO AUTONOMOUS MUNICIPALITY OF CAYEY Corrective Action Plan For the Fiscal Year Ended June 30, 2025 Auditor Report: Report on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Ronaldo Ortiz Velázquez, Mayor Contact Person: Mrs. Eunice Díaz, Finance and Budget Director Phone: (787)738-3211 Original Finding Number: 2025-003 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: As an internal control and prevention measure, the budget sent by the Agency will be verified with the percentages (%) established in the contract. If they do not match, ACUDEN will be asked to amend the budget. Also, as part of the corrective action plan, the municipality will be moving the location of its centers in search of better accessibility for participants and to be more aggressive in providing services and spending the allocations in full. Implementation Date: During fiscal year 2025-2026. Responsible Person: Mrs. Natasha Vázquez Federal Programs Director

View Audit 393130

Finding 1181832 (2025-001)

Material Weakness 2025

Miami Dade County District School Board

FL

Subrecipient Monitoring HUD Housing Programs

PLANNED CORRECTIVE ACTION: Miami-Dade County Public Schools (M-DCPS) adheres to Section 1003.23, Florida Statutes, as it pertains to withdrawal of all students enrolled in the District. Based on the DOE's Comprehensive Management Information System Automated Student Attendance Recordkeeping System H...

PLANNED CORRECTIVE ACTION: Miami-Dade County Public Schools (M-DCPS) adheres to Section 1003.23, Florida Statutes, as it pertains to withdrawal of all students enrolled in the District. Based on the DOE's Comprehensive Management Information System Automated Student Attendance Recordkeeping System Handbook: A withdrawal is official when one or more of the following occurs: 1. A parent or legal guardian notifies the school that the child is permanently leaving the school to enroll in another school or in home education. 2. A request for the student's school record is received from a public or private school, in- or out-of-state, in which the student is enrolled or plans to enroll. 3. The student has died. 4. The student transferred to a prison or juvenile facility. The following withdrawal procedures are in place for scenarios where a student needs to be removed from the cohort due to emigration: 1. The registering parent notifies the school, in person, that the student is withdrawing because of having to leave the country. 2. The registrar validates the individual requesting to withdraw the student is the registering parent/legal guardian. 3. The registrar goes to the Student Information screen and inputs Code W3B under the transaction code, and inputs in the School Location line, FLOR or out of Florida identifier. 4. The registrar complete the Notice of Withdrawal/Transfer screen in DSIS by inputting the New School Name, New School Address, (City, State, Country), and phone numbers in addition to the out of Florida identifier (FLOR). 5. The registrar prints the Notice of Withdrawal/Transfer screen and the registering parent signs and dates the document. 6. The registrar provides the registering parent with a copy of the signed Notice of Withdrawal/Transfer screen and keeps a copy of the documentation in the student's cumulative folder (CUM). Upon further review, the District examined the Every Student Succeeds Act High School Graduation Rate Non-Regulatory Guidance. The guidance indicates that for students who leave the country, documentation of withdrawal may include the parent's signed confirmation indicating the student is departing the United States. The District's current procedure requiring a parent or guardian signature on the PF15 aligns with this guidance and reflects the parent's formal acknowledgement that the student is leaving the country and no longer enrolled in the District. The District's withdrawal procedures strictly adhere to the Florida Department of Education (FDOE) Automated Student Attendance Recordkeeping System Handbook. Per State protocol, a withdrawal is deemed official when a parent or legal guardian notifies the school that the child is leaving to enroll in another school. M-DCPS considers the parent's signed acknowledgment at the point of withdrawal as official documentation of a change in status, rather than a mere statement of "intent". While the District followed established State recordkeeping protocols, we recognize the Auditor General's emphasis on the additional evidentiary requirements found in Title 20, Section 7801(25), United States Codes. To address the variance between State and Federal requirements, the District will consult with the Florida Department of Education to seek clarification and work toward reconciling State withdrawal codes with Federal graduation cohort documentation standards. ANTICIPATED COMPLETION DATE: 03/04/2027 RESPONSIBLE CONTACT PERSON: Ana M. Gutierrez

View Audit 393099

Finding 1181796 (2025-001)

Material Weakness 2025

Palo Alto History Museum

CA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

The Organization is currently updating its Accounting Policies and Procedures. The revised policies will include a provision requiring that, if federal awards subject to Uniform Guidance (2 CFR Part 200) are received, all required federal financial reports will be independently reviewed and approved...

The Organization is currently updating its Accounting Policies and Procedures. The revised policies will include a provision requiring that, if federal awards subject to Uniform Guidance (2 CFR Part 200) are received, all required federal financial reports will be independently reviewed and approved prior to submission. The Board Treasurer will perform the review, or the Finance Committee Chair if the Treasurer is unavailable. Documentation of the review will be retained with the related reports.

View Audit 393079

Finding 1181792 (2025-004)

Material Weakness 2025

East Central Iowa Workforce Development Board

IA

Subrecipient Monitoring

The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: Revision of its ‘Local Oversight & Monitoring Policy’ as approved by the Board of Directors on May 29, 2025, with a subsequent ‘Post-Award Risk Assessment’ completed on September 22, 2025. Both docum...

The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: Revision of its ‘Local Oversight & Monitoring Policy’ as approved by the Board of Directors on May 29, 2025, with a subsequent ‘Post-Award Risk Assessment’ completed on September 22, 2025. Both documents have since been provided to Iowa Workforce Development to demonstrate compliance with WIOA and Uniform Guidance, Part 200.332.

View Audit 393074

Finding 1181791 (2025-003)

Material Weakness 2025

East Central Iowa Workforce Development Board

IA

Subrecipient Monitoring

The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective July 1, 2025, and were subsequently provide...

The ECIWDB acknowledges this prior deficiency and has already taken the following corrective action: All Sub-Recipient Agreements were re-executed to include elements as required by Uniform Guidance, Part 200.332 and WIOA. These agreements became effective July 1, 2025, and were subsequently provided to Iowa Workforce Development (IWD) and AOS Senior Auditor Tristan Swiggum.

View Audit 393074

Finding 1181783 (2025-003)

Material Weakness 2025

The Cottages at Beaufort, Inc.

GA

Subrecipient Monitoring HUD Housing Programs

2. 2025-003 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. P...

2. 2025-003 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. Policies must be reviewed regularly for compliance. ii. Actions Taken or Planned: Management will ensure continuous fidelity bond coverage and verify that policies remain compliant with HUD requirements.  Responsible Person: Jill Cromartie  Anticipated Completion Date: 09/30/2026  Steps to Implement: Review of existing controls and implementation of new procedures to ensure continuous fidelity bond coverage, including timely renewal and periodic verification that coverage meets HUD requirements.

View Audit 393063

Finding 1181779 (2025-004)

Material Weakness 2025

The Cottages at Beaufort Ii, Inc.

GA

Subrecipient Monitoring HUD Housing Programs

3. 2025-004 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. P...

3. 2025-004 i. Comments on Finding: Fidelity bond coverage lapsed on September 11, 2025, during the audit period ending September 30, 2025. Coverage was reinstated on November 12, 2025. Management should ensure continuous fidelity bond coverage that meets HUD standards throughout the audit period. Policies must be reviewed regularly for compliance. ii. Actions Taken or Planned: Management will ensure continuous fidelity bond coverage and verify that policies remain compliant with HUD requirements.  Responsible Person: Jill Cromartie  Anticipated Completion Date: 9/30/2026  Steps to Implement: Review of existing controls and implementation of new procedures to ensure continuous fidelity bond coverage, including timely renewal and periodic verification that coverage meets HUD requirements.

View Audit 393062

Finding 1181777 (2025-003)

Material Weakness 2025

The Cottages at Beaufort Ii, Inc.

GA

Subrecipient Monitoring HUD Housing Programs

2. 2025-003 i. Comments on Finding: Payments were made for non-project expenses, resulting in noncompliance with HUD requirements. Management should review vendor payment procedures to ensure only Project expenses are paid. ii. Actions Taken or Planned: Payments to vendors will be reviewed to ensure...

2. 2025-003 i. Comments on Finding: Payments were made for non-project expenses, resulting in noncompliance with HUD requirements. Management should review vendor payment procedures to ensure only Project expenses are paid. ii. Actions Taken or Planned: Payments to vendors will be reviewed to ensure they relate to Project expenses and comply with HUD requirements.  Responsible Person: Jill Cromartie  Anticipated Completion Date: 9/30/2026  Steps to Implement: Review of old controls or the implementation of new controls to avoid future noncompliance with HUD

View Audit 393062

Finding 1181775 (2025-002)

Material Weakness 2025

The Cottages at Beaufort Ii, Inc.

GA

Subrecipient Monitoring Equipment & Real Property Management HUD Housing Programs § 200.310

1. 2025-002 i. Comments on Finding: For the year ended September 30, 2025, the Corporation did not maintain the required amount of property insurance coverage for certain portions of the year. Management should ensure that an insurance policy is in place and that coverage amounts meet HUD requiremen...

1. 2025-002 i. Comments on Finding: For the year ended September 30, 2025, the Corporation did not maintain the required amount of property insurance coverage for certain portions of the year. Management should ensure that an insurance policy is in place and that coverage amounts meet HUD requirements consistently throughout the year. ii. Actions Taken or Planned: Insurance coverage will be reviewed and monitored to ensure that an active policy is maintained and that coverage amounts comply with HUD requirements.  Responsible Person: Jill Cromartie  Completion Date: 11/12/2025  Steps to Implement: Review of existing controls and implementation of new procedures to ensure timely premium payments and prevent future lapses in required insurance coverage.

View Audit 393062

Finding 1181773 (2025-004)

Material Weakness 2025

Manor College

PA

Subrecipient Monitoring Internal Control / Segregation of Duties Significant Deficiency

Management has developed a written information security program to comply with the FTC Safeguards Rule. The program documents administrative, technical, and physical safeguards designed to protect customer information and assigns responsibility for oversight and monitoring.

View Audit 393057

Finding 1181741 (2025-002)

Material Weakness 2025

The Hektoen Institute of Medicine, LLC

IL

Subrecipient Monitoring Cash Management Material Weakness § 200.303 § 200.305

Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: Management acknowledges the finding. Delays in approvals may occur due to multiple internal and external parties involved. To prev...

Condition: Controls in place were not sufficient to ensure subrecipients were paid consistently within 30 days of a request for reimbursement. Planned Corrective Action: Management acknowledges the finding. Delays in approvals may occur due to multiple internal and external parties involved. To prevent recurrence, management will monitor all parties, issue email reminders with clear deadlines, and enforce timely processing to ensure compliance with the 30-day requirement. Contact person responsible for corrective action: Teresa Martinez, Lorena Soto, Alvaro Espino and Mariela Romo Anticipated Completion Date: 8/31/2026

View Audit 392991

Corrective Action Plans

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