Corrective Action Plans

Finding 498169 (2024-001)

Significant Deficiency 2024

SC

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended June 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $4,110 from the operating account to the reserve for replacements acco...

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended June 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $4,110 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. Management deposited $4,110 to the reserve for replacements account on August 7, 2024. No further action is required.

View Audit 320908 Questioned Costs: $1

Finding 498167 (2024-001)

Significant Deficiency 2024

Lancaster Landing, Inc.

SC

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended June 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $1,000 from the operating account to the reserve for replacements acco...

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended June 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $1,000 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. Management deposited $1,000 to the reserve for replacements account on August 28, 2024. No further action is required.

View Audit 320905 Questioned Costs: $1

Finding 498165 (2024-001)

Significant Deficiency 2024

Ipock, Inc.

SC

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended June 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $548 from the operating account to the reserve for replacements accoun...

Finding #2024-001: Comments on the Finding and Each Recommendation: During the year ended June 30, 2024, the Corporation did not make the HUD required number of deposits to the reserve for replacements. Management should transfer $548 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation. On August 28, 2024, management transferred $548 to the reserve for replacements account. No further action is required.

View Audit 320903 Questioned Costs: $1

Finding 497594 (2024-002)

Significant Deficiency 2024

Dogwood Retirement Housing, Inc. Dba Dogwood Retirement Apts.061-Eh142

CA

HUD Housing Programs Subrecipient Monitoring

Finding 2024-002: Two of the move-in residents' security deposits tested were not collected timely. Comments on the Finding and Each Recommendation: Management should collect the security deposit at the time of resident move-in. Action(s) taken or planned on the finding: Agree. Management will col...

Finding 2024-002: Two of the move-in residents' security deposits tested were not collected timely. Comments on the Finding and Each Recommendation: Management should collect the security deposit at the time of resident move-in. Action(s) taken or planned on the finding: Agree. Management will collect the security deposit at the time of move-in. During the year ended May 31, 2024, the residents' security deposits were collected. There is no further action required.

View Audit 320355

Finding 497593 (2024-001)

Significant Deficiency 2024

Dogwood Retirement Housing, Inc. Dba Dogwood Retirement Apts.061-Eh142

CA

Questioned Costs Subrecipient Monitoring

Finding 2024-001: The resident security deposit account did not have adequate funds to cover the security deposits collected at May 31, 2024. Comments on the Finding and Each Recommendation: Management should reconcile the security deposit listing on a monthly basis and transfer funds from the oper...

Finding 2024-001: The resident security deposit account did not have adequate funds to cover the security deposits collected at May 31, 2024. Comments on the Finding and Each Recommendation: Management should reconcile the security deposit listing on a monthly basis and transfer funds from the operating cash account to ensure the resident security deposit account is adequately funded. Action(s) taken or planned on the finding: Agree. On July 22, 2024, Management transferred $223 from the operating cash account to fully fund the security deposit account.

View Audit 320355 Questioned Costs: $1

Finding 497401 (2024-001)

Material Weakness 2024

Charter Township of Clinton

MI

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Finding Number: 2024-001 Condition: We noted no formal evidence that required inspections were performed prior to contract approval in one instance. We also noted no formal evidence that inspections were performed upon project completion to ensure that work was carried out in accordance with contrac...

Finding Number: 2024-001 Condition: We noted no formal evidence that required inspections were performed prior to contract approval in one instance. We also noted no formal evidence that inspections were performed upon project completion to ensure that work was carried out in accordance with contract specifications in one instance. Planned Corrective Action: After the inspector has done the initial walk through to identify required repairs, a full comprehensive write-up and cost is established for all rehabilitation projects that document additional repairs to be completed that are more preventative in nature. Any additional items discovered during the project or requested by the homeowner will be added to the write-up. For any emergency repairs, a memorandum will be added to the file. To ensure that pre_x0002_rehabilitation and post-rehabilitation inspections are taking place, the Assistant Planning Director will review a list of ongoing rehabilitation projects at a minimum on a monthly basis. Contact person responsible for corrective action: Edwin Manninen Anticipated Completion Date: Immediately

View Audit 320150

Finding 496411 (2024-001)

Material Weakness 2024

Full Harvest Housing, Inc.

IA

Allowable Costs / Cost Principles Questioned Costs Special Tests & Provisions

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED MARCH 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended March 31, 2024. Finding 2024-001 Responsible Party Name: Tamara Wallace Position: Executive Director – Management Agent Telephone Number: 816-233-4250 Federal Agency Department of Housing and Urban Development Federal Program Supportive Housing for the Elderly (Section 202) Compliance Requirements A/B - Activities Allowed or Unallowed and Allowable Costs/Cost Principles, C – Cash Management, E – Eligibility, L – Reporting, and N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action Management reported that the failure(s) involved records related to the period managed by the predecessor management company. We will request and keep all required documentation from HUD and establish processes and procedures to ensure compliance with the Regulatory Agreement. Anticipated Completion Date September 30, 2024

View Audit 319319

Finding 496232 (2024-001)

Significant Deficiency 2024

Lakefront Senior Residences, Inc.

KS

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Statement of condition #2024-001: The Corporation did not furnish HUD with a complete Management Occupancy Review response within 30 days. Comments on the Finding and Each Recommendation: Management should submit a plan to resolve all deficiencies within 30 calendar days of the date of the receipt ...

Statement of condition #2024-001: The Corporation did not furnish HUD with a complete Management Occupancy Review response within 30 days. Comments on the Finding and Each Recommendation: Management should submit a plan to resolve all deficiencies within 30 calendar days of the date of the receipt of the report. Action(s) taken or planned on the finding: No further action is necessary. Management's response was submitted on October 27, 2023.

View Audit 319176

Finding 496230 (2024-001)

Significant Deficiency 2024

MacArthur Manor Senior Residences, Inc.

KS

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Statement of condition #2024-001: The Corporation used reserve for replacements funds for a non-approved purpose. Comments on the Finding and Each Recommendation: Management should reimburse the reserve for replacements fund all excess funds withdrew. Action(s) taken or planned on the finding: Man...

Statement of condition #2024-001: The Corporation used reserve for replacements funds for a non-approved purpose. Comments on the Finding and Each Recommendation: Management should reimburse the reserve for replacements fund all excess funds withdrew. Action(s) taken or planned on the finding: Management refunded $2,717 to reserve for replacement account on August 13, 2024.

View Audit 319175 Questioned Costs: $1

Finding 496228 (2024-001)

Significant Deficiency 2024

Southern Hills Senior Residences, Inc.

KS

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Statement of condition #2024-001: The Corporation did not furnish HUD with a complete Management Occupancy Review response within 30 days. Comments on the Finding and Each Recommendation: Management should submit a plan to resolve all deficiencies within 30 calendar days of the date of the receipt ...

Statement of condition #2024-001: The Corporation did not furnish HUD with a complete Management Occupancy Review response within 30 days. Comments on the Finding and Each Recommendation: Management should submit a plan to resolve all deficiencies within 30 calendar days of the date of the receipt of the report. Action(s) taken or planned on the finding: No further action is necessary. Management's response was submitted on October 31, 2023.

View Audit 319174

Finding 496226 (2024-001)

Significant Deficiency 2024

Woodlake Senior Residences, Inc.

KS

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Statement of condition #2024-001: The Corporation did not furnish HUD with a complete Management Occupancy Review response within 30 days. Comments on the Finding and Each Recommendation: Management should submit a plan to resolve all deficiencies within 30 calendar days of the date of the receipt ...

Statement of condition #2024-001: The Corporation did not furnish HUD with a complete Management Occupancy Review response within 30 days. Comments on the Finding and Each Recommendation: Management should submit a plan to resolve all deficiencies within 30 calendar days of the date of the receipt of the report. Action(s) taken or planned on the finding: No further action is necessary. Management's response was submitted on October 30, 2023.

View Audit 319173

Finding 486020 (2024-003)

Material Weakness 2024

Central Michigan University Research Corporation

MI

Subrecipient Monitoring § 200.332

Corrective Action Plan: Management will review the required procedures for pass-through entities as listed in 2 CFR 200.332 and implement the procedures accordingly. This will include documented risk assessment and monitoring procedures for all subrecipient of federal awards.

View Audit 318710

Finding 485762 (2024-001)

Material Weakness 2024

Mountain Famly Health Centers

CO

Subrecipient Monitoring § 200.331

Federal Program: Coronavirus State and Local Recovery Funds Assistance Listing No. 21.027 Recommendation: Our auditors recommended that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring an...

Federal Program: Coronavirus State and Local Recovery Funds Assistance Listing No. 21.027 Recommendation: Our auditors recommended that the Organization create an internal policy over sub-grant recipient procedures and create effective internal controls and procedures over subrecipient monitoring and tracking that allow for compliance with all applicable Federal laws, regulations, and compliance requirements of various Federal grants Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization has accepted the recommendation and will add language to the existing Grant Funds Tracking Policy and Procedure outlining the Organization’s responsibilities for establishing effective internal controls and procedures over subrecipient monitoring. The updated policy will also include reference to the Information to Provide to Every Subrecipient for Each Subaward form. This form outlines details of the pass-through grant, and subrecipient responsibilities, and will be signed by each subrecipient prior to any pass-through fund disbursement. Also, the Organization will educate supervisors on this policy update at an upcoming training meeting no later than October 31, 2024.

View Audit 318603

Finding 485748 (2024-001)

Significant Deficiency 2024

Lockport Housing Authority

NY

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Auditee Response: The Authority will not pay any invoices until the proper documentation of Davis Bacon wages being paid is received from the contractor. The Authority will then be ensured that future payments have the proper certified payroll.

View Audit 318581

Finding 485611 (2024-002)

Significant Deficiency 2024

Fulton County Community Unit School District No. 3

IL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Response and Corrective Action Plan: The District will review current processes for identifying, coding and reporting federal expenditures and implement processes to ensure amounts reported are supported by the District’s general ledger.

View Audit 318383

Finding 485276 (2024-007)

None 2024

Village of Kingsley

MI

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

This finding is due to the Village not having control procedures in place to submit the annual Project and Expenditure Report for the reporting period ended March 31, 2024, accurately or within 30 days of the close of the reporting period. In the future, the Village will have controls in place to en...

This finding is due to the Village not having control procedures in place to submit the annual Project and Expenditure Report for the reporting period ended March 31, 2024, accurately or within 30 days of the close of the reporting period. In the future, the Village will have controls in place to ensure accurate and timely filing of the report. The person responsible for the corrective action is the Village Manager. The anticipated completion date of the corrective action plan is before the end of the 2025 fiscal year. The plan for adherence is the Council will build a timeline for preparation and completion of the report to ensure timely and accurate filing.

View Audit 318038

Finding 485250 (2024-007)

None 2024

Village of Baldwin

MI

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

This finding is due to the Village not having formal written policies in place required by Uniform Guidance. The Village is now aware that these policies are required and will adopt all necessary policies. The Village does not believe that there were any actual nonallowable costs or transactions bec...

This finding is due to the Village not having formal written policies in place required by Uniform Guidance. The Village is now aware that these policies are required and will adopt all necessary policies. The Village does not believe that there were any actual nonallowable costs or transactions because of the lack of written policies as required by Uniform Guidance. The Village will adopt all necessary policies to be in compliance. The person responsible for the corrective action is the Village President. The anticipated completion date of the corrective action plan is before the end of the 2025 fiscal year. The plan for adherence is the Council will review all proposed policies and adopt them, the Council will also monitor any changes to policy requirements to ensure that they are in compliance in the future.

View Audit 318008

Finding 485172 (2024-002)

Significant Deficiency 2024

Regis University

CO

Student Financial Aid Questioned Costs Special Tests & Provisions

Finding 2024-002 Personnel Responsible for Corrective Action: Cathy Gorrell, Registrar Anticipated Completion Date: September 30, 2024 Corrective Action Plan: The Office of the Registrar recognizes the systematic programming of a pseudo academic program after a pseudo course has been added with a ...

Finding 2024-002 Personnel Responsible for Corrective Action: Cathy Gorrell, Registrar Anticipated Completion Date: September 30, 2024 Corrective Action Plan: The Office of the Registrar recognizes the systematic programming of a pseudo academic program after a pseudo course has been added with a future date after the student’s current program has been inactivated or graduated. This process has been at the request of the Office of Student Accounts for the graduation fee. The Office of the Registrar will work with the Office of Student Accounts to move to the system Graduation Application process rather than the customized and manual process of pseudo courses. Further, the Office of the Registrar has increased its data quality checks on the pseudo programs and courses. In conjunction, this should eliminate the reporting of active programs when the student has graduated.

View Audit 317977

Finding 403896 (2024-001)

Material Weakness 2024

Uncompahgre Combined Clinics Dba Uncompahgre Medical Center

CO

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that the support for the...

Recommendation: Our auditors recommended the Organization to review internal controls in regards to the determination, recording, and monitoring of the sliding fee process to ensure that appropriate sliding fee rates/categories are utilized for each sliding fee encounter and that the support for the sliding fee discounts is retained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Organization recognizes the deficiency of internal controls regarding determination, recording, and monitoring of the sliding fee process from application through adjustment. The Organization has acknowledged that along with our Finance Team being new to the position for all of 2023 along with the realization that our electronic medical record was making an automatic adjustment on the Federal Poverty Level. This automatic adjustment issue has been resolved. We also reviewed the monthly adjustments and have implemented a monthly oversight process to review adjustments made to patient accounts. If the U.S. Department of Health and Human Services has questions regarding this plan, please call Tricia Lippert, Comptroller at 970-327-0537.

View Audit 310773

Finding 403361 (2024-001)

Significant Deficiency 2024

Ott's Branch Elderly Housing, Inc.

SC

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Finding #2024-001 Comments on Findings and Recommendation: During the year ended March 31, 2024, deposits to the reserve for replacements account were $236 less than the required amount. Management should transfer $236 from the operating account to the reserve for replacements account. Action(s) tak...

Finding #2024-001 Comments on Findings and Recommendation: During the year ended March 31, 2024, deposits to the reserve for replacements account were $236 less than the required amount. Management should transfer $236 from the operating account to the reserve for replacements account. Action(s) taken or planned on the finding: Management concurs with the finding and recommendation.

View Audit 310491 Questioned Costs: $1

Finding 1229621 (2023-011)

Material Weakness 2023

Municipality of Anchorage, Alaska

AK

Subrecipient Monitoring § 200.303 § 200.332 § 200.501

Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan: The Municipality has begun implementing standardized subrecipient monitoring procedures, including documented risk assessments, monitoring protocols, supervisory review,...

Subrecipient Monitoring – Material Noncompliance and Material Weakness in Internal Control Over Compliance Corrective Action Plan: The Municipality has begun implementing standardized subrecipient monitoring procedures, including documented risk assessments, monitoring protocols, supervisory review, and enhanced oversight to strengthen compliance with Uniform Guidance requirements. Management will evaluate the effectiveness of these controls through completion of a full audit cycle. Anticipated Completion Date June 30, 2027

View Audit 410871

Finding 1229291 (2023-001)

Material Weakness 2023

Oklahoma City County Health Department

OK

Subrecipient Monitoring

Fiscal Year Ended June 30, 2023 CFDA: 93.297 Federal Awarding Agency: U.S. Department of Health and Human Services Federal Program Title: Reproductive Education to Achieve Community Health (Project REACH) Teenage Pregnancy Prevention Program Finding: FFATA Reporting Finding No. 2023-001 Audit Findin...

Fiscal Year Ended June 30, 2023 CFDA: 93.297 Federal Awarding Agency: U.S. Department of Health and Human Services Federal Program Title: Reproductive Education to Achieve Community Health (Project REACH) Teenage Pregnancy Prevention Program Finding: FFATA Reporting Finding No. 2023-001 Audit Finding The audit identified incomplete Federal Funding Accountability and Transparency Act (FFATA) reporting. Required data elements were omitted from one or more FFATA submissions because of deficiencies in the organization’s internal reporting process. Root Cause The organization determined that the missing FFATA data resulted from an internal process gap. Existing procedures did not include adequate controls to ensure that all required FFATA data elements were identified, reviewed, and verified prior to submission. Roles and responsibilities for collecting and validating reporting information were not sufficiently documented. Corrective Action Planned The organization will implement the following corrective actions: 1. Review all affected federal awards to identify incomplete or missing FFATA data. 2. Correct and submit all outstanding FFATA reports in accordance with federal reporting requirements. 3. Develop and implement written FFATA reporting procedures that define: o Required data elements. o Reporting timelines. o Staff responsibilities. o Review and approval requirements. 4. Implement a standardized FFATA reporting checklist to verify completeness and accuracy before each submission. 5. Provide training to employees responsible for FFATA reporting on applicable requirements and internal procedures. 6. Establish supervisory review and approval of all FFATA submissions before they are finalized. 7. Incorporate periodic internal monitoring to verify continued compliance and identify any reporting deficiencies promptly. Anticipated Completion Date All corrective actions will be implemented within 90 days of acceptance of this Corrective Action Plan unless otherwise directed by the federal awarding agency or pass-through entity. Responsible Official Responsible Position: Janice Slaughter, Finance Officer The responsible official will oversee implementation of the corrective actions, monitor progress, verify completion, and maintain documentation supporting compliance. Status of Prior Corrective Actions This is a new finding. No prior corrective action plan exists for this issue. Monitoring and Internal Control Improvements Management will monitor implementation of the corrective actions through periodic internal reviews, documented supervisory approvals, and annual evaluations of FFATA reporting procedures. Any deficiencies identified through monitoring will be addressed promptly through additional corrective actions and staff training. Expected Outcome Implementation of these corrective actions will result in complete, accurate, and timely FFATA reporting, strengthened internal controls over federal reporting, and reduced risk of future noncompliance.

View Audit 410770

Finding 1228735 (2023-005)

Material Weakness 2023

Activate Work Inc.

CO

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.308

Action Taken in Response to Finding: Budget-to-actual comparisons began in 2024 and were subsequently standardized and incorporated into Financial Policies and Procedures. As of 2026, budget-to-actual comparisons are performed on a monthly basis as part of the month-end (EOM) close, prior to the pre...

Action Taken in Response to Finding: Budget-to-actual comparisons began in 2024 and were subsequently standardized and incorporated into Financial Policies and Procedures. As of 2026, budget-to-actual comparisons are performed on a monthly basis as part of the month-end (EOM) close, prior to the preparation and submission of Federal reimbursement requests. This ensures that: • Expenditures are reviewed against approved grant budgets prior to reimbursement • Variances are identified and evaluated • Costs charged to Federal awards align with approved budgets and allowable use requirements Additionally, Budget and Program Revisions and Allowable Use of Funds policies were incorporated into the Financial Policies and Procedures to formalize requirements for budget compliance and modification. Control Enhancement: A standardized budget-to-actual review has been implemented across all applicable Federal awards. This process: • Compares actual expenditures to approved grant budgets on a monthly basis • Identifies variances requiring review or correction • Ensures expenditures are aligned with budget categories and allowable cost requirements • Requires budget review prior to submission of reimbursement requests Monitoring & Review: • Budget-to-actual comparisons are performed monthly as part of EOM close • Initial review is completed by Finance • Secondary review is performed by the Director of Finance & Operations • Program staff are engaged as needed to validate alignment with program activities • Any required budget modifications are identified and addressed prior to reimbursement Testing & Validation: • Beginning in June 2026, quarterly internal reviews will be conducted to validate that budget monitoring controls are operating effectively • Testing will confirm that: o Budget-to-actual reviews are completed consistently o Variances are appropriately identified and addressed o Reimbursements align with approved budgets Documentation & Evidence: • Budget-to-actual reports maintained in Teams / Sharepoint • Supporting documentation for budget revisions retained • Approval and review evidenced via email/workflow/sign-off Control Owner(s): • Director of Finance & Operations • Finance Team Responsible Party: Director of Finance & Operations, with executive oversight by the Chief Executive Officer Anticipated Completion Date: All corrective actions will be implemented by June 30, 2026. Ongoing monthly monitoring and quarterly validation will continue. Status: • Budget-to-actual comparisons (limited): Implemented 2024 • Standardized monthly workflow (EOM close): Implemented April 2026 • Policy integration into Financial Policies and Procedures: Completed May 2026 • Quarterly internal reviews will be conducted to validate that budget monitoring controls are operating effectively: June 2026

View Audit 410398

Finding 1228734 (2023-004)

Material Weakness 2023

Activate Work Inc.

CO

Allowable Costs / Cost Principles Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.307 § 200.403

Action Taken in Response to Finding: Financial practices addressing program income were in place; however, processes were formalized to ensure full compliance with 2 CFR §200.307. ActivateWork developed and implemented a Program Income Policy as part of its Financial Policies and Procedures, adopted...

Action Taken in Response to Finding: Financial practices addressing program income were in place; however, processes were formalized to ensure full compliance with 2 CFR §200.307. ActivateWork developed and implemented a Program Income Policy as part of its Financial Policies and Procedures, adopted May 2026. As of March 2026, a standardized program income tracking and reconciliation is performed monthly as part of the month-end (EOM) close. This process includes: • Identification and tracking of program income by funding source • Application of program income to actual allowable expenses • Mapping of Federal reimbursement requests to underlying expenses to ensure program income is applied prior to reimbursement • Validation that no duplication of funding occurs between program income and Federal reimbursements These enhancements establish a structured and auditable framework for program income tracking, application, and compliance. Control Enhancement: Program income is tracked and recorded within a standardized Excel-based tool (Program Income vs. Unreimbursed Cost Analysis) and applied in accordance with federal requirements. A standardized program income tracker: • Applies program income to actual expenses • Links expenses to reimbursement requests • Ensures program income is fully utilized prior to requesting Federal reimbursement, unless otherwise specified by award terms • Prevents duplication of income and reimbursement Monitoring & Review: • Program income tracking is reviewed monthly as part of the EOM close process • Review is performed by the Senior Accountant • A secondary review is performed by the Director of Finance & Operations to validate completeness and compliance • Any discrepancies are identified and resolved prior to reimbursement submission Testing & Validation: • Beginning in June 2026, quarterly internal reviews will be conducted to validate program income tracking and application • Testing will confirm that: o Program income is accurately recorded o Program income is applied prior to reimbursement o No duplication of funding exists • Results will be documented and tracked for remediation Documentation & Evidence: • Program income tracker maintained in Teams / SharePoint • Supporting documentation tied to underlying expenses Control Owner(s): • Director of Finance & Operations • Finance Team Responsible Party: Helen Young Hayes, Founder / Chief Executive Officer, in coordination with the Director of Finance & Operations and Finance Staff Anticipated Completion Date: All corrective actions will be implemented by June 30, 2026. Ongoing monthly monitoring, reconciliation, and quarterly validation will continue. Status: • Program Income Policy: Implemented May 2026 • Program income tracking process: Implemented April 2026 • Monthly reconciliation and application (EOM Close): Implemented May 2026 • Quarterly internal reviews will be conducted to validate program income tracking and application: June 2026.

View Audit 410398

Finding 1228733 (2023-003)

Material Weakness 2023

Activate Work Inc.

CO

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting § 200.214 § 200.332

Action Taken in Response to Finding: A Subrecipient Monitoring Policy was implemented in May 2023 to establish processes for subrecipient identification, agreement requirements, invoice review, and ongoing monitoring. The policy was developed in alignment with guidance provided by the CDLE monitorin...

Action Taken in Response to Finding: A Subrecipient Monitoring Policy was implemented in May 2023 to establish processes for subrecipient identification, agreement requirements, invoice review, and ongoing monitoring. The policy was developed in alignment with guidance provided by the CDLE monitoring team. In subsequent years, the subrecipient monitoring framework was strengthened. As of February 2026, CLA’s grant management team has been engaged to further enhance subrecipient monitoring processes. Enhancements include: • Formalization and expansion of the Subrecipient Monitoring Policy, incorporated into the Financial Policies and Procedures, adopted May 2026 • Implementation of a standardized risk assessment process to evaluate subrecipient risk prior to award issuance • Implementation of a formal Subrecipient Monitoring Memorandum process to document monitoring activities • Implementation of a standardized monthly monitoring checklist to ensure consistent financial and compliance review (effective October 2025) • Establishment of a secondary review control requiring validation by the Chief Operating Officer or Chief Executive Officer in addition to the initial review by the Director of Finance & Operations (effective June 2026) These enhancements strengthened documentation, consistency, and oversight, and established a structured and audit-ready subrecipient monitoring framework. Control Enhancement: ActivateWork has strengthened its subrecipient monitoring practices through the implementation of a structured and documented framework that includes: A segregation of duties has been implemented within the monitoring framework, requiring preparer-level review by the Director of Finance & Operations and secondary review by executive leadership (Chief Operating Officer or Chief Executive Officer). These controls are integrated into ongoing financial operations to ensure subrecipient monitoring is consistently applied, documented, and reviewed. 1. Subaward Identification & FSRS Reporting Subawards are identified and tracked within the Subrecipient Determination Checklist. First-tier subaward reporting is completed in accordance with federal requirements. The Director of Finance & Operations is responsible for ensuring FSRS reporting is completed timely and accurately in accordance with federal deadlines, and documentation of submission is retained within the subrecipient file. 2. Suspension and Debarment (SAM.gov) Subrecipients are verified against SAM.gov prior to contract execution. Documentation of verification is retained in subrecipient files and is included as part of the Subrecipient Determination Checklist. 3. Risk Assessment (Pre-Award) A formal risk assessment is conducted prior to issuing subawards using a standardized scoring methodology that evaluates: • Experience with grants • Program complexity • Funding size • Documentation quality • Prior monitoring issues This assessment is documented within the Subrecipient Determination Checklist. 4. Ongoing Financial Monitoring Monthly invoice reviews are conducted, including: • Mathematical accuracy • Alignment with contract terms • Allowability, allocability, and reasonableness under 2 CFR Part 200 • Reconciliation to supporting documentation This is documented and maintained in the Subrecipient Monthly Monitoring Checklist. 5. Programmatic Monitoring Ongoing coordination is conducted between ActivateWork and subrecipient program staff to monitor: • Program delivery • Participant outcomes • Alignment with grant deliverables 6. Subrecipient Audit Review Subrecipient audit information is obtained and reviewed when applicable. The Director of Finance & Operations is responsible for review, and documentation is maintained within the Subrecipient Monthly Monitoring Checklist. 7. Subaward Agreement Requirements Subaward agreements include required federal award information, compliance expectations, and reporting requirements. The Director of Finance & Operations utilizes a subrecipient agreement template provided by the CDLE monitoring office and ensures all federal award information is complete. 8. Personnel Cost Monitoring (Payroll / Fringe) Personnel costs are reviewed based on documentation provided and evaluated for: • Alignment with program delivery • Reasonableness of allocations • Consistency with invoice detail Review is performed by the Director of Finance & Operations, with documentation maintained within the Subrecipient Monthly Monitoring Checklist. Monitoring & Review: • Monthly monitoring is conducted using a standardized checklist • All invoices are reviewed prior to approval and payment • Issues are documented and tracked through resolution Testing & Validation: • Beginning in June 2026, quarterly internal reviews will be conducted to validate that subrecipient monitoring controls are operating effectively • Monitoring documentation will be reviewed for completeness and compliance Documentation & Evidence: • Monitoring memorandums maintained for each subrecipient • Monthly monitoring checklists retained • Supporting documentation maintained in Teams / SharePoint Control Owner(s): • Director of Finance & Operations • Finance Team • Program Leadership Responsible Party: Director of Finance & Operations, with executive oversight by the Chief Executive Officer Anticipated Completion Date: All corrective actions will be implemented as of June 30, 2026. Ongoing monitoring, documentation, and quarterly validation will continue as part of standard operations. Status: • Subrecipient monitoring policy: Adopted May 2023 and updated annually • Monitoring documentation (memorandum and checklist): Implemented in 2024 and enhanced in Oct 2025 • Policy strengthened: May 2026 to incorporate enhanced documentation, standardized procedures, and secondary review controls • Quarterly internal reviews will be conducted to validate the subrecipient monitoring controls are operating effectively: Jun 2026

View Audit 410398

Corrective Action Plans

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