Corrective Action Plans

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April 27, 2026 Person responsible: Teresa Council, Executive Director Fiscal Year Ended June 30, 2025 Section III – Federal Awards Findings and Questioned Costs Item 2025 – 001 Federal Assistance Listing Number: 10.558 – Child and Adult Care Food Program Federal Assistance Listing Number: 93.575 – C...
April 27, 2026 Person responsible: Teresa Council, Executive Director Fiscal Year Ended June 30, 2025 Section III – Federal Awards Findings and Questioned Costs Item 2025 – 001 Federal Assistance Listing Number: 10.558 – Child and Adult Care Food Program Federal Assistance Listing Number: 93.575 – Child Care and Development Block Grant – CCDF Cluster Condition The Organization’s Data Collection Form submission to the Federal Audit Clearinghouse was not filed on time within nine months of the end of its fiscal year. Current Status The delay in submission to the FAC was due to a combination of factors, including the extended time required to prepare the fiscal year 2025 financial statements and compile supporting documentation, as well as delays in the completion of the audit process. To support timely future submissions, the Organization will implement the recommended control procedures and adopt an internal timeline beginning with the fiscal year ending June 30, 2026. In addition, the audit process will be initiated earlier to ensure completion and submission by the established deadline of March 31, 2027.
The Finance and Administration Department will create an internal policy requiring a copy of the SAM.gov search results for the vendor, including the date of the search, and store the documentation in the appropriate grant file. Further, the policy will require a sign-off process where the vendor pa...
The Finance and Administration Department will create an internal policy requiring a copy of the SAM.gov search results for the vendor, including the date of the search, and store the documentation in the appropriate grant file. Further, the policy will require a sign-off process where the vendor payment cannot be finalized without a "Debarment Check Complete". The Finance and Administration Department will include quality control checks and perform regular internal audits of a sample of vendor files related to grants to check for the presence of the Suspension and Debarment Check. Personnel Responsible for Implementation: Meredith Elguira, Carol Molina, Ralston Turner Position of Responsible Personnel: Interim Community Development Director, Finance and Administration Director, Senior Finance Analyst Expected Date of Implementation: April 30, 2026
Management will update its procurement policies and procedures to require formal evidence that suspension and debarment checks are completed prior to entering into contracts. This will include requiring staff to sign/initial, and date SAM.gov verification screenshots or reports, or alternatively, ob...
Management will update its procurement policies and procedures to require formal evidence that suspension and debarment checks are completed prior to entering into contracts. This will include requiring staff to sign/initial, and date SAM.gov verification screenshots or reports, or alternatively, obtain vendor certifications confirming their status. Training will be provided for relevant personnel to ensure consistent implementation of the revised procedures.
FINDING 2025-017 Name of Responsible Individual: Director of Post Award Compliance and Training Senior Associate Vice President of Financial Strategy Corrective Action: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report...
FINDING 2025-017 Name of Responsible Individual: Director of Post Award Compliance and Training Senior Associate Vice President of Financial Strategy Corrective Action: In response to the auditor’s recommendation to strengthen internal controls and ensure timely submission of the Single Audit Report to the Federal Audit Clearinghouse, Howard University will enhance cross collaboration across the University to improve audit readiness. During the May 2025 transition from the Grants and Contracts Accounting Office to the Sponsored Awards Office, the University experienced significant staff turnover and a loss of institutional knowledge, which contributed to audit readiness challenges. Since that time, the University has focused on stabilization efforts. The Office of Research Sponsored Programs has been restructured and is now almost fully staffed. The University will be establishing monthly check ins with key stakeholders to ensure adherence to a compliance calendar with clearly defined roles and responsibilities across core compliance areas. Additionally, the University has hired a Director of Post Award Compliance and Training to lead audit readiness efforts, strengthen internal controls, and support ongoing monitoring and compliance throughout the fiscal year. Anticipated Completion Date: March 31, 2027
FINDING 2025-016 Name of Responsible Individual: Director of Post Award Compliance and Training Christina Flood, Budget Analyst Corrective Action: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted ...
FINDING 2025-016 Name of Responsible Individual: Director of Post Award Compliance and Training Christina Flood, Budget Analyst Corrective Action: Monthly Settlement Reports are used to reconcile actual expenses. An outdated spreadsheet was previously used to convert travel expenses, which resulted in incorrect exchange rate calculations. The team has implemented an updated conversion process. Going forward, the Sponsored Program Office Team will review and approve the exchange rates to ensure they are reasonable, accurate, and applied consistently. Anticipated Completion Date: June 30, 2026
FINDING 2025-015 Name of Responsible Individual: Assistant Vice President of Procurement Director of Post Award Compliance and Training Corrective Action: In response to the auditor’s recommendation to enhance internal controls and ensure timely review of invoice protocols and subrecipient monitorin...
FINDING 2025-015 Name of Responsible Individual: Assistant Vice President of Procurement Director of Post Award Compliance and Training Corrective Action: In response to the auditor’s recommendation to enhance internal controls and ensure timely review of invoice protocols and subrecipient monitoring, Howard University is implementing the following: • The University is currently piloting a new Supplier Invoice Portal, launched jointly by the Sponsored Programs Office and the Office of Procurement, to improve invoicing efficiency and compliance. Under this new process, subrecipients will be required to submit invoices electronically in accordance with the terms and conditions of their subawards. The portal will support a streamlined review and approval process, with invoices routed through an automated workflow to ensure timely review and disbursement. • To support completion of the University’s annual audit verification requirements for subrecipients, oversight will occur at multiple stages throughout the subaward lifecycle. This includes reviewing audit reports at the proposal development stage, during which subrecipients are required to complete a Subrecipient Commitment Form (implemented September 2025) prior to proposal submission. • At the award stage, refreshed due diligence will be conducted, including a re-review of the subrecipient’s Single Audit and/or financial statements. Finally, the Post Award Compliance team will perform an annual review of subrecipients’ audit reports and complete audit follow up procedures as necessary. Anticipated Completion Date: August 30, 2026
FINDING 2025-014 Name of Responsible Individual: Assistant Vice President for Post Award Corrective Action: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include pre...
FINDING 2025-014 Name of Responsible Individual: Assistant Vice President for Post Award Corrective Action: The University initiated the Effort Certification process to capture the full calendar year 2025 in April 2026. This represents a one-time extended certification period designed to include previously uncertified periods that had concluded, specifically the second half of FY25 (January–June 2025) and the first half of FY26 (July–December 2025). In May 2025, the non-accounting functions of Grants and Contracts Accounting at Howard University were transitioned to the Office of Research, Sponsored Programs Office. During this organizational transition, the University prioritized the completion and accuracy of all costing allocations to ensure payroll data was complete and reliable for effort certification purposes. This period was also utilized to identify and resolve any backlog of costing allocations and award charges and stabilize the Office of Research. Addressing these items ensured that effort reflected complete and accurate payroll activity, thereby enabling Principal Investigators to appropriately review and certify their effort. The Sponsored Programs Office (SPO) now leads post-award financial oversight and collaborates with Human Resources (HR) and Finance to ensure designated personnel are identified and granted system access to enter costing allocations and labor cost transfers in Workday. In addition, in response to the auditor’s recommendation to enhance internal controls and ensure timely monitoring of effort reporting, Howard University has implemented the following corrective actions: Hired Dedicated Departmental Support – Six College Research Administrators (CRAs) and an Associate Director of CRA’s were hired to support high-volume research colleges. The CRAs ensure timely and accurate labor cost transfers, effort certification, and costing allocation entries during award setup and throughout the award lifecycle. Enhanced Effort Reporting Process – SPO will lead improvements to the effort certification process, including: • Advance communication to PIs, CRAs, and Deans outlining certification deadlines • Clear guidance on when labor cost transfers may occur outside the certification cycle • Reinforcement that all effort changes must be reflected in the effort system to ensure alignment with payroll. • Training – Targeted training will be delivered to Principal Investigators, CRAs, and other research stakeholders to support consistent application of policies and procedures. Monitoring and Oversight – Monthly and quarterly reconciliation reports will be developed to track and validate timely and accurate payroll allocations for research personnel. Anticipated Completion Date: August 30, 2026
In response to the Auditor’s recommendations, the Municipality will establish formal procedures to ensure that all required forms, including Form 90-91, are properly completed, maintained, and submitted in accordance with applicable grant requirements. Additionally, all supporting documentation rela...
In response to the Auditor’s recommendations, the Municipality will establish formal procedures to ensure that all required forms, including Form 90-91, are properly completed, maintained, and submitted in accordance with applicable grant requirements. Additionally, all supporting documentation related to the period of performance for each project will be identified, organized, and maintained, including approved project worksheets, grant award documentation, and related financial records. Furthermore, monitoring mechanisms and periodic reviews will be implemented to ensure ongoing compliance with applicable requirements and the timely availability of required documentation for audit and monitoring purposes.
In response to the Auditor’s recommendations and as corrective action, the staff responsible or department will locate and document all required reports that were filed in accordance with the grant agreement requirements, including reconciliations with the Municipality’s official accounting subsidia...
In response to the Auditor’s recommendations and as corrective action, the staff responsible or department will locate and document all required reports that were filed in accordance with the grant agreement requirements, including reconciliations with the Municipality’s official accounting subsidiary ledgers. Furthermore, the Municipality will design, document, establish, and provide the necessary training, along with written guidelines and procedures, to all personnel who work directly or indirectly with the management of these federal funds. In addition, the Municipality will implement periodic reviews and monitoring mechanisms to ensure ongoing compliance with reporting requirements and the accuracy of financial information related to federal funds.
Finding 1211187 (2025-001)
Material Weakness 2025
Syntiro
ME
We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a pr...
We agree with the finding and will review and implement the recommendations accordingly. We are committed to ensuring proper application of indirect costs, avoiding duplication of costs across reporting periods, and maintaining compliance with allocability requirements under Uniform Guidance on a prospective basis. This corrective action plan will be implemented by June 30, 2026.
All donor‑restricted balances were reviewed to identify instances where restrictions had been satisfied but not released timely. Required releases were recorded to correct net asset classifications in the general ledger. Where available, supporting documentation (e.g., expenditure reports, grant ter...
All donor‑restricted balances were reviewed to identify instances where restrictions had been satisfied but not released timely. Required releases were recorded to correct net asset classifications in the general ledger. Where available, supporting documentation (e.g., expenditure reports, grant terms, and donor agreements) was acquired and reviewed to substantiate the timing of releases. Management plans to enhance controls over donor restriction tracking by implementing clearer procedures for identifying restriction satisfaction, improving cross-department communication, and strengthening review controls to ensure timely and accurate recording of donor restriction releases. Auditor’s Evaluation of the Corrected Action Plan: Wesleyan College’s response was appropriate for immediate remediation for the current affected period. Furthermore, the plan for preventative actions appears to be appropriately focused to achieve timely and documented of releases related to satisfied purpose or time conditions.
Wesleyan College management has completed all outstanding reconciliations for the affected periods. Reconciling items noted during the delayed reconciliations were reviewed, investigated, and resolved or appropriately aged and documented. Evidence of supervisory review has been added to completed re...
Wesleyan College management has completed all outstanding reconciliations for the affected periods. Reconciling items noted during the delayed reconciliations were reviewed, investigated, and resolved or appropriately aged and documented. Evidence of supervisory review has been added to completed reconciliations where missing. Management is in the process of developing and implementing remediation and preventative actions, including strengthening reconciliation policies, assigning clear ownership and escalation procedures, and implementing monitoring controls to ensure reconciliations are prepared and reviewed timely. These actions are expected to improve the effectiveness of controls over material account balance reconciliations. Auditor’s Evaluation of the Corrected Action Plan: Wesleyan College’s response was appropriate for immediate remediation for the current affected period. Furthermore, the plan for preventative actions appears to be appropriately focused to ensure reconciliations are prepared and reviewed timely.
Finding ref number: 2025-002 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations, 216 North G Street, Aberde...
Finding ref number: 2025-002 Finding caption: The District did not have adequate internal controls and did not comply with time-and-effort requirements. Name, address, and telephone of District contact person: Elyssa Louderback, Executive Director of Business & Operations, 216 North G Street, Aberdeen, WA. 98520. (360) 538-2007 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for non-concurrence). The district will make sure all staff are listed on the Semi-Annual Certifications. Staff with braided funding will have a PAR with monthly verifications. Anticipated date to complete the corrective action: February 1, 2026
2025-001-Internal Control over Financial Reporting, Health Resources and Services Administration Native Hawaiian Health Care 93.932, Significant adjusting journal entries, Due to lack of fiscal staff and high turnover, the organization fell behind on audits, and therefore, many adjusting entries wer...
2025-001-Internal Control over Financial Reporting, Health Resources and Services Administration Native Hawaiian Health Care 93.932, Significant adjusting journal entries, Due to lack of fiscal staff and high turnover, the organization fell behind on audits, and therefore, many adjusting entries were required to reconcile accounts. The audits have been completed, and all accounts have been reconciled as of July 31, 2025. In addition to the high turnover, during fiscal year ending 2024, there was an increase in donor funding to assist with the Lahaina wildfires recovery efforts. Again, our staff were challenged to meet the demands of the requirements of the funding and to continue to monitor the previous and current fiscal years financial state.
Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.
Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.
Health Center Program Cluster, Assistance Listings 93.224, 93.527 Special Tests and Provisions Recommendation: Wallace should strengthen controls over the sliding fee discount process by implementing system validations to support accurate sliding fee discount schedule (SFDS) application, requiring d...
Health Center Program Cluster, Assistance Listings 93.224, 93.527 Special Tests and Provisions Recommendation: Wallace should strengthen controls over the sliding fee discount process by implementing system validations to support accurate sliding fee discount schedule (SFDS) application, requiring documented income verification prior to billing, and performing periodic supervisory reviews to ensure consistent compliance with Section 330 requirements. Planned Corrective Action: Management agrees with the finding. Management will strengthen controls over the sliding fee discount process by requiring documented income verification prior to billing, reinforcing proper application of the sliding fee discount schedule, and performing periodic supervisory reviews of patient encounters subject to sliding fee discount requirements. These corrective actions are intended to address the specific deficiencies identified in the application of Special Tests and Provisions requirements. Contact Person Responsible for Corrective Action: Daisy Velasco, Director of Operations Anticipated Completion Date: June 30, 2026
Corrective Action Plan: A new procurement policy was developed, reviewed, and formally approved by the Board of Directors on January 20, 2026. The policy establishes procurement procedures aligned with industry best practices and strengthens internal controls to ensure transparency, accountability, ...
Corrective Action Plan: A new procurement policy was developed, reviewed, and formally approved by the Board of Directors on January 20, 2026. The policy establishes procurement procedures aligned with industry best practices and strengthens internal controls to ensure transparency, accountability, and compliance with applicable requirements. Individual(s) Responsible: Yolanda Adams Completion Date: Policy was voted on by the board and put into place subsequent to year end.
Corrective Action Plan: Training and ongoing education initiatives have been implemented to ensure reports are completed and submitted in accordance with established deadlines. The new Chief Financial Officer is actively monitoring report status and accuracy to ensure timely compliance. A defined re...
Corrective Action Plan: Training and ongoing education initiatives have been implemented to ensure reports are completed and submitted in accordance with established deadlines. The new Chief Financial Officer is actively monitoring report status and accuracy to ensure timely compliance. A defined reporting structure has been established to strengthen oversight, accountability, and adherence to all reporting requirements. Individual(s) Responsible: Yolanda Adams Completion Date: Plan has been implemented as of date of audit submission.
Finding 2025-002: Lower Income Housing Assistance Program – Section 8 New Construction/ Substantial Rehabilitation Assistance Listing Number: 14.182 U.S. Department of Housing and Urban Development (Repeat of Finding 2024-003) Compliance Requirements: Special Tests and Provisions Type of finding: In...
Finding 2025-002: Lower Income Housing Assistance Program – Section 8 New Construction/ Substantial Rehabilitation Assistance Listing Number: 14.182 U.S. Department of Housing and Urban Development (Repeat of Finding 2024-003) Compliance Requirements: Special Tests and Provisions Type of finding: Internal Control Over Compliance (material weakness) and Compliance (material noncompliance) Recommendation: The Organization should strengthen its internal controls with adopted policies and procedures to establish a monitoring process to ensure compliance with Mortgage Restructuring Loan terms and conditions. Action Taken: Action Taken: The Organization has accepted the recommendation to strengthen internal controls regarding Mortgage Restructuring Loan terms. We are currently in active remediation, working in direct coordination with our HUD Account Exexuctive, to ensure our adopted policies align with the federal requirments. Our HUD Account Exexuctive, has been notified of the finalized 2025 Auditied financials and are currently working to set up a time to discuss a Management Action Plan regarding a recommedation for Mortgage Restructuring controls. If these are questions regarding this plan, please call the responsible part at (719)852-5578. Sincerely yours, Brenda Quintana Administrator Tri-County Senior Citizens and Housing, Inc.
ASTHO concurs with this recommendation. The CFO/Vice President, Finance will: 1. Update subrecipient monitoring procedures to determine at time of subaward: a. If subrecipient has a history with ASTHO b. If subrecipient is required to conduct a single audit c. Obtain copies of single audits for the ...
ASTHO concurs with this recommendation. The CFO/Vice President, Finance will: 1. Update subrecipient monitoring procedures to determine at time of subaward: a. If subrecipient has a history with ASTHO b. If subrecipient is required to conduct a single audit c. Obtain copies of single audits for the applicable period. 2. Require no later than September 15, 2026, Program Operations will ensure for all subrecipients included on preliminary SEFA as of July 31, 2026, that any single audit reports have been collected and reviewed. 3 Require that upon completion of the final SEFA for the year ended September 30, 2026, single audits have been obtained and reviewed for any subrecipients that were not reported on the preliminary July 31, 2026 SEFA. 4. These processes will be repeated for years subsequent to 2026.
The Florida School Nutrition Association, Inc. (FSNA) acknowledges the audit finding regarding the misalignment between the pass-through entity’s grant agreement and the OMB Compliance Supplement for ALN 10.185. While the Association operated in accordance with the terms of the executed agreement wi...
The Florida School Nutrition Association, Inc. (FSNA) acknowledges the audit finding regarding the misalignment between the pass-through entity’s grant agreement and the OMB Compliance Supplement for ALN 10.185. While the Association operated in accordance with the terms of the executed agreement with the Florida Department of Agriculture and Consumer Services, it was subsequently determined that certain administrative costs permitted under that agreement were not allowable under the Uniform Guidance (2 CFR Part 200). Finding 2025-001: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Upon identification of this discrepancy, FSNA has taken immediate and decisive action: Program Termination & Strategic Shift: FSNA has formally concluded its participation in the Local Food for Schools Cooperative Agreement Program and has ceased all related activities. The Association has made the strategic decision not to pursue or engage in federal grant programs of this nature moving forward. This determination ensures alignment with the organization’s operational capacity and mitigates compliance risk associated with complex federal cost principles. Final Resolution: The identified material weakness has been addressed through the discontinuation of the applicable program, thereby removing the operational conditions under which the noncompliance occurred. Future Funding Consideration (If Applicable): While FSNA does not anticipate pursuing similar federal awards, the organization has established an internal standard that any future funding opportunities, if considered, will undergo a comprehensive compliance review to ensure alignment with the Uniform Guidance (2 CFR Part 200), the OMB Compliance Supplement, and all grantspecific terms and conditions. Record Retention: FSNA will maintain all financial and supporting documentation related to the FY25 audit period in accordance with applicable federal record retention requirements.
View of Responsible Officials and Planned Corrective Actions: In actual practice, the resettlement case managers make their best efforts to respond to the refugees' needs fully. That is why they are usually too short of time to make complete case notes. As a corrective action, we have arranged for t...
View of Responsible Officials and Planned Corrective Actions: In actual practice, the resettlement case managers make their best efforts to respond to the refugees' needs fully. That is why they are usually too short of time to make complete case notes. As a corrective action, we have arranged for the department director and supervisor to receiive regular training sessions with our funding source's grant specialist.
Finding 2025-004: Finding of Significant Deficiency in Internal Control over Eligibility and Subrecipient Monitoring and Finding of Non-compliance ALN 14.241 Housing Opportunities for Persons with AIDS (HOPWA) Award #TXH22-F004, TXH23-F004 and TXH24-F004, 2025, U.S. Department of Housing and Urban D...
Finding 2025-004: Finding of Significant Deficiency in Internal Control over Eligibility and Subrecipient Monitoring and Finding of Non-compliance ALN 14.241 Housing Opportunities for Persons with AIDS (HOPWA) Award #TXH22-F004, TXH23-F004 and TXH24-F004, 2025, U.S. Department of Housing and Urban Development ALN 93.686 Ending the HIV Epidemic: A Plan for America - Ryan White HIV/AIDS Award # 5 UT8HA33918-05-00 and 5 UT8HA33918-06-00, 2025, U.S. Department of Health & Human Services Contact Person – Adrienne Sturrup, Director, Austin Public Health Management Response – Concur. Management has taken the following steps to address this finding: 1. Process Improvement: The department is: • reviewing the interlocal agreement to update the language for greater clarity on requirements. • mapping the process for requesting, receiving and requiring financial audits and single audits. • identifying the appropriate party to review and follow-up on any areas of concern identified in a Single Audit. 2. Internal Control: Periodic supervisory verification that audits are obtained and reviewed. 3. Additional training: • After mapping out the process for tracking and requiring financial and single audits, training will be provided to staff and vendors. • If department staff will be reviewing and following-up on financial and single audits, appropriate level of staff and aligned trainings will be identified and provided. Estimated Completion – September 30, 2026.
Finding 2025-002: ALN 93.686 Ending the HIV Epidemic: A Plan for America - Ryan White HIV/AIDS, 5 UT8HA33918-05-00 & 5 UT8HA33918-06-00, U.S. Department of Health & Human Services — Significant Deficiency in Internal Control over Reporting and Finding of Non-compliance Contact Person – Adrienne Stur...
Finding 2025-002: ALN 93.686 Ending the HIV Epidemic: A Plan for America - Ryan White HIV/AIDS, 5 UT8HA33918-05-00 & 5 UT8HA33918-06-00, U.S. Department of Health & Human Services — Significant Deficiency in Internal Control over Reporting and Finding of Non-compliance Contact Person – Adrienne Sturrup, Director, Austin Public Health Management Response – Concur. Management has taken the following steps to address this finding: 1. Submission Completed: The required FFATA subaward report has since been submitted to Sam.gov as of March 3, 2026. 2. Process Improvement: Austin Public Health has established/updated procedures for FFATA reporting, including a clearly assigned responsibility to the appropriate staff for monitoring and submitting grant-required reports. 3. Internal Control: We will be adding more staff to the authorized list, which now includes the program's Financial Analyst. This analyst will be able to submit and upload documentation to SAM.gov. He/she will also coordinate with the Admin Support Finance team to ensure the accuracy of FFATA information before uploading any documents. Estimated Completion – June 30, 2026.
Ocosta School District No. 172 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Pri...
Ocosta School District No. 172 September 1, 2024 through August 31, 2025 This schedule presents the corrective action planned by the District for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2025-01 Finding caption: The District did not have adequate internal controls and did not comply with federal suspension and debarment requirements. Name, address, and telephone of District contact person: Robert Butler 2580 S. Montesano St. Westport, WA 98595 360.268.9125 ext. 1004 Corrective action the auditee plans to take in response to the finding: The District acknowledges the finding and appreciates the opportunity to strengthen our documentation practices related to suspension and debarment verification. We would like to clarify that the District did perform suspension and debarment checks through SAM.gov for the vendors in question on an annual basis. While these procedures were consistently completed, the District did not retain independent documentation of those checks. The District relied on SAM.gov as the authoritative federal system of record, including its historical tracking and notification features, rather than maintaining locally stored or printed copies. At the time, staff were not aware that compliance requirements required retention of documentation evidencing these checks. As a result, this finding reflects a documentation deficiency rather than the absence of the control itself. As confirmed during the audit, all vendors tested were in good standing and not suspended or debarred. Therefore, the District was not at risk of contracting with an ineligible vendor, and no questioned costs were identified.
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