Corrective Action Plans

Finding 1156598 (2024-001)

Material Weakness 2024

Educate Maine

ME

Reporting Subrecipient Monitoring

Management agrees with the finding and is working on submission of the federal reporting package for the year ended December 31, 2023. The submission of the December 31,2024 federal reporting package will be completed prior to its due date.

View Audit 368944

Finding 1156586 (2024-002)

Material Weakness 2024

Saint Charles County, Missouri

MO

Subrecipient Monitoring Cash Management § 200.332

Action taken in response to finding: The County will review the subrecipient monitoring requirements and work with the County Auditor to develop a formal policy that includes internal controls, monitoring procedures, and documentation requirements.

View Audit 368939

Finding 1156585 (2024-001)

Material Weakness 2024

Saint Charles County, Missouri

MO

Subrecipient Monitoring Reporting

Action taken in response to finding: The County will identify all federal awards that FFATA reporting is required. Once all the requirements are identified, the County will then determine if there are eligible subrecipients or contracts that need to be reported on the FFATA website.

View Audit 368939

Finding 1156582 (2024-003)

Material Weakness 2024

Knox County

IN

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.1 § 200.303

FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Lisa Clark/Benock Contact Phone Number and Email Address: 812-885-2502 lcbenock@knoxcounty.in.gov Views of Responsible for Corrective Action: W...

FINDING 2024-003 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds - Reporting Contact Person Responsible for Corrective Action: Lisa Clark/Benock Contact Phone Number and Email Address: 812-885-2502 lcbenock@knoxcounty.in.gov Views of Responsible for Corrective Action: We concur with the finding. Description of Corrective Action Plan: The annual reporting for fund 8950 – Coronavirus State and Local Fiscal Recovery Funds with the Treasury shall be prepared by the First Deputy, reviewed by an independent accountant to verify and consult that all the information is correct, and the final report will be reviewed and approved by the County Auditor before submission. Anticipated Completion Date: Next annual reporting Due April 30, 2026 for 2025

View Audit 368932

Finding 1156581 (2024-002)

Material Weakness 2024

Knox County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2024-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Lisa Clark/Benock Contact Phone Number and Email Address: 812-885-2502 lcbenock@knoxcounty.in.gov Views of Responsible for Corre...

FINDING 2024-002 Finding Subject: COVID-19 – Coronavirus State and Local Fiscal Recovery Funds – Suspension and Debarment Contact Person Responsible for Corrective Action: Lisa Clark/Benock Contact Phone Number and Email Address: 812-885-2502 lcbenock@knoxcounty.in.gov Views of Responsible for Corrective Action: We concur with the finding. Description of Corrective Action Plan: The County will provide documentation that the vendor/contractor is not suspended or disbarred from participation in federal award programs. The First Deputy will review the website www.sam.gov, a tool to use to look for active exclusions for the contractor/vendor, for any active exclusions, and the County Auditor will review the verification. Anticipated Completion Date: Immediately

View Audit 368932

Finding 1156559 (2024-002)

Material Weakness 2024

Union County

OH

Procurement, Suspension & Debarment Subrecipient Monitoring

The Mental Health and Recovery Board corrected finding 2023-002 on 9/30/24 by adding Suspension and Debarment language to all Contracts and Service Agreements as stated in the 2023 Corrective Action Plan. The contract that was cited in finding 2024-002 was executed on 6/12/2024 which was prior to th...

The Mental Health and Recovery Board corrected finding 2023-002 on 9/30/24 by adding Suspension and Debarment language to all Contracts and Service Agreements as stated in the 2023 Corrective Action Plan. The contract that was cited in finding 2024-002 was executed on 6/12/2024 which was prior to the notification of the 2023 finding.

View Audit 368894

Finding 1156543 (2024-002)

Material Weakness 2024

Samaritas and Subsidiaries

MI

Questioned Costs Eligibility Matching / Level of Effort / Earmarking § 200.303

Contact Person(s): Bridgette Zappacosta Corrective Action Planned: Management concurs with the finding. The Organization will strengthen eligibility verification procedures to ensure that only participants meeting the specific award requirements are approved for benefits. This will include: revising...

Contact Person(s): Bridgette Zappacosta Corrective Action Planned: Management concurs with the finding. The Organization will strengthen eligibility verification procedures to ensure that only participants meeting the specific award requirements are approved for benefits. This will include: revising intake and eligibility documentation protocols to require verification and supervisory sign-off that the individual meets the award’s eligibility definition and providing targeted staff training on eligibility requirements under the Refugee Admissions Program. Quarterly internal reviews of eligibility determinations will be conducted, with exceptions reported to management for corrective action. Anticipated Completion Date: December 31, 2025

View Audit 368884 Questioned Costs: $1

Finding 1156530 (2024-001)

Material Weakness 2024

Journalism Development Network, Inc.

DC

Subrecipient Monitoring Reporting

Views of Responsible Officials: We acknowledge this lapse. We have already updated procedures to ensure that we are registering subgrants correctly.

View Audit 368879

Finding 1156526 (2024-002)

Material Weakness 2024

Sustainable Fisheries Partnership Foundation

HI

Subrecipient Monitoring § 200.332

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends amending existing subaward agreements to include the award information required by CFR 200.332(b) and to verify all future subawards agreements include all necessary information prior to iss...

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends amending existing subaward agreements to include the award information required by CFR 200.332(b) and to verify all future subawards agreements include all necessary information prior to issuance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SFP will revise its subaward agreement template to include all necessary award information as required by CFR 200.332(b). Name(s) of the contact person(s) responsible for corrective action: Annie Haylon Planned completion date for corrective action plan: October 31, 2025

View Audit 368873

Finding 1156518 (2024-001)

Material Weakness 2024

Tyonek Tribal Conservation District

AK

Cash Management Subrecipient Monitoring § 200.1 § 200.305

Federal Award Finding: 2024-001 Material Weakness in Internal Control over Cash Management Name and Contact Person: Laurie Stuart, Executive Director Corrective Action: The Organization has evaluated and revised the processes and procedures regarding cash management and reporting, in efforts to mini...

Federal Award Finding: 2024-001 Material Weakness in Internal Control over Cash Management Name and Contact Person: Laurie Stuart, Executive Director Corrective Action: The Organization has evaluated and revised the processes and procedures regarding cash management and reporting, in efforts to minimize the time elapsing between the transfer of funds from the awarding agency and disbursement by the Organization. The Organization also has processes in place for maintaining detailed records supporting all grant payments, disbursements to vendors, and tracking of grant advances still outstanding. Additionally, the Organization is monitoring interest earned on grant advances and has processes in place to remit interest as appropriate when required in accordance with Uniform Guidance. Management has appointed an individual to oversee these processes for each grant. Management will also submit a revised annual financial report [FFR] for USFWS Agreement No. F23AC02320 to correct any errors related to cash on hand amounts reported. Proposed Completion Date: December 31, 2025

View Audit 368872

Finding 1156516 (2024-002)

Material Weakness 2024

Kama'aina Care, Inc.

HI

Subrecipient Monitoring Reporting Significant Deficiency § 200.329

Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.

View Audit 368868

Finding 1156515 (2024-001)

Material Weakness 2024

Texas Biomedical Research Institute

TX

Cash Management Subrecipient Monitoring § 200.303 § 200.305

Corrective Action Plan Year Ended December 31, 2024 Finding 2024-001 – Cash Management – Pass-Through Entities Condition: Texas Biomed Research Institute (Texas Biomed) did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by Texas Biomed within 30 days ...

Corrective Action Plan Year Ended December 31, 2024 Finding 2024-001 – Cash Management – Pass-Through Entities Condition: Texas Biomed Research Institute (Texas Biomed) did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by Texas Biomed within 30 days of requests for reimbursement received by Texas Biomed. In 18 instances, Texas Biomed paid subrecipients after 30 days of receipt of the request for reimbursement from the subrecipient, resulting in noncompliance with 2 CFR 200.305(b)(3). Corrective Action Plan: Effective June 1, 2023 Texas Biomed implemented enhanced controls to ensure timely entry of subrecipient invoices into the financial system and timely approvals by Principal Investigators (PIs) of invoices. While these controls were operating effectively after the implementation date, turnover within the Accounts Payable team had not been anticipated and led to delayed payment processing. In mid-2024, Texas Biomed implemented a new electronic AP/invoice system as part of a comprehensive Enterprise Resource Planning system (and associated supporting systems) conversion to enhance efficiencies and functionality. With implementation of new systems, control enhancements enabled by the systems were implemented. This included setting up subawards as Purchase Orders, which enabled automation of a previously manual process to secure PI approval of invoices. Accounts Payable staff have been trained on how to properly enter subaward invoices into the system to trigger electronic routing to the PI for approval. While these steps will streamline the approval process, a further mitigating control will be implemented, with Accounts Payable staff periodically tracking approvals of pending subrecipient invoices and notifying the appropriate Sponsored Program Administrator for follow up with PIs in the event of delayed approvals. Responsible Parties: Eva Zepeda, Director, Finance; Michelle Hyde, Controller Completion Date: September 30, 2024

View Audit 368866

Finding 1156504 (2024-001)

Material Weakness 2024

Romulus Housing Commission

MI

Questioned Costs Subrecipient Monitoring Eligibility

Report period: 12/31/2024 Title of result and comment FY24 Audit Corrective Action Plan Contact person Responsible for Sabrina Bollinger Corrective Action: Contact's Phone Number 248-593-4611 Contact's Email Address: sbollinger@fourmidable,com Views of Responsible Official: Management agrees with th...

Report period: 12/31/2024 Title of result and comment FY24 Audit Corrective Action Plan Contact person Responsible for Sabrina Bollinger Corrective Action: Contact's Phone Number 248-593-4611 Contact's Email Address: sbollinger@fourmidable,com Views of Responsible Official: Management agrees with the auditor's finding and will implement the auditor's recommendations. Description of Corrective Action Plan The Commission should implement internal controls over tenant files to ensure accountability. Allcertifications and the required documentation should be maintained in the tenant's current file. Additionally,in order to ensure certifications are performed timely and tenant information is input correctly, theCommission should have a second party review files in a timely manner. Anticipated Completion Date: The plan is to implement the corrective action within six months of the audit date. If applicable: Document reason issue will NOT be corrected with 6 months: N/A

View Audit 368862 Questioned Costs: $1

Finding 1156503 (2024-002)

Material Weakness 2024

City of Tacoma

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

Subrecipient Monitoring and Suspension & Debarment. Neighborhood & Community Services (NCS) has existing processes to ensure subrecipient monitoring requirements and suspension and debarment requirements. While not all JAG subrecipients had previously been included, beginning in 2025, all subrecipie...

Subrecipient Monitoring and Suspension & Debarment. Neighborhood & Community Services (NCS) has existing processes to ensure subrecipient monitoring requirements and suspension and debarment requirements. While not all JAG subrecipients had previously been included, beginning in 2025, all subrecipients of JAG funding are being included in NCS processes. Specifically, one position (Contract/Program Auditor) is assigned to each contract and is responsible for verifying and documenting suspension and debarment at award and at the annual renewal and also for ensuring monitoring is completed. Prior to the audit, NCS had begun scheduling with the subrecipient that had not been monitored, consistent with NCS processes. NCS is currently also developing a grant handbook to ensure that all staff are aware of general and specific grant requirements and processes for managing grants. Procurement. The City’s procurement policies and procedures outline the process for the competitive procurement of services using federal funds, in alignment with federal regulations. However, the City acknowledges that certain aspects of the current policies maybe unclear or inconsistence with existing procedures. Additionally, the City recognizes that its internal controls are not fully effective in ensuring that all departments consistently comply with these policies and procedures. To strengthen internal control, the City will revise its procedure and develop and implement training around federal grants for staff responsible for managing or overseeing these contracts.

View Audit 368860

Finding 1156500 (2024-001)

Material Weakness 2024

City of Tacoma

WA

Subrecipient Monitoring

To meet Federal Funding and Transparency Act (FFATA) reporting requirements, the City will take the following actions: Update training material for all accounting staff and City departments managing federal grants. Update and distribute monthly email to departments to clarify the required informatio...

To meet Federal Funding and Transparency Act (FFATA) reporting requirements, the City will take the following actions: Update training material for all accounting staff and City departments managing federal grants. Update and distribute monthly email to departments to clarify the required information for FFATA filing and require responses with supporting documentation for review. If responses are not received in a timely manner, a second email will be sent to those individuals, requiring an immediate action. Periodically review federal reporting requirements for any updates and adjust the reporting process as needed, utilizing resources such as the State Auditor’s Office (SAO) Newsletter, conferences, and trainings.

View Audit 368860

Finding 1156484 (2024-001)

Material Weakness 2024

Northwest Youth Services

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this pol...

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this policy and procedure to ensure rental rates fall within federal grant compliance requirements at the time of each lease signing or renewal. Documentation of rent reasonableness certification will be performed by NWYS housing staff, reviewed by NWYS housing service leadership, and maintained in the client’s permanent file, as defined in the NWYS Rent Reasonableness Policy. Name(s) of Responsible Party:  NWYS Housing leadership staff – Luis Reyna, Addison Ausley, Daniel Pry Anticipated Completion Date:  9/5/25

View Audit 368841 Questioned Costs: $1

Finding 1156477 (2024-002)

Material Weakness 2024

Lifewire

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.430

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underly...

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underlying the attestations were erroneous. In addition, LifeWire was not able to secure an attestation from a former employee before they departed the organization. In 2025, LifeWire is revising their attestation procedure such that contract-supported staff members will attest to the nature of their work instead of amounts of time to contracts. This will simplify the administrative burden of attestations and reduce opportunities for errors while still meeting our audit and contract funders’ requirements. We anticipate this revised method will be rolled out by the end of Q3-2025. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: Procedure rollout will be completed by the end of Q3-2025. Anticipated full compliance with the requirement will be in evidence through the end of 2025 and beyond.

View Audit 368819

Finding 1156474 (2024-001)

Material Weakness 2024

Lifewire

WA

Subrecipient Monitoring HUD Housing Programs Reporting § 200.303

Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental...

Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental payment request made with public funds. LifeWire’s AP approval process requires review and approval by members of the Director team before payments can be issued. In 2025, all rental payments made with CoC funds now have documented evidence of internal approval and review. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: The new process was rolled out in November 2024.

View Audit 368819

Finding 1156466 (2024-001)

Material Weakness 2024

Council Towers Housing Development Fund Corporation

NY

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.

View Audit 368800 Questioned Costs: $1

Finding 1156465 (2024-001)

Material Weakness 2024

Wadhwani Institute for Artificial Intelligence Foundation

CA

Subrecipient Monitoring Reporting

Corrective Action Plan Finding Reference: Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting (FFATA) Date of finding: Financial Audit 2024 Responsible Parties: Amy Frizzi and David Mangene 1. Management's Response Management accepts the finding and agrees with the a...

Corrective Action Plan Finding Reference: Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting (FFATA) Date of finding: Financial Audit 2024 Responsible Parties: Amy Frizzi and David Mangene 1. Management's Response Management accepts the finding and agrees with the auditor's recommendations and further acknowledges that a subaward contract under which FFATA reporting was required was not submitted within the required 30 days after the subaward was executed. 2. Corrective Action FFATA Reporting: Wadhwani Institute for Artificial Intelligence Foundation (WIAI) is working to gain access to the SAM.gov reporting capabilities for the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) to ensure proper reporting for any and all required FFATA reporting is met for new federal subawards. Process Enhancement: WIAI will ensure comprehensive reporting processes for federal grants are in place prior to engaging as a prime or subrecipient, including tracking reporting and other significant deadlines. 2024 Finding Resolution: The specific grant referenced in this finding was terminated in January 2025. The awarding agency (USAID) has since been functionally dismantled by the Trump administration, with 83% of programs eliminated as of March 2025 and remaining functions transferred to the State Department. Given the agency's operational dissolution and the grant's termination, late FFATA reporting for the 2024 subaward is not feasible through normal channels. Management will monitor for any guidance from the State Department regarding reporting obligations for grants from the former USAID structure. 3. Timeline FSRS Access: Target completion by December 2025 (pending SAM.gov registration resolution) Process Documentation: Within 60 days of FSRS access being obtained Full Implementation: Upon receipt of next federal subaward requiring FFATA reporting Ongoing Monitoring: Monthly grant reviews and comprehensive year-end validation Prepared by: Ann Marie Ilibasic, Grants & Compliance Consultant Reviewed by: David Martin, Audit Committee Chair Next Review Date: Fiscal Year End 2025

View Audit 368798

Finding 1156463 (2024-001)

Material Weakness 2024

King County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contra...

The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contract requests through established King County Procurement processes, and timelines to submit similar requests through central procurement with sufficient time to allow central procurement to perform all the necessary legal and compliance checks necessary for the associated transactions. After initial training, all existing key personnel will receive repeat training every 2 years; all new staff will receive training as part of onboarding procedures.

View Audit 368796

Finding 1156460 (2024-001)

Material Weakness 2024

Power Forward Communities, Inc.

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.180

Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will streng...

Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will strengthen its internal controls around debarment checks for vendors in both its procurement and contracting processes to address the finding as follows: Procurement • PFC will use a process checklist for its procurements, similar to the checklist PFC developed for its coalition members. • The checklist will include an additional step for a debarment search on SAM.gov and require internal confirmation and documentation that this debarment check is valid. • This process checklist will be reviewed and signed off when complete by PFC management for each procurement. • PFC will include completed checklists to accompany each procurement memo. Contracting • PFC will continue including debarment language in each of its vendor contracts to ensure adherence to 2 CFR Section 180.300. • For vendors with contracts above $25,000, PFC will implement quality control by running a debarment search twice annually, once in June and once in December every year. This documentation will be saved to the vendor file.

View Audit 368780

Finding 1156452 (2024-001)

Material Weakness 2024

Unleashing Potential

MO

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.430

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hour...

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hours incurred compared to the estimated amounts by individuals assigned to federal grant programs prior to requesting reimbursement from the funding course. The review will be performed by an individual other than the preparer of the reimbursement request, with knowledge of the federal grant program and will be formally documented.

View Audit 368766

Finding 1156451 (2024-001)

Material Weakness 2024

Illinois Network of Charter Schools

IL

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member ...

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member - the CSP Grant Manager - to oversee FFATA reporting and maintain a comprehensive log of all qualifying subawards. The CSP Grant Manager will provide training to finance and grants management staff on FFATA reporting requirements and timelines. Joyanna Smith, CPOO, will conduct monthly reviews of subaward activity to ensure all required reporting is completed by the end of the month following the obligation date. FFATA reporting will be incorporated into INCS’s quarterly internal compliance monitoring process to sustain ongoing compliance.

View Audit 368752

Finding 1156392 (2024-001)

Material Weakness 2024

Liberty Terrace Apartments

IN

Questioned Costs HUD Housing Programs Special Tests & Provisions

Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on...

Finding 2024-001: The Corporation did not make all required reserve for replacements deposits during the year ended December 31, 2024. Comments on the Finding and Each Recommendation: The Corporation should make a deposit of $30,975 to the reserve for replacements fund. Action(s) Taken or Planned on the Finding: The Corporation concurs with the recommendation and will make the deposit to fully fund the reserve for replacements fund.

View Audit 368702 Questioned Costs: $1

Corrective Action Plans

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