Corrective Action Plans

Finding 1176751 (2025-004)

Material Weakness 2025

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2025-004 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Ellen Prince and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; c...

FINDING 2025-004 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Audit Findings: Material Weakness, Modified Opinion Contact Person Responsible for Corrective Action: Ellen Prince and Chrystal Street Contact Phone Number and Email Address: ellenprince@crothersville.k12.in.us; cstreet@crothersville.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The district has implemented enhanced documentation procedures requiring written justification for all future ESSER-funded purchases, including identification of the program purpose and connection to learning loss when applicable. The district’s centralized grant binder will serve as the official tracking document for federal programs. The binder includes grant identification details, funding source, compliance requirements, and expenditure documentation. Anticipated Completion Date: January 2026

View Audit 390661

Finding 1176718 (2025-002)

Material Weakness 2025

Pensdale Housing, Inc.

CA

Subrecipient Monitoring Eligibility HUD Housing Programs

Comments on the Finding and Each Recommendation The Property received a NSPIRE inspection dated August 1, 2024. The inspection resulted in a score of 59 (out of a possible 100). Scores below 60 are referred to the Departmental Enforcement Center. Management must maintain the Property in decent, safe...

Comments on the Finding and Each Recommendation The Property received a NSPIRE inspection dated August 1, 2024. The inspection resulted in a score of 59 (out of a possible 100). Scores below 60 are referred to the Departmental Enforcement Center. Management must maintain the Property in decent, safe, and sanitary condition and good repair. Management must respond to HUD in three days of receiving the inspection report and confirm all lifethreatening deficiencies have been corrected. Action(s) taken or planned on the finding Management and the Board of Directors concur with the finding and the auditor's recommendations. Management has responded to HUD in regard to this inspection report and on July 8, 2025 another inspection was conducted that resulted in a final score of 95 (out of a possible 100).

View Audit 390616

Finding 1176716 (2025-001)

Material Weakness 2025

Pensdale Housing, Inc.

CA

Subrecipient Monitoring

Comments on the Finding and Each Recommendation The Form SF-SAC Single Audit Data Collection Form for the year ended May 31, 2022 was not submitted to the federal audit clearinghouse in the required timeframe. The Corporation should submit the Form SF-SAC Single Audit Data Collection Forms for the y...

Comments on the Finding and Each Recommendation The Form SF-SAC Single Audit Data Collection Form for the year ended May 31, 2022 was not submitted to the federal audit clearinghouse in the required timeframe. The Corporation should submit the Form SF-SAC Single Audit Data Collection Forms for the year ended May 31, 2022 as soon as practical. Action(s) taken or planned on the finding Management and the Board of Directors concur with the finding and the auditor's recommendations. Form SF-SAC Single Audit Data Collection Form for the year ended May 31, 2022 will be submitted to the federal audit clearinghouse as soon as practical.

View Audit 390616

Finding 1176647 (2025-002)

Material Weakness 2025

Vanderbilt University Medical Center

TN

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

Federal Program: Department of Homeland Security Assistance Listing: 97.036 Federal Agency: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Entity: State of Tennessee Grant Award Number: All FEMA Projects (Projects 435263,550461, 684580) Award Per...

Federal Program: Department of Homeland Security Assistance Listing: 97.036 Federal Agency: COVID-19 Disaster Grants – Public Assistance (Presidentially Declared Disasters) (FEMA) Pass-Through Entity: State of Tennessee Grant Award Number: All FEMA Projects (Projects 435263,550461, 684580) Award Period: Project 435263: 1/1/2020-7/31/2021 Project 550461: 1/1/2020-7/31/2021 Project 684580: 8/1/2020-6/30/2022 Management understands that additional audit evidence must be retained at a detailed enough level to allow the auditor to meet their reperformance standard. All expenses claimed were eligible and were reviewed by management prior to the submission. The control issue identified is due to the lack of evidence to support approval. Should management have a future FEMA claim we will retain additional audit evidence to enable auditor reperformance of the controls regarding approval of expenditures. Paula Yarbrough, VUMC Director – Grants and Contracts will be responsible for the implementation by fiscal year-end 2026.

View Audit 390522

Finding 1176646 (2025-001)

Material Weakness 2025

Vanderbilt University Medical Center

TN

Subrecipient Monitoring Procurement, Suspension & Debarment Reporting § 200.303

Federal Program: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing: 93.110 Federal Agency: Maternal and Child Health Federal Consolidated Programs (MCH) Grant Award Number: 5 T73MC30767-09 Award Period: 7/1/2024-6/30/2025 Management ...

Federal Program: U.S. Department of Health and Human Services, Health Resources and Services Administration (HRSA) Assistance Listing: 93.110 Federal Agency: Maternal and Child Health Federal Consolidated Programs (MCH) Grant Award Number: 5 T73MC30767-09 Award Period: 7/1/2024-6/30/2025 Management agrees with the finding and has strengthened our internal controls and procedures to ensure required FFATA reports are submitted timely in compliance with the Federal Transparency Act. Paula Yarbrough, VUMC Director – Grants and Contracts will be responsible for the implementation by fiscal year-end 2026.

View Audit 390522

Finding 1176645 (2025-011)

Material Weakness 2025

Second Judicial District Court

NM

Subrecipient Monitoring Reporting Significant Deficiency

The agency concurs with this finding as the documents provided by the agency showed that some contracts that were modified and met the required threshold for FFATA reporting was not done when the modifications were approved. FFATA reporting has been done by the agency but a breakdown in the reportin...

The agency concurs with this finding as the documents provided by the agency showed that some contracts that were modified and met the required threshold for FFATA reporting was not done when the modifications were approved. FFATA reporting has been done by the agency but a breakdown in the reporting process by the agency did not include reporting contracts that has modification. The agency is revising internal policies and procedures to ensure all staff responsible for FFATA reporting understand that all contracts, including contracts that have modifications that increase funding up to the threshold of FFATA reporting, must be included in the FFATA reporting. Continuous training will be done for all financial staff responsible for FFATA training.

View Audit 390502

Finding 1176644 (2025-010)

Material Weakness 2025

Second Judicial District Court

NM

Subrecipient Monitoring § 200.332

The agency concurs with this finding as subrecipient monitoring has increased significantly with increase federal funding award to the agency. Subrecipient monitoring has been in place but with new staff being hired the agency processes were not monitored and followed to ensure subrecipient monitori...

The agency concurs with this finding as subrecipient monitoring has increased significantly with increase federal funding award to the agency. Subrecipient monitoring has been in place but with new staff being hired the agency processes were not monitored and followed to ensure subrecipient monitoring requirements were completed. The agency is in the process of strengthening its policies as they are related to subrecipient monitoring. The agency is in the process of reviewing and strengthening its internal policy related to subrecipient monitoring. The agency is working with the State Controller’s Office to include subrecipient monitoring training which will take place in early 2026. The agency is implementing standardized processes to include subrecipient checklist that will be included in all agreements that will identify if the agreement is a subrecipient or contract. The agency is working to ensure all agreement templates have correct subrecipient language Per 2 CFR §200.332 prior to submission for signatures.

View Audit 390502

Finding 1176629 (2025-001)

Material Weakness 2025

Brooklyn Law School

NY

Student Financial Aid Subrecipient Monitoring Reporting

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of a...

Brooklyn Law School Single Audit Corrective Action Plan For the Year Ending June 30, 2025 Section III - Federal Awards Findings and Questioned Costs Finding 2025-001: Significant Deficiency - NSLDS Enrollment Reporting Criteria: Title IV regulations (34 CFR 685.309(b)) require that upon receipt of an enrollment report from the Secretary of the Department of Education (Secretary), institutions must update all information included in the report and return the report to the Secretary: (I) in the manner and format prescribed by the Secretary; and (ii) within the timeframe prescribed by the Secretary. Unless the institution expects to submit its next updated enrollment report to the Secretary within the next 60 days, an institution must notify the Secretary within 30 days after the date the institution discovers that: (i) a loan under Title IV of the Act was made to or on behalf of a student who was enrolled or accepted for enrollment at the institution, and the student has ceased to be enrolled on at least a halftime basis or failed to enroll on at least a half-time basis for the period for which the loan was intended or (ii) a student who is enrolled at the institution and who received a loan under Title IV of the Act has changed his or her permanent address. Condition: The Law School did not notify the National Student Loan Data System (NSLDS) in a timely manner for 23 students with status changes in our sample of 25 students. For 2 out of 25 students selected in the sample, the effective date that was reported to the NSLDS did not match the date that the student changed status. The sample was not a statistically valid sample. Questioned Costs: There are no questioned costs associated with this finding. Cause: The Law School's controls surrounding the reporting of students’ statuses and status effective dates to the NSLDS did not appropriately ensure the information was submitted accurately or timely. Effect: The accuracy of the Title IV student loan records depends heavily on the accuracy of the enrollment information reported by schools. If an institution does not review, update, and verify student enrollment statuses, effective dates of the enrollment status, and the anticipated completion dates, then the Title IV student loan records will be inaccurate. Recommendation: We recommend that the Law School review its procedures for student status changes and NSLDS notifications to ensure there are follow-up and review procedures being performed for all students with status changes at the Law School to ensure accurate and timely reporting. Management Response: Management agrees with the finding, The Director of Financial Aid and the Registrar will implement procedures and controls in fiscal 2026 to ensure accurate and timely updating of the enrollment reports to NSLDS. Anticipated Completion Date: June 30, 2026 Responsible Person: John K. Zhang, Vice President for Finance and Board Treasurer (718)-780-7503 - john.zhang@brooklaw.edu

View Audit 390480

Finding 1176625 (2025-008)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles § 200.305

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the sub...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring remittance of federal funds directly to subrecipients, rather than paying vendors on the subrecipient's behalf. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective October 1, 2025, all subrecipients were notified that payments would be made only to them, requiring them to directly pay their contractors and vendors. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: October 1, 2025

View Audit 390474

Finding 1176622 (2025-005)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring the review and approval of performance, with such review and approval clearly documented. Ex...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement formal policies and procedures requiring the review and approval of performance, with such review and approval clearly documented. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective January 1, 2026, the Executive Director will review a PDF copy and document approval via email of OARN's Semi-Annual Progress Reports prior to uploading into the EHB. Name(s) of the contact person(s) responsible for corrective action: Kendra Jones, Executive Director Planned completion date for corrective action plan: January 1, 2026

View Audit 390474

Finding 1176620 (2025-003)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Procurement, Suspension & Debarment Subrecipient Monitoring

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend the Association design controls to ensure an adequate review process is in place to review potential subrecipients, contractors, or vendors to determine they are no...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend the Association design controls to ensure an adequate review process is in place to review potential subrecipients, contractors, or vendors to determine they are not suspended or debarred prior to entering into transactions. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OARN's vendor approval process has included the following steps:● Review and Verification: Review the Vendor Approval Form to ensure it is complete and includes all necessary documentation. Verify that the vendor is not excluded from receiving federal contracts by checking for debarment on SAM.gov. ● Decision: Approve or deny the Approval Form. ● Communication and Record-Keeping: Return a signed and dated copy to the vendor, indicating approval or denial. Enter information for all approved vendors into the grant management tracking system. OARN recognizes that an essential best practice for federal compliance is conducting semi-annual checks on SAM.gov to confirm a vendor's continued eligibility for federal funds. Effective January 1, 2026, OARN implemented a policy to review all vendors' status on SAM.gov. This initial review is scheduled for completion by February 28, 2026. A subsequent review will take place in July 2026 for any vendors involved in projects that are still ongoing. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: February 28, 2026

View Audit 390474

Finding 1176619 (2025-002)

Material Weakness 2025

Oregon Association of Relief Nurseries

OR

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness § 200.303

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and appro...

Community Project Funding/Congressionally Directed Spending ‐ Construction – Assistance Listing No. 93.493 Recommendation: We recommend that the Association implement policies and procedures to ensure the performance of subrecipient monitoring and that the monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OARN's current monitoring of Subrecipients has included reviewing budgets and progress reports, approving vendors, and processing drawdown requests to confirm the appropriate use of subaward funds in compliance with Federal regulations and subaward terms. However, OARN recognizes the need for a more comprehensive review process to ensure full subrecipient compliance. Therefore, we plan to request audits or financial reviews from all subrecipients. We will also require documentation demonstrating that the subrecipient has taken prompt and necessary corrective action in response to any deficiencies identified through audits, on-site reviews, or other methods related to the Federal program. OARN has created and will maintain a Subrecipient Monitoring and Approval Form that tracks receipt and review of 1) audit reports and corrective actions along with 2) checks on SAM.gov to confirm the subrecipient's continued eligibility for federal funds. Name(s) of the contact person(s) responsible for corrective action: Lee McKenzie, OARN Grant Manager Planned completion date for corrective action plan: March 30, 2026

View Audit 390474

Finding 1176608 (2025-002)

Material Weakness 2025

Rushmore Electric Power Cooperative, Inc.

SD

Subrecipient Monitoring Reporting Matching / Level of Effort / Earmarking

Finding 2025-002: Internal Controls over Compliance Responsible Individuals: Mark Miller, Accounting Manager Corrective Action Plan: Management is currently implementing review procedures and proper oversight of compliance. Anticipated Completion Date: 2026

View Audit 390424

Finding 1176593 (2025-002)

Material Weakness 2025

Sabin Group 1 Hud Project No. 101-Hh003-Np-Cmi-L8

CO

HUD Housing Programs Subrecipient Monitoring Eligibility

February 25, 2026 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2025 AUDITOR FINDING: 2025-002 – AL# 14.157 Supportive Housing for the Elderly (Section 202) Area: Eligibility In accordance with 24 CFR section 891.410, section 5.230, and OMB No. 2502-0204, owner shall re-examine tenant elig...

February 25, 2026 CORRECTIVE ACTION PLAN FISCAL YEAR OF FINDING: June 30, 2025 AUDITOR FINDING: 2025-002 – AL# 14.157 Supportive Housing for the Elderly (Section 202) Area: Eligibility In accordance with 24 CFR section 891.410, section 5.230, and OMB No. 2502-0204, owner shall re-examine tenant eligibility at least every 12 months with respect to family income, composition and is required to obtain signed consent forms from assistance applicants. In accordance with HUD Multifamily Occupancy Handbook, Chapter 7, annual certification should be completed and submitted through TRACS within 15 months from previous year’s anniversary date. Based on testing performed recertifications did not occur within the required time period. It is recommended to add monitoring controls to help ensure recertifications are completed in accordance with 24 CFR section 891-410, section 5.230, and OMB No. 2502-0204. CLIENT PLANNED ACTION: (1) Annual recertification report will be reviewed monthly with ComCap Management to ensure timely completion of all recertifications. Demands will be given to tenants if recertifications are not completed within 60 days of initial notification. (2) Monthly dashboards will continue to be produced and reviewed with ComCap Management. The monthly dashboards include annual recertifications, occupancy/vacancy, and move-in/move-outs. CLIENT RESPONSIBLE PARTY: Darla Goddard, Director of Real Estate COMPLETION DATE: 01/01/2026

View Audit 390410

Finding 1176555 (2025-002)

Material Weakness 2025

Johnson C. Smith University

NC

Student Financial Aid Reporting Internal Control / Segregation of Duties

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliati...

Corrective Action Plan: To address the deficiencies identified in Finding 2025-002, the University has implemented and is continuing to formalize a comprehensive corrective action strategy focused on strengthening disbursement scheduling, improving system integration, institutionalizing reconciliation and quality assurance processes, and enhancing cross-functional oversight of COD reporting. Primary Control Enhancements. A standardized disbursement and reporting calendar has been established, and system integration between Ellucian Colleague and Jenzabar has been strengthened to improve consistency of cost-of-attendance and disbursement data transmitted to COD. For the 2025–2026 academic year, the Office of Financial Aid and the Office of Student Accounts are disbursing Title IV aid on the second and fourth Tuesday of each month. This schedule has been jointly approved and will continue to be followed by both departments to ensure consistency between disbursement activity and COD reporting. Supporting Controls and Training. Staff participate in targeted training related to COD reporting and cash management through NASFAA and FSA to reinforce knowledge of reporting timelines and requirements. Monitoring and Quality Assurance. A formal financial aid compliance calendar has been developed and institutionalized, outlining required quality assurance (QA) reviews by month, identifying responsible departments, and requiring documented supervisory sign-off. Reviews of COD reporting timelines are conducted twice per semester, and any discrepancies identified are documented, reviewed, and resolved in a timely manner. A systematic monthly reconciliation process has been instituted and is maintained involving the Office of Financial Aid, the Office of Student Accounts, and Budgets & Grants Accounting to ensure consistency across internal systems and COD reporting. Sustained Oversight. Any discrepancies identified through reconciliation are documented, communicated to relevant departments, and resolved, with formal supervisory sign-off required from the Assistant Director of Financial Aid and the Director of Budgets & Grants Accounting. In addition, Financial Aid maintains standing bi-weekly coordination meetings with Student Accounts and Business Office staff to support ongoing alignment related to Title IV disbursement activity and COD reporting timelines. Anticipated Completion Date: June 2026

View Audit 390365

Finding 1176540 (2025-018)

Material Weakness 2025

State of West Virginia

WV

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303 § 200.320 § 200.334 § 200.520

2025-018 PROCUREMENT HIGHER EDUCATION POLICY COMMISSION (HEPC), BLUEFIELD STATE UNIVERSITY (BSU) Assistance Listing Number: Various – Research & Development Cluster Higher Education Policy Commission (HEPC) response: HEPC maintains procurement policies consistent with state law, which is one of the ...

2025-018 PROCUREMENT HIGHER EDUCATION POLICY COMMISSION (HEPC), BLUEFIELD STATE UNIVERSITY (BSU) Assistance Listing Number: Various – Research & Development Cluster Higher Education Policy Commission (HEPC) response: HEPC maintains procurement policies consistent with state law, which is one of the three allowable criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. A Self-Certification letter will be developed and maintained by April 30, 2026, while formally defining micro-purchase thresholds applied to federal awards. This selfcertification letter will be retained as part of our procurement documentation and will provide how the micro-purchase threshold was determined and applied in accordance with 2 CFR §200.320(a)(1)(iv). Bluefield State University (BSU) response: Beginning in FY 2026, the BSU Controller and Director of Purchasing will review the criteria recognized in 2 CFR §200.320(a)(1)(iv) for establishing a micro purchase threshold of up to $50,000. These requirements will be presented to the Board of Governors before June 30, 2026.

View Audit 390319

Finding 1176531 (2025-014)

Material Weakness 2025

State of West Virginia

WV

Special Tests & Provisions Subrecipient Monitoring Eligibility

2024-014 SPECIAL TESTS AND PROVISIONS - HEALTH AND SAFETY REQUIREMENTS DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.575/93.596 The Quality Assurance specialists have established a plan of action for each Regulation Unit (Child Care Licensing Unit and Family Child Care Unit) to m...

2024-014 SPECIAL TESTS AND PROVISIONS - HEALTH AND SAFETY REQUIREMENTS DEPARTMENT OF HUMAN SERVICES (DOHS) Assistance Listing Number: 93.575/93.596 The Quality Assurance specialists have established a plan of action for each Regulation Unit (Child Care Licensing Unit and Family Child Care Unit) to maintain continual monitoring of conducted Annual Unannounced Monitoring Visits required under 45 CFR §98.42(b)(2)(i)(B). Within the tracking spreadsheet, detailed information is input from our documentation system PATH COGNOS Report PCC-PLI 1080. Information includes Provider Name, Provider Number, Provider Type, Specialist Name, and columns for visits conducted and visits not yet conducted. To provide an overall year-to-date calculation of monthly totals/percentages, a Yearly Summary tab is included in the spreadsheet for a quick reference analysis to provide an additional method of tracking visits. As the monthly totals and percentages change, the data updates on the monthly tabs and the Yearly Summary tab. Program Managers have implemented individual efforts to track visits conducted by specialists. The PCC-PLI 1080 report is distributed twice per month by PM II to each Program Manager for review. Specialists have been instructed to include completed annual unannounced monitoring visits on monthly report data, which can then be compared with the PCC-PLI-1080 reports. Additionally, a tracking system has been implemented that requires specialists to pre-plan annual unannounced visits for the 2026 calendar year to ensure visits are completed.

View Audit 390319

Finding 1176523 (2025-021)

Material Weakness 2025

State of West Virginia

WV

Subrecipient Monitoring § 200.303 § 200.332

2025-021 SUBRECIPIENT MONITORING DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 Management concurs with this finding. For current subawards, contents will be reviewed for required elements and subrecipients informed of any missing elements with documentation of this communication ...

2025-021 SUBRECIPIENT MONITORING DEPARTMENT OF AGRICULTURE (DOA) Assistance Listing Number: 93.103 Management concurs with this finding. For current subawards, contents will be reviewed for required elements and subrecipients informed of any missing elements with documentation of this communication kept within subaward files. For future subawards, the Department of Agriculture will create a checklist based on 2 CFR 200.332 (b)(1) to use in review of new agreements (one checklist per funding source), including section citations for the required elements.

View Audit 390319

Finding 1176502 (2025-019)

Material Weakness 2025

State of West Virginia

WV

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility § 200.214 § 200.303

2025-019 SUSPENSION AND DEBARMENT HIGHER EDUCATION POLICY COMMISSION Assistance Listing Number: 47.076 This finding was previously identified during the FY 2024 audit. Since the original finding, HEPC has addressed and resolved this issue by strengthening its internal controls and procedures. On Mar...

2025-019 SUSPENSION AND DEBARMENT HIGHER EDUCATION POLICY COMMISSION Assistance Listing Number: 47.076 This finding was previously identified during the FY 2024 audit. Since the original finding, HEPC has addressed and resolved this issue by strengthening its internal controls and procedures. On March 31, 2025, HEPC updated policies and procedures that established and maintain effective control over federal awards. The update established a threshold for identifying covered transactions and provides clear guidance on conducting suspension and debarment searches in SAM.gov for those transactions. The update also provided additional steps for documentation required to assess whether a vendor is excluded or disqualified if not in SAM.gov. The instances noted in this finding happened before the corrective action plan was implemented. Management believes the updated processes and procedures are effective.

View Audit 390319

Finding 1176499 (2025-009)

Material Weakness 2025

State of West Virginia

WV

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

2025-009 REPORTING SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS OFFICE OF THE GOVERNOR (GO) Assistance Listing Number: 21.027 The GO fully believes that its documentation and support for obligations and expenditures incurred under its SLFRF funding is available and appro...

2025-009 REPORTING SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE, OTHER MATTERS OFFICE OF THE GOVERNOR (GO) Assistance Listing Number: 21.027 The GO fully believes that its documentation and support for obligations and expenditures incurred under its SLFRF funding is available and appropriate to support all items, though recognizes there were challenges and delays in its ability to provide the information to our auditors due to miscommunications and need to coordinate across multiple agencies. That said, the GO recognizes that certain errors were noted in the amounts reported in the quarterly expenditure reports and is committed to enhancing its processes going forward. In particular, as the new administration has had a chance to become more familiar with the reporting processes and its relationship with the third-party firm responsible for assisting the State’s creation and submission of its expenditure reporting. In particular, the GO will ensure that each quarterly expenditure report includes a clearly defined project schedule that allows ample time for the full review and confirmation of information and data included prior to the report’s due date. Additionally, the third-party firm has added additional resources to support the reporting periods and developed new templates to better track and summarize the information aggregated across all agencies spending SLFRF funds to better enable review and identification of any errors or questions.

View Audit 390319

Finding 1176495 (2025-006)

Material Weakness 2025

State of West Virginia

WV

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

2025-006 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) Assistance Listing Number: 15.252 The finding states that the DEP did not report subaward information in accordance with reporting requirements. Specifically, two reports sel...

2025-006 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF ENVIRONMENTAL PROTECTION (DEP) Assistance Listing Number: 15.252 The finding states that the DEP did not report subaward information in accordance with reporting requirements. Specifically, two reports selected for testing were not reported in a timely manner. Based on the previous year’s finding, DEP implemented standard operating procedures on January 24, 2024, to ensure compliance with the FFATA reporting requirements. DEP concurs that the two reports found to be in noncompliance were, in fact, submitted after the required deadline. This oversight was primarily due to the understaffing of the Sub Grants Unit at the time these reports were to be submitted. DEP currently has sufficient standard operating procedures to ensure compliance with FFATA reporting. DEP will temporarily reassign staff responsibilities to ensure reporting compliance timelines are met until the current vacancy in the Sub Grants Unit can be filled to provide additional support to the existing staff.

View Audit 390319

Finding 1176493 (2025-005)

Material Weakness 2025

State of West Virginia

WV

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally enter...

2025-005 REPORTING – FEDERAL FUNDING ACCOUNTABILITY AND TRANSPARENCY ACT (FFATA) DEPARTMENT OF EDUCATION (DOE) Assistance Listing Numbers: 10.553/10.555/10.556/10.559/10.582 During FY 2025, the FFATA reporting system changed from the FSRS site to SAM.gov. Many transactions that were originally entered into the FSRS site did not transfer over and had to be re-entered into SAM.gov, making those entries appear late. In addition, we had trouble getting the SAM.gov site to accept our FFATA entries. DOE worked with SAM.gov customer support to eventually get the issues resolved, but this also resulted in late reporting. Subsequent to the systematic issues being resolved, all FFATA reports have been completed timely and will continue to be reported timely going forward.

View Audit 390319

Finding 1176480 (2025-002)

Material Weakness 2025

City of Benton Harbor, Michigan

MI

Procurement, Suspension & Debarment Subrecipient Monitoring

2025-002 - Timeliness of Federal Funding Accountability and Transparency Act Reporting Auditor Description of Condition and Effect. The City completed its FFATA reporting after the reporting deadline of 30 days. As a result of this condition, the City did not comply with the requirements of the Unif...

2025-002 - Timeliness of Federal Funding Accountability and Transparency Act Reporting Auditor Description of Condition and Effect. The City completed its FFATA reporting after the reporting deadline of 30 days. As a result of this condition, the City did not comply with the requirements of the Uniform Guidance to complete FFATA reporting in a timely manner. Auditor Recommendation. We recommend that the City complete FFATA reporting requirements in a timely manner. Corrective Action. Management concurs with the finding. The City will complete FFATA reporting requirements in a timely manner going forward. Responsible Person. Deb Chubb - Community Development Block Grant Manager Anticipated Completion Date. June 30, 2026

View Audit 390297

Finding 1176450 (2025-004)

Material Weakness 2025

Board of Child Care of the United Methodist Church, Inc.

MD

Subrecipient Monitoring § 200.332

Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subr...

Views of Responsible Officials: Management acknowledges the audit finding related to the Federal Funding Accountability and Transparency Act of 2006 (FFATA) Reporting and appreciates the opportunity to address this matter. Everstand does have an established procedure for consistent reporting of subrecipient activities as required under FFATA regulations. However, the lack of a clearly defined responsibility for this task resulted in non-compliance. Management recognizes this gap and is committed to implementing corrective measures to ensure full compliance moving forward.

View Audit 390264

Finding 1176449 (2025-003)

Material Weakness 2025

Board of Child Care of the United Methodist Church, Inc.

MD

Subrecipient Monitoring § 200.332

Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although ...

Views of Responsible Officials: Management acknowledges the audit finding related to Subrecipient Monitoring and appreciates the opportunity to address this matter. We recognize the importance of robust monitoring procedures to ensure compliance with Federal requirements and mitigate risk. Although procedures exist for verifying SAM.gov registration (suspension/debarment status) and obtaining audited financial statements from subgrantees, these procedures were not documented or codified in the Caminos Nacional Policy Manual. Pre-award risk assessments have been conducted informally without a formal determination of risk, and protocols surrounding risk assessment were inadequately documented, resulting in inconsistent implementation.

View Audit 390264

Corrective Action Plans

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