Corrective Action Plans

Finding 1186953 (2025-003)

Material Weakness 2025

State of Ohio

OH

Period of Performance Subrecipient Monitoring Allowable Costs / Cost Principles

Corrective Action Plan: The Department will evaluate its current policies and procedures relating to the processing of expenditure transactions and update them, as necessary, to reasonably ensure compliance with period of performance requirements. Anticipated Completion Date for Corrective Action: J...

Corrective Action Plan: The Department will evaluate its current policies and procedures relating to the processing of expenditure transactions and update them, as necessary, to reasonably ensure compliance with period of performance requirements. Anticipated Completion Date for Corrective Action: June 2026 Contact Person Responsible for Corrective Action: Name: Daniel Schreiber Title: Deputy Chief, Budget Address: 77 South High Street, 27th Fl, Columbus, Ohio 43215 Phone Number: 614-466-2209 E-Mail Address: daniel.schreiber@development.ohio.gov

View Audit 394693

Finding 1186952 (2025-012)

Material Weakness 2025

State of Ohio

OH

Eligibility Special Tests & Provisions Subrecipient Monitoring

Corrective Action Plan: The Ohio Benefits team, in partnership with the Program Office, continues to develop and implement system enhancements to assist in the reduction of the work effort related to the Income Eligibility Verification System (IEVS) for the county workers. A complete end to end revi...

Corrective Action Plan: The Ohio Benefits team, in partnership with the Program Office, continues to develop and implement system enhancements to assist in the reduction of the work effort related to the Income Eligibility Verification System (IEVS) for the county workers. A complete end to end review was conducted and improvements were identified and implemented into the Ohio Benefits system to assist with the volume and usefulness of the data in the IEVS matches. A summary of the changes implemented can be found on the table below. We continue to monitor the impact of these changes on the overall volume and frequency of IEVS matches. Description Release/Release Date Summary State Wage Information Collection Agency (SWICA) Alerts Reduction 4.14.1/January 18, 2025 Modified the income comparison check to not generate the SWICA Alert if the income received on the file is less than $750/quarter or $250/month when compared to the Salary, Wages Income record in Ohio Benefits Worker Portal (OBWP). Public Assistance Reporting Information System (PARIS) Alerts Reduction 4.14.1/ January 18, 2025 Modified PARIS Veteran and Federal Wage Match to suppress generating E-Verify records and alerts if the inbound record has the same data as previous PARIS E-Verify records. Modified PARIS Interstate Match to suppress generating EVerify records and alerts if the record does not include Client Eligibility Information. Modified PARIS Alerts to generate only one alert to each worker assigned to the case based on the alert hierarchy. National News Hire (NNH) Alerts Reduction 4.14.1/ January 18, 2025 Modified NNH interface to not generate E-Verify (Interface Detail) records or Alert if the interface detail screen and alert has already been generated in the past for the same employer, and the inbound record has the same Employer Information as previous E-Verify records. Modified NNH interface to generate only one alert to each worker assigned to the case based on the alert hierarchy. Beneficiary Earnings and Data Exchange (BENDEX) Alerts Reduction 4.15.1/March 28, 2025 Modified BENDEX Interface to not generate E-Verify records or Alerts if the information received on the inbound record has not changed from the last update received from SSA. Modified BENDEX interface to generate only one alert to each worker assigned to the case based on the alert hierarchy. Modified the BENDEX Difference Alert (> $49) to be program neutral and retired the existing program specific alerts for the income limit check. IEVS threshold modification – Unemployment Compensation Benefit (UCB) 5.1.1/August 15, 2025 Modified income comparison check to not generate the IEVS: Unemployment Compensation – Discrepancy Alert if the difference is less than $250/month (changed from $25/month to $250/month). IEVS threshold modification – State Data Exchange Supplemental Security Income (SDX SSI) Interface 5.1.1/ August 15, 2025 Modified income comparison check to not generate the IEVS: IEVS: SDX-SSI Response from SSA – Unearned Income Difference Alert if the difference is less than $250/month (changed from $25/month to $250/month). IEVS threshold modification – BENDEX Interface 5.1.1/ August 15, 2025 Modified income comparison check to not generate the BENDEX Difference Alert if the difference is less than $250/month (changed from $49/month to $250/month). IEVS threshold modification – Internal Revenue Service (IRS) Unearned Income Interface 5.1.1/ August 15, 2025 Modified the IEVS: IRS Income Program Block alert to be suppressed when the ‘Income Amount’ and ‘Income Indicator’ on the E-Verify record of the incoming tax data is within $250/month of the existing matching unearned income on the individual’s case. Also, as reported previously, the state has requested a waiver from Food and Nutrition Services at the U.S. Department of Agriculture related to the requirement to interface with the IRS Unearned Income data source. This interface produces outdated, and therefore unusable, data. The same data is available and received from other sources timelier, making the Internal Revenue Service’s Unearned Income data source unnecessary. Other states have already implemented this change with success. This request is currently pending national office review. If this waiver is approved, we will drop this interface, eliminating approximately 1 million matches per year. If the waiver is not approved, a separate effort will be made to update the threshold to match the other data sources listed above. Reduction of the volume of these matches is anticipated to lead to improvements in the timely completion of matches on the part of the county worker while continuing to remain compliant with IEVS policies. The Department provides IEVS Alert/Match Processing training to educate staff on matches received through IEVS for the Supplemental Nutrition Assistance Program (SNAP) and Temporary Assistance for Needy Families (TANF) programs. This training supports eligibility workers by enhancing their understanding of IEVS matches, their importance in ensuring case accuracy, and the associated processing requirements. The IEVS Processing training is available on demand through the Ohio Benefits Portal and Ohio Learn, the state’s learning management system. Additionally, the Department offers one-on-one IEVS training and technical assistance to counties upon request. The state is reviewing our ability to mandate any type of training and will include this in our review. Fraud Control Triad Reviews and Assessments are conducted on a three-year cycle, ensuring that each county is evaluated at least once within that period, resulting in approximately 28 county reviews annually. These reviews include an assessment of IEVS alert and match activity, along with clear communication regarding each county’s responsibility to monitor all IEVS activity for compliance. Anticipated Completion Date for Corrective Action: August 2026 Contact Person Responsible for Corrective Action: Name: Christina L Burt Title: Assistant Deputy Director Address: 30 E Broad St, 31st Floor, Columbus, Ohio 43215 Phone Number: 614-644-1621 E-Mail Address: christina.burt@jfs.ohio.gov

View Audit 394693

Finding 1186948 (2025-004)

Material Weakness 2025

State of Ohio

OH

Subrecipient Monitoring § 200.332

Corrective Action Plan: The Department developed and re-evaluated its internal control procedures to ensure that all subprograms and subrecipients will be adequately monitored for program compliance. The Department also evaluated its existing control procedures to reasonably ensure that the quarterl...

Corrective Action Plan: The Department developed and re-evaluated its internal control procedures to ensure that all subprograms and subrecipients will be adequately monitored for program compliance. The Department also evaluated its existing control procedures to reasonably ensure that the quarterly program reports submitted through the Salesforce System will be timely, accurate, and complete. Anticipated Completion Date for Corrective Action: Completed April 2025 Contact Person Responsible for Corrective Action: Name: Thomas Fitz Gibbon Title: Deputy Chief, Office of Division Support Address: 77 South High Street, Columbus, Ohio 43220 Phone Number: 614-466-0043 E-Mail Address: thomas.fitzgibbon@development.ohio.gov

View Audit 394693

Finding 1186945 (2025-011)

Material Weakness 2025

State of Ohio

OH

Allowable Costs / Cost Principles Eligibility Internal Control / Segregation of Duties § 200.1 § 200.516

Corrective Action Plan: For Benefits Adjudication: Standard procedures for verifying claimant eligibility for unemployment benefits remain in place. Adjudication staff have been reminded to double-check start dates and eligibility documentation to prevent the recurrence of similar errors. For Benefi...

Corrective Action Plan: For Benefits Adjudication: Standard procedures for verifying claimant eligibility for unemployment benefits remain in place. Adjudication staff have been reminded to double-check start dates and eligibility documentation to prevent the recurrence of similar errors. For Benefit Payment Control (BPC): The Department remains committed to strengthening accountability and proactively identifying any potential training gaps within the team. To support this effort, the Department has recently implemented monthly random case reviews conducted by supervisors, followed by individualized email feedback to staff to reinforce expectations and provide timely coaching. Additionally, supervisors are now required to track all audits and document follow up actions to ensure consistent monitoring and early identification of any emerging trends. These measures are intended to enhance quality assurance, support staff development, and maintain the high standards expected within the Department. Anticipated Completion Date for Corrective Action: Completed February 2026 Contact Person Responsible for Corrective Action: For Benefits Adjudication: Name: Traci A. Brown Title: Assistant Deputy Director - Benefits Adjudication Address: 30 East Board Street, Columbus, Ohio 43215 Phone Number: 614-387-3647 E-Mail Address: Traci.Brown@jfs.ohio.gov For Benefit Payment Control (BPC): Name: BJ Knutson-Cruset Title: Bureau Chief Address: 6680 Poe Ave, Dayton, Ohio 45414 Phone Number: 937-264-5742 E-Mail Address: bj.knutson-cruset@jfs.ohio.gov

View Audit 394693

Finding 1186943 (2025-018)

Material Weakness 2025

State of Ohio

OH

Reporting Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Corrective Action Plan: The Ohio Department of Natural Resources has timely entered all awarded subrecipient agreements into SAM.gov as of September 2025 and implemented a new automated tracking/reminder process through a newly built grant SharePoint tracker. Going forward, subrecipient information ...

Corrective Action Plan: The Ohio Department of Natural Resources has timely entered all awarded subrecipient agreements into SAM.gov as of September 2025 and implemented a new automated tracking/reminder process through a newly built grant SharePoint tracker. Going forward, subrecipient information will be entered into SAM.gov by the end of the month following the month in which the award was issued. Anticipated Completion Date for Corrective Action: Completed September 2025 Contact Person Responsible for Corrective Action: Name: Jennifer Woodman Title: Assistant Chief, Division of Mineral Resources Management Address: 2045 Morse Rd, Building H2, Columbus, Ohio 43229 Phone Number: (614) 265-1094 E-Mail Address: JenniferE.Woodman@dnr.ohio.gov

View Audit 394693

Finding 1186941 (2025-009)

Material Weakness 2025

State of Ohio

OH

School Nutrition Programs Subrecipient Monitoring Reporting

Corrective Action Plan: The Department has designated and implemented additional internal controls over Transparency Act reporting to ensure that the Child Nutrition Cluster expenditures are timely and accurately entered into the SAM.gov website. These procedures include several edit checks of the d...

Corrective Action Plan: The Department has designated and implemented additional internal controls over Transparency Act reporting to ensure that the Child Nutrition Cluster expenditures are timely and accurately entered into the SAM.gov website. These procedures include several edit checks of the data before it is uploaded as well as a reconciliation of the reported data to ensure compiance with federal regulations. Anticipated Completion Date for Corrective Action: Completed December 2025 Contact Person Responsible for Corrective Action: Name: Corey Fronk Title: Administrator of Audits and Risk Management Address: 25 S. Front Street, 7th Floor; Columbus, OH 43215 Phone Number: (614) 644-7812 E-Mail Address: Corey.Fronk@education.ohio.gov

View Audit 394693

Finding 1186932 (2025-004)

Material Weakness 2025

Town of Elkton, Maryland

MD

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

CSLRF Reporting - Revenue Replacement Recommendation: We recommend that the Town enhance its internal controls over CSLRF reporting to ensure that amounts reported as revenue replacement are accurately identified, supported, and reconciled to the underlying accounting records prior to submission of ...

CSLRF Reporting - Revenue Replacement Recommendation: We recommend that the Town enhance its internal controls over CSLRF reporting to ensure that amounts reported as revenue replacement are accurately identified, supported, and reconciled to the underlying accounting records prior to submission of required federal reports. This should include implementing a formal reconciliation 9rocess between the general ledger and CSLRF reporting schedules, along with documented review and approval procedures to ensure accuracy and proper classification. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will strengthen internal controls over CSLRF reporting related to revenue replacement. The Town will implement a formal reconciliation process between the general ledger and CSLRF reporting schedules prior to submission of required federal reports. This process will include documented review and approval procedures to ensure that expenditures designated as revenue replacement are accurately identified, properly classified, allowable, and supported by underlying accounting records. Management will also perform periodic monitoring to ensure that these controls are consistently applied and operating as designed. Name of the contact person responsible for corrective action: Tyler Home. Director of Finance. Planned completion date for corrective action plan: March 3 I . 2026

View Audit 394691

Finding 1186931 (2025-003)

Material Weakness 2025

Town of Elkton, Maryland

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213 § 200.303

Suspension and Debarment Recommendation: We recommend that the Town reinforce the consistent execution of its existing suspension and debarment procedures to ensure that vendors are verified as not suspended or debarred prior to contract execution or the processing of program-related expenditures. I...

Suspension and Debarment Recommendation: We recommend that the Town reinforce the consistent execution of its existing suspension and debarment procedures to ensure that vendors are verified as not suspended or debarred prior to contract execution or the processing of program-related expenditures. In addition, the Town should consistently retain documentation evidencing the timely performance, review, and approval of suspension and debarment checks for audit purposes. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management agrees with the finding and will strengthen the consistent execution of its suspension and debarment controls. All vendor eligibility checks will be required to be completed, reviewed, and approved prior to contract execution or the processing of program-related expenditures. Review and approval will be evidenced through a dated "Received" stamp or similar documentation applied by the Assistant Town Administrator and retained in the vendor file. Management will also perform periodic monitoring to ensure that suspension and debarment controls are applied consistently. Name of the contact person responsible for corrective action: Tyler Home, Director of Finance. Planned completion date for corrective action plan: March 31, 2026

View Audit 394691

Finding 1186928 (2025-002)

Material Weakness 2025

Ivy Tech Community College of Indiana

IN

Subrecipient Monitoring Eligibility Material Weakness § 200.303 § 200.329

FINDING 2025-002 (Auditor Assigned Reference Number) Finding Subject: TRIO - Reporting Contact Person Responsible for Corrective Action: Stacy Atkinson, Indianapolis Chancelor John Gipson, Lake County Chancelor Chad Bolser, Richmond Chancelor Jeffrey Scott, Muncie Chancelor Contact Phone Numbers and...

FINDING 2025-002 (Auditor Assigned Reference Number) Finding Subject: TRIO - Reporting Contact Person Responsible for Corrective Action: Stacy Atkinson, Indianapolis Chancelor John Gipson, Lake County Chancelor Chad Bolser, Richmond Chancelor Jeffrey Scott, Muncie Chancelor Contact Phone Numbers and Email Addresses: 317-921-4800 ext. 085745 and satkinson17@ivytech.edu 812-297-3252 and jgipson33@ivytech.edu 765-966-2656 ext. 092345 and cmbolser@ivytech.edu 765-506-1942 and jdscott@ivytech.edu Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The College will ensure that each affected campus develops and implements a plan that includes internal controls to mitigate risks and ensure compliance. Campuses will be expected to conduct internal reviews of annual performance reports and maintain proper documentation of any identified corrections. Anticipated Completion Date: June 30, 2026

View Audit 394679

Finding 1186866 (2025-002)

Material Weakness 2025

Wabash City Schools

IN

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

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dr. Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the ...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Dr. Amy K. Sivley Contact Phone Number and Email Address: 260-563-2151; sivleya@apaches.k12.in.us Views of Responsible Officials: We concur with the finding. Explanation and Reasons for Disagreement: n/a Description of Corrective Action Plan: An updated Procurement Policy will be developed and adopted. This policy will outline our process for obtaining multiple quotes for small purchase vendors. Quotes will be reviewed and approved by Superintendent/CFO. All vendors will be vetted through the SAM.gov website for suspension or debarment by the Corporation Treasurer prior to ordering. Any vendor that cannot be vetted through SAM.gov will be required to selfcertify that they have not been suspended or debarred. A vendor list will be updated yearly by the Corporation Treasurer and reviewed and signed off by the Superintendent/CFO. Anticipated Completion Date: Board policy will be adopted by April 1, 2026. Vetting of vendors will begin immediately (1/20/2026).

View Audit 394615

Finding 1186861 (2025-003)

Material Weakness 2025

Homeless Assistance Leadership Organization, Inc.

WI

Subrecipient Monitoring HUD Housing Programs Period of Performance

Finding #2025-003 - Rent Reasonableness Criteria: HUD requires that recipients ensure that rent is reasonable compared to similar unassisted units and maintain documentation supporting the determination; rent paid with CoC leasing funds·may not exceed Fair Market Rent (FMR); and rent reasonableness ...

Finding #2025-003 - Rent Reasonableness Criteria: HUD requires that recipients ensure that rent is reasonable compared to similar unassisted units and maintain documentation supporting the determination; rent paid with CoC leasing funds·may not exceed Fair Market Rent (FMR); and rent reasonableness determinations must be completed before providing assistance. Condition: During testing of rent reasonableness controls and documentation, the following exceptions were identified: • 4 of 4 rent reasonableness determinations lacked evidence of an independent review and approval. • There were 8 instances (2 units x 4 months) where rents exceeded HUD FMR limits. • 3 of 20 rent reasonableness determinations were not completed prior to the lease start date. Questioned Costs: $392. Cause: The Organization did not have sufficiently defined or consistently followed procedures for documenting independent review of rent reasonableness determinations, verifying rents against applicable FMR limits before authorizing payments, and ensuring determinations were complete prior to lease start dates. Effect: Units are approved and paid at non-compliant rent levels, federal funds are used for rents above allowable limits, and documentation does not meet HUD standards, potentially leading to questioned costs, required repayment, and findings in future monitoring or audits. Recommendation: We recommend that management establish a mandatory review and approval step for all rent reasonableness forms, require staff to verify current FMR limits before approving leasing amounts, and require rent reasonableness completion before any lease start date or payment authorization. Response: HALO's management concurs with this finding. HALO management will implement procedures to ensure compliance with rent reasonableness and FMR limits and train staff on those procedures. HALO will replace the current Rent Reasonableness form with the one on the HUD Exchange. Contact Person: Yvonne MacDonald Hames Anticipated Completion: June 30, 2026

View Audit 394609

Finding 1186855 (2025-001)

Material Weakness 2025

Argus Manor Association

WA

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT S3800-010: Finding Reference Number 2025-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification...

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT S3800-010: Finding Reference Number 2025-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an independent contractor prior to finalization of tenant income certifications and new tenant move-in files. However, during our testing, we noted four (4) move-in files out of four (4) move-in files tested where tenants were approved for move-in prior to review and approval by the independent contractor, circumventing the control. In addition, there was no evidence of approvals of tenant income certifications in the tenant files prior to billing of rental assistance for eleven (11) out of twelve (12) tenant files tested. S3800-080: Auditor Recommendation: We recommend that the client immediately implement corrective actions to ensure compliance with internal control procedures. Specifically: 1. The compliance specialist should be required to wait for proper approval of tenant eligibility files before processing them. 2. Review and reinforce the approval process through additional training for staff to ensure they understand the critical importance of obtaining necessary approvals before proceeding. 3. Implement stronger oversight and monitoring mechanisms to ensure that files are not processed before approval. S3800-045: Actions Taken or to be Taken: Management has reviewed the policies and procedures with the property manager, who also serves as the compliance specialist. The property manager was instructed that no tenants are to be granted occupancy and no billing of rental assistance based on certifications should be billed until the file has been approved by the independent contractor conducting the compliance review.

View Audit 394602

Finding 1186845 (2025-002)

Material Weakness 2025

Westchester Jewish Community Services, Inc.

NY

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

Finding 2025{D2, Accuracy of the SEFA Persons Responsible: lrene Math, Chief Financial Officer; Jack Babwah, Director of Revenue and Reimbursement Comment: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee's financial statements. The SEFA included 10...

Finding 2025{D2, Accuracy of the SEFA Persons Responsible: lrene Math, Chief Financial Officer; Jack Babwah, Director of Revenue and Reimbursement Comment: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee's financial statements. The SEFA included 100% of expenditures for each grant, even if the grant was not 100% federally funded. Proper identification of federal funds and their related allocations is critical to ensure compliance with federal requirements and accurate reporting. Management subsequently reviewed the funding allocations and revised the SEFA during the audit to properly reflect only the federally funded portion of expenditures. The final SEFA included in the financial statements reflects these corrections. Response: Management acknowledges the importance of accurately reporting only the federal portion of grant expenditures in the SEFA. To address this, management is implementing enhanced procedures. During the current year, a master grants listing was developed to strengthen the grants onboarding process. As part of this process, the team will determine the federal funding details at the outset of each award, when not clearly specified in the contract, and will proactively contact funders to obtain the Assistance Listing Number (ALN)/Catalog of Federal Domestic Assistance (CFDA) number and related information. In addition, federal funding allocation percentages will be appropriately identified, calculated and reported on the SEFA. These actions are expected to improve accuracy and compliance with federal requirements. Estimated Completion Date: The additional review procedures will be implemented by the June 30, 2026 financial statement close process.

View Audit 394587

Finding 1186695 (2025-101)

Material Weakness 2025

Maricopa County

AZ

Reporting Subrecipient Monitoring § 200.303

Assistance Listings number and program name: 14.218 Community Development Block Grant/Entitlement Grants Department: Maricopa County Human Services Contact Person(s): Nicole Forbes, Finance Manager, Human Services Department. Anticipated completion date: December 31, 2026 Concur: The Human Services ...

Assistance Listings number and program name: 14.218 Community Development Block Grant/Entitlement Grants Department: Maricopa County Human Services Contact Person(s): Nicole Forbes, Finance Manager, Human Services Department. Anticipated completion date: December 31, 2026 Concur: The Human Services Department (HSD) is committed to ensuring full compliance with the Federal Funding Accountability and Transparency Act (FFATA), Uniform Guidance requirements, and all applicable County policies. In 2025, to address the issues identified in the original finding (2024-101), the Department developed a new HUD Federal Funding Accountability and Transparency Act (FFATA) Reporting Procedure. This procedure establishes clear expectations, reporting timelines, documentation requirements, and internal controls to ensure accurate and timely reporting. HSD’s CDBG agreements, however, are typically multi-year and often do not incur expenditures until the second year. They also may include multiple amendments throughout the life of the agreement. Many of the agreements are related to public facilities and public infrastructure projects which take many years to complete. Due to nature of the agreements, full remediation of FFATA findings may take several years. The Department will implement the following corrective actions: Action 1: Correct and Resubmit All Required Subaward Information HSD will complete a full reconciliation of all active subawards and amendments and correct or resubmit any remaining inaccurate, incomplete, or duplicate FFATA entries in the federal reporting system. Target Completion: December 31, 2026 Action 2: Reinforce Compliance with FFATA Reporting Requirements HSD will formalize and expand FFATA training for all staff responsible for subaward reporting. The Department will reinforce adherence to federal requirements and County policies, including the requirement to report all subaward actions by month end following the subaward action. Target Completion: Completed January 30, 2026 Action 3: Implement Monthly Tracking List Review and Maintenance HSD will fully implement the HUD FFATA Procedures, which outlines the specific tracking tools to be used and the frequency of updates. This tracking tool will include all subawards, and amendments to subawards to ensure complete, accurate, and timely reporting. Target Completion: Completed January 30, 2026 Action 4: Establish Independent Review and Internal Control Enhancements HSD will formalize a permanent independent review process and adopt standardized review procedures to ensure accuracy and completeness of all FFATA reporting. Maricopa County Corrective Action Plan Year ended June 30, 2025 Target Completion: Completed December 31, 2026 These corrective actions will strengthen internal controls, improve reporting accuracy and timeliness, and ensure the Department meets all federal and County requirements for subaward transparency. The Department anticipates completing all corrective actions within the timelines outlined in the corrective action plan.

View Audit 394404

Finding 1186677 (2025-003)

Material Weakness 2025

The Primary Care Coalition of Montgomery County, Maryland, Inc.

MD

Subrecipient Monitoring Internal Control / Segregation of Duties Eligibility

Views of Responsible Official: Management agrees with the finding. Management will develop an alert system for Program Directors to use in tracking their sub-awards and sub-contracted engagement values and related amendments. This system will create an alert when a contract value exceeds $30,000 pro...

Views of Responsible Official: Management agrees with the finding. Management will develop an alert system for Program Directors to use in tracking their sub-awards and sub-contracted engagement values and related amendments. This system will create an alert when a contract value exceeds $30,000 prompting the Program Director to file, or work with appropriate staff to file the FFATA.

View Audit 394372

Finding 1186676 (2025-002)

Material Weakness 2025

The Primary Care Coalition of Montgomery County, Maryland, Inc.

MD

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.303 § 200.328

Views of Responsible Official: Management agrees with the finding. Management will institute additional calendar alerts and accountability procedures to ensure reports are filed on time. Recognizing that technical issues, illness, and other unforeseen circumstances can arise, Management will institu...

Views of Responsible Official: Management agrees with the finding. Management will institute additional calendar alerts and accountability procedures to ensure reports are filed on time. Recognizing that technical issues, illness, and other unforeseen circumstances can arise, Management will institute a requirement that all late filings must be communicated to the Contract Monitor as soon as the delay is anticipated.

View Audit 394372

Finding 1186664 (2025-010)

Material Weakness 2025

Marshall County

OK

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Subrecipient Monitoring

The Board of County Commissioners will work toward assessing and identifying risks to design written county-wide controls.

View Audit 394367

Finding 1186661 (2025-001)

Material Weakness 2025

Conway Apartments, Inc.

AR

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions

Name: Conway Apartments, Inc. Contact: Jeffrey Woods, Director of Accounting Contact Phone Number: 479-967-5570 Audit Period Ending: June 30, 2025 Anticipated Completion Date: March 18, 2026 Finding 2025-001: The Project did not remit residual receipts in excess of $250 per unit to HUD upon renewal ...

Name: Conway Apartments, Inc. Contact: Jeffrey Woods, Director of Accounting Contact Phone Number: 479-967-5570 Audit Period Ending: June 30, 2025 Anticipated Completion Date: March 18, 2026 Finding 2025-001: The Project did not remit residual receipts in excess of $250 per unit to HUD upon renewal of its PRAC on January 1, 2025, as required by HUD guidance. Management had not recorded a liability for the recapture and was not aware of the requirements. Management’s Response and Planning Corrective Actions: Management has contacted Willaim Stokes at HUD and has been advised to use the funds on an upcoming remodel. The money will be spent by June 30, 2026. Moving forward the Residual Account will be monitored to ensure prompt repayment of funds. Management concurs with findings and plans to implement recommendations above.

View Audit 394363

Finding 1186657 (2025-002)

Material Weakness 2025

City of Elk Grove

CA

Subrecipient Monitoring Matching / Level of Effort / Earmarking

• Corrective Action Plan: The staff will ensure that all invoices affected by the fiscal year-end encumbrance rollover process are prioritized in the purchasing review workflow. The Purchasing Division, presently constituted of a newly onboard Purchasing Manager and Purchasing Specialist, will ensur...

• Corrective Action Plan: The staff will ensure that all invoices affected by the fiscal year-end encumbrance rollover process are prioritized in the purchasing review workflow. The Purchasing Division, presently constituted of a newly onboard Purchasing Manager and Purchasing Specialist, will ensure that established encumbrance rollover procedures are followed in coordination with key Finance Department staff who have supervisorial ownership of the encumbrance rollover process. The Purchasing Division will receive training from the Finance Department to ensure that it is able to take task ownership of its purchasing reviews involved within the fiscal year-end encumbrance rollover process. • Anticipated Completion Date: 6/30/2026 • Corrective Action Plan: The Construction Management (CM) Team will include a standing Progress Payment agenda item in the weekly progress meetings with the Contractor. During these meetings, the team will review all progress payments that have been submitted or are in progress and track their review and approval status. This process will ensure that progress payments are monitored regularly and processed within the required timeframe. Under standard practice, progress payments are typically processed and paid within two weeks of submission. The weekly tracking process will provide additional oversight to help ensure payments continue to be reviewed and approved in a timely manner. • Anticipated Completion Date: 04/01/2026

View Audit 394350

Finding 1186656 (2025-001)

Material Weakness 2025

City of Elk Grove

CA

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties

The City will implement the following corrective actions to ensure timely compliance with all grant requirements: 1. Grant Compliance Tracking • The City will establish a formal, centralized tracking system for all active grants and associated compliance deadlines, including award package submittals...

The City will implement the following corrective actions to ensure timely compliance with all grant requirements: 1. Grant Compliance Tracking • The City will establish a formal, centralized tracking system for all active grants and associated compliance deadlines, including award package submittals. • Grant requirements will be reviewed on a weekly basis as part of an established internal coordination meeting. • Submission deadlines (including the 60-day award package requirement) will be tracked and monitored proactively. 2. Integration into Existing City Processes • Since contract award actions are already tracked through established internal coordination meetings, staff will incorporate post-award compliance milestones into this workflow. • This ensures continuity between award approval and required grant documentation submittals. 3. Implementation of Grant Management Software • The City is implementing a grant management system through Euna Solutions (formerly AmpliFund) to strengthen compliance and oversight. • This system will: • Centralize grant information and documentation • Track deadlines, requirements, and deliverables in one platform • Provide automated reminders and notifications for key dates • Maintain audit-ready records and reporting • As described by the platform, grant management software helps "centralize and streamline the entire grant lifecycle...ensuring compliance" and provides "automatic notifications to remind you of key dates and deadlines" while improving transparency and accountability. • The system also enables real-time visibility into grant requirements, deadlines, and progress, helping agencies "track compliance requirements... and provide complete audit trails" to reduce risk of future findings. 4. Enhanced Accountability and Oversight • Responsibility for tracking and submitting award packages will be clearly assigned to designated staff, identified as the Senior Civil Engineer in the Capital Improvement Program assigned to the project. • Supervisory review will be incorporated into the weekly tracking process to ensure accountability. Expected Outcome These corrective actions will: • Ensure all award packages and grant deliverables are submitted within required timeframes • Improve internal coordination and accountability • Reduce administrative risk and prevent recurrence of audit findings • Enhance overall grant compliance through centralized tracking and automated reminders Anticipated Completion Date: • Weekly tracking procedures: Implemented immediately • Integration into City processes: Implemented immediately • Grant management software (Euna Solutions): Implementation underway, full integration estimated by January 31, 2027

View Audit 394350

Finding 1186640 (2025-002)

Material Weakness 2025

Waimanalo Health Center

HI

Procurement, Suspension & Debarment Subrecipient Monitoring

Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-002 - Procur...

Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2025: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2025 Item 2025-002 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6, 2 H80CS00646-24-01, 1 H8LCS51923-01-00 for 2024 and 2025, 1 H8NCS54043-01- 00 for 2025 - (Significant Deficiency) During our audit, we noted that certain employees have no record of an exclusion search conducted during 2025. There were also certain employees for whom an exclusion search was not consistently conducted on a monthly basis. Recommendation We recommend that the Center train its personnel in relation to the exclusion screening and proper documentation thereof and that the Center conduct regular reviews to ensure the completeness of exclusion search documentation. Action Taken Management agrees with the finding and will be conducting training for its personnel to help ensure the accuracy, completeness and timeliness of exclusion searches. Effectivity Date: June 30, 2026

View Audit 394336

Finding 1186634 (2025-001)

Material Weakness 2025

The New York Botanical Garden

NY

Subrecipient Monitoring § 200.303 § 200.332 § 200.521

2025-001 Monitoring of Subrecipients Agency: National Aeronautics & Space Administration Program Titles: Surviving a mass extinction: Lessons from the post K-Pg fern spike Grant Numbers: 80NSSC23K1013 Contact Person: Emily Schwarz, Chief Financial Officer (718) 817-8730 Corrective Action: Subsequent...

2025-001 Monitoring of Subrecipients Agency: National Aeronautics & Space Administration Program Titles: Surviving a mass extinction: Lessons from the post K-Pg fern spike Grant Numbers: 80NSSC23K1013 Contact Person: Emily Schwarz, Chief Financial Officer (718) 817-8730 Corrective Action: Subsequent to year end, the Garden obtained and reviewed Single Audit filings for all its Subrecipients from the Federal Audit Clearinghouse. In the Garden’s review of the Subrecipient Single Audit Reports, it did not note any findings related to its Federal programs. The Garden has implemented a control to continue to obtain and review the Single Audit filings for its Subrecipients on an annual basis. Anticipated Completion Date: Plan implemented immediately, and then continues on an ongoing basis.

View Audit 394332

Finding 1186633 (2025-002)

Material Weakness 2025

Mississippi Regional Housing Authority No. V

MS

HUD Housing Programs Subrecipient Monitoring Cash Management

To the Department of Housing and Urban Development, During the audit of the Housing Authority’s fiscal year ended June 30, 2025 financial statements, it was determined that the unaudited financial data schedule that is utilized as the Housing Authority’s underlying financial statements were not prop...

To the Department of Housing and Urban Development, During the audit of the Housing Authority’s fiscal year ended June 30, 2025 financial statements, it was determined that the unaudited financial data schedule that is utilized as the Housing Authority’s underlying financial statements were not properly stated. Significant errors existed regarding grant receivables, the allowance for doubtful accounts - tenants, capital assets, accounts payable, grant revenues and bad debt expense. Also, a desk review was performed by HUD and it was determined that the Housing Authority had not properly documented its calculation of monthly voucher leased amounts and it understated its Housing Assistance Payment expenses in its VMS reporting. The Housing Authority’s Executive Director, Ashiya Hawkins, is responsible for implementing the corrective action plan. Finding 2025-002 - VMS Reporting Deficiencies We concur with the recommendation and we will establish standard operating procedures that ensure that the HAP amounts and number of vouchers stated on the VMS report are both accurate and properly documented. We are working with our software provider to ensure that VMS reporting software is being fully and correctly utilized. We are also planning on additional training for HCV employees to make sure they are qualified to meet VMS reporting and documentation requirements.

View Audit 394328

Finding 1186614 (2025-001)

Material Weakness 2025

Community Action Team, Inc.

OR

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

3/20/2026 Community Action Team, Inc. respectfully submits the following corrective action plan for the year ending June 30, 2025. Kern & Thompson, LLC: Audit period: July 1, 2024 to June 30, 2025 The finding from the schedule of findings are discussed below. FINANCIAL STATEMENT FINDINGS 2025-001 Fe...

3/20/2026 Community Action Team, Inc. respectfully submits the following corrective action plan for the year ending June 30, 2025. Kern & Thompson, LLC: Audit period: July 1, 2024 to June 30, 2025 The finding from the schedule of findings are discussed below. FINANCIAL STATEMENT FINDINGS 2025-001 Federal Award Special Reporting Federal Funding Accountability and Transparency Act (FFATA) Material Non-Compliance and Material Weakness in Internal Controls over Compliance (Repeat of finding 2023-003, 2024-002) Recommendation: The Organization should establish written policies and procedures regarding review of grant agreements for compliance requirements along with written policies and procedures for first-tier subawards including tracking and proper internal control procedures. Action Taken: Management concurs with the finding and has defined corrective action to address it. We understand a material weakness is identified in the internal control over special reporting. We have identified gaps in our reporting processes and worked to implement changes to ensure compliance with special reporting requirements. The responsibility for reporting under the Federal Funding Accountability and Transparency Act (FFATA) will be within the Fiscal Department. Policies and procedures will be updated regarding special reporting requirements. The Fiscal department will also be responsible for reviewing all contracts to identify all compliance requirements. Tracking procedures will be implemented to ensure reports are filed timely. The above identified corrective action was implemented in July 2024 and subsequent filing for 2025 and 2026 are compliant. Stacey Wilson, Fiscal Director, has implemented a tracking system for the FFATA. Should you have any questions regarding this plan, please contact me at 503-366-6563. Sincerely, Daniel Brown Executive Director

View Audit 394320

Finding 1186610 (2025-002)

Material Weakness 2025

American Rivers, Inc.

DC

Subrecipient Monitoring

Finding Number: 2025-002 – Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Not Performed Planned Corrective Action: American Rivers hired a Grants Director in January 2026 and the FFATA reporting will be the director’s responsibility to ensure compliance with all FFATA...

Finding Number: 2025-002 – Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting Not Performed Planned Corrective Action: American Rivers hired a Grants Director in January 2026 and the FFATA reporting will be the director’s responsibility to ensure compliance with all FFATA and other required reporting. Anticipated Completion Date: 02/28/2026 Responsible Contact Person: Vickie Barrow-Klein, Chief Financial Officer

View Audit 394315

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