Corrective Action Plans

Finding 1191848 (2025-008)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Allowable Costs / Cost Principles School Nutrition Programs Questioned Costs

Finding Number: 2025-008 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure payments were allowable and made only to eligible beneficiaries for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benef...

Finding Number: 2025-008 Finding: The Department of Social and Health Services did not have adequate internal controls to ensure payments were allowable and made only to eligible beneficiaries for the Summer Electronic Benefits Transfer Program for Children. Program: 10.646 – Summer Electronic Benefits Transfer Program for Children Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Eligibility Questioned Costs: $55,454 Status: Corrective action in progress Corrective Action: The Department concurs with the finding. The improper payments identified by the auditors resulted from the challenges of a new program in its first year of implementation. Errors occurred when users from the Department and the Office of Superintendent of Public Instruction migrated data onto new templates and inadvertently included ineligible students and inaccurate dates of birth. The Department agrees that thorough data validation prior to issuance of benefits would have better identified systemic issues related to age and enrollment. Upon discovery, the Department promptly removed ineligible issuances to limit the state’s liability. The Department does not process overpayments on spent benefits based on 7 CFR 292.27(c)(2): “To the maximum extent practicable, Summer EBT agencies should limit claims against households to situations where there is evidence that the household knowingly obtained benefits through fraudulent activities.” In addition, the approved state plan with the federal grantor included a provision that the Department will not process overpayments for improper benefits unless there is evidence of fraud. By April 2026, the Department’s Community Services Division (CSD) will: • Implement a review process to verify age of applicants and address questionable data before submission to the contractor. • Amend the contract with the contractor to include specific reporting requirements for duplicate issuances and identification of ineligible participants. By July 2026, the Department’s CSD will: • Implement a mandatory data reconciliation process in which the contractor must provide full participant datasets, including dates of birth and eligibility status, to the CSD for review and approval prior to benefit issuance. • Request the contractor to complete an enhancement to its eligibility determination system to automatically flag participants under age one or over age 22 for further review. • Request the Electronic Benefits Transfer vendor to create a standard monthly report to show expenditures and expired benefits by client. If the grantor contacts the Department regarding the questioned costs identified in this finding, the Department will consult with the grantor to determine whether repayment is required. Prior Findings: None Completion Date: Estimated July 2026 Agency Contact: Richard Meyer External Audit Compliance Manager Richard.Meyer@dshs.wa.gov

View Audit 395688

Finding 1191845 (2025-007)

Material Weakness 2025

State of Washington C/o Office of Financial Management

WA

Subrecipient Monitoring

Finding Number: 2025-007 Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Program: 1...

Finding Number: 2025-007 Finding: The Office of Superintendent of Public Instruction did not have adequate internal controls over and did not comply with requirements to ensure it communicated federal award identification elements to subrecipients of the Child and Adult Care Food Program. Program: 10.558 – Child and Adult Care Food Program Compliance Requirement: Subrecipient Monitoring Questioned Costs: $0 Status: Corrective action complete Corrective Action: In response to the prior year’s finding, the Office had updated procedures for distributing federal award information and requirements to all subrecipients of the Child and Adult Care Food Program to ensure compliance with federal requirements. To further strengthen internal controls to address the exceptions identified during the audit, the Office has made additional procedural updates to address situations where new program operators and sponsors renew outside of the typical renewal cycle. Prior Findings: The conditions noted in this finding were previously reported in findings 2024-004 and 2023-003. Completion Date: January 2026 Agency Contact: Chaundi Barbosa Director, CACFP (360) 725-0411 chaundi.barbosa@k12.wa.us

View Audit 395688

Finding 1191809 (2025-002)

Material Weakness 2025

Government of Puerto Rico Department of Corrections and Rehabilitation

PR

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

The DCR's management acknowledged the delay in preparing and retaining OP-15 documentation and stated that the Department's immediate priority was to ensure that employees received their authorized salary increases in a timely manner. To address this priority, management updated the internal payroll...

The DCR's management acknowledged the delay in preparing and retaining OP-15 documentation and stated that the Department's immediate priority was to ensure that employees received their authorized salary increases in a timely manner. To address this priority, management updated the internal payroll database by developing an electronic listing of affected employees and implementing approved salary changes directly within the system. Management indicated that this approach ensured that employees were compensated in accordance with approved salary adjustments, although the supporting documentation in personnel files lagged behind. Management further indicated that corrective efforts are currently underway to address a more recent, similar personnel action involving fewer than 50 employees and that, upon completion, the Department intends to proceed with preparing the OP-15 forms related to the broader population of over 4,000 employees. Management expects to complete the preparation and filing of the outstanding OP-15 documentation prior to the end of fiscal year 2026.

View Audit 395624

Finding 1191808 (2025-003)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Eligibility Questioned Costs Subrecipient Monitoring

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management a...

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management acknowledges the eligibility determination error involving a two-unit dwelling and agrees that eligibility verification procedures were not sufficiently applied in accordance with DOE requirements for multiunit properties. The Organization takes this finding seriously and is committed to strengthening controls to prevent recurrence. The Organization is actively working with the pass-through entity to resolve the questioned costs of $4,048.39 and will repay any disallowed costs as required. Corrective Action Plan 1. Multi-Unit Eligibility Control Protocol A new Multi-Unit Eligibility Determination Checklist has been implemented requiring: • Individual income verification for each unit • Calculation worksheet demonstrating compliance with: o 66% rule, OR o 50% rule (where applicable), OR o HUD categorical eligibility per WPN 22-5 • Written supervisory approval prior to job authorization No multi-unit property may proceed to audit or production until eligibility documentation is approved. 2. Pre-Service Supervisory Approval Requirement • All multi-unit eligibility determinations must be reviewed and signed by: o Will Eberle (Weatherization Director) • Documentation must be verified before work order issuance. This adds a preventive control prior to expenditure of funds. 3. Executive Oversight Review • Will Eberle (Weatherization Director) will receive a monthly eligibility compliance report. • Any exceptions will trigger immediate review. • Quarterly summary reporting will be presented to senior leadership. 4. Targeted Eligibility Training • Staff will complete focused training on: o DOE WAP multi-family eligibility requirements o Income documentation standards o HUD categorical eligibility • Training will be conducted within 45 days and annually thereafter. • Attendance logs and materials will be maintained by Scott Hall. 5. File Audit & Continuous Monitoring • Will Eberle (Weatherization Director) will conduct monthly random sampling of: o 100% of multi-unit approvals for the next 6 months o Minimum 20% thereafter • Findings will be documented and tracked. 6. Resolution of Questioned Costs • The Organization is in communication with the pass-through entity regarding the $4,048.39 in questioned costs. • Repayment will occur promptly if required. • A repayment tracking file will be maintained by finance and reviewed by Chris Locarno. Implementation Timeline Summary Action, Responsible Party, Completion Target: Multi-unit checklist implemented, Scott Hall, Completed Supervisory sign-off requirement, Scott Hall, Immediate Staff eligibility training, Scott Hall, Within 45 days Executive reporting framework, Chris Locarno Completed Monthly sampling audits, Will Eberle, Ongoig Resolution of questioned costs WX Finance / Chris Locarno, Within 90 days Statement of Commitment The Organization is committed to restoring and maintaining full compliance with all federal and state Weatherization program requirements. Leadership, including, but not limited to: Will Eberle (Weatherization Director), Scott Hall (Weatherization Associate Director), and Chris Locarno (Business Manager), has implemented structural safeguards, enhanced supervisory review, and reinforced a culture of compliance and accountability to ensure that these deficiencies do not recur. Management believes the corrective actions outlined above address both the immediate deficiencies and the underlying control weaknesses identified in the audit. Responsible Person: Will Eberle Date of Completion: April 1, 2026

View Audit 395614

Finding 1191799 (2025-002)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring

Community Services Block Grant (ALN 93.569) U.S. Department of Health and Human Services State of Vermont Department for Children and Families Finding 2025-002 Compliance Finding - Special Tests and Provisions Corrective Action Plan Board Composition Matrix In response to the audit comment concernin...

Community Services Block Grant (ALN 93.569) U.S. Department of Health and Human Services State of Vermont Department for Children and Families Finding 2025-002 Compliance Finding - Special Tests and Provisions Corrective Action Plan Board Composition Matrix In response to the audit comment concerning the need for a Board Composition Matrix, we reviewed our current Board Roster. This review indicates our Roster meets the requirements listed (sector designation, term start and end dates, public official designation expiration, as applicable, and vacancy status). The board is sent an updated roster upon request. and it is updated each time a board member and/or seat is changed. The Board Development and Governance Committee reviews this most of the months that they meet, especially when discussing board recruitment, which is an ongoing agenda item while a seat is vacant. Current Procedure Currently, the Board Chair (Abby White) and Governance Committee Chair (Karen Lowry Reed) are both regularly consulted about board vacancies by the Executive Director (Alison Calderara), both to commit to outreach, and to review current candidates for the board. The Board Bylaws currently reference that the Board Development & Governance Committee is responsible for "[filling] any vacancies on the Board as soon as reasonably Possible." Additionally, all Board members sign an acknowledgement of the Bylaws annually, which reference the board composition. Recruitment is the responsibility of the Development and Governance Committee. Proposed Update of Procedure With the assistance of associated staff, the Development & Governance Committee will create a procedure to follow when vacancies arise, that covers unforeseen vacancies, as well as planned ones (such as when a board member's term limit is approaching). This will also include reference for different sectors, each of which have slightly different requirements for coming on the board. Capstone will complete this written procedure within 90 days. Current Status The Board seat that resulted in the organizational standard finding was filled November 2025. Three of the four required public sector seats are now filled. Responsible Person: Alison Calderara Date of Completion: June 28, 2026

View Audit 395614

Finding 1191798 (2025-001)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Inter...

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Internal Control Over Compliance Views of Responsible Officials Management acknowledges the deficiency identified in the Quality Control Inspection (QCI) process. While questioned costs were not identified, we recognize that the breakdown in controls represents a material weakness requiring immediate and sustained corrective action. Since the Office of Economic Opportunity (OEO) monitoring review, the Organization has undergone structural and cultural changes within the Weatherization Department. Leadership has taken decisive steps to reinforce compliance expectations, supervisory accountability, and documentation integrity. Corrective Action Plan 1. Immediate Structural Oversight Enhancement • Will Eberle (Weatherization Director) is designated as the primary responsible official for QCI program compliance. • Scott Hall (Weatherization Associate Director and Quality Control Lead) is responsible for direct oversight of all QCI staff and inspection standards. • Chris Locarno (Business Manager) will provide executive-level oversight and ensure crossdepartmental accountability and reporting to senior leadership and the Board. Effective immediately: • No weatherization unit may be reported or invoiced until: o QCI documentation is fully complete, o All required test results (blower door, combustion safety, final inspection) are included, o Client signature is present, o Secondary supervisory review is completed. 2. Secondary File Review Control A new Two-Tier Review Process has been implemented: Tier 1 - QCI Review (Performed by Certified BPI QCI) • Full compliance with Vermont Weatherization Program Standards • Documentation of all required final tests • Verification that QCI was not performed by supervising crew members or project participant Tier 2 - Supervisory File Review • Conducted by Scott Hall • Random sampling at minimum 25% of completed units monthly • Monthly summary report submitted to Will Eberle • Quarterly compliance summary reviewed with Chris Locarno No unit will be considered production-complete until Tier 2 review confirms documentation sufficiency. 3. Mandatory QCI Refresher Training • All QC I-certified staff will complete refresher training on: o DOE and HHS requirements o Vermont Weatherization Program Standards o Documentation standards o Independence requirements • Training will occur semi-annually at minimum. • Scott Hall will document attendance and maintain training logs. • Chris Locarno will verify annual compliance training completion as part of management review. Additionally, peer case reviews will be incorporated quarterly to reinforce quality standards. 4. Cultural and Performance Accountability • QCI compliance metrics will be incorporated into staff performance evaluations. • Repeated documentation failures will result in retraining or removal of QCI approval authority. • Monthly compliance meetings led by Scott Hall will include trend review and corrective tracking. 5. Monitoring & Reporting Timeline Action Two-tier review implemented, Will Eberle, Completed Refresher training session, Scott Hall, Within 60 Days Executive compliance review structure , Chris Locarno, Completed Quarterly internal audit sampling, Scott Hall / Will Eberle, Ongoing Responsible Person: Scott Hall Date of Completion: April 1, 2026

View Audit 395614

Finding 1191785 (2025-001)

Material Weakness 2025

Elk City Independent School District No. 06

OK

Questioned Costs Subrecipient Monitoring Material Weakness

Elk City Public Schools will ensure that on all future construction contracts that deal with federal awards, requirements of the Davis-Bacon Act will be included. Prevailing wages will be inserted into the language of the contract and shall be signed by contractors and subcontractors. All contracts ...

Elk City Public Schools will ensure that on all future construction contracts that deal with federal awards, requirements of the Davis-Bacon Act will be included. Prevailing wages will be inserted into the language of the contract and shall be signed by contractors and subcontractors. All contracts will also spell out weekly reporting requirements of certified wages paid by contractors and subcontrators. In addition, ECPS will ensure that Davis-Bacon information is posted at all job sites. These policy changes will be implemented immediately and be in place as of October 9, 2025.

View Audit 395599

Finding 1191772 (2025-007)

Material Weakness 2025

Northeastern Illinois University

IL

Questioned Costs Subrecipient Monitoring Reporting

Condition: Northeastern Illinois University (University) did not report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for the Higher Education Institutional Aid grants. Planned Corrective Action: The University wil...

Condition: Northeastern Illinois University (University) did not report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for the Higher Education Institutional Aid grants. Planned Corrective Action: The University will review applicable guidelines and assign the responsibility to the appropriate office. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026

View Audit 395581

Finding 1191771 (2025-008)

Material Weakness 2025

Northeastern Illinois University

IL

Subrecipient Monitoring Cash Management Reporting § 200.305

Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective act...

Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026

View Audit 395581

Finding 1191766 (2025-001)

Material Weakness 2025

Illinois Housing Development Authority

IL

Subrecipient Monitoring HUD Housing Programs § 200.303 § 200.332

The Authority agrees with the finding. The Authority will implement additional internal controls, including quality control of completed inspection, documentation, and inspection scheduling. Additionally, the Authority recognizes that the volume of required annual inspections has increased beyond ex...

The Authority agrees with the finding. The Authority will implement additional internal controls, including quality control of completed inspection, documentation, and inspection scheduling. Additionally, the Authority recognizes that the volume of required annual inspections has increased beyond existing Full Time Equivalent (FTE) capacity; therefore, an RFP for the third-party inspection vendor has been issued to supplement internal resources and support timely completion of inspections.

View Audit 395570

Finding 1191763 (2025-001)

Material Weakness 2025

Dawn Center for Independent Living

NJ

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Responsible Executive: CEO – Carmela Slivinski Implementation Status: Effective Immediately Full Implementation Date: No later than June 30, 2026 Finding — Compliance (Period of Performance) Significant Deficiency Condition: Auditor noted while testing period of performance, 1 of the 10 expenses rec...

Responsible Executive: CEO – Carmela Slivinski Implementation Status: Effective Immediately Full Implementation Date: No later than June 30, 2026 Finding — Compliance (Period of Performance) Significant Deficiency Condition: Auditor noted while testing period of performance, 1 of the 10 expenses recorded in June 2025 pertained to subsequent months outside of the contract period. Effect: One expense was included in the expenditure report under the incorrect grant period ending June 30, 2025. Cause: The Organization noted that this finding came about due to a clerical error. The bookkeeper inadvertently recorded a July invoice on June 30th and this led to an incorrect charge to the grant period ending June 30th. Recommendation: Auditor recommends management continue to perform a second review on the grant submission especially towards the end of the grant period. Management’s Response: Management concurs with the finding regarding deficiencies in grant period-of-performance compliance. Corrective Action Plan - Review existing Accounts Payable and Accounting Controls processes and revise as needed to ensure expenses are recorded as required. - Staff Training and Competency Development conducted annually to review accounting controls and ensure accounting personnel understand period of performance grant compliance requirements. - Ongoing Monitoring and Internal Compliance Review conducted periodically to ensure oversight of financial controls and grant compliance.

View Audit 395564

Finding 1191761 (2025-003)

Material Weakness 2025

County of Los Angeles

CA

Subrecipient Monitoring Internal Control / Segregation of Duties Questioned Costs

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Deputy Director, Department of Public Health 2. Corrective action plan: DPH agrees with the finding and recommendation. VPDCP will develop and implement written procedures for the centralized and secure storage of do...

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Deputy Director, Department of Public Health 2. Corrective action plan: DPH agrees with the finding and recommendation. VPDCP will develop and implement written procedures for the centralized and secure storage of documentation supporting grant deliverables and required progress reports. The procedures will include, at a minimum, the following: • Define required documentation, storage location, staff responsibilities, and retention requirements. • Require all supporting documentation to be maintained in a designated centralized repository and ensure documentation is complete, organized, and readily accessible for review. • Detail the steps during staff transitions that new staff must follow to access, maintain, and update grant-related documentation, ensuring consistency and completeness of records. VPDCP will perform periodic reviews of the centralized repository and formally document and sign-off on the reviews to verify that required documentation is maintained. 3. Anticipated implementation date: June 19, 2026

View Audit 395559

Finding 1191760 (2025-002)

Material Weakness 2025

County of Los Angeles

CA

Subrecipient Monitoring § 200.332 § 200.425 § 200.513 § 200.521

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Administrative Deputy, DCBA 2. Corrective action plan: DCBA concurs with the findings and the recommendation, however, the total expenditure amount of $5,917,341 is inclusive of expenditures from a different contract...

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Administrative Deputy, DCBA 2. Corrective action plan: DCBA concurs with the findings and the recommendation, however, the total expenditure amount of $5,917,341 is inclusive of expenditures from a different contract held by the same agency who was identified as a contractor and not a sub-recipient. As such, expenditures under that contract would not be subject to monitoring as set forth in 2 CFR § 200.332. Therefore, the total expenditures for the four (4) subrecipient agreements that are missing monitoring reports are $585,756. To address the finding, DCBA will establish a formal monitoring plan that will include a monitoring checklist, monitoring schedule, and a detailed tracking log to ensure timely monitoring of its subrecipients. DCBA will work with CEO and/or the Auditor-Controller to identify resources to implement ongoing monitoring of subrecipients, with clear documentation and reporting. Additionally, DCBA already implemented a risk assessment process to ensure an assessment of all subrecipients is completed at least once a year. This process will be formalized in writing. The process involves identifying risk areas, including reviewing financial stability, legal risks, capacity, and performance history. The assessment process uses a risk scoring model that rates organizations using a risk level scale between 1-5 that takes into consideration operating reserves, program and fundraising efficiency, and their ability to meet financial obligations. 3. Anticipated implementation date: September 30, 2026.

View Audit 395559

Finding 1191751 (2025-009)

Material Weakness 2025

School District of the City of St. Louis

MO

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement p...

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures and controls to ensure pre-approval in accordance with the Uniform Guidance compliance requirements.

View Audit 395555

Finding 1191750 (2025-008)

Material Weakness 2025

School District of the City of St. Louis

MO

Questioned Costs Subrecipient Monitoring Cash Management

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement p...

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures for review and reconciliation of lunch count data with claims reports in accordance with the Uniform Guidance.

View Audit 395555

Finding 1191680 (2025-001)

Material Weakness 2025

Discovery Science Center of Orange County and Subsidiaries

CA

Questioned Costs Subrecipient Monitoring Reporting § 200.329

Management’s Plan for Corrective Action: Management agrees with the finding and plans to implement procedures to ensure timely submission of required performance reports. We will ensure that the grant administrator develops processes for a reporting calendar, preparing required reports, and document...

Management’s Plan for Corrective Action: Management agrees with the finding and plans to implement procedures to ensure timely submission of required performance reports. We will ensure that the grant administrator develops processes for a reporting calendar, preparing required reports, and documenting submission. Management expects these procedures to be implemented beginning in the next reporting cycle. Management has subsequently completed and submitted all of the required performance reports to remedy the identified deficiency.

View Audit 395528

Finding 1191678 (2025-003)

Material Weakness 2025

M. Carter Plaza

OR

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Finding no.: 2025-003 Contact person(s) responsible: Kymberly Horner, Executive Director for PCRI and Matthew Wrigley, Accounting Financial and Audit Manager for Cascade Management Corrective action planned: The monthly deposits to the replacement reserve account have been reinstated after the lapse...

Finding no.: 2025-003 Contact person(s) responsible: Kymberly Horner, Executive Director for PCRI and Matthew Wrigley, Accounting Financial and Audit Manager for Cascade Management Corrective action planned: The monthly deposits to the replacement reserve account have been reinstated after the lapse which was due to a period of transition of management in the property management department. The funding processes have been reestablished and procedures are in place to ensure there are no unplanned lapses in funding the reserve going forward. Anticipated completion date: February 2026

View Audit 395527

Finding 1191676 (2025-001)

Material Weakness 2025

M. Carter Plaza

OR

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring § 200.512

Finding no.: 2025-001 Contact person(s) responsible: Kymberly Horner, Executive Director for PCRI and Matthew Wrigley, Accounting Financial and Audit Manager for Cascade Management Corrective action planned: The closing of books and preparation for audit procedures is being addressed via improvement...

Finding no.: 2025-001 Contact person(s) responsible: Kymberly Horner, Executive Director for PCRI and Matthew Wrigley, Accounting Financial and Audit Manager for Cascade Management Corrective action planned: The closing of books and preparation for audit procedures is being addressed via improvements in internal controls related to property accounting, month and year end closing procedures which include a new property management accounting software package. It is also being addressed via the hiring of more experienced staff during fiscal year 2024-2025. The organization anticipates that these improvements will allow for the audit to be completed within the required timeframe in the upcoming cycle. Anticipated completion date: October 2026

View Audit 395527

Finding 1191675 (2025-004)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Questioned Costs Subrecipient Monitoring

Condition: Of the 40 students selected for enrollment reporting, the College did not update the student enrollment information for 3 students accurately. Planned Corrective Action: The College will modify its process and update its documented procedures to include periodically running an Enrollment ...

Condition: Of the 40 students selected for enrollment reporting, the College did not update the student enrollment information for 3 students accurately. Planned Corrective Action: The College will modify its process and update its documented procedures to include periodically running an Enrollment Reporting Graduated/Withdrawn Report from NLSDS and review for accuracy and make timely corrections, if necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2026

View Audit 395523

Finding 1191673 (2025-003)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Questioned Costs Subrecipient Monitoring

Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented proced...

Condition: The College did not have appropriate segregation of duties in place to ensure the reporting to COD is being reviewed by an individual separate from the process of preparing the reconciliations. Planned Corrective Action: The College will modify its process and update its documented procedures to include an appropriate review of the reconciliation by an individual separate from the process of preparing the reconciliations. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: June 30, 2026

View Audit 395523

Finding 1191671 (2025-002)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Questioned Costs Subrecipient Monitoring

Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct a...

Condition: The College did not provide notifications to certain students related to direct loan disbursements. Planned Corrective Action: The Director of Financial Aid will work with our information technology department to ensure the criteria used for triggering the notification emails is correct and capturing all the necessary students. Additionally, an exception report will be created to identify students who have not been sent the notification email for the financial aid department to review and then send the appropriate notification. The department procedures will be updated to reflect these changes in process. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026

View Audit 395523

Finding 1191669 (2025-001)

Material Weakness 2025

Kalamazoo Valley Community College

MI

Student Financial Aid Questioned Costs Subrecipient Monitoring

Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to ident...

Condition: Out of 60 students tested for return to Title IV, we identified 4 students whose calculations were performed outside of the required time frame. Planned Corrective Action: The College will work with its Director of Financial Aid to ensure the semester end procedures include steps to identify those students who unofficially withdrew. Once the students are identified, individuals with appropriate skills and knowledge will be able to determine if a return of Title IV calculation is necessary and appropriately return any funds, as necessary. Contact person responsible for corrective action: Director of Financial Aid Anticipated Completion Date: March 31, 2026

View Audit 395523

Finding 1191651 (2025-002)

Material Weakness 2025

Hawaii Pacific University

HI

Subrecipient Monitoring Student Financial Aid Reporting

The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity ...

The University has made substantial progress toward completing the remaining elements required under the Gramm-Leach-Bliley Act (GLBA) and aligning its program with the FTC Safeguards Rule. Full implementation timelines are primarily constrained by current staffing capacity within ITS/Cybersecurity and Legal, as well as certain technical tool limitations (e.g., data discovery and validation). Despite these constraints, notable progress has been achieved across the required FTC Safeguards Program elements as summarized below: • Element 1 – Designate a Qualified Individual: Completed. Qualified individual appointed to implement and supervise the company’s information security program; reporting mechanisms to the Board established. Completion is confirmed based on oversight and execution of subsequent program elements. • Element 2 – Conduct a Risk Assessment: Completed. Initial risk assessment conducted to identify reasonably foreseeable threats; controls and priorities for Elements 3–9 is being guided by this assessment. • Element 3 – Access Controls & Data Classification: 70% complete. Policies finalized; multi- factor authentication (MFA) implemented; initial asset inventory completed. Data owner assignments and detailed access reviews are in progress. • Element 4 – Vulnerability Management: Complete. Latest penetration testing identified no critical findings. • Element 5 – Information Security Policies: Drafted and pending Legal review; Board acceptance scheduled for March 2026. • Element 6 – Third-Party Oversight: 70% complete. Policy and workflow developed; Board acceptance scheduled for March 2026. • Element 7 – Periodic Risk Assessments: 80% complete. Updated risk assessment currently in progress. • Element 8 – Incident Response Plan: 90% complete. Final reporting and approval scheduled for March 2026. • Element 9 – Qualified Individual & Board Reporting: 90% complete. Annual report scheduled for March 2026. • Red Flags Rule (Identity Theft Prevention): 50% complete. Policy drafted, complete comprehensive program, formal procedures and additional trainings still required. Next Steps: Remaining actions will be completed as Legal and Board approvals are obtained and staffing capacity allows. HPU will continue to develop and retain documentation supporting the completion and implementation of each safeguard element, as prescribed by GLBA. Periodic internal assessments of the Information Security Program will be scheduled following full implementation, with consideration given to engaging an independent third party for future reviews. Person(s) Responsible: Information Security Officer; Vice President of Operations and Chief Information Officer. Targeted Correction Date: March 31, 2026.

View Audit 395499

Finding 1191583 (2025-005)

Material Weakness 2025

Municipality of Catano

PR

Questioned Costs Subrecipient Monitoring Reporting § 200.302 § 200.328 § 200.329

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordan...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number: 2025-005 Statement of Concurrence or Nonconcurrence: We concur we the finding. Corrective Action: Adopted Measures • Expense Synchronization: A protocol will be implemented requiring contracted consultants to record and report incurred expenses only when a validated disbursement voucher is available, thereby ensuring the integrity of the financial flow. • Reconciliation: The office will conduct a detailed comparison between the draft quarterly report and the general ledger to identify and correct any discrepancies prior to final submission. • Compliance Timeline: An internal deadline will be established for the submission of the report, ensuring attainment of the minimum percentage required under the Quality Activities category through accurate financial data. Expected Outcome To ensure that all financial information submitted is complete, accurate, and fully aligned with the Municipality’s accounting records, thereby eliminating the risk of audit findings. Implementation Date: March 2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

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Finding 1191581 (2025-003)

Material Weakness 2025

Municipality of Catano

PR

Subrecipient Monitoring Questioned Costs Allowable Costs / Cost Principles

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordan...

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF CATAÑO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Julio Alicea Vasallo, Mayor Contact Person: Mrs. Honoris Machado, Finance Director Phone: (787) 788-0404 Original Finding Number: 2025-003 Statement of Concurrence or Nonconcurrence: We concur with the finding. Corrective Action: Corrective Action Implemented 1. Request for Technical Assistance Technical assistance was requested from the corresponding state agency and all municipal components involved in the process, with the purpose of: • Establishing a structured work plan. • Aligning compliance processes. • Clearly defining the documentation required for quarterly reports. • Reviewing the processes of the Fiscal Monitoring System Portal. • Incorporating technical recommendations issued by the agency. 2. Measures Adopted by This Office As a result of the technical assistance, the following corrective actions were implemented: • Development of a Required Documentation Checklist to standardize the collection of information. • Clear definition of the scope of collaborative work among offices. • Formal establishment of tasks, roles, and responsibilities. • Assignment and monitoring of the limited staff designated by the office. • Update of the Fiscal Monitoring System Portal to grant access to newly authorized personnel. Results Achieved As a result of the implementation of the corrective action plan: • The required information from the various municipal offices was collected completely and in a timely manner. • The quarterly report was submitted by the established deadline (01/15/2026). • The agency validated compliance (01/30/2026). • The disbursement of funds was successfully received (02/04/2026). Evidence of Effectiveness • Compliance with the established deadline. • Confirmation of receipt and approval of the report. • Disbursement processed without findings or additional requirements. • Strengthened interdepartmental coordination. • A documented and standardized process for future quarterly cycles. Standardization and Prevention • The Checklist was adopted as an official tool of the process. • The assignment of roles and responsibilities was formally established. • Access to the Fiscal Monitoring System Portal is kept up to date. • Continuous monitoring was established to ensure compliance in future quarters. Observation Regarding Human Resources Although the corrective action proved effective and allowed for the timely submission of the report and receipt of the disbursement, the personnel currently assigned to the process also support multiple additional programs. While the situation was corrected following internal reorganization, the shared operational workload could pose a risk to the long-term sustainability of the control. It is recommended that the allocation of additional human resources be evaluated to strengthen operational continuity and prevent recurrence of the previously identified issue. Conclusion and Closure The corrective action implemented proved to be effective and sustainable, eliminating the deficiencies identified in the process of collecting and submitting quarterly reports. Regulatory compliance and strengthened administrative management are evidenced, ensuring continuity in the timely receipt of future disbursements. Implementation Date: Fiscal Year 2025-2026. Responsible persons: • Person responsible for the implementation: Mr. Carlos Flores, Federal Program’s Subdirector • Person responsible for the supervision: Mrs. Yolanda Maldonado, Federal Program’s Director

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