Corrective Action Plans

Finding 1186983 (2025-015)

Material Weakness 2025

State of Ohio

OH

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Corrective Action Plan: ODM agrees with the Auditor’s recommendation to re-evaluate its Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure subaward information— including data reported by partner agencies— is entered accurately and on time in SAM.gov. ODM is c...

Corrective Action Plan: ODM agrees with the Auditor’s recommendation to re-evaluate its Federal Funding Accountability and Transparency Act (FFATA) reporting procedures to ensure subaward information— including data reported by partner agencies— is entered accurately and on time in SAM.gov. ODM is committed to timely reporting and is implementing the following actions to address this finding: • Multiple ODM staff now have SAM.gov access. (Completed) • ODM will document FFATA reporting procedures in a formal manual. • ODM is creating a tracking sheet with an approval process to verify that monthly reports from partner agencies are complete and accurate. • ODM has improved communication with subrecipients to ensure subaward information is received and submitted by required deadlines. Anticipated Completion Date for Corrective Action: June 2026 Contact Person Responsible for Corrective Action: Name: Megan Powell Title: Audit Remediation Manager Address: 50 West Town Street, Suite 400, Columbus, Ohio 43215 Phone Number: 614-752-3844 E-Mail Address: megan.powell@medicaid.ohio.gov

View Audit 394693

Finding 1186982 (2025-014)

Material Weakness 2025

State of Ohio

OH

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

Corrective Action Plan: The Department agrees with the finding related to the large volume of system alerts and remains committed to ongoing work with our vendor, the Department of Job and Family Services (ODJFS), and the Department of Children and Youth (DCY) to improve the Ohio Benefits eligibilit...

Corrective Action Plan: The Department agrees with the finding related to the large volume of system alerts and remains committed to ongoing work with our vendor, the Department of Job and Family Services (ODJFS), and the Department of Children and Youth (DCY) to improve the Ohio Benefits eligibility system and reduce unnecessary alerts, including those generated through IEVS. These efforts are already showing progress: total incoming alerts decreased from 21.2 million in SFY 2024 to 16.9 million in SFY 2025. ODM has also reduced the average time it takes to clear alerts. Alerts play a key role in program integrity by notifying county caseworkers of important eligibility information that may require action. Anytime new programs are added to the Ohio Benefits system or program rules change, new alerts may be generated. ODM meets every other month with ODJFS to review IEVS-related issues. This collaboration resulted in nine system enhancements in SFY 2025 to reduce unnecessary alert generation. Several enhancements introduced Smart Alert Hierarchy logic, which prevents duplicate alerts by directing an alert to the individual’s first active or pending program in the sequence: Medicaid, SNAP, TANF, Child Care. Notable changes include: • AVS alerts: Only the final alert is generated 15 business days after the request. • SWICA alerts: The threshold for generating alerts increased to $750 per quarter or $250 per month. • PARIS alerts: Alerts are no longer generated when data matches previous records or when information is incomplete; Smart Alert Hierarchy now applies. • New Hire alerts: Alerts are suppressed when employer information has not changed; Smart Alert Hierarchy applies. • BENDEX alerts: Alerts are suppressed when SSA information has not changed; program-specific income limit alerts were retired; Smart Alert Hierarchy applies. • IEVS UCB and SDX alerts: Alerts no longer generate when changes are under $250 per month (up from $25). • IEVS BENDEX alerts: Alerts suppressed for changes under $250 per month (up from $49). • IRS Unearned Income alerts: Alerts suppressed when income differences are within $250 per month of existing records. ODM is continuing to evaluate additional alert-reduction opportunities. Confirmed upcoming system updates include: • Release 5.5 (anticipated June 12, 2026): Automation of verified-upon-receipt SDX interfaces, suppressing alerts after automatic reconciliation. • Release 5.6 (anticipated August 22, 2026): Updated thresholds for IRS Unearned Income alerts. Regarding automation, ODJFS explored using bots to process IEVS alerts. However, federal rules prohibit automation in IEVS processing for SNAP, and because IEVS alerts span multiple programs, automation cannot be applied solely for Medicaid. ODM will continue working with ODJFS to evaluate future options. ODM’s Technical Assistance, Compliance, and County Engagement teams regularly train and support county staff. ODJFS provides a web-based course, available year-round through the County Resources website, to ensure ongoing access despite frequent staffing changes. The training is being updated to be more interactive and modular. The next live annual training event is scheduled for October 2026. The Auditor of State noted that 833,232 of the 1,721,772 IEVS alerts issued during the audit period (48.4%) were not cleared within 45 days. Federal rules require agencies to develop and follow verification procedures (42 CFR 435.945), and state rule OAC 5160:1-1-04 requires agencies to take specific steps to determine eligibility within 45 days. However, clearing an alert in the Ohio Benefits system is not itself a federal or state requirement. ODM agrees counties must improve the administrative step of clearing alerts, but failure to clear an alert does not necessarily mean the information was not reviewed or acted upon in a timely manner. ODM will continue to emphasize the importance of completing this final step. Anticipated Completion Date for Corrective Action: January 2027 Contact Person Responsible for Corrective Action: Megan Powell Audit Remediation Manager 50 West Town Street, Suite 400, Columbus, Ohio 43215 614-752-3844 megan.powell@medicaid.ohio.gov

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Finding 1186955 (2025-007)

Material Weakness 2025

State of Ohio

OH

Reporting Procurement, Suspension & Debarment Subrecipient Monitoring

Corrective Action Plan: The Department will continue to evaluate its internal controls over the SAM.gov reporting process, by collecting and reporting complete, accurate, and timely information regarding the subawards subject to the Transparency Act. The Department will cross-train employees over th...

Corrective Action Plan: The Department will continue to evaluate its internal controls over the SAM.gov reporting process, by collecting and reporting complete, accurate, and timely information regarding the subawards subject to the Transparency Act. The Department will cross-train employees over the Transparency Act reporting process to ensure the SAM.gov reporting can be performed by various personnel during vacations or with employee turnover. Management will review these procedures to ensure they promote compliance with federal regulations and are operating as intended. Anticipated Completion Date for Corrective Action: June 2026 Contact Person Responsible for Corrective Action: Name: Colin Grisier Title: Senior Manager for Reporting and Compliance Address: 77 South High Street, Columbus, Ohio 43215 Phone Number: 614-446-2625 E-Mail Address: Colin.Grisier@development.ohio.gov

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Finding 1186953 (2025-003)

Material Weakness 2025

State of Ohio

OH

Period of Performance Questioned Costs Subrecipient Monitoring

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

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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

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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

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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

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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

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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

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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

Questioned Costs Subrecipient Monitoring HUD Housing Programs

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 1186833 (2025-018)

Material Weakness 2025

Second Judicial District Court

NM

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Recommendation: We recommend the Department implements procedures to ensure compliance with federal period of performance regulations. Views of responsible officials: The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditur...

Recommendation: We recommend the Department implements procedures to ensure compliance with federal period of performance regulations. Views of responsible officials: The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

View Audit 394575

Finding 1186828 (2025-015)

Material Weakness 2025

Second Judicial District Court

NM

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

Recommendation: We recommend that the Department assist the Programs by providing training to employees, including supervisory-level employees, to ensure adherence with Department or Program policy. Views of responsible officials: ALN 84.367 Open – Views of responsible officials and management’s pla...

Recommendation: We recommend that the Department assist the Programs by providing training to employees, including supervisory-level employees, to ensure adherence with Department or Program policy. Views of responsible officials: ALN 84.367 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.424A/F Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.424D Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.365 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

View Audit 394575

Finding 1186823 (2025-014)

Material Weakness 2025

Second Judicial District Court

NM

Subrecipient Monitoring

Recommendation: We noted improvements have been made during the audit period, including retainage of the FY26 Federal Programs Cross-Cutting Risk Assessment Tool. We recommend the Department continues to follow new procedures in place. Additionally, we recommend the Department implement effective pr...

Recommendation: We noted improvements have been made during the audit period, including retainage of the FY26 Federal Programs Cross-Cutting Risk Assessment Tool. We recommend the Department continues to follow new procedures in place. Additionally, we recommend the Department implement effective processes and procedures to ensure all required elements are included in the communications to subawardees Views of responsible officials: ALN 84.367 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.365 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.424D Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 21.029 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

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Finding 1186819 (2025-013)

Material Weakness 2025

Second Judicial District Court

NM

Questioned Costs Subrecipient Monitoring Reporting

Recommendation: We recommend the Department implement effective processes and procedures to ensure the information reported aligns with the underlying support Views of responsible officials: ALN 21.029 Open – Views of responsible officials and management’s planned corrective actions, timeline and de...

Recommendation: We recommend the Department implement effective processes and procedures to ensure the information reported aligns with the underlying support Views of responsible officials: ALN 21.029 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

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Finding 1186816 (2025-011)

Material Weakness 2025

Second Judicial District Court

NM

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

Recommendation: We recommend the Department review the instructions for completion of the FFATA reports with training provided to the program staff who are preparing and reviewing the FFATA reports to ensure submitted reports are timely and complete. We recommend the Department implement effective p...

Recommendation: We recommend the Department review the instructions for completion of the FFATA reports with training provided to the program staff who are preparing and reviewing the FFATA reports to ensure submitted reports are timely and complete. We recommend the Department implement effective processes and procedures to maintain the submitted reports and the documentation used to prepare the reports in the files of the Department. Views of responsible officials: ALN 10.555: Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.425U The SSFS staff is currently working on adding all pertinent subawards. However, it has proven difficult to get access to our staff via the FFATA helpdesk. We are diligently trying to solve such issues as not knowing the previous owner of these grants in the FFATA system in order to transfer this ownership to the current staff. The Director and Deputy Director of the Student, School, and Family Support (SSFS) Bureau are responsible for ensuring the FFATA reporting is completed by March 31, 2025. ALN 21.029 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.365: Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.367: Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

View Audit 394575

Finding 1186812 (2025-010)

Material Weakness 2025

Second Judicial District Court

NM

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

ALN 84.424F Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.365 Open – Views of responsible officials and management’s planned corrective actions, timel...

ALN 84.424F Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. ALN 84.365 Open – Views of responsible officials and management’s planned corrective actions, timeline and designation of what employee position are responsible for meeting deadlines in the timeline. The Division of Vocational Rehabilitation agrees with the findings and, as such, will implement regular reviews of federal expenditures and period of performance. The DVR General ledger team will meet quarterly with the Chief Financial Officer and review all federal expenditures to be recorded timely and accurately. DVR will also continue to meet with program field staff to ensure obligations are within the appropriate period. Position: CFO Timeline: 06/30/2025

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Finding 1186810 (2025-001)

Material Weakness 2025

Behavioral Health Initiatives, Inc.

TN

Subrecipient Monitoring Reporting Significant Deficiency

Management has implemented procedures effective 7/1/2025 to ensure that reports are submitted timely and that any new filing deadlines will be documented and met without exception.

View Audit 394574

Finding 1186805 (2025-005)

Material Weakness 2025

Greater Clark County Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S4...

Information on the federal program: Subject: Education Stabilization Fund (ESSER) - Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers and Years (or Other Identifying Numbers): S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Reporting Audit Finding: Material Weakness Context: The School Corporation was required to submit one Annual Data Report for each year in the audit period to the Indiana Department of Education (IDOE) to meet federal reporting requirements for ESSER grant awards. There was no documented review by someone other than the preparer of the Annual Data Report to ensure the information submitted was complete and accurate. Additionally, we noted that the ESSER Ill amount reported ($4,576,082) did not agree to the underlying expenditure records ($5,158,597) of the School Corporation. Also, the School Corporation was not unable to provide supporting documentation to support the Full-Time (FTE) count reported in the Crossact Report. Contact Person Responsible for Corrective Action: Laura Hubinger Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: 1. All final reports will be reviewed by someone other than the preparer to check accuracy. 2. Work with software company to be able to capture the FTE payment reports that were requested for any future possible federal payments for Crossact Reporting. Anticipated Completion Date: Resolved, March 2026

View Audit 394550

Finding 1186803 (2025-003)

Material Weakness 2025

Greater Clark County Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring

Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Internal Controls Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.01 0A Federal Award Numbers and Years (or Other Identifyin...

Information on the federal program: Subject: Title I Grants to Local Educational Agencies - Internal Controls Federal Agency: Department of Education Federal Program: Title I Grants to Local Educational Agencies Assistance Listing Number: 84.01 0A Federal Award Numbers and Years (or Other Identifying Numbers): S010A220014, S010A230014, S010A240014 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Test and Provisions - Annual Report Card, High School Graduation Rate Audit Finding: Material Weakness Context: In a sample of 60 students who were removed from the cohort, we noted 1 0 student for which the School Corporation did not maintain any mobility documentation to support their removal from the cohort. Additionally, we noted 8 students for which the School Corporation did not maintain the appropriate mobility documentation to support their removal from the cohort. Per Indiana Department of Education (IDOE) guidance, students withdrawn by parents for nonpublic education must be documented using the withdrawal code "Withdrawal to non-accredited nonpublic school." The correct form was not maintained for these students. Contact Person Responsible for Corrective Action: Laura Hubinger Contact Phone Number: 812-288-4802 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: Continued training for staff will be provided and suggested withdrawal forms will be used, and documentation of the withdrawal will be maintained to explain any deficiencies. Anticipated Completion Date: Resolved, March 2026

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Corrective Action Plans

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