Corrective Action Plans

Finding 1201513 (2025-005)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Matching / Level of Effort / Earmarking Special Tests & Provisions Questioned Costs § 200.303

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 ...

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 out of 21 contractor and subcontractor certified payrolls tested were not submitted timely. VOAWW recognizes that timely receipt and review of certified payrolls is essential to ensuring compliance with federal wage requirements. To strengthen internal controls and ensure certified payrolls are consistently obtained, reviewed, and retained, VOAWW will implement the following corrective actions: Implementation of Certified Payroll Submission Controls Before the end of FY26, VOAWW will implement internal controls requiring contractors and subcontractors to submit certified payrolls with each pay application. These controls will include: • A requirement that certified payrolls be submitted prior to payment • A standardized checklist for verifying receipt of certified payrolls • Documentation of the review and approval process • Follow up procedures for missing or incomplete payrolls These steps will ensure certified payrolls are consistently obtained and reviewed before payment is released. Training for Staff on Wage Rate Requirements Beginning in FY26, staff responsible for managing HUD funded construction projects will receive training on: • Davis-Bacon and related wage requirements • Certified payroll documentation standards • Review procedures and red flags • Requirements under 29 CFR Part 5 Contractor Communication and Expectations Before the end of FY26, VOAWW will update contractor communication materials to clearly outline certified payroll requirements, including: • Submission timelines • Required documentation • Consequences for noncompliance • Points of contact for questions or clarifications These expectations will be reinforced during project kick off meetings and throughout the contract period. Centralized Tracking of Certified Payrolls By the end of FY26, VOAWW will implement a centralized tracking log for all certified payroll submissions. This log will document: • Receipt dates • Review dates • Reviewer initials • Any follow up actions taken This will ensure a complete audit trail and consistent monitoring of compliance. These corrective actions will strengthen VOAWW’s internal controls over Wage Rate Requirements, ensure timely receipt and review of certified payrolls, and reduce the risk of noncompliance with federal labor standards. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201512 (2025-004)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Questioned Costs § 200.414

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA...

2025-004 Indirect Cost Rate Application on Federal Invoices We acknowledge BDO’s observation regarding the indirect cost rate applied to federal invoices during the period in which VOAWW transitioned from its approved NICRA rate to the de minimis rate. During this transition, VOAWW applied the NICRA rate of 17.2% while moving to the de minimis rate but did not complete the required true-up to 10% for a three-month period prior to the de minimis rate being increased to 15%. VOAWW has reviewed the circumstances that led to this error and determined that it occurred during an unusual and infrequent set of conditions. Transitions between indirect cost methodologies are rare and increases to the federal de minimis rate are also uncommon. As a result, this specific scenario is unlikely to recur. Nonetheless, VOAWW recognizes the importance of strengthening controls around indirect rate changes to ensure accurate application during any future transitions. To address this finding and strengthen controls over indirect cost rate application, VOAWW will implement the following corrective actions: • Formal Rate Transition Procedures – Before the end of FY26, the Finance Department will develop and document a standardized procedure for transitioning between indirect cost rates, including effective dates, interim rate requirements, required true-ups, and approval checkpoints to ensure accurate application during any future rate changes. • Centralized Indirect Rate Tracking – Before the end of FY26, the Finance Department will maintain a centralized indirect rate schedule that includes approval documentation, effective dates, and any required adjustments. This schedule will be referenced during invoice preparation and review to ensure consistent and accurate rate application across all federal awards. • Contract Kick-Off Meetings and Cross-Department Alignment – Before the end of FY26, Finance, Grants, and Contract Compliance will implement contract kick-off meetings for new awards and significant contract amendments to align on billing requirements, approved indirect cost rates, effective dates, and other critical compliance information and ensure consistent communication across departments. • Documentation of Important Communications – Before the end of FY26, VOAWW will implement guidance for documentation of important communications with funders that have a single audit impact. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201504 (2025-001)

Material Weakness 2025

Hardee County District School Board

FL

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budge...

The District appreciates the opportunity to respond to the audit finding regarding inconsistencies between Title I rank order and the allocation of funds based on low-income student percentages for the 2024-2025 fiscal year. Our review indicates that the variance in allocations resulted from a budget decision to provide additional Title I funding to Bowling Green Elementary to support after-school programming, without fully accounting for per-pupil allocation. Historically, Bowling Green Elementary has served one of the highest concentrations of students from low-income families in the District, and the additional allocation was intended to ensure continuity of extended learning opportunities for students with significant academic need. While this decision was grounded in student need, the District recognizes that the additional funds were not fully reconciled with updated poverty data and required rank-order calculations. The District has demonstrated compliance with rank and serve requirements in prior years; however, to prevent recurrence, we are strengthening our internal controls. Beginning immediately, the District will implement a structured monthly review of Title I school allocations involving the Title I Program Specialist, the Finance Director, and the Deputy Superintendent to ensure that the 2025-2026 allocations align with current poverty data and PSES calculations. Additionally, the District will seek guidance from the Florida Department of Education Title I Office to confirm that our procedures fully meet all regulatory expectations. The District is confident that these corrective actions will ensure full compliance in 2025-2026 moving forward and will strengthen the integrity of our allocation processes.

View Audit 396085

Finding 1201466 (2025-001)

Material Weakness 2025

Scripps Health and Affiliates

CA

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

Corrective Action Plan Corrective Action Plan – Uniform Guidance Audit Finding Organization: Scripps Health and Affiliates Federal Agency: U.S. Department of Homeland Security Pass-Through Agency: California Governor’s Office of Emergency Services UEI Number: JJRCL53EXL36 Audit Period: Year Ended Se...

Corrective Action Plan Corrective Action Plan – Uniform Guidance Audit Finding Organization: Scripps Health and Affiliates Federal Agency: U.S. Department of Homeland Security Pass-Through Agency: California Governor’s Office of Emergency Services UEI Number: JJRCL53EXL36 Audit Period: Year Ended September 30, 2025 Finding Reference Number: 2025-001 Federal Program: COVID-19 – Disaster Grants – Public Assistance (Presidentially Declared Disasters) Assistance Listing Number: 97.036 Finding Summary: The organization did not employ an adequate internal control review of payroll expenditures to support activities allowed or unallowed and allowable costs/cost principles related to payroll expenditures reimbursed for the project worksheet. Corrective Action Plan: Additional internal controls to ensure payroll expenditures are reviewed were implemented in late fiscal year 2022 by adopting a new approach to ensure compliant timekeeping. The new approach includes the following steps: revised the timekeeping policy to clarify employee and manager responsibilities, modified “failure to comply” provisions, deployed educational programs for both management and staff, reviewed/improved Kronos and UKG Pro Time and Attendance system automated notifications, and training resources have been available to management and staff via our Scripps intranet site. Leadership monitors policy compliance by individual employee and managers via systemwide reporting on a biweekly basis. Responsible Officials & Contact Person: Brett Tande, Executive Vice President & Chief Financial Officer Scripps Health and Affiliates Expected Completion Date: Completed in fiscal year 2022. As the expenditures in the project worksheet were incurred from the beginning of the COVID-19 pandemic, the corrective action plan put in place during 2022 could not previously remediate the project; however, all payroll expenditures incurred after the end of fiscal year 2022 have these corrective actions in place.

View Audit 396036

Finding 1201438 (2025-003)

Material Weakness 2025

County of Orange, California

CA

Subrecipient Monitoring Material Weakness Reporting

Program: Community Development Block Grant Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: B-24-UC-06-0504 and 2025; B-20-UW-06-0504 and 2021 Compliance Requirements: Reporting Type of Finding: Material Weaknes...

Program: Community Development Block Grant Federal Financial Assistance Listing Number: 14.218 Federal Grantor: U.S. Department of Housing and Urban Development Award No. and Year: B-24-UC-06-0504 and 2025; B-20-UW-06-0504 and 2021 Compliance Requirements: Reporting Type of Finding: Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Criteria: CFR Appendix A to Part 170I(a)(2), Reporting Requirements, states the recipient must report each subaward to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) no later than the end of the month following the month in which the subaward was issued. Condition: During our testing of the County’s compliance with reporting requirements, we noted the County did not submit the required subaward data to FSRS. Cause: The department was unaware of this compliance requirement. Effect: Reports were not submitted to FSRS in accordance with the reporting requirements per Appendix A to Part 170I(a)(2). Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling : We identified that the FFATA reporting was not completed as required by 2 CFR Part 170 for the following instances: (Refer to Chart/Table to Finding 2025-003) Repeat Finding from Prior Years: No. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR Appendix A to Part 170I(a)(2). Management Response and Corrective Action Plan: 1. Person Responsible: Francisco Padilla, Community Development Analyst 2. Corrective action plan: Concur. We will adhere to our policies and procedures to ensure reports are submitted to FSRS in accordance with 2 CFR Appendix A to Part 170I(a)(2). 3. Anticipated Implementation date: April 30, 2026

View Audit 395982

Finding 1201435 (2025-009)

Material Weakness 2025

County of Orange, California

CA

Subrecipient Monitoring § 200.332

Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Pass-Through Entity: California Governor’s Office of Emergency Services Award No. and Year: Multiple Compliance Requirements: Subrecipient Monitoring Typ...

Program: Homeland Security Grant Program Federal Financial Assistance Listing Number: 97.067 Federal Grantor: U.S. Department of Homeland Security Pass-Through Entity: California Governor’s Office of Emergency Services Award No. and Year: Multiple Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: Title 2 of the U.S. Code of Federal Regulations (CFR), Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.332, requires that pass-through entities: • Evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. • Verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. • Verify whether the subrecipient is suspended, debarred, or otherwise excluded before entering into a covered transaction. Condition: For two (2) out of two (2) subrecipients selected for testing, the subrecipient risk assessments were not performed by the department and the subrecipient was not checked for suspension or debarment prior to entering into the agreement. For one (1) out of two (2) subrecipients selected for testing, evidence could not be provided to verify the County reviewed the subrecipient’s single audit report to ensure timely corrective action was taken on audit findings, as applicable. Cause: Internal controls were not in place to ensure compliance with subrecipient monitoring requirements. Effect: Ineffective controls over this area of compliance could result in noncompliance occurring for a subrecipient and not being detected. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sample of two (2) subrecipients out of a population of two (2) was selected for testing. Repeat Finding from Prior Years: No. Recommendation: We recommend the department enhance internal controls to ensure compliance with subrecipient monitoring requirements. Management Response and Corrective Action Plan: 1. Person Responsible: Monique Vansuch, Fiscal Administrator 2. Corrective action plan: The Sheriff-Coroner Department will complete and document risk assessments, suspension/debarment status and verify subrecipient’s single audit report is reviewed and corrective actions are implemented prior to subaward issuance. 3. Anticipated Implementation date: June 30, 2026

View Audit 395982

Finding 1201421 (2025-006)

Material Weakness 2025

County of Orange, California

CA

Subrecipient Monitoring § 200.332

Program: Block Grants for Community Mental Health Services Federal Financial Assistance Listing Number: 93.958 Federal Grantor: U.S. Department of Health and Human Services Pass Through: California Department of Health Care Services Award No. and Year: 68-0317191 and 2024 Compliance Requirements: Su...

Program: Block Grants for Community Mental Health Services Federal Financial Assistance Listing Number: 93.958 Federal Grantor: U.S. Department of Health and Human Services Pass Through: California Department of Health Care Services Award No. and Year: 68-0317191 and 2024 Compliance Requirements: Subrecipient Monitoring Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: In accordance with Title 2 U.S. Code of Federal Regulations (CFR) 200.332, pass-through entities must comply with the following: • 2 CFR Part 200.332(a), Requirements for Pass-Through Entities, states that all passthrough entities must ensure that every subaward is clearly identified to the subrecipient as a subaward and includes certain information as well as all the requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations, and the terms and conditions of the award. Condition: The following information was not provided at the time of the subaward for three (3) out of five (5) subawards selected for testing from the HCA’s Block Grants for Community Mental Health Services program • Federal Award Identification Number (FAIN) • Federal award date of award to recipient by the Federal Agency • Identification of whether or not the award is R&D • Indirect cost rate for the Federal award (including if the de-minimus rate is charged) Cause: The HCA’s procedures did not consistently ensure that the required award information and applicable requirements were communicated to the subrecipients at the time of subaward. Effect: The County’s control policies were not consistently followed which require compliance with the Subrecipient Monitoring requirements as found in 2 CFR 200.332. Questioned Costs: No questioned costs were identified as a result of our audit procedures. Context/Sampling: A nonstatistical sample of three (3) of five (5) subrecipients were sampled. The condition noted above was identified during our procedures related to subrecipient monitoring. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County adhere to their policies and procedures in accordance with 2 CFR 200.332 to ensure compliance with subrecipient monitoring requirements. Management Response and Corrective Action Plan: 1. Person Responsible: Brittany Davis, HCA Procurement & Contract Services Division Manager 2. Corrective action plan: HCA will coordinate with internal stakeholders on the review of all subrecipient contracts and applicable funding source requirements to ensure that subaward criteria and subrecipient responsibilities are included. Amendments or subrecipient notification letters will be issued, as needed, to notify contractors of subrecipient responsibilities. 3. Anticipated Implementation date: June 30, 2026

View Audit 395982

Finding 1201404 (2025-004)

Material Weakness 2025

City of Perris

CA

Subrecipient Monitoring Questioned Costs Reporting

The City has commenced the preparation of the FFATA report and is working toward full compliance with reporting requirements. The corrective action is expected to be fully implemented by Fiscal Year 2025/2026. The contact persons for this corrective action are Sabrina Chavez, Director of Public Serv...

The City has commenced the preparation of the FFATA report and is working toward full compliance with reporting requirements. The corrective action is expected to be fully implemented by Fiscal Year 2025/2026. The contact persons for this corrective action are Sabrina Chavez, Director of Public Services, and Martin E. Martinez, Principal Management Analyst, of the City of Perris.

View Audit 395981

Finding 1201403 (2025-004)

Material Weakness 2025

State of New Mexico Workforce Solutions Department

NM

Subrecipient Monitoring § 200.332 § 200.521

Recommendation We recommend that the Department continue to monitor its monitoring activities over subrecipients, to ensure that they are being performed timely. Management Response Corrective Action The Department acknowledges the corrective action related to the completion of required WIOA monitor...

Recommendation We recommend that the Department continue to monitor its monitoring activities over subrecipients, to ensure that they are being performed timely. Management Response Corrective Action The Department acknowledges the corrective action related to the completion of required WIOA monitoring activities and has taken concrete steps to bring monitoring into compliance. NMDWS has scheduled onsite monitoring reviews and issued formal notification letters to all four subrecipients, as outlined below: • Southwestern Local Workforce Development Board: Notification letter sent January 26, 2026; onsite monitoring scheduled for March 9–13, 2026 • Northern Area Local Workforce Development Board: Notification letter sent January 26, 2026; onsite monitoring scheduled for April 20–24, 2026 • Workforce Connection of Central New Mexico: Notification letter sent January 5, 2026; onsite monitoring scheduled for May 4–11, 2026 • Eastern Area Workforce Development Board: Notification letter sent January 26, 2026; onsite monitoring scheduled for May 18–22, 2026 The Department has completed Program Years 2022, 2023 and 2024. In addition, the Department has also completed a Program Year 2024 risk assessment, which is now incorporated into the grant agreements. The WIOA Monitoring Unit will continue to utilize the Department’s Grant Risk Assessment tool for future grant agreements to ensure consistent and risk-informed monitoring. Finally, the WIOA Monitoring Unit has drafted a comprehensive subrecipient monitoring policy. This policy will establish clear monitoring standards for subrecipients and pass-through entities under WIOA Title I-B and related discretionary awards, including monitoring frequency, scope, and requirements for monitoring letters and reports. These actions are intended to address the identified deficiencies and strengthen the Department’s monitoring framework moving forward. Due Date of Completion: June 30, 2026 Responsible Party(ies): Administrative Services Division Director

View Audit 395973

Finding 1201300 (2025-008)

Material Weakness 2025

State of Hawaii, Department of Accounting and General Services

HI

Subrecipient Monitoring § 200.332 § 200.414

Finding No. 2025-008 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that State did not communicate the following award information required under 2 CFR 200.332: • Subrecipient...

Finding No. 2025-008 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that State did not communicate the following award information required under 2 CFR 200.332: • Subrecipient’s unique entity identifier; • Federal Award Date; • Identification of whether the Federal award is for research and development; and • Indirect cost rate for the Federal award (including if the de minimis rate is used in accordance with 200.414). Corrective Action Plan DBEDT OPSD will strengthen internal controls over subaward identification and monitoring subrecipients to ensure that subrecipient monitoring requirements are met. The Program will communicate with the subrecipient to record their UEI. Program will supply the subrecipient with the date of the federal award, the indirect cost rate for the Federal award per CFR 200.414, and information on whether the award is for research and development. The Program will continue to supply subrecipient with Period of Performance Start and End Date, Budget Period Start and End Date, and the Assistance Listing number. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026

View Audit 395953

Finding 1201299 (2025-007)

Material Weakness 2025

State of Hawaii, Department of Accounting and General Services

HI

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

Finding No. 2025-007 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that the State did not submit FFATA reports for most of the active grant agreements open for the program. C...

Finding No. 2025-007 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that the State did not submit FFATA reports for most of the active grant agreements open for the program. Corrective Action Plan DBEDT OPSD will strengthen internal controls over subaward identification and reporting. This will include hiring and training staff to support federal grant administration and management-level review of all subawards to ensure FFATA reporting is complete and timely. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026

View Audit 395953

Finding 1201298 (2025-006)

Material Weakness 2025

State of Hawaii, Department of Accounting and General Services

HI

Cash Management Subrecipient Monitoring

Finding No. 2025-006 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that for various samples, the time between drawdown and disbursement of federal funds was up to 266 days el...

Finding No. 2025-006 ALN No. 11.419 Program Title: Hawaii Coastal Zone Management Program Grant Award No.: NA22NOS4190022 NA23NOS4190139 NA24NOSX419C0023 NA22NOS4190065 Condition Accuity noted that for various samples, the time between drawdown and disbursement of federal funds was up to 266 days elapsed. Indicating that cash management controls were not operating to minimize the time between transfer and disbursement. Corrective Action Plan OPSD DBEDT will ensure that program personnel are familiar with all federal requirements, including ensuring that funds are disbursed timely. Person Responsible Mary Alice Evans, Director of Office of Planning and Sustainable Development Anticipated Date of Completion April 1, 2026

View Audit 395953

Finding 1201297 (2025-005)

Material Weakness 2025

State of Hawaii, Department of Accounting and General Services

HI

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles

Finding No. 2025-005 ALN No. 10.179 Program Title: Micro-Grants Food Security Program Grant Award No.: AM200100XXXG132 21MGFSPHI1003-00 AM22MGFSPHI1007-04 23MGFSPHI1011-00 24MGFSPHI1016-00 Condition An elapsed time of 583 days between the drawdown and disbursement date of funds for the program and t...

Finding No. 2025-005 ALN No. 10.179 Program Title: Micro-Grants Food Security Program Grant Award No.: AM200100XXXG132 21MGFSPHI1003-00 AM22MGFSPHI1007-04 23MGFSPHI1011-00 24MGFSPHI1016-00 Condition An elapsed time of 583 days between the drawdown and disbursement date of funds for the program and that the check date of 01/24/2025 occurred after the grant period expiration of 09/29/2024. Indicating that cash management controls were not operating to minimize time between transfer and disbursement and that the period of performance was unauthorized to be extended past the budget date. Corrective Action Plan Concur. The Hawaii Department of Agriculture and Biosecurity (DAB) will change administrative procedures for drawdown and disbursement of federal funds under the Micro-Grants Food Security Program. DAB will process the grant contracts and payments in batches of about 100 micro-grants per month, and federal drawdown will not occur until about a batch of 100 contracts have been executed. Additional staff hired for grant processing will expedite the payment process to ensure conformity with the 25-day disbursement timeline. Person Responsible Brendan Akamu, Market Development Branch Manager Anticipated Date of Completion Corrective action plan will be implemented in April 2026.

View Audit 395953

Finding 1201295 (2025-101)

Material Weakness 2025

Navajo County

AZ

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

Earmarking (Material Weakness in Internal Control and Noncompliance) Cluster name: WIOA Cluster Assistance Listings number and program name: 17.258 WIOA Adult Program 17.259 WIOA Youth Program 17.278 WIOA Dislocated Worker Formula Grants Recommendation: The County should strengthen WIOA Youth Activi...

Earmarking (Material Weakness in Internal Control and Noncompliance) Cluster name: WIOA Cluster Assistance Listings number and program name: 17.258 WIOA Adult Program 17.259 WIOA Youth Program 17.278 WIOA Dislocated Worker Formula Grants Recommendation: The County should strengthen WIOA Youth Activities program policies and procedures to ensure no less than the required 20 percent of its monies is spent to provide in-school and out-of-school youth with paid and unpaid work experience, retain qualified in-school and out-of-school youth, and consistently monitor the County's and subrecipients spending throughout the award period. Contact Person(s): Adam Garrard, WIOA Executive Director Anticipated completion date: June 30, 2026 County Discussion: Concur: The County will take corrective actions to strengthen WIOA Youth program policies, procedures, and oversight to ensure compliance with the 20 percent work experience requirement. This includes ongoing monitoring and oversight of sub-recipient expenditures, addressing barriers to work experience opportunities, and increasing engagement and enrollment of both in-school and out-of-school youth. These activities will include the following: 1) include local school counselors and administrators to support recruitment of in-school youth; 2) engage community partners with access to out-of-school youth; and 3) support outreach, enrollment, and retention strategies to attract eligible youth participants.

View Audit 395952

Finding 1201280 (2025-001)

Material Weakness 2025

Community Service Society of New York

NY

Subrecipient Monitoring Reporting Significant Deficiency

Community Service Society (the Society) requires its subrecipients to submit their financial and progress program reports fifteen days after the end of the reporting period. This is done so that the Society can review the underlying documentation in those reports to ensure that proper payments are m...

Community Service Society (the Society) requires its subrecipients to submit their financial and progress program reports fifteen days after the end of the reporting period. This is done so that the Society can review the underlying documentation in those reports to ensure that proper payments are made to the subrecipients and, in turn, proper and timely reports are filed by the Society with the State of New York. There are instances when, because of delays in receipt of information from the subrecipients, or information from the subrecipients needs to be revised, reports are submitted late to the State of New York. The Society notifies the State of New York when reports will be submitted late. In addition, the Society is working with its subrecipients to improve their reporting procedures, as well as the timeliness and accuracy of their reports. This will result in the Society improving the timeliness of its reporting to the State of New York.

View Audit 395939

Finding 1201277 (2025-001)

Material Weakness 2025

Columbia University

NY

Subrecipient Monitoring

The University agrees with this finding and acknowledges that the monitoring process to ensure all required FFATA reporting is completed in a timely manner can be strengthened. While responsible staff continued to track agreements subject to reporting, changes in staffing overseeing this work result...

The University agrees with this finding and acknowledges that the monitoring process to ensure all required FFATA reporting is completed in a timely manner can be strengthened. While responsible staff continued to track agreements subject to reporting, changes in staffing overseeing this work resulted in a lapse in monitoring the completion of required filings in FY2025. The identified filings have now been completed. In response, the University has retrained supervisors and staff to reinforce reporting requirements, processes, and the importance of timely compliance. Additionally, the University is developing an automated solution to facilitate this reporting monthly, which will improve oversight and timeliness. The automated solution is planned to be in place prior to June 30, 2026. Responsible person contact name: William Berger, AVP Sponsored Projects Administration (SPA), wb2174@cumc.columbia.edu, or (212)-305-9571.

View Audit 395936

Finding 1201267 (2025-003)

Material Weakness 2025

Town of Foxborough, Massachusetts

MA

Cash Management Subrecipient Monitoring Eligibility

Assistance to Firefighters Grant Assistance Listing Number 97.044 Recommendation: We recommend that the Town establish and implement written procedures requiring the preparation, review, and retention of all federal grant reimbursement requests. Explanation of disagreement with audit finding: Mana...

Assistance to Firefighters Grant Assistance Listing Number 97.044 Recommendation: We recommend that the Town establish and implement written procedures requiring the preparation, review, and retention of all federal grant reimbursement requests. Explanation of disagreement with audit finding: Management agrees with the finding. Action taken in response to finding: The Town agrees with this recommendation and has updated its grant policies and procedures accordingly. Written procedures are now in place requiring the preparation, review, and retention of all federal grant reimbursement requests. Going forward, the Finance Department will review all requests, and approval from the Town Manager will be required prior to submission. This is not expected to be an issue going forward. Name(s) of the contact person(s) responsible for corrective action: Marie Almodovar, Finance Director Planned completion date for corrective action plan: Fiscal Year 2026.

View Audit 395927

Finding 1201264 (2025-005)

Material Weakness 2025

Lindenwood University

MO

Special Tests & Provisions Questioned Costs Student Financial Aid

Corrective Action Plan 2025-005: Management concurs with the finding. The University is revising its procedures to ensure all post-withdrawal disbursement offers are properly issued and documented and will implement additional controls and staff training to ensure future compliance with federal R2T4...

Corrective Action Plan 2025-005: Management concurs with the finding. The University is revising its procedures to ensure all post-withdrawal disbursement offers are properly issued and documented and will implement additional controls and staff training to ensure future compliance with federal R2T4 requirements. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services

View Audit 395921

Finding 1201260 (2025-004)

Material Weakness 2025

Lindenwood University

MO

Special Tests & Provisions Questioned Costs Student Financial Aid

Corrective Action Plan 2025-004: Management concurs with the finding. The University is revising its procedures to ensure timely processing of all required R2T4 returns and is implementing additional internal controls and monitoring steps to ensure compliance with the 45-day return requirement. Comp...

Corrective Action Plan 2025-004: Management concurs with the finding. The University is revising its procedures to ensure timely processing of all required R2T4 returns and is implementing additional internal controls and monitoring steps to ensure compliance with the 45-day return requirement. Completion Date: February 2026 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services

View Audit 395921

Finding 1201251 (2025-001)

Material Weakness 2025

Lindenwood University

MO

Special Tests & Provisions Subrecipient Monitoring Cash Management

Corrective Action Plan 2025-001: Management has made the appropriate updates and communicated the URLs for its contract and cost information to the Department of Education in July 2025 for its contract with BankMobile. Management will monitor the Department of Education’s cash management contract li...

Corrective Action Plan 2025-001: Management has made the appropriate updates and communicated the URLs for its contract and cost information to the Department of Education in July 2025 for its contract with BankMobile. Management will monitor the Department of Education’s cash management contract listing and will ensure that the contract is listed once the Department of Education updates its cash management contracts database as the most recent update to the cash management contracts database published by the Department of Education listed an update date of mid-January 2024. Completion Date: July 2025 Contact Person: Joanne Rozborski, Assistant Vice President, Student Financial Services

View Audit 395921

Finding 1201240 (2025-001)

Material Weakness 2025

Economic Development and Industrial Corporation of Boston

MA

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties

2025-001 Reporting 17.289, Community Project Funding/ Congressionally Directed Spending Responsible Official Devon Wedge, Assistant Controller Plan Detail Management acknowledges that the untimely FFATA reporting resulted from lack of familiarity with reporting requirements for its staff. To address...

2025-001 Reporting 17.289, Community Project Funding/ Congressionally Directed Spending Responsible Official Devon Wedge, Assistant Controller Plan Detail Management acknowledges that the untimely FFATA reporting resulted from lack of familiarity with reporting requirements for its staff. To address this issue and strengthen internal controls, management will implement additional training for its staff, enhance its written procedures and develop a tracking mechanism to establish a tracking log or calendar system to monitor subaward issuance dates and corresponding reporting deadlines. Anticipated Completion Date: April 30, 2026

View Audit 395914

Finding 1201235 (2025-008)

Material Weakness 2025

City of Boston

MA

Subrecipient Monitoring

Homeland Security Grant Program (HSGP) – Assistance Listing No. 97.067 Recommendation: We recommend the Mayor’s Office of Emergency Management review and enhance internal controls and procedures to ensure that required information is included in its subawards. Action taken in response to finding: Th...

Homeland Security Grant Program (HSGP) – Assistance Listing No. 97.067 Recommendation: We recommend the Mayor’s Office of Emergency Management review and enhance internal controls and procedures to ensure that required information is included in its subawards. Action taken in response to finding: The Mayor’s Office of Emergency Preparedness acknowledges the finding and has implemented enhanced internal controls to ensure all required federal award information is included in subaward documentation in accordance with 2 CFR 200.332. Specifically, we are implementing a standardized pre-execution subaward checklist to verify that all required elements such as the Federal Award Identification Number (FAIN) and Federal Award Date are included prior to issuance. Additionally, we are reinforcing internal review procedures to ensure compliance and consistency across all subawards moving forward. Name(s) of the contact person(s) responsible for corrective action: Malik Canty, Director of Administration & Finance Alicia Woodberry, Project Director (UASI) Planned completion date for corrective action plan: March 31, 2026

View Audit 395895

Finding 1201229 (2025-002)

Material Weakness 2025

City of Boston

MA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

Economic Development Cluster - Assistance Listing No. 11.307 Recommendation: We recommend the Mayor’s Office of Workforce Development develop procedures and internal controls to ensure that all required subawards are reported timely and accurately to SAM.gov no later than the end of the month follow...

Economic Development Cluster - Assistance Listing No. 11.307 Recommendation: We recommend the Mayor’s Office of Workforce Development develop procedures and internal controls to ensure that all required subawards are reported timely and accurately to SAM.gov no later than the end of the month following the month of issuance of each subaward. Action taken in response to finding: The City has implemented a more timely FFATA review and submission procedure in FY25/FY26, however due to this award having been transferred from another organization this was not able to be submitted on Sam.gov. The City made multiple attempts to have the award updated in the system but due to this program ending, there was no contact available to remedy this issue. Name(s) of the contact person(s) responsible for corrective action: Colin Musto, Assistant City Auditor Planned completion date for corrective action plan: March 1, 2026

View Audit 395895

Finding 1201166 (2025-002)

Material Weakness 2025

Virginia Housing Development Authority

VA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – PIC Submissions Recommendation: We recommend that the Authority review its Agent’s process for uploading data to the PIC system to ensure each HUD-50058 recertification gets submitted timely and accurately. Explanation of disagr...

Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – PIC Submissions Recommendation: We recommend that the Authority review its Agent’s process for uploading data to the PIC system to ensure each HUD-50058 recertification gets submitted timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Authority is currently evaluating improvements to its data submission and reconciliation processes. This evaluation includes reviewing peer agency approaches to transmission monitoring, data verification, and centralized oversight controls. In addition, Virginia Housing has engaged a third-party consultant to assist with PIC submission oversight, reconciliation, and process refinement. The consultant’s involvement has supported a significant reduction in late and missing submissions and is helping to strengthen internal monitoring practices. Name of the contact person responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: September 30, 2026

View Audit 395856

Finding 1201163 (2025-001)

Material Weakness 2025

Virginia Housing Development Authority

VA

HUD Housing Programs Subrecipient Monitoring Internal Control / Segregation of Duties

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Eligibility Recommendation: We recommend that the Authority review its Agent’s internal controls and policies related to HUD tenant eligibility requirements to ensure that all req...

U.S. DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT Housing Voucher Cluster – Assistance Listing No. 14.871/14.879/14.EHV – Eligibility Recommendation: We recommend that the Authority review its Agent’s internal controls and policies related to HUD tenant eligibility requirements to ensure that all required documentation is obtained and maintained at the time of recertification. We further recommend that the Authority implements uniform documentation standards and requirements across all local housing agencies (LHAs) and agents of the Authority. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Virginia Housing is evaluating enhancements to its quality control framework. This evaluation includes reviewing best practices from peer agencies with strong compliance outcomes and consistent audit performance. Many of these agencies utilize more structured oversight models that provide independent file review functions while maintaining coordination with program operations. Virginia Housing is currently assessing options that may include: - Expanding centralized quality control review functions - Increasing file sampling and review throughout the year - Improving monitoring of HUD-9886 and third-party verification documentation Implementation details will be finalized following this evaluation process and may include structural adjustments, enhanced tools, or expanded oversight protocols. Name of the contact person responsible for corrective action: Yilla Smith, Director, Housing Opportunity Programs and Initiatives Planned completion date for corrective action plan: December 31, 2026

View Audit 395856

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