Corrective Action Plans

Finding 1214559 (2025-004)

Material Weakness 2025

PR

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

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

COMMONWEALTH OF PUERTO RICO MUNICIPALITY OF COAMO Corrective Action Plan For the Fiscal Year Ended June 30, 2025 _____________________________________________________________________________________________________________________ Audit Report: Reports on Compliance and Internal Control in Accordance with Government Auditing Standards and OMB Super Circular Uniform Guidance Audit Period: July 1, 2024 – June 30, 2025 Fiscal Year: 2024-2025 Principal Executive: Hon. Juan C. García Padilla, Mayor Contact Person: Mrs. Miraisa David Esparra, Finance and Budget Director Phone: (787) 825-1150 Original Finding Number: 2025-004 Statement of Concurrence or Non concurrence: We concur with the finding. Corrective Action: We acknowledge and accept the observation noted during the Single Audit regarding the frequency of monitoring visits and the completion of monthly evaluations for participants in the Housekeeper Program. We understand that, according to the program’s activity procedures guide, staff are expected to conduct at least two visits per month to each participant’s housing unit and to complete a monthly evaluation of the services provided. However, we would like to provide additional context regarding the operational realities of the program. The assigned Program Coordinator is responsible for overseeing approximately 20 program participants, which would require a minimum of 40 home visits per month to fully comply with the two-visits-per-month requirement. Considering that there are, on average, 20 working days per month, this expectation represents a significant workload within the available time. In addition to conducting home visits and preparing the corresponding reports, the coordinator performs a wide range of essential duties. These include supervising and addressing situations involving approximately 20 housekeeper aides, coordinating services and referrals with external agencies to meet participants’ social needs, organizing meetings, managing administrative responsibilities such as procurement of supplies used by the aides, and participating in program-related administrative meetings. We can attest that the coordinator consistently demonstrates a high level of commitment and diligence in fulfilling these responsibilities. Priority is given to participants with more complex or urgent needs, and in such cases, visits may occur more than once per month. However, meeting the requirement of two visits per month for every participant presents a significant challenge given the scope of responsibilities assigned. We remain committed to evaluating our processes and identifying opportunities to strengthen compliance while ensuring the continued quality and effectiveness of services provided to program participants. Notwithstanding these challenges, we will continue making every effort to comply with the requirements established in the CDBG guidelines. Implementation Date: March 31, 2027 Responsible Person: Mr. Hector R. Sanjurjo Rodríguez Federal Programs Director

View Audit 401230

Finding 1214511 (2025-005)

Material Weakness 2025

Laurel Public School District No. 7 and 7-70

MT

Eligibility Subrecipient Monitoring

A sample of 28 students receiving targeted Title I services was tested for eligibility compliance. For three students, the district could not provide supporting documentation to verify eligibility. Additionally, discrepancies were noted across multiple District- maintained Title I student listings, ...

A sample of 28 students receiving targeted Title I services was tested for eligibility compliance. For three students, the district could not provide supporting documentation to verify eligibility. Additionally, discrepancies were noted across multiple District- maintained Title I student listings, including inconsistencies and inclusion of students who did not meet established eligibility criteria. Response: In an effort to improve our record retention practices and strengthen internal controls over documentation management, we will implement the following practices and procedures improving our standardized procedures for maintaining and reconciling eligibility records for Title I. Staff training: • Secretary training on the standardized procedures for maintaining Title I eligibility documentation. Each school will have one secretary who will manage the data entry and therefore streamline practices in maintaining our eligibility documentation. • Teacher and administrator training on the standardized procedures for maintaining Title I eligibility documentation. Establishing clarity on which staff member collects the data and can show evidence of eligibility rationale, and then the teacher will communicate the students for record keeping and therefore streamline practices in maintaining our eligibility documentation. Quarterly Checks for accuracy: • Implementation of quarterly checks for eligibility determination to be reviewed at the school level and then verified with the Director overseeing the Title I program. This review will include system-wide documentation and record retention in according to federal requirements. This will ensure accuracy and consistency with data entry, documentation and our ability to correct errors quickly if needed. Systematic Checklist for program oversight: • Development of required evidence collection for Title programs in order to strengthen our internal controls to ensure documentation is complete, accurate, and readily accessible for audit. • Development of eligibility criteria guidance and necessary documentation to be collected at all buildings and communicated through our staff training to ensure documented rationale supporting eligibility.

View Audit 401215

Finding 1214468 (2025-003)

Material Weakness 2025

Meals on Wheels of Middle Georgia, Inc.

GA

Reporting Procurement, Suspension & Debarment Subrecipient Monitoring § 200.502 § 200.510

March 31, 2026 To: Clausell & Associates, P.C. From: Javonna Latimore, Executive Director of Meals on Wheels of Middle Georgia, Inc. COMMENT#2025-001 CONTROLS OVER FINANCIAL STATEMENT PREPARATION SHOULD BE IMPROVED Views of Responsible Officials and Planned Corrective Actions: We concur with this fi...

March 31, 2026 To: Clausell & Associates, P.C. From: Javonna Latimore, Executive Director of Meals on Wheels of Middle Georgia, Inc. COMMENT#2025-001 CONTROLS OVER FINANCIAL STATEMENT PREPARATION SHOULD BE IMPROVED Views of Responsible Officials and Planned Corrective Actions: We concur with this finding. The Organization has contracted with a seasoned outside accounting professional to assure that the financial system is designed to properly report financial activity by funding source and statements are completed and prepared timely. In addition, the Organization has committed to upgrading our accounting system software along with appropriate amendments to the formal accounting policy and procedures manual to cover the proper internal controls for accurately reporting financial activities (expenses) for each grant and making sure that the allocation of expenses is supported by a methodology governed by generally accepted accounting principles. The Organization will maintain a backup copy of all financial data on-site. The accounting process and the software backup process will be completed by July 31, 2026. The Organization is also engaged to have training on common software applications and cybersecurity awareness. Date to be implemented: On-going and completed by July 31, 2026. Persons responsible: Javonna Latimore, CEO, and financial consultant COMMENT#2025-002 POLICIES AND PROCEDURES AND INTERNAL CONTROLS OVER DISBURSEMENTS SHOULD BE IMPROVED Views of Responsible Officials and Planned Corrective Actions: We concur with this finding. The Organization will immediately assign a committee to take the lead in establishing policies and procedures and internal controls over the procurement process. The Organization has engaged a third party to help establish values of in-kind contributions. Date to be implemented: On-going and completed by July 31, 2026. Persons responsible: Javonna Latimore, CEO (contact person) under the direction of the board of directors with the outside consultant. COMMENT#2025-003 INTERNAL CONTROLS OVER FINANCIAL STATEMENT PREPARATION AND COMPLIANCE WITH RELATED PROVISIONS OF GRANTS AND CONTRACTS SHOULD BE IMPROVED. Coronavirus State and Local Fiscal Recovery Funds, Aging Cluster, and Social Services Block Grant-Home Delivered Meals and Community Development Block Grant FALN 14.218, 21.027, 93.045, 93.053 and 93.667 GENERAL Views of Responsible Officials and Planned Corrective Actions: See Comment 2025-001 and 002. Date to be implemented: See Comment 2025-001 and 002. Persons responsible: See Comment 2025-001 and 002.

View Audit 401175

Finding 1214441 (2025-002)

Material Weakness 2025

Michigan Rural Water Association

MI

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Finding – Title 2 CFR Part 200 and the terms of the federal award require recipients to comply with program reporting requirements, including the timely submission of required financial reports. Timely reporting is a key internal control over compliance designed to ensure appropriate monitoring of f...

Finding – Title 2 CFR Part 200 and the terms of the federal award require recipients to comply with program reporting requirements, including the timely submission of required financial reports. Timely reporting is a key internal control over compliance designed to ensure appropriate monitoring of federal expenditures and program activity. Under the Technical Assistance and Training Grants - Circuit Rider Services program, the National Rural Water Association requires recipients to submit monthly financial reports no later than 10 working days after the month following the reported activity. For the period January through May 2025, all required monthly financial reports were submitted timely. However, for the period June through December 2025, all monthly financial reports were submitted after the required deadline, in some cases significantly late. Recommendation – The auditor recommends that management strengthen internal control over compliance by: • Establishing documented procedures and internal deadlines to ensure monthly financial reports are prepared and submitted in accordance with program requirements. • Implementing management-level review and monitoring controls to verify that required reports are submitted timely, particularly during periods of staff transition. • Ensuring that personnel responsible for federal reporting possess the appropriate experience and training related to federal grant compliance requirements. • Developing contingency plans or cross-training procedures to ensure continuity of compliance functions in the event of future personnel turnover. Action to be taken – Documented policies and procedures were left for the succeeding financial manager. The Finance Director who left the Organization was also available as a consultant during the rest of 2025. Help was made available to the new financial personnel through both executive management and the consultant. More in-depth training and screening will be prepared in succession planning by the current Finance Director during the summer of 2026. Emphasis will be given to timeliness and accuracy. New programs are also being screened for payroll and expense reporting, allowing for direct import as opposed to manual entry, allowing for better accuracy and timing of financial reports. The new Standard Operating Procedures will be shared with Executive management so they might step in in the event that there is a gap in the financial management position. Executive management is also evaluating the use of an independent accounting firm in the event of a vacancy in the future. Estimated completion date – December 31, 2026 Responsible person – Jennifer Lewis, CPA, Finance Director

View Audit 401144

Finding 1214438 (2025-002)

Material Weakness 2025

National College Advising Corps

NC

Subrecipient Monitoring Internal Control / Segregation of Duties

Corrective Action Plan – Finding 2025-001. Federal Program: AmeriCorps State and National Service Program. Management will implement written internal controls and procedures to ensure timely FFATA reporting of all required first-tier subawards. A centralized tracking system will be developed to moni...

Corrective Action Plan – Finding 2025-001. Federal Program: AmeriCorps State and National Service Program. Management will implement written internal controls and procedures to ensure timely FFATA reporting of all required first-tier subawards. A centralized tracking system will be developed to monitor subaward obligations and amendments and ensure identification of awards meeting the $30,000 reporting threshold. The Director of Grants Management will be responsible for developing and implementing FFATA tracking procedures and ensuring ongoing compliance with reporting requirements. The Controller will oversee financial reporting integration and ensure proper documentation of subawards within the accounting system. The CFO will provide overall oversight of compliance, approve final procedures, and ensure adequate resources and controls are in place. All overdue FFATA reports in SAM.gov have been submitted on 5/11/26 following issuance of the audit report . Staff training on FFATA requirements will be completed by the Director of Grants Management and the Controller within 90 days of the audit report issuance. Full implementation of updated tracking procedures and internal controls will be completed within 90 days of the audit report date under CFO supervision.

View Audit 401136

Finding 1214436 (2025-001)

Material Weakness 2025

Ensign College

UT

Student Financial Aid Reporting Subrecipient Monitoring

Finding 2025-001 – Untimely Reporting of Disbursement Records Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.063 Award Titles: Federal Pell Grant Program Award Years: 7/2024 – 6/2026 Management agrees with the finding and proposes the foll...

Finding 2025-001 – Untimely Reporting of Disbursement Records Grantor: U.S. Department of Education Program: Student Financial Assistance Cluster Assistance Listing#: 84.063 Award Titles: Federal Pell Grant Program Award Years: 7/2024 – 6/2026 Management agrees with the finding and proposes the following corrective action plan: Corrective Action Plan In order to maintain timely disbursement reporting, senior financial aid staff will be cross-trained by the Financial Aid Manager/Director to perform disbursement originations as a back-up in the event that the Financial Aid Manager/Director is unable to perform the control. Additionally, in order to prevent human error in reporting, financial aid procedures will be updated to include a reconciliation between PeopleSoft and COD every 7–10 days to ensure that all disbursement originations are accurate and that any discrepancies are identified and corrected in a timely manner. Timing In February 2025, the Senior Financial Aid Specialist was cross-trained by the Financial Aid Manager to perform disbursement originations when the primary control owner is unable to complete this control. Going forward, additional training will be provided by the Financial Aid Director as needed to the appropriate financial aid personnel. The new procedure to reconcile between PeopleSoft and COD every 7–10 days was implemented in October 2025. With these changes, there are now three employees trained to reconcile and perform disbursement originations to ensure the timeliness of disbursement reporting.

View Audit 401131

Finding 1214434 (2025-001)

Material Weakness 2025

County of Mariposa

CA

Reporting Subrecipient Monitoring

2025-001 Highway Planning and Constrution; Grants to States for Medicaid (Material Weakness); We recommend that the County Departments provide the County Auditor with accurate federal expenditures information prior to the beginning of audit fieldwork.; Management's Response: The County concurs with ...

2025-001 Highway Planning and Constrution; Grants to States for Medicaid (Material Weakness); We recommend that the County Departments provide the County Auditor with accurate federal expenditures information prior to the beginning of audit fieldwork.; Management's Response: The County concurs with the finding.; Responsible Individual: Luis Mercado, Auditor; Corrective Action Plan: The Auditor's Office will work with County departments to ensure federal expenditure information is accurate; Anticipated Completion Date: Fiscal Year 2025-2026

View Audit 401123

Finding 1214346 (2025-002)

Material Weakness 2025

Operation A.b.l.e. of Greater Boston, Inc.

MA

Subrecipient Monitoring

Corrective Action Plan Condition: Subrecipient monitoring procedures for ALN 17.235 were not followed, resulting in a duplicate payment and inadequate oversight. Cause: Significant turnover in accounting staff and lack of continuity in subrecipient monitoring controls. Effect: Duplicate payment was ...

Corrective Action Plan Condition: Subrecipient monitoring procedures for ALN 17.235 were not followed, resulting in a duplicate payment and inadequate oversight. Cause: Significant turnover in accounting staff and lack of continuity in subrecipient monitoring controls. Effect: Duplicate payment was made and required federal monitoring controls were not followed. Corrective Actions Taken or to be Taken:  Conduct a complete file review of the subrecipient, including all invoices, monitoring records, and communications.  Recovered the duplicate payment and coordinated resolution with the sub award agency.  Prepare a formal Subrecipient Close-Out Certification documenting deliverables and financial reconciliation. Timeline for Completion: All subrecipient corrective actions will be completed before complete liquidation of the Organization. Responsible Party: Liquidation Board Officer / Grant Close-Out Administrator

View Audit 401019

Finding 1214224 (2025-002)

Material Weakness 2025

Community Housing Iii, Inc. Fir Grove Apartments

OR

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures a...

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that move out inspections are performed timely, security deposits are returned timely and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to return security deposits in a timely manner but was delayed in issuing the security deposit refund for this unit due to staffing issues. In 2026 property management will be outsourced to a third-party management company to address any outstanding compliance issues.

View Audit 400934

Finding 1214222 (2025-001)

Material Weakness 2025

Community Housing Iii, Inc. Fir Grove Apartments

OR

Eligibility HUD Housing Programs Subrecipient Monitoring

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures a...

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that EIVs and recertifications are performed timely, inspections are completed, waitlists are being completed and followed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to complete certifications in a timely manner but due to staffing shortages at the property continued to have issues with timely completion of income certifications in 2025. In 2026 property management will be outsourced to a third-party management company to address outstanding compliance issues.

View Audit 400934

Finding 1214220 (2025-003)

Material Weakness 2025

Community Housing Ii, Inc. the Maples II Apartments

OR

Eligibility HUD Housing Programs Special Tests & Provisions

Federal Award Findings and Questioned Costs Item 2025-003 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor com...

Federal Award Findings and Questioned Costs Item 2025-003 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that the determination of tenant eligibility and the maintenance of lease files are in accordance with guidelines specified by HUD. Action Taken: REACH has policies in place to complete move in inspections but due to tenant noncompliance and staffing issues this inspection was missed. Management scheduled training with staff in March 2026.

View Audit 400933

Finding 1214218 (2025-002)

Material Weakness 2025

Community Housing Ii, Inc. the Maples II Apartments

OR

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor com...

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that move out inspections are performed timely, security deposits are returned timely and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to return security deposits in a timely manner but was slightly delayed in issuing the security deposit refund for this unit. Management reviewed with the teams to ensure rent refunds would be processed within 30 days.

View Audit 400933

Finding 1214216 (2025-001)

Material Weakness 2025

Community Housing Ii, Inc. the Maples II Apartments

OR

Eligibility HUD Housing Programs Subrecipient Monitoring

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor com...

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that EIVs are performed timely, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to complete EIVs and recertifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2025. In 2026 property management will be outsourced to third party management company to address outstanding compliance issues.

View Audit 400933

Finding 1214214 (2025-002)

Material Weakness 2025

Powell Boulevard Apartments, Inc.

OR

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities Program Federal Assistance Listing Number: 14.181 Recommendation: Management should review the HUD...

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities Program Federal Assistance Listing Number: 14.181 Recommendation: Management should review the HUD-52670 and HUD-52670-A every month to ensure that it contains the correct tenants and amounts requested. Action Taken: REACH has policies in place to ensure that HAP funds received are only for current tenants. Due to staffing issues there was a delay in updating the HAP contract. All excess funds received will be returned to HUD.

View Audit 400931

Finding 1214212 (2025-001)

Material Weakness 2025

Powell Boulevard Apartments, Inc.

OR

Eligibility HUD Housing Programs Subrecipient Monitoring

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities Program Federal Assistance Listing Number: 14.181 Recommendation: Management should establish proc...

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for Persons with Disabilities Program Federal Assistance Listing Number: 14.181 Recommendation: Management should establish procedures and monitor compliance with those procedures to insure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to complete certifications and EIVs in a timely manner but due to staffing shortages at the property continued to have issues with timely completion of income certifications in 2025. In 2026 property management will be outsourced to a third party management company to address outstanding compliance issues.

View Audit 400931

Finding 1214206 (2025-002)

Material Weakness 2025

Community Housing, Inc.

OR

Special Tests & Provisions Subrecipient Monitoring HUD Housing Programs

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should address all deficienci...

Federal Award Findings and Questioned Costs Item 2025-002 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should address all deficiencies identified in the NSPIRE Physical Inspection in a timely manner to ensure compliance with HUD regulations. Action Taken: REACH has policies in place to address deficiencies identified in the NSPIRE Physical Inspections but due to staffing shortages was having issues addressing them in a timely manner. REACH has cleared all deficiencies and submitted all requested materials to HUD and is awaiting the close-out confirmation letter.

View Audit 400927

Finding 1214204 (2025-001)

Material Weakness 2025

Community Housing, Inc.

OR

Eligibility HUD Housing Programs Subrecipient Monitoring

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures a...

Federal Award Findings and Questioned Costs Item 2025-001 Name of Federal Agency: U.S. Department of Housing and Urban Development Federal Program Name: Supportive Housing for the Elderly (Section 202) Federal Assistance Listing Number: 14.157 Recommendation: Management should establish procedures and monitor compliance with those procedures to ensure that recertifications are performed timely and signed, tenant eligibility is correctly determined and that tenant lease files are properly maintained in accordance with the requirements of HUD Handbook 4350.3, Occupancy Requirements of Subsidized Multifamily Housing Programs. Action Taken: REACH has policies in place to complete EIVs and recertifications in a timely manner but due to staffing shortages and tenant noncompliance issues the property continued to have issues with timely completion of income certifications in 2025. In 2026 property management will be outsourced to third party management company to address outstanding compliance issues.

View Audit 400927

Finding 1214172 (2025-036)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

2025-036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) 97.036 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should review and enhance its procedures and internal controls to ensure that ...

2025-036 Disaster Grants – Public Assistance (Presidentially Declared Disasters) 97.036 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should review and enhance its 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: MEMA has assigned entering roles and review/approval roles to several employees to ensure our ability to meet MEMA’s FFATA reporting requirements. Grants Units will not forward any contract, amendment, settlement agreement to CFO for signature without confirmation that a properly completed/signed FFATA form has been received from subrecipient. Once contract/amendment/settlement agreement has been signed by CFO, grant program staff will save FFATA form in SharePoint FFATA folder, within the month/year of obligation (signed by MEMA). Grants Unit will have at least one position, and Fiscal will have at least one position assigned to the role of FFATA Data Entry. Assigned FFATA Data entry personnel will review the FFATA SharePoint folders for any recent FFATA forms. This review should be done weekly but no later than every other week. All new FFATA forms will be entered into SAM.gov within ten (10) business days of subcontractor/subrecipient award obligation (date contract/amendment is signed by MEMA’s CFO). Grants Unit will have at least one position, and Fiscal will have at least one position assigned to the role of FFATA Data reviewer/approval. FFATA Data reviewers/approvals will be notified by FFATA Data entry personnel when new FFATA forms have been entered. Reviews/Approval will have ten (10) business days to review the new forms and either approval or reach back to the Data Entry personnel for clarification/adjustments if needed. Name(s) of the contact person(s) responsible for corrective action: Shannon Norton, Chief Fiscal Officer Planned completion date for corrective action plan: End of the Federal Fiscal Year 9/30/2025

View Audit 400886

Finding 1214170 (2025-035)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Subrecipient Monitoring § 200.303 § 200.332

2025-035 Opioid STR 93.788 Recommendation: We recommend the Department complete its corrective action plan from the prior year. The Department should verify that its internal controls and procedures are sufficient to ensure subrecipient monitoring is performed in compliance with the requirements of ...

2025-035 Opioid STR 93.788 Recommendation: We recommend the Department complete its corrective action plan from the prior year. The Department should verify that its internal controls and procedures are sufficient to ensure subrecipient monitoring is performed in compliance with the requirements of the federal program and that all required information is included in subaward agreements. Action taken in response to finding: The Department will implement a procedure to verify annually each city and town subrecipient meets the Single Audit threshold, obtain the corresponding audit reports from directly from the Federal Audit Clearinghouse (fac.gov), and document. Additionally, a monitoring checklist and staff training will be updated to reinforce these requirements and ensure ongoing compliance. The Department implemented the FAIN number on 9/20/2025, amendments and new contracts after this date show this number. Name(s) of the contact person(s) responsible for corrective action: Matt Courchene, Chief Financial Officer Planned completion date for corrective action plan: 9/30/2026

View Audit 400886

Finding 1214158 (2025-030)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

2025-030 CCDF Cluster 93.575, 93.596 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. We recommend the Department develop procedures and internal controls to ensure that all required subawards are reported timely and accurately no...

2025-030 CCDF Cluster 93.575, 93.596 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. We recommend the Department develop procedures and internal controls to ensure that all required subawards are reported timely and accurately no later than the end of the month following the month of issuance of each subaward. Action taken in response to finding: Over the next year, EEC will revise its written agreements with subrecipients to strengthen internal controls and support program integrity within the Child Care Financial Assistance (CCFA) program. These updates will ensure that agreements clearly reflect state and federal requirements related to CCFA program administration. As part of this effort, EEC will incorporate clearly defined subrecipient key performance indicators (KPIs) and indicators of success, a defined cadence for programmatic coordination meetings, and standardized monitoring checklists to assess adherence to program requirements, including applicable federal requirements. These updates will support clearer expectations for subrecipients administering services and strengthen EEC’s oversight of program implementation. Together, these efforts will promote program integrity, consistency in program administration, and greater accountability across all entities supporting CCFA operations. Name(s) of the contact person(s) responsible for corrective action: Tyreese Nicolas, Deputy Commissioner of Family Access and Engagement Planned completion date for corrective action plan: December 31, 2027

View Audit 400886

Finding 1214155 (2025-029)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Special Tests & Provisions Subrecipient Monitoring Eligibility

2025-029 CCDF Cluster 93.575, 93.596 Recommendation: We recommend the Department fully implement procedures and internal controls regarding written agreements as part of Program Integrity and Accountability. It should ensure that it fulfills the eight identified requirements including ensuring that ...

2025-029 CCDF Cluster 93.575, 93.596 Recommendation: We recommend the Department fully implement procedures and internal controls regarding written agreements as part of Program Integrity and Accountability. It should ensure that it fulfills the eight identified requirements including ensuring that the program complies with the approved Plan and all Federal requirements, monitoring programs and services, and ensuring that all State and local or non-governmental agencies through which the State administers the program, including agencies and contractors that determine individual eligibility, operate according to the rules established for the program. Action taken in response to finding: The department is putting FFATA reporting procedures in place for all current contracts. Fiscal leadership meets regularly to review and refine federal reporting processes, including FFATA. The fiscal team is also providing FFATA specific training to staff, which will cover the purpose of FFATA reporting, required subrecipient data, and deadlines for collecting and submitting information. Name(s) of the contact person(s) responsible for corrective action: Eric Hansson, CFO Planned completion date for corrective action plan: September 30, 2026

View Audit 400886

Finding 1214150 (2025-027)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Subrecipient Monitoring § 200.303 § 200.332

2025-027 Epidemiology and Laboratory Capacity for Infectious Diseases 93.323 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. We recommend the Department review and enhance its internal controls and procedures to ensure subrecipie...

2025-027 Epidemiology and Laboratory Capacity for Infectious Diseases 93.323 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. We recommend the Department review and enhance its internal controls and procedures to ensure subrecipient monitoring is performed in compliance with the requirements of the federal program. The Department should review and enhance internal controls and procedures to ensure that it includes all required information in the subaward agreements. Action taken in response to finding: The Department will implement a procedure to verify annually each city and town subrecipient meets the Single Audit threshold, obtain the corresponding audit reports from directly from the Federal Audit Clearinghouse (fac.gov), and document. Additionally, a monitoring checklist and staff training will be updated to reinforce these requirements and ensure ongoing compliance. The Department implemented the FAIN number on 9/20/2025, amendments and new contracts after this date show this number. Name(s) of the contact person(s) responsible for corrective action: Matt Courchene, Chief Financial Officer Planned completion date for corrective action plan: 9/30/2026

View Audit 400886

Finding 1214148 (2025-026)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

2025-026 Epidemiology and Laboratory Capacity for Infectious Diseases 93.323 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior audit. It should establish procedures and internal controls to ensure that all required subawards are reported...

2025-026 Epidemiology and Laboratory Capacity for Infectious Diseases 93.323 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior audit. It should establish 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 Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting May 1, 2026 a process to review obligations for subawards under Epidemiology and Laboratory Capacity for Infectious Diseases COVID-19 – Epidemiology and Laboratory Capacity for Infectious Diseases - Assistance Listing No. 93.323, to identify subawards that fall under the rules set forth by Federal Funding Accountability and Transparency Act (FFATA) and report the appropriate obligations to FSRS according to the above-mentioned recommendations Name(s) of the contact person(s) responsible for corrective action: Cheryl Bernard-Dort, Director of Administration and Finance, BIDLS Planned completion date for corrective action plan: 7/31/2026

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Finding 1214146 (2025-025)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

2025-025 Immunization Cooperative Agreements 93.268 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior audit. It should establish procedures and internal controls to ensure that all required subawards are reported timely and accurately to...

2025-025 Immunization Cooperative Agreements 93.268 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior audit. It should establish 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 Bureau of Infectious Disease and Laboratory Sciences (BIDLS) will put in place starting May 1, 2026 a process to review obligations for subawards under Immunization, Assistance Listing No. 93.268 to identify subawards that fall under the rules set forth by Federal Funding Accountability and Transparency Act (FFATA) and report the appropriate obligations to FSRS according to the above-mentioned Name(s) of the contact person(s) responsible for corrective action: Cheryl Bernard-Dort, Director of Administration and Finance, BIDLS Planned completion date for corrective action plan: 7/31/2026

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Finding 1214139 (2025-023)

Material Weakness 2025

Commonwealth of Massachusetts

MA

Subrecipient Monitoring § 200.303 § 200.332

2025-023 Aging Cluster 93.044, 93.045, 93.053 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should review and enhance internal controls and procedures to ensure that it includes all required information in the su...

2025-023 Aging Cluster 93.044, 93.045, 93.053 Recommendation: We recommend the Department complete implementation of its corrective action plan from the prior year. The Department should review and enhance internal controls and procedures to ensure that it includes all required information in the subaward agreements. We also recommend the Department review and enhance its internal controls and procedures to ensure subrecipient monitoring is performed in compliance with the requirements of the federal programs. Action taken in response to finding: This finding is related to prior year Finding 2023-022. AGE implemented revised internal controls during FFY24 to address deficiencies in subaward agreement content and subrecipient monitoring; however, the current finding relates to subawards issued in prior fiscal years that were not amended following the original audit observation. Since the prior finding, AGE has updated its subaward agreement templates to ensure inclusion of all required federal award identification elements, including the Federal Award Identification Number (FAIN), federal award date, Assistance Listing number, federal award title, and related required data elements. These updated templates are being used for FFY25 and all subsequent contracts. Name(s) of the contact person(s) responsible for corrective action: Sheila Tunney, Chief Financial Officer, Christina H. Martinez, Director of Contracts and Accounting Ted Zimmerman, State Planner Planned completion date for corrective action plan: September 30, 2026

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