Corrective Action Plans

Finding 564262 (2024-002)

Significant Deficiency 2024

CA

Questioned Costs Student Financial Aid Special Tests & Provisions

Corrective Actions: A. Incorrect Calculation of Return of Title IV Funds Los Angeles Harbor College The District’s Central Financial Aid Unit (CFAU) R2T4 Unit centralized the R2T4 process at all nine colleges during the 2023-24 aid year. CFAU is currently processing R2T4 calculations for Los Angeles...

Corrective Actions: A. Incorrect Calculation of Return of Title IV Funds Los Angeles Harbor College The District’s Central Financial Aid Unit (CFAU) R2T4 Unit centralized the R2T4 process at all nine colleges during the 2023-24 aid year. CFAU is currently processing R2T4 calculations for Los Angeles Harbor College. Personnel Responsible for Implementation: Ludwig Perez, Financial Aid Manager, Los Angeles Harbor College Steve Giorgi, Financial Aid Manager, Central Financial Aid Unit Expected Date of Implementation: Already Implemented B. Distance Education (DE) Courses – Implementation of Formal Process to Determine Accuracy of Student Withdrawal Date – Partial Implementation of Prior Year Corrective Action Plan (CAP) EPIE will share the most recent annual internal audit review with each college team and require each college to develop a corrective action plan. EPIE will submit a request to add a pop-up message to the faculty roster directly tied to completion of the mandatory exclusion roster (census roster), supplemental roster, and active enrollment roster. The pop-up message will continue to be displayed until the faculty member successfully submits their roster. EPIE will work with the distance education (DE) faculty coordinators to create professional development training geared toward using Canvas to determine an online student’s last date of academic engagement and will offer the training annually. Additionally, EPIE will conduct training for administrators on the use of queries to monitor pending rosters. Personnel Responsible for Implementation: Nicole Albo-Lopez, Vice Chancellor, EPIE Expected Date of Implementation: June 30, 2025

View Audit 358384 Questioned Costs: $1

Finding 564254 (2024-002)

Significant Deficiency 2024

Amphitheater Unified School District No. 10

AZ

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting

Finding Number: 2024‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be r...

Finding Number: 2024‐002 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Contact Person: Cliff Wadhams, Business Manager Anticipated Completion Date: August 31, 2025 Planned Corrective Action: The District will be requiring all District LEAs to take the necessary training through the Arizona Department of Education web portal and related classes as necessary to be better informed on ESSER reporting and supporting documentation.

View Audit 358361

Finding 564247 (2024-001)

Material Weakness 2024

Metro Towers, Inc. St. James Place

MO

HUD Housing Programs Special Tests & Provisions Procurement, Suspension & Debarment

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee t...

CORRECTIVE ACTION PLAN FOR THE YEAR ENDED DECEMBER 31, 2024 Title 2, U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart F, Section 511 – Audit Findings Follow-up requires the auditee to prepare a corrective action plan to address each audit finding included in the current year auditor’s reports. The Corrective Action Plan for Current Year Findings present our corrective action plan for the Financial Statement and/or Federal Award Findings described in the accompanying Schedule of Findings and Questioned Costs for the period ended December 31, 2024. Finding 2024-001 Responsible Party Name: Fred Gibbs Position: President – Management Agent Telephone Number: 913-709-1811 Federal Agency U.S. Department of Housing and Urban Development Federal Program Mortgage Insurance for Purchase or Refinancing of Existing Multifamily Rental Housing (Section 207/223(F)) Compliance Requirements N – Special Tests and Provisions Finding Type Financial Statement and Federal Awards Auditee’s Comment on Finding We agree with the auditor’s finding. Corrective Action We will follow our policies and procedures to ensure that accounting records are kept accurate and complete, and a responsible official will review and sign off on the monthly financial statements. Anticipated Completion Date June 30, 2025

View Audit 358353

Finding 564240 (2024-002)

Significant Deficiency 2024

Cardea Services

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Sexually Transmitted Diseases (STD) Prevention and Control Grants – Assistance Listing No. 93.977 Recommendation: CLA recommends Cardea update policies to ensure that Uniform Guidance requirements are met to perform and document suspension and debarment checks are being done. Explanation of disagree...

Sexually Transmitted Diseases (STD) Prevention and Control Grants – Assistance Listing No. 93.977 Recommendation: CLA recommends Cardea update policies to ensure that Uniform Guidance requirements are met to perform and document suspension and debarment checks are being done. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management updated its policies and procedures to include the required suspension and debarment check. Suspension and debarment checks are completed for all relevant vendors on a quarterly basis. In addition, a Vendor Approval process has been implemented to confirm no debarment or suspension exists prior to utilizing all new vendors. The reviews will be saved and approved by the CFO. Name(s) of the contact person(s) responsible for corrective action: Cathy Bogan Planned completion date for corrective action plan: June 2025

View Audit 358349

Finding 564239 (2024-002)

Significant Deficiency 2024

Housing Connector

WA

Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.306

Corrective action planned: Housing Connector will develop and implement a written policy to address company match contributions used to meet federal cost share requirements, in alignment with 2 CFR 200.306. The policy will provide general guidance on the allowability, tracking, and reporting of matc...

Corrective action planned: Housing Connector will develop and implement a written policy to address company match contributions used to meet federal cost share requirements, in alignment with 2 CFR 200.306. The policy will provide general guidance on the allowability, tracking, and reporting of match to ensure compliance with federal grant regulations. Relevant staff will be informed once the policy is finalized.

View Audit 358335

Finding 564238 (2024-001)

Significant Deficiency 2024

Housing Connector

WA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Corrective action planned: In alignment with 2 CFR 200.430, Housing Connector will develop and implement a formal time tracking policy and procedure to ensure that personnel expenses charged to federal grants are supported by records reflecting the actual time worked on each award.

View Audit 358335 Questioned Costs: $1

Finding 564234 (2024-002)

Significant Deficiency 2024

National Railroad Passenger Corporation

DC

Subrecipient Monitoring Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.302 § 200.303

Finding 2024-002: Review of Compliance Matrices and Narratives The single audit report included the following recommendation: We recommend that Amtrak establishes a more defined timeline for the events that would trigger the update and review of the compliance matrices and compliance narrative, w...

Finding 2024-002: Review of Compliance Matrices and Narratives The single audit report included the following recommendation: We recommend that Amtrak establishes a more defined timeline for the events that would trigger the update and review of the compliance matrices and compliance narrative, which could include execution of any new federal awards or amendments to existing federal awards. Additionally, Amtrak should establish a process where the modifications to the provisions are assessed for materiality/applicability and include documentation of the respective conclusions as part of the review process. Management Response/Status of Action Plans: Amtrak acknowledges the need to augment process documentation around the controls over the preparation and updates to the compliance matrices. The company is in the process of updating these controls now and will incorporate the identified findings in developing more robust controls. The company specifically notes the need to add more documentation on considerations for what provisions are updated in the compliance matrices and the evidence of review. The review procedures and controls are being enhanced to include a checklist to improve the review. This checklist will be completed by both the compliance matrix creator (upon creation) and the compliance matrix reviewer/approver (upon review and final approval). The contact for this item is Lucia Butts, AVP Funding and Grants and Meghan Histand, Director of Discretionary Grants. Amtrak anticipates fully remediating this finding by September 2025.

View Audit 358334

Finding 564233 (2024-001)

Significant Deficiency 2024

National Railroad Passenger Corporation

DC

Reporting Subrecipient Monitoring Internal Control / Segregation of Duties § 200.302 § 200.303 § 200.328 § 200.329

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, includi...

Finding 2024-001: Preparation of Schedule of Expenditures of Federal Awards (SEFA) The single audit report included the following recommendation: We recommend Amtrak to strengthen the SEFA oversight process to ensure appropriate preparation and review of the SEFA to validate its accuracy, including reconciliation with prior year audited SEFA. This should include having one reviewer take overall responsibility for the completeness and accuracy of the final submitted SEFA. This robust review process should include appropriate procedures to confirm accuracy of the SEFA, which may include a protocol where representatives from various groups (both discretionary and non-discretionary federal programs) work collaboratively to review the SEFA and underlying details of expenditures, to ensure all the adjustments have been properly reflected as well as any projects that might have multiple fund sources are identified timely and reviewed for appropriate inclusion within the SEFA. Additionally, Amtrak should establish a process where any modifications of WBS funding assignments and allocations are updated in a timely manner Management Response/Status of Action Plans: Amtrak recognizes the need to improve the preparation and review of the SEFA. The company has documented the steps for preparing and reviewing the SEFA within its process narrative. The company will update the narrative to address the preparation and review issues that led to the multiple versions of the SEFA being provided during the audit. The company is in the process of updating the SEFA preparation documentation for FY2025, which will be used at the end of the year. The review procedures and controls are being enhanced to include a checklist to improve the review. The company will review and update the Grants Management Compliance Narrative and controls to improve timing of updates for modifications of WBS funding assignments. The contact for this item is Lucia Butts, AVP Funding and Grants. Amtrak anticipates fully remediating this finding by September 2025.

View Audit 358334

Finding 564146 (2024-002)

Significant Deficiency 2024

Cohoes Housing Authority

NY

HUD Housing Programs Subrecipient Monitoring Allowable Costs / Cost Principles

Name of Auditee: Cohoes Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: September 30, 2024 CAP Prepared by; Mathew Ethier, Executive Director (2) Finding 2024-002 (d) Comments on the finding and recommendation - The...

Name of Auditee: Cohoes Housing Authority Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: September 30, 2024 CAP Prepared by; Mathew Ethier, Executive Director (2) Finding 2024-002 (d) Comments on the finding and recommendation - The Authority agrees with the finding. The Authority also agrees with the recommendation, please see below for action. (e) Action taken - The Authority will strengthen internal controls and training of staff to ensure reporting deadlines. The Authority has also engaged a new fee accountant to assist with the year-end closing procedures. (f) Planned Implementation Date - The Authority expects to complete the corrective action by September 30, 2025, at the time of its next required unaudited submission.

View Audit 358311

Finding 564143 (2024-001)

Material Weakness 2024

Shelby City School District

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring HUD Housing Programs

The district will ensure that any contracts that will be paid with Federal Funds will follow the provisions outlined in the grant documentation.

View Audit 358306

Finding 564138 (2024-002)

Material Weakness 2024

Myrtle Point School District

OR

Subrecipient Monitoring Reporting Material Weakness § 200.508 § 200.510

Finding 2024-002 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 10.555 National School Lunch Program cluster Name of Federal Agency: U.S. Department of Agriculture Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.5...

Finding 2024-002 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 10.555 National School Lunch Program cluster Name of Federal Agency: U.S. Department of Agriculture Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit with values that were not reconciled with the general ledger. Cause: The District relied on individuals with insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have sufficient training or monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Expenditures of federal awards and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly, and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following: • SEFA was originally presented for auditors with incorrect information. • No reconciliation between federal expenditures reported on the GL and the SEFA was presented. • Recording of State vs Federal activities was not posted to the GL correctly, requiring adjustments during the audit. • Not all grants were recorded in separate and identifiable GL accounts. Repeat of a Prior-Year Finding: Yes Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. City’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Planned Implementation Date: October 1, 2025 Responsible Person: Director of Business Services, Myrtle Point School District No. 41

View Audit 358289

Finding 564132 (2024-001)

Significant Deficiency 2024

Family Health International

NC

Subrecipient Monitoring Reporting § 200.303

Corrective Action Plan: Finding 2024-001 – Reporting – Federal Funding Accountability and Transparency Act (FFATA) Federal Program Information: Federal Agency: United States Agency for International Development United States Department of State Assistance Listing: 98.001 - USAID Foreign Assist...

Corrective Action Plan: Finding 2024-001 – Reporting – Federal Funding Accountability and Transparency Act (FFATA) Federal Program Information: Federal Agency: United States Agency for International Development United States Department of State Assistance Listing: 98.001 - USAID Foreign Assistance for Programs Overseas 19.421 – Department of Statue Bureau of Educational and Cultural Affairs: Academic Exchange Programs – English Language Program Federal Award Identification Number: 98.001 - 7200AA22CA00016; 72048619CA00001; 7200AA18CA00011; 7200AA19CA00002; 7200AA19CA00002 19.421 - SECAGD19CA0156 Award Year: FY 2024 Corrective Action Plan: FHI 360 will implement a corrective action plan comprised of the following actions: 1) continue global communications and meetings with key management teams 2) targeted and detailed training on FFATA requirements and completion of the FSRS template via an e-module 3) continue additional review through centralized team both to identify prospective transactions and perform a final review of data quality prior to data entry in FSRS, and 4) implement system-based enhancement to capture signature data to allow for centralized monitoring of execution date ensuring timely reporting based on execution dates Person(s) Responsible: Director, Contract Management Services Chief Operating Officer Completion Date: September 30, 2025

View Audit 358281

Finding 564129 (2024-003)

Material Weakness 2024

Crooksville Exempted Village School District

OH

Subrecipient Monitoring Material Weakness Reporting § 200.332

The District will thoroughly examine all grant disclosures and requirements, follow guidance provided, and maintain records related to all reporting. Treasurer has communicated that all district expenditure data reporting be completed by Treasurer/CFO in the future.

View Audit 358259

Finding 564122 (2024-002)

Material Weakness 2024

Town of Brownsburg

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2024-002 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Summary of Finding: Controls were not in place to ensure the Town followed its procedures for suspension and debarment. Contact Person Responsible for Corrective Action: Aaron Kaytar Cont...

FINDING 2024-002 Finding Subject: Drinking Water State Revolving Fund - Procurement and Suspension and Debarment Summary of Finding: Controls were not in place to ensure the Town followed its procedures for suspension and debarment. Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317-852-1120 akaytar@brownsburg.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: In 2023 a Purchasing Policy was implemented for all departments to follow. It states: To provide services to the Town of Brownsburg, you must not be debarred, suspended, or otherwise be excluded from or ineligible for participation in federally assisted programs under Executive Order 12549. Upon entering contracts, the Capital Projects and Procurement manager will ensure a vendor is not suspended or debarred by following one of the three acceptable means as required by the federal government. All contracts are reviewed and approved by the Town Council. Anticipated Completion Date: January 1, 2025

View Audit 358219

Finding 564121 (2024-001)

Material Weakness 2024

Town of Brownsburg

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2024-001 Finding Subject: SLFRF - Procurement, Suspension and Debarment Summary of Finding: Controls were not in place to ensure the Town followed its procedures for suspension and debarment. Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Addres...

FINDING 2024-001 Finding Subject: SLFRF - Procurement, Suspension and Debarment Summary of Finding: Controls were not in place to ensure the Town followed its procedures for suspension and debarment. Contact Person Responsible for Corrective Action: Aaron Kaytar Contact Phone Number and Email Address: 317-852-1120 akaytar@brownsburg.org Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: In 2023 a Purchasing Policy was implemented for all departments to follow. It states: To provide services to the Town of Brownsburg, you must not be debarred, suspended, or otherwise be excluded from or ineligible for participation in federally assisted programs under Executive Order 12549. Upon entering contracts, the Capital Projects and Procurement manager will ensure a vendor is not suspended or debarred by following one of the three acceptable means as required by the federal government. All contracts are reviewed and approved by the Town Council. Anticipated Completion Date: January 1, 2025

View Audit 358219

Finding 564088 (2024-001)

Significant Deficiency 2024

Paterson Community Health Center, INC

NJ

Procurement, Suspension & Debarment Subrecipient Monitoring

CORRECTIVE ACTION PLAN May 15, 2024 Agency: U.S. Department of Health and Human Services: Health Resources and Services Administration (HRSA) Paterson Community Center, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. ___________________________...

CORRECTIVE ACTION PLAN May 15, 2024 Agency: U.S. Department of Health and Human Services: Health Resources and Services Administration (HRSA) Paterson Community Center, Inc. respectfully submits the following corrective action plan for the year ended December 31, 2023. ______________________________________ CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: 12/31/2024 The findings from the 12/31/2024, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule.Section III - Federal and State Awards Findings and Questioned Costs Significant Deficiency I Item 2024-001 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) FAIN # H8000163, H8F41100 for 2024 Recommendation: We recommend that the Center train its personnel in relation to the exclusion screening and proper documentation thereof and that the Center conduct regular reviews to ensure the completeness of exclusion search documentation. Action taken: We will ensure that the center's personnel are trained in the exclusion screening, maintain the location of the proper documentation, and conduct regular reviews to ensure the completeness of exclusion search documentation. The center performs background checks but was unable to locate the documents for those two new employees who were terminated but will ensure that we will put control processes in place to make sure we can demonstrate that the exclusion search was conducted. If the Health Resources and Services Administration has questions regarding this plan, please call Debora Walcott, Chief Financial Officer at 973-790-6594 ext. 320. Sincerely yours,

View Audit 358180

Finding 563967 (2024-001)

None 2024

603 Legal Aid

NH

Subrecipient Monitoring Internal Control / Segregation of Duties

Planned Corrective Action: The 603LA Accounting Manual has been updated and completed, taking into consideration the requirements of the 2023 LSC Financial Guide, including the completion of the Self-Assessment Questionnaire (Appendix 9) of the Guide. The Board of Directors reviewed, approved, and ...

Planned Corrective Action: The 603LA Accounting Manual has been updated and completed, taking into consideration the requirements of the 2023 LSC Financial Guide, including the completion of the Self-Assessment Questionnaire (Appendix 9) of the Guide. The Board of Directors reviewed, approved, and codified the Accounting Manual at the May 28, 2025 Board of Directors meeting. Responsible Person: Controller. Date of Completion: Compliant as of May 2025.

View Audit 358140

Finding 563934 (2024-001)

Material Weakness 2024

Learning Grove, Inc.

KY

Subrecipient Monitoring Reporting § 200.329

Corrective Action Plan: Finding 2024‐001 Responsible: Roseann Hayes, Emily Lewis, George Moore DD Recommendation: We recommend the Organization establish procedures for the preparation, review and timely submission of all reporting requirements. This can include implementing a system to track report...

Corrective Action Plan: Finding 2024‐001 Responsible: Roseann Hayes, Emily Lewis, George Moore DD Recommendation: We recommend the Organization establish procedures for the preparation, review and timely submission of all reporting requirements. This can include implementing a system to track reporting deadlines and timely submission as well as designating individuals with the responsibilities of preparation, review, and submission of reports. Additionally, we recommend the Organization designate someone to review the grant documents for all compliance requirements to ensure nothing is missed. Corrective Action Summary: • Advancement and Finance will create an updated Grants Management process • This Grants Management process will: o Be documented o Clearly define roles for Advancement and Finance staff o Create a flowchart to define what type of grant has been awarded (conditional vs. unconditional) o Assure awarded grants are reviewed for all performance, outcomes, invoicing and reporting requirements o Define who sets up calendar reminders for grant milestones (i.e. reporting) o Define how Program staff will be selected to receive these calendar reminders Anticipated Completion Date: 6/30/2025

View Audit 358106

Finding 563847 (2024-001)

Material Weakness 2024

Seminole County Board of Edcuation

GA

Questioned Costs Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking § 200.303 § 200.403

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: ...

FA 2024-001 Strengthen Controls over Expenditures Compliance Requirement: Activities Allowed or Unallowed Allowable Costs/Cost Principle Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: COVID-19 - 84.425D - Elementary and Secondary School Emergency Relief Fund COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund Federal Award Number: S425D210012 (Year: 2021), S425U210012 (Year: 2021) Questioned Costs: $72,595 Description: A review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund programs revealed that the School District's internal control procedures were not operating appropriately to ensure that expenditures were properly recorded. Corrective Action Plans: Our office was unaware our financial program could automatically generate employee's supplemental checks in addition to standard monthly checks. Now that we are aware, Ivey McLendon and I will monitor our financial program's automatically generated claims closely to adapt our manual accrual entries. Estimated Completion Date: June 30, 2025 Contact Person: Sherry Gray, Financial Director Telephone: (229) 524-2433 Email: sgray@seminole.k12.ga.us

View Audit 358065 Questioned Costs: $1

Finding 563835 (2024-002)

Material Weakness 2024

Oslc Developments, Inc.

OR

Reporting Subrecipient Monitoring Material Weakness § 200.502

Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and ar...

Recommendation: We recommend the organization revisit its policies and procedures surrounding management’s review of grant and other contractual agreements to ensure all federal assistance, including subawards, are properly identified as such at the time the agreements are signed or received, and are properly included on the SEFA. ODI agrees with the auditors’ recommendation. Consistent with response to finding 2024-001, we have reviewed the design and implementation of internal controls procedures around accounting for grants and contracts. This has resulted in revision of our new funding form including identifying federal and nonfederal designations in subcontracts from states, and determination of conditions to ensure compliance with U.S. GAAP. Responsible staff member, Laurie Larson-Lewis, Finance Manager, completion date 5/31/2025.

View Audit 358060

Finding 563817 (2024-005)

Significant Deficiency 2024

Waimanalo Health Center

HI

Procurement, Suspension & Debarment Subrecipient Monitoring

Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2024: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2024Item 2024-005 - Procu...

Health Resources and Services Administration Mary Frances Oneha, Waimanalo Health Center’s CEO respectfully submits the following corrective action plan for the year ended June 30, 2024: CohnReznick LLP 1301 Avenue of the Americas New York, NY 10019 Audit Period: June 30, 2024Item 2024-005 - Procurement, Suspension and Debarment - U.S. Department of Health and Human Services, Health Center Program Cluster (Assistance Listing Number 93.224/93.527) Notice of Award Number 6 H80CS00646-22-03, 2 H80CS005646-23-00, 4 H8GCS48213-01-01, 1 H8LCS51923-01-00 for 2023 and 2024 - (Significant Deficiency) During our audit, we noted that certain employees have no record of an exclusion search conducted during 2024. There were also certain employees for whom an exclusion search was not consistently conducted on a monthly basis. Recommendation We recommend that the Center train its personnel in relation to the exclusion screening and proper documentation thereof and that the Center conduct regular reviews to ensure the completeness of exclusion search documentation. Action Taken Management agrees with the finding and will be conducting training for its personnel to help ensure the accuracy, completeness and timeliness of exclusion searches. Effectivity Date: June 30, 2025

View Audit 358045

Finding 563807 (2024-001)

Significant Deficiency 2024

Healthwest

MI

Subrecipient Monitoring Internal Control / Segregation of Duties Cash Management § 200.305

Finding 2024-001: Cash Management Federal Grant – ALN 93.788 and ALN 93.959 Condition – During testing, it was noted that cash was requested prior to disbursement of funds by a month or more. Corrective Action –HealthWest finance management will conduct a mandatory staff training session for all r...

Finding 2024-001: Cash Management Federal Grant – ALN 93.788 and ALN 93.959 Condition – During testing, it was noted that cash was requested prior to disbursement of funds by a month or more. Corrective Action –HealthWest finance management will conduct a mandatory staff training session for all relevant staff on cash management requirements, including timing of cash requests, documentation of expenditures, and consequences of non-compliance. Refresher grant compliance and cash management policy review and training will be incorporated into annual training for all grant management personnel. HealthWest will update grant pre-draw process to require a documented review and approval of all cash draw requests by finance leadership or designee ensuring drawdowns are supported by general ledger expenditure activity reports. Contract Person – Brandy Carlson, Chief Financial Officer Anticipated Completion Date – June 30, 2025

View Audit 358023

Finding 563801 (2024-004)

Significant Deficiency 2024

Wallingford Housing Authority

CT

HUD Housing Programs Subrecipient Monitoring Reporting

Finding Reference Number: 2024-004 Reporting Description of Finding: During the fiscal year ended June 30, 2024, the Authority's internal controls over the submission of VMS to HUD did not include a review or reconciliation of the information submitted to supporting documentation. As a result, hous...

Finding Reference Number: 2024-004 Reporting Description of Finding: During the fiscal year ended June 30, 2024, the Authority's internal controls over the submission of VMS to HUD did not include a review or reconciliation of the information submitted to supporting documentation. As a result, housing assistance payments for Mainstream Port-out vouchers were not reported in VMS. Statement of Concurrence or Nonconcurrence: The Wallingford Housing Authority agrees and accepts the above reference findings. Corrective Action Plan: Maintaining a properly staffed and trained staff will ensure that each montky VMS report will be reconciled prior to being submitted by the third-party fee accountant. A schedule or reconciliations will be created and implemented.

View Audit 358012

Finding 563792 (2024-002)

Significant Deficiency 2024

Herzing University, Ltd.

WI

Student Financial Aid Subrecipient Monitoring Eligibility § 200.303

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-002 – Eligibility - Pell Finding: Herzing University did not properly award Pell funding to an eligible student in the Spring 2024 semeste...

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-002 – Eligibility - Pell Finding: Herzing University did not properly award Pell funding to an eligible student in the Spring 2024 semester. Condition: A student was eligible to receive Pell funding but did not receive Pell funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive Pell funding but did not receive Pell funds due to an employee error. Action Taken: The identified student withdrew from the University on May 8, 2023. The student’s 2023-24 Pell award was cancelled during the required R2T4 process that was completed on May 23, 2023. The 2023-24 Pell award for the Spring 2024 semester was not manually reinstated upon the student’s return to an Active status on June 28, 2023. The employee who was responsible for updating the student’s financial aid package upon the student’s return to an Active status erroneously neglected to reinstate the 2023-24 Pell award for the Spring 2024 semester. This finding is attributed to human error. In April 2025, Herzing University created an internal compliance checkpoint for Pell awarding. This checkpoint will identify any students with a Pell eligible SAI for the Federal Award year that do not have Pell packaged for the semester. This checkpoint was completed for the Spring 2025 semester on April 7, 2025, and will be completed each semester going forward. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package revised to include Pell funding for the applicable semester, prior to the end of the semester. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the Pell Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the Pell funds that the student was eligible for and should have received for the Spring 2024 semester. The required corrective action for Finding 2024-002 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu

View Audit 358003

Finding 563791 (2024-001)

Significant Deficiency 2024

Herzing University, Ltd.

WI

Student Financial Aid Subrecipient Monitoring Eligibility § 200.303

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-001 – Eligibility - SEOG Finding: Herzing University did not properly award SEOG funding to an eligible student in the Fall 2024 semester....

Audit Firm: RSM US LLP 30 S Wacker Drive, Suite 3300 Chicago, IL 60606 Audit Period: 1/1/2024 – 12/31/2024 Comments on Findings and Recommendations: Finding 2024-001 – Eligibility - SEOG Finding: Herzing University did not properly award SEOG funding to an eligible student in the Fall 2024 semester. Condition: A student was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. For one out of 40 students tested for eligibility, we noted 1 student (2.5%) who was eligible to receive SEOG funding but did not receive SEOG funds due to an employee error. Action Taken: On May 1, 2024, a Financial Aid Advisor manually cancelled the identified student’s 2024-25 SEOG award in Regent (Herzing University’s Financial Aid Management Software), with a notation that the student had an ineligible Student Aid Index (SAI). The student had an SAI of -117 on their 2024-25 ISIR, and in accordance with Herzing University’s FSEOG policy were eligible for 2024-25 SEOG in the Fall 2024 semester. The award was incorrectly manually canceled by the advisor because of human error. In April 2025, Herzing University created an internal compliance checkpoint for FSEOG awarding. This checkpoint will serve as a safety net to identify any students who have a Pell award for the Federal Award year, have an SAI that is FSEOG eligible according to Herzing University’s FSEOG policy, and do not correctly have FSEOG packaged for the semester. Any affected students identified during the completion of this semester-based checkpoint will have their financial aid package reviewed and if necessary revised to include FSEOG funding for the applicable semester, prior to the end of the semester. This checkpoint was completed for the Spring 2025 semester on April 4, 2025, and will be completed each semester going forward. Herzing University’s Policy Manual was updated in April 2025 to reflect the addition of the FSEOG Awarding compliance checkpoint. For the identified student, Herzing University has provided a tuition waiver for the amount of the FSEOG funds that the student was eligible for and should have received for the Fall 2024 semester. The required corrective action for Finding 2024-001 listed in the SFA audit for the period 1/1/2024 – 12/31/2024 was completed on 5/7/2025. The person responsible for completion of the corrective action was Kevin McShane, Vice President of Financial Aid & Compliance. ____________________________________ _______________________ Kevin McShane Date Vice President of Financial Aid & Compliance Herzing University 275 W. Wisconsin Ave., Ste. 210, Milwaukee, WI 53203 Email Address: kmcshane@herzing.edu

View Audit 358003

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