Corrective Action Plans

Finding 1186861 (2025-003)

Material Weakness 2025

Homeless Assistance Leadership Organization, Inc.

WI

Questioned Costs Subrecipient Monitoring HUD Housing Programs

Finding #2025-003 - Rent Reasonableness Criteria: HUD requires that recipients ensure that rent is reasonable compared to similar unassisted units and maintain documentation supporting the determination; rent paid with CoC leasing funds·may not exceed Fair Market Rent (FMR); and rent reasonableness ...

Finding #2025-003 - Rent Reasonableness Criteria: HUD requires that recipients ensure that rent is reasonable compared to similar unassisted units and maintain documentation supporting the determination; rent paid with CoC leasing funds·may not exceed Fair Market Rent (FMR); and rent reasonableness determinations must be completed before providing assistance. Condition: During testing of rent reasonableness controls and documentation, the following exceptions were identified: • 4 of 4 rent reasonableness determinations lacked evidence of an independent review and approval. • There were 8 instances (2 units x 4 months) where rents exceeded HUD FMR limits. • 3 of 20 rent reasonableness determinations were not completed prior to the lease start date. Questioned Costs: $392. Cause: The Organization did not have sufficiently defined or consistently followed procedures for documenting independent review of rent reasonableness determinations, verifying rents against applicable FMR limits before authorizing payments, and ensuring determinations were complete prior to lease start dates. Effect: Units are approved and paid at non-compliant rent levels, federal funds are used for rents above allowable limits, and documentation does not meet HUD standards, potentially leading to questioned costs, required repayment, and findings in future monitoring or audits. Recommendation: We recommend that management establish a mandatory review and approval step for all rent reasonableness forms, require staff to verify current FMR limits before approving leasing amounts, and require rent reasonableness completion before any lease start date or payment authorization. Response: HALO's management concurs with this finding. HALO management will implement procedures to ensure compliance with rent reasonableness and FMR limits and train staff on those procedures. HALO will replace the current Rent Reasonableness form with the one on the HUD Exchange. Contact Person: Yvonne MacDonald Hames Anticipated Completion: June 30, 2026

View Audit 394609

Finding 1186855 (2025-001)

Material Weakness 2025

Argus Manor Association

WA

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT S3800-010: Finding Reference Number 2025-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification...

FINDINGS – MAJOR FEDERAL AWARD PROGRAMS AUDIT S3800-010: Finding Reference Number 2025-001 S3800-030: Statement of Condition: Management designed Control Activities to ensure compliance with the Eligibility requirement with respect to tenant eligibility. Those Control Activities include verification and review of tenant files by an independent contractor prior to finalization of tenant income certifications and new tenant move-in files. However, during our testing, we noted four (4) move-in files out of four (4) move-in files tested where tenants were approved for move-in prior to review and approval by the independent contractor, circumventing the control. In addition, there was no evidence of approvals of tenant income certifications in the tenant files prior to billing of rental assistance for eleven (11) out of twelve (12) tenant files tested. S3800-080: Auditor Recommendation: We recommend that the client immediately implement corrective actions to ensure compliance with internal control procedures. Specifically: 1. The compliance specialist should be required to wait for proper approval of tenant eligibility files before processing them. 2. Review and reinforce the approval process through additional training for staff to ensure they understand the critical importance of obtaining necessary approvals before proceeding. 3. Implement stronger oversight and monitoring mechanisms to ensure that files are not processed before approval. S3800-045: Actions Taken or to be Taken: Management has reviewed the policies and procedures with the property manager, who also serves as the compliance specialist. The property manager was instructed that no tenants are to be granted occupancy and no billing of rental assistance based on certifications should be billed until the file has been approved by the independent contractor conducting the compliance review.

View Audit 394602

Finding 1186845 (2025-002)

Material Weakness 2025

Westchester Jewish Community Services, Inc.

NY

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

Finding 2025{D2, Accuracy of the SEFA Persons Responsible: lrene Math, Chief Financial Officer; Jack Babwah, Director of Revenue and Reimbursement Comment: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee's financial statements. The SEFA included 10...

Finding 2025{D2, Accuracy of the SEFA Persons Responsible: lrene Math, Chief Financial Officer; Jack Babwah, Director of Revenue and Reimbursement Comment: The Uniform Guidance requires that the auditee prepare a SEFA for the period covered by the auditee's financial statements. The SEFA included 100% of expenditures for each grant, even if the grant was not 100% federally funded. Proper identification of federal funds and their related allocations is critical to ensure compliance with federal requirements and accurate reporting. Management subsequently reviewed the funding allocations and revised the SEFA during the audit to properly reflect only the federally funded portion of expenditures. The final SEFA included in the financial statements reflects these corrections. Response: Management acknowledges the importance of accurately reporting only the federal portion of grant expenditures in the SEFA. To address this, management is implementing enhanced procedures. During the current year, a master grants listing was developed to strengthen the grants onboarding process. As part of this process, the team will determine the federal funding details at the outset of each award, when not clearly specified in the contract, and will proactively contact funders to obtain the Assistance Listing Number (ALN)/Catalog of Federal Domestic Assistance (CFDA) number and related information. In addition, federal funding allocation percentages will be appropriately identified, calculated and reported on the SEFA. These actions are expected to improve accuracy and compliance with federal requirements. Estimated Completion Date: The additional review procedures will be implemented by the June 30, 2026 financial statement close process.

View Audit 394587

Finding 1186833 (2025-018)

Material Weakness 2025

Second Judicial District Court

NM

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

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

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

View Audit 394575

Finding 1186828 (2025-015)

Material Weakness 2025

Second Judicial District Court

NM

Questioned Costs Subrecipient Monitoring Allowable Costs / Cost Principles

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

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

View Audit 394575

Finding 1186823 (2025-014)

Material Weakness 2025

Second Judicial District Court

NM

Subrecipient Monitoring

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

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

View Audit 394575

Finding 1186819 (2025-013)

Material Weakness 2025

Second Judicial District Court

NM

Questioned Costs Subrecipient Monitoring Reporting

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

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

View Audit 394575

Finding 1186816 (2025-011)

Material Weakness 2025

Second Judicial District Court

NM

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

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

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

View Audit 394575

Finding 1186812 (2025-010)

Material Weakness 2025

Second Judicial District Court

NM

Internal Control / Segregation of Duties Questioned Costs Subrecipient Monitoring

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

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

View Audit 394575

Finding 1186810 (2025-001)

Material Weakness 2025

Behavioral Health Initiatives, Inc.

TN

Subrecipient Monitoring Reporting Significant Deficiency

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

View Audit 394574

Finding 1186805 (2025-005)

Material Weakness 2025

Greater Clark County Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring

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

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

View Audit 394550

Finding 1186803 (2025-003)

Material Weakness 2025

Greater Clark County Schools

IN

Internal Control / Segregation of Duties Subrecipient Monitoring

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

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

View Audit 394550

Finding 1186794 (2025-002)

Material Weakness 2025

Charleston County Housing and Redevelopment Authority

SC

HUD Housing Programs Subrecipient Monitoring Eligibility

2025-002 ALN: 14.850 – Public Housing Operating Fund – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Childers, Chief Executive Officer ...

2025-002 ALN: 14.850 – Public Housing Operating Fund – Eligibility Management acknowledged the finding and will follow the Auditor's recommendations as listed in the Schedule of Findings and Questioned Costs. Person Responsible for Correction of Finding: Ms. Angela Childers, Chief Executive Officer Projected Completion Date: March 31, 2027

View Audit 394546

Finding 1186790 (2025-005)

Material Weakness 2025

Community Schools of Frankfort

IN

Subrecipient Monitoring Allowable Costs / Cost Principles Questioned Costs

FINDING 2025-005 Finding Subject: Special Education Grants to States, Special Education Pre-school grants – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Scott Weltz, Denise Funston Contact Phone Number and Email Address: 765-65...

FINDING 2025-005 Finding Subject: Special Education Grants to States, Special Education Pre-school grants – Activities Allowed or Unallowed and Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Scott Weltz, Denise Funston Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, funstond@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Due to turnover in the Director of Exceptional Needs position, there were expenditures made from the wrong grant cycle. A system of internal controls will be implemented to both ensure that supporting documentation is maintained and that the expenditures and reimbursements are attributed to the correct grant/fund. Anticipated Completion Date: Current and ongoing with any special education grants.

View Audit 394542

Finding 1186788 (2025-004)

Material Weakness 2025

Community Schools of Frankfort

IN

Internal Control / Segregation of Duties Period of Performance Subrecipient Monitoring

FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Scott Weltz, Denise Funston Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, funstond@frankfort.k12.in.us Views of Responsible ...

FINDING 2025-004 Finding Subject: Special Education Cluster (IDEA)- Period of Performance Contact Person Responsible for Corrective Action: Scott Weltz, Denise Funston Contact Phone Number and Email Address: 765-654-5585, weltzs@frankfort.k12.in.us, funstond@frankfort.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Due to turnover in the Director of Exceptional Needs position, there were expenditures made, through payroll distributions, from the wrong grant cycle. Moving forward the Treasurer and the Director will work closely together to review grant cycles and distributions to ensure the correct fund (grant) is being used. Both will sign off on distribution changes as a form of internal controls. Anticipated Completion Date: Current and ongoing with any special education grants.

View Audit 394542

Finding 1186771 (2025-002)

Material Weakness 2025

Vermont Law and Graduate School, Inc. and Subsidiary

VT

Questioned Costs Subrecipient Monitoring

The Business Office at Vermont Law and Graduate School will review the Single Audit of all subrecipients to determine whether there are any findings which require a Corrective Action Plan related to those federal funds. We will implement a workbook which documents the date and time the Single Audit ...

The Business Office at Vermont Law and Graduate School will review the Single Audit of all subrecipients to determine whether there are any findings which require a Corrective Action Plan related to those federal funds. We will implement a workbook which documents the date and time the Single Audit was reviewed. The Business office will educate each Principal Investigator as to where to find the Policy for Subawards, as well as ensuring they have a clear understanding of their roles/responsibilities in accordance with the Policy. Responsible Parties: Stephanie Svahn – Controller (802) 831-1209 Angie Poulin – Grant Accountant (802) 831-1219 Principal Investigators of each Subaward Estimated Completion Date: Will be implemented moving forward as of 2/17/2026

View Audit 394511

Finding 1186770 (2025-001)

Material Weakness 2025

Vermont Law and Graduate School, Inc. and Subsidiary

VT

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring

The Business Office at Vermont Law and Graduate School will update the Policy for Subawards document to include reviewing the System for Award Management (SAM) for employees as well as vendors to ensure they are not suspended, debarred or otherwise excluded from participating in federal programs. We...

The Business Office at Vermont Law and Graduate School will update the Policy for Subawards document to include reviewing the System for Award Management (SAM) for employees as well as vendors to ensure they are not suspended, debarred or otherwise excluded from participating in federal programs. We will implement this upon entry into a new Sub-Award Agreement, as well as for existing Sub-Award Agreements wherein the transaction is equal or exceeds $25,000.00. We will also implement this annually to any payment that is equal or exceeds $25,000.00 as best practice. We will implement a workbook which documents the date SAM was reviewed, and that the vendor/employee wasn’t suspended, debarred, or otherwise excluded from participating in federal programs at that time. The Business office will educate each Principal Investigator as to where to find the Policy for Subawards, as well as ensuring they have a clear understanding of their roles/responsibilities in accordance with the Policy. Responsible Parties: Stephanie Svahn – Controller (802) 831-1209 Angie Poulin – Grant Accountant (802) 831-1219 Principal Investigators of each Subaward Rebecca Dube – Accounts Payable (802) 831-1218 Estimated Completion Date: Will be implemented moving forward as of 2/17/2026

View Audit 394511

Finding 1186768 (2025-006)

Material Weakness 2025

Van Buren County, Tennessee

TN

Subrecipient Monitoring School Nutrition Programs Cash Management

The Tennessee Department of Agriculture concurs. To ensure effective internal controls over inventory at storage locations for school food distribution, the Tennessee Department of Agriculture added the risk of not complying with inventory requirements for school food to our Financial Integrity Act ...

The Tennessee Department of Agriculture concurs. To ensure effective internal controls over inventory at storage locations for school food distribution, the Tennessee Department of Agriculture added the risk of not complying with inventory requirements for school food to our Financial Integrity Act risk assessment along with the following mitigating controls: 1 - Monthly inventory reports are required to be sent by each of the three school food warehouses to the Commodities team. 2 - Developed monitoring guides and have begun using those guides to assist with warehouse visits. The Tennessee Department of Agriculture has a plan to begin observing inventory annually. We completed our first warehouse visit in February 2026 and anticipate completing visits to the other two warehouses by September 30, 2026. In addition to the annual on-site inventory observation, internal monthly inventory monitoring has been added to the duties of the Commodities team. Warehouses are now required to submit monthly inventory reports by the 10th of each month which are then analyzed by the team. The Tennessee Department of Agriculture is looking at ways to add a permanent position to the Commodities team. We have tried getting an additional position approved in the budget and we are exploring the possibility of repurposing vacant positions within the department. Finally, the Tennessee Department of Agriculture's special projects team has been looking at SOPs in place as well as the need for SOPs in areas without them. The Commodities team is next on the list for special projects to help with drafting and revising SOPs. The department plans to use this opportunity to establish written procedures that outline responsibilities for the school food program to help us ensure compliance with federal requirements. The Commodity Distribution Administrator will be responsible for ensuring corrective actions are implemented by the anticipated completion date of December 31, 2026.

View Audit 394493

Finding 1186767 (2025-004)

Material Weakness 2025

Van Buren County, Tennessee

TN

Subrecipient Monitoring Procurement, Suspension & Debarment School Nutrition Programs

The Tennessee Department of Education (TDOE) concurs. The Tennessee Department of Education State Director of School Nutrition, Senior Compliance and Data Manager, and Data Processing and Reporting Specialist have been working with the Federal Funding and Accountability Transparency Act (FFATA) Syst...

The Tennessee Department of Education (TDOE) concurs. The Tennessee Department of Education State Director of School Nutrition, Senior Compliance and Data Manager, and Data Processing and Reporting Specialist have been working with the Federal Funding and Accountability Transparency Act (FFATA) System for Award Management (SAM) administrators to submit the required reports. The department is pursuing both internal practice adjustments and external collaboration with the United States Department of Agriculture (USDA) to ensure proper reporting. Internally, the department is working to develop an application programming interface (API) between the department’s nutrition data system and the recently updated federal reporting system to promote seamless report submissions. Externally, the department is collaborating with the Office of the CFO for the United States Department of Agriculture (USDA), noting the lack of more robust bulk upload options in the federal reporting system compared to the prior system. The department, alongside other states, continues to work with USDA to determine more efficient bulk upload options to streamline federal data reporting. The department will continue to leverage both these efforts to ensure reporting requirements are met. The Tennessee Department of Education has created and deployed a standard operating procedure (SOP) to inform staff of the responsibilities our office has in uploading the required reports. The department will also include a certification process in its standard operating procedures so that reports are reviewed prior to submission in the SAM platform.

View Audit 394493

Finding 1186766 (2025-011)

Material Weakness 2025

Van Buren County, Tennessee

TN

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management

The Tennessee State Veterans Homes (VHB) partially concurs. While the Tennessee State Veterans Homes (VHB) grant application did not explicitly itemize retention bonuses, their use is consistent with the framework and intent of the grant, as defined in 38 CFR Part 53.11(b), which states the purpose ...

The Tennessee State Veterans Homes (VHB) partially concurs. While the Tennessee State Veterans Homes (VHB) grant application did not explicitly itemize retention bonuses, their use is consistent with the framework and intent of the grant, as defined in 38 CFR Part 53.11(b), which states the purpose is for an “employee incentive program to reduce the shortage of nurses at the TSVH.” The VHB is also actively consulting with the VA to clarify the status of prior billings and determine the appropriate path forward if any are deemed improper. As of the date of this update, we have not received a response.

View Audit 394493

Finding 1186765 (2025-010)

Material Weakness 2025

Van Buren County, Tennessee

TN

Subrecipient Monitoring

The Department of Human Services concurs. 1 - STS has taken steps to address the issues identified, implemented new processes to enhance oversight and risk management, and will continue to refine these efforts in alignment with evolving state policies and guidance. 2 - STS is working with DHS to est...

The Department of Human Services concurs. 1 - STS has taken steps to address the issues identified, implemented new processes to enhance oversight and risk management, and will continue to refine these efforts in alignment with evolving state policies and guidance. 2 - STS is working with DHS to establish a new interagency agreement that explicitly outlines each party’s responsibilities in monitoring vendor performance, validating security controls, and responding to risks associated with vendor-managed systems. 3 - In an effort to establish consistent standards for monitoring vendors, assessing technical safeguards, and ensuring alignment with applicable state and federal control frameworks, including the GAO Green Book and NIST 800-53, STS has also developed and presented a new Information Systems Council (ISC) policy regarding statewide guidance on third-party vendor oversight. Additionally, STS reviewed and updated departmental risk assessment documents to reflect third-party IT vendor oversight controls.

View Audit 394493

Finding 1186764 (2025-009)

Material Weakness 2025

Van Buren County, Tennessee

TN

Subrecipient Monitoring Procurement, Suspension & Debarment

The Tennessee Department of Transportation (TDOT) Management concurs. The following processes have been created to correct the issues with FFATA reporting: 1 - An internal submittal deadline has been created to ensure the timely submission of the FFATA report each month. This timeframe is 15 days fr...

The Tennessee Department of Transportation (TDOT) Management concurs. The following processes have been created to correct the issues with FFATA reporting: 1 - An internal submittal deadline has been created to ensure the timely submission of the FFATA report each month. This timeframe is 15 days from project approval. In the event something happens and the 15 days is missed, there is still time to correct the issue before becoming noncompliant with the FAA. 2 - All the information is kept on a separate excel strictly for FFATA reporting and contains checks in the file stating if it has been entered into SAM.gov and to ensure it is also on the ALL-Aero spreadsheet. 3 - Ensure that the information that is entered is transferred into the folder for that month. Via pdf or screenshot. 4 - Created a folder dedicated to FY26 for all things FFATA. This will be the norm going forward per fiscal year. 5 - Trained two senior staff members within the Grants and Compliance section on entering the information if the Statewide Technical Specialist is out or unable to get it in within the allotted timeframe. 6 - Emailing the Team Lead after the FFATA report has been entered as well as storing it on the shared drive in the FY26 FFATA Reporting Folder (or future corresponding folder). 7 - Created a section on our section’s OneNote (SOP) of how to enter the information and also put the information for the paths to the share drive FFATA files as well for anyone else in case something happened to any of the people who are trained it, continuity will be maintained. 8 - A line item has been created on the weekly one-on-one agenda between the Team Lead and Statewide Tech Spec following up on FFATA reporting status and cross-referenced with project approval list.

View Audit 394493

Finding 1186762 (2025-008)

Material Weakness 2025

Van Buren County, Tennessee

TN

Subrecipient Monitoring Reporting Cash Management

The Tennessee Housing Development Agency Management (THDA) partially concurs. THDA has continued to refine its process to ensure timely and accurate reporting. In 2025, steps were taken to review reports prior to submission. The Manager additionally consulted with APPRISE, Inc., the data management ...

The Tennessee Housing Development Agency Management (THDA) partially concurs. THDA has continued to refine its process to ensure timely and accurate reporting. In 2025, steps were taken to review reports prior to submission. The Manager additionally consulted with APPRISE, Inc., the data management firm contracted to support HHS and LIHEAP grantees, prior to report submission. Apprise acknowledges that the report templates do not properly identify errors and encourages THDA to submit reports even when errors are noted. Any instances where errors were substantiated following report submission have been corrected in consultation with APPRISE. HHS has accepted all reports submitted by THDA and we have received no communication from HHS that THDA is in jeopardy of their consideration of any of the effects noted in your letter. We do acknowledge that there was an instance where numbers were not reported correctly or timely due to lags in getting the Low Income Home Energy Assistance Program (LIHEAP) weatherization data as well as improper grantee reporting. We are working to resolve this issue through the implementation of new software that will join the LIHEAP utility assistance and LIHEAP weatherization data together, on a single platform. THDA launched the software for the utility assistance segment of LIHEAP on November 1, 2025, and we expect the LIHEAP weatherization data to be online by October 1, 2026. THDA's work in 2025 to improve its reporting accuracy has been impacted considerably by inconsistent guidance at the Federal level. Since January 2025, due to periods of non-communication by the Health & Human Services (HHS) and subsequent reductions and changes in staffing at HHS, we have received various interpretations of HHS guidance. For instance, HHS has provided differing definitions of "obligation", creating some confusion with reporting. To date, HHS has not provided a final definition. THDA will continue to report obligations as is stated in our Model Plan, when funds are awarded and a contract is fully executed with the sub-grantee.

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Finding 1186761 (2025-007)

Material Weakness 2025

Van Buren County, Tennessee

TN

Subrecipient Monitoring Reporting

The Tennessee Department of Health (TDH) concurs. 1 - With regard to the monitoring of single audit findings within subrecipients, Emergency Preparedness will work with their column’s Business and Grant Management (BGM) Team to ensure that grantees that require an annual single audit are identified ...

The Tennessee Department of Health (TDH) concurs. 1 - With regard to the monitoring of single audit findings within subrecipients, Emergency Preparedness will work with their column’s Business and Grant Management (BGM) Team to ensure that grantees that require an annual single audit are identified and that single audits are reviewed within 60 days of the audit date. If relevant findings and corresponding corrective actions are identified, the BGM Team will confer with program management, and communicate with the subrecipient as to whether the corrective actions taken are believed to sufficiently mitigate the deficiencies noted in the finding. This communication will be filed for reference by program management and shared with the Compliance & Ethics Office, where a log will be kept to track this activity. This process will be put in place by January 31, 2026, and be the responsibility of the BGM Team Compliance Manager. 2 - With regard to staffing issues, the Compliance & Ethics Office was challenged with the untimely death of their monitoring manager, while at the same time losing an additional staff member due to attrition. The Compliance & Ethics Office will ensure that in the event of staffing shortages, a hierarchical management structure is in place to make needed changes in the subrecipient monitoring plan if needed. The Assistant Commissioner that leads the Compliance & Ethics Office will be responsible for this effort and has put this structure in place effective January 1, 2026. 3 - Finally, the evaluation of the effectiveness of the subrecipient monitoring system will be conducted as part of the annual Financial Integrity Act Risk Assessment, conducted by December 31 of each year, beginning December 31, 2026. Additionally, the Compliance & Ethics Office will conduct an enterprise-wide refresher course on single audit review and other subrecipient compliance responsibilities on or before June 30 each year, beginning June 30, 2026.

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Finding 1186759 (2025-005)

Material Weakness 2025

Van Buren County, Tennessee

TN

Matching / Level of Effort / Earmarking Subrecipient Monitoring Cash Management

The Tennessee Department of Education (TDOE) concurs. Matching: On July 10, 2025, cross‑divisional staff members from the Tennessee Department of Education (TDOE) participated in a virtual training with Andrew Johnson from the U.S. Department of Education (ED), Office of Career, Technical, and Adult...

The Tennessee Department of Education (TDOE) concurs. Matching: On July 10, 2025, cross‑divisional staff members from the Tennessee Department of Education (TDOE) participated in a virtual training with Andrew Johnson from the U.S. Department of Education (ED), Office of Career, Technical, and Adult Education (OCTAE). The training agenda included an overview of matching requirements for the Perkins grant. Additionally, TDOE has procured training scheduled for April 1, 2026. Cross‑divisional staff members will engage in a full day of training focused on both programmatic and fiscal topics, including matching requirements, to further build team capacity. To support internal collaboration, CTE program staff currently attend monthly budget meetings to review and discuss program expenditures including both federal and state funds and determine whether adjustments are needed. Historically, these meetings focused primarily on program allowability; however, they were expanded to include a review of matching requirements specifically. Maintenance of Effort (MOE): On July 10, 2025, cross‑divisional staff members from the Tennessee Department of Education (TDOE) participated in a virtual training with Andrew Johnson from the U.S. Department of Education (ED), Office of Career, Technical, and Adult Education (OCTAE). The training agenda included an overview of Maintenance of Effort (MOE) requirements for the Perkins grant. Additionally, TDOE has procured training scheduled for April 1, 2026. Cross‑divisional staff members will engage in a full day of training focused on both programmatic and fiscal topics, including MOE requirements, to further build team capacity. The TDOE Fiscal Director reviews financial data and discusses any concerns or questions with CTE Program Managers. Processes have been updated to include documentation of these discussions. The team is implementing internal controls to ensure compliance with federal matching and MOE requirements. These controls include developing and documenting key processes and procedures to promote consistent and ongoing compliance. Documentation of review activities will be collected to demonstrate compliance and support ongoing monitoring of fiscal practices. In addition, leadership will evaluate the effectiveness of these control activities in mitigating identified risks and update the department’s annual risk assessment to reflect any new or revised controls implemented as a result of this finding.

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Corrective Action Plans

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