Corrective Action Plans

Finding 1224889 (2024-004)

Material Weakness 2024

MO

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.213

All covered contractors will be checked in SAM.gov and any required recoveries will be addressed; procurement policy will be updated to require formal exclusion screening and certification for SLFRF-related contracts; procurement and program staff will receive training on suspension/debarment rules;...

All covered contractors will be checked in SAM.gov and any required recoveries will be addressed; procurement policy will be updated to require formal exclusion screening and certification for SLFRF-related contracts; procurement and program staff will receive training on suspension/debarment rules; and an annual compliance checklist will be implemented to confirm all future covered transactions include exclusion checks.

View Audit 408114

Finding 1224885 (2024-003)

Material Weakness 2024

SUFFIELD HOUSING AUTHORITY

CT

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

We will implement formalized procedures to strengthen oversight and accounting for grant-funded programs administered by external parties. This will include establishing defined communication protocols requiring external grant administrators to provide detailed expenditure reports on a quarterly bas...

We will implement formalized procedures to strengthen oversight and accounting for grant-funded programs administered by external parties. This will include establishing defined communication protocols requiring external grant administrators to provide detailed expenditure reports on a quarterly basis. In addition, external parties will be required to submit sufficient supporting documentation to enable the Authority to properly record grant activity on an accrual basis in accordance with applicable financial reporting and single audit requirements. We will also prepare annual schedules of expenditures for both federal awards and state financial assistance to facilitate timely evaluation of single audit requirements. These schedules will be reviewed annually by the Board.

View Audit 408110

Finding 1224876 (2024-004)

Material Weakness 2024

Albuquerque Area Indian Health Board, Inc.

NM

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.331

View of Responsible Officials and Corrective Action Plan The AAIHB acknowledges that its subrecipient related practices could be improved upon. The AAIHB will review and revise its internal processes and procedures and implement the auditor’s recommendations to ensure compliance with subrecipient re...

View of Responsible Officials and Corrective Action Plan The AAIHB acknowledges that its subrecipient related practices could be improved upon. The AAIHB will review and revise its internal processes and procedures and implement the auditor’s recommendations to ensure compliance with subrecipient requirements. Corrective Action Plan Timeline Prior to the audit finding, the AAIHB already had one meeting with key personnel involved in the administration and oversight of subawards to begin implementing improvements to our subrecipient monitoring practices. The AAIHB is actively working to update subrecipient monitoring practices and anticipates having policies and procedures in place by the beginning of the next fiscal year. In addition, the GHWIC program has found our internal administrative assistance portal that was developed to optimize admin workflow has been helpful because it has also optimized the processing of subaward invoices. Furthermore, the GHWIC program is in the process of developing a sub awardees data portal for invoicing and reporting purposes to streamline the subaward process and ensure payment in a timely manner. Designation of Employee Position Responsible for Meeting Deadline Executive Director, Finance, Program Managers/Directors/Coordinators, Grants & Contracts Specialist

View Audit 408092

Finding 1224776 (2024-009)

Material Weakness 2024

Scott County School District 2

IN

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-009 Finding Subject: ESSER Grant Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officia...

FINDING 2024-009 Finding Subject: ESSER Grant Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The ESSER program has concluded and corrections were made following leadership changes. Financial activity was reviewed and adjusted where possible. Reimbursement requests are now tied to general ledger activity with full documentation. The prior practice of correcting errors through transfers has been discontinued. Controls implemented apply to all future grants and monitoring is ongoing. Anticipated Completion Date: May 2026

View Audit 407972

Finding 1224773 (2024-008)

Material Weakness 2024

Scott County School District 2

IN

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-008 Finding Subject: Special Education Cluster (IDEA) Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views o...

FINDING 2024-008 Finding Subject: Special Education Cluster (IDEA) Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation partnered with Mazi Education for oversight. Separate funds are maintained for each project year. Payroll mapping has been corrected and reimbursement requests are based on ledger activity with supporting documentation. Transfers are documented and restricted. Monitoring procedures ensure ongoing compliance. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with Special Education grant requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

View Audit 407972

Finding 1224767 (2024-007)

Material Weakness 2024

Scott County School District 2

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.303 § 200.334 § 200.77 § 200.78

FINDING 2024-007 Finding Subject: Title I Eligibility Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible...

FINDING 2024-007 Finding Subject: Title I Eligibility Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Nonpublic schools are required to provide detailed documentation for enrollment and poverty data. Verbal data is no longer accepted. Documentation is reviewed, retained, and verified prior to use in calculations. Mazi Education provides oversight to ensure compliance and accuracy. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with Title I eligibility requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

View Audit 407972

Finding 1224765 (2024-006)

Material Weakness 2024

Scott County School District 2

IN

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2024-006 Finding Subject: Title I Grants Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Offi...

FINDING 2024-006 Finding Subject: Title I Grants Contact Person Responsible for Corrective Action: Superintendent and Treasurer Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Casey Cheatham; 812-752-8949; ccheatham@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation partnered with Mazi Education to provide oversight of grant compliance. Separate funds are maintained for each grant and project year. Payroll mapping has been corrected to ensure proper allocation. Reimbursement requests are based on general ledger activity and supported by documentation. Transfers are restricted and documented. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with federal grant requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

View Audit 407972

Finding 1224763 (2024-005)

Material Weakness 2024

Scott County School District 2

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

FINDING 2024-005 Finding Subject: Child Nutrition Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Superintendent and Food Service Director Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Tammy Mosier; 812-752-8921; t...

FINDING 2024-005 Finding Subject: Child Nutrition Procurement, Suspension, and Debarment Contact Person Responsible for Corrective Action: Superintendent and Food Service Director Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Tammy Mosier; 812-752-8921; tmosier@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Formal procurement procedures have been established including micro-purchase and small purchase thresholds. Required price quotes are obtained and documented. Procurement history is maintained, including rationale and vendor selection. Vendor suspension and debarment checks are performed using SAM.gov or certifications. OPAA provides oversight of procurement processes and monitoring is ongoing. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance procurement control activities, and provide ongoing monitoring to ensure compliance with federal procurement standards, suspension and debarment requirements, and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

View Audit 407972

Finding 1224757 (2024-004)

Material Weakness 2024

Scott County School District 2

IN

School Nutrition Programs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

FINDING 2024-004 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Superintendent and Food Service Director Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Tammy Mosier; 812-752-8921; tmosier@scsd...

FINDING 2024-004 Finding Subject: Child Nutrition Cluster – Internal Controls Contact Person Responsible for Corrective Action: Superintendent and Food Service Director Contact Phone Number and Email Address: Kyle Neukam; 812-752-8921; kneukam@scsd2.k12.in.us Tammy Mosier; 812-752-8921; tmosier@scsd2.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: A new Food Service Director has been appointed and the District partnered with OPAA! Food Management to provide oversight and compliance support. Invoice review procedures ensure pricing accuracy and compliance with contracts. Risk assessment and monitoring procedures have been implemented to ensure ongoing compliance. Scott County School District 2 now participates in the Community Eligibility Provision (CEP) for its school nutrition programs. Under CEP, individual household applications for free and reduced-price meal eligibility are no longer collected or processed. As a result, the eligibility determination procedures that were the subject of finding are no longer applicable. Therefore, no further action is warranted regarding this compliance requirement. The School Corporation has implemented procedures designed to strengthen the control environment, improve risk assessment and information and communication processes, enhance control activities, and provide ongoing monitoring to ensure compliance with Child Nutrition Program requirements and timely identification and correction of deficiencies. Anticipated Completion Date: August 2026

View Audit 407972

Finding 1224545 (2024-001)

Material Weakness 2024

City of Milan

TN

Subrecipient Monitoring Reporting Material Weakness § 200.510 § 200.518

Person Responsible for Implementing the Correction Plan: Autumn Stewart, City Recorder Anticipated Completion Date: June 30, 2026 Repeat Finding: Yes Reason Corrective Action Was Not Taken: Issue was found in the 2025 audit, so was not known at the time. Planned Corrective Action: The City will stre...

Person Responsible for Implementing the Correction Plan: Autumn Stewart, City Recorder Anticipated Completion Date: June 30, 2026 Repeat Finding: Yes Reason Corrective Action Was Not Taken: Issue was found in the 2025 audit, so was not known at the time. Planned Corrective Action: The City will strengthen internal controls over SEFA identification and preparation to ensure compliance with Uniform Guidance single-audit requirements. The City will also implement enhanced review and communication procedures with external auditors, as the condition was significantly impacted by deficiencies in the auditors’ evaluation and classification of major programs during the audit process.

View Audit 407794

Finding 1224540 (2024-001)

Material Weakness 2024

COUNTY OF NEWTON

TX

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting § 200.512

The Commissioner’s of the County of Newton, Texas has reviewed the finding indicated as 2024-001 and agree with the finding. The Commissioner’s have adopted controls, and employed external accounting support, to ensure that the County will comply in all material respects with its reporting requireme...

The Commissioner’s of the County of Newton, Texas has reviewed the finding indicated as 2024-001 and agree with the finding. The Commissioner’s have adopted controls, and employed external accounting support, to ensure that the County will comply in all material respects with its reporting requirements as per the Uniform Guidance 2 CFR 200. Anticipated Completion Date: September 30, 2026. Responsible Parties: Sherry Moore, County Auditor and Commissioners

View Audit 407779

Finding 1224529 (2024-004)

Material Weakness 2024

Harvest Homes Corporation 094-Hd005-Np-Cmi

ND

Internal Control / Segregation of Duties Subrecipient Monitoring Eligibility

Contact Person – Terry Hanson, Executive Director Corrective Action Plan – The Project will review its policies and procedures over documentation of periodic review of tenant files. Completion Date – 12/31/26

View Audit 407778

Finding 1224385 (2024-001)

Material Weakness 2024

BHARATIYA TEMPLE

PA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.512

Finding 2024-001: Late Submission of Data Collection Form Name of Auditee’s Contact Person Responsible for Corrective Action: Nand Todi Corrective Action Planned: Management will ensure that submission of the data collection form to the federal clearinghouse is completed prior to the 9 month subsequ...

Finding 2024-001: Late Submission of Data Collection Form Name of Auditee’s Contact Person Responsible for Corrective Action: Nand Todi Corrective Action Planned: Management will ensure that submission of the data collection form to the federal clearinghouse is completed prior to the 9 month subsequent to the year end mandated deadline. Anticipated completion date: Implemented July 2026

View Audit 407709

Finding 1224362 (2024-003)

Material Weakness 2024

Center for Independent Living of North Florida Inc.

FL

Subrecipient Monitoring

"Management concurs that formalizing contract management procedures will further strengthen organizational oversight. Since FY2025, Ability1st has made significant investments in improving grant administration and compliance management. These improvements include: • centralized grant files; • enhanc...

"Management concurs that formalizing contract management procedures will further strengthen organizational oversight. Since FY2025, Ability1st has made significant investments in improving grant administration and compliance management. These improvements include: • centralized grant files; • enhanced tracking of reporting deadlines and deliverables; • standardized internal monitoring tools; • expanded written policies and procedures; • improved coordination between program staff, accounting personnel, and executiveleadership; • implementation of CIL Suite to improve documentation, reporting, and participantrecord management; • strengthened Board financial reporting; and • ongoing collaboration with the Organization's accounting firm to ensure compliance with federal, state, and local funding requirements. Management recognizes that compliance is an evolving process and remains committed to continuously improving internal controls as funding requirements expand and organizational capacity grows. Responsible Official: Executive Director Implementation Date: Ongoing. Ability1st is committed to continuous improvement and recognizes that strong financial stewardship is essential to fulfilling our mission. Management believes the corrective actions already implemented significantly strengthen the Organization's internal control environment and position Ability1st for improved compliance, financial reporting, and audit readiness in future years."

View Audit 407668

Finding 1224360 (2024-001)

Material Weakness 2024

Center for Independent Living of North Florida Inc.

FL

Subrecipient Monitoring HUD Housing Programs Program Income

"Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program inc...

"Management concurs that stronger documentation surrounding the collection and monitoring of Continuum of Care program income would have strengthened internal controls and the audit trail. The finding relates to a program that has since been discontinued. Throughout the audit period, all program income that was collected was used for allowable program purposes; however, management acknowledges that documentation supporting assessment, collection, monitoring, and reconciliation procedures should have been more comprehensive. Although this activity is no longer part of the Organization's operations, Ability1st has strengthened its overall documentation standards. Should the Organization administer future programs involving program income, written policies and procedures will be implemented prior to program implementation and will include: • documented fee assessment methodology; • collection and deposit procedures; • reconciliation requirements; • supervisory review; • record retention standards; and • periodic internal monitoring. Management believes these procedures will provide an appropriate level of accountability and compliance with federal requirements should program income be collected in the future. Responsible Official: Executive Director Implementation Date: Completed for discontinued program; procedures will be implemented before any future program income activity."

View Audit 407668

Finding 1224330 (2024-003)

Material Weakness 2024

Juel Fairbanks Chemical Dependency Services

MN

Internal Control / Segregation of Duties Subrecipient Monitoring Period of Performance § 200.303

Juel Fairbanks Chemical Dependency Services has implemented a change in how we do our day-to-day process of approvals of payments, authorized signature for payments prior to being issued.

View Audit 407643

Finding 1224076 (2024-008)

Material Weakness 2024

Town of Vinton, Va

VA

Special Tests & Provisions Subrecipient Monitoring

Management acknowledges the recommendation. Throughout the duration of this multi-year project, staff made repeated efforts to obtain quality assurance testing documentation from the applicable contractors and subcontractors. Despite multiple requests and follow-up attempts, we were not successful i...

Management acknowledges the recommendation. Throughout the duration of this multi-year project, staff made repeated efforts to obtain quality assurance testing documentation from the applicable contractors and subcontractors. Despite multiple requests and follow-up attempts, we were not successful in securing the required documentation. We will evaluate and strengthen our procedures going forward to improve contractor compliance and ensure that quality assurance testing records are consistently obtained, reviewed, and retained in accordance with applicable requirements

View Audit 407471

Finding 1224013 (2024-001)

Material Weakness 2024

A+ Arts Academy

OH

Matching / Level of Effort / Earmarking Subrecipient Monitoring

During FY24 A+ Arts Academy was under a management company arrangement. The management company negotiated and recommended the contract for construction services that prevailing wages were not paid. As of 7/1/25, A+ Arts is self-managed and any future construction contracts will be negotiated by A+ A...

During FY24 A+ Arts Academy was under a management company arrangement. The management company negotiated and recommended the contract for construction services that prevailing wages were not paid. As of 7/1/25, A+ Arts is self-managed and any future construction contracts will be negotiated by A+ Arts administration and presented to the Board for approval. Prior to entering into any contract, a determination will be made if prevailing wages should be paid. Additionally, the fact the construction contract was paid for with Federal dollars is unusual and only happened to do ESSER dollars. it is unlikely that any contracts in the future will be paid for using Federal dollars.

View Audit 407427

Finding 1223976 (2024-002)

Material Weakness 2024

Housing Hope and Subsidiaries

WA

Subrecipient Monitoring § 200.332

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and o...

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and only grant Housing Hope has administered that required subrecipient monitoring. The grant has since ended and the organization does not anticipate entering any future agreements that would require subrecipient monitoring. To ensure compliance should such an agreement arise again, Housing Hope adopted a Subrecipient Monitoring Policy. This policy outlines the criteria for identifying subrecipient relationships and establish a standardized process for monitoring subrecipients, if any are engaged in the future. Anticipated completion date: The Subrecipient Monitoring Policy was adopted October 2025 by the Board.

View Audit 407369

Finding 1223974 (2024-003)

Material Weakness 2024

Housing Hope and Subsidiaries

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.303

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Beginning July 1, 2025, ...

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Beginning July 1, 2025, the Payroll Specialist began saving physically signed timesheets that document allocations to grants. Beginning August 1, 2025, allocations to grants are captured within the payroll system, ADP, along with the supervisor approval. The Payroll Specialist verifies each line on the timesheet is approved, which the system requires for the employee to receive payment. Anticipated completion date: Corrective action of signed allocation timesheets was implemented July 1, 2025. Corrective action of allocations to grants within ADP was implemented August 1, 2025.

View Audit 407369

Finding 1223784 (2024-002)

Material Weakness 2024

City of Santa Maria

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

U.S. Department of Housing and Urban Development Community Development Block Grant – Assistance Listing No. 14.218 Recommendation: We recommend the City implement policies and procedures to ensure that the Federal Funding Accountability and Transparency Act (FFATA) reporting occurs for all subawards...

U.S. Department of Housing and Urban Development Community Development Block Grant – Assistance Listing No. 14.218 Recommendation: We recommend the City implement policies and procedures to ensure that the Federal Funding Accountability and Transparency Act (FFATA) reporting occurs for all subawards of $30,000 or more for all federal awards and that the reporting be performed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Finance Department will ensure that all departments are aware of this compliance requirement and ensure reporting requirements are performed timely in relation to subawards. Name(s) of the contact person(s) responsible for corrective action: Rebecca Campbell, Finance Director Planned completion date for corrective action plan: July 2026

View Audit 407251

Finding 1223690 (2024-001)

Material Weakness 2024

WHITE BUFFALO, INC.

CT

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

Action Taken: The Organization has re-evaluated its internal controls related to grant budgeting with Federal agencies and cost billing expectations. The updated controls will be implemented in the next fiscal year.

View Audit 407180

Finding 1223589 (2024-001)

Material Weakness 2024

John Stark Regional High School

NH

Subrecipient Monitoring Reporting Significant Deficiency

We created a procedure and ensured the appropriate staff members know their responsibilities in filing time and effort documentation

View Audit 407020

Finding 1223571 (2024-004)

Material Weakness 2024

County of Imperial

CA

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

2024-004 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA111008 and 2021 Compliance Requirements: Reporting Type of Finding:...

2024-004 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA111008 and 2021 Compliance Requirements: Reporting Type of Finding: Significant Deficiency Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: ICWDO acknowledges the recommendation and is actively working on a remedy and on the development of formal policies as recommended, which will assist ICWDO’s fiscal team in ensuring that all reports are appropriately reconciled. ICWDO acknowledges the recommendations from finding 2021-010 related to a formalization of the Administrative/fiscal processes and protocols to ensure that procedures are consistently followed to guarantee that reports agree to the amounts recorded in the general ledger and SEFA. Additionally, the recommendation specifics that protocols to ensure the separation of duties are featured in the policy. ICWDO operates under WIOA guidelines and follows County fiscal/administrative policies. Internal policies that include formal controls and procedures to ensure that monthly reports and general ledgers are consistent, with clear segregation of duties will be formally adopted. Aspects of these policies will include: • Protocol for preparation of monthly reports by the fiscal manager, and approval and signature by ICWDO Director • Protocol for preparation of closeouts that will provide the hierarchy of development, review, and approval for future reference. • Schedule monthly closeout meetings with the fiscal department and administration to ensure that documents are reviewed separately, and issues are addressed promptly. • Protocol for Policy Committee review, comment and direction, and approval for implementation by vote of the full workforce development board. ICWDO anticipates to implement the corrective action by December 31, 2025. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2025

View Audit 406996

Finding 1223570 (2024-003)

Material Weakness 2024

County of Imperial

CA

Subrecipient Monitoring § 200.1 § 200.303 § 200.331 § 200.332 § 200.414

2024-003 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Ty...

2024-003 Program: WIOA Cluster Federal Financial Assistance Listing Number: 17.258, 17.259, 17.277, 17.278 Federal Grantor: U.S. Department of Labor Pass-Through: California Department of Employment Development Award No. and Year: AA011008 and 2019 Compliance Requirements: Subrecipient Monitoring Type of Finding: Material Weakness Management’s or Department’s Response: Imperial County Workforce Development Office (ICWDO) agrees with the finding. Views of Responsible Officials and Corrective Action Plan: The questions from finding 2021-008 relate to a formalization of the fiscal processes and protocols. ICWDO operates under WIOA guidelines and follows Imperial County’s fiscal policies. Internal policy will be formally updated to reflect compliance with WIOA regulations, as well as Imperial County policies. These policies will include formal controls and procedures to evaluate each subrecipient’s risk of noncompliance. Once the formal procedure is drafted, it will go through the ICWDO Policy Committee for comment and direction, and then finally reviewed and approved for implementation by the full Workforce Development Board. Additionally, for any future Memorandums of Understanding (MOUs) between this Imperial County department and any outside agency, there will be an additional step to include review by Imperial County Counsel to reflect that recital around the funding source will specify the following required information: • Federal Award Identification Number • Federal award date of award to recipient by the Federal agency • Name of Federal awarding agency • CFDA Number • Specific identification of whether the award is research and development ICWDO will develop internal policies for formalizing all subrecipient monitoring process. ICWDO operates under WIOA guidelines for monitoring; therefore a formal internal policy for future contracts will be developed and implemented using the usual review and approval procedures followed by the department. ICWDO will develop a formal internal documentation system, with appropriate checks and signatures, for the evaluation and assessment of each subrecipient’s risk of noncompliance. ICWDO will utilize this formal process to properly document the risk assessment of all subrecipients. ICWDO anticipates to implement the corrective action by December 31, 2025. Name of Responsible Person: Priscilla A Lopez, ICWDB Director Implementation Date: December 31, 2025

View Audit 406996

Corrective Action Plans

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