Corrective Action Plans

Finding 1154180 (2024-006)

Material Weakness 2024

Evangeline Booth Residence, Inc., A Florida Corporation

FL

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Finding 2024-006 Comments on the Finding and Each Recommendation We agree two tenants were not reimbursed their security deposits timely. This is due in part to staffing issues onsite as well as not having an address to forward the security deposits to upon the former tenant’s demise. Action(s) Take...

Finding 2024-006 Comments on the Finding and Each Recommendation We agree two tenants were not reimbursed their security deposits timely. This is due in part to staffing issues onsite as well as not having an address to forward the security deposits to upon the former tenant’s demise. Action(s) Taken or Planned on the Finding Management will review the processes and procedures with site personnel to strengthen controls over the refund of tenant security deposits. If we are late due to missing appropriate forwarding addresses, we will add documentation in the tenant files of those efforts to support our compliance with HUD procedures.

View Audit 367098

Finding 1154168 (2024-003)

Material Weakness 2024

Industrial Technology Institute Dba Mi Manufacturing Tech Center

MI

Subrecipient Monitoring Procurement, Suspension & Debarment Cash Management § 200.305

Condition: The Organization did not have the appropriate controls in place over FFATA reporting and did not file the required reports. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. Planned Corrective Ac...

Condition: The Organization did not have the appropriate controls in place over FFATA reporting and did not file the required reports. Further, while the Organization had written procedures over cash management, they were outdated and did not reflect the current staffing model. Planned Corrective Action: Reporting was completed in SAM.gov in May 2025 for subrecipient subaward amount based on the award period running from calendar periods of July to June. Written internal MMTC procedures regarding cash management will be updated and will include the current staff. Contact person responsible for corrective action: Alan Kowalewski Anticipated Completion Date: 10/31/2025

View Audit 367090

Finding 1154166 (2024-004)

Material Weakness 2024

City of Longview

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-004 Finding caption: The city did not have adequate internal controls and did not comply with federal procurement requirements. Name, address, and telephone of City contact person: Lisa Wolff, Finance Director PO Box 128 Longview, WA 98632 (360) 442-5036 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). In response to the issues identified, the city is taking the following steps: 1. Rewriting Procurement Manual o The city passed a resolution in August to update the city’s procurement policy. The new policy will include flow charts and links to Title 2 U.S. Code of Federal Regulations (CFR) Part 200 and applicable RCWs to ensure the City is following required procurement processes. The procurement policy updates are expected to be completed by the end of 2025. 2. Checklist Creation o The city will create a checklist as part of the procurement policy. This checklist will guide city staff through the proper processes and document the steps taken. Status of Identified Errors • The agreement with the organization currently operating the city’s homeless shelter is expiring in the near future. The city is currently going through the bidding process for a new operator. Conclusion The City acknowledges that the procurement policy was not followed upon receipt of grant funding. The City is working on new policies and procedures that will ensure that proper procurement processes are followed moving forward. Upon completion of the updates to the procurement process, the City can supply a copy of the new process at your request. Anticipated date to complete the corrective action: No later than December 31, 2025

View Audit 367073

Finding 1154165 (2024-002)

Material Weakness 2024

City of Longview

WA

Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-002 Finding caption: The city did not have adequate internal controls and did not comply with federal subrecipient monitoring, underwriting and maximum per-unit subsidy requirements. Name, address, and telephone of City contact person: Lisa Wolff, Finance Director PO Box 128 Longview, WA 98632 (360) 442-5036 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Corrective Action Plan In response to the issues identified, the city has taken and is continuing to take the following steps: 1. Create a subrecipient monitoring schedule o The city plans to monitor two subrecipients by the end of the city’s 2025 HUD fiscal year. One subrecipient is scheduled to be monitored in October. 2. Provide new guidance to subrecipients o The city will provide new guidance through monitoring to subrecipients that includes: i. Ensuring that all checklists meet HQS standards. ii. Rental contracts are review by the city. iii. Income eligibility evaluations and revaluations are done properly. iv. Funding is spent properly. 3. New underwriting checklists, policies and procedures o The city will work to develop new underwriting policies and procedures that will ensure federal requirements are met. The city will use HUD-provided checklists with certifying signatures for underwriting and thoroughly document that all requirements were met. 4. Underwriting Approvals o All underwriting will be sent to the department director for review and approval. The approvals will include the maximum per-unit subsidy calculations. Status of Identified Errors • The city will perform two monitoring visits in 2025 to ensure subrecipient compliance with federal standards. The city will distribute new guidance during those monitoring visits. City staff members have received new underwriting training earlier this year to fully understand all requirements. Conclusion The turnover in City staff exposed gaps in training for several of these factors. The City is closing these gaps by developing monitoring policies, risk ratings, and performing monitoring this year. With the improvements for subrecipient monitoring and development of new policies and procedures for underwriting, the City will comply with HUD requirements. Anticipated date to complete the corrective action: No later than December 31, 2025

View Audit 367073

Finding 1154164 (2024-003)

Material Weakness 2024

City of Longview

WA

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Longview January 1, 2024, through December 31, 2024 This schedule presents the corrective action the City is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-003 Finding caption: The city did not have adequate internal controls and did not comply with federal reporting requirements. Name, address, and telephone of City contact person: Lisa Wolff, Finance Director PO Box 128 Longview, WA 98632 (360) 442-5036 Corrective action the auditee plans to take in response to the finding: (If the auditee does not concur with the finding, the auditee must list the reasons for disagreement). Corrective Action Plan In response to the issues identified, the City has taken, and is continuing to take, the following steps: 1. Create a contract review checklist o The city will create a new checklist for federal contracts to ensure compliance with reporting and included language. 2. Contract finalization and reporting o Upon execution of subaward contracts, the City will ensure that all subawards are entered into the FFATA reporting system on SAM.GOV as required. A city staff member will certify that reporting information has been entered for each subaward contract. Status of Identified Errors • The city has entered all 2024 subawards into the FFATA reporting system. The City will ensure that all 2025 subawards are entered into the FFATA system once subaward contracts are executed. Conclusion The turnover within city staff created a gap in the reporting requirements in SAM.GOV. The City of Longview is committed to improving its internal controls and will continue to develop processes and checklists to ensure accurate reporting. Anticipated date to complete the corrective action: No later than December 31, 2025

View Audit 367073

Finding 1154163 (2024-002)

Material Weakness 2024

Housing Authority of the City of Dothan

AL

Questioned Costs Cash Management HUD Housing Programs

2024-002 – ALN 14.881 – Moving to Work Demonstration Program – Allowable Activities 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: Samuel Crawford, Chief Execu...

2024-002 – ALN 14.881 – Moving to Work Demonstration Program – Allowable Activities 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: Samuel Crawford, Chief Executive Officer Projected Completion Date: Ongoing work in progress. No completion date can currently be determined.

View Audit 367072 Questioned Costs: $1

Finding 1154143 (2024-003)

Material Weakness 2024

Adams Housing Authority

MA

HUD Housing Programs Internal Control / Segregation of Duties Subrecipient Monitoring

Auditee’s Response and Planned Corrective Action The Adams Housing Authority will ensure timely submission of the unaudited FDS going forward. Planned Implementation Date of Corrective Action: June 1, 2025 Person Responsible for Corrective Action: William Schrade, Executive Director

View Audit 367068

Finding 1154137 (2024-004)

Material Weakness 2024

American Association of Community Colleges

DC

Questioned Costs Subrecipient Monitoring Reporting

To address this finding, AACC will continue to request that all contracts be reviewed by the Chief Financial Officer prior to execution based on AACC’s Financial Policies and Procedures (page 25). Signed copies of the agreement will be held on file within the accounting department and the party exec...

To address this finding, AACC will continue to request that all contracts be reviewed by the Chief Financial Officer prior to execution based on AACC’s Financial Policies and Procedures (page 25). Signed copies of the agreement will be held on file within the accounting department and the party executing the agreement.

View Audit 367061 Questioned Costs: $1

Finding 1154136 (2024-003)

Material Weakness 2024

American Association of Community Colleges

DC

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

To address this finding, AACC will adhere to the financial policies and procedures properly documenting procurement decisions for goods and services with a total cost of $25,000 or greater. (Financial Policies and Procedures, pages 25, 45). In the event of “Sole Service Providers”, staff will docume...

To address this finding, AACC will adhere to the financial policies and procedures properly documenting procurement decisions for goods and services with a total cost of $25,000 or greater. (Financial Policies and Procedures, pages 25, 45). In the event of “Sole Service Providers”, staff will document the circumstances as such for recording. Effective immediately, all projects will be reviewed by a team assembled within the association, (Staffing to be determined by the President/CEO). A staff member, housed in the President’s Office with research and using a scorecard, assess and present potential opportunities to the President/CEO for approval to proceed. Approved opportunities will be reviewed by the team along with the department head making the request. There will be a collaborative effort of the scope of the project along with the budget necessary to implement the project. All parties will sign-off on their respective steps prior to the full package being presented to the President/Chief Executive Officer for final approval. A checklist will be used to monitor the process. All vendors written into the agreement will be vetted through a process that will include the rationale for their selection.

View Audit 367061 Questioned Costs: $1

Finding 1154135 (2024-002)

Material Weakness 2024

American Association of Community Colleges

DC

Questioned Costs Subrecipient Monitoring § 200.332

To address this finding, AACC will adhere to the financial policies and procedures properly documenting the fraud risk assessments to determine the level of risk (Low, Medium, High), and will properly document all necessary monitoring procedures (Financial Policies and Procedures, pages 45-53). Addi...

To address this finding, AACC will adhere to the financial policies and procedures properly documenting the fraud risk assessments to determine the level of risk (Low, Medium, High), and will properly document all necessary monitoring procedures (Financial Policies and Procedures, pages 45-53). Additionally, AACC has developed a risk assessment policy that will accompany AACC’s Subrecipient Award and Monitoring Policy developed in 2021. The appropriate signatures and corrective action plans and follow up with be managed in a timely manner.

View Audit 367061 Questioned Costs: $1

Finding 1154134 (2024-001)

Material Weakness 2024

American Association of Community Colleges

DC

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring § 200.403

To address this finding, AACC will adhere to the financial policies and procedures requiring all necessary itemized information be submitted to accounting with the proper signatures for review and approval. (Financial Policies and Procedures, page 26) Additionally, a tracking document will be utiliz...

To address this finding, AACC will adhere to the financial policies and procedures requiring all necessary itemized information be submitted to accounting with the proper signatures for review and approval. (Financial Policies and Procedures, page 26) Additionally, a tracking document will be utilized by the project manager outlining all expenditure reporting and invoices for each of the sub-award recipients. This document will be reviewed during the meeting with the accounting services department for reconciliation with the transactions reported in AACC’s accounting systems. (Financial Policies and Procedures, page 42).

View Audit 367061 Questioned Costs: $1

Finding 1154101 (2024-003)

Material Weakness 2024

Town of Oxford Connecticut

CT

Procurement, Suspension & Debarment Subrecipient Monitoring

FINDING 2024-003 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Description of Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awar...

FINDING 2024-003 – SIGNIFICANT DEFICIENCY- PROCUREMENT AND SUSPENSION AND DEBARMENT- INTERNAL CONTROL OVER VERIFICATION AGAINST THE SYSTEM FOR AWARD MANAGEMENT (“SAM”) Description of Finding: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, (Uniform Guidance) requires compliance with provisions of procurement, suspension, and debarment. Non-federal entities are required to ensure that they do not award contracts or make subawards to any parties that are suspended or debarred from receiving federal funds. This verification may be accomplished by checking the System for Award Management (SAM). The Town does not have a process in place to check that vendors are not suspended or debarred by checking the System for Award Management (SAM). Statement of Concurrence or Nonconcurrence: The Town agrees with the audit finding. Corrective Action: The Town will establish policies and procedures to ensure vendors are not suspended or debarred by checking the System for Award Management (SAM) and maintain documentation showing that verification. Name of Contact Person: George Temple, First Selectman, (203) 888-2543 Ext. 3034 Projected Completion Date: June 30, 2025

View Audit 366990

Finding 1153880 (2024-003)

Material Weakness 2024

Ho-Chunk Housing and Community Development Agency, Inc.

WI

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

Finding 2024-003 – Eligibility Assistance Listing No. 14.867 – Indian Housing Block Grant Condition: Pursuant to testing of eligibility and internal controls over eligibility, auditors noted the following control deficiency and noncompliance: • Seven tenants did not have an annual recertification or...

Finding 2024-003 – Eligibility Assistance Listing No. 14.867 – Indian Housing Block Grant Condition: Pursuant to testing of eligibility and internal controls over eligibility, auditors noted the following control deficiency and noncompliance: • Seven tenants did not have an annual recertification or inspection completed. Recommendation: We recommend that the Agency strengthen its internal controls over eligibility to monitor all relevant information and documentation affecting the eligibility process. Corrective Action Plan: 1. Implement Tracking System o Establish/Update the tracking log (electronic) to record due dates for all tenant annual recertifications and inspections. o Assign responsibility to a designated staff member for updating and monitoring the log monthly. 2. Supervisory Review o Require quarterly review of the tracking log to ensure all inspections and recertifications are current. 3. Corrective Action on Missing Inspections o Immediately complete any outstanding inspections and recertifications for the seven files. Name of Contact Person Responsible for Corrective Action Plan: Raven Rosin Anticipated Completion Date: November 1, 2025

View Audit 366937

Finding 1153874 (2024-006)

Material Weakness 2024

Chicago Housing Authority

IL

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

Finding 2024-006 I. Procurement, Suspension and Debarment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. As background context, the previous Chief Legal Officer, at the request of the previous CEO, reviewed the original inte...

Finding 2024-006 I. Procurement, Suspension and Debarment – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: CHA Management concurs with the finding. As background context, the previous Chief Legal Officer, at the request of the previous CEO, reviewed the original intergovernmental agreement (IGA) and determined that the agreement had not expired and required no additional board approval or agreement. This is why each year since, Legal has provided authorization for purchase order creation and payment to Chicago Police Department (CPD). The agency is working with CPD to formalize a new IGA. Contact Person: Shelia Johnson, Deputy Chief Procurement Anticipated Completion Date: End of 4th Qtr. 2025

View Audit 366932 Questioned Costs: $1

Finding 1153870 (2024-002)

Material Weakness 2024

Chicago Housing Authority

IL

HUD Housing Programs Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303

Finding 2024-002 N. Special Tests and Provisions: N17. Environmental Contaminants Testing and Remediation – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Under the recent Property and Asset Management (PAM) reorganization and CHA’s Year of Renewal, the Healthy Homes...

Finding 2024-002 N. Special Tests and Provisions: N17. Environmental Contaminants Testing and Remediation – Assistance Listing No. 14.881 Corrective Action Plan: Response/Planned Actions: Under the recent Property and Asset Management (PAM) reorganization and CHA’s Year of Renewal, the Healthy Homes Division was established to identify and address historic indoor environmental health hazards and proactively engage CHA programs in primary prevention strategies. In addition to regulatory lead and asbestos compliance, the Healthy Homes team will engage on mold, pest/pesticides, indoor air quality, and other indoor environmental concerns. Strategies include, but are not limited to: • Establish a compliance assurance protocol and tracking system and engage appropriate regulatory agencies (HUD, Illinois Department of Public Health, U.S. Environmental Protection Agency, Chicago Department of Public Health) • Establish records management schedule related to inspections, abatement or remediation, and clearance testing • Draft Quality Assurance Performance Plan and Scientific Integrity Policy • Track, route, and review applicable healthy homes-related work orders • Create screening and assessment criteria (for inspection schedules) • Provide basic environmental health training to CHA staff and media-specific training to appropriate programs (for instance, mold cleanup for Property Operations Managers) • Coordinate training and review certification/license of CHA contractors (construction vendors and property management firms) • Establish policies, procedures, and best practices guidance Timeline: Spring/Summer 2025: - Healthy Homes Team (within PAM) established and full team build out begins. Team hiring will be complete by September 2025. o Healthy Homes Director (1) o Environmental Health and Safety Managers (2) o Environmental Health and Safety Analysts (2) o Quality Assurance/Quality Control Analyst (1) - Coordinated renovation, repair, and painting (RRP) training for construction vendors, inhouse construction project management, and Property Management firms (16 courses, 20 participants each, between June and October). RRP is a federal regulation that requires lead-safe work practices in targeted housing. Established CHA’s RRP Policy that requires all construction and maintenance staff and vendors to be RRP certified by November 2025. All maintenance, repair, renovation, rehabilitation, or construction work will be done under RRP, in both target and non-target housing. Current and ongoing into 2026: - Drafting policies, procedures, and best practices guidance for construction and property operations, including but not limited to life-cycle abatement manual, lead safe work practices, safe mold clean-up and best practices, and lead abatement during unit turns - Creating a data management system which includes relevant unit inventory and recurrent inspection schedules. Contact Person: Leonard Langston, Jr., Interim Chief Property Officer Anticipated Completion Date: Q1 2026

View Audit 366932

Finding 1153868 (2024-001)

Material Weakness 2024

Port of Clarkston

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Port of Clarkston January 1, 2024 through December 31, 2024 This schedule presents the corrective action the Port is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE Port of Clarkston January 1, 2024 through December 31, 2024 This schedule presents the corrective action the Port is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2024-001 Finding caption: The Port did not have adequate internal controls and did not comply with federal suspension and debarment requirements.Name, address, and telephone of Port contact person: Kim Petrie, Accounting and Finance Manager 849 Port Way Clarkston, WA 99403 (509) 758-5272 Corrective action the auditee plans to take in response to the finding: The Port of Clarkston has implemented internal controls for federally funded projects that all contractors will be verified for suspension and debarment by obtaining written certification, adding a clause or condition into the contract that states the government contractor is not suspended or debarred, or checking for exclusion records in the U.S General Services Administration’s System for Award Management at SAM.gov, regardless of threshold amount and prior to executing contract or purchasing. The identical finding for FY 2024 suspension and debarment (S&D), carry over from FY 2023 can be partially attributed to timing of federal single audit with the Washington State Auditor’s Office (SAO). In September 2024 (FY 2023) the Port was made aware of non-compliance with S&D and immediately made changes to internal controls. Purchases made prior (January – May of 2024) were self-reported non-compliant for S&D to SAO and corrections to internal controls were made per the “Corrective Action Plan for Findings Reported Under Uniform Guidance” dated 9/5/24 Anticipated date to complete the corrective action: 9/5/2024

View Audit 366930

Finding 1153798 (2024-004)

Material Weakness 2024

Full Circle Communities, INC

IL

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

Finding #2024-004 Comments on the Finding and Each Recommendation: Hollywood House Limited Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending December 31, 2024. Action(s) taken or planned on the finding: Managem...

Finding #2024-004 Comments on the Finding and Each Recommendation: Hollywood House Limited Partnership did not furnish HUD with a complete annual financial report within ninety (90) days following the end of the fiscal year ending December 31, 2024. Action(s) taken or planned on the finding: Management concurs with the finding and the recommendation. Management is in the process of implementing internal control processes to ensure compliance with applicable regulations. The audit report for the year ended December 31, 2024 has been submitted to HUD. No further action is required.

View Audit 366892

Finding 1153797 (2024-003)

Material Weakness 2024

Full Circle Communities, INC

IL

Special Tests & Provisions Procurement, Suspension & Debarment Subrecipient Monitoring

Finding #2024-003 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, Hollywood House Limited Partnership paid entity expenses of $278,645 in excess of surplus cash. Action(s) taken or planned on the finding: Management concurs with the finding and the recommend...

Finding #2024-003 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, Hollywood House Limited Partnership paid entity expenses of $278,645 in excess of surplus cash. Action(s) taken or planned on the finding: Management concurs with the finding and the recommendation.

View Audit 366892

Finding 1153796 (2024-002)

Material Weakness 2024

Full Circle Communities, INC

IL

HUD Housing Programs Special Tests & Provisions Subrecipient Monitoring

Finding #2024-002 Comments on the Finding and Each Recommendation: During the year ended December 31, 2024, AR Preservation, LP prepaid management fees of $42,201. Action(s) taken or planned on the finding: The Agent will reduce the fees charged in the following periods by $42,201.

View Audit 366892

Finding 1153757 (2024-010)

Material Weakness 2024

City of Bangor

ME

Subrecipient Monitoring Cash Management

Management’s Response/Corrective Action Plan: Program managers review and approve each line of reimbursement on the monthly invoices to ensure the allowable costs. After the Grants Accounting Specialist attended a national grant management conference in MAR25, she has since put a plan in place reque...

Management’s Response/Corrective Action Plan: Program managers review and approve each line of reimbursement on the monthly invoices to ensure the allowable costs. After the Grants Accounting Specialist attended a national grant management conference in MAR25, she has since put a plan in place requesting copies of receipts to match a month of invoice (2x per year).

View Audit 366845

Finding 1153717 (2024-005)

Material Weakness 2024

City of Bangor

ME

Subrecipient Monitoring Reporting

Management’s Response/Corrective Action Plan: The Administrative conditions related to this issue include a delay in entitlement award which caused the City to not complete any IDIS Drawdowns until December 2024. However, during that time, program income was received, and the CDO understands that th...

Management’s Response/Corrective Action Plan: The Administrative conditions related to this issue include a delay in entitlement award which caused the City to not complete any IDIS Drawdowns until December 2024. However, during that time, program income was received, and the CDO understands that the report should have been filed to reflect COH at the deadline. The Community Development Officer consulted with staff from the Auditing firm in July 2023 to inquire about the relevance of FFATA and was told that these reports were not required because the City did not award CDBG funds to Subrecipients. However, several key awards made prior to 2022 were made pursuant to an executed Subrecipient Agreement and would be subject to this requirement. The CDO received clarification on this issue in the Fall of 2024 from HUD during a regional training of all CDBG entitlement communities. It is further understood that all CDBG funds, excluding that provided to income eligible beneficiaries is a Subrecipient for the purpose of FFATA. Pursuant to these findings, the Community Development Officer began revising the CDBG Policies and Procedures to implement these reporting obligations, including: 1. Monthly reports submitted on the FFATA website for any award made to an entity not expressly deemed an eligible beneficiary. This includes nonprofit and for-profit entities completing an approved activity which provides a benefit to low- and moderate-income residents of Bangor. This does not include payments made to or on behalf of LMI individuals in the Homeowner Rehab or Down Payment Assistance programs, but may include all other grants or loans made over $30,000. This will be accomplished by additional training on the use of the online portal and the integration of City software into the project award and reporting process. 2. The CDO continues to review the Cash On Hand reporting process to implement changes which will prevent further delays in reporting. The CDO recently implemented a quarterly desk audit of all CDBG Financials and continues to improve Department efficiency in this area. In addition, staff will be cross-trained to complete this procedure to ensure that personnel changes do not impact the report filing. This will be accomplished by requiring that the Cash on Hand report be entered monthly and updated until the report is submitted at the end of the Quarter.

View Audit 366845

Finding 1153704 (2024-003)

Material Weakness 2024

White County

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2024-003 Finding Subject: COVID-10 Coronavirus State and Local Fiscal Recovery Funds-Suspension and Debarment Contact Person Responsible for Corrective Action: Elizabeth J. Billue Contact Phone Number and Email Address: 574-583-1515 libby.billue@whitecounty.in.gov Views of Responsible Offici...

FINDING 2024-003 Finding Subject: COVID-10 Coronavirus State and Local Fiscal Recovery Funds-Suspension and Debarment Contact Person Responsible for Corrective Action: Elizabeth J. Billue Contact Phone Number and Email Address: 574-583-1515 libby.billue@whitecounty.in.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The previous planned corrective action was implemented but did not correct the deficiency and the stated issue remains. An Ordinance Establishing a Grant Management Process for White County was approved in response to the original finding. This ordinance is provided annually, and as needed, to all departments as a reminder of the requirements. Although this ordinance was intended to provide direction to all county department grant applicants for proper internal controls, it does not specifically identify suspension and debarment. The Auditor previously met with the County Attorney to put a plan in place to make sure that a suspension and debarment clause is included in all federally funded projects, but a new County Attorney was brought in and the clause has not yet been included. Going forward, the County will require that a suspension and debarment clause be included in the contract or all vendors paid with federal grant dollars will now be checked for their status in SAM.gov. The new County Attorney is on board with the requirement and is working to implement a policy for all future contracts that includes a statement or certification that the vendor is not suspended, debarred or otherwise excluded. Anticipated Completion Date: Immediately, as of August 2025

View Audit 366842

Finding 1153678 (2024-004)

Material Weakness 2024

Pittsburgh Innovation District D/b/a Innovatepgh Partnership

PA

Subrecipient Monitoring § 200.332

Finding 2024-004: Subrecipient Monitoring U.S. Department of Commerce, Economic Development Cluster- Assistance Listing Number 11.307 Questioned Costs: Unknown Condition: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk...

Finding 2024-004: Subrecipient Monitoring U.S. Department of Commerce, Economic Development Cluster- Assistance Listing Number 11.307 Questioned Costs: Unknown Condition: The Organization does not have formal subrecipient monitoring policies and procedures in place to document the assessment of risk for subrecipients. Specifically, there is no documented review of subrecipient financial or performance reports, no formal risk assessments conducted prior to disbursement of funds, and no site visits or other monitoring activities to ensure compliance with award terms and federal regulations. In addition, the Organization does not have procedures in place to adequately review the subrecipient audits received, ensure that audit requirement language is included in each contract, or notify the subrecipient of the subaward ALN and amount that was paid during the year. Action: InnovatePGH will implement monitoring procedures for subrecipients, including risk assessment, site visits as deemed appropriate, and review of reporting and audits.

View Audit 366831

Finding 1153677 (2024-003)

Material Weakness 2024

Pittsburgh Innovation District D/b/a Innovatepgh Partnership

PA

Subrecipient Monitoring Reporting

Finding 2024-003: Reporting U.S. Department of Commerce, Economic Development Cluster- Assistance Listing Number 11.307 Questioned Costs: Unknown Condition: The Organization did not comply with reporting requirements established under the Federal Funding Accountability and Transparency Act (FFATA) -...

Finding 2024-003: Reporting U.S. Department of Commerce, Economic Development Cluster- Assistance Listing Number 11.307 Questioned Costs: Unknown Condition: The Organization did not comply with reporting requirements established under the Federal Funding Accountability and Transparency Act (FFATA) - one subaward was not identified and reported. Action: InnovatePGH will review all new and existing contracts over $30,000, subject to federal funding sources, to ensure the contracts are properly entered into the FFATA system.

View Audit 366831

Finding 1153671 (2024-002)

Material Weakness 2024

Oregon Tilth, INC

OR

Subrecipient Monitoring § 200.303 § 200.332

FINDING – FINANCIAL STATEMENT 2024-001 Financial Statement Recommendation: We recommend that the Organization implement the necessary internal controls to ensure that accruals are properly recorded and the associated expenses and revenues are recorded in the proper period. Explanation of disagreemen...

FINDING – FINANCIAL STATEMENT 2024-001 Financial Statement Recommendation: We recommend that the Organization implement the necessary internal controls to ensure that accruals are properly recorded and the associated expenses and revenues are recorded in the proper period. Explanation of disagreement with audit findings: Management concurs with the finding and will implement effective internal controls to ensure that financial information is reported in accordance with GAAP. Action Plan: The Finance & Administration Director has updated the Accounting protocol guide and Grants Internal Control guide instructing staff how to identify accrual expense invoices. These policies establish procedures for recording accrual expense invoices to ensure that all expenses are properly recognized in the correct accounting period in accordance with Generally Accepted Accounting Principles (GAAP). This policy applies to all accounting and grant management staff responsible for processing and recording expense transactions, including accounts payable, month-end closing and journal entries, and other financial reporting activities. In addition, on Sept. 11, 2025, a training program was developed and administered to accounting staff to ensure they understand this policy. The Finance & Administration Director will conduct quarterly internal reconciliations and reviews to audit compliance and identify areas of error. This process is tracked in the Asana project management tool. The Finance Director will review all invoices for appropriate invoice dates so that accrued expenses will be posted to the correct period. And lastly, the Grants Finance Manager and Finance & Administration Director will review journal entries, financial statements, and key estimates (such as allowances for doubtful accounts or depreciation methods) further ensure accuracy. Name(s) of the contact people responsible for correction action: Renee Kempka, Finance & Administration Director U.S. Department of Agriculture 2024-002 Assistance Lising #10.163 – Market Protection Program Recommendation: The Organization should establish written policies and procedures regarding the contracting and monitoring of subrecipients that are in line with Uniform Guidance requirements, as well as establish organizational controls to ensure that such policies and procedures are being followed. Explanation of disagreement with audit findings: Management concurs with the finding and will implement effective internal controls to ensure that subrecipient monitoring is properly done and documented appropriately. Action taken in response to finding: Upon discovery of the initial audit finding, an accrual journal entry was created to correct the subrecipient invoicing between 2025 and 2024. The adjusting journal entries and updated financial statements were submitted to Kern & Thompson, who we engaged to conduct the financial audits. This altered previous financial statements for 2024 and 2025, and the SEFA. Action Plan: The late reporting was primarily due to delays in receiving invoices from the subrecipient after the fiscal year end closing. The Education and Advocacy Director will send out quarterly reminders to partners informing them of the invoice due dates. Subrecipient partners will be expected to submit the invoice within the allotted time of 30 days after the closing of the reporting period. The Grant Finance Manger will conduct a review of all active subrecipient partners to ensure invoices have been received and recorded in the corresponding fiscal period for which the activity was conducted. If the invoice is not received, a courtesy reminder email and/or phone call will be sent to let the partner know that if the invoice is received outside of the 30 days, it will no longer be allowable. 21 days after the close of a quarter, the Finance Director and the Grants Finance Manager will meet and audit the sub-recipient budget against what has been submitted for payables. A list of partners who have not submitted invoices will be created with subsequent intent to contact the organization. This task will be tracked for completion according to timelines in the Grant Internal Control Asana project. Name(s) of the contact people responsible for correction action: Abigail Soto, Grants Finance Manager, Ben Bowell, Education & Advocacy Director and Renee Kempka, Finance & Administration Director Plan completion date for corrective action plan: 09/11/25

View Audit 366826

Corrective Action Plans

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