Corrective Action Plans

Finding 1163358 (2024-007)

Material Weakness 2024

ND

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

2024-007 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – IMPROPER REPORTING OF EXPENDITURES – ALN 21.027 – SIGNIFICANT DEFICIENCY & OTHER NONCOMPLIANCE Condition Pembina County did not properly report expenditures and obligations on the March 31, 2024, Project and Expenditure Report for the Co...

2024-007 – CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS – IMPROPER REPORTING OF EXPENDITURES – ALN 21.027 – SIGNIFICANT DEFICIENCY & OTHER NONCOMPLIANCE Condition Pembina County did not properly report expenditures and obligations on the March 31, 2024, Project and Expenditure Report for the Coronavirus State and Local Fiscal Recovery Funds program. The total cumulative and current expenditures and cumulative and current obligations reported were understated by $17,797.40. Corrective Action Plan: We agree, Pembina County will ensure obligations and expenditures for the SLFR grant are properly stated in future periods. Anticipated Completion Date: FY 2025

View Audit 372866

Finding 1163357 (2024-006)

Material Weakness 2024

Pembina County Water Resource District

ND

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

2024-006 – WATERSHED REHABILITATION PROGRAM – LACK OF CONTROLS AND IMPROPER PERIOD OF PERFORMANCE – WRD – ALN 10.916 – MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition Pembina County Water Resource District applied costs to the Watershed Rehabilitation Program after the period of performance, wh...

2024-006 – WATERSHED REHABILITATION PROGRAM – LACK OF CONTROLS AND IMPROPER PERIOD OF PERFORMANCE – WRD – ALN 10.916 – MATERIAL WEAKNESS & MATERIAL NONCOMPLIANCE Condition Pembina County Water Resource District applied costs to the Watershed Rehabilitation Program after the period of performance, which shows a lack of internal controls. The total value of the expenses past the period of performance end date was approximately $170,468 which occurred through September 14, 2024, more than a month past the period of performance end date. Corrective Action Plan: We agree we will ensure costs are in the proper period of performance going forward Anticipated Completion Date: FY2025

View Audit 372866 Questioned Costs: $1

Finding 1163340 (2024-012)

Material Weakness 2024

Canadian County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Board of County Commissioners will work with all County Officials to go over all grants and federal monies that the County receives to ensure that proper internal controls are implemented.

View Audit 372861

Finding 1163339 (2024-010)

Material Weakness 2024

Canadian County

OK

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties

We will work to implement a Risk Assessment plan over federal grants. We will implement controls to make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compli...

We will work to implement a Risk Assessment plan over federal grants. We will implement controls to make sure we comply with grant requirements and that federal funds are expended in accordance with grant agreements and in a timely manner. We will ensure employees have the current and correct compliance supplement to work from.

View Audit 372861

Finding 1163221 (2024-006)

Material Weakness 2024

Greater Columbia Accountable Community of Health

WA

Subrecipient Monitoring Allowable Costs / Cost Principles § 200.303

The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.945 Recommendation: We recommend that the Organization implements policies and procedures to perform subrecipient monitoring and that monitoring is formally documented and approved. Exp...

The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.945 Recommendation: We recommend that the Organization implements policies and procedures to perform subrecipient monitoring and that monitoring is formally documented and approved. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We will implement policies and procedures to implement subrecipient monitoring. Names of the contact persons responsible for corrective action: Jan Warren, Director of Finance & Amber Henderson, Chief Organization Excellence & Strategy Officer Planned completion date for corrective action plan: December 31. 2025.

View Audit 372710

Finding 1163217 (2024-002)

Material Weakness 2024

Greater Columbia Accountable Community of Health

WA

Subrecipient Monitoring § 200.305

The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request ...

The Department of Health and Human Services/Centers for Disease Control and Prevention – Assistance Listing No. 93.495 Recommendation: We recommend that the Organization implement policies and procedures to ensure subrecipients are paid within 30 days of when the billing is received. If the request is believed to be improper, support for the delay in payment should be maintained. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have established a process to review and track accounts payable, including monthly reviews of outstanding bills, partner invoices, and partner compliance. Furthermore, we have added additional accounting staff focused on disbursements for subrecipients involved in federal grant programs. Finally, we have a process in place to document the receipt of partner invoices submitted to GHN for payment as well as a record of payment approval and/or revisions necessary. Names of the contact persons responsible for corrective action: Jan Warren, Director of Finance & Amber Henderson, Chief Organization Excellence & Strategy Officer Planned completion date for corrective action plan: December 31, 2025

View Audit 372710

Finding 1163192 (2024-001)

Material Weakness 2024

City of Clarksville Gas & Water

TN

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.502 § 200.510

Management concurs with the finding. Procedures have been implemented to enhance year-end review of grant activity, including reconciliation of grant expenditures and receivables to the SEFA and general ledger prior to issuance. The Departments’ will continue to monitor these processes to ensure com...

Management concurs with the finding. Procedures have been implemented to enhance year-end review of grant activity, including reconciliation of grant expenditures and receivables to the SEFA and general ledger prior to issuance. The Departments’ will continue to monitor these processes to ensure compliance with the Uniform Guidance reporting requirements. Anticipated Completion Date: October 31, 2025

View Audit 372690

Finding 1163077 (2024-003)

Material Weakness 2024

Dayton School District #8

OR

Reporting Subrecipient Monitoring § 200.508 § 200.510

Finding 2024-003 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 84.010 Grants to Local Education Agencies (Title I) Name of Federal Agency: U.S. Depa...

Finding 2024-003 - Schedule of Expenditures of Federal Awards (Material Weakness) CFDA Title and Number 84.425 Education Stabilization Fund Name of Federal Agency: U.S. Department of Education CFDA Title and Number 84.010 Grants to Local Education Agencies (Title I) Name of Federal Agency: U.S. Department of Education Compliance/Internal Control over Compliance: Auditee Responsibilities Criteria: CFR Part 200.508, CFR Part 200.510, Auditee Responsibilities state that the auditee must prepare the Schedule of Expenditures of Federal Awards, which must list individual Federal awards by Federal Agency, including the total Federal awards expended, name of the pass-through entity, CFDA number, and total amount provided to subrecipients. The information contained in the Schedule of Expenditures of Federal Awards should be derived from and relate directly to the underlying accounting and other records used to prepare the financial statements. Condition: The Schedule of Expenditures of Federal Awards (SEFA) was presented for audit on an untimely basis, and with values that were not reconciled with the general ledger. Cause: The District staff had insufficient training or support to prepare the SEFA and ensure that it was reconciled with general ledger amounts. District management did not have monitoring policies to recognize and correct the deficiency. Effect or Potential Effect: Errors in recording and reporting of revenues and expenditures of federal awards may not be detected and/or corrected. Because the Auditee’s SEFA that was presented for audit was completed incorrectly, and not reconciled to the general ledger, the SEFA was materially misstated, prior to auditor's correction recommendations. Questioned Cost: No Context: Lack of adequate controls over the Schedule of Expenditures of Federal Awards and related accounting resulted in the following:  SEFA was originally presented for auditors with incorrect information.  SEFA was not presented for auditors on a timely basis.  No reconciliation between federal expenditures reported on the GL and the SEFA was presented. Repeat of a Prior-Year Finding: No Recommendation: We recommend that the District establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFAs. Internal controls should be designed to prevent, detect, or correct errors in a timely manner by performing periodic reconciliations of the SEFA information to the general ledger throughout the fiscal year. The District should provide appropriate training to staff who are assigned to prepare and review the SEFA. District’s Response: The District acknowledges the deficiencies. Corrective Action Plan: The District will establish policies and procedures to ensure that all Federal awards are identified and reported accurately on future SEFA reports. Planned Implementation Date: August 1, 2025 Responsible Person: Director of Business Services, Yamhill County School District No. 8

View Audit 372646

Finding 1163060 (2024-001)

Material Weakness 2024

Town of York

ME

Procurement, Suspension & Debarment Subrecipient Monitoring

Management’s response/corrective action plan: YSD acknowledges the deficiency and attributes it to a lack of knowledge on the part of the Special Education group for this requirement. The appropriate personnel have been notified and have been provided sufficient training materials to address this is...

Management’s response/corrective action plan: YSD acknowledges the deficiency and attributes it to a lack of knowledge on the part of the Special Education group for this requirement. The appropriate personnel have been notified and have been provided sufficient training materials to address this issue. It is, however, possible that since this finding covers only the FY24 fiscal year, that additional violations have occurred in the FY25 fiscal year.

View Audit 372626

Finding 1163018 (2024-001)

Material Weakness 2024

Community Based Public Safety Collective, Inc.

NJ

Subrecipient Monitoring Period of Performance Reporting § 200.512

Auditors Recommendation: CBPSC should ensure that its records are completed and reconciled in a timely manner, so that the single audit can be performed and completed on time, and the reporting package and data collections form can be submitted before the deadline. Corrective Action Plan: Management...

Auditors Recommendation: CBPSC should ensure that its records are completed and reconciled in a timely manner, so that the single audit can be performed and completed on time, and the reporting package and data collections form can be submitted before the deadline. Corrective Action Plan: Management acknowledges that the reporting package and Data Collection Form for the 2023 audit were not filed by the required September 30, 2024 deadline. Management also acknowledges that this finding will appear for the next audit year, however to correct this and prevent recurrence of this issue the organization has implemented the following actions: Established external filing deadlines. Enhanced monitoring and tracking. Assignment of oversight responsibility. Improved coordination with external auditors. Staff Training. Anticipation Completion Date: These corrective actions were initiated in the 2025 fiscal year and will be fully in place for the 2025 audit cycle, ensuring timely submission by September 30. 2026 Management Statement: Management believes these corrective steps will ensure full compliance with federal reporting requirements going forward and prevent recurrence of late submissions. Responsible Individual: Managing Director, Fred Fogg

View Audit 372614

Finding 1163003 (2024-003)

Material Weakness 2024

Barry County, Missouri

MO

Subrecipient Monitoring § 200.1 § 200.331 § 200.332

The County has created a filing system for recipients of SLFRF funds and a calendar set to send reminder notices to get receipts and other information from recipients. The reminders will be set in 3 month increments from the time funds are awarded to recipient. Implementation will begin January 1, 2...

The County has created a filing system for recipients of SLFRF funds and a calendar set to send reminder notices to get receipts and other information from recipients. The reminders will be set in 3 month increments from the time funds are awarded to recipient. Implementation will begin January 1, 2026 with reminder notices set in calendar.

View Audit 372593

Finding 1163001 (2024-001)

Material Weakness 2024

Barry County, Missouri

MO

Subrecipient Monitoring Reporting Cash Management

The County Clerk and Treasurer will work with the accounts payable department to update and create spreadsheets and schedule a mid-year review of SEFA funds and grants. Implementation of spreadsheets is in progress and expected to be fully implemented by June 1, 2026.

View Audit 372593

Finding 1162992 (2024-003)

Material Weakness 2024

Red Lake County

MN

Subrecipient Monitoring

Summary of Corrective Action Previously Reported: The County will take corrective action to ensure compliance with federal subrecipient monitoring requirements and will review its procedures to ensure that all future subrecipient agreements include proper documentation of monitoring activities, incl...

Summary of Corrective Action Previously Reported: The County will take corrective action to ensure compliance with federal subrecipient monitoring requirements and will review its procedures to ensure that all future subrecipient agreements include proper documentation of monitoring activities, including communication of award terms, risk assessments, and verification that funds are expended in accordance with federal requirements. Anticipated Completion Date: December 31, 2025.

View Audit 372590

Finding 1162906 (2024-008)

Material Weakness 2024

City of Peabody

MA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the education stabilization grant for 2026, as well as into future periods.

View Audit 372554 Questioned Costs: $1

Finding 1162893 (2024-006)

Material Weakness 2024

City of Peabody

MA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the Title I grant for 2026, as well as into future periods.

View Audit 372554 Questioned Costs: $1

Finding 1162890 (2024-005)

Material Weakness 2024

City of Peabody

MA

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

Views of Responsible Officials and Planned Corrective Actions: The School District will immediately begin reissuing and recollecting the forms for the special education grant for 2026, as well as into future periods.

View Audit 372554 Questioned Costs: $1

Finding 1162880 (2024-002)

Material Weakness 2024

City of Hempstead, Texas

TX

Internal Control / Segregation of Duties Special Tests & Provisions Subrecipient Monitoring § 200.303 § 200.328

Finding 2024-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management agrees with the finding and will establish a formal review and approval process for all Section 3 quarterly and annual reports prepared and submitted by...

Finding 2024-002: Insufficient Documentation of Management Review of Section 3 Quarterly and Annual Reporting Planned Corrective Action: Management agrees with the finding and will establish a formal review and approval process for all Section 3 quarterly and annual reports prepared and submitted by the grant administrator to the Texas General Land Office. Going forward, the City Secretary will review each report for accuracy and completeness prior to submission, and evidence of this review, such as signed approval or email confirmation, will be retained in the grant files. The City anticipates implementing this procedure for all future reporting periods to ensure compliance with federal reporting and internal control requirements. Anticipated Completion Date: December 2025

View Audit 372549

Finding 1162878 (2024-001)

Material Weakness 2024

Portage County

OH

Reporting Subrecipient Monitoring § 200.328

The Mental Health and Recovery Board of Portage County will submit program final expenditures in the GFMS system within the grant close-out reporting period.

View Audit 372539

Finding 1162849 (2024-003)

Material Weakness 2024

Kitsap Rescue Mission

WA

Subrecipient Monitoring Procurement, Suspension & Debarment Cash Management § 200.302

Condition: Management did not retain evidence of the execution of the Organization’s internal controls over the review and or authorization of the payment or reimbursement of credit card charges during the year. Recommendation: Management should document the review and/or authorization of credit car...

Condition: Management did not retain evidence of the execution of the Organization’s internal controls over the review and or authorization of the payment or reimbursement of credit card charges during the year. Recommendation: Management should document the review and/or authorization of credit card charges and reimbursement. Views of responsible officials: The Organization will adopt a new policy on corporate credit cards with the following general provisions. Corporate credit cards may only be issued to the Executive Director and, if approved by the Executive Director, to the heads of shelter operations, and the Organization’s Accountant. All charges shall be made solely for goods or services for the use or benefit of the Organization. Use of the credit card for the purchase of gift cards or recurring automatic transactions can only be made by the Executive Director or the Organization’s Accountant after approval by Executive Director. Receipts shall be provided to the internal accountant monthly by the 5th day of the following month. The internal accountant shall prepare a summary of all charges highlighting any 1) that are not supported by a receipt, or 2) appear questionable, and also an allocation of each charge to the appropriate expense category for financial reporting. The summary and the credit card statement shall be provided to the Executive Director for review and approval. The Executive Director will spot check actual receipt documentation for credit card2 purchases of the Organization’s Accountant and the Shelter Director. In the case of the credit card used by the Executive Director, the summary and statement shall be reviewed and approved by the Treasurer or Board President. Any improper or unsupported transaction shall create a reimbursement obligation by the card holder to the Organization. Misuse of the credit card shall be a cause for discipline in accordance with the employment manual.

View Audit 372514

Finding 1162832 (2024-001)

Material Weakness 2024

The Booker T. Washington Community Center of Auburn, N.y., Inc.

NY

Subrecipient Monitoring Reporting § 200.512

Response: We agree with the finding presented by the auditors. The Organization’s annual financial statements have been delayed due to turn over in staff. The Organization has also hired a new bookkeeper and doesn’t anticipate delays to continue in the future. Responsible Party: Denise Farrington, E...

Response: We agree with the finding presented by the auditors. The Organization’s annual financial statements have been delayed due to turn over in staff. The Organization has also hired a new bookkeeper and doesn’t anticipate delays to continue in the future. Responsible Party: Denise Farrington, Executive Director Estimated Completion: 12/31/25

View Audit 372495

Finding 1162807 (2024-005)

Material Weakness 2024

Green Lake County

WI

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.320

Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over susp...

Recommendation: We recommend the County review and update procurement policies for the entire County to ensure it meets the minimum requirements of 2 CFR 200 for all federal grants and establish a procurement process in order to ensure this policy is followed which includes adding language over suspension and debarment. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The County is working on reviewing policies and procedures and updating as necessary. Further, training will be available to all those involved in grants. Name(s) of the contact person(s) responsible for corrective action: Jason Jerome Planned completion date for corrective action plan: December 31, 2025

View Audit 372450

Finding 1162801 (2024-002)

Material Weakness 2024

TOWN OF CHESTER

MA

Subrecipient Monitoring Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Condition: The Town has not documented in writing its policies regarding federal awards. Corrective Action Planned: The Town plans to draft and adopt policies. Anticipated Completion Date: 12/31/2025 Contact: Andrew Alward, Town Administrator

View Audit 372434

Finding 1162799 (2024-011)

Material Weakness 2024

Micronesian Legal Services Corporation

MP

Internal Control / Segregation of Duties Subrecipient Monitoring

Management’s Response and Corrective Action Plan: MLSC management acknowledges the finding and concurs with the auditor’s recommendation. Management would like to note that MSLC has an existing Petty Cash Policy, which was recently updated and approved by the Board of Directors to ensure full compli...

Management’s Response and Corrective Action Plan: MLSC management acknowledges the finding and concurs with the auditor’s recommendation. Management would like to note that MSLC has an existing Petty Cash Policy, which was recently updated and approved by the Board of Directors to ensure full compliance with LSC Financial Guide §3.2.5 that address the following: • Segregation of duties • Required monthly reconciliation of all petty cash funds • Allowable use of petty cash • Documentation necessary to support each petty cash disbursement • Procedures to follow in the event of overage or shortage in the fund Responsible person: Chief Fiscal Officer, Jocelyn Mallari Corrective action planned: The updated Petty Cash Policy is immediately implemented to strengthen internal control, ensure accountability, and prevent future loss or mismanagement. A monthly petty cash reconciliations for each office is scheduled. These corrective actions will ensure compliance with LSC requirements Anticipated completion date: Completed

View Audit 372427

Finding 1162797 (2024-009)

Material Weakness 2024

Micronesian Legal Services Corporation

MP

Subrecipient Monitoring Significant Deficiency

Management’s Response and Corrective Action Plan: See the response on finding 2024-009

View Audit 372427

Finding 1162796 (2024-008)

Material Weakness 2024

Micronesian Legal Services Corporation

MP

Subrecipient Monitoring Significant Deficiency

Management’s Response and Corrective Action Plan: Management agrees, and has addressed this as follows: Responsible person: Lee Pliscou MLSC Board of Directors approved a revised accounting manual in October 2025 which requires an annual cybersecurity assessment and response in compliance with LSC F...

Management’s Response and Corrective Action Plan: Management agrees, and has addressed this as follows: Responsible person: Lee Pliscou MLSC Board of Directors approved a revised accounting manual in October 2025 which requires an annual cybersecurity assessment and response in compliance with LSC Financial Guide § 2.5.3, together with a formal risk assessment of banking operations to identify and address vulnerabilities, as required by LSC Financial Guide § 3.2.1. Specifically, our cybersecurity policies include the following requirements: ● Perform (and document) an annual risk assessment ● Resolve any risk findings or conclusions ● Maintain physical access controls for servers and storage rooms ● Develop and periodically test an emergency disaster prevention and recovery plan ● Perform regular back up of electronic records and systems stored offsite or in a virtual environment with easy-to-use restoration options ● Formally assign computer and data security responsibilities The risk assessment process: ● Identifies the physical and digital assets susceptible to cyberattacks ● Identifies risks to those assets (risks should be evaluated annually for changes) ● Evaluates the risks (e.g., high, medium, or low) based on likelihood and impact ● Documents the results of the risk assessment, including the development and implementation of appropriate controls Finding 2024-008 LSC Financial Guide § 2.5.3 Electronic Data Processing and Cybersecurity, continued Also, per our new Accounting Manual, MLSC conducts a risk assessment of its electronic banking policies and procedures to identify areas that need additional safeguards and protections. We do this in conjunction with the annual cybersecurity risk assessment. As of November 2025, MLSC has contracted with a consultant to provide such an assessment, and the contractor has delivered a first draft of an assessment. Anticipated completion date: MLSC has already completed the requirement to have policies in compliance with LSC Financial Guide Sections 2.5.3 (Electronic Data Processing and Cybersecurity) and 3.2.1 (Bank accounts). MLSC will complete the annual assessment by February 28, 2026.

View Audit 372427

Corrective Action Plans

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