Corrective Action Plans

Finding 1172737 (2025-001)

Material Weakness 2025

WV

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.1 § 200.303

Finding 2025-001 Reporting Federal Agency- U.S. Department of the Treasury Program Name - Coronavirus State and Local Fiscal Recovery Funds (SLFRF} Federal Assistance Listing Number: 21.027 2 CFR 200.303 requires that a non-federal entity must "(a) establish and maintain effective internal control o...

Finding 2025-001 Reporting Federal Agency- U.S. Department of the Treasury Program Name - Coronavirus State and Local Fiscal Recovery Funds (SLFRF} Federal Assistance Listing Number: 21.027 2 CFR 200.303 requires that a non-federal entity must "(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The terms and conditions of the funding require the recipient to submit quarterly Project and Expenditure Reports to the U.S. Department of the Treasury {Treasury). Information required to be included in these quarterly reports includes projects funded, expenditures, obligations, and other information. Treasury's Coronavirus State and Local Fiscal Recovery Guidance requires that "Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1." Responsible Officials: The City of Charleston utilizes an outside agency to compile and submit the required quarterly reports to the Department of Treasury for the State and Local Fiscal Recovery Funds. City officials provide the details of the projects funded, expenditures, obligations, and all other required information to the outside agency, who will then compile and submit the report. Upon review of prior period reports, City officials discovered that the expenditure amount for one of the projects was less than the amount provided to the outside agency for the report. The City brought this to the attention of the outside agency, then increased the project expenditures of the report in question so that the project to-date.

View Audit 386032

Finding 1172687 (2025-001)

Material Weakness 2025

East Peoria Elementary School District No. 86

IL

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent or associate superintendent) compares the meal counts in the cl...

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (superintendent or associate superintendent) compares the meal counts in the claim to the Skyward and RevTrak daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: June 30, 2026. Name of contact person: Tony Ingold, Superintendent. Management response: The corrective action plan was discussed with the employee responsible for filing the claim, the associate superintendent, and the superintendent. After discussion, the plan was approved and will be implemented.

View Audit 385944

Finding 1172555 (2025-002)

Material Weakness 2025

YWCA Pierce County

WA

Internal Control / Segregation of Duties § 200.303

Monthly/quarterly reimbursement invoices will be prepared by the Finance Coordinator. Before submission, the Finance Director will review the invoices comparing them with general ledger supporting documents and then will initial the organization’s copy of the invoice. The CEO, or other designee will...

Monthly/quarterly reimbursement invoices will be prepared by the Finance Coordinator. Before submission, the Finance Director will review the invoices comparing them with general ledger supporting documents and then will initial the organization’s copy of the invoice. The CEO, or other designee will then review and sign the original invoice being sent to the grantor.

View Audit 385850

Finding 1172535 (2025-003)

Material Weakness 2025

Mill Creek Community School Corporation

IN

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

FINDING 2025-003 Finding Subject: Education Stabilization Fund - Earmarking Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Correct...

FINDING 2025-003 Finding Subject: Education Stabilization Fund - Earmarking Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: While the school corporation no longer has any active funds with the COVID-19 Education Stabilization Fund the school corporation will ensure that the designed or implemented a system of internal controls, which would include segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance for any future federal program. Anticipated Completion Date: January 1, 2026 INDIANA STATE

View Audit 385771

Finding 1172533 (2025-002)

Material Weakness 2025

Mill Creek Community School Corporation

IN

Procurement, Suspension & Debarment Subrecipient Monitoring School Nutrition Programs § 200.303

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description o...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster - Suspension and Debarment Contact Person Responsible for Corrective Action: Lori Bennett Contact Phone Number and Email Address: 317-539-9200, LBennett@mccsc.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will require that suspension and debarment verification be done for all appropriate vendors prior entering into and paying an invoice at the start of each year. The verification is to be done by checking the SAM exclusions, collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Documentation will be included with the first voucher each year for that qualifying vendor. Anticipated Completion Date: January 2026

View Audit 385771

Finding 1172512 (2025-003)

Material Weakness 2025

Norwood School District No. 63

IL

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person will compare the meal counts in the claim to: (1) the daily meal counts prepare...

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person will compare the meal counts in the claim to: (1) the daily meal counts prepared by cafeteria staff and (2) the monthly enrollment reports from the accounting software. The reviewer will then sign and date the supporting documentation before the meal claim is submitted. Anticipated date of completion: December 2025. Name of contact person: Jake Flowers, Superintendent. Management response: The corrective action plan was discussed with the employees responsible for filing the claim and the superintendent. After discussion, the plan was approved by the superintendent and will be adopted.

View Audit 385731

Finding 1172447 (2025-001)

Material Weakness 2025

Alamosa School District Re-11j

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Internal Control / Segregation of Duties § 200.303

Action Taken: The District has updated internal control procedures to add additional segregation of duties and documentation. A standard time sheet has been implemented District wide until the District can purchase and implement the timeclock management system add on to its current employee tracking...

Action Taken: The District has updated internal control procedures to add additional segregation of duties and documentation. A standard time sheet has been implemented District wide until the District can purchase and implement the timeclock management system add on to its current employee tracking software. Timesheets are only allowed to be turned in to the Payroll Clerk by the approving supervisor, and after timesheets are entered by the Payroll Clerk they are scanned to the supervisor to review and make sure they agree to what was turned in. The Chief Operations and Financial Officer, Director of Child Nutrition, and Payroll Clerk have all completed internal control training, and The District is evaluating the Child Nutrition Department’s staffing and job descriptions and looking into adding a clerical position to help with reporting and add to segregation of duties/checks and balances.

View Audit 385590

Finding 1172162 (2025-008)

Material Weakness 2025

School District of Thorp

WI

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Procurement, Suspension & Debarment § 200.303

Recommendation: CLA recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases, along with adding controls to ensure that the item purchased was r...

Recommendation: CLA recommends the District review its grant disbursement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving purchases, along with adding controls to ensure that the item purchased was received by the District. CLA also also recommends the District printout the eligibility reports from Wisegrants and sign and date them to indicate review and approval after meeting with CESA 10 each year. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The District will note the date of the budget meeting with CESA 10. When items are purchased for Title I, approval will be made by either the Elementary Principal or Superintendent before purchases are made. Name(s) of the contact person(s) responsible for corrective action: Brooke Rosemeyer, Adrian Foster, Brandon Baldry Planned completion date for corrective action plan: September 1, 2026.

View Audit 385300

Finding 1172156 (2025-006)

Material Weakness 2025

School District of Thorp

WI

Procurement, Suspension & Debarment School Nutrition Programs § 200.303

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends the District review its procurement process to ensure that there is adequate segregation ...

Child Nutrition Cluster (School Breakfast Program, National School Lunch Program, and Summer Food Service Program for Children) – Assistance Listing No. 10.553, 10.555, and 10.559 Recommendation: CLA recommends the District review its procurement process to ensure that there is adequate segregation of duties in regards to initiating, authorizing, reviewing for grant allowability and approving all procurement transactions. CLA also recommends that the District review and update policies and procedures to help ensure that all federal grants with covered transactions have vendors reviewed for suspension and debarment status prior to entering into the transaction and that documentation of the status is maintained with the procurement history of each transaction that it is required for. Explanation of disagreement with audit finding: There is no disagreement with this finding. Action planned/taken in response to finding: The Food Service Director and the Executive Administrative Assistant and District Administrator will work together to ensure that procedures are in place to review and confirm for accuracy. Name(s) of the contact person(s) responsible for corrective action: Frankie Soto, Dawn Rausch, Adrian Foster Planned completion date for corrective action plan: September 1, 2026.

View Audit 385300

Finding 1172137 (2025-010)

Material Weakness 2025

Mecklenburg County

NC

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303 § 200.334

U.S. Department of Health and Human Services Program Name: Maternal and Child Health Services Block Grant Federal Assistance Listing Number: 93.994 Significant Deficiency, Nonmaterial Noncompliance – Reporting Finding 2025-010 – Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of...

U.S. Department of Health and Human Services Program Name: Maternal and Child Health Services Block Grant Federal Assistance Listing Number: 93.994 Significant Deficiency, Nonmaterial Noncompliance – Reporting Finding 2025-010 – Repeat Finding Criteria or Specific Requirement: Per Section 200.303 of the Uniform Grant Guidance, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Per 2 CFR 200.334 the recipient must retain all federal award records for three years from the date of submission of their final financial report. Condition: During the audit we tested 9 reports and noted the following: a) There was one (1) instance out of (9) nine reports tested where the submitted reports were unable to be provided, including the date of submission for the reports. b) There were four (4) instances out of nine (9) reports tested where the County was unable to provide evidence the report was reviewed prior to submission. c) There were two (2) instances out of nine (9) reports tested where the County was unable to provide the date of submission for the reports. Questioned Costs: None of the nonmaterial noncompliance items resulted in questioned costs. Effect: By not having the required documentation and underlying support, the County is not able to demonstrate compliance with the applicable requirements. Cause: The County did not have a formal policy to ensure documentation was retained to evidence review and submission of all reports. Recommendation: While the County made updates to policies and procedures surrounding reporting during the current year to address the prior year finding, the County should ensure these policies are adhered to ensure all submitted reports and underlying data are retained in accordance with the Uniform Grant Guidance requirements. Views of Responsible Officials: Management agrees with the finding and is implementing procedures to correct this which is further discussed in the Corrective Action Plan. Corrective Action Plan: As of July 2025, The Health Department has created and adopted policy FIS-05 Retention of Reporting Requirement Submissions to ensure that federal award reports and data are retained in accordance with Uniform Guidance. The Health Department will document with screen shots as outlined in the FIS-05 Policy, to address circumstances when the required report consists of answering a NCDHHS survey or form that does not have “save” or “download” capability, to maintain record of documented submissions. In addition, the Health Department has developed a standard operating procedure whereby fiscal compliance Management Analysts, in collaboration with Program Managers, ensure they have reviewed federal award reports prior to submission and file documentation of review and approvals. While review of grant reports is common, the Health Department did not have adequate documentation to demonstrate completion of this step prior to July 2025. An additional training, to be recorded, will be held with program staff Friday December 19th, 2025. Anticipated Completion Date: December 19,, 2025 Responsible Person(s): Autumn Watson, Business Operations Director

View Audit 385263

Finding 1172060 (2025-002)

Material Weakness 2025

Myrtle Point School District

OR

Reporting Internal Control / Segregation of Duties Significant Deficiency § 200.303

Finding 2025-002 – Internal Control over Compliance – Reporting (Significant Deficiency) CFDA Title and Number 84.354A Qualified Zone Academy Bonds (QZAB) Name of Federal Agency: U.S. Department of Education Compliance/Internal Control over Compliance: Auditee Responsibilities - 87 - Criteria: Unifo...

Finding 2025-002 – Internal Control over Compliance – Reporting (Significant Deficiency) CFDA Title and Number 84.354A Qualified Zone Academy Bonds (QZAB) Name of Federal Agency: U.S. Department of Education Compliance/Internal Control over Compliance: Auditee Responsibilities - 87 - Criteria: Uniform Guidance CFR Part 200.303 requires entities to maintain effective internal control over compliance for federal programs, including accurate financial reporting. GAAP requires proper recognition and disclosure of long-term obligations such as Qualified Zone Academy Bonds (QZAB). In-ternal controls should ensure debt balances are reconciled to lender statements and amortization schedules to prevent misstatement in reports and the SEFA. Condition: Myrtle Point School District No. did not perform routine reconciliations of QZAB debt bal-ances during the fiscal year ended June 30, 2025. The general ledger balance for QZAB differed from the amortization schedule and accrued interest was not updated. No documented review or reconciliation was performed. Failed to report the interest for the QZAB bonds and failed to post the principal pay-ments that were paid from the QZAB for the Flex fund. Entries were required to correct this deficiency in order to complete the audit. Cause: Lack of formal reconciliation procedures and oversight; reliance on outdated schedules without updates. Effect or Potential Effect: Failure to accurately reconcile QZAB balances or amortization records, can result in a risk of material misstatement of liabilities and interest expense for the financial statements; po-tential errors in SEFA reporting when QZAB financed federally funded assets. This could lead to non-compliance with reporting requirements and misclassification of debt-financed assets. Questioned Cost: None reported Repeat of a Prior-Year Finding: Yes Recommendation: We recommend that Myrtle Point School District No. 41 implement a monthly recon-ciliation process for QZAB debt, agreeing general ledger balances to lender statements and amortization schedules, and require documented review and sign-off by the Director of Business Services. District's Response: The District concurs with the recommendation. Corrective Action Plan: The District will implement reconciliations and update the schedules, and inte-grate review into the year-end close process. Planned Implementation Date: January 31, 2026 Responsible Person: Director of Business Services, Myrtle Point School District No. 41

View Audit 385190

Finding 1172045 (2025-002)

Material Weakness 2025

Tell City-Troy Township School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions § 200.303

FINDING 2025-002 Finding Subject: COVID-19- Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: State Board of Accounts has asserted that the school corporation did not ensure that the contractor for the elementary building’s roofing project, whic...

FINDING 2025-002 Finding Subject: COVID-19- Education Stabilization Fund – Special Tests and Provisions – Wage Rate Requirements Summary of Finding: State Board of Accounts has asserted that the school corporation did not ensure that the contractor for the elementary building’s roofing project, which was partially funded through a federal ESSER grant, had paid prevailing wage rates on this project. Contact Person Responsible for Corrective Action: Debra Elder, Treasurer and John Scioldo, Superintendent Contact Phone Number and Email Address: 812-547-3300; debbie.elder@tellcity.k12.in.us and john.scioldo@tellcity.k12.in.us Views of Responsible Officials: We concur with the finding.. Description of Corrective Action Plan: While we will agree that the school corporation did not physically have on file and/or review the detailed certified payroll timesheets from Eskola, the awarded contractor for the project, the school corporation had hired in good faith Universal Design Associates (UDA) to manage all facets of the project. UDA has managed other capital improvements on the school’s campus, and their services have been exemplary. A school corporation of our size simply does not have the manpower, resources or expertise to oversee a project of this size, and therefore we rely on the hired project manager/architectural design company to ensure all federal Davis-Bacon wage scale requirements and the construction project as a whole are being fully followed, in addition to their close oversight of the day-to-day project management. The Application to Pay statements for payment to Eskola were provided by, and assumably thoroughly reviewed by, UDA. These pay applications obviously included payment for payroll, again assumably of which UDA checked certified payroll for federal wage compliance. The project was completed in the spring of 2025, and therefore this is no longer an issue. We have determined as a result of this finding that the current school administration will not consider funding future capital projects with federal grants due to the complexities of the involved federal compliance requirements. Anticipated Completion Date: N/A – Based on Corrective Action Plan

View Audit 385149

Finding 1171997 (2025-004)

Material Weakness 2025

Village of Milford, Michigan

MI

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Condition: The Village did not have adequate controls in place to exercise its oversight responsibility of adherence to wage rate requirements that were reviewed by a contractor for the program. The Village also did not have controls in place to exercise oversight over the same contractor's review o...

Condition: The Village did not have adequate controls in place to exercise its oversight responsibility of adherence to wage rate requirements that were reviewed by a contractor for the program. The Village also did not have controls in place to exercise oversight over the same contractor's review of general and subcontractors for suspension and debarment. Planned Corrective Action: The Village has implemented updated procedures as recommended by the auditors. Contact person responsible for corrective action: Penny Ray Anticipated Completion Date: 12/31/2025

View Audit 385089

Finding 1171973 (2025-001)

Material Weakness 2025

Virginia Commonwealth University Health System

VA

Allowable Costs / Cost Principles Period of Performance § 200.303 § 200.308 § 200.403

Audit Finding: The Authority did not have sufficient internal controls to ensure that payroll expenditures submitted to FEMA were incurred within the applicable period of performance prior to submission of the project worksheet. Recommendation: The Authority’s policy and procedures should be designe...

Audit Finding: The Authority did not have sufficient internal controls to ensure that payroll expenditures submitted to FEMA were incurred within the applicable period of performance prior to submission of the project worksheet. Recommendation: The Authority’s policy and procedures should be designed to strengthen the internal controls over the review of the submissions to ensure accurate reporting as required by the Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: 1. Enhanced Review of Period of Performance (POP): The Authority will implement a formal verification step requiring the Finance Department to confirm that all costs included in FEMA project worksheets were incurred within the approved period of performance prior to submission. This verification will specifically address payroll costs that span multiple pay periods. 2. Payroll Cost Allocation Controls: Payroll expenditures that cross fiscal periods or project periods of performance will be allocated based on actual days worked within the applicable period. Payroll reports will be reviewed to ensure that only eligible dates are included in each FEMA project. 3. Secondary Review: The Authority will require a secondary review by a finance staff member not involved in the initial preparation of the FEMA project worksheet to ensure accuracy, completeness, and compliance with FEMA eligibility requirements. 4. Correction of Identified Error: Management has corrected the duplicated payroll costs of $104,434 by removing them from the project ending June 30, 2022 and ensuring they are only reported in the project beginning July 1, 2022. Total FEMA expenditures reported on the Schedule of Expenditures of Federal Awards were adjusted accordingly. In addition, VCUHSA has voluntarily prepared a letter to VDEM to alert them of the identified issue and request assistance on next steps to return the funds that were received in error. The letter will be followed up by an email. The Finance team has also notified the CFO of both the findings of the audit and the related corrective actions. Name(s) of the contact person(s) responsible for corrective action: Min Cummings, VP of Finance and Accounting, 804-827-0545 Planned completion date for corrective action plan: Notification of error to be sent to VDEM within 60 days of audit completion. All other planned actions to be implemented immediately for any future costs and expenditures.

View Audit 385059

Finding 1171934 (2025-003)

Material Weakness 2025

City of Wells, Nv

NV

Reporting Cash Management Significant Deficiency § 200.303

Finding Summary: 2 CFR Part 200 (Uniform Guidance) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award. Eide Bailly noted two out of five reimbursement requests had no evidence of approval. Responsible Individuals: Samantha Nance, City C...

Finding Summary: 2 CFR Part 200 (Uniform Guidance) requires that the non-Federal entity must establish and maintain effective internal control over the Federal award. Eide Bailly noted two out of five reimbursement requests had no evidence of approval. Responsible Individuals: Samantha Nance, City Clerk Corrective Action Plan: Create a checklist for all reimbursement request procedures to include prepared by and approved by signatures with every request. Anticipated Completion Date: Immediately

View Audit 384971

Finding 1171866 (2025-001)

Material Weakness 2025

Cleveland State University

OH

Student Financial Aid Subrecipient Monitoring Significant Deficiency § 200.303

Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate con...

Name of the contact person responsible for corrective action planned: Brenda Wendt Controller Cleveland State University 2121 Euclid Avenue Cleveland, OH 44115 Phone: 216.687.3676 Email: b.wendt@csuohio.edu Corrective actions planned: Finding Number: 2025-001 The University did not have adequate controls in place to ensure that credit balances were refunded in a timely manner within the 14-calendar-day requirement. Management has implemented a process to ensure that credit balances are processed within the 14-calendar-day requirement. A workflow hierarchy is in place to ensure adequate staffing and training, preventing processing delays. Any deviations from the normal processing of credit balances will be sent to the relevant department immediately for further action. Anticipated completion date: December 2025

View Audit 384835

Finding 1171684 (2025-003)

Material Weakness 2025

South Gibson School Corporation

IN

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.208 § 200.303 § 200.403

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Amy Silva Contact Phone Number and Email Address: 812-753-4230 amy.silva@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corr...

FINDING 2025-003 Finding Subject: Special Education Cluster (IDEA) - Earmarking Contact Person Responsible for Corrective Action: Amy Silva Contact Phone Number and Email Address: 812-753-4230 amy.silva@sgibson.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation has designated the Director of Special Education as the primary monitor responsible for overseeing nonpublic proportionate share expenditures. The Corporation Treasurer will provide the Director of Special Education and the Assistant Superintendent with a monthly budget-to-actual expenditure report for all active grants with nonpublic proportionate share requirements. This report will track the remaining unspent balance. The Director of Special Education will meet monthly with nonpublic school administrators to review the remaining fund balances, ensure services are being rendered, and project future expenditures. A final reconciliation will be performed within 30 days of each grant's end date to confirm all required funds were spent or a waiver was successfully obtained. Anticipated Completion Date: March 1, 2026

View Audit 384700

Finding 1171679 (2025-014)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed ...

Finding 2025-014 U.S. Department of Treasury AL No. 21.027 American Rescue Plan Act (ARPA) Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-015 Auditee’s Corrective Action Plan: The Recovery Office will complete a review of all executed subgrant agreements to confirm that the correct Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) appear in the agreement. • This review will exclude Interagency Agreements with City agencies since they are not considered subrecipients, but as the prime recipient, the City of Baltimore. • This review will also exclude any agreements related to projects classified under Expenditure Category (EC) 6.1 in ARPA SLFRF guidance. According to Frequently Asked Questions (FAQs) issued by the U.S. Department of Treasury, this EC does not give rise to a subrecipient relationship, therefore UEI information is not required. • For any subgrant agreements with an incorrect or missing UEI or FAIN, the Recovery Office will submit a single memorandum that presents correct UEIs and FAIN to the Board of Estimates (BOE) to ensure that the official record has correct UEI and FAIN information. We believe there is a direct conflict between Treasury guidance and 2 CFR 200 regarding the requirement for active SAM.gov registration. Treasury does not require subrecipients to maintain an active SAM.gov registration and instead permits the use of alternative screening questions in lieu of an active registration. Treasury does not collect individualized subrecipient data for subawards at or below $50,000. Each of these three awards are at or below that threshold, therefore the SAM.gov information, including the subrecipient UEI, registration, or the alternative screening questions, were not collected. The total amount of funding for the three identified subrecipients combined is $100,000. The Recovery Office will require that all subrecipients fully register in SAM.gov. The Recovery Office will require that agencies provide a 30-day window to allow all subrecipients to fully register or funds will be withheld until the subrecipient can fully register to demonstrate the organization is not suspended or debarred. In those cases where the Recovery Office is unable to withhold disbursements for noncompliant subrecipients, the Recovery Office will issue a Corrective Action Plan or issue a finding in the subrecipient's closeout letter. For any grants that expired, if payments occurred outside the period of performance, and did not have written justification for and approval of an extension to the allowable closeout period, the Recovery Office will require that the agency to take the agreement back to the Board of Estimates for a retroactive extension. In certain cases, such as when extended monitoring or implementation of corrective action items go beyond the period of performance, a payment may be made outside of the allowable closeout period. According to 2 CFR 200.344c, "The recipient must liquidate all financial obligations incurred under the Federal award no later than 120 calendar days after the conclusion of the period of performance. A subrecipient must liquidate all financial obligations incurred under a subaward no later than 90 calendar days after the conclusion of the period of performance of the subaward (or an earlier date as agreed upon by the pass-through entity and subrecipient). When justified, the Federal agency or pass-through entity may approve extensions for the recipient or subrecipient." In these cases, the Recovery Office will assure there is written justification for the extension on liquidating all financial obligations. Contact Person: Elizabeth Tatum, Director Completion Date: June 30, 2026

View Audit 384683

Finding 1171579 (2025-020)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring § 200.303

Finding 2025-020 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: In FY 2025 BCHD dev...

Finding 2025-020 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheet, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. • Prioritize meetings with programs that have not conducted monitoring in the prior fiscal year to strategize and to ensure monitoring occurs in FY 2026. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

View Audit 384683

Finding 1171578 (2025-019)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Finding 2025-019 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: To address reporting finding...

Finding 2025-019 U.S. Department of Health and Human Services AL No. 93.977 Sexually Transmitted Diseases (STD) Prevention and Control Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

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Finding 1171561 (2025-018)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025...

Finding 2025-018 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-028 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

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Finding 1171560 (2025-017)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking Reporting Significant Deficiency § 200.303

Finding 2025-017 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-027 Auditee’s Corrective Action Plan: To address reporting fin...

Finding 2025-017 U.S. Department of Health and Human Services AL No. 93.940 HIV Prevention Activities Health Department Based Programs Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-027 Auditee’s Corrective Action Plan: To address reporting findings, in FY 2025 BCHD developed a Grants Management Standard Operating Procedure manual that continues to be updated as processes are adjusted to ensure compliance with all grant awards. Additionally, BCHD fiscal has completed the following steps to address this finding: • Restructured the fiscal grants management team to strengthen internal controls around grants management, standardize processes and improve efficiency. • Conducted small group training within the newly formed teams around the specifics of job responsibilities and requirements. • Created an internal grants tracker in Smartsheet to include all grant award periods, reporting requirements and due dates. • Compliance team entered required data in SAM.gov for FFATA reporting. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Conduct separate workshops with division leaders, programs directors and the compliance team to review all grant awards and compliance requirements for each award in addition to reviewing process for close out of grant awards and annual reporting requirements. • Update the grants tracker to include both fiscal and program reporting requirements. BCHD will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. Per the GMO’s guidance, BCHD will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

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Finding 1171537 (2025-016)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring § 200.303 § 200.332

Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an inte...

Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts unit. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheet, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

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Finding 1171514 (2025-015)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring § 200.303 § 200.332

Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed...

Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Subrecipient vs. Contractor determination checklist that are required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Created fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: June 30, 2026

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Finding 1171506 (2025-013)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengt...

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengthen internal controls, MOED will establish separate grant worktags for all parts of the grant award to ensure the grant reference number is unique within the Workday award setup. UEI Subaward Validation: As a corrective action, Contracts Specialist training has been updated to require verification and documentation of the sub-recipient’s Unique Entity Identifier (UEI) through SAM.Gov as part of the subaward setup process. MOED will require grant staff to familiarize themselves with Administrative Manual policy 413- 21 Federal Grant Registration and Unique Entity Identifier, which requires UEI verification and identification in the City’s financial system of record for all subrecipients. Subrecipient Monitoring: MOED does maintain a standardized sub-recipient monitoring checklist designed to ensure subawards are administered in compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward as well as relevant supporting documentation. FY2025 subrecipient monitoring was not scheduled in accordance with the monitoring timeframes outlined in the terms and conditions of the grant award. Management acknowledges this oversight and will ensure that all subrecipient monitoring is scheduled and conducted timely in accordance with the monitoring timeframes outlined in the award. Review of Subrecipient Single Audit Report: MOED performs a review of subrecipient Single Audit reports during the technical proposal evaluation and confirms the subrecipient’s inclusion on the State of Maryland’s Eligible Training Provider List (ETPL). Due to document volume size, this documentation has not historically been included in BOE-approved subrecipient agreements or retained within Workday award files. As a corrective action, MOED will formally incorporate ETPL verification into subrecipient agreements. Single Audit reports will be retained separately from the BOE approval package and uploaded to the applicable Grant Award record in Workday to ensure consistent documentation and accessibility. MOED will utilize the GMO’s subrecipient monitoring templates provided on the centralized SharePoint Grants Management platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reports are completed. Additionally, MOED will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOED will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. MOED will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: September 30, 2026

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Corrective Action Plans

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