Corrective Action Plans

Finding 1179760 (2025-062)

Material Weakness 2025

State of Nebraska

NE

Questioned Costs Allowable Costs / Cost Principles Eligibility § 200.303 § 200.511

Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Allowability & Eligibility Corrective Action Plan: The ERA2 program officially concluded as of September 30, 2025. Because the program ended, there will be no further eligibility determinations to be made and no additional action is...

Program: AL 21.023 – COVID-19 Emergency Rental Assistance Program – Allowability & Eligibility Corrective Action Plan: The ERA2 program officially concluded as of September 30, 2025. Because the program ended, there will be no further eligibility determinations to be made and no additional action is necessary. On all other grant programs for which the Agency is the recipient, eligibility determinations are a shared responsibility of the Agency and the funding entity. Contact: Erv Portis Anticipated Completion Date: Complete

View Audit 392165

Finding 1179744 (2025-026)

Material Weakness 2025

State of Nebraska

NE

Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.403 § 200.405 § 200.511

Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.090 – Guardianship Assistance; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Desi...

Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.090 – Guardianship Assistance; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Grants to States for Medicaid – Allowable Cost/Cost Principles Corrective Action Plan: A new Business Unit mapping process has been implemented that will ensure that all Business Units are correctly accounted for. In addition, procedures were updated and sent to applicable staff to ensure payroll is correctly recorded. Contact: Patrick Werner Anticipated Completion Date: Complete

View Audit 392165

Finding 1179743 (2025-025)

Material Weakness 2025

State of Nebraska

NE

Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.403 § 200.405 § 200.511

Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575...

Program: AL 10.561 – State Administrative Matching Grants for the Supplemental Nutrition Assistance Program; AL 93.558 – Temporary Assistance for Needy Families; AL 93.563 – Child Support Services; AL 93.566 – Refugee and Entrant Assistance State/Replacement Designee Administered Programs; AL 93.575 Child Care and Development Block Grant; AL 93.658 – Foster Care Title IV-E; AL 93.659 – Adoption Assistance; AL 93.767 – Children’s Health Insurance Program; AL 93.778 – Grants to States for Medicaid – Allowable Cost/Cost Principles Corrective Action Plan: DHHS has begun strengthening processes and procedures to ensure entries are complete and accurate and in compliance with Federal regulations. Contact: Patrick Werner Anticipated Completion Date: June 30, 2026

View Audit 392165

Finding 1179698 (2025-061)

Material Weakness 2025

State of Nebraska

NE

Cash Management § 200.302 § 200.303 § 200.305

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: Continue to monitor program expenditures to aid in optimizing forecasting and advance request accuracy. Contact: Lauren Hargreaves Anticipated Completion Date:...

Program: AL 12.401 – National Guard Military Operations and Maintenance (O&M) Projects – Cash Management & Reporting Corrective Action Plan: Continue to monitor program expenditures to aid in optimizing forecasting and advance request accuracy. Contact: Lauren Hargreaves Anticipated Completion Date: Ongoing

View Audit 392165

Finding 1179658 (2025-003)

Material Weakness 2025

Rogue Community College

OR

Questioned Costs Reporting Significant Deficiency § 200.303

Finding: 2025-003 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.493 Program Name: Community Project Funding Finding Summary: Uniform Guidance at 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over f...

Finding: 2025-003 Federal Agency Name: U.S. Department of Health and Human Services Assistance Listing Number(s): 93.493 Program Name: Community Project Funding Finding Summary: Uniform Guidance at 2 CFR 200.303 requires nonfederal entities to establish and maintain effective internal control over federal awards that provides reasonable assurance that the entity is managing federal awards in compliance with applicable laws, regulations, and the terms and conditions of the award. Effective internal control includes appropriate independent review of reports to ensure accuracy prior to submission. During our testing over the report submissions for the fiscal year, we noted there was not an independent review completed over the quarterly expenditure report. Responsible Individuals: Michael Pollock, CFO and Debbie Dice, Director, Financial Reporting, Audit/Compliance Corrective Action Plan: There was transition in several of the key roles during the fiscal year, causing the review not to be completed over the quarterly submissions that will be rectified during 2025-26. Internal controls will be updated with the following steps: 1) Quarterly federal expenditure reports will be prepared by the an assigned Accountant II member and reviewed by a the Director of Financial Reporting, Audit and Compliance prior to submission to the granting agency; 2) Obtain evidence of the independent review, including reviewer sign-off and date of review, will be documented and retained with the report submission records; 3) The College will update written internal control procedures governing federal grant reporting to formally incorporate the independent review requirement; and 4) The Director of Financial Reporting, Audit and Compliance will monitor adherence to the review process and ensure that documentation is maintained for audit purposes. Anticipated Completion Date: June 2026

View Audit 392056

Finding 1179616 (2025-002)

Material Weakness 2025

Perry Central Community School Corporation

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2025-002 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: I...

FINDING 2025-002 Information on the federal program: Subject: Education Stabilization Fund – Internal Controls Federal Agency: Department of Education Federal Program: COVID-19 – Education Stabilization Fund Assistance Listing Number: 84.425U Federal Award Numbers: S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions – Wage Rate Requirements Audit Finding: Material Weakness Condition: An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions – Wage Rate Requirements compliance requirements. Context: The School Corporation had one project for a bus garage addition that which was funded with ESSER III (84.425U) grant awards. The School Corporation did not execute a formal contract with the vendor as the transaction was under the simplified acquisition threshold of $150,000. As such, there was no internal controls to communicate required prevailing wage rate requirements to the vendor prior to entering into the transaction. The School Corporation did obtain the weekly wage reports from the vendor. The total project cost disbursed during the audit period was $88,727, which included materials and labor. Views of Responsible Officials and Corrective Action Plan: Management agrees with the finding. We did not have a formal contract for this project. It was below a threshold that we had used before that necessitated a formal contract. We now understand that we should have gotten a formal contract in place because this is federal funding. We used the quotes that were provided, and the school board approved the expenditures at a school board meeting. In the future, we will secure a formal contract for all federal funds. Responsible Party and Timeline for Completion: Tara Bishop, Superintendent. Completed 3/1/24.

View Audit 392012

Finding 1179549 (2025-002)

Material Weakness 2025

International Rescue Committee, Inc.

NY

Subrecipient Monitoring Reporting Procurement, Suspension & Debarment § 200.303

2025-002 Reporting - Federal Funding Accountability and Transparency Act Federal Agencies: U.S. Department of State/Bureau of Population and Refugees and Migration, and U.S. Agency for International Development Program Titles and ALN Numbers: 1. ALN #19.519: Overseas Refugee Assistance Programs for ...

2025-002 Reporting - Federal Funding Accountability and Transparency Act Federal Agencies: U.S. Department of State/Bureau of Population and Refugees and Migration, and U.S. Agency for International Development Program Titles and ALN Numbers: 1. ALN #19.519: Overseas Refugee Assistance Programs for Middle East and North Africa 2. ALN #19.523: Overseas Refugee Assistance Program for South Asia. 3. ALN #98.001: United States Foreign Assistance for Programs Overseas Federal Grant Numbers: 1. SPRMCO24CA0321 - Provision of lifesaving protection & health response for Syrian refugees and vulnerable Lebanese 2. SPRMCO24CA0239- Comprehensive, Integrated Multi-Sector Response for Rohingya Refugees and Host Communities in Cox’s Bazar (Y2) 3. 72052224CA00004 - Improved (Re)integration Services Activity. 4. 720BHA22GR00218- Lifesaving Integrated Humanitarian Services in Underserved Areas of Sudan Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: The following corrective action will be taken to ensure the documentation for timely FFATA reporting in SAM.Gov is clearly evidenced: a. All staff responsible for entering FFATA details in Sam.Gov will be required to obtain a screenshot when the report is submitted to Sam.Gov showing the date of submission. Anticipated Completion Date: September 30, 2026

View Audit 391920

Finding 1179547 (2025-001)

Material Weakness 2025

International Rescue Committee, Inc.

NY

Allowable Costs / Cost Principles § 200.303 § 200.403

2025-001-Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Beneficiary Payments Federal Agencies: U.S. Department of State/ Bureau of Population and Refugees and Migration Program Titles and ALN Numbers: 1. ALN #19.510: U.S. Refugee Admissions Program Federal Grant Numbers: 1. SP...

2025-001-Activities Allowed or Unallowed and Allowable Costs/Cost Principles - Beneficiary Payments Federal Agencies: U.S. Department of State/ Bureau of Population and Refugees and Migration Program Titles and ALN Numbers: 1. ALN #19.510: U.S. Refugee Admissions Program Federal Grant Numbers: 1. SPRMCO23CA0361- FY24 MRA Capacity Development Funds 2. SPRMCO24CA0356- FY2023-25 Year 3 Reception and Placement Program - Affiliate MRA DA+Admin 3. SPRMCO24CA0357- FY2023-25 Year 3 Reception and Placement Program - Affiliate ERMA DA+Admin Contact Person: Rick Estridge, Controller, rick.estridge@rescue.org, (443)890-0915 Corrective Action: IRC’s management has taken several steps to stop fraudulent activities, prevent new fraud and improve IRC’s ability to detect future fraud. a. Upon identifying potentially unauthorized and fraudulent fund requests, all program office access to the USIO bank portal was immediately suspended. USIO debit card loads were centralized, and this process remains in place. b. Nine staff potentially involved in those activities were placed on leave during the investigation; five were eventually terminated. Following investigations, the IRC has made significant changes in leadership in structure in Northern California. By the end of June 2026, new Finance, Operations, and Program Delivery leadership will be in place, and the office will be broken down into two smaller offices, each with its own Executive Director. c. Working visits and in-person training on fraud prevention have been and will continue to be delivered to reinforce IRC’s compliance standards in all offices engaged in direct client payments. Additionally, network wide training are being provided focused on on compliance, CFR and fraud prevention for all staff. New policies on pre-paid cards and gift cards have also been issued. d. A Financial Analyst position was created under the RAI Head of Finance to focus on compliance. The analyst performs quarterly sample-based spot checks across all U.S. network offices, randomly selecting transactions for end-to-end review, including USIO payments. An automated tool also flags potential non-compliance issues such as irregular p-card payments and gift card purchases – vulnerabilities that could be exploited in NorCal-like situations. The RAI Head of Finance then compiles quarterly compliance reports for office leadership, highlighting areas for improvement. Anticipated Completion Date: June 30, 2026

View Audit 391920

Finding 1179523 (2025-001)

Material Weakness 2025

Clinton Central School Corporation

IN

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.403

FINDING 2025-001 Finding Subject: Twenty-First Century Community Learning Centers – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: April Boone and Levi Yowell Contact Phone Number and Email Address: 765-249-2515; april.boone@clinton...

FINDING 2025-001 Finding Subject: Twenty-First Century Community Learning Centers – Activities Allowed or Unallowed, Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: April Boone and Levi Yowell Contact Phone Number and Email Address: 765-249-2515; april.boone@clinton.k12.in.us; levi.yowell@clinton.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Per written directive from our Superintendent, Mr. Yowell on November 14, 2025, the following steps are being implemented to provide better oversight over the Twenty-First Century Program. 1. Multiple signatures are now required on all payroll, including the CCE Principal, Site Coordinator, CCSC Treasurer, and Superintendent 2. Immediately discontinuing the unallowable expenses as shared by the SBOA auditors 3. Required approval for all purchases from Site Coordinator, CCE Principal, CCSC Treasurer, and Superintendent. On December 15, 2025, the School Board will be reviewing and considering the approval of a District Financial Authority Oversight Resolution. This resolution will better define who has financial oversight and authority for all spending within the corporation. Anticipated Completion Date: November 14, 2025 and December 15, 2025 (Note: Provide the projected date of completion of major tasks for the planned corrective actions described above.)

View Audit 391913

Finding 1179419 (2025-004)

Material Weakness 2025

MacOnaquah School Corporation

IN

Matching / Level of Effort / Earmarking § 200.303

FINDING 2025-004 Finding Subject: COVID-19 Education Stabilization Fund – Matching, Level of Effort, Earmarking Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsi...

FINDING 2025-004 Finding Subject: COVID-19 Education Stabilization Fund – Matching, Level of Effort, Earmarking Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the Finding Response Comments: When the initial budget was set up for this Grant, it was not set up correctly to track the 20% learning loss for this Federal Grant. The Grant has now closed and is no longer being used. In the future, any Grants that must show level of effort, will be set up by the Corporate Treasurer in the accounting software to better track the level of effort or any matching funds. Anticipated Completion Date: This grant is closed and there is no need for a corrective action

View Audit 391812

Finding 1179416 (2025-003)

Material Weakness 2025

MacOnaquah School Corporation

IN

Allowable Costs / Cost Principles § 200.303 § 200.403

FINDING 2025-003 Finding subject: COVID-19 Educational Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131 millerje@maconaquah.k12.in.us Views of Responsible O...

FINDING 2025-003 Finding subject: COVID-19 Educational Stabilization Fund – Allowable Costs/Cost Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131 millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the finding According to our Classified Handbook, we only have a starting wage stated for employees. This handbook is in place for the 2025-2026 and 2026-2027 school years. We will take action to update the handbook for the 2026-2027 school year to include a starting and ending wage for the classified positions listed within the Classified Employee Handbook. This action will need to be voted on by the School Board. Anticipated Completion Date: August 2026

View Audit 391812

Finding 1179413 (2025-002)

Material Weakness 2025

MacOnaquah School Corporation

IN

Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsible Officials: We c...

FINDING 2025-002 Finding Subject: Child Nutrition Cluster – Allowable Costs/Costs Principles Contact Person Responsible for Corrective Action: Jennifer Miller, Corporate Treasurer Contact Phone Number and Email Address: 765-689-9131; millerje@maconaquah.k12.in.us Views of Responsible Officials: We concur with the findings Response Comments: According to our Classified Handbook, we only have a starting wage stated for employees. This handbook is in place for the 2025-2026 and 2026-2027 school years. We will take action to update the handbook for the 2026-2027 school year to include a starting and ending wage for the classified positions listed within the Classified Employee Handbook. This will need to voted on by the School Board before we can put into practice. Anticipated Completion Date: August 2026

View Audit 391812

Finding 1179382 (2025-001)

Material Weakness 2025

Northwest Allen County Schools

IN

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

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Leeanne Koeneman Contact Phone Number and Email Address: Leeanne.Koeneman@nacs.k12.in.us; 260-637-8768 Views of Responsible Officials: We concur with...

FINDING 2025-001 Finding Subject: Child Nutrition Cluster – Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: Leeanne Koeneman Contact Phone Number and Email Address: Leeanne.Koeneman@nacs.k12.in.us; 260-637-8768 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School Corporation will design and implement a proper system of internal controls and procedures to ensure there are appropriate procurement procedures for goods and services and contractors and subrecipients, as appropriate, are not suspended, debarred, or otherwise excluded prior to entering any contracts or subawards. This process will include obtaining vendor certifications and/or verification through SAM.gov, with two independent individuals reviewing and confirming the completeness and accuracy of the documentation. Certification will be initialed and retained in the procurement file. Anticipated Completion Date: January 26, 2026 INDIANA STATE

View Audit 391748

Finding 1179376 (2025-007)

Material Weakness 2025

Salem Community School Corporation

IN

Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Allowable Costs / Cost Principles § 200.303

FINDING 2025-007 Finding Subject: BRIC: Building Resilient Infrastructure and Communities – Internal Controls Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We ...

FINDING 2025-007 Finding Subject: BRIC: Building Resilient Infrastructure and Communities – Internal Controls Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: This grant was fully expended in 2024. Going forward, the current treasurer will work closely with the grant administrator, whether within corporation or an outside source, when compiling all claims, disbursements and reporting for any given project, including BRIC programs. Internal controls will be incorporated at the Corporation level for future grants that use an outside Grant Administrator. Anticipated Completion Date: 2/16/2026

View Audit 391728

Finding 1179375 (2025-006)

Material Weakness 2025

Salem Community School Corporation

IN

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

FINDING 2025-006 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding...

FINDING 2025-006 Finding Subject: COVID-19 - Education Stabilization Fund - Earmarking Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: When the current treasurer was hired, the ESSER III grant was at the end of the grant cycle. The learning loss aspect was discovered toward the end of the funding. In the future, breakdowns of grant funding will be understood by the treasurer and used as a guide for expenditures, helping the grant administrators keep on track with the grant budget. In addition, internal controls will be designed to ensure compliance with requirements of grant programs, such as a secondary review by another staff member who understands the program requirements. Anticipated Completion Date: 2/16/2026

View Audit 391728

Finding 1179373 (2025-005)

Material Weakness 2025

Salem Community School Corporation

IN

Subrecipient Monitoring Cash Management Material Weakness § 200.303

FINDING 2025-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding ...

FINDING 2025-005 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Internal controls for reimbursement requests will include necessary documentation of expenditures from the accounting program attached to the reimbursement form for all grants. Each reimbursement request will be checked and approved by two school employees. The treasurer will keep the packet until funds are received and receipted and then the packet, with the receipt, will be filed in two places; the respective grant folder and in the monthly receipt folder. Anticipated Completion Date: 2/16/2026

View Audit 391728

Finding 1179370 (2025-004)

Material Weakness 2025

Salem Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring Special Tests & Provisions § 200.303 § 200.334

FINDING 2025-004 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@s...

FINDING 2025-004 Finding Subject: Title I Grants to Local Educational Agencies - Special Tests and Provisions - Annual Report Card, High School Graduation Rate Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: When removing students from the graduation cohort, files will be kept in two places. One will be a file of all transfers/removals from the cohort. That same information will be filed in each students’ file. These files will be kept at the high school. An internal control will be developed that will ensure that the proper documentation is retained. Anticipated Completion Date: 2/16/2026

View Audit 391728

Finding 1179368 (2025-003)

Material Weakness 2025

Salem Community School Corporation

IN

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

FINDING 2025-003 Finding Subject: Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the f...

FINDING 2025-003 Finding Subject: Title I Grants to Local Educational Agencies – Eligibility Contact Person Responsible for Corrective Action: Lana Hamilton Contact Phone Number and Email Address: 812-883-4437, ext. 1005, lhamilton@salemschools.us Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: Due to continued turnover in the Title I administrator position, application details have not been mastered. The treasurer and current Title I administrator are continuing to learn the process through guidance from our DOE Title I specialist and what we have learned from this audit. We will continue to work together on applying for future Title I grants and for the necessary implementation of the current Title I grant. Internal control over the processes will be developed and implemented, and will be notated with a “reviewed by” signature and date. Anticipated Completion Date: 2/16/2026

View Audit 391728

Finding 1179311 (2025-006)

Material Weakness 2025

Catholic Charities of the Archdiocese of St. Paul and Minneapolis

MN

Matching / Level of Effort / Earmarking Questioned Costs Material Weakness § 200.303

Grant Accounting Finding 2025-006 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the administrative costs were appro...

Grant Accounting Finding 2025-006 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the administrative costs were appropriately billed as allowed under uniform guidance. Corrective Action Plan: CCSPM will adhere to uniform guidance specific to Administrative Expenses ensuring Administrative Expenses plus Indirect Expenses are no more than 10% of the total award over the grant period. Adherence will be monitored as part of an expanded monthly secondary review process across Continuum of Care grants. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: Adherence will be met by the end of the current grant period or end of FY26 (6.30.26), whichever is sooner for each currently active Continuum of Care grant.

View Audit 391668

Finding 1179305 (2025-005)

Material Weakness 2025

Catholic Charities of the Archdiocese of St. Paul and Minneapolis

MN

Allowable Costs / Cost Principles Period of Performance Significant Deficiency § 200.303

Grant Accounting Finding 2025-005 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the de minimis rates were appropria...

Grant Accounting Finding 2025-005 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the de minimis rates were appropriately billed as allowed under uniform guidance. Corrective Action Plan: CCSPM will adhere to uniform guidance specific to de minimis rates ensuring Indirect Expenses are no more than allowable percentage of eligible total expenses over the grant period. Adherence will be monitored as part of an expanded monthly secondary review process across Continuum of Care grants. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: Allowable de minimis rates will be met by the end of the current grant period or end of FY26 (6.30.26), whichever is sooner for each currently active Continuum of Care grant.

View Audit 391668

Finding 1179299 (2025-004)

Material Weakness 2025

Catholic Charities of the Archdiocese of St. Paul and Minneapolis

MN

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

Grant Accounting Finding 2025-004 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health* Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities’ internal controls did not operate as designed, which resulted ...

Grant Accounting Finding 2025-004 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health* Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities’ internal controls did not operate as designed, which resulted in transactions not being reviewed timely or the review process not being formally documented and maintained. Corrective Action Plan: CCSPM is expanding the monthly secondary review of Continuum of Care grants to include matching grant requirements, de minimis rates and administrative expenses to ensure compliance with uniform guidance. The expanded review process will include the evidencing of each criteria reviewed. A senior member of the Accounting Team will perform the review. Responsible Individuals: Mary Ammer, Senior Director of Accounting and Finance and Grant Accountants: Jen Goeppinger and Ashley Feldick. Anticipated Completion Date: A secondary review of each Continuum of Care grant will be performed under these expanded criteria for the period of 7.25-12.25 and monthly beginning with January 2026 and thereafter. *The Radias Health pass-through ended early in FY2025. The correction action outlined above will be applied across existing active Continuum of Care grants.

View Audit 391668

Finding 1179284 (2025-003)

Material Weakness 2025

Catholic Charities of the Archdiocese of St. Paul and Minneapolis

MN

Procurement, Suspension & Debarment § 200.303 § 200.317 § 200.318 § 200.327

Procurement Finding 2025-003 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the p...

Procurement Finding 2025-003 Federal Agency Name: Department of Housing and Urban Development Pass‐Through Entity: Radias Health Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities did not have adequate internal controls in place to ensure that the processes laid out in their procurement policy regarding the process of obtaining quotes to support procurement and testing vendors for suspension and debarment were followed. Corrective Action Plan: Catholic Charities is enhancing procurement oversight and compliance by centralizing procurement documentation, strengthening review and approval controls, and increasing management oversight. Procurement records will be centrally maintained and made accessible to the Accounting and Compliance Departments, in order to support monitoring and audit readiness. Updated training and standardized compliance tools are in the process of implementation, to reinforce consistent application of federal procurement requirements. In addition, Catholic Charities is strengthening vendor oversight through a centralized vendor management process that ensures ongoing monitoring for suspension and debarment. The Compliance Department already runs regular debarment/suspension checks against all vendors engaged in any form of agreement (e.g., contract, grant, MOU, amendment, etc.) but has no visibility to vendors not tied to an agreement. To solve this, the Compliance Department will request a report from the Accounting Department, which lists all vendors paid and will run debarment and suspension checks. All new vendors will be reviewed prior to engagement, and existing vendors will be reviewed on a recurring basis using this report. Responsible Individuals: Primary: Carys Church, Procurement Manager Secondary: Elizabeth Knight, Chief Compliance Officer; Mary Ammer, Sr. Director of Accounting and Finance Anticipated Completion Date: April 2026

View Audit 391668

Finding 1179269 (2025-002)

Material Weakness 2025

Catholic Charities of the Archdiocese of St. Paul and Minneapolis

MN

Special Tests & Provisions Questioned Costs HUD Housing Programs § 200.303

Finding 2025-002 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being reviewed befor...

Finding 2025-002 Federal Agency Name: Department of Housing and Urban Development Assistance Listing Number: 14.267 Program Name: Continuum of Care Finding Summary: Catholic Charities’ internal controls did not operate as designed, which resulted in rent reasonableness tests not being reviewed before the rent was paid. Corrective Action Plan: The Senior Division Director (now VP of Housing) issued the Rent Reasonableness Policy (Scattered Sites) on May 14, 2025. This policy was approved by the CEO on June 3, 2025, and was disseminated to all applicable staff via the Learning Management System (Bridge). Staff are required to read and electronically sign acknowledgement of every policy sent to them via Bridge. Managers in the Scattered Site program were trained on the policy and procedure in July 2025. To ensure compliance with this policy, the VP of Housing will audit all client files at least twice annually. The first audit is scheduled for March 11, 2026. Results of the internal audit will be shared with the Compliance Department for further assessment and action. Responsible Individuals: Kristen Brown, Vice-President of Housing Anticipated Completion Date: March 31, 2026

View Audit 391668

Finding 1179255 (2025-001)

Material Weakness 2025

Washington College

MD

Matching / Level of Effort / Earmarking Questioned Costs Student Financial Aid § 200.303

Student Financial Aid Cluster – National Student Loan Data System (NSLDS) Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations....

Student Financial Aid Cluster – National Student Loan Data System (NSLDS) Reporting Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College review its reporting procedures to ensure that students’ statuses are accurately and timely reported to NSLDS as required by regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: We have reviewed and updated our documentation, as needed; we have worked with our vendor to locate one source of errors and have corrected those issues in our database; we have started a two-person check on our enrollment and graduation uploads. Name(s) of the contact person(s) responsible for corrective action: Kelly Rowett-James Planned completion date for corrective action plan: We have completed the documentation review and the work with the vendor. We have started our two-person check on enrollment uploads and will continue to do so going forward; our first graduation upload will be done in May and we will start our two-person check for that type of transmission with that upload. If the U.S. Department of Education has questions regarding this plan, please call Jennifer Gallagher at 410-778-7765.

View Audit 391638

Finding 1179249 (2025-003)

Material Weakness 2025

School Town of Speedway

IN

Matching / Level of Effort / Earmarking Special Tests & Provisions § 200.303

FINDING 2025-003 Finding Subject: COVID-19 – Education Stabilization Fund-Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Eric Rosebrough, Director of Facilities Contact Phone Number and Email Address: 317-244-0236 erosebrough@speedwayschools.n...

FINDING 2025-003 Finding Subject: COVID-19 – Education Stabilization Fund-Special Tests and Provisions – Wage Rate Requirements Contact Person Responsible for Corrective Action: Eric Rosebrough, Director of Facilities Contact Phone Number and Email Address: 317-244-0236 erosebrough@speedwayschools.net Views of Responsible Officials: We concur with the finding Description of Corrective Action Plan: The Superintendent and Director of Facilities will monitor each contract that must include Davis Bacon requirements, wage rate requirements, and require the contractor to complete the prescribed Department of Labor wage rate form. Timesheets will be requested from the contractor in a timely manner. This is a repeat finding because contracts were tested from 2023 in the current audit period, and management was made aware of this rule in 2024 from the prior audit Anticipated Completion Date: Completed May 31, 2024, there have been no ESSER Equipment purchases since 2023, therefore, no action is needed.

View Audit 391619

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