Corrective Action Plans

Finding 1202924 (2025-005)

Material Weakness 2025

WI

Material Weakness Period of Performance Matching / Level of Effort / Earmarking § 200.303

2025-005 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Period of Performance Auditor's Recommendation: We recommend that the Organization maintain effective internal controls over period of performance requirements Corrective Action: One City under...

2025-005 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Period of Performance Auditor's Recommendation: We recommend that the Organization maintain effective internal controls over period of performance requirements Corrective Action: One City understand the requirements for expenditure of grant funds in the proper period and will work more closely with the funders to ensure that documentation exists when a no cost extension is needed. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists in the grant management system. Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026

View Audit 396186

Finding 1202923 (2025-004)

Material Weakness 2025

One City Schools, Inc.

WI

Cash Management Material Weakness Matching / Level of Effort / Earmarking § 200.303

2025--004 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Cash Management Auditor's Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Corrective Action: One City ad...

2025--004 US Department of Education Material Weakness in Internal Control over Compliance and Other Matter Cash Management Auditor's Recommendation: One City Schools, Inc. should implement appropriate internal controls for reviewing funding claims prior to submission. Corrective Action: One City adopted a new grants management process which requires that all submitted claims are reviewed and signed by two responsible officials. Evidence of approvals will be maintained in the electronic grant files. In addition, One City has developed a training tool so that all staff who have grant claiming authority must participate in the training. The new Chief Financial Officer will monitor compliance with the policy and ensure proper documentation exists. Responsible for Corrective Action: Scott R Haumersen CPA, CGMA Shaumersen@onecityschools.org 608-575-4950 Anticipated Completion Date: June 30th, 2026

View Audit 396186

Finding 1201513 (2025-005)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

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

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 ...

2025-005 Special Tests and Provisions – Wage Rate Requirements We acknowledge BDO’s finding regarding the lack of internal controls to ensure certified payrolls were submitted timely and reviewed in accordance with Wage Rate Requirements (Davis Bacon Act and 29 CFR Part 5). During the FY25 audit, 3 out of 21 contractor and subcontractor certified payrolls tested were not submitted timely. VOAWW recognizes that timely receipt and review of certified payrolls is essential to ensuring compliance with federal wage requirements. To strengthen internal controls and ensure certified payrolls are consistently obtained, reviewed, and retained, VOAWW will implement the following corrective actions: Implementation of Certified Payroll Submission Controls Before the end of FY26, VOAWW will implement internal controls requiring contractors and subcontractors to submit certified payrolls with each pay application. These controls will include: • A requirement that certified payrolls be submitted prior to payment • A standardized checklist for verifying receipt of certified payrolls • Documentation of the review and approval process • Follow up procedures for missing or incomplete payrolls These steps will ensure certified payrolls are consistently obtained and reviewed before payment is released. Training for Staff on Wage Rate Requirements Beginning in FY26, staff responsible for managing HUD funded construction projects will receive training on: • Davis-Bacon and related wage requirements • Certified payroll documentation standards • Review procedures and red flags • Requirements under 29 CFR Part 5 Contractor Communication and Expectations Before the end of FY26, VOAWW will update contractor communication materials to clearly outline certified payroll requirements, including: • Submission timelines • Required documentation • Consequences for noncompliance • Points of contact for questions or clarifications These expectations will be reinforced during project kick off meetings and throughout the contract period. Centralized Tracking of Certified Payrolls By the end of FY26, VOAWW will implement a centralized tracking log for all certified payroll submissions. This log will document: • Receipt dates • Review dates • Reviewer initials • Any follow up actions taken This will ensure a complete audit trail and consistent monitoring of compliance. These corrective actions will strengthen VOAWW’s internal controls over Wage Rate Requirements, ensure timely receipt and review of certified payrolls, and reduce the risk of noncompliance with federal labor standards. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201508 (2025-003)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Allowable Costs / Cost Principles § 200.303

2025-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles We acknowledge BDO’s finding regarding an unallowable cost that was initially charged to the Home Investment Partnerships Program. Although the error was able to be rectified, the initial error indicated that internal controls...

2025-003 Activities Allowed or Unallowed, Allowable Costs/Cost Principles We acknowledge BDO’s finding regarding an unallowable cost that was initially charged to the Home Investment Partnerships Program. Although the error was able to be rectified, the initial error indicated that internal controls did not prevent or detect the unallowable charge at the time of posting. To strengthen internal controls over allowable costs and ensure expenditures charged to federal programs comply with Uniform Guidance and program-specific requirements, VOAWW will implement the following corrective actions: Strengthened Review of Allowable Costs Before the end of FY26, the Finance Department will enhance its invoice review procedures for all programs. This strengthened review will include verification of: • Allowability under 2 CFR §200 Subpart E • Program specific requirements • Contract terms and approved budgets • Supporting documentation for each cost Review steps will be documented to ensure a clear audit trail. Training for Staff on Federal Allowable Cost Requirements Beginning in FY26, Finance, Grants, and Contract Compliance staff responsible for coding, approving, or reviewing federal expenditures will receive training on: • Allowable cost principles under 2 CFR §200.403–.405 • Program specific cost restrictions • Documentation standards • The importance of internal controls over federal expenditures Before the end of FY26, VOAWW will implement internal controls to ensure that allowability determinations are made internally by trained staff prior to charging costs to federal awards. Centralized Federal Award Compliance Reference By the end of FY26, Contract Compliance will maintain a centralized compliance reference for all federal programs, including allowability rules, program specific restrictions, and documentation requirements. Finance staff will reference this tool during invoice review to ensure consistent application of federal requirements. These corrective actions will strengthen VOAWW’s internal controls over allowable costs, reduce the risk of unallowable expenditures being charged to federal programs, and ensure compliance with Uniform Guidance and HUD program requirements. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201506 (2025-002)

Material Weakness 2025

Volunteers of America Western Washington and Subsidiary

WA

Reporting Allowable Costs / Cost Principles § 200.303 § 200.403

2025-002 Accounts Payable Cutoff We acknowledge BDO’s inquiry regarding an invoice that appeared to relate to the prior fiscal period. The invoice was received after Accounts Payable closed without advance notification for accrual. BDO noted a similar issue in an additional sample. To strengthen our...

2025-002 Accounts Payable Cutoff We acknowledge BDO’s inquiry regarding an invoice that appeared to relate to the prior fiscal period. The invoice was received after Accounts Payable closed without advance notification for accrual. BDO noted a similar issue in an additional sample. To strengthen our accounts payable cutoff controls and prevent similar issues, we will implement the following improvement measures: • Formalize the Accrual Process – While an accrual process already exists, before the end of FY26, we will document and strengthen the accrual procedures by requiring Program Managers to notify Finance, specifically the AP team inbox, when work from a vendor has been completed, but an invoice has not yet been received, on an annual basis by a given deadline. This will ensure that known obligations are captured in the correct fiscal period. • Strengthen Review of Post-Year-End Invoices – While regular review of invoices is already a part of our regular AP process, Accounts Payable will implement a more stringent review process before the end of FY26 for all invoices received in the first period after fiscal year end, including verification of service dates, contract terms, and deliverables. • Enhanced Communication Expectations – Program Managers will receive training and guidance before the end of FY26 on the importance of timely invoice submission and the need to alert Finance when delays occur. • Documentation of Cutoff Decisions – For invoices received after close, before the end of FY26, Accounts Payable will document the receipt date, supporting details, and rationale for the period in which the expense is recorded to maintain a clear audit trail. These improvements will strengthen our internal controls over AP cutoff, improve the consistency of accrual practices, and reduce the risk of misstatements due to late or ambiguous invoices. Responsible Individual: Claire Danielson, VIP of Finance Estimated Completion Date: June 30, 2026

View Audit 396088

Finding 1201495 (2025-003)

Material Weakness 2025

Lewistown Community Unit Schools District 97

IL

Internal Control / Segregation of Duties Reporting § 200.303

Condition: Multiple individuals are responsible for the preparation and submission of the District's quarterly exepnditure reports; however, the expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of t...

Condition: Multiple individuals are responsible for the preparation and submission of the District's quarterly exepnditure reports; however, the expenditure reports filed for September 30, 2024 included expenditures in the amount of $22,040 that were neither obligated nor liquidated by the date of the report. Plan: Mannagement will review all expenditure reports. Only expenditures obligated within the grant period will be included on the expenditure report. Any obligations not yet liquidated will be reported as such.

View Audit 396063

Finding 1201487 (2025-010)

Material Weakness 2025

William Peace Universirty

NC

Student Financial Aid Internal Control / Segregation of Duties Material Weakness § 200.303

Segregation of Duties Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. ...

Segregation of Duties Recommendation: We recommend the University implement additional internal controls to ensure proper segregation of duties. This includes hiring additional staff or redistributing responsibilities to separate the functions of authorizing, processing, and reviewing transactions. Additionally, ongoing training should be provided to financial aid staff on the importance of internal controls and compliance with Title IV regulations. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management will review its staffing and the need for separation of duties as part of an effective internal control system and take appropriate actions.. Name(s) of the contact person(s) responsible for corrective action: Vice President for Enrollment Management Damon Wade, Director of Financial Aid Deniesha Newby, and Controller Will Gibbons Planned completion date for corrective action plan: June 30, 2026

View Audit 396041

Finding 1201445 (2025-001)

Material Weakness 2025

County of Orange, California

CA

Reporting § 200.303 § 200.331 § 200.502 § 200.510

Program: Congressionally Recommended Awards / HOME Investment Partnerships Program / Homeland Security Grant Program / Epidemiology and Laboratory Capacity for Infectious Disease Federal Financial Assistance Listing Number: 16.753 / 14.239 / 97.067 / 93.323 Federal Grantor: U.S. Department of Justic...

Program: Congressionally Recommended Awards / HOME Investment Partnerships Program / Homeland Security Grant Program / Epidemiology and Laboratory Capacity for Infectious Disease Federal Financial Assistance Listing Number: 16.753 / 14.239 / 97.067 / 93.323 Federal Grantor: U.S. Department of Justice / U.S. Department of Housing and Urban Development / U.S. Department of Homeland Security / U.S. Department of Health and Human Services Award No. and Year: Multiple Compliance Requirements: Other – Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) - Schedule of expenditures of Federal awards Type of Finding: Material Weakness in Internal Control Over Compliance Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) §200.510(b) states that the auditee (the County) must prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the auditee’s financial statements, which must include the total federal awards expended as determined in accordance with §200.502. §200.331 of the Uniform Guidance states the County is responsible for making case-by-case determinations to determine whether the entity receiving the Federal funds is a subrecipient. In addition, §200.303 of the Uniform Guidance states that the County must establish and maintain effective internal control over the federal awards, including controls over the accuracy of program information and expenditure amounts. Condition: During our audit procedures performed over the SEFA we noted the following: • The Sheriff-Coroner Department did not properly identify the amount expended for the Congressionally Recommended Awards, AL No. 16.753. The expenditures reported by the Department were overstated by $2,638,516. • The Orange County Community Resources Department did not properly identify the amount of Federal funding passed through to subrecipients for the HOME Investment Partnerships Program, AL No. 14.239. The amount passed through to subrecipients reported by the Department was overstated by $4,500,624. • The Sheriff-Coroner Department did not properly identify the amounts expended for the Homeland Security Grant Program, AL No. 97.067. The expenditures reported by the Department were overstated by $715,489. • The Orange County Health Care Agency (HCA) did not properly identify the amount expended for the Epidemiology and Laboratory Capacity for Infectious Disease program, AL No. 93.323. The expenditures reported by the Agency were overstated by $486,000. Cause: As a result, the County lacked adequate internal controls to ensure the SEFA is completely and accurately stated. Specifically, the County’s processes for recording and tracking expenditures of Federal awards are not designed so that expenditures are identified when incurred. In addition, the County’s processes for identifying and reporting subrecipients are not designed to ensure appropriate reporting on the SEFA. Effect: Adjustments to the SEFA were required. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: No sampling was used. Program expenditures and amounts passed through to subrecipients were reconciled to the supporting records. Repeat Finding from Prior Years: No. Recommendation: The County, including all its reporting departments, should follow existing policies, procedures and internal controls to ensure all expenditures and amounts passed through to subrecipients are accurately tracked and reported on the SEFA. Personnel knowledgeable of federal expenditures should review amounts coded to federal programs for completeness and accuracy. The SEFA should be prepared and reviewed in a timely manner and reconciled to underlying records as well as the basic financial statements. Management Response and Corrective Action Plan: Health Care Agency: 1. Person Responsible: David Santalahti, HCA Claims & Financial Reporting Manager 2. Corrective action plan: HCA Accounting will review and enhance its procedures and training for analysis and tracking federal award expenditures to ensure expenditures are reported in the appropriate fiscal year period. 3. Anticipated Implementation date: June 30, 2026 Orange County Community Resources: 1. Person Responsible: Bill Malohn, OCCR Accounting Manager 2. Corrective action plan: Concur. OCCR has established policies and internal controls to ensure all expenditures and amounts passed through to subrecipients are accurately tracked and reported on the SEFA. Appropriate personnel review amounts coded to federal programs for completeness and accuracy. We prepare and review the SEFA in a timely manner and reconcile to underlying records as well as the basic financial statements. In this particular situation, we miscategorized one provider as a subrecipient and reported the related funding as such on the SEFA. This oversight had no impact on the total amount we reported on the SEFA. We will be sure to follow our policies and procedures to ensure accurate SEFA reporting. 3. Anticipated Implementation date: February 2, 2026 Sheriff-Coroner: 1. Person Responsible: Monique Vansuch, Fiscal Administrator 2. Corrective action plan: The Sheriff-Coroner Department acknowledges the finding and recognized federal grant expenditure incurred is defined as when expenditures are delivered and/or services are performed rather than when the expenditures are paid. We will strengthen the internal controls to ensure grant expenditures are reported per the Uniform Guidance. 3. Anticipated Implementation date: June 30, 2026

View Audit 395982

Finding 1201419 (2025-005)

Material Weakness 2025

County of Orange, California

CA

Allowable Costs / Cost Principles § 200.303 § 200.430

Program: HIV Emergency Relief Project Grants (Ryan White) Federal Financial Assistance Listing Number: 93.914 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 6H89HA00019-32-04; 2024 Compliance Requirements: Activities Allowable or Unallowed and Allowable Costs/Cost ...

Program: HIV Emergency Relief Project Grants (Ryan White) Federal Financial Assistance Listing Number: 93.914 Federal Grantor: U.S. Department of Health and Human Services Award No. and Year: 6H89HA00019-32-04; 2024 Compliance Requirements: Activities Allowable or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the 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. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing, for one (1) out of sixty (60) payroll expenditures, we noted the timecard did not contain documented evidence of supervisory approval. Cause: The County’s internal control procedures were not consistently followed to ensure that the review and approval of timecards was documented. Effect: Lack of documented review for personnel hours could lead to an increased risk that unallowable or inaccurate activities and costs to be charged to the Federal program. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sampling of sixty (60) timecards were selected for testing out of a population of 5,994. The condition noted above was identified during our procedures related to activities allowed or unallowed and allowable costs/cost principles. Repeat Finding from Prior Years: No. Recommendation: We recommend that the County strengthen its policies and procedures to ensure that timecards consistently include documented evidence of supervisor approval prior to payroll processing. The County should also establish compensating controls for circumstances where timely supervisory approvals is not possible, and ensure such controls are consistently documented. Management Response and Corrective Action Plan: 1. Person Responsible: Barbara Harano, HCA Disbursements Manager 2. Corrective action plan: HCA Payroll will continue to review the Unapproved Timesheets Report in OC Time and send reminder emails to all supervisors with pending approvals. If supervisory approvals cannot be obtained by the OC Time timesheet upload deadlines, HCA Payroll will ensure documented timesheet approvals are appended through the OC Time amendment process and archived in the Unit’s shared drive. 3. Anticipated Implementation date: January 22, 2026

View Audit 395982

Finding 1201417 (2025-008)

Material Weakness 2025

County of Orange, California

CA

Allowable Costs / Cost Principles Eligibility Significant Deficiency § 200.303

Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Financial Assistance Listing Number: 93.566 Federal Grantor: U.S. Department of Health and Human Services Pass Through: California Department of Social Services Award No. and Year: Various Compliance Req...

Program: Refugee and Entrant Assistance State/Replacement Designee Administered Programs Federal Financial Assistance Listing Number: 93.566 Federal Grantor: U.S. Department of Health and Human Services Pass Through: California Department of Social Services Award No. and Year: Various Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Eligibility Type of Finding: Significant Deficiency in Internal Control Over Compliance and Instance of Noncompliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the 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. 45 CFR Part 400, prescribes the eligibility conditions refugees must meet to receive RCA including the following: • RCA recipients must meet the general eligibility requirements for immigration status and refugee identification in accordance with 45 CFR §400.40 - §400.44. • RCA is limited to refugees who are ineligible for TANF, SSI, OAA, AB, APTD, and AABD in accordance with 45 CFR §400.53. • Mandatory work registrants must comply with work requirements and may not voluntarily quit or refuse suitable employment within 30 days prior to application; benefits must be terminated when requirements are not met (45 CFR §§400.75(a), 400.77, and 400.82(a)). • RCA payments may not exceed ORR-authorized rates and may not be less than the State TANF payment rate (45 CFR §§400.60(b) and 400.60(d); ORR PL 22-01). Condition: During our testing of the Social Services Agency’s (SSA) compliance with eligibility and allowable cost/cost principles, we noted the following: • One (1) instance of payment issued to a participant who did not meet eligible immigration status requirements. • One (1) instance of payment issued to a participant who was eligible for another federally funded cash assistance program. • One (1) instance of payment issued to a participant who failed to meet the mandatory work registrant requirements within the required time frame. • One (1) instance of payment issued to a participant using an incorrect benefit rate. Cause: Controls over eligibility determination and benefit rate calculation were not consistently applied, including insufficient verification and supervisory review of eligibility criteria and payment amounts. Effect: Program funds were expended for ineligible participants and an incorrect benefit rate was used, increasing the risk of noncompliance with federal requirements. Questioned Costs: Questioned costs for cases tested in which we determined to be ineligible to receive cash assistance was $1,814. Context/Sampling: A nonstatistical sample of sixty (60) out of all active program participants were sampled. For ineligible cases, we have projected questioned costs against the remaining population for a total of $24,276. The underpayment related to an incorrect benefit rate used was not projected as questioned costs as this did not result in an over-expenditure of federal funds The condition above was identified during our procedures over eligibility, activities allowed or unallowed, and allowable costs/cost principles testing. Repeat Finding from Prior Years: Yes. Recommendation: We recommend that the SSA department strengthen its internal controls to ensure that program eligibility criteria and benefit determinations are properly supported. Management Response and Corrective Action Plan: 1. Person Responsible: Rosa Palacios, Human Services Manager 2. Corrective action plan: Staff Guidance and Eligibility Reminder: Program will issue a reminder to all eligibility staff reinforcing program eligibility requirements and the importance of thoroughly reviewing documentation when making eligibility determinations. The reminder will highlight key areas identified in the audit findings, including verification of immigration eligibility, identifying applicants who may qualify for other federally funded cash assistance programs, and ensuring accurate benefit determinations. Work Requirement Reporting Coordination: Program will also communicate with the contracted provider responsible for monitoring work participation requirements to reinforce expectations regarding timely reporting of participant non-compliance. Internal staff will be reminded to take timely action once non-compliance is reported to ensure benefits are discontinued in accordance with program requirements. System Correction: The incorrect benefit rate identified during the audit was related to a prior system configuration issue that required manual processing. The system has since been updated. Program staff will continue to monitor system updates and verify benefit calculations as needed. 3. Anticipated Implementation date: June 30, 2026

View Audit 395982

Finding 1201405 (2025-004)

Material Weakness 2025

County of Orange, California

CA

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.430

Program: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing Number: 10.557 Federal Grantor: U.S. Department of Agriculture Pass-Through: California Department of Public Health Award No. and Year: 22-10270 A03 and 2022 Compliance Requireme...

Program: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Federal Financial Assistance Listing Number: 10.557 Federal Grantor: U.S. Department of Agriculture Pass-Through: California Department of Public Health Award No. and Year: 22-10270 A03 and 2022 Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: 2 CFR Section 200.303(a), Internal Controls, states that the 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. 2 CFR Section 200.430, Compensation – Personal Services, states that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control that provides reasonable assurance that the charges are accurate, allowable, and properly allocated. Condition: During our testing of the HCA’s provisions for activities allowed or unallowed and allowable costs/cost principles requirements, we noted that for one (1) of sixty (60) payroll samples tested, the employee was able to review and approve their own timecard. Cause: It was determined that the control deficiency resulted from a system configuration error that permitted the employee to approve their own timecard under the supervisor/manager review role. Effect: Failure to consistently apply internal controls over payroll charges increases the risk that unallowable or unsupported payroll costs could be charged to the Federal program and not be detected in a timely manner. Questioned Costs: No questioned costs were identified as a result of our procedures. Context/Sampling: A nonstatistical sampling of sixty (60) timecards was selected for testing out of a population of 1,144. The condition noted above was identified during our procedures related to activities allowed or unallowed and allowable costs/cost principles. Repeat Finding from Prior Years: No. Recommendation: Management should ensure appropriate segregation of duties within the payroll system by restricting approval authority to independent supervisors or managers and implementing controls to prevent self-approval. In addition, management should periodically review user access roles and system configurations to confirm that approval controls are operating as designed and that payroll charges to Federal programs are allowable, properly allocated, and adequately supported. Management Response and Corrective Action Plan: 1. Person Responsible: Barbara Harano, HCA Disbursements Manager 2. Corrective action plan: An unexpected change occurred in the OC Time system that allowed an employee to both submit and approve their own timesheet. This issue had been previously reported and resolved. Auditor-Controller IT has reported the issue again to the timekeeping system vendor and is currently validating and testing the updated configuration to ensure the problem does not recur. 3. Anticipated Implementation date: June 30, 2026

View Audit 395982

Finding 1201384 (2025-002)

Material Weakness 2025

Southern Oregon University

OR

Student Financial Aid § 200.303

Special Tests - Enrollment Reporting Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the thi...

Special Tests - Enrollment Reporting Federal Direct Student Loans and Federal Pell Grant Program - Assistance Listing No. 84.268 and 84.063 Recommendation: We recommend that the University enhance its policies and procedures regarding enrollment reporting including additional monitoring over the third-party service provider to ensure that reporting is completed accurately and timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: New registrar hired 9/2025 has enhanced policies and procedures regarding enrollment reporting by initiating regular and frequent (weekly/biweekly) contact with the National Student Clearinghouse (NSC) to ensure that reporting is completed accurately and timely. Names of the contact person responsible for corrective action: Jennifer Bratz Planned completion date for corrective action plan: Correction action plan involves ongoing regular communication with NSC and regular monitoring of reports for timeliness and accuracy, no completion date.

View Audit 395962

Finding 1191766 (2025-001)

Material Weakness 2025

Illinois Housing Development Authority

IL

Subrecipient Monitoring HUD Housing Programs § 200.303 § 200.332

The Authority agrees with the finding. The Authority will implement additional internal controls, including quality control of completed inspection, documentation, and inspection scheduling. Additionally, the Authority recognizes that the volume of required annual inspections has increased beyond ex...

The Authority agrees with the finding. The Authority will implement additional internal controls, including quality control of completed inspection, documentation, and inspection scheduling. Additionally, the Authority recognizes that the volume of required annual inspections has increased beyond existing Full Time Equivalent (FTE) capacity; therefore, an RFP for the third-party inspection vendor has been issued to supplement internal resources and support timely completion of inspections.

View Audit 395570

Finding 1191659 (2025-001)

Material Weakness 2025

Asian University for Women (auw) Support Foundation

MA

Reporting Internal Control / Segregation of Duties § 200.303 § 200.510

Finding: 2025-001 Reimbursable federal grant revenue Responsible Person: Cecilia Frerotte Title: Contract CFO Phone Number: 617-261-8186 Anticipated Completion Date: June 30, 2026 Corrective Action: Management will enhance grant review and reconciliation procedures to ensure that reimbursable expend...

Finding: 2025-001 Reimbursable federal grant revenue Responsible Person: Cecilia Frerotte Title: Contract CFO Phone Number: 617-261-8186 Anticipated Completion Date: June 30, 2026 Corrective Action: Management will enhance grant review and reconciliation procedures to ensure that reimbursable expenditures incurred under cost-reimbursement grants are properly recognized as contribution revenue and federal expenditures in the appropriate period. These procedures will include a grant-by-grant reconciliation of reimbursement requests, refundable advances, award terms, general ledger balances, amounts reported on the Schedule of Expenditures of Federal Awards (SEFA) and amounts reported in all other grant-related compliance reports, as applicable. Management will also formalize and expand supervisory review and approval controls over all grant compliance reporting and year end financial reporting, including the SEFA. In addition, the Board plans to increase the size of the Audit Committee to include members with substantial experience in auditing and grant program oversight. The Audit Committee will meet regularly with both the external auditors and the outsourced accounting firm to provide enhanced governance and oversight of grant accounting and compliance matters.

View Audit 395510

Finding 1191579 (2025-001)

Material Weakness 2025

Oregon State University

OR

Reporting § 200.303 § 200.502 § 200.510

2025-001: Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Educational Stabilization Fund ASSISTANCE LISTING Numbers: 84.425C – Governor’s Emergency Education Relief Fund 84.425R – Emergency Assistance to Non-Public Schools 84.425U – Elementary and Secondary S...

2025-001: Allowable Costs/Cost Principles Federal Agency: Department of Education Federal Program: Educational Stabilization Fund ASSISTANCE LISTING Numbers: 84.425C – Governor’s Emergency Education Relief Fund 84.425R – Emergency Assistance to Non-Public Schools 84.425U – Elementary and Secondary School Emergency Relief Fund 84.425V – Emergency Assistance to Non-Public Schools Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matter Recommendation: We recommend that the University evaluate its cutoff procedures to ensure that federal costs are identified and reported in the correct fiscal year. We also recommend that the University evaluate its internal controls to ensure that federal awards are properly identified as such at inception. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: OSU is implementing a campus-wide Administrative Modernization Program (AMP) to update technology, improve efficiencies, and ensure a comprehensive internal control environment. This modernization includes redesigning the university’s administrative and grant processes, including budget development, payroll lifecycle, employee recruitment, grant effort reporting, procurement, and others. A primary aspect of this optimization is a transition of the university’s enterprise resource planning (ERP) system from Banner to Workday effective July 1, 2026. To reflect this system transition, OSU’s actions in response to the finding will be taken in two stages: 1. For FY26, the Division of Research and Innovation (DRI) will run reports and screen for anomalies and mismatches of revenue type and fund type to identify awards with the correct federal fund when a federal program is identified with an ALN#. The screening will take place before the fiscal year end, allowing time for corrections to be made in Banner while the fiscal year is still active. 2. For FY27 and beyond, rather than a warning, critical custom validations will be required and established in Workday as follows: • Any award that uses an ALN# also must include the appropriate Fund and Revenue Category worktags on the award line • Any award with a federal sponsor or federal prime sponsor must have ALN# entered • Any award with a federal sponsor or federal prime sponsor must include the appropriate Fund and Revenue Category worktag on the award line Name of the contact person responsible for corrective action: Jennifer Creighton, Associate Vice President for Research Administration, Finance and Operations Planned completion date for corrective action plan: Corrective action to screen for anomalies and mismatches of revenue type and fund type in Banner to ensure awards are identified with the correct federal fund will occur by June 30, 2026. The establishment of custom validations in Workday to ensure identification of federal awards will occur and be ongoing with the new system implementation after July 1, 2026.

View Audit 395445

Finding 1191568 (2025-006)

Material Weakness 2025

PROJECT WORTHMORE

CO

Internal Control / Segregation of Duties HUD Housing Programs Reporting § 200.303

Management will implement a formal review and approval process for Federal reporting to ensure compliance with 2 CFR 200.303. • Review Process: Establish standardized procedures for preparation, review, and submission of Federal reports. • Roles and Responsibilities: Assign responsibility for prepar...

Management will implement a formal review and approval process for Federal reporting to ensure compliance with 2 CFR 200.303. • Review Process: Establish standardized procedures for preparation, review, and submission of Federal reports. • Roles and Responsibilities: Assign responsibility for preparation and independent review of reports. • Documented Approval: Require documented evidence of review and approval. • Supporting Documentation: Ensure all reported amounts are supported by underlying records and reconciliations. • Training: Prior to next Federal Grant requiring a single audit, provide training on Federal reporting requirements and internal control expectations.

View Audit 395436

Finding 1191530 (2025-009)

Material Weakness 2025

City of Montgomery, Alabama

AL

Subrecipient Monitoring Material Weakness Reporting § 200.303 § 200.328

Management concurs. The City will strengthen its policies and procedures over the grant reporting process to ensure that the review and approval of federal reports is documented. This will be implemented by September 2026.

View Audit 395426

Finding 1191503 (2025-003)

Material Weakness 2025

Western Illinois University

IL

Subrecipient Monitoring Cash Management Reporting § 200.303 § 200.305

Finding Number: 2025-003 - Inadequate Internal Control over Subrecipient Payments Condition: Western Illinois University (University) did not have adequate procedures in place to complete a timely disbursement of requested pass-through funds to subrecipients within the required time period. Planned ...

Finding Number: 2025-003 - Inadequate Internal Control over Subrecipient Payments Condition: Western Illinois University (University) did not have adequate procedures in place to complete a timely disbursement of requested pass-through funds to subrecipients within the required time period. Planned Corrective Action: The University is committed to developing a comprehensive plan to ensure compliance with payment of pass-through funds policies and procedures. Contact person responsible for corrective action: Mary Pat Wolhford Anticipated Completion Date: 06/30/2026

View Audit 395418

Finding 1191502 (2025-002)

Material Weakness 2025

Western Illinois University

IL

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

Finding Number: 2025-002 - Inadequate Internal Control over Return of Title IV Funds Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely return of Title IV funds for all students within the required time period. Planned Correc...

Finding Number: 2025-002 - Inadequate Internal Control over Return of Title IV Funds Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate and timely return of Title IV funds for all students within the required time period. Planned Corrective Action: From University Response: The University is committed to developing a comprehensive plan to ensure compliance with return of Title IV funds policies and procedures. From last year's CAP: The University has streamlined the process of R2T4 to prevent delays in processing. This enhanced process creates a countdown report to prioritize R2T4 calculation when staff resources as strained. Contact person responsible for corrective action: Roberta Smith Anticipated Completion Date: 06/30/2026

View Audit 395418

Finding 1191494 (2025-001)

Material Weakness 2025

Western Illinois University

IL

Student Financial Aid Reporting Matching / Level of Effort / Earmarking § 200.303

Finding Number: 2025-001 - Inadequate Internal Control over Student Enrollment Reporting Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. Planned Corrective Action: The University is implementing...

Finding Number: 2025-001 - Inadequate Internal Control over Student Enrollment Reporting Condition: Western Illinois University (University) did not have adequate procedures in place to complete accurate enrollment reporting for all students. Planned Corrective Action: The University is implementing enhanced internal controls to ensure enrollment status changes and degree confirmations are being appropriately submitted and reported. Contact person responsible for corrective action: Roberta Smith/Sarah Lawson Anticipated Completion Date: 06/30/2027

View Audit 395418

Finding 1191481 (2025-003)

Material Weakness 2025

Housing Authority of the City of Westwego, Louisiana

LA

Reporting HUD Housing Programs Material Weakness § 200.303 § 200.516

FINDING 2025 003 — MATERIAL WEAKNESS (INTERNAL CONTROL OVER COMPLIANCE) — GRANT ACCOUNTING AND CLOSE PROCESS AFFECTING MAJOR FEDERAL PROGRAMS — (PROGRAMS: ALN 14.872 AND ALN 97.036) Cross reference: This finding is directly related to Financial Statement Finding 2025 001. Contact Person: Cantrese Wi...

FINDING 2025 003 — MATERIAL WEAKNESS (INTERNAL CONTROL OVER COMPLIANCE) — GRANT ACCOUNTING AND CLOSE PROCESS AFFECTING MAJOR FEDERAL PROGRAMS — (PROGRAMS: ALN 14.872 AND ALN 97.036) Cross reference: This finding is directly related to Financial Statement Finding 2025 001. Contact Person: Cantrese Wilson Jones, Executive Director Corrective Action Planned: Corrective actions for this compliance finding will be addressed through the same improvements outlined in Finding 2025 001, including: 1. Adoption of a documented monthly and year end closing calendar. 2. Timely reconciliation of all grant related accounts. 3. Enhanced supervisory review and documentation of compliance related reporting, including SEFA preparation. 4. Strengthening internal controls to ensure grant activity is recorded in the proper period. Anticipated Completion Date: June 30, 2026 Management Response: Management concurs with the finding and will implement the corrective measures beginning FY 2026.

View Audit 395397

Finding 1191450 (2025-002)

Material Weakness 2025

Langston University

OK

Equipment & Real Property Management § 200.303 § 200.313

Research and Development – Assistance Listing No. Various Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. Various Higher Education Institutional Aid – Assistance Listing No. Various Recommendation: We recommend the University ensure that a physical inventory over equip...

Research and Development – Assistance Listing No. Various Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. Various Higher Education Institutional Aid – Assistance Listing No. Various Recommendation: We recommend the University ensure that a physical inventory over equipment is completed at least every two years. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is committed to strengthening its physical inventory process for tracking fixed assets. We are actively recruiting a Capital Asset Accountant. This is a new position within the Controller’s area that will assume primary responsibility for equipment management. The position will assume the following equipment management responsibilities: • Coordinate the accounting of equipment acquisitions/dispositions/disposals daily. • Place physical tags on all new equipment purchases, creating a video log along the way. • Perform a physical inventory of equipment, department by department, throughout the year. At a minimum, every item should be verified at least once per fiscal year. • Maintain an accurate record of additions/dispositions/disposals in Banner, which supports the external audit and reflects the results of the above-mentioned physical inventories. • Coordinate the periodic disposal/sale/auction of unneeded physical assets. In addition, existing personnel are actively working to ensure a complete physical inventory has been conducted by fiscal year-end. Name(s) of the contact person(s) responsible for corrective action: Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: June 2026

View Audit 395389

Finding 1191428 (2025-003)

Material Weakness 2025

Langston University

OK

Procurement, Suspension & Debarment Significant Deficiency § 200.303 § 200.318

Research and Development – Assistance Listing No. 10.205 Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. 10.512 Higher Education Institutional Aid – Assistance Listing No. 84.031 Recommendation: We recommend that the University review policies and procedures for procur...

Research and Development – Assistance Listing No. 10.205 Agriculture Extension at 1890 Land-grant Institutions – Assistance Listing No. 10.512 Higher Education Institutional Aid – Assistance Listing No. 84.031 Recommendation: We recommend that the University review policies and procedures for procurement to ensure that every applicable transaction is going through the proper procurement procedures Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is reviewing existing procurement policies and procedures and strengthening processes as necessary. Additionally, training is being provided to relevant personnel to ensure an understanding of proper procurement procedures. Name(s) of the contact person(s) responsible for corrective action: Ms. Andrea Sherwood, Assistant Director, Grants and Contracts Financial Administration at Oklahoma State University and Ms. Nykkia Harris, Controller for Fiscal and Administrative Affairs Planned completion date for corrective action plan: June 2026

View Audit 395389

Finding 1191374 (2025-005)

Material Weakness 2025

Langston University

OK

Student Financial Aid Matching / Level of Effort / Earmarking Material Weakness § 200.303

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal...

Student Financial Aid Cluster: Federal Supplemental Educational Opportunity Grant – Assistance Listing No. 84.007 Federal Work Study Program – Assistance Listing No. 84.033 Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Federal TEACH Grant Program – Assistance Listing No. 84.379 Recommendation: We recommend the University review current processes for reporting to NSLDS and implement additional procedures to ensure submissions are reported timely and accurately. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: This is a repeat finding that was first presented to the University in conjunction with the release of the 2022 audit report in November 2023. While procedures had previously been implemented to address this issue, additional measures are being taken to ensure full compliance. The University will implement additional udates to its NSLDS reporting processes to ensure needed submissions are reported timely and accurately. Respective staff will receive additional training to ensure proper reporting to NSLDS occurs. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid; Mr. Heath Burge, Assistant Vice President for Strategic Enrollment and Advising Services; and Mrs. Jeanese Outlaw-Gunter, University Registrar Planned completion date for corrective action plan: April 2026

View Audit 395389

Finding 1191373 (2025-006)

Material Weakness 2025

Langston University

OK

Student Financial Aid Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds ar...

Student Financial Aid Cluster: Federal Pell Grant Program – Assistance Listing No. 84.063 Federal Direct Student Loans – Assistance Listing No. 84.268 Recommendation: We recommend the University review its current procedures for Title IV funds and implement additional procedures to ensure refunds are returned timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is evaluating its current Title IV funds procedures and implementing additional procedures to ensure timely return of refunds. This includes assigning additional staff to manage this process. Also, relevant staff have been reminded of the need to notify Financial Aid of student withdrawals timely. Name(s) of the contact person(s) responsible for corrective action: Ms. Nacasaw Coppage, Director of Office of Financial Aid Planned completion date for corrective action plan: March 2026

View Audit 395389

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