Corrective Action Plans

Finding 1171931 (2024-004)

Material Weakness 2024

CO

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

Planned Corrective Action: SAVA Center’s new Executive Director added information about the requirements for a single audit to the newly updated ﬁnancial policies, reﬂecting that it is the responsibility of the Executive Director to monitor when a single audit is warranted. The Executive Director wi...

Planned Corrective Action: SAVA Center’s new Executive Director added information about the requirements for a single audit to the newly updated ﬁnancial policies, reﬂecting that it is the responsibility of the Executive Director to monitor when a single audit is warranted. The Executive Director will maintain a spreadsheet summarizing the Schedule of Federal Expenditures (SEFA) and provide this to the auditor engaged to perform the Single Audit. Name of Contact Person: Alison Jones-Lockwood, Executive Director Anticipated completion date: January 12, 2026

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Finding 1171930 (2024-001)

Material Weakness 2024

Sexual Assault Victim Advocate Center

CO

Internal Control / Segregation of Duties Subrecipient Monitoring

Planned Corrective Action: Prior to the completion of the 2024 Audit, SAVA Center’s Executive Director began revising and updating the organizational ﬁnancial policies. These policies have been reviewed by the SAVA Center Finance Committee and voted for approval on January 16th, 2026. The updated ﬁn...

Planned Corrective Action: Prior to the completion of the 2024 Audit, SAVA Center’s Executive Director began revising and updating the organizational ﬁnancial policies. These policies have been reviewed by the SAVA Center Finance Committee and voted for approval on January 16th, 2026. The updated ﬁnancial policies now contain detailed information on the segregation of duties, which now includes the following people: The Director of Operations (in-house bookkeeper and preparer of grant invoices), the contract Accountant (allocates payroll, prepares monthly ﬁnancial statements, and assists with preparing the organization budget), the Executive Director (signer of checks, holder of bank card, reviews all grant invoices prior to submission, monitors revenue/expenses, and monthly ﬁnancials), and the Board Treasurer (reviews and presents monthly ﬁnancials, signing authority, chairs the ﬁnance committee, and provides opinion when needed on accounting best practices). Name of Contact Person: Alison Jones-Lockwood, Executive Director Anticipated completion date: January 16, 2026

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Finding 1171926 (2024-012)

Material Weakness 2024

Community Benefit Solutions

PA

School Nutrition Programs Internal Control / Segregation of Duties Subrecipient Monitoring

2024-012 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 C...

2024-012 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth) review of CBS Food Program's financial accounting system, it was noted that the Food Program utilizes QuickBooks software for their accounting system. Based on inquiry with CBS Food Program management, we determined internal controls connected with their QuickBooks accounting software were insufficient in the following areas: • User Access Management: Formal written policies or procedures have not been developed and implemented related to access authorization, access monitoring, and removal of system access. Additionally, certain functions are not properly segregated as users have access to perform both input and authorization of transactions. • Input Management: Formal written policies or procedures to ensure information input into QuickBooks is appropriate and accurate have not been developed and implemented. • Change Control Management: A formal written change management policy for QuickBooks Accounting System has not been developed and implemented including requirements that system security updates are implemented timely. • Backup and Recovery: A formal written policy for regular backup and recovery testing has not been developed and implemented. Recommendation: We recommend that CBS Food Program develop and implement comprehensive written internal control policies and procedures connected with their QuickBooks Accounting System. This should include: • Development and utilization of an Accounting Manual which includes an outline of CBS Food Program's accounting rules, procedures, and guidelines. • Access control policies and procedures to ensure that user access to QuickBooks is appropriate, regularly reviewed and promptly revoked upon termination or when otherwise merited. Recommendation (Continued) • A formal written change management policy for QuickBooks should be developed and implemented including requirements that systems security updates are implemented timely. • A disaster recovery plan and procedures to perform periodic testing to ensure that plans are functional and mitigate the risk of extended downtime. This process should also include regular review of backup records to ensure they are appropriately created and maintained. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions does not dispute this finding. Community Benefit Solutions will migrate from Quickbooks Desktop to Quickbooks Online, which will provide a perfect transitional opportunity to re-evaluate processes, and to develop and implement necessary controls over its systems. Community Benefit Solutions will work with independent auditors, internal information technology team, and, if necessary, legal counsel to plan, draft, and implement the relevant internal controls. Planned completion date for corrective action plan: June 30, 2025

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Finding 1171925 (2024-011)

Material Weakness 2024

Community Benefit Solutions

PA

School Nutrition Programs Internal Control / Segregation of Duties Material Weakness

2024-011 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 C...

2024-011 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth) review of CBS Food Programs banking policies, it was noted that the CBS Food Program did not establish appropriate controls to ensure bank account access changes and bank account closures could be promptly completed when organizational or personnel changes merited such actions. CBS Food Program management noted two instances during the engagement period in which lack of cooperation from parties with CBS Food Program bank account authority or access prevented the Food Program from closing bank accounts in an expeditious manner. This resulted in the CBS Food Program simultaneously having bank accounts open at three different banks for a portion of the audit period. As of May 2025, CBS Food Program only actively banks with one institution. Of the accounts with the other institutions, one account is closed, and the other remains open, but inactive because CBS Food Program has not initiated any account-related activity for an extended period of time. According to CBS Food Program management, they are working to close the inactive account, but closure requires assistance from Congregation Beth Solomon which has not been cooperative. The Commonwealth noted that CBS Food Program has inefficient control procedures in place over the issuance of high-value checks. Following the separation of CBS Food Program's prior CEO, the Food Program opened a new bank account in order to remove the prior CEO's access to food program funds. The former CEO was not cooperative in removing his access to the bank account the Food Program used at the time of his separation, so CBS Food Program determined moving the Food Program's funds to a new bank was in the best interest of the organization. To move the Food Program's funds from the old bank to the new bank, CBS Food Program's Director of Finance wrote two checks for $1.5 million dollars each. While CBS Food Program's Director of Finance obtained approval from the board prior to preparing and depositing the checks in the new bank account, a secondary signature was not obtained as CBS Food Program policy did not require a second signature for any check regardless of amount. Recommendation: CBS Food Program should assign bank authorization and access roles to appropriate CBS representatives to ensure access is appropriately limited, but that changes to account authorization can be completed timely when organizational or personnel changes merit such modifications. CBS Food Program should establish, document, and adhere to, a policy requiring documented prior approval and dual signatures on checks exceeding a predetermined threshold set by management and/or the board of directors. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Planned completion date for corrective action plan: June 30, 2025 Action taken in response to finding: Community Benefit Solutions does not dispute this finding and provides the following for the purpose of additional clarification. Between February 14, 2024, and June 10, 2024, the departure of the Farmer CEO and several key Board members resulted in the absence of authorized signers. In order to expeditiously remove individuals from accessing bank funds during this transition, the Community Benefit Solutions Board of Directors granted the Accounting Associate authority to sign all relevant checks and take steps necessary to remove those individuals. Going forward, Community Benefit Solutions will, with the assistance of either Board-approved counsel or outside independent audit firm, develop and implement thresholds for dual signature requirements. Moreover, Community Benefit Solutions will work with JP Morgan Chase Bank to ensure that authorization and authority can be expeditiously amended in the event such a need arises.

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Finding 1171924 (2024-010)

Material Weakness 2024

Community Benefit Solutions

PA

Procurement, Suspension & Debarment School Nutrition Programs Internal Control / Segregation of Duties

2024-010 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 C...

2024-010 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on interviews by the Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (“Commonwealth”) with CBS Food program management, inspection of records, and on-site observations, we identified internal control deficiencies in the following areas: • For a portion of the audit period, there was a lack of segregation of duties between the cash receipt, bookkeeping, and bank reconciliation processes. The Director of Finance was responsible for all these tasks. The Director of Finance was also responsible for both processing and approving payroll and had authorization to make purchases, make vendor payments, record accounting transactions and complete bank reconciliations. • CBS Food Program performs bank reconciliations; however, they are not signed or dated by the individual performing the reconciliation and a second individual does not review or sign off on the reconciliations. Of nine reviewed account reconciliations, three were completed more than 30 days after the statement period end date. • According to CBS Food Program's former Purchasing Distribution Manager, as of June 2024, they were the only CBS Food Program's employees with detailed knowledge of developing monthly menus and creating purchase orders based on current inventory levels to meet menu requirements. Additionally, the former Purchasing Distribution Manager stated that as of June 2024 formal training on internal purchasing policies and procedures is not provided or required. Condition (Continued) • For a portion of the engagement period, CBS Food Program lacked written policies or procedures for several key business functions including: o No written Accounting Manual or Standard Operating Manual for accounting functions. o No written policy or procedure for the use of credit cards or the handling of lost or stolen credit cards. o No written policy or procedure to analyze account balances to ensure transactions have been properly recorded. o No written records retention policy. o No written procedures for handling payroll for separating employees. o No written or implemented review process for changes to the payroll system including changes to employee payrates. o For a portion of the engagement period, the Food Program did not have procedures to o Prior to July 1, 2024, CBS Food Program did not have documented procurement procedures. On July 1, 2024, CBS Food Program implemented a procurement plan. Recommendation: If not already addressed, CBS Food Program should develop and implement improved internal controls including: • Develop written policies, procedures and/or manuals for accounting functions. • Develop a formal internal control policy and framework that focuses on key business and operations areas including segregation of duties, transaction review and approval processes, and monitoring procedures over critical operational functions. • Improve cross training of employees including training on purchasing and accounting tasks. • CBS Food Program should develop and implement a record retention policy that complies with food program requirements for maintaining documentation of operations. The policy should ensure key records are maintained in a shared location accessible to all appropriate personnel. This ensures the CBS Food Program does not lose access to key records in the event an employee leaves the food program. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions will work with its outside independent audit firm, Board-approved counsel, and other necessary stakeholders to develop and implement all the necessary controls as required by the Comptroller. Community Benefit Solutions' implementation of any of the noted changes will be the ability to recruit Finance Committee and Nutrition Committee members of the Board. Moreover, Community Benefit Solutions made strides in implementing some of the requested policies during the Audit. Community Benefit Solutions will endeavor to meet each of the requests despite any lack of human capital that would allow for ease of segregation of authority. Community Benefit Solutions is optimistic that incoming Board Members and external accounting, audit, HR, and legal will provide critical support. Planned completion date for corrective action plan: June 30, 2025

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Finding 1171923 (2024-009)

Material Weakness 2024

Community Benefit Solutions

PA

School Nutrition Programs

2024-009 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 C...

2024-009 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: Based on Commonwealth of Pennsylvania, Office of the Budget, Bureau of Audits (Commonwealth), testing and calculations of the CBS Food Program's Net Cash Resources Available and their 3 months averages expenditures, the Commonwealth determined the Food Program's net cash resources exceeded their 3 months average expenditures as of June 30, 2024. The Commonwealth calculated both 3-month average operating expenditures and Net Cash Resources Available based on financial statement information provided by CBS Food Program. The Commonwealth's calculations of Net Cash Resources found that the Food Program exceeded their 3 months average expenditures by $2,354,119 as of June 30, 2024. The Pennsylvania Department of Education (PDE) has been communicating with CBS Food Program to develop plans for spending down their excess non-profit food program balance. Recommendation: CBS Food Program should work with PDE to develop a plan to appropriately utilize its resources. In the future, the Food Program should monitor cash resources to ensure they do not exceed maximum thresholds required by federal regulations. Excess food program resources can be used to improve or expand the nonprofit food service for program participants. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions agrees in principle with this finding; however, disputes the amount of Net Cash Resources Available in Excess of Federal Regulation. Based on the 2025 Year End Balance, CBS Food Program has $1,087,495.35 in cash and $2,106,728.79 in Certificates of Deposits which totals $3,194,224.11 in Net Cash Resources. CBS Food Program's expenditures during the 24-25 Program Year totaled $8,542,614, which results in allowable Net Cash Resources of$2,135,653.50 (three months of total expenditures). More accurately, the expected expenditures for the 25-26 Program Year are $7,167,206, results in allowable Net Cash Resources of $1,791,801.50. Accordingly, Community Benefit Solutions contends that the Net Cash Resources Available in Excess of Federal Regulations is $1,793,571. Prior to the issuance of the Draft Report, Community Benefit Solutions provided PDE with a preliminary Spend Down Proposal based on an expected $2,800,000 in excess funds. The Spend Down Proposal included, among other things, $837,000 set aside for the purpose of equipping Community Benefit Solutions' new headquarters with a commercial kitchen, refrigerator, and freezer (the "Warehouse Buildout"). PDE approved the portion of the Spend Down Plan pertaining to the Warehouse Buildout. The Board of Directors along with Community Benefit Solutions leadership and PDE will continue to coordinate and determine appropriate and allowable actions to spend down Net Cash Resources in accordance with the federal requirements. Planned completion date for corrective action plan: June 30, 2025

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Finding 1171922 (2024-007)

Material Weakness 2024

Community Benefit Solutions

PA

Subrecipient Monitoring School Nutrition Programs Internal Control / Segregation of Duties § 200.332

2024-007 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 C...

2024-007 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of subrecipient monitoring activities for PDE programs CACFP, NLSP, and SFSP, we selected 31 contracted centers at random. Management provided documentation for each site, including contracts, meal pattern usage records, licensure and training documentation, and both announced and unannounced meal observation reviews. However, we found that CBS Food Program did not always maintain sufficient evidence to prove required monitoring was performed under the CACFP program. For one center, management could not produce proof that meal observation reviews or the mandated two unannounced visits occurred. At another center, neither a contract nor any meal observation review records, including the two required unannounced visits, could be provided. For the NLSP and SFSP, management was unable to provide contracts for any of the seven sampled centers. Additionally, there was no evidence of training for one center, and a second center had a noncompliant monitoring visit; although corrective action was prepared, follow-up occurred only after 66 days instead of within the required 45-day window. Recommendation: We recommend that management strengthen internal controls to ensure all required PDE CACFP, NLSP and SFSP subrecipient monitoring activities, including scheduled meal observations and the mandated unannounced visits—are consistently performed, documented, and retained. Management should implement a centralized tracking system to monitor review deadlines, required follow up actions, and receipt of supporting documentation from each contracted center. In addition, staff responsible for monitoring should receive periodic refresher training on PDE CACFP, NLSP and SFSP specific expectations. Finally, management should conduct periodic internal reviews to verify that monitoring documentation is complete, compliant, and appropriately maintained. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions shall utilize internally developed Quickbase application to schedule and track monitoring visits including ensuring necessary corrective action follow-ups are conducted within 45 days documented corrective action needed. Moreover, Community Benefit Solutions will require all monitoring staff to successfully complete monitoring specific training in addition to the annual and civil rights training to ensure up to date knowledge of all requirements. Trainings will be assigned, monitored and signed off on by Director of Operations. Planned completion date for corrective action plan: June 30, 2025

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Finding 1171921 (2024-006)

Material Weakness 2024

Community Benefit Solutions

PA

Procurement, Suspension & Debarment School Nutrition Programs § 200.213

2024-006 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 C...

2024-006 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of our procurement testing in accordance with Uniform Guidance requirements, we requested that management provide the most recent suspension and debarment assessments for the vendors selected for review. Our analysis indicated that management did not perform these assessments by reviewing the federal government's suspended or debarred vendor list on SAM.gov. Rather, they relied on vendor certifications obtained through the Commonwealth of Pennsylvania, Department of Education, to determine vendor eligibility with respect to suspension or debarment from federally funded programs. Additionally, we observed that the current procurement policy for the CBS Food Program does not outline a formal procedure for evaluating vendors' suspension and debarment status as required by Uniform Guidance. Recommendation: We recommend that management establish and implement a formal process for evaluating vendors regarding suspension and debarment. This process should include regular reviews of the federal government's suspended or debarred list on SAM.gov to ensure that vendors are not suspended or debarred from participating in federal programs. Additionally, management should ensure that all procurement policies and procedures are updated to reflect this requirement. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions shall update its current procurement policy to include a suspension and debarment review of all vendors seeking to do business with the organization. Prior to February 13, 2026, Community Benefit Solutions shall conduct a comprehensive review of all current vendors to ensure compliance with these recommendations. Community Benefit Solutions will update procurement policy to include quarterly suspension and debarment review to be conducted by Quality Assurance Associate and signed off on by Warehouse and Purchasing Director. Planned completion date for corrective action plan: June 30, 2025

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Finding 1171920 (2024-005)

Material Weakness 2024

Community Benefit Solutions

PA

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring

2024-005 Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of participant eligibility, we selected a sample of 40 participants receiving me...

2024-005 Material Weakness in Internal Control over Compliance 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: During our testing of participant eligibility, we selected a sample of 40 participants receiving meals at centers contracted with the CBS Food Program. For 2 of the 40 participants, management was unable to provide complete and valid eligibility documentation. In one instance, the only available eligibility form had been prepared in a future fiscal year, and in another instance, the eligibility form could not be located at all. Recommendation: We recommend that management strengthen its CACFP eligibility documentation procedures to ensure that all required forms are properly completed, collected, and retained for every participant. This should include implementing a standardized intake process, maintaining timely reviews to confirm completeness of eligibility files, and developing a tracking or monitoring system to identify missing or outdated documentation. Management should also reinforce internal expectations for timely updating of eligibility files and ensure staff are trained on CACFP documentation requirements. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: On February 1, 2025, Community Benefit Solutions rolled out the KidKare software system wide. KidKare is a CACFP software that allows Community Benefit Solutions to digitally process all eligibility-documentation, standardize the enrollment procedures, ensure forms are completed in accordance with the relevant regulations, request updated documentation upon the expiration of enrollment forms, and digitally store all the eligibility related information for all participants. Planned completion date for corrective action plan: June 30, 2025

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Finding 1171919 (2024-004)

Material Weakness 2024

Community Benefit Solutions

PA

Allowable Costs / Cost Principles School Nutrition Programs Material Weakness § 200.303 § 200.430

2024-004 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 C...

2024-004 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program 10.558 – Child and Adult Care Food Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition As part of our audit procedures, we selected a sample of 40 payroll transactions for review. This process included examination of employee human resource files (such as signed W-4 and I-9 forms), management-approved pay rates, time sheets with supervisory sign-off, and corresponding payroll reports. We recalculated total hours per timesheet using the employees' pay rates and compared these figures to the relevant payroll reports. During our review, we observed that two employees received additional compensation ranging from $25 to $75 for undertaking extra responsibilities related to the administration of the CBS Food Program’s Summer Food Service Program by the former Chief Executive Officer. Management was unable to provide supporting documentation evidencing approval by the former Chief Executive Officer or confirmation from the Commonwealth of Pennsylvania, Department of Education, indicating that such additional compensation complied with the contractual agreement governing the Summer Food Service Program. Additionally, of the 40 payroll transactions sampled, we noted one employee’s required payroll change documentation (e.g., an approved payroll change form) was not present in their personnel file. Recommendation We recommend that management improve internal controls for payroll authorization by making sure every payroll change form and supplemental compensation approval is filled out, approved, and kept on file. Introducing a central electronic document management system will help securely store records, standardize documentation, and create clear audit trails for all payroll and personnel files. Management should also regularly review payroll records to confirm that all necessary paperwork, such as personnel forms, pay rate approvals, and backup for extra pay, is included. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Community Benefit Solutions repeats the actions to be taken in response to finding 2024-003 and adds the following: Community Benefit Solutions will utilize ADP document management capabilities to maintain employee files including, but not limited to, Payroll Change Forms or other documentation related to modifications or supplements to employee pay. Community Benefit Solutions will ensure complete upload of all paper files to the appropriate employee profile within ADP to ensure documentation can be readily accessible by those with necessary authorization. Planned completion date for corrective action plan: June 30, 2025

View Audit 384963

Finding 1171914 (2024-008)

Material Weakness 2024

Community Benefit Solutions

PA

School Nutrition Programs Subrecipient Monitoring Material Weakness § 200.327 § 200.328 § 200.334

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirem...

2024-008 Material Weakness in Internal Control over Compliance The Child Nutrition Cluster: 10.555 – National School Lunch Program and 10.559 – Summer Food Service Program Commonwealth of Pennsylvania, Department of Education Contract Number: 359-46-477-8 Condition: As part of the reporting requirements for the CBS Food Program under the National School Lunch Program (NSLP) and Summer Food Service Program (SFSP), management is responsible for submitting the FNS 10 (NSLP) and FNS 418 (SFSP) reports within 30 days after month-end. However, management was unable to provide five (5) monthly NSLP reports and one (1) monthly SFSP report requested for audit testing. Recommendation: The Organization should establish and enforce strengthened internal controls over federal reporting to ensure that all required monthly reports (FNS 10 and FNS 418) are: (a) completed accurately, (b) submitted on time, and (c) retained in accordance with federal record retention requirements (2 CFR 200.334). Management should designate responsible personnel and implement a monitoring process to ensure compliance. Repeat Finding: No Explanation of Disagreement with Audit Finding There is no disagreement with the audit finding. Action taken in response to finding: Effective, July 1, 2024, Community Benefit Solutions no longer administers the National School Lunch Program. In the event Community Benefit Solutions should begin administering the NSLP, Community Benefit Solutions will develop and implement requisite policies and procedures to ensure proper reporting requirements including, but not limited to, completion and submission of the FNS10. Planned completion date for corrective action plan: June 30, 2025

View Audit 384963

Finding 1171899 (2024-003)

Material Weakness 2024

City of Gloversville, New York

NY

Reporting Internal Control / Segregation of Duties § 200.510

The City will implement procedures to ensure accurate SEFA preparation

View Audit 384938

Finding 1171897 (2024-002)

Material Weakness 2024

City of Gloversville, New York

NY

Internal Control / Segregation of Duties § 200.512

The City intends to implement procedures to ensure timely account reconciliations which will facilitate timely audit submission.

View Audit 384938

Finding 1171896 (2024-001)

Material Weakness 2024

Town of Plaistow

NH

Procurement, Suspension & Debarment

Audit Finding Reference: 2024-001 Management’s Response and Planned Corrective Action: The Town recognizes the need to follow the rules regarding suspension and debarment. Although, not formally, it was considered prior to awarding the contracts. In the future, before awarding/signing any contracts ...

Audit Finding Reference: 2024-001 Management’s Response and Planned Corrective Action: The Town recognizes the need to follow the rules regarding suspension and debarment. Although, not formally, it was considered prior to awarding the contracts. In the future, before awarding/signing any contracts that involve Federal funds, care will be taken to ensure the requirement is met. Name of Contact Person and Completion Date: Name: Gregory A Colby, CPA – Town Manager/Finance Director Anticipated Completion Date – January 28, 2026

View Audit 384927

Finding 1171884 (2024-003)

Material Weakness 2024

Heart of Georgia Regional Airport Authority

GA

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking

THE BOARD WILL DOCUMENT THE PROCUREMENT PROCEDURES FOR FEDERAL AWARDS AND SUBAWARDS.

View Audit 384866

Finding 1171869 (2024-006)

Material Weakness 2024

Municipality of Loiza

PR

Subrecipient Monitoring Reporting Significant Deficiency § 200.339

The Municipality Administration is currently addressing the control and compliance issue. Starting on January 2026 prior year reports will be submitted. Full compliance expected to start on January 2026 going forward.

View Audit 384837

Finding 1171868 (2024-005)

Material Weakness 2024

Municipality of Loiza

PR

Subrecipient Monitoring Internal Control / Segregation of Duties Reporting § 200.339

All monthly reports were delivered on time to AFAAF as established on the guidelines and following the agency’s reporting guidelines and support. The Municipality is full compliance with the Puerto Rico Fiscal Agency and Financial and Financial Advisory Authority

View Audit 384837

Finding 1171867 (2024-004)

Material Weakness 2024

Municipality of Loiza

PR

Reporting Significant Deficiency § 200.12 § 200.508 § 200.510 § 200.512

The Municipality is working diligently to publish its statements on time. In 2025 the Municipality published two audited statements (2022 and 2023) and the 2024 audited statements are expected to be published in January 2026. The 2025 audited financial statements will be published on time.

View Audit 384837

Finding 1171851 (2024-001)

Material Weakness 2024

Horizon Healthcare Partners

RI

Internal Control / Segregation of Duties Reporting

We agree with the recommendation and understand the required compliance responsibility to provide audited financial statements and major Federal program compliance reporting timely each fiscal year, in accordance with the Federal Single Audit Act. Because of past misunderstandings and incorrect assu...

We agree with the recommendation and understand the required compliance responsibility to provide audited financial statements and major Federal program compliance reporting timely each fiscal year, in accordance with the Federal Single Audit Act. Because of past misunderstandings and incorrect assumptions about major Federal program compliance requirements for fiscal 2019, 2020, 2021, 2022, 2023, and 2024 management failed to provide for timely audits. One critical assumption was that the Organization’s subrecipient, responsible for over ninety percent (90%) of grant distributions, fulfilled the audit requirement for the required Federal grant reporting under the Single Audit Act. However, upon recognizing this error, the Organization promptly engaged for the financial statement and major Federal program compliance audits spanning multiple years including up to last fiscal year and is on track to provide for timely filing with the current year. With this understanding and the expectation of financial statement and major Federal program compliance audits, the Organization replaced its contracted accountants by hiring its first Chief Financial Officer (CFO) in January of 2021 and a number of additional support accountants beginning in November of 2021 through January of 2024. Upon hire, and with the growth of the programming, the CFO and the accounting team focused extensively on enhancing the Organization’s financial reporting framework and data management systems to ensure continued compliance with federal and state guidelines and reporting requirements. This effort has been crucial in expediting the more recent audits and improving overall efficiencies in the day-to-day and monthly financial reporting and budgeting requirements. Further, the Organization must acknowledge the challenges posed by the transition of multiple Chief Executive Officers in a 2-year period as well as the impact of the pandemic on operations and reporting. These two factors affected operations and time lines as well as access to data files as many were in paper form. Despite these difficulties, management’s commitment to timely financial reporting and program compliance remains steadfast and are working diligently to get its timing back on track going forward.

View Audit 384813

Finding 1171708 (2024-015)

Material Weakness 2024

Osage County

OK

Subrecipient Monitoring § 200.332

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developi...

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of Federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on Grants and Awards. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.

View Audit 384731

Finding 1171707 (2024-014)

Material Weakness 2024

Osage County

OK

Subrecipient Monitoring Internal Control / Segregation of Duties § 200.1 § 200.329 § 200.344

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developi...

Chairman of the Board of County Commissioners: This issue originated under the prior County Clerk’s administration where key reporting processes were not followed. The Board of County Commissioners and the other elected officials have made correcting this a top priority. Together, we are: • developing a comprehensive SOP to ensure accurate and timely tracking and reporting of federal funds, • improving communication and oversight between all county offices to ensure consistent reporting standards, • and ensuring annual compliance with federal reporting requirements. Our collective goal is to implement the policies and structures that will keep Osage County operating with the highest standard of accountability and excellence. County Clerk: I was not the County Clerk in office at this time. To correct this issue. the County plans to develop a SOP to timely and accurately track and report on federal funds. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. County Treasurer: The County was under the understanding that once we established we were reporting as Loss Revenue, we would not have to submit the report annually. The final reporting was submitted prior to deadline.

View Audit 384731

Finding 1171706 (2024-013)

Material Weakness 2024

Osage County

OK

Procurement, Suspension & Debarment § 200.214 § 200.317 § 200.319 § 200.320 § 200.327

Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on ...

Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in Office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners.

View Audit 384731

Finding 1171705 (2024-012)

Material Weakness 2024

Osage County

OK

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

Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk's administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to up...

Chairman of the Board of County Commissioners: The lack of cooperation and oversight during the prior County Clerk's administration left significant gaps that required immediate attention. The current leadership has made addressing these gaps a top priority. Together, we are: • meeting monthly to update procedures and build stronger internal controls, • developing and formalizing policies to ensure full compliance with federal grant requirements, • and improving communication between offices to ensure federal reporting is accurate and timely. Our collective commitment is to put permanent measures in place to prevent these issues from recurring and to uphold the highest level of compliance for all federal programs. County Clerk: I was not the County Clerk in office at this time. The County will comply with all aspects of grant reporting and requirements. The Officials will work together to put policies and procedures in place to ensure more accurate reporting. County Treasurer: The County Officers will work on better communication to more accurately report the SEFA funds.

View Audit 384731

Finding 1171704 (2024-011)

Material Weakness 2024

Osage County

OK

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring

Chairman of the Board of County Commissioners: These findings trace back to gaps under the prior County Clerk's administration and her lack of cooperation with the Board of County Commissioners, but our focus is on fixing the problems, not dwelling on them. Under the current leadership, the Board of...

Chairman of the Board of County Commissioners: These findings trace back to gaps under the prior County Clerk's administration and her lack of cooperation with the Board of County Commissioners, but our focus is on fixing the problems, not dwelling on them. Under the current leadership, the Board of County Commissioners, the new County Clerk and the other elected officials have made addressing these control weaknesses a priority. Together, we are: • strengthening county-wide policies and procedures to meet federal compliance requirements • improving communication and oversight to ensure accurate and timely federal reporting • and establishing clear standards and training for all reporting officers to prevent inaccurate or untimely reporting. Our collective goal is to build a stronger, more accountable system that ensures federal programs are managed with the highest level of integrity. County Clerk: I was not the County Clerk in office at this time. Ensure that the County has standards in place that will deter inaccurate and untimely reporting. In addition, those reporting have the knowledge and understanding to properly report. County Treasurer: The County Officers will work on better communication to more accurately report the Schedule of Expenditures of Federal Awards (SEFA) funds.

View Audit 384731

Finding 1171693 (2024-101)

Material Weakness 2024

City of Parker, Florida

FL

Special Tests & Provisions Subrecipient Monitoring Cash Management § 200.303

City of Parker Management’s Corrective Action Plan For the Fiscal Year Ended September 30, 2024 Financial Statement Finding Number: 2024-101: Reimbursement Requests were Not Formally Approved by the City Prior to Submission Planned Corrective Action: The City will update its procedures to require do...

City of Parker Management’s Corrective Action Plan For the Fiscal Year Ended September 30, 2024 Financial Statement Finding Number: 2024-101: Reimbursement Requests were Not Formally Approved by the City Prior to Submission Planned Corrective Action: The City will update its procedures to require documented City review and approval of all reimbursement requests prior to submission to a grantor. The City will also clarify responsibilities with the consultant to ensure submission and acknowledgment are independently performed and appropriately documented. Anticipated Completion Date: 09/30/2026 Responsible Contact Person: Kimberly Dalton, Bookkeeper

View Audit 384721

Corrective Action Plans

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