Corrective Action Plans

Finding 1205754 (2025-001)

Material Weakness 2025

CA

HUD Housing Programs Procurement, Suspension & Debarment Cash Management

3250 SACRAMENTO HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan ...

3250 SACRAMENTO HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development 3250 Sacramento Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Timely Deposit of Annual Residual Receipts No. 14.157. Program –Section 202 Supportive Housing for Elderly Personal Significant Deficiency 3250 Sacramento Housing should reevaluate its policies and procedures to ensure that required residual receipts deposits are made timely each year. Action Taken: This was an isolated incident for fiscal year ending 6/30/24. As soon as the oversight was realized, we took action to remedy it. In addition, we have updated our process to send out residual receipts deposits once we have a draft audit completed versus waiting until after the final audit to ensure deposits are made before the 9/30 deadline. If there are any changes post audit completion, they should be immaterial and would be deposited as soon as we have final numbers. This will ensure timely deposits. Confirmation of deposits are tracked and will be followed up on regularly to ensure we do not miss the residual receipts distributions from surplus cash in the future. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 397480

Finding 1205752 (2025-001)

Material Weakness 2025

Bay Bridge Corporation

CA

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

BAY BRIDGE CORPORATION 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Bay Bridge Corporation respectfully submits the following corrective action plan for the year...

BAY BRIDGE CORPORATION 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Bay Bridge Corporation respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Recommendation: Bay Bridge should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: We hired a new Property Manager for Bay Bridge Apartments, who has worked diligently to complete outstanding recertifications and this property is back on track. All recertifications are now current with one exception due to a lack of tenant cooperation which is being properly managed with legal action. To ensure that staff changes and vacancies do not result in late recertifications in the future, we have employed Property Operations Specialists (roving personnel) to provide coverage if there is staff turnover. We have also increased oversight by the Regional Manager to ensure roving staff remain on track and that recertifications are completed timely. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and conducts monthly progress meetings with the management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 397479

Finding 1205750 (2025-001)

Material Weakness 2025

Vernon Street Housing, Inc.

CA

Procurement, Suspension & Debarment Eligibility HUD Housing Programs

VERNON STREET HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Vernon Street Housing, Inc. respectfully submits the following corrective action plan for ...

VERNON STREET HOUSING INC 2220 OXFORD STREET BERKELEY, CALIFORNIA 94704 (510) 841-4410 CORRECTIVE ACTION PLAN March 31, 2026 Cognizant or Oversight Agency for Audit: Department of Housing and Urban Development Vernon Street Housing, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Lindquist von Husen & Joyce LLP 301 Howard Street, Suite 850 San Francisco, CA 94105 Audit period: July 1, 2024, to June 30, 2025 The findings from the June 30, 2025, schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS—FINANCIAL STATEMENT AUDIT None noted. FINDINGS—FEDERAL AWARD PROGRAMS AUDITS 2025-001 Compliance over Eligibility Requirements to Perform Annual Recertification - Assistance Listing No. 14.181. Program –Supportive Housing for Persons with Disabilities Significant Deficiency Vernon Street Housing, Inc. should develop an operating plan in order to ensure that recertifications are performed timely each year, despite of staff shortages. Action Taken: Unanticipated staff shortages created gaps in performance of annual recertifications at this location. New staff has since been hired in the Regional Manager role and the Director role. Both new employees are providing greater oversight and visiting the property regularly to track progress. In addition to our permanent staffing efforts, we have deployed a Property Operations Specialist to bring recertifications current at Vernon Street Housing This specialist is focused specifically on compliance tasks and critical deadlines. Additionally, senior leadership at the John Stewart Company has implemented enhanced tracking of recertifications across the full portfolio and now conducts monthly progress meetings with management team to monitor compliance, identify risks early, and ensure accountability. We are confident that these corrective actions will result in sustained improvement and ongoing compliance. If the Department of Housing and Urban Development has questions regarding this plan, please call Zelda Ryan, Corporate Controller, at (510) 841-4410 x304#. Sincerely, Eric Knecht, CFO Resources for Community Development

View Audit 397478

Finding 1205743 (2025-001)

Material Weakness 2025

St. Lucy's Senior Living, Inc.

AK

Cash Management HUD Housing Programs Subrecipient Monitoring

We will deposit the delinquent amount when there is sufficient funds to do so.

View Audit 397472

Finding 1205738 (2025-009)

Material Weakness 2025

Northampton County

NC

Eligibility Internal Control / Segregation of Duties Significant Deficiency

Corrective Action Plan For the Year Ended June 30, 2025 NorthamptoN CouNty Finance Department 9467 Hwy 305 Jackson, North Carolina 27845 Leslie Edwards Finance Director Finding 2025-009 Inaccurate Information Entry Name of contact: Sammantha Thomas, Program Manager Corrective Action: Proposed Comple...

Corrective Action Plan For the Year Ended June 30, 2025 NorthamptoN CouNty Finance Department 9467 Hwy 305 Jackson, North Carolina 27845 Leslie Edwards Finance Director Finding 2025-009 Inaccurate Information Entry Name of contact: Sammantha Thomas, Program Manager Corrective Action: Proposed Completion Date: Corrective Actions for finding 2025-010 also apply to State Award findings. Section IV - State Award Findings and Question Costs Section III - Federal Award Findings and Question Costs The program manager held a staff meeting to discuss audit results and all errors. The Program Manager will be requiring policy training for all Medicaid supervisors and caseworkers. The program manager will have another staff meeting to discuss new procedures for caseworkers and supervisors. New actions for caseworkers will include a new detailed checklist that will be reviewed by a lead worker or supervisor when requesting information for cases that result in a termination, reduction or denial. Additionally, all caseworkers will be responsible for generating a report of all outstanding and overdue reviews and will prioritize cases nearing compliance deadlines. New actions for Supervisors will include a review of all cases completed by new employees. Currently second party reviews are being completed on five cases weekly per caseworker, however, going forward this will be increased to 8-10 cases weekly per caseworker. Additionally, supervisors will be responsible for implementing a real-time tracking log for review due dates, review timeliness of these reports daily, and supervisors will meet with the Program Manager monthly to report timeliness metrics. Supervisors and staff will be required to complete yearly policy training provided by the Program Manager to ensure they are clear on review timelines and accuracy. A meeting with all staff and supervisors was held on 2/25/2026 to discuss the findings of the Audit. All trainings will be completed no later than 3/31/2026. All new requirements by the program manager will be implemented immediately. 156

View Audit 397461

Finding 1205734 (2025-002)

Material Weakness 2025

Ignacio School District 11JT

CO

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

Ignacio School District has already taken steps in changing the overall process of managing our Federal Award grants and year-end closing entries. Our district has implemented regularly scheduled monthly Requests For Funds and budget reviews for each grant to confirm that the grants are being spent ...

Ignacio School District has already taken steps in changing the overall process of managing our Federal Award grants and year-end closing entries. Our district has implemented regularly scheduled monthly Requests For Funds and budget reviews for each grant to confirm that the grants are being spent according to their approved applications. This includes, but is not limited to assuring that the district charges a de minimis indirect cost rate and submits End of Year Financial Reports to CDE in a timely manner. The district has assigned responsibility of Federal Grant oversight to new personnel. To assure a segregation of duties, there are three district office personnel involved in the management and oversight of the grants. The district has also been trained on proper closing entry procedures for all year-end closing entries and SEFA requirements.

View Audit 397438

Finding 1205732 (2025-003)

Material Weakness 2025

Ignacio School District 11JT

CO

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties § 200.501 § 200.502 § 200.510 § 200.514

Ignacio School District has already taken steps in changing the overall process of managing our Federal Award grants and overall year-end closing entries. The district will be working closely with our new auditors to ensure that Single Audits are completed annually moving forward. Our district has i...

Ignacio School District has already taken steps in changing the overall process of managing our Federal Award grants and overall year-end closing entries. The district will be working closely with our new auditors to ensure that Single Audits are completed annually moving forward. Our district has implemented scheduled monthly Requests For Funds and budget reviews for each grant to confirm that the grants are being spent according to their approved applications. The Superintendent and Finance Director meet to review the overall process to ensure grant compliance. This includes, but is not limited to assuring that the district charges a de minimis indirect cost rate and submitting End of Year reports to CDE. The district has assigned responsibility of Federal Grant oversight to new personnel. To assure a segregation of duties, there are three district office personnel involved in the management and oversight of the grants. The district has also been trained on proper closing entry procedures for all year-end closing entries and year-end Annual Financial Reporting of grants.

View Audit 397438

Finding 1205716 (2025-001)

Material Weakness 2025

University Properties, Inc.

PA

Matching / Level of Effort / Earmarking Subrecipient Monitoring Reporting

2025-001 Reporting U.S. Department of Agriculture - Community Facilities Loans and Grants - Assistance Listing Number 10.766 Recommendation: University Properties, Inc.’s management should put processes in place over reporting, which include continuous monitoring of compliance requirements, to ensur...

2025-001 Reporting U.S. Department of Agriculture - Community Facilities Loans and Grants - Assistance Listing Number 10.766 Recommendation: University Properties, Inc.’s management should put processes in place over reporting, which include continuous monitoring of compliance requirements, to ensure timely identification of audit requirements and timely submission of the audit report and data collection form. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented processes to continuously monitor the federal audit compliance supplements in order to identify changes to the single audit reporting requirements and execute those changes, when applicable, in a timely manner. Name of the contact person responsible for corrective action: Jeffrey Snyder - University Properties, Inc. President 570-856-1178 jassynder@icloud.com Planned completion date for corrective action plan: October 17, 2025 If the U.S. Department of Agriculture has questions regarding this plan, please contact the individual noted above.

View Audit 397432

Finding 1205715 (2025-002)

Material Weakness 2025

Economic Development Alliance of St. Clair County

MI

Procurement, Suspension & Debarment Cash Management Material Weakness

Due to the number of grant programs the organization is managing, written policies will be developed and implemented to meet the requirements under the Uniform Guidance within the next year. The purpose of the policies will be to ensure that all grant funds, including reimbursable grants, are traced...

Due to the number of grant programs the organization is managing, written policies will be developed and implemented to meet the requirements under the Uniform Guidance within the next year. The purpose of the policies will be to ensure that all grant funds, including reimbursable grants, are traced and recorded appropriately. Our contracted accountant is responsible for managing journal entries and recordings and will participate in these reviews. The quarterly reviews will be held on or about the third week of September, December, March, and June.

View Audit 397425

Finding 1205714 (2025-004)

Material Weakness 2025

Paine College

GA

Cash Management Internal Control / Segregation of Duties § 200.305

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The third (2025-03) and fourth (2025-004) findings relate to federal cash management practices for Title Ill and TRIO grant programs. The audit determined that federal funds had been drawn down prior to immediate program expenditures, resulting in excess cash balances. To correct this issue, the College implements formal grant cash management procedures to ensure that internal controls over federal funds management are strong. Please review the details below: Corrective action 2025-004: Implement monthly grant reconciliation procedures, strengthen monitoring of federal drawdowns, and align disbursements with program spending patterns Target resolution: FY 2026

View Audit 397416

Finding 1205712 (2025-002)

Material Weakness 2025

Paine College

GA

Eligibility Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303 § 200.328

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The second (2025-002) finding pertains to compliance with federal eligibility requirements for the TRIO Upward Bound Program. Federal regulations require at least two-thirds of program participants to be both low-income and first-generation college students. The audit identified that the program fell below the required threshold. To address this issue, the College is strengthening participant eligibility verification procedures and implementing additional monitoring to ensure compliance throughout the program year. Recruitment strategies are also being enhanced to increase the number of eligible participants served by the program. In addition, staff will continue to receive targeted training to ensure accurate eligibility documentation and consistency between program records and federal reporting requirements. Corrective Action 2025-002: Strengthen participant eligibility verification, improve recruitment of eligible participants, enhance APR reporting accuracy, and provide compliance training for TRIO staff. Target resolution 2025-2026 Program Year

View Audit 397416

Finding 1205711 (2025-007)

Material Weakness 2025

Paine College

GA

Student Financial Aid Internal Control / Segregation of Duties

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns.

View Audit 397416

Finding 1205707 (2025-006)

Material Weakness 2025

Paine College

GA

Student Financial Aid Internal Control / Segregation of Duties Subrecipient Monitoring

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns.

View Audit 397416

Finding 1205703 (2025-005)

Material Weakness 2025

Paine College

GA

Student Financial Aid Subrecipient Monitoring Eligibility

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. Corrective Action 2025-005: Administrative and Fiscal Affairs 1235 Fifteenth Street, Augusta, GA 30901 Implement the Return to Title IV monitoring system, weekly credit balance tracking, counseling verification procedures, and strengthen coordination between Financial Aid, Registrar, and Business Office Target resolution: Spring-Summer 2026

View Audit 397416

Finding 1205699 (2025-003)

Material Weakness 2025

Paine College

GA

Cash Management Internal Control / Segregation of Duties § 200.305

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institu...

Uniform Guidance Financial and Compliance Audit-June 30, 2025, Ending Fiscal Year Paine College has developed a structured corrective action plan to address findings (2025- 001, 2025-002, 2025-003, 2025-004, and 2025-005) identified in the Uniform Guidance Financial and Compliance Audit. The institution is prioritizing the strengthening of internal controls, the improvement of financial oversight, and the enhancement of compliance monitoring to ensure responsible stewardship offederal funds and long-term institutional stability. The corrective action outlines each audit finding and the steps the College is taking to resolve the identified concerns. The third (2025-03) and fourth (2025-004) findings relate to federal cash management practices for Title Ill and TRIO grant programs. The audit determined that federal funds had been drawn down prior to immediate program expenditures, resulting in excess cash balances. To correct this issue, the College implements formal grant cash management procedures to ensure that internal controls over federal funds management are strong. Please review the details below: Corrective action 2025-003: Establish formal grant cash management procedures, implement monthly reconciliation of drawdowns vs. expenditures, and increase oversight of grant balances. Target resolution: FY 2026

View Audit 397416

Finding 1205697 (2025-003)

Material Weakness 2025

Miles College

AL

Allowable Costs / Cost Principles Cash Management § 200.305 § 200.430

Finding 2025-003 - U.S. Department of Education (USO), TRIO Programs (Significant Deficiencies): Information on the federal program - Student Support SeNices, FAL No. 84.042A, June 30, 2025; Ronald McNair Program, FAL No. 84.217A, June 30, 2025. Under 2 CFR 200.305, non-Federal entities must request...

Finding 2025-003 - U.S. Department of Education (USO), TRIO Programs (Significant Deficiencies): Information on the federal program - Student Support SeNices, FAL No. 84.042A, June 30, 2025; Ronald McNair Program, FAL No. 84.217A, June 30, 2025. Under 2 CFR 200.305, non-Federal entities must request Federal funds only for allowable program costs that have been incurred, and must maintain contemporaneous supporting documentation demonstrating: a. Actual, allowable expenditures existed at the time Federal funds were drawn; and b. Records supporting the nature and timing of those expenditures were on file and readily available. These requirements ensure 1. Corrective Action Description a. The College now mandates that GS drawdown requests include approved documentation stored on the accounting drive, effective July 31, 2025. b. Time and Effort reports must be submitted monthly with supervisor sign-off before reaching the Office of Sponsor Programs, showing 100% time allocation. Any changes will require a Personnel Action Form and administrative approval signatures. c. showing 100% time allocation. Any changes will require a Personnel Action Form and administrative signatures of approval. 1. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu 2. Implementation Timeline This procedure took effect as of July 31, 2025. 3. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. 4. Disagreement with the Finding None

View Audit 397405

Finding 1205695 (2025-002)

Material Weakness 2025

Miles College

AL

Student Financial Aid Cash Management Allowable Costs / Cost Principles § 200.305

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Oppo...

Finding 2025-002 - U.S. Department of Education (USO}, Title IV Student Financial Aid Programs (significant deficiency): Information on the federal program - Federal Pell Grant Program, FAL No. 84.063, June 30,2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Teachers Education Assistance for College(TEACH),FAL No. 84.379, June 30, 2025. Under 2 CFR 200.305 and the U.S. Department of Education's cash management requirements at 34 CFR 668.162, institutions must draw down Title IV funds only for expenditures 1. Corrective Action Description The College now requires all drawdowns to include supporting documentation of the funds requested from GS, along with sign-offs on preparation and approval. Supporting documents are stored securely on the College's accounting drive for easy access. 2. Person Responsible and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu a. Implementation Timeline This procedure took effect as of July 31, 2025. b. Planned Preventive Measures Following the policy and procedures to support all drawdowns with proper documentation. c. Disagreement with the Finding None

View Audit 397405

Finding 1205691 (2025-001)

Material Weakness 2025

Miles College

AL

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL ...

Finding 2025 - 001 - U.S. Department of Education (USD), Title IV Student Financial Aid Programs (material weakness): Information on the federal program - (Federal Award Identification): - Federal Pell Grant Program, FAL No. 84.063, June 30, 2025; Federal Supplemental Opportunity Grant Program, FAL No. 84.007, June 30, 2025; Federal Work-Study Program, FAL No. 84.033, June 30, 2025; Federal Direct Student Loan Program, FAL No. 84.268, June 30, 2025; Federal Teacher Education Assistance for College (TEACH), FAL No. 84.379, June 30, 2025. Institutions must determine a student's financial need by subtracting the expected family contribution and estimated financial assistance from the cost of attendance. 34 CFR 668.2 and 34 CFR 637.S(a). 1. Corrective Action Description The College has engaged a financial aid consultant to support the development of cost-of-attendance budgets and ensure they align with industry best practices, thereby making improvements to the College's financial aid operating system. After evaluating the auditors' sample of forty students, the College confirmed that no instances of over/under awarding occurred. There were clarifications and changes made to the initial cost of attendance budgets provided to the auditors that led to the questioned cost. The College will implement ongoing monitoring each semester to further enhance operational efficiency and effectiveness. The cost of attendance budgets has been uploaded into the College's financial aid system to prevent the recurrence of this issue for the current and future years. a. Responsible Person and Department Diana Knighton Senior Vice President, Finance and Business Administration Miles College 5500 Myron Massey Boulevard Fairfield, AL 3506 (205) 929-1442 dknighton@miles.edu b. Implementation Timeline January 18, 2026, for the spring semester c. Planned Preventive Measures The College hired a financial aid consultant to assist the financial aid Director with best practices and to make modifications to the ERP system to provide better operating efficiency and effectiveness. d. Disagreement with the Finding None

View Audit 397405

Finding 1205687 (2025-001)

Material Weakness 2025

Mount Zion Madison Street Properties

WA

HUD Housing Programs Cash Management Reporting

Management agrees with the finding and funds will be moved from replacement reserve to residual receipts account.

View Audit 397404

Finding 1205686 (2025-005)

Material Weakness 2025

Quay County

NM

Procurement, Suspension & Debarment

The County acknowledges the importance of documenting suspension and debarment verification for federally funded transactions. The County will update procurement policies and procedures to clearly assign responsibility for suspension and debarment checks, including situations where third-party procu...

The County acknowledges the importance of documenting suspension and debarment verification for federally funded transactions. The County will update procurement policies and procedures to clearly assign responsibility for suspension and debarment checks, including situations where third-party procurement services are used. Corrective Action Plan Timeline: June 2026 Designation Of Employee Position Responsible for Meeting Deadline: Finance Director

View Audit 397398

Finding 1205685 (2025-002)

Material Weakness 2025

East-West University

IL

Reporting Significant Deficiency Internal Control / Segregation of Duties

2025-002: Enrollment Reporting - Student Financial Aid Cluster -Assistance Listing Number 84.007, 84.033, 84.063, and 84.268 - Year Ended August 31, 2025 Condition Found During our Enrollment Status Changes testing, we selected forty students for our sample. In our sample of forty we tested twenty g...

2025-002: Enrollment Reporting - Student Financial Aid Cluster -Assistance Listing Number 84.007, 84.033, 84.063, and 84.268 - Year Ended August 31, 2025 Condition Found During our Enrollment Status Changes testing, we selected forty students for our sample. In our sample of forty we tested twenty graduated students to verify that they were reported within sixty days and we tested twenty current students to note that their student status is reported correctly. We noted ten students were not reported within the required sixty days. We consider this finding to be a significant deficiency relating to the Reporting Compliance Requirement. Corrective Action Plan The delay in Enrollment Reporting was due to staffing turnover within the Registrar's Office, which disrupted and delayed normal graduation reporting. East-West University has reviewed and strengthened its enrollment reporting procedures to ensure timely and accurate submission of student status changes. The University has: Filled vacant position and provided training to new staff on reporting requirements. Implemented a cross-departmental review process between the Program Directors, Registrar and Financial Aid offices to verify graduation and updated the National Clearing House enrollment status to meet the reporting requirements. As of Spring 2025 Quarter, all graduates have been reported on time. Responsible Person for Corrective Action Plan Registrar Raymond Zhen, Network Spcialist Xinghua Gou Implementation Date of Corrective Action Plan April 2025

View Audit 397395

Finding 1205680 (2025-001)

Material Weakness 2025

East-West University

IL

Student Financial Aid Eligibility Matching / Level of Effort / Earmarking

2025-001: Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, Grant Period - Year Ended August 31, 2025 Condition Found During our student file testing we noted two students out of forty were disbursed the incor...

2025-001: Incorrect Direct Loans Disbursement Amount - Student Financial Aid Cluster Assistance Listing Number 84.007, 84.033, 84.038, 84.063, 84.268, Grant Period - Year Ended August 31, 2025 Condition Found During our student file testing we noted two students out of forty were disbursed the incorrect Direct Loan amount. Based on the student’s enrollment status and need, the University over awarded the students by $1,229. We consider this error in awarding to be an instance of noncompliance of the Eligibility Compliance Requirement. Corrective Action Plan Financial Aid office will make sure the correct amount is awarded based on the student enrollment status and need of the student. EWU will make the proper adjustments to the Direct Subsidized Loan to reflect the correct amount for the two students. Responsible Person for Corrective Action Plan Director of Financial Aid Cesar Campos Implementation Date of Corrective Action Plan March 06, 2026

View Audit 397395

Finding 1205671 (2025-001)

Material Weakness 2025

Madison Interfaith Residential Community, Inc.

CT

Subrecipient Monitoring Reporting

Management acknowledges the finding regarding the replacement reserve account not being funded at the minimum level required by the USDA‑RD approved budget. To address this issue, the Project will make a deposit to fully restore the replacement reserve to the required threshold in accordance with US...

Management acknowledges the finding regarding the replacement reserve account not being funded at the minimum level required by the USDA‑RD approved budget. To address this issue, the Project will make a deposit to fully restore the replacement reserve to the required threshold in accordance with USDA‑RD guidelines. In addition, we will continue to monitor reserve balances throughout the year and communicate with USDA‑RD if significant variances arise.

View Audit 397381

Finding 1205669 (2025-008)

Material Weakness 2025

City of South Gate

CA

Allowable Costs / Cost Principles § 200.430

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to the Housing Choice Voucher (HCV) Program under CFDA 14.871 must be supported by recordsthat accurately reflect actual work performed, as required under 2 ...

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to the Housing Choice Voucher (HCV) Program under CFDA 14.871 must be supported by recordsthat accurately reflect actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of using predetermined allocation percentages to distribute payroll across multiple funding sources did not fully satisfy the federal standards for documenting actual time worked on HCV-eligible activities. Management notes that the projected questioned costs of $214,045 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City will coordinate with HUD to determine the appropriate resolution of these questioned costs. The corrective actions outlined in Finding 2025-007 apply equally to the HCV Program. Specifically: 1. Actual Time Reporting: All Housing Authority employees who perform HCV program activities are required to document actual hours worked per program activity on their timesheets, effective immediately. 2. Discontinuation of Fixed Allocations: Predetermined allocation percentages will no longer serve as the basis for payroll charges to the HCV Program. All charges must be supported by actual time records. 3. Timesheet System and Training: Housing Authority staff will be included in the system enhancement and training initiatives described in Finding 2025-007, with particular emphasis on documentation standards under the HCV Program's applicable requirements4. Quarterly Internal Compliance Reviews: HCV payroll charges will be included in the Accounting & Finance Division's quarterly compliance reviews, with findings reported to the City Manager and the Housing Authority Director.

View Audit 397378

Finding 1205667 (2025-007)

Material Weakness 2025

City of South Gate

CA

Allowable Costs / Cost Principles § 200.430

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior pr...

Management’s Response Regarding Corrective Action Taken or Planned Management acknowledges this finding and concurs that payroll costs charged to federal awards must be supported by documentation accurately reflecting the actual work performed, as required under 2 CFR 200.430(i). The City's prior practice of distributing payroll costs using predetermined allocation percentages for employees working across multiple programs did not fully satisfy federal requirements for documenting actual time expended on CDBG-eligible activities. Management notes that the projected questioned costs of $217,355 represent a projection of potential unallowable payroll charges based on the sample tested, that were unsupported due to insufficient time documentation and are not necessarily unallowable. The City isprepared to work with HUD to determine the appropriate resolution of these questioned costs. The City is implementing the following corrective actions: 1. Actual Time Reporting: Effective immediately, all employees who charge any portion of their time to federal grant programs—including CDBG—are required to document actual hours worked on each program or activity in their timesheets. Time entries must correspond to specific program activities and must be reviewed and certified by the employee's supervisor each pay period. 2. Discontinuation of Fixed Allocation Percentages: The City is eliminating the use of predetermined payroll allocation percentages as the basis for charging personnel costs to federally funded programs. Future payroll charges to federal awards will be based exclusively on actual documented hours, in compliance with 2 CFR 200.430(i). 3. Staff Training: The City will provide mandatory training to all employees who charge time to federal programs, supervisors responsible for timesheet review, and payroll staff. Training will cover the requirements of 2 CFR 200.430, the City's updated time documentation procedures, and the consequences of noncompliance.4. Quarterly Internal Compliance Reviews: Beginning in Q1 of FY 2025-26, the Accounting & Finance Division will conduct quarterly reviews of payroll charges to all federal programs to confirm that expenditures are supported by compliant time records. Results will be reported to the applicable department directors.

View Audit 397378

Corrective Action Plans

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