Corrective Action Plans

Finding 1205538 (2025-003)

Material Weakness 2025

ME

Effect: Untimely filing of reports could result in delays in future funding or funds received being returned to the grantor.

View Audit 397221

Finding 1205538 (2025-003)

Material Weakness 2025

Milestone Recovery and Subsidiaries

ME

Repeat Finding: Yes

View Audit 397221

Finding 1205538 (2025-003)

Material Weakness 2025

Milestone Recovery and Subsidiaries

ME

Recommendation: We encourage the Organization to continue its efforts to ensure that all contract reports are submitted timely in the future, and support of such submissions be maintained in a central location easily accessible by all authorized users.

View Audit 397221

Finding 1205538 (2025-003)

Material Weakness 2025

Milestone Recovery and Subsidiaries

ME

Views of responsible officials and planned corrective action: We are in agreement with the finding. Management is in the process of creating an updated process/system to ensure compliance with this requirement moving forward.

View Audit 397221

Finding 1205536 (2025-001)

Material Weakness 2025

Lindenhurst Union Free School District

NY

Allowable Costs / Cost Principles § 200.430

2025-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Title I Grants to Local Educational Agencies ALN: 84.010A Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for...

2025-001. Allowable Costs/Cost Principles United States Department of Education, Passed Through New York State, Department of Education: Title I Grants to Local Educational Agencies ALN: 84.010A Condition: Subpart E, 2 CFR §200.430 of the Uniform Guidance requires that charges to “Federal awards for salaries and wages must be based on records that accurately reflect the work performed.” The documentation should support the distribution of the employee’s compensation among specific activities if the employee works on more than one federal award, or a federal award and non-federal award. The preparation of personnel activity reports (PAR) or periodic certifications or the equivalent is the most effective way to comply with this requirement. During the current year, the District prepared periodic certification equivalents, but it did not comply with the documentation standards prescribed by Subpart E, 2 CFR §200.430; the amount of one employee’s actual payroll charged to the Title I federal award was less than the allocation percentage on the periodic certification reports that were signed by the employee’s supervisor. Planned Corrective Action: The District will adopt procedures that ensure that appropriate documentation for time and effort will be used to support costs charged to the federal award, and comply with Subpart E, 2 CFR §200.430. Responsible Contact Person: Mr. William Ludeker Assistant Superintendent for Business Lindenhurst Union Free School District 350 Daniel Street Lindenhurst, New York 11757 Anticipated Completion Date: June 30, 2026.

View Audit 397219

Finding 1205535 (2025-001)

Material Weakness 2025

Youth Advocate Programs, INC

PA

Reporting

Finding 2025-001 Condition There were 2 invoices out of 40 tested that were incorrectly entered into the Organization’s billing system related to the Rehabilitation Services Vocational Grant program. The Organization erroneously recorded the invoices, and the error was not detected during the Organi...

Finding 2025-001 Condition There were 2 invoices out of 40 tested that were incorrectly entered into the Organization’s billing system related to the Rehabilitation Services Vocational Grant program. The Organization erroneously recorded the invoices, and the error was not detected during the Organization’s daily operations. The sample was not a statistically valid sample. Corrective Action Plan Corrective Action Planned: The process for internal verification will be strengthened by centralizing the internal controls to include one individual responsible for the approval of the pre-bill and one individual responsible for entering the invoice into the internal billing system. This process will be changed from a monthly to a weekly verification. The person responsible for the approval of the pre-bill will review the amounts entered into the internal billing system for accuracy by verifying that all invoices entered match the dollar amount listed on the invoice. Name(s) of Contact Person(s) Responsible for Corrective Action: Abigail Fisch – PA Program Coordinator of OVR, Nicole Brion – Revenue Cycle Management Billing Manager Anticipated Completion Date: September 30, 2025

View Audit 397208

Finding 1205530 (2025-003)

Material Weakness 2025

Alpha One

ME

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Management concurs in part and disagrees in part with this finding. Management has always understood that alcohol purchases may not be charged to a Federal program and are unallowable under Uniform Guidance, and we are committed to ensuring full compliance with federal cost principles. Upon identifi...

Management concurs in part and disagrees in part with this finding. Management has always understood that alcohol purchases may not be charged to a Federal program and are unallowable under Uniform Guidance, and we are committed to ensuring full compliance with federal cost principles. Upon identification of this exception, management initiated corrective measures to reinforce internal controls surrounding expense review and documentation. The accounting staff member did not have the itemized receipt at the time the expense was initially allocated. Had the receipt been available, the unallowable cost would have been identified, and the expense would not have been allocated to program costs. Once the receipt was reviewed, the alcohol purchase was identified as unallowable under Federal programs and allocated correctly to administration costs. To prevent similar issues moving forward, accounting staff have been re-trained on expense documentation and receipt-tracking requirements, with emphasis on ensuring that itemized receipts are obtained and reviewed prior to allocation, reimbursement, or payment. Staff have also been reminded of the importance of validating expenditures against Uniform Guidance allowability requirements as part of their routine review procedures. Management will continue to monitor expense activity to ensure the effectiveness of these reinforced controls. The anticipated completion date for this corrective action is 11/1/2025.

View Audit 397202

Finding 1205529 (2025-002)

Material Weakness 2025

Alpha One

ME

Procurement, Suspension & Debarment

Management concurs with this finding. Maintaining complete and accurate receipt documentation is essential for ensuring proper expense coding, supporting auditability, and maintaining compliance with organizational policies and funding requirements. Upon identification of this exception, management ...

Management concurs with this finding. Maintaining complete and accurate receipt documentation is essential for ensuring proper expense coding, supporting auditability, and maintaining compliance with organizational policies and funding requirements. Upon identification of this exception, management initiated corrective actions to reinforce our internal controls over receipt retention and documentation. Accounting staff have been re-trained on our receipt-tracking procedures, with an emphasis on the requirement that receipts must be obtained and retained for all meal expenses. We will continue to monitor compliance with these updated procedures to ensure their effectiveness. The anticipated completion date for this corrective action is 11/1/2025.

View Audit 397202

Finding 1205528 (2025-001)

Material Weakness 2025

Alpha One

ME

Internal Control / Segregation of Duties HUD Housing Programs Significant Deficiency

Management agrees with this finding. Upon identification of the issue, we initiated immediate corrective actions to reinforce our internal control environment and ensure full compliance with our cash disbursement approval policy. We have completed re-training for all accounting staff to reaffirm the...

Management agrees with this finding. Upon identification of the issue, we initiated immediate corrective actions to reinforce our internal control environment and ensure full compliance with our cash disbursement approval policy. We have completed re-training for all accounting staff to reaffirm the requirements of our payment approval policy and to emphasize the importance of verifying documented approval prior to processing any invoice, regardless of the payment method (check, automated withdrawals, or portals). Additionally, management has implemented a system upgrade, transitioning from a manual approval workflow to an automated approval process. This upgraded system is designed to require approval before an invoice can proceed to payment, thereby preventing invoices from being disbursed without documented written authorization. We expect this automated control to significantly reduce the risk of future exceptions and strengthen overall compliance. Management will continue to monitor disbursement activity to ensure ongoing adherence to policy and the effectiveness of the new control measures. The anticipated completion date for this corrective action is 11/1/2025.

View Audit 397202

Finding 1205524 (2025-006)

Material Weakness 2025

Michigan City Area Schools

IN

Equipment & Real Property Management § 200.303 § 200.313

FINDING 2025-006 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We hav...

FINDING 2025-006 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We have Deyo-Stone scheduled to come out to do a detailed capital asset inventory. Moving forward, we will put policies and procedures in place to keep a listing of all capital and fixed assets. We will maintain a schedule to have our capital asset inventory completed every two years as required. We will also implement a system of Internal controls to ensure that all capital assets purchased through Federal funds meet all compliance requirements. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027.

View Audit 397194

Finding 1205521 (2025-005)

Material Weakness 2025

Michigan City Area Schools

IN

Allowable Costs / Cost Principles § 200.300 § 200.303 § 200.306 § 200.308 § 200.309

FINDING 2025-005 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We wil...

FINDING 2025-005 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure allowable costs are documented and that receive board approval for all pay rates moving forward. However, we disagree with the finding on the allowable costs pertaining to the Financial Consulting Claims. We wrote them into the grant, and the grant was approved. There was also no Business Manager or Chief Financial Officer in place during the pandemic, resulting in the need for the consulting firm. Anticipated Completion Date: We anticipate that this correction will be in place by July 2026.

View Audit 397194

Finding 1205518 (2025-004)

Material Weakness 2025

Michigan City Area Schools

IN

Special Tests & Provisions Subrecipient Monitoring Material Weakness § 200.303

FINDING 2025-004 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We wil...

FINDING 2025-004 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure the proper documentation is in place for any students removed from the graduation cohort. Anticipated Completion Date: We anticipate that this correction will be in place by August 2026

View Audit 397194

Finding 1205516 (2025-003)

Material Weakness 2025

Michigan City Area Schools

IN

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

FINDING 2025-003 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We wil...

FINDING 2025-003 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027

View Audit 397194

Finding 1205515 (2025-002)

Material Weakness 2025

Michigan City Area Schools

IN

Allowable Costs / Cost Principles School Nutrition Programs Internal Control / Segregation of Duties § 200.208 § 200.303 § 200.403

FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We wil...

FINDING 2025-002 Finding Subject: Contact Person Responsible for Corrective Action: Tracey Haas, Business Manager Contact Phone Number and Email Address: 219-873-2000 x 8346 thaas@mcas.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: We will implement a system of internal controls to ensure that the Form 9 and all underlying expenditures are properly documented. Anticipated Completion Date: We anticipate that this correction will be in place by July 2027

View Audit 397194

Finding 1205507 (2025-001)

Material Weakness 2025

City of Pensacola

FL

HUD Housing Programs

The finding from the September 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. The City of Pensacola Housing Department’s direct action in response to the finding is to meet with the Housing Placeme...

The finding from the September 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. The City of Pensacola Housing Department’s direct action in response to the finding is to meet with the Housing Placement Specialists to discuss the finding, review Pensacola Housing’s Administrative Plan and 24 CFR 982.516, clarify the proper procedures for accepting self-declared income, and monitoring for ongoing compliance. Program Manager Nicole Louie will randomly select files from each Housing Placement Specialist’s caseload to complete a quality control review over the next 60 days to ensure proper income-verification procedures are followed. In addition, SEMAP (Section 8 Management Assessment Program) quality control is conducted quarterly by the Housing Office Coordinator as part of the self-scoring assessment submitted to HUD. Any non-compliance identified during the SEMAP quarterly review will be brought to the attention of the Section 8 Program Manager and the Housing Placement Specialist. Name of Contact Person for Completing Corrective Action Plan: Nicole Louie, Program Manager 850-858-0316 nlouie@cityofpensacola.com Expected date of completion is April 30, 2026 FINDING 2025-001 During the review of 40 tenant files, there were three instances a tenant file did not document why third-party income verification was not utilized. After review, the Housing Placement Specialists calculated the income correctly, and there was no resulting over subsidy. However, their notation regarding the acceptance of self-declared income was not captured electronically in the Housing Pro software. Prior to transitioning to electronic files, such notations were documented in the physical file. Moving forward, Housing Eligibility Specialists will be required to record all notes regarding self-declared income directly in the Housing Pro software.

View Audit 397193

Finding 1205506 (2025-002)

Material Weakness 2025

Susquehanna Workforce Network INC

MD

Allowable Costs / Cost Principles § 200.334 § 200.403

SWN will develop additional review procedures over contracts to ensure proper adjustments are proposed to allocate expenses between proper periods. Procedure for approval of the Finance Committee by May 21, 2026. This procedure may include implementation of official listing of SWN's written contract...

SWN will develop additional review procedures over contracts to ensure proper adjustments are proposed to allocate expenses between proper periods. Procedure for approval of the Finance Committee by May 21, 2026. This procedure may include implementation of official listing of SWN's written contracts and vendor contracts. Additionally, the Organization plans to work with vendors to align contracts with the fiscal reporting period.

View Audit 397189

Finding 1205505 (2025-001)

Material Weakness 2025

Hampton School District

NH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties

Corrective Actions 1. Immediately cease noncompliant payment practices • Stop all direct payments or reimbursements to private schools • Communicate the change to all stakeholders 2. Establish compliant fiscal procedures • Ensure the district (LEA) retains control of Title I funds at all times • Pay...

Corrective Actions 1. Immediately cease noncompliant payment practices • Stop all direct payments or reimbursements to private schools • Communicate the change to all stakeholders 2. Establish compliant fiscal procedures • Ensure the district (LEA) retains control of Title I funds at all times • Payments must be made: o To third-party vendors, or o For district-managed services (staff, materials, contracts) • Update written fiscal procedures to explicitly prohibit: o Reimbursement-based arrangements with private schools o Direct cash transfers to private schools • Require pre-approval for all Title I expenditures related to equitable services 3. Implement a vendor-based service model • Contract with approved vendors to provide services to private school students 4. Strengthen review and approval processes • Require multi-level approval (program+ finance) before payments • Cross-check expenditures against: o Approved equitable services plan o Student eligibility and services provided 7. Provide targeted fiscal training • Train finance and program staff on: o Control of funds requirements o Allowable vs. unallowable costs under Title I

View Audit 397188

Finding 1205504 (2025-005)

Material Weakness 2025

Oregon Cascades West Council of Governments

OR

Allowable Costs / Cost Principles

We have revised our process and operating procedure to apply indirect cost methods consistently across all federal grants. We have already corrected the error in FY 2026.

View Audit 397187

Finding 1205503 (2025-003)

Material Weakness 2025

Oregon Cascades West Council of Governments

OR

Reporting Matching / Level of Effort / Earmarking

SEFA expense overstatement originated from a misunderstanding of how to categorize COVID funds. Due to program staffing changes since 2021, it took several inquiries to verify that funds originally categorized as Federal and included on the schedule, were done so in error. It was through an abundanc...

SEFA expense overstatement originated from a misunderstanding of how to categorize COVID funds. Due to program staffing changes since 2021, it took several inquiries to verify that funds originally categorized as Federal and included on the schedule, were done so in error. It was through an abundance of caution that the agency chose to include the funds on the schedule. The thought was it would be better to include than not. This will not be an issue in the future as we have adjusted our grant and project tracking systems to tag transactions that are attached to our funding types. Program and accounting staff work together to verify that information at least quarterly and better tracking systems now exist through the agency’s use of OneDrive, Teams and other centralized Microsoft filing tools. We have also increased communication between the programs, contracts unite, and finance team.

View Audit 397187

Finding 1205502 (2025-004)

Material Weakness 2025

Oregon Cascades West Council of Governments

OR

Matching / Level of Effort / Earmarking

Reporting issues with the USDA lending program have been resolved as of March 2025. Steps have been identified to validate and verify information being reported prior to submission. USDA, CCD and Lending staff are working cooperatively on this effort.

View Audit 397187

Finding 1205499 (2025-003)

Material Weakness 2025

Trustees of the College of the Holy Cross

MA

Allowable Costs / Cost Principles Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.430

Corrective Action Plan: The identified conditions related to timesheets for hourly employees. To mitigate the risk of missing approval documentation for payroll charged to Federal R&D awards, the College is formalizing procedures requiring PI or supervisor review of applicable timesheets, configurin...

Corrective Action Plan: The identified conditions related to timesheets for hourly employees. To mitigate the risk of missing approval documentation for payroll charged to Federal R&D awards, the College is formalizing procedures requiring PI or supervisor review of applicable timesheets, configuring the approval workflow in Workday to require and retain evidence of approval, and implementing periodic monitoring to identify and correct missing approvals. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented before the end of fiscal year 2026.

View Audit 397172

Finding 1205493 (2025-002)

Material Weakness 2025

Trustees of the College of the Holy Cross

MA

Procurement, Suspension & Debarment § 200.214

Corrective Action Plan: The College concurs with this finding. To mitigate the risk of entering into covered transactions with suspended or debarred vendors, the College is updating and formalizing its suspension and debarment policy, establishing procedures to require and document SAM verification ...

Corrective Action Plan: The College concurs with this finding. To mitigate the risk of entering into covered transactions with suspended or debarred vendors, the College is updating and formalizing its suspension and debarment policy, establishing procedures to require and document SAM verification prior to covered transactions under Federal awards, and implementing periodic monitoring to ensure these procedures are performed consistently. Timeline for Implementation of Corrective Action Plan: These process updates will be implemented before the end of fiscal year 2026.

View Audit 397172

Finding 1205487 (2025-001)

Material Weakness 2025

Trustees of the College of the Holy Cross

MA

Equipment & Real Property Management § 200.303 § 200.313

Corrective Action Plan: The College acknowledges that the federally acquired equipment listing did not include all required data elements outlined in 2 CFR 200.313(c) and did not reconcile it against the bi-annual physical inventory completed. To mitigate the risk of incomplete equipment records for...

Corrective Action Plan: The College acknowledges that the federally acquired equipment listing did not include all required data elements outlined in 2 CFR 200.313(c) and did not reconcile it against the bi-annual physical inventory completed. To mitigate the risk of incomplete equipment records for federally acquired equipment, the College is formalizing policies and procedures to ensure required data elements are recorded and maintained, implementing a periodic review process to update the equipment listing, and establishing a reconciliation process to compare bi-annual physical inventory results to the property records and promptly resolve any discrepancies. Timeline for Implementation of Corrective Action Plan: These corrective actions are being implemented before the end of fiscal year 2026.

View Audit 397172

Finding 1205485 (2025-001)

Material Weakness 2025

Metropolitan Familly Services

IL

Procurement, Suspension & Debarment Reporting Internal Control / Segregation of Duties

CORRECTIVE ACTION PLAN FOR FINDING 2025-001 Identifying Number: 2025-001 Finding: For the Federal Award Identification Number: 84.215, contract number (S215J230147), the reporting requirement for FFAFTA reporting, due August 31, 2024 was not met. Required reporting was submitted on January 28, 2026,...

CORRECTIVE ACTION PLAN FOR FINDING 2025-001 Identifying Number: 2025-001 Finding: For the Federal Award Identification Number: 84.215, contract number (S215J230147), the reporting requirement for FFAFTA reporting, due August 31, 2024 was not met. Required reporting was submitted on January 28, 2026, which was after the submission due date. Corrective Action Taken: Metropolitan Family Services will implement a process to ensure new contracts are reviewed so we are adhering to reporting requirements. The Assistant Budget Directors have been notified to review the reporting requirements more closely. The initial review of the reporting requirements will be conducted by the Assistant Budget Directors, and a final review will be by the Budget Director. Responsible Individuals: This will be completed by the following Assistant Budget Directors: Casey Maher Leticia Reyes Jeff Sklenar Emilia Vargas Gaz Meni Ramiro Chavez Reviews will be performed by the Budget Director (Don Pyznarski). Anticipated Completion Date: The anticipated completion date is June 1, 2026.

View Audit 397170

Finding 1205484 (2025-007)

Material Weakness 2025

Las Vegas City Schools

NM

School Nutrition Programs Equipment & Real Property Management Internal Control / Segregation of Duties § 200.303

Recommendation We recommend the District implement documented daily edit checks reconciling meal counts to attendance records and maintain records of this review. For food inventory, the District should establish a formal inventory system, including perpetual inventory records, monthly physical coun...

Recommendation We recommend the District implement documented daily edit checks reconciling meal counts to attendance records and maintain records of this review. For food inventory, the District should establish a formal inventory system, including perpetual inventory records, monthly physical counts, and supervisory review. Staff involved in Child Nutrition operations should receive training on USDA and federal compliance requirements Management Response Corrective Action The Food Service Director will implement the federally required daily edit check process. This will include comparing daily meal counts against the attendance and enrollment figures to ensure that claims do not exceed the number of students present. Any discrepancies identified during this process will be investigated and documented prior to submission of the monthly claim. The District will also change the tracking of meals served by using an official meal tracking device or by having students use their badge/ID cards to get a more accurate meal count each day. The District has a formal inventory process for all food service supplies including canned goods, dry goods, and freezer items. This system tracks items from receipt through consumption. The District conducts monthly physical inventory counts of all food service assets. These counts are reconciled and any significant variances are reviewed by the Food Service Director and reported to the Business Manager. The District will ensure that all nutrition staff is trained on these procedures as well. Due Date of Completion: June 30, 2026 Responsible Party Business Manager, Food Service Director

View Audit 397169

Corrective Action Plans

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