Corrective Action Plans

Finding 1182831 (2025-012)

Material Weakness 2025

State of Vermont

VT

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

Reference Number: 2025-012 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Public Service Department Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/202...

Reference Number: 2025-012 Prior Year Finding: No Federal Agency: U.S. Department of the Treasury State Agency: Agency of Administration Public Service Department Federal Program: COVID-19 – Coronavirus Capital Projects Fund Assistance Listing Number: 21.029 Award Number and Year: CPFFN0202 (2/4/2022 – 12/31/2026) Compliance Requirement: Reporting – Performance Reports Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Department and the Agency review their respective procedures and internal controls to ensure that Quarterly Performance Reports are accurate, are supported by documentation, and that supporting documentation is maintained and is readily available for audit. Views of responsible officials: Management agrees with the finding. Corrective Action Plan The Department of Public Service, the Department of Libraries, and the Department of Forests, Parks, and Recreation will hold a monthly coordination meeting to review program updates, monthly expenditures, reporting processes, and other matters. Notes will be sent out from the monthly meetings within 5 business days. The Department of Public Service will create a review process to be managed by the Financial Director IV. This process will ensure sign-off before reporting is certified and Treasury draws are performed. Scheduled Completion Date of Corrective Action Plan: Monthly Meeting Series Established – 04/15/2026 Full Review process in place – 7/31/2026 Contacts for Corrective Action Plan: Doug Farnham, Vermont State Recovery Office, douglas.farnham@vermont.gov Brittney Wilson, Department of Public Service, brittney.wilson@vermont.gov

View Audit 394235

Finding 1182830 (2025-011)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness § 200.303

Reference Number: 2025-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 ...

Reference Number: 2025-011 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 (4/29/2022 – 4/29/2032) CA0751 (5/1/2023 – 10/1/2028) CA0906 (1/24/2025 – 11/1/2030) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Agency review its procedures and internal controls to ensure that subawards are reported timely and accurately to SAM.gov in no later than the end of the month following the month of issuance or modification. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: VTrans will update procedures to ensure compliance with the Federal Funding Accountability and Transparency Act (FFATA) reporting requirements. As part of this update, the Agency will review the current reporting workflow and clearly define roles, responsibilities, and timelines for FFATA reporting. The updated procedure will include guidance for identifying reportable sub-awards, collecting required data elements, and entering information into the appropriate federal reporting system within the required timeframe. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Diane Bigglestone, Financial Director, diane.bigglestone@vermont.gov

View Audit 394235

Finding 1182829 (2025-010)

Material Weakness 2025

State of Vermont

VT

Reporting § 200.303 § 200.502

Reference Number: 2025-010 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 ...

Reference Number: 2025-010 Prior Year Finding: No Federal Agency: U.S. Department of Transportation State Agency: Agency of Transportation Federal Program: National Infrastructure Investments Assistance Listing Number: 20.933 Award Number and Year: 69A36520401930BLDVT (8/1/2020 – 10/31/2026) CA0714 (4/29/2022 – 4/29/2032) CA0751 (5/1/2023 – 10/1/2028) CA0906 (1/24/2025 – 11/1/2030) Compliance Requirement: Reporting – Schedule of Expenditure of Federal Awards Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend the Agency review and enhance internal controls and procedures for payment processing and SEFA preparation to ensure that payments are properly coded in the accounting system and that expenditures are reported accurately on the SEFA. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: Rail Program Manager • Establish and maintain database with all federal grants and federal funding CFDA/ALN’s. • Coordinate between Budget & Business Support Services / Federal Programs and the Accounting Unit to establish EA’s. • Train all project managers on the collaboration and database management process for gathering and maintaining all required codes and information related to federal funding. • For FRA funded projects the Program or Project Manager will include the federal grant award document when submitting an EA setup request. Budget & Business Support Services / Federal Programs • Upon receipt of a new EA request from the RAIL Program or Project Manager, the Finance EA Setup resource (Patrick MacCormick) will complete the following steps to verify the ALN: o If an FHWA project:  Search the federal project in FMIS. If the federal project does not exist in FMIS,  Make a request to the Federal Programs Team to set up the federal project in FMIS. o All other projects:  Request the grant award from the Program or Project Manager. If the grant award has not yet been distributed,  Request the Notice of Funding Opportunity (NOFO) from Grants.gov or SAM.gov from the Program or Project Manager. o Review the EA setup request and the ALN identified in any one of the methods above to ensure the Assistance Listing Number (ALN) is consistent between both documents. o If a discrepancy is identified between the ALN listed on the EA request and one of the methods above, return the request to the Program or Project Manager for clarification before proceeding with setup. • Federal Program Quarterly FHWA Reporting o Generate a report of all active federal projects with associated ALNs listed in FMIS and AOT EAs.  The report shall pull in ALNs from the previous quarter’s report and flag any changes.  Send email to the Finance EA Setup resource and Accounting Unit containing the generated report. Accounting Unit: • The Accounting Unit will perform an audit of all FRA EA’s and ask the Rail Program Manager to verify. o Any incorrect or missing CFDA/ALN’s will be addressed in STARS. • Prior to year end, the Accounting Unit will contact the Rail Division again. o A list of the EA’s and expenditures with the CFDA/ALN’s from STARS for the year will be provided. o Rail will be asked to verify and certify that Accounting has captured the amounts in the correct CFDA/ALN’s. o Note: These processes have been put in place for the FY26 reporting cycle. (Per Diane Bigglestone) Scheduled Completion Date of Corrective Action Plan: April 1, 2026 Contacts for Corrective Action Plan: Diane Bigglestone, Financial Director, diane.bigglestone@vermont.gov Paul Libby, Senior Project Manager, paul.libby@vermont.gov Patrick MacCormack, Financial Director, patrick.maccormack@vermont.gov

View Audit 394235

Finding 1182828 (2025-009)

Material Weakness 2025

State of Vermont

VT

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

Reference Number: 2025-009 Prior Year Finding: 2024-009; 2023-007 and 2022-016 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) ...

Reference Number: 2025-009 Prior Year Finding: 2024-009; 2023-007 and 2022-016 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) UI370952155A50 (9/1/2021 – 5/22/2025) 23A60UB000019 (8/3/2023 – 5/22/2025) 24A60UD000052 (8/20/2024 – 8/20/2027) Compliance Requirement: Allowable Costs/Cost Principles Type of Finding: Significant Deficiency in Internal Control over Compliance Recommendation: We recommend the Department review and enhance its procedures and controls regarding payment processing to ensure that, prior to charging costs to the program, they are reviewed by a supervisor who is knowledgeable of the regulations regarding allowable program costs and that documentation of the review is maintained. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department has reviewed its procedures and internal controls, and we believe that they adequately require oversight and signoff of all expenditures to ensure that expenditures are adequately reviewed and signed off on. However, there is currently no double check to ensure that the accounting clerks are following these procedures. Department will be adding a secondary check to the procedure to occur at the end of each month to review expenditures for proper coding (cost center, project code and function code) as well as responsible party signoff. Scheduled Completion Date of Corrective Action Plan: May15, 2026 Contacts for Corrective Action Plan: Kristine Murphy, Director, Unemployment Insurance, kristine.murphy@vermont.gov Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182827 (2025-008)

Material Weakness 2025

State of Vermont

VT

Special Tests & Provisions Eligibility Reporting § 200.303

Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2...

Reference Number: 2025-008 Prior Year Finding: No Federal Agency: U.S. Department of Labor State Department Name: Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Year: 23A60UI038010 (1/1/2022 – 9/30/2024) 23A60UR000010 (1/1/2023 – 9/30/2025) 24A60UR000093 (1/1/2024 – 9/30/2026) Compliance Requirement: Special Tests and Provisions: UI Reemployment Programs: RESEA Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: The Department should update its internal controls to ensure that RESEA procedures are followed, that cases are properly documented and appropriate actions are taken when participants fail to meet program requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: In September of 2025, the RESEA program in Vermont was transitioned from the VDOL Unemployment Insurance division to the VDOL Workforce Development division. This transition included a change of supervision for the RESEA Facilitators from a centralized supervisor to supervision by the VDOL American Job Center Regional Managers. Training was provided to these Regional Job Center Managers to help them to support their new RESEA staff. The RESEA Program Administrator will meet with the specific RESEA Facilitator, and the Regional Manager associated with these cases to provide additional technical assistance. This will include on-site visits and virtual follow-up meetings. Additionally, the RESEA Program Administrator is reviewing the current program monitoring plan and will be making some changes to include a quarterly case monitoring requirement for the regional managers in addition to the current monthly Peer Review monitoring. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Jay Ramsey, Director, Workforce Development, jay.ramsey@vermont.gov

View Audit 394235

Finding 1182826 (2025-007)

Material Weakness 2025

State of Vermont

VT

Allowable Costs / Cost Principles Period of Performance Subrecipient Monitoring § 200.303 § 200.308 § 200.309 § 200.403

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027)...

Reference Number: 2025-007 Prior Year Finding: 2024-010; 2023-008: and 2022-017 Federal Agency: U.S. Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) Compliance Requirement: Period of Performance Type of Finding: Material Weakness in Internal Control over Compliance, Material Noncompliance Recommendation: We recommend the Department review and enhance its procedures and controls to ensure that, prior to charging costs to the program, they are incurred within an award’s allowable period of performance and that payments are reviewed and approved by a supervisor who has knowledge of costs that are allowable under the program. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: The Department will review its procedures and internal controls and update as necessary to ensure that all expenditures incurred on an award fall within the allowable period of performance. Scheduled Completion Date of Corrective Action Plan: June 30, 2026 Contacts for Corrective Action Plan: Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182825 (2025-006)

Material Weakness 2025

State of Vermont

VT

Internal Control / Segregation of Duties Material Weakness Reporting § 200.303

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A5...

Reference Number: 2025-006 Prior Year Finding: 2024-008; 2023-005; and 2022-012 Federal Agency: Department of Labor State Agency: Vermont Department of Labor Federal Program: Unemployment Insurance Assistance Listing Number: 17.225 Award Number and Period: 25A55UI000119 (10/1/2024 – 12/31/2027) 24A55UI000063 (10/1/2023 – 12/31/2026) UI370952155A50 (9/1/2021 – 5/22/2025) 23A60UB000019 (8/3/2023 – 5/22/2025) 23A60UB000024 (4/1/2023 – 5/22/2025) 24A60UD000052 (8/20/2024 – 8/20/2027) UI347462055A50 (8/20/2024 – 8/20/2027) 23A60UD000013 (7/14/2023 – 7/14/2026) 25A60UD000067 (10/1/2024 – 9/30/2027) Compliance Requirement: Reporting Type of Finding: Material Weakness in Internal Control over Compliance Recommendation: We recommend that policies and procedures be implemented to ensure that all reports are reviewed by an authorized State official prior to submission and that supporting documentation providing evidence of supervisory review is maintained and available for audit. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: These reports are filed by our Labor Market Information division on behalf of the UI Division. The LMI employee responsible for these reports takes the data from a server/system generated report and enters it into a federal reporting system. Department will review internal controls and update as necessary to ensure that all required reports are filed timely and accurately and that reports are reviewed and approved by authorized State officials prior to submission. From now on the employee responsible for these reports will have their immediate supervisor review both reports to certify and signoff that the submitted report matches the system generated report and that they were submitted timely. Scheduled Completion Date of Corrective Action Plan: March 31, 2026 Contacts for Corrective Action Plan: Kristine Murphy, Director, Unemployment Insurance, kristin.murphy@vermont.gov Chad Wawrzyniak, Chief Financial Officer, chad.wawrzyniak@vermont.gov

View Audit 394235

Finding 1182824 (2025-005)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Nu...

Reference Number: 2025-005 Prior Year Finding: No Federal Agency: U.S. Department of Housing and Urban Development State Agency: Agency of Commerce and Community Development Federal Program: Community Development Block Grants/State's Program and Non-Entitlement Grants in Hawaii Assistance Listing Number: 14.228 Award Number and Year: B-20-RH-50-0001 (1/17/2022 - 2/1/2029) B-22-RH-50-0001 (3/27/2023 - 9/1/2029) B-23-RH-50-0001 (7/1/2023 - 9/1/2030) B-22-DC-50-0001 (7/1/2022 - 9/1/2029) Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported in accordance with FFATA requirements. Views of responsible officials: Management agrees with the finding. Corrective Acton Plan: We have developed specific fields in the online grants management system, GEARS to manage the process of input into SAM.GOV of grant agreements and amendments by the execution date. In addition, the SAM.GOV system clearly identifies the “Subaward Date” stating “enter the date you have signed the subaward.” Staff have been trained appropriately on both GEARS and SAM.GOV to ensure the correct Subaward Date is entered. Scheduled Completion Date of Corrective Action Plan: Completed Contacts for Corrective Action Plan: Ann Karlene Kroll, DHCD Federal Programs Director, annkarlene.kroll@vermont.gov

View Audit 394235

Finding 1182823 (2025-004)

Material Weakness 2025

State of Vermont

VT

Eligibility Reporting Special Tests & Provisions § 200.303

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2...

Reference Number: 2025-004 Prior Year Finding: 2024-004 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Human Services Federal Program: SNAP Cluster Assistance Listing Number: 10.551, 10.561 Award Number and Year: 4VT402513 (10/1/2023 – 9/30/2024) 4VT433933 (10/1/2023 – 9/30/2026) 4VT437533 (10/1/2023 – 9/30/2025) Compliance Requirement: Special Tests and Provisions – ADP System for SNAP Type of Finding: Material Weakness in Internal Control Over Compliance, Material Noncompliance Recommendation: We recommend that the Agency review and enhance procedures and controls to ensure that eligibility case reviews are performed timely, accurately, and are properly documented. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: A majority of the findings from the 2025 audit predate the completion of corrective actions associated with Audit 2024-004. Because the corrective action completion date was April 18, 2025, these issues resulted in repeat findings related to supervisory case reviews. To address this, the 3SquaresVT Food and Nutrition Team will review the findings with ESD Operations and present examples, along with refresher training on the Supervisor Case Review (SCR) process, at the District Directors Meeting on February 11, 2026. In addition, a new column will be added to the SCR tracking spreadsheet to allow supervisors to document the date corrective actions were completed when revisions are required following a review. The refresher training and the updated SCR tracking spreadsheet are expected to prevent the recurrence of these findings during the 2026 Single Audit. Scheduled Completion Date of Corrective Action Plan: February 11, 2026 Contacts for Corrective Action Plan: Jessica Duranleau, ESD Program Manager, jessica.duranleau@vermont.gov Leslie Wisdom, Food and Nutrition Program Director, leslie.wisdom@vermont.gov Peter Moino, AHS Director of Internal Audit, peter.moino@vermont.gov

View Audit 394235

Finding 1182821 (2025-003)

Material Weakness 2025

State of Vermont

VT

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting § 200.303

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1...

Reference Number: 2025-003 Prior Year Finding: 2024-003 Federal Agency: U.S. Department of Agriculture State Agency: Agency of Agriculture Federal Program: Dairy Business Innovation Initiatives Assistance Listing Number: 10.176 Award Number and Year: 21DBIVT1004 (10/31/2021 – 10/30/2024), AM22DBIVT1015 (9/30/2022 – 9/29/2025), AM21DBIVT1011 (9/30/2022 – 9/29/2026), Compliance Requirement: Reporting – Federal Funding Accountability and Transparency Act (FFATA) Type of Finding: Significant Deficiency in Internal Control Over Compliance, Other Matters Recommendation: We recommend the Agency complete implementation of its corrective action plan from the prior year. It should review its procedures and internal controls to ensure that all required subawards and subaward modifications are reported timely to SAM.gov in accordance with FFATA requirements and that all previously issued subawards are reported. Views of responsible officials: Management agrees with the finding. Corrective Action Plan: The business office will ensure that subrecipient grants containing federal funding that meet the FFATA reporting threshold are marked as “FFATA reportable” upon grant execution in the Agency’s grants and contracts workbook. The Financial Directors will then confirm that all executed agreements that meet the FFATA reporting requirement have been entered and submitted into the appropriate Federal system by the last business day of each month. Scheduled Completion Date of Corrective Action Plan: 4/30/26 Contacts for Corrective Action Plan: Amy Mercier, Financial Director, amy.mercier@vermont.gov Karen Mae Smith, Financial Director, karenmae.smith@vermont.gov

View Audit 394235

Finding 1182820 (2025-002)

Material Weakness 2025

Lehigh University

PA

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the...

Finding 2025-002; Lehigh acknowledge that in two instances, Title IV credit balances were not refunded within the required 14-day timeframe. The two exceptions identified were isolated in nature and attributable to unique circumstances rather than systemic process failure. In the first instance, the student was enrolled in the summer term and their summer Pell Grant was not processed until October. As a result, the Title IV credit balance was created well after the end of the summer payment period, outside of our typical refund monitoring cycle for that term. In the second instance, the credit balance was identified within the 14-day requirement. However, the student had not enrolled in direct deposit through the eBill system. Lehigh contacted the student to obtain payment instructions. When no banking information was provided to Lehigh, a paper check had to be issued, which extended the disbursement timeline beyond the 14-day period. While these situations were atypical, we recognize the importance of ensuring timely disbursement regardless of individual circumstances. To strengthen controls, we continue to prioritize Title IV credit balance refunds over refunds resulting from institutional aid or other funding sources to ensure compliance with federal timelines. Although we continue our institutional practice of holding refunds until after the 10th day of class to account for schedule adjustments and enrollment changes, we will begin generating and reviewing credit balance reports earlier in the cycle to allow sufficient processing time. We will implement automated reporting to identify credit balances that occur after the end of an academic period. These reports will be sent to a shared bursar office email account rather than an individual staff member. This will ensure visibility and actionability even during staff absences, turnover, or non-workdays. Responsibility for monitoring and processing Title IV credit balances will be formally documented. Multiple staff members will be trained in the procedures to ensure appropriate backup coverage during employee absences, leave, or staffing transitions. Management will periodically review refund timelines to confirm adherence to procedures and verify that credit balances are disbursed within regulatory timeframes. We believe these corrective actions address the audit recommendation and will ensure timely and consistent processing of Title IV credit balance disbursements regardless of staffing availability.Name of contact person: Jennifer Mertz is the Assistant Vice Provost of Financial Services and Director of Financial Aid. Completion date: All of the control strengthening mechanisms and documentation will be complete by June 30, 2026.

View Audit 394233

Finding 1182817 (2025-007)

Material Weakness 2025

Circle of Nations School INC

ND

Allowable Costs / Cost Principles § 200.430

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identifie...

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identified an expenditure where payroll benefits were not paid in accordance with the employment letter. Responsible Individuals: Trevor Gourneau, Superintendent Corrective Action Plan: The School will review internal controls surrounding allowable costs and activities to exsure they are adequate to identify unallowable expenditures. Anticipated Completion Date: June 30, 2026

View Audit 394228

Finding 1182816 (2025-002)

Material Weakness 2025

Southwestern Oregon Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. E...

Student Financial Assistance Cluster – Assistance Listing No. 84.063, 84.268 Recommendation: We recommend the College evaluate its policies and procedures around reporting to COD to ensure that information is reported accurately and timely and to retain evidence of the key control having occurred. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Additional staff member will review COD reports before they are submitted via EdConnect. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: April 2026

View Audit 394224

Finding 1182814 (2025-001)

Material Weakness 2025

Southwestern Oregon Community College

OR

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

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Expla...

Student Financial Assistance Cluster – Assistance Listing No. 84.007, 84.033, 84.063, 84.268 Recommendation: We recommend the College implement changes in process and procedures for NSLDS enrollment reporting and implement an internal control that ensures reporting is both timely and accurate. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Continue to review policies and procedures for accurate reporting. Investigate and identify discrepancies being exported by the Student Information System (Jenzabar). Have additional staff member review file and sign off before the data is submitted. Name(s) of the contact person(s) responsible for corrective action: Laura Sneddon Planned completion date for corrective action plan: June 2026

View Audit 394224

Finding 1182810 (2025-002)

Material Weakness 2025

Taylor Brown Hdf CO (east Main Street Apartments

NY

HUD Housing Programs

Finding 2025-002: Mortgage Insurance – Rental Housing (Section 207), federal assistance listing number 14.134 Recommendation: We recommend that East Main Street Apartments resume unit inspections and ensure those inspections are properly documented in the tenant files. Views of management and planne...

Finding 2025-002: Mortgage Insurance – Rental Housing (Section 207), federal assistance listing number 14.134 Recommendation: We recommend that East Main Street Apartments resume unit inspections and ensure those inspections are properly documented in the tenant files. Views of management and planned corrective action: East Main Street Apartments has resumed unit inspections and will ensure those inspections are properly documented in the tenant files. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394208

Finding 1182809 (2025-001)

Material Weakness 2025

Taylor Brown Hdf CO (east Main Street Apartments

NY

HUD Housing Programs

Audit period: January 1, 2025 – December 31, 2025 The findings from the 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 FINDINGS – FEDERAL AWARD PROGRAM AUD...

Audit period: January 1, 2025 – December 31, 2025 The findings from the 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 FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Mortgage Insurance – Rental Housing (Section 207), federal assistance listing number 14.134 Recommendation: East Main Street Apartments should ensure residual receipts are made within 90 days of year-end in accordance with the HUD Regulatory Agreement. Views of management and planned corrective action: East Main Street Apartments agrees with the finding and will make the required payment. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394208

Finding 1182808 (2025-001)

Material Weakness 2025

Geneva General Housing Development Fund Company, Inc.

NY

HUD Housing Programs

Audit period: January 1, 2025 – December 31, 2025 The finding from the 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Fi...

Audit period: January 1, 2025 – December 31, 2025 The finding from the 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Mortgage Insurance - Rental Housing (Section 207), Federal Assistance Listing Number 14.134 Recommendation: Our auditors recommended that we resume unit inspections and ensure those inspections are properly documented in the tenant files. Action Taken: We are currently in the process of completing and documenting unit inspections. Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821. Anticipated Completion Date: April 2026

View Audit 394206

Finding 1182807 (2025-001)

Material Weakness 2025

St. Anthony School and Daycare/preschool of St. Anthony Congregation

WI

Procurement, Suspension & Debarment § 200.320

Corrective Action Plan: Beginning with the 2026-2027 school year, the organization will follow our Federal Funds Procurement Policy and obtain a minimum of 3 bids for vendors whose purchases exceed $100,000 a year. Anticipated Corrective Action Plan Completion Date: June 30, 2027

View Audit 394205

Finding 1182803 (2025-003)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

HUD Housing Programs Internal Control / Segregation of Duties Procurement, Suspension & Debarment

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance,...

Finding 2025-003: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Rogers Senior Apartments strengthen its overall internal controls surrounding HUD program compliance, including improvements to supervisory oversight, tenant file documentation practices, and monitoring procedures to ensure that required certifications, inspections, and voucher submissions are completed accurately, timely, and in accordance with HUD regulations. Action Taken: Rogers Senior has hired a new apartment manager and regional property manager with significant HUD program experience. The new regional property manager is now providing enhanced oversight, including regular review of tenant files, recertification documentation, and HUD voucher submissions to ensure that all required activities are completed timely, accurately, and in accordance with HUD regulations. Management will continue to monitor compliance and strengthen internal processes to prevent recurrence of these issues. Anticipated Completion Date: April 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394204

Finding 1182802 (2025-002)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

HUD Housing Programs

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Rogers Senior Apartments should ensure residual receipts are made within 90 days of year-end in accordance with the HUD Regulatory A...

Finding 2025-002: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Rogers Senior Apartments should ensure residual receipts are made within 90 days of year-end in accordance with the HUD Regulatory Agreement. Views of management and planned corrective action: Rogers Senior Apartments agrees with the finding and will make the required payment. Anticipated Completion Date: March 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

View Audit 394204

Finding 1182801 (2025-001)

Material Weakness 2025

Miller Road Housing Development Fund Company, Inc.

NY

Internal Control / Segregation of Duties

Audit period: January 1, 2025 – December 31, 2025 The findings from the 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 Finding 2025-001: Board Meetings Recommen...

Audit period: January 1, 2025 – December 31, 2025 The findings from the 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 Finding 2025-001: Board Meetings Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes and the annual report of directors. Additionally, they recommended that we adopt a board governance calendar with statutory checkpoints (annual meeting, director elections, policy reviews) and assign responsibility for compliance tracking. Action Taken: Rogers Senior Apartments has drafted an annual report of directors and are scheduling an annual meeting. Additionally, Rogers Senior Apartments has implemented a governance calendar and checklist. Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821.

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Finding 1182799 (2025-002)

Material Weakness 2025

Loretto Apts at O'Brien Road Hdfc, Inc. (o'brien Rd SR Appts 2)

NY

HUD Housing Programs

Finding 2025-002: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 (Continued) Recommendation: Our auditor’s recommended that we ensure sufficient operating cash flow to make all required reserve for replacement deposits in the future. Views of management an...

Finding 2025-002: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 (Continued) Recommendation: Our auditor’s recommended that we ensure sufficient operating cash flow to make all required reserve for replacement deposits in the future. Views of management and planned corrective action: Management concurs. The December payment was made on January 9, 2026. Action Taken: The December payment was made on January 9, 2026. Completion Date: January 9, 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821

View Audit 394200

Finding 1182798 (2025-001)

Material Weakness 2025

Loretto Apts at O'Brien Road Hdfc, Inc. (o'brien Rd SR Appts 2)

NY

HUD Housing Programs

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. Findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Fi...

Audit period: January 1, 2025 – December 31, 2025 The findings from the 2025 schedule of findings and questioned costs are discussed below. Findings are numbered consistently with the number assigned in the schedule. FINDINGS – FINANCIAL STATEMENT AUDIT None FINDINGS – FEDERAL AWARD PROGRAM AUDIT Finding 2025-001: Supportive Housing for the Elderly (Section 202), Federal Assistance Listing Number 14.157 Recommendation: Our auditor’s recommended that O’Brien Road Senior Apartments 2 remit the overage of $14,632 to HUD’s Accounting Center or submit HUD 9250 for HUD approved application if directed. Views of management and planned corrective action: Management concurs and will submit form HUD 9250. Action Taken: Management is in the process of submitting form HUD 9250. Anticipated Completion Date: May 2026 Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821

View Audit 394200

Finding 1182795 (2025-002)

Material Weakness 2025

St. Peter's Italian Church Housing Development Fund Co., Inc.

NY

HUD Housing Programs Reporting Internal Control / Segregation of Duties

Finding 2025-001: U.S. Department of Housing and Urban Development - Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 See Findings – Financial Statement Audit Finding 2025-002: U.S. Department of Housing and Urban D...

Finding 2025-001: U.S. Department of Housing and Urban Development - Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 See Findings – Financial Statement Audit Finding 2025-002: U.S. Department of Housing and Urban Development - Program: Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Housing Projects, Federal Assistance Listing Number 14.155 Recommendation: Our auditor’s recommended that Villa Scalabrini strengthen its overall internal controls surrounding HUD program compliance, including improvements to supervisory oversight, tenant file documentation practices, and monitoring procedures to ensure that required certifications, inspections, and voucher submissions are completed accurately, timely, and in accordance with HUD regulations. Action Taken: Villa Scalabrini has hired a new apartment manager and regional property manager with significant HUD program experience. The new regional property manager is now providing enhanced oversight, including regular review of tenant files, recertification documentation, and HUD voucher submissions to ensure that all required activities are completed timely, accurately, and in accordance with HUD regulations. Management will continue to monitor compliance and strengthen internal processes to prevent recurrence of these issues. Name of Contact Person Responsible for Corrective Action: John Lutz, VPF, (315) 424-1821. Anticipated Completion Date: March 2026

View Audit 394197

Finding 1182794 (2025-001)

Material Weakness 2025

St. Peter's Italian Church Housing Development Fund Co., Inc.

NY

Internal Control / Segregation of Duties

Audit period: October 1, 1899 – September 30, 2025 The findings from the 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 Finding 2025-001: Board Meetings Recomme...

Audit period: October 1, 1899 – September 30, 2025 The findings from the 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 Finding 2025-001: Board Meetings Recommendation: Our auditors recommended that we schedule and hold an annual meeting of the board of directors and document minutes and the annual report of directors. Additionally, they recommended that we adopt a board governance calendar with statutory checkpoints (annual meeting, director elections, policy reviews) and assign responsibility for compliance tracking. Action Taken: Villa Scalabrini has drafted an annual report of directors and are scheduling an annual meeting. Additionally, Villa Scalabrini has implemented a governance calendar and checklist. Name of Contact Person Responsible for Corrective Action: John Lutz, Vice President of Finance, (315) 424-1821. Anticipated Completion Date: April 2026

View Audit 394197

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