Corrective Action Plans

Finding 1223498 (2025-005)

Material Weakness 2025

Guam Housing and Urban Renewal Authority

GU

Subrecipient Monitoring HUD Housing Programs Reporting

Finding #2025-005 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B20SW660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Reporting - Federal Funding Accountability and Transparency Act Views of Responsible Officials and Planned Corrective Action Management’s Position: Ma...

Finding #2025-005 14.225 CDBG – Endtitlement Grants Cluster B19ST660001, B20ST660001, B20SW660001, B21ST660001, B22ST660001, B23ST660001, B24ST660001 Reporting - Federal Funding Accountability and Transparency Act Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that documenting FFATA lagged in some instances during the earlier periods reviewed. In some instances, challenges with the reporting system complicated our ability to submit timely reports. This was discussed with the audit team. A review of additional requests by the auditor was not completed in time to be incorporated into this commentary. Explanation of Disagreement: FFATA submissions in FSRS are often complicated by limitations in the reporting system. For example, validation of an awardee’s address was often an impediment to completing the FFATA submission. The result is the inability to complete the reporting process. Responsible staff would make multiple varied attempts to enter verified information that would be rejected. In an effort to comply, responsible staff make attempts to resolve this either through the funder or the reporting system. Corrective Actions: To strengthen FFATA reporting, management will review its established processes of pre-award through award documentation. Management will review assigned responsibilities to ensure confirmation of FFATA submission. The RPE Division is responsible for FFATA reporting into SAM.gov. Specific responsibilities to oversee this process are assigned and necessary accesses assigned. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: Immediate. The processes of FFATA reporting are in place for all FFTA submissions. Personnel are assigned to ensure the FFTA process is executed and documented for all funded activities.

View Audit 406860

Finding 1223497 (2025-004)

Material Weakness 2025

Guam Housing and Urban Renewal Authority

GU

Reporting Subrecipient Monitoring HUD Housing Programs

Finding #2025-004 14.225 CDBG – Endtitlement Grants Cluster B23ST660001, COVID-19 B20SW660001, B20ST660001 Reporting - CDBG Financial Summary Report Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowled...

Finding #2025-004 14.225 CDBG – Endtitlement Grants Cluster B23ST660001, COVID-19 B20SW660001, B20ST660001 Reporting - CDBG Financial Summary Report Views of Responsible Officials and Planned Corrective Action Management’s Position: Management partially concurs with the finding. Management acknowledges that supporting documentation explaining differences between the PR26 – CDBG Financial Summary Report, PR26 – CDBG-CV Financial Summary Report, and the Authority’s accounting records can be further strengthened. However, management does not concur that the identified differences resulted in noncompliance with CDBG expenditure requirements or applicable Public Service (PS) and Planning and Administration (PA) expenditure limitations. Explanation of Disagreement: Management notes that the PR26 report referenced in the finding is not the final CDBG Financial Summary Report submitted for Program Year 2024. Management requests that the PR26 report submitted in response to audit request #204 be considered for purposes of evaluating the reported CDBG financial activity. Management also notes that the FY2025 expense detail does not represent the full amount of CDBG expenditures reflected in FY2025 draw activity. This is because certain payroll expenditures incurred during FY2024 were drawn during FY2025 and are therefore included in FY2025 cash activity reported through HUD. Management notes that the purpose of the PR26 reports is to summarize CDBG and CDBG-CV financial activity and demonstrate compliance with applicable program expenditure limitations, including the Public Service and Planning and Administration caps. Management has reviewed these calculations and confirmed, in coordination with HUD representatives, that the applicable caps were not exceeded. Management further notes that differences between the PR26 reports and the Authority’s accounting records may occur due to differences in reporting methodologies. The PR26 reports are prepared based on cash activity reported through HUD, while the Authority’s financial records are maintained on an accrual basis. As a result, differences may occur due to timing of draws, prior-period expenditures drawn during the current reporting period, and other applicable reconciling items. Based on the above, management maintains that the identified differences are attributable to reporting basis and timing differences rather than noncompliance with CDBG expenditure requirements. The final CDBG Financial Summary Reports and supporting documentation have been provided for the auditor’s consideration. Corrective Actions: Management will enhance existing PR26 preparation procedures by maintaining supporting documentation identifying significant reconciling items between HUD-reported activity and the Authority’s accounting records. The purpose of this documentation will be to explain differences resulting from reporting methodology, timing of draws, prior-period expenditures drawn during the current reporting period, and other applicable reconciling items. The RPE Accounting Department, will be responsible for maintaining supporting documentation for PR26 reporting and documenting significant reconciling items. Supervisory review will continue to be performed prior to submission of future PR26 reports to ensure reported information is supported and appropriately documented. Responsible Party: Katherine Taitano, Chief Planner Anticipated Date of Completion: The enhanced documentation procedures will be implemented beginning with the next PR26 reporting cycle.

View Audit 406860

Finding 1223496 (2025-003)

Material Weakness 2025

Guam Housing and Urban Renewal Authority

GU

HUD Housing Programs Special Tests & Provisions

Finding #2025-003 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions – Reasonable Rent Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed the regulations 24 ...

Finding #2025-003 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions – Reasonable Rent Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed the regulations 24 CFR 982.507 and is fully knowledgeable of the process when determining rent reasonableness with comparable units in the private market and properly document all comparables. Before executing a HAP Contract, a rent reasonableness analysis is conducted for all units. This analysis includes assessing comparable unassisted units taking into account the location, size, type, and age of unit, as well as any amenities (such as septic, sewer, air conditioning, etc.), and utility responsibilities. We have standard operating procedures and methodologies in place to conduct these analyses and certify that comparable rents are reasonable. Any identified errors are likely due to isolated oversights during the data entry process. Explanation of Disagreement: Listed below are the discrepancies with accompanying comments. Out of the seven (7) entries provided, one (1) was identified as a calculation error. TOTAL: 07 entries (table provided to support explanation) 1. 4 Rent Reasonableness entries were completed correctly. 2. 2 Rent Reasonableness entries were system input errors. 3. 1 Rent Reasonableness analysis was an administrative error. Voucher Number Effective Date Auditor Comment Section 8 HCV Response HCV2828 2/1/2025 Per examination of the Rent Reasonableness reports, it was noted the comparables are not within similar area locations. We noted that the unit is located in Yigo (Northern), while the comparable units used in the rent reasonableness determination were located in the Southern area. To properly check the unit comparisons, the rent reasonableness module was updated to reflect the correct location and the three highest scoring comparable units were selected based on the applicable comparison factors. From the revised analysis, the average rent of the comparable unassisted units were $1,924, which is less than the initial calculated average of $2,966.67. SYSTEM INPUT ERROR: Location of the Proposed Unit was inputted as 'Southern' when the Yigo unit is a 'Northern' located unit. As a result, comparables for units located in the southern location were pulled. SOLUTION: All Section 8 assisted units in the system will be assessed to verify location accuracy based off of village and zip code. NED0444 10/1/2024 The Authority did not rely on the comparable contract rents reflected in the Rent Reasonableness Determination Report (average $949.33), but instead recalculated contract rent using gross rent less a utility allowance, resulting in $1,000. This methodology is not directly supported by the market comparables presented in the report. ADMINISTRATIVE ERROR: The amount of $949.33 should have been the contract rent amount. SOLUTION: Review discrepancy with team to ensure errors will not happen in the future. HCV2796 1/1/2025 Per Mark McCormick on the Rent Reasonable Determination Report and Request for Tenancy Approval (RFTA), the documents indicate no comparable unassisted units were available in the proposed unit's area; however, a nearby unassisted unit in the RFTA is at Ladera Tower and appears reasonably comparable based on proximity. 12a. Owner’s Certification 1. Ladera Towers - Date rented: 9/1/24 - Rental amount: 2,450 2. Washington Dr - Date rented: 10/21/21 - Rental amount: 1,850 3. Quichocho St Villa - Date rented: 1/21/23 - Rental amount: 1,850 RR DETERMINED CORRECTLY: (1) Rent Determination Documents has a note that the unassisted units are not on premises. (2) The units listed in the RFTA-12A were not located on the premises of the unit to be under HAP contract which is why it was not referenced. (3) The Ladera Towers may or may not be in the unassisted units database; is was not in the database at the time the comparables were made. HCV2876 6/30/2025 The approved contract rent of $1,400 was calculated using the average column in the Rent Reasonableness Determination Report (exception); however, the three comparable unassisted units listed on the RFTA are each $1,200, which is lower than the approved amount. Owners Certification: 138 (#347) and 148 (#363) Chalan totche $1,200 132 Chalan Guihan #402 $1,200 RR DETERMINED CORRECTLY: RFTA lists LITHC properties. LITHC unit rates are not used in comparables. 6-05-0050- 56262 9/1/2025 The owner proposed rent of $2,500 was determined to be rent reasonable based on the average comparable unassisted units of $3,774 and Fair Market value of $2,964. However, it was noted that the unit is located in Chalan Pago (Central), while one of the comparable units used in the rent reasonableness determination was located in the Northern area. To properly check the unit comparisons, the rent reasonableness module was updated to reflect the correct location and the three highest scoring comparable units were selected based on the applicable comparison factors. From the revised analysis, the average rent of the comparable unassisted units were $1,870, which is less than the initial calculated average of $3,774. SYSTEM INPUT ERROR: Location of unassisted unit was labelled as 'Central' when the village and zip code indicates that unit is located in the 'Northern' area. SOLUTION: All Section 8 unassisted units in the system will be assessed to verify location accuracy based off of village and zip code. 6-08-0353- 60378 1/1/2025 Per examination of the rent determination report, we noted the approved rent exceeds the rent reflected in the owner-certified lease for a comparable unit; however, no documentation was provided to support or justify the variance between the approved and contracted rent amounts. RR DETERMINED CORRECTLY: Tenant exercised the rent burden rule for this contract. The $100 amount does not exceed the tenant's 40% of AMI. NED0070 11/1/2024 Rent determination documentation indicates an approved amount of $940; however, the executed lease agreement (dated 10/29/2024) reflects a rent of $942 as requested by the landlord. No supporting documentation was provided to justify the variance between the approved rent and the amount charged. RR DETERMINED CORRECTLY: Approved amount for the contract was $942; which aligns with landlord's request. Corrective Actions: (1) SYSTEM INPUT ERRORS: All Section 8 unassisted and assisted units in the system will be assessed to verify location accuracy based off of village and zip code. (2) ADMINISTRATIVE ERRORS: Review discrepancy with team to identify the cause of this issue and ensure similar errors do not happen in the future. Preventive Measures: Closely assess rent determination calculations to ensure accuracy and certified rental amounts are correct. Responsible Party: Nicole Alejandro, Section 8 Administrator Anticipated Date of Completion: Timeline for Resolution: (1) SYSTEM INPUT ERRORS: • 6/18/2026: Request report from MIS to provide list of units with location in the systems. • 6/22/2026: Received report from MIS, consisting of 4,922 units. • 6/22-6/10/2026: Review report, identify deficiencies, and create plan to correct deficiencies. • 6/13/2026: Assign staff to update system with accurate data to address any location deficiencies. • 7/31/2026: Complete assignment. Preventive Measures: Pull quarterly report for assisted and unassisted units in the system and review list of units and ensure location is accurate based off of village and zip code of unit. (2) ADMINISTRATIVE ERRORS: Review discrepancy with team to identify the cause of this issue and ensure similar errors do not happen in the future. • 6/17/2026: Review and discuss discrepancy with HCV Inspection Supervisor • 6/18/2026: Conduct Inspection Team Meeting to address discrepancy with HCV Inspection Team to identify the cause of the issue. Review SOP with team to ensure similar errors do not happen in the future • 6/18/2026: Assignment completed.

View Audit 406860

Finding 1223495 (2025-002)

Material Weakness 2025

Guam Housing and Urban Renewal Authority

GU

HUD Housing Programs

Finding #2025-002 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions - National Standards for the Physical Inspection of Real Estate (NSPIRE)/Housing Quality Standards Inspection Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respect...

Finding #2025-002 14.871 Section 8 Housing Choice Vouchers Special Tests and Provisions - National Standards for the Physical Inspection of Real Estate (NSPIRE)/Housing Quality Standards Inspection Views of Responsible Officials and Planned Corrective Action Management’s Position: Management respectfully disagrees with this finding. GHURA’s HCV program remains committed to our biennial inspection requirements and are fully compliant with all applicable regulations. When a unit fails inspection, we work quickly to resolve the issues and ensure housing standards are met, as outlined in 24 CFR Part 982. In accordance with 24 CFR 982.405(d), we provide both participants and landlords adequate time to correct deficiencies, which is documented in our system. We remain compliant in our conduct and oversight of these requirements. Should there be a late HQS biennial inspection, this should not interrupt the HAP. Suspending these payments creates an undue burden for participants and strains our partnership with landlords. Unless a unit is deemed unsafe, HAP will continue. HAP abatement and reimbursement policies are in place should they need to be activated to retrieve HAP in instances where it was not entitled. Explanation of Disagreement: The list provided below is insufficient to claim any finding in HQS due to the following: TOTAL: 32 entries (table provided to support explanation) 17 families ended their participation before the biennial inspection was due. 5 families were port-out participants before the biennial inspection was due. 5 units were recorded to have inspections completed before the biennial inspection due date and passed inspection. 1 unit inspection was completed on time, but failed on the first inspection. 1 unit inspection was completed on time, but was a no entry on the first attempted inspection. 1 family moved out of the unit before the biennial inspection. 1 family had incorrect dates in this list and was recorded to have met the biennial inspection and passed inspection. 1 family’s inspection was late by 17 days, however, the inspection was completed and passed in that same month, which did not affect the HAP. Voucher Latest HQS Inspection Activity Sum of Amount Section 8 HCV Response 6-01-0105-926 09/28/23 $ 220.00 EOP: 1/31/25 6-01-0212-58183 04/13/23 $ 13,824.00 EOP: 3/31/25 6-03-0198-2327 4/4/2022 (should be 9/19/22) $ 27,648.00 NOTE: Latest HQS Inspection Activity is 9/19/22 and inspection passed on 9/11/24. The 4/4/22 Inspection Date is for Voucher #6-04-0171-47367 (different tenant). 6-05-0005-42278 07/12/22 $ 25,320.00 NO ENTRY: 7/9/24 | PASSED: 8/21/24 6-05-0145-47900 07/18/22 $ 12,794.00 PASSED: 7/9/24 6-05-0241-46089 08/29/23 $ 2,280.00 OUTSEARCHING: 4/1/25 6-07-0028-2139 07/19/22 $ 23,996.00 FAILED: 7/17/24 | PASSED: 8/19/24 6-07-0115-1927 09/11/23 $ 6,278.00 EOP: 2/28/25 6-07-0289-52502 05/06/22 $ 28,316.00 PASSED: 5/6/24 EHV0132 08/23/23 $ 1,076.00 PORT-OUT: 10/31/24 FUP0156 08/21/23 $ 17,607.00 EOP: 5/31/2025 HCV0134 01/05/22 $ (402.65) PORT-OUT: 6/30/22 HCV0521 04/22/22 $ 18,997.00 PASSED: 4/3/24 HCV0561 08/16/23 $ 14,409.00 EOP: 6/30/25 HCV0735 12/09/22 $ 1,227.00 EOP: 11/30/24 HCV0874 04/17/23 $ 4,383.00 EOP: 12/31/24 HCV1038 03/17/22 $ 5,130.00 PASSED: 1/17/24 HCV1083 9/12/2022 (should be 2/15/22) $ 17,987.00 PASSED: 1/17/24 HCV1333 08/17/23 $ 4,686.00 EOP: 12/31/24 HCV1699 10/18/22 $ (90.40) PORT-OUT: 8/10/23 HCV1704 09/12/23 $ 5,596.00 EOP: 1/31/25 HCV1811 08/31/23 $ 9,096.00 EOP: 3/31/25 HCV1873 07/11/23 $ 1,096.00 EOP: 11/30/24 HCV2024 07/06/22 $ 22,875.00 PASSED: 7/23/24 (LATE) HCV2110 07/19/23 $ 8,344.00 PORT-OUT: 4/30/25 HCV2452 08/02/23 $ 6,256.00 EOP: 1/31/25 HCV2457 07/13/23 $ (1,681.00) PORT-OUT: 7/5/24 HCV2466 08/31/23 $ 1,374.00 EOP: 6/30/25 MS0028 04/05/23 $ 1,449.00 EOP: 10/31/24 MS0031 04/14/23 $ 1,026.00 EOP: 4/30/25 NED0213 07/11/23 $ 9,642.00 EOP: 3/31/25 VASH0149 08/03/23 $ 6,272.00 EOP: 7/31/25 Corrective Actions: Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001. Responsible Party: Nicole Alejandro, Section 8 Administrator Anticipated Date of Completion: Due to my explanation above, there are no corrective actions needed for Finding No.: 2025-001.

View Audit 406860

Finding 1223494 (2025-002)

Material Weakness 2025

DAUPHIN COUNTY CONSERVATION DISTRICT

PA

Questioned Costs Reporting Internal Control / Segregation of Duties

Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should establishe procedures to ensure reports are reviewed and approved prior to submission in the state's GIS system. Action: The Financial Coordinator will prepare the quarterly report and related supporting documenta...

Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should establishe procedures to ensure reports are reviewed and approved prior to submission in the state's GIS system. Action: The Financial Coordinator will prepare the quarterly report and related supporting documentation and enter the data into the state's GIS system. A draft of the quarterly GIS report and supporting documentation will be fowarded to the District Manager for review and approval. The manager approved report will be submitted in the state's GIS system by the Financial Coordinator for final review and approval by the state. Date for Completion: June 16, 2026.

View Audit 406857

Finding 1223493 (2025-001)

Material Weakness 2025

DAUPHIN COUNTY CONSERVATION DISTRICT

PA

Procurement, Suspension & Debarment

Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should design and implement procedures to ensure that contractors are neither suspended nor debarred prior to entering into a contract. Action: District staff will perform a verification of suspension or debarment prior ...

Contact Person: Eric A. Naguski, District Manager. Recommendation: The District should design and implement procedures to ensure that contractors are neither suspended nor debarred prior to entering into a contract. Action: District staff will perform a verification of suspension or debarment prior to entering into future contracts by checking the System for Award Management Exclusions and saving a screenshot showing the results of the search. Date for Completion: June 16, 2026.

View Audit 406857

Finding 1223482 (2025-003)

Material Weakness 2025

Spirit Lake Community School District

IA

Internal Control / Segregation of Duties

SEE RESPONSE AND CORRECTIVE ACTION PLAN AT 2025-001

View Audit 406845

Finding 1223479 (2025-003)

Material Weakness 2025

Evergreen Rural Water of Washington

WA

Allowable Costs / Cost Principles Questioned Costs § 200.303 § 200.414

Community Projects Funding / Congressionally Directed Funding – Assistance Listing No. 17.289. Recommendation: CLA recommends the Organization revise the indirect costs calculation process to review program-only costs, rather than entity-wide costs. Develop policies and procedures to incorporate app...

Community Projects Funding / Congressionally Directed Funding – Assistance Listing No. 17.289. Recommendation: CLA recommends the Organization revise the indirect costs calculation process to review program-only costs, rather than entity-wide costs. Develop policies and procedures to incorporate appropriate internal controls over indirect cost calculations; ensure the performer of the internal control has the required knowledge & understanding of compliance requirements & accounting to catch errors during the review & approval process. There is no disagreement with this audit finding. Action taken in response to finding: In January 2026 we recevied an email from DOL outlining the correct way to allocate indirect costs. We made those adjustments to our indirect calculations and will adjust any previous overstated reimbursements. Name(s) of the contact person(s) responsible for corrective action: Tracey Hunter. Planned completion date for corrective action plan: May 2026

View Audit 406840

Finding 1223470 (2025-003)

Material Weakness 2025

COUNTY OF POCAHONTAS

IA

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

The County will develop procedures to ensure that required federal reports will be reviewed and approved by an independent person who is knowledgeable about the program. Indpendent review will be documented.

View Audit 406835

Finding 1223469 (2025-003)

Material Weakness 2025

Campbellsport School District

WI

Reporting Questioned Costs

District has implemented procedures where amounts reported on the SBS Quarterly and Annual reporting are tied out directly to financial system reports. The business manager and Assistant Superintendent of Teaching & Learning will both review the amounts included in the filings.

View Audit 406824

Finding 1223462 (2025-002)

Material Weakness 2025

City of Greeley

CO

Reporting § 200.502 § 200.510

Condition: The Outdoor Recreation Acquisition, Development and Planning program and the Drinking Water State Revolving Fund program expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Planned Corrective Action: The Finan...

Condition: The Outdoor Recreation Acquisition, Development and Planning program and the Drinking Water State Revolving Fund program expenditures on the schedule of expenditures of federal awards (SEFA) initially presented for audit were not complete and accurate. Planned Corrective Action: The Finance Department recently hired a new Grants Manager after being without this critical position for almost a year. The Grants Manager, along with the Grant Specialist and the Financial Reporting team accountants, plan to work together to improve the tracking and reconciliation of grant activity. In addition, the City implemented eCivis Euna Grants, a grant application, tracking, and reporting system, in November of 2025. The Grants Team will be working with Departments to document the grants process formally for the City and this will ensure that all grants are accounted for and tracked in the Euna grants system. This renewed capacity and new initaitives, supported by the new administrative cost recovery framework and the City's grants management platform, reflects a broader commitment to managing external funding with the same discipline applied to locally generated revenues. Contact person responsible for corrective action: Julie Cunningham, Grants Manager. Anticipated Completion date: 05/01/2027

View Audit 406819

Finding 1223459 (2025-003)

Material Weakness 2025

Corbett School District

OR

Reporting Subrecipient Monitoring § 200.510

Finding 2025-003 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.184H Title IV ESEA, School Based Mental Health Name of Federal Agency: U.S. Department of Education Criteria: Per 2 CFR §200.510(b), ...

Finding 2025-003 Accounting for Grants, Schedule of Expenditures of Federal Awards, and Fiscal Man-agement (Material Weakness) Assistance Listing Number and Title: 84.184H Title IV ESEA, School Based Mental Health Name of Federal Agency: U.S. Department of Education Criteria: Per 2 CFR §200.510(b), the auditee must prepare a complete and accurate Schedule of Federal Expenditures (SEFA) for the period covered by the auditee’s financial statements and submit it with the reporting package by the date required by auditors. The SEFA must include total federal awards expended by Assistance Listing (ALN, formerly CFDA), pass-through entity identifying numbers as applicable, the amount provided to subrecipients (if any), and other required disclosures. The SEFA must include all federal expenditures and awards for the year reported and be reconciled to the General Ledger. Condition: The District did not timely prepare an accurate Schedule of Expenditures of Federal Awards (SEFA). The SEFA provided for audit did not reconcile to the District’s general ledger and contained multiple inaccuracies, including reporting federal expenditures in excess of current-year general ledger activity and misclassification of awards, with certain state programs incorrectly reported as federal programs. Cause: The District lacked effective internal controls over the preparation and review of the Schedule of Expenditures of Federal Awards. Specifically, expenditures reported on the SEFA were not reconciled to the District’s general ledger, and there was no documented review process to verify program classification or reported amounts. Changes in finance staff and the incomplete status of the District’s general ledger at year-end further contributed to the errors and untimely completion of the SEFA. Effect or Potential Effect: Expenditures of federal awards may be reported incorrectly and not be detected and corrected. Because the Auditee’s SEFA was completed incorrectly and not reconciled to the general ledger the SEFA was materially misstated, prior to auditors’ correction recommendations. Questioned Cost: None noted Context: The Schedule of Expenditures of Federal Awards (SEFA) is a required supplementary schedule for Single Audit reporting and is intended to accurately reflect federal award activity in accordance with Uniform Guidance requirements. During the audit, the District provided an initial SEFA that was not timely and contained material inaccuracies. The re-ported expenditures did not reconcile to the District’s general ledger. Certain programs were incorrectly identified as feder-al rather than state awards, and some federal expenditures exceeded amounts recorded in the accounting records. Because the SEFA was neither complete nor accurate at the time of submission, auditors were required to perform addi-tional procedures to identify errors, investigate discrepancies, and propose audit adjustments. Thei extended the audit timeline and increased the risk of noncompliance with federal reporting requirements. Repeat of a Prior-Year Finding: No Recommendation: The District should strengthen internal controls over SEFA preparation by ensuring the general ledger is finalized prior to preparation, reconciling all reported expenditures to accounting records, and implementing a docu-mented review and approval process to verify accuracy and proper program classification. Strengthening procedures, cross training staff, and implementing supervisory review and approval process to verify accuracy, completeness and proper classification of federal versus state awards will enhance compliance with Uniform Guidance, and reduce the risk of future audit findings, and support a more efficient and timely audit process. District’s Response: The District agrees with the finding and recognizes that staffing changes and an incomplete year-end close contributed to the SEFA issues. The District is strengthening reconciliation, review, and oversight procedures to en-sure timely and accurate SEFA reporting in future years. Corrective Action Plan: The District transitioned to a new accounting software for the year ended June 30, 2026. The new system will allow for more clear tracking of individual federal awardS. that are required to be reported on the Schedule of Expenditures of Federal Awards. Additionally, the new business manager for the 2026-2027 fiscal year has multiple years' experience in preparing Schedules of Expenditures of Federal Awards. Planned Implementation Date: August 1, 2026 Responsible Person: District Finance Director

View Audit 406814

Finding 1223458 (2025-001)

Material Weakness 2025

Parenteral Drug Association, Inc.

PA

Allowable Costs / Cost Principles Cash Management Questioned Costs § 200.305 § 200.403

Management acknowledge the improper treatment of the expenditure for the specific period. The expenditure in question was for a one-year marketing services agreement supporting activities under the FDA 503B award. The vendor required payment in advance as a condition of service delivery, and the cos...

Management acknowledge the improper treatment of the expenditure for the specific period. The expenditure in question was for a one-year marketing services agreement supporting activities under the FDA 503B award. The vendor required payment in advance as a condition of service delivery, and the cost was incurred for legitimate grant-related purposes within the approved scope of work and period of performance. The expenditure was fully documented, allocable to the award, reasonable in nature, and directly connected to approved programmatic objectives. Management acknowledges that the transaction involved payment for services extending across a future service period. Specifically, 2 CFR 200 does not prohibit recipients from entering into prepaid contractual arrangements for allowable services necessary to support award implementation, particularly where such arrangements reflect standard vendor business practices and operational necessity. Further, the organization’s actions must be evaluated in the context of significant federal payment administration changes that began in February 2025. Historically, the organization received advance funding under the award consistent with the cash management principles contemplated under 2 CFR 200.305. Beginning in 2025, however, the organization was required to operate under a reimbursement-based process requiring submission of supporting documentation prior to payment release. This materially altered the organization’s working capital position and limited its ability to independently finance operational expenditures for extended periods pending reimbursement. As a result, management was required to make operational decisions necessary to ensure continuity of approved grant activities while balancing vendor requirements, cash flow limitations, and evolving federal reimbursement practices. The organization did not receive excess federal cash, improperly retain federal funds, incur unallowable costs, or use award funds outside the approved project scope. The questioned transaction reflects a timing and payment structure issue rather than a violation of fundamental federal compliance requirements. Management also notes that 2 CFR 200.305 expressly contemplates advance payment methodologies and recognizes that reimbursement-only environments may create operational hardships for recipients lacking sufficient working capital. The organization’s actions were undertaken in good faith to maintain uninterrupted program operations under materially changed federal payment conditions. Importantly, the expenditure was allowable, the services supported approved award objectives, the costs were incurred during the award period, supporting documentation exists, no misuse or diversion of federal funds occurred, and no financial harm to the federal government resulted. Note also that going forward, PDA will record future services and subscriptions to prepaid and amortize based on the periods stipulated on the vendor invoices.

View Audit 406813

Finding 1223293 (2025-001)

Material Weakness 2025

Geer Village, A Housing & Development CO - Bhe

CT

MANAGEMENT AGREES WITH THE FINDING. THE REPLACEMENT RESERVE DEFICIENCY WILL BE FUNDED IN THE AMOUNT OF $4,117. MANAGEMENT WILL ENSURE THAT THE REPLACEMENT RESERVE DEPOSITS ARE MADE ON A TIMELY BASIS IN THE FUTURE.

View Audit 406799

Finding 1223293 (2025-001)

Material Weakness 2025

Geer Village, A Housing & Development CO - Bhe

CT

MANAGEMENT AGREES WITH THE FINDING. THE REPLACEMENT RESERVE DEFICIENCY WILL BE FUNDED IN THE AMOUNT OF $1,600. MANAGEMENT WILL ENSURE THAT THE REPLACEMENT RESERVE DEPOSITS ARE MADE ON A TIMELY BASIS IN THE FUTURE.

View Audit 406799

Finding 1223291 (2025-001)

Material Weakness 2025

Schoolhouse Apartments, Inc.

CT

HUD Housing Programs Procurement, Suspension & Debarment

Finding No. 2025-001 - Replacement Reserve Deposit Increases Planned Corrective Action - Management has since implemented additional procedures to ensure that future replacement reserve deposit changes are implemented by the mortgage servicer. Management has made the 2025 shortage deposit to the rep...

Finding No. 2025-001 - Replacement Reserve Deposit Increases Planned Corrective Action - Management has since implemented additional procedures to ensure that future replacement reserve deposit changes are implemented by the mortgage servicer. Management has made the 2025 shortage deposit to the replacement reserve. Anticipated Completion Date - June 2026 Responsible Contact Person - Stephen Hoover, President, Board of Directors, E-mail: sbhoover@outlook.com

View Audit 406797

Finding 1223290 (2025-001)

Material Weakness 2025

Lymes Elderly Housing, Inc. (lymewood)

CT

Management agrees with the finding. The replacement reserve deficieny will be funded in the amount of $2,414. Management will ensure that the replacement reserve deposits are made on a timely basis in the future.

View Audit 406796

Finding 1223289 (2025-003)

Material Weakness 2025

Wapello Community School District

IA

Internal Control / Segregation of Duties Reporting

The District acknowledges this finding. Due to the limited number of administrative and business office personnel, complete segregation of duties is not always feasible. District administration continually evaluates internal control procedures and has implemented compensating controls to reduce the ...

The District acknowledges this finding. Due to the limited number of administrative and business office personnel, complete segregation of duties is not always feasible. District administration continually evaluates internal control procedures and has implemented compensating controls to reduce the risks associated with limited segregation of duties. As an additional compensating control, the Board of Directors receives and reviews a monthly internal control report that includes receipts, journal entries, manual journal entries, paid claims, and employee absence data. The Board reviews this information and documents its review through a formal sign-off process. In addition, the Board approves claims, reviews monthly financial reports, and monitors budget activity throughout the year. The District will continue to evaluate internal control procedures and implement additional compensating controls when practical to strengthen oversight and reduce the risk of errors or irregularities.

View Audit 406794

Finding 1223285 (2025-001)

Material Weakness 2025

TOWN OF MOORESVILLE

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The...

FINDING 2025-001 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Tom Warthen Contact Phone Number and Email Address: 317-831-1608 twarthen@mooresville.in.gov Views of Responsible Officials: The Town of Mooresville Management agrees that we failed to adopt adequate internal controls by not having a procurement policy in place regarding the use of federal funds and that by not doing so, we failed to recognize the need to obtain three quotes for small purchases. Description of Corrective Action Plan: The Town of Mooresville will adopt a procurement policy for the use of federal funds to ensure that all federal grants are handled appropriately, and all grant requirements are met to the best of our ability going forward. Anticipated Completion Date: To allow time for a policy to be written and adopted by Council and the potential need for outside assistance in creating said policy, the Town of Mooresville anticipates having this policy in place within 60 days of the exit conference.

View Audit 406789

Finding 1223281 (2025-001)

Material Weakness 2025

Dakota Business Lending

ND

Internal Control / Segregation of Duties Questioned Costs Reporting

The Organization will review its procedures for preparing and submitting reports under federal loan programs and put proper supervision controls in place.

View Audit 406780

Finding 1223280 (2025-002)

Material Weakness 2025

City of Noblesville

IN

Subrecipient Monitoring § 200.332

FINDING 2025-002 Contact Person Responsible for Corrective Action: Jeffrey Spalding Contact Phone Number: 317-776-6328 Views of Responsible Official: The City concurs with the finding and recommendation. While monitoring activities were performed for all subrecipients of Coronavirus State and Local ...

FINDING 2025-002 Contact Person Responsible for Corrective Action: Jeffrey Spalding Contact Phone Number: 317-776-6328 Views of Responsible Official: The City concurs with the finding and recommendation. While monitoring activities were performed for all subrecipients of Coronavirus State and Local Fiscal Recovery Funds, the City acknowledges that a formal written procedure and a standardized tracking mechanism were not in place to ensure all monitoring activities were consistently documented in accordance with Uniform Guidance requirements. Description of Correction Action Plan: The City is in the process of developing and implementing formal written procedures for subrecipient monitoring to ensure compliance with the requirements of 2 CFR 200.332 and other applicable Uniform Guidance provisions. The procedures will establish responsibilities for evaluating subrecipient risk, performing monitoring activities, following up on identified deficiencies, and maintaining documentation supporting monitoring efforts. The City will continue to maintain a centralized tracking system, within its new ERP system, for all federal awards passed through to subrecipients. The tracking system will document subrecipient agreements, risk assessments, reporting requirements, monitoring activities performed, required follow-up actions, and the status of corrective actions, if applicable. Prior to issuing federal funds to a subrecipient, the City will perform and document a risk assessment considering factors such as the subrecipient's prior experience with federal awards, results of previous audits, financial stability, personnel and systems responsible for federal compliance, and any identified compliance concerns. Monitoring procedures will be tailored based on the assessed level of risk. Throughout the period of performance, the City will review required financial and performance reports, verify compliance with applicable award requirements, review audit reports when required, and follow up on any identified deficiencies. Documentation supporting all monitoring activities will be maintained in accordance with federal record retention requirements. Management believes these procedures will strengthen compliance with Uniform Guidance requirements and ensure subrecipient monitoring activities are performed consistently, timely, and appropriately documented. Anticipated Completion Date: December 31, 2026

View Audit 406770

Finding 1223272 (2025-002)

Material Weakness 2025

Children's Advocacy Center of Hidalgo County, Inc.

TX

Allowable Costs / Cost Principles Cash Management

Recommendation: It is recommended the Center evaluate and update it internal controls and procedures to ensure costs are appropriately considered when preparing the Center's monthly RFRs. Management Corrective Action Plan: The Center will evaluate its current procedures related to the RFRs and recog...

Recommendation: It is recommended the Center evaluate and update it internal controls and procedures to ensure costs are appropriately considered when preparing the Center's monthly RFRs. Management Corrective Action Plan: The Center will evaluate its current procedures related to the RFRs and recognizes the need to strengthen controls over the preparation of monthly RFRs. The Finance Department will implement additional review procedures to ensure prepaid contracts are properly amortized over the proper benefit period, and expenses are reported in the appropriate benefit period. Responsible Individual & Contact Info: Finance Director-Hilda Valdez Senior Accountant-Dominikue Martinez Executive Director-Nadia Ochoa Anticipated Completion Date: As soon as possible

View Audit 406768

Finding 1223271 (2025-002)

Material Weakness 2025

Bladen County

NC

Eligibility Questioned Costs

Name of Contact Person: Jill Sampson, DSS Director Corrective Action: Training will take place to reiterate the importance of properly recording the required telephonic signature and date. After reviewing the findings listed, the availability of time reserve and how to record it as well the steps fo...

Name of Contact Person: Jill Sampson, DSS Director Corrective Action: Training will take place to reiterate the importance of properly recording the required telephonic signature and date. After reviewing the findings listed, the availability of time reserve and how to record it as well the steps following its expiration will also be discussed. All will be addressed in the upcoming training. Proposed Completion Date: April 7, 2026.

View Audit 406763

Finding 1223270 (2025-001)

Material Weakness 2025

Bladen County

NC

Eligibility Matching / Level of Effort / Earmarking Questioned Costs

Name of Contact Person: Jill Sampson, DSS Director Corrective Action- Internal Control Error: The Auditor Report for Bladen County disclosed finding(s) of non-compliance with laws and regulations. The audit shows that we have repetitive errors from the previous year. We take these results very serio...

Name of Contact Person: Jill Sampson, DSS Director Corrective Action- Internal Control Error: The Auditor Report for Bladen County disclosed finding(s) of non-compliance with laws and regulations. The audit shows that we have repetitive errors from the previous year. We take these results very seriously and are committed to implementing lasting improvements. Bladen County Department of Social Services is focused on establishing protocols that will build a standard of confidence for our Income Maintenance case workers. It has been and will remain our constant goal to strengthen our Medicaid programs through knowledge and training to eradicate errors. Bladen County DSS will implement the following program policy and procedures to improve proficiency in service delivery. We do recognize that we fell short of expectations on this audit, particularly with the repeat error findings. The nucleus of the Plan of Correction will have a framework that will involve both Income Maintenance staff and Managers to set a groundwork that will empower the Medicaid teams to meet state expectations and improved audit outcomes in the future. The Second-Party Audits completed each month by Medicaid Supervisors will track our performance and upon completion of the second party of cases training will be completed to address the errors found. Staff will be given a test that will measure our performance improvement to assure accuracy on case work. Areas Needing Correction: Internal Control Errors • Failure to comply with policy requirement: Three (3) instances of failure to complete at least one compliance component. All identified missing or incomplete verification of facts or were improperly forced. • Inaccurate Resource Calculation: Three (3) instances of inaccurate resource calculations in NC FAST. The values entered in NC FAST evidence and used in the eligibility determination did not match the supporting documentation or was lacking any substantiating documentation. • Inaccurate Budget Calculation: Six (6) instances of inaccurate budget calculations in NC FAST. The values entered in NC FAST evidence and used in the eligibility determination did not match the supporting documentation or was lacking any substantiating documentation. • Failure to document/correct system issues: Four (4) instances of system errors found that were not addressed or corrected. Cases contained benefit histories that were not representative of the benefit that was issued. Goal for Correction: • Work Number Usage Administrative Letter No: 02-19 The Work Number Procedures • The Work Number (TWN) - Job Aid dated 09/21/2023; The Work Number (Fact Sheet) Dated 09/25/2023. • Manual Calculations of Income F/C MA 3300; MA 2250 • MAF-MIC-HSF Budgeting – MA 3305 • Financial Resources MA 2230 • Evidence Dashboard Relationships - Job Aid dated11/27/2018 • Acceptable use of Medical Forced Eligibility– Last updated 03/01/2023. • NC FAST Mandatory Evidence and Verifications • Adding Evidence to Case (Job Aid) • Online Verifications (Job Aid) • MA 3515 Bladen County DSS is committed to using tools listed in this Plan of Correction to assist in recognizing any areas of concern for the Medicaid Teams. Bladen County DSS is eager to assist workers to become the most efficient and productive in their daily work routine, to reach the best desired outcome for both the clients served, as well as the overall audited scores. • Training has been completed for the Medicaid staff on February 23, 2026 (Adult Department) and February 24, 2026 (Family and Children Medicaid Department). See list of Medicaid policy, Administrative letter and NC FAST job aids that were addressed during the meeting. • Medicaid Program Checklist- each Medicaid team will have a checklist that will be utilized on each application/ recertification completed. This tool will be used to ensure Income Maintenance workers have completed all necessary actions to application/recertifications. This tool will also be used in auditing each case during the second party review of the case. *Note: Item Number 18 from the Medicaid Eligibility Testing Attribute has been updated to include The Work Number for household members age 14 and above. These tools are included in the Second Party review of the record and if the worker does not complete the tool a point is deducted as being in error. • Second Party Review of Records – Will be completed monthly by the Supervisor and Lead Worker for the specific program. Each Income Maintenance worker will be monitored by monthly review of three applications and three recertifications. Any errors that are determined during the second party review will be addressed with the worker, who will be given 3 days to make the correction to the file, refute the error finding by discussing manual policy with the Supervisor/Lead worker, workers will need the policy name and section number. This internal audit will assist in determining areas of training that staff need for overall improvement in job performance. • Medicaid Spreadsheet Internal Report Card – has been created for the Medicaid team monthly utilizing the individual scores received from the Second Party review of cases. This will be the benchmark set at 96.8% for Eligibility errors and 90% for technical errors. • Monthly Audits completed by Bladen County Finance Office will continue to be completed. Each worker is given their individual errors discovered by this audit. The worker will be coached concerning the errors found and will be required to make corrections to the case. The worker will also sign the audit form indicating that the information was reviewed with them and the date recorded. • Medicaid Spreadsheet Internal Report Card reviewed by County Boards – The Medicaid Second Party Spreadsheet (Internal Accuracy Report Card) for the Adult Medicaid and the Family and Children Medicaid Department will be reviewed monthly by the Bladen County Health and Human Services Advisory Committee. A formal presentation will be sent to the committee each month via computer. This information will be sent out in the format of spreadsheets; the spreadsheets will indicate each worker (using an alphabet identification) and will indicate if the employee met the benchmark goal of 96.8% eligibility and 90% technical error rate each month. This chart will give a three-month snapshot (window of time) for notifications of error trends identified by the audits. This report will be discussed quarterly at the Health and Human Service Advisory Committee meeting offering each committee member the opportunity to address their concerns about audit scores during that quarter. • All Medicaid Program teams will staff all pending applications (by date priority) with the IMC, Supervisor, and/or Lead worker. This will help to eliminate any questions that the IMC may have in response to completion of the application. • Second Party review of cases will be completed monthly by Supervisor and Lead worker in the Medicaid programs. Upon completion of the entire team’s second party reviews, training will be created based on the errors found at the second party of work. Once the training has been completed, workers will be given a test to determine their understanding of policy, job aid and forms reviewed in the training. A test score of 90% accuracy must be maintained by each staff member to receive a passing score. A score below 90% will require additional training. • A training outline form will be utilized during training so that staff have the opportunity to give feedback as to what they feel they need additional training in. • Newly hired staff within the first (1) year of employment will receive quarterly job performance evaluations. • Newly hired and all active Income Maintenance staff will take and pass (score of 70% or above) the NC FAST Core Functions Certification and Level 1 Training Program. • Newly hired staff will be required to have work reviewed 100%. • Warning System for Persistent Errors – Implementation of a warning system for caseworkers who persistently make errors, despite corrective actions and counseling. First Warning:  When an employee repeatedly makes errors despite individual counseling and corrective actions, they will receive a First Warning.  The employee's supervisor will meet with them to discuss the errors and reinforce the importance of adhering to policies and procedures.  As per Bladen County DSS policy, employees will be given three workdays to make necessary corrections.  The First Warning will be documented in the employee's personnel file. Second Warning:  Within three months, If the employee continues to make errors after receiving a First Warning, they will be issued a Second Warning.  The supervisor will conduct another meeting with the employee to address the persistent issues.  During this meeting, a performance improvement plan will be established, outlining specific areas for improvement and a timeline for achieving them.  The Second Warning will be documented in the personnel file. • Demotion in Position – If the employee's errors persist even after receiving the Second Warning and failing to meet the goals of the Plan of Correction, they will face demotion in position. The demotion will involve a change in job responsibilities or a transfer to a lower-level position if available within the organization. This action will be taken after thorough evaluation and consultation with Human Resources. • Termination – If, despite previous warnings, the employee continues to make errors that significantly impact their performance and the effectiveness of DSS, the last step is termination. Termination is the last resort and will be considered only after the employee has received a First Warning, a Second Warning, and a demotion in position. The decision to terminate will be made in consultation with Human Resources and higher-level management. • Proposed Completion Date: This Plan of Correction will become effective April 1, 2026. The Bladen County Department of Social Services Economic Services Division for the Medicaid Programs will take an active role in ensuring work is monitored and that staff receive training throughout the year, to minimize the error rate from the Single County Audit.

View Audit 406763

Finding 1223269 (2025-002)

Material Weakness 2025

City of La Habra

CA

Questioned Costs Cash Management

The City will update its procedures to ensure the most current school enrollment data is used when determining tier status for day care homes. This includes the use of the KidKare software system with built-in internal controls for tier determination, a double-check process, and additional staff tra...

The City will update its procedures to ensure the most current school enrollment data is used when determining tier status for day care homes. This includes the use of the KidKare software system with built-in internal controls for tier determination, a double-check process, and additional staff training.

View Audit 406755

Corrective Action Plans

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