Corrective Action Plans

Finding 1205416 (2025-003)

Material Weakness 2025

University of Maryland Medical System Corporation

MD

Procurement, Suspension & Debarment § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congre...

I. Procurement, Suspension and Debarment Incomplete Federal Requirements within Procurement Policies Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: The Corporation should update its procurement policy to include the provisions required by the Uniform Guidance for purchasing goods and/or services with federal funds. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA, Corporate Financial Reporting and Legal drafted a procurement policy for federal awards. The policy is under review by other relevant stakeholders across UMMS. Anticipated Completion Date – August 31, 2026 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

View Audit 397091

Finding 1205414 (2025-002)

Material Weakness 2025

University of Maryland Medical System Corporation

MD

Allowable Costs / Cost Principles Cash Management Reporting

C. Cash Management; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressional...

C. Cash Management; L. Reporting Evidence of Review and Approval of the Reported Expenditures Assistance Listing Assistance Listing 93.078 – Strengthening Emergency Care Delivery in the United States Healthcare System through Health Information and Promotion Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Health and Human Services Department of Justice Recommendation: Management should reassess the design of its controls to ensure documentation is retained that evidences the review and approval of expenditures submitted to the DOJ and DHHS for reimbursement. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. ORSPA and Corporate Financial Reporting are developing standard operating procedures and policies for the required review and reconciliation of grant expenditures per the accounting system to the financial submissions to the granting agency, including requirements for maintaining evidence of the review(s). A shared central repository for financial submissions was created. For each grant, this repository includes the financial submission and evidence of review and approval of the financial report submissions. The ORSPA and Corporate Financial Reporting will monitor the repository and work with grant managers to ensure evidence of financial submission review and approval is maintained. Anticipated Completion Date – June 30, 2027 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

View Audit 397091

Finding 1205412 (2025-001)

Material Weakness 2025

University of Maryland Medical System Corporation

MD

Allowable Costs / Cost Principles

A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Review and Approval of Payroll Expenditures Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Justice (DOJ) Recommendation: Management should retain documentation that evidences the revi...

A. Activities Allowed or Unallowed; B. Allowable Costs/Cost Principles Review and Approval of Payroll Expenditures Assistance Listing 16.753 – Congressionally Recommended Awards Federal Agency: Department of Justice (DOJ) Recommendation: Management should retain documentation that evidences the review and approval of expenditures submitted to the DOJ. Explanation of disagreement with audit finding: There is no disagreement with the finding and recommendation. Action planned/taken in response to finding: The Corporation established a centralized UMMS Office for Research and Sponsored Programs Administration (ORSPA) department in December 2025. The ORSPA department created a standard pre-award approval process for all sponsored proposals prior to submission or award acceptance. The pre-award approval process applies to all federal, state, local, private and commercial funding opportunities across all UMMS entities and covers new, renewal, resubmission and supplemental proposals. The pre-award approval process includes review of budgeted expenditures and setup of a specific grant identifier within the accounting system and timekeeping system. Grant managers will be provided with updated policies and standard operating procedures, including the required review and approval of payroll expenditures via review of employee timecards in the Kronos and/or Workforce Management timekeeping systems. In lieu of review of timecards, ORSPA and Corporate Financial Reporting established a shared repository for financial submissions to the granting agencies, payroll reports, and detailed expenditure reports generated from the accounting system. The payroll reports and detailed expenditure reports are made available to grant managers to assist in their review and approval of expenditures included in their financial submissions to the granting agencies. The ORSPA and Corporate Financial Reporting will monitor the repository and work with grant managers to ensure evidence of review of the expenditures included within the financial submission is maintained. Anticipated Completion Date – June 30, 2027 Name(s) of the contact person(s) responsible for corrective action: Jeff Chadwick, Financial Reporting Director, jeff.chadwick@umm.edu

View Audit 397091

Finding 1205411 (2025-001)

Material Weakness 2025

West River Transit Authority Dba Prairie Hills Transit

SD

Internal Control / Segregation of Duties § 200.303

Condition: During our testing of controls over payroll, we identified three instances of payroll summary reports lacking an indication of review and approval. Criteria: The Uniform Guidance 2 CFR 200.303 requires auditees to establish and maintain effective internal control over federal awards that ...

Condition: During our testing of controls over payroll, we identified three instances of payroll summary reports lacking an indication of review and approval. Criteria: The Uniform Guidance 2 CFR 200.303 requires auditees to establish and maintain effective internal control over federal awards that provides reasonable assurance that the awards are being managed in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The Organization should have a system of internal control in place to provide reasonable assurance that payroll summary reports are accurate and are being reviewed. Repeat of Prior Year Finding: No. Auditor’s Recommendation: We recommend that payroll summary reports be reviewed and approved prior to completing the payroll process. If the Executive Director is unavailable, another staff member should review and approve the reports so the payroll process can be completed. Management’s Response: Payroll reports will be reviewed and approved by the Executive Director. If the Executive Director is unavailable, another staff member will review and approve the reports. The Executive Director has reviewed and approved all payroll reports to date. Completion Date: March 17, 2026

View Audit 397085

Finding 1205393 (2025-003)

Material Weakness 2025

City of Dunkirk Housing Authority

NY

HUD Housing Programs

Finding: 2025-001 Policies and procedures Corrective Action Plan: Management will work to develop, formalize, and implement a complete set of accounting policies and procedures. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2027 Finding: 2025-002 N...

Finding: 2025-001 Policies and procedures Corrective Action Plan: Management will work to develop, formalize, and implement a complete set of accounting policies and procedures. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2027 Finding: 2025-002 NYSERS submissions Corrective Action Plan: Management will work to submit all overdue ERS submissions as soon as possible. Additionally, Management will work to develop processes and procedures to ensure that future submissions are made timely. Management will attempt to obtain any requisite training for the employee(s) who is charged with this task. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2026 Finding: 2025-003 Federal grants Corrective Action Plan: Management will work to develop and implement better and more comprehensive policies and procedures to ensure that its grant accounting and management processes are more accurate, more efficient, and in compliance with HUD regulation. Responsible Party and Anticipated Completion Date: Elizabeth Cardona, Executive Director June 30, 2027

View Audit 397082

Finding 1205391 (2025-102)

Material Weakness 2025

Pima County

AZ

Cash Management Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303 § 200.328 § 200.334

2025-102 The County did not develop internal control procedures over program reporting and cash management requirements, increasing risk of report errors to awarding agencies and wrongly receiving monies Cluster Name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings number...

2025-102 The County did not develop internal control procedures over program reporting and cash management requirements, increasing risk of report errors to awarding agencies and wrongly receiving monies Cluster Name: Workforce Innovation and Opportunity Act (WIOA) Cluster Assistance Listings numbers and program names: 17.258 WIOA Adult Program 17.259 WIOA Youth Activities 17.278 WIOA Dislocated Worker Formula Grants Award Numbers and years: IGA DI21-002286 July 1, 2024 through June 30, 2025 IGA DI23-002389 July 1, 2023 through June 28, 2028 Assistance Listings numbers and program name: 21.027 COVID-19—Coronavirus State and Local Fiscal Recovery Funds Award Numbers and years: 1505-0271 March 3, 2021 through December 31, 2024 CT-FM-22-149 October 1, 2024 through September 30, 2025 SLFRFP1962 January 5, 2023 through December 31, 2026 CTR069300 January 1, 2024 through December 30, 2026 GTAW-FM-23*123 October 3, 2022 through July 3, 2026 ACJC-VC-25-001A July 1, 2024 through December 31, 2024 Assistance Listings numbers and program name: 93.268 Immunization Cooperative Agreements Award numbers and years: CTR062571 July 1, 2022 through June 30, 2025 CTR059891 July 1, 2022 through June 30, 2027 Name of contact person: Art Cuaron, Director, Finance and Risk Management Anticipated completion date: June 30, 2027 The County recognizes the need to strengthen internal controls over federal reporting and cash management requirements. F&RM will complete the following actions to ensure compliance with 2 CFR Part 200: 1. Establish written internal control policies and procedures for federal program reporting. All federal financial reports will undergo an independently documented review before submission to ensure accuracy, allowability, and proper reporting periods. 2. Implement documentation standards requiring staff to retain supporting materials such as system reports, financial queries, screenshots, and reconciliations, in accordance with federal and County retention requirements. 3. Pima County has been working with each of its grant implementing entities to use Euna Grants calendaring and reminders to prompt the entities’ timely reporting activities. Grants Management and Innovation (GMI) Department sets the reminders schedule at the onset of the performance period. The reminders are then automatically emailed to the grants manager and the assigned accountant for each grant on a set schedule throughout the course of the grant. GMI and Finance – Grants will continue to work with grant implementing entities to use these reminders to trigger the necessary actions in a timely manner. Pima County was still in the process of institutionalizing this system during FY25. 4. Provide training for staff who prepare and review federal reports, focusing on reporting requirements, documentation standards, internal controls, and record retention. 5. Conduct periodic management oversight reviews to confirm that internal controls are followed and that reports are complete, accurate, and submitted on time. The County is also planning to implement the Workday Grants Module with an anticipated go-live of July 1, 2027. This solution will enhance our ability to manage the full fiscal lifecycle of grant awards and ensure compliance with federal reporting requirements. The Workday Grants Module is a native Workday solution, purpose-built to support the full fiscal grant lifecycle. The module supports the following financial grant objectives: • Grant setup and award and fiscal tracking • Cost allocation and allocability controls • Real-time grant financial reporting • Compliance with federal Uniform Guidance (2 CFR 200) • Integration with Workday Financial Management, Procurement and Human Capital Management (HCM) In addition, F&RM has submitted FY 2026/27 budget requests to fund three additional Accountant III positions in our Finance – Grants Division. These positions will expand our capacity to manage our grant portfolio and strengthen our reconciliation, billing and SEFA preparation processes. The contract for the Workday Grants Module is scheduled to go before the Board of Supervisors for approval in April. These new positions will be included in the County Administrator’s Recommended Budget and will be considered by the Board as part of the full budget adoption process in June.

View Audit 397080

Finding 1205382 (2025-001)

Material Weakness 2025

Wayne County Community College District

MI

Reporting

AUDIT FINDINGS Finding Reference Number: 2025-001 Description of Finding: The District is required to submit semi-annual Performance (Technical) Reports where the reporting of grant expenditures must reconcile to the expenditures reported on SF-425 for the same reporting period. For the reporting pe...

AUDIT FINDINGS Finding Reference Number: 2025-001 Description of Finding: The District is required to submit semi-annual Performance (Technical) Reports where the reporting of grant expenditures must reconcile to the expenditures reported on SF-425 for the same reporting period. For the reporting period ended March 31, 2025, the District's CMC Performance Report Line Bk (Totals) agreed to SF-425 Line 1 Ob (Federal cash disbursements) rather than SF-425 Line 1 Oe (Federal share of expenditures). The Performance Report did not accurately present total expenditures for the CMC award for the period. This results in noncompliance with the program's reporting requirements. The Performance Report reported cash disbursement data instead of accrual-basis expenditure data. Statement of Concurrence or Nonconcurrence: Management acknowledges that due to an oversight of cash vs. accrual basis accounting, an immaterial misstatement not resulting in questioned costs or returned funds occurred in grant reporting. Corrective Action: To ensure the increased accuracy of future grant reporting, Management will implement a dual-review process for all future performance reporting. The grant accountant responsible for the financial Performance Report data will now complete a standardized quality assurance checklist before submission. This report will then be formally reviewed and cross-referenced against source data by a secondary finance administrator to verify the accuracy of reported metrics. The CMC (Technical) Performance Report in question has been adjusted to reflect the accurate expenditure values and resubmitted to the grantor. Name of Contact Person: Kim DiCaro, Chief Financial Officer Phone: (313)496-2532 Email: kdicaro1@wcccd.edu Projected Completion Date: The corrective action plan has been implemented; March 18, 2026

View Audit 397075

Finding 1205381 (2025-001)

Material Weakness 2025

United Playaz

CA

Procurement, Suspension & Debarment Internal Control / Segregation of Duties § 200.317 § 200.318 § 200.321 § 200.322 § 200.324

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving fede...

Develop and formally adopt a written procurement policy compliant with 2 CFR 200.317 - 200.327 Train all staff involved in procurement to ensure consistent understanding and proper implementation Perform periodic reviews and updates of the procurement policy to maintain compliance with evolving federal requirements.

View Audit 397074

Finding 1205380 (2025-002)

Material Weakness 2025

South Carolina State University

SC

Internal Control / Segregation of Duties Special Tests & Provisions Student Financial Aid § 200.303

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct ...

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026

View Audit 397073

Finding 1205376 (2025-001)

Material Weakness 2025

South Carolina State University

SC

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

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct ...

Finding 2025-001 – Special Tests and Provisions: Enrollment Reporting – Status Change at Program Level Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-001 related to deficiencies in enrollment reporting at the program level under the Pell Grant, Direct Loan, and Federal Family Education Loan (“FFEL”) programs. The University concurs with the finding and recognizes the importance of accurate and timely reporting to the National Student Loan Data System (“NSLDS”) in accordance with federal requirements (OMB No. 1845-0035). The University is committed to strengthening internal controls, enhancing operational procedures, and ensuring full compliance with all enrollment reporting requirements. II. Criteria Institutions participating in federal student aid programs are required to: • Report accurate enrollment information through NSLDS, including enrollment status and program-level data elements. • Ensure that all significant data elements—including enrollment status, program begin date, and enrollment effective date—are accurate as of the reporting date. • Submit enrollment reporting updates at least every 60 days (bi-monthly). • Maintain adequate internal controls to ensure data integrity and compliance with federal regulations. III. Condition The audit identified errors in enrollment reporting for a sample of 25 students, including: • 2 instances of incorrect program enrollment effective date reporting These errors were attributed to administrative oversight and insufficient internal controls governing enrollment reporting processes. IV. Cause Analysis The University has identified the following contributing factors: • Insufficient internal controls and review mechanisms over enrollment status updates • Limited system automation and alert capabilities for tracking status changes • Inadequate staffing resources to manage reporting timelines and data verification • Lack of formalized cross-functional coordination between the Office of the Registrar and reporting entities • Absence of an independent monitoring function to ensure compliance consistency V. Corrective Actions and Implementation Plan The University will implement the following corrective actions to address the identified deficiencies: 1. Establishment of Internal Audit Function • The University will establish a formal Internal Audit function by the start of the next academic year. • This function will have broad authority to oversee compliance, enforce corrective actions, and evaluate internal controls across all relevant departments. • Internal Audit will lead ongoing reviews of enrollment reporting processes and ensure accountability. 2. Process Review and Cross-Functional Collaboration • Internal Audit will coordinate a comprehensive review of enrollment reporting processes involving the Office of the Registrar and the National Student Loan Clearinghouse. • This review will include a structured assessment of strengths, weaknesses, opportunities, and risks (SWOT analysis). • Standard operating procedures (SOPs) will be updated and formally documented. 3. Staffing and Resource Enhancements • The University will enhance staffing within the Office of the Registrar to support enrollment reporting functions. • Additional technological tools and system capabilities will be implemented to provide automated alerts, status tracking, and exception reporting. 4. Implementation of Monitoring and Control Systems • A robust monitoring system will be deployed to: o Track student enrollment status changes in real time o Generate alerts for discrepancies or missing data o Ensure timely submission of required updates to NSLDS • Data validation checkpoints will be integrated prior to submission to ensure accuracy. 5. Strengthening Reporting Protocols • Interim control measures will include the submission of transfer student status reports on a semester basis until full remediation is achieved. • All enrollment updates will undergo a secondary review and certification prior to submission. • A compliance calendar will be implemented to ensure adherence to the 60-day reporting requirement. 6. Training and Accountability Measures • Mandatory training sessions will be conducted for all personnel involved in enrollment reporting. • Training will focus on federal requirements, data accuracy standards, and system utilization. • Performance expectations and accountability metrics will be clearly defined and monitored. VI. Timeline for Implementation • Immediate (0–90 Days): o Initiate staffing enhancements o Implement interim review and validation procedures o Conduct training sessions • Short-Term (90–120 Days): o Deploy monitoring and alert systems o Formalize SOPs and compliance calendar o Begin enhanced reporting protocols • Long-Term (By Start of Next Academic Year): o Fully establish Internal Audit function o Complete comprehensive process review and continuous monitoring framework VII. Monitoring and Ongoing Compliance The Internal Audit function will conduct periodic reviews and report findings for executive leadership. Continuous monitoring will ensure that corrective actions remain effective and that compliance with federal regulations is sustained. VIII. Conclusion Through the implementation of these corrective measures, the University will address the deficiencies identified in Finding 2025-001 and significantly strengthen its internal control environment. These actions will ensure accurate and timely enrollment reporting, uphold the integrity of federal student aid programs, and reinforce the University’s commitment to regulatory compliance and operational excellence. Anticipated Completion Date: September 1, 2026

View Audit 397073

Finding 1205372 (2025-003)

Material Weakness 2025

South Carolina State University

SC

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.303

Finding 2025-003 – Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountabi...

Finding 2025-003 – Reporting – Special Reports for Federal Funding Accountability and Transparency Act (“FFATA”) Corrective Action Plan I. Overview and Acknowledgment The University acknowledges Finding 2025-003 regarding noncompliance with reporting requirements under the Federal Funding Accountability and Transparency Act. Specifically, the University did not submit a first-tier subaward agreement/amendment/modification within the required timeframe to the System for Award Management (SAM.gov). The University concurs with the findings and is committed to strengthening its internal controls, procedures, and oversight mechanisms to ensure full compliance with all FFATA reporting requirements moving forward. II. Criteria Under FFATA requirements: • Recipients of federal grants or cooperative agreements must report first-tier subawards of $30,000 or more to SAM.gov. • Reporting must be completed timely and accurately in accordance with federal guidelines. • Institutions must maintain sufficient internal controls to ensure that all reportable subawards are identified, tracked, and submitted within required deadlines. III. Condition The audit determined that a subaward agreement, amendment, or modification meeting FFATA reporting thresholds was not submitted within the required timeframe. This reflects a lapse in the University’s internal processes governing subrecipient monitoring and reporting compliance. IV. Root Cause Analysis The University has identified the following contributing factors: • Inadequate tracking mechanisms for subaward reporting deadlines • Insufficient coordination between Grants Administration and responsible program personnel • Lack of automated alerts and centralized monitoring systems • Gaps in internal review and approval workflows prior to submission • Limited oversight to ensure timely compliance with FFATA requirements V. Corrective Actions and Implementation Plan The University will implement the following corrective measures effective immediately: 1. Internal Audit Oversight and Governance • The Internal Audit function will assume leadership responsibility for overseeing FFATA compliance and subrecipient reporting processes. • Quarterly compliance reports will be prepared and submitted directly to the Vice President and Chief Finance Officer until sustained compliance is achieved. • Internal Audit will conduct periodic reviews and testing of subaward reporting to ensure adherence to federal requirements. 2. Enhanced Tracking and Monitoring Systems • A centralized tracking system will be implemented to monitor all subawards, including thresholds, reporting deadlines, and submission status. • Automated alerts and reminders will be established to notify responsible personnel of upcoming reporting deadlines. 3. Strengthening Policies and Procedures • Standard Operating Procedures (“SOPs”) for FFATA reporting will be updated and formally documented. • Procedures will clearly define roles, responsibilities, timelines, and escalation protocols for noncompliance. • A compliance checklist will be required prior to execution and modification of all subaward agreements. 4. Improved Interdepartmental Coordination • Formal communication protocols will be established between Grants Administration, Principal Investigators, and Finance to ensure timely identification and reporting of subawards. • Designated compliance liaisons will be assigned to ensure accountability across departments. 5. Training and Capacity Building • Mandatory training will be conducted for all staff involved in grants management and subrecipient oversight. • Training will focus on FFATA requirements, reporting timelines, system usage, and compliance expectations. 6. Pre-Submission Review and Quality Assurance • A secondary review process will be implemented prior to submission to SAM.gov to ensure accuracy and completeness. • Documentation supporting all submissions will be retained in a centralized repository for audit and compliance purposes. VI. Timeline for Implementation • Immediate: o Initiate Internal Audit oversight o Implement interim tracking and reporting processes o Begin staff training • Short-Term: o Deploy centralized tracking system and automated alerts o Finalize and implement updated SOPs o Begin quarterly reporting to the Vice President and Chief Finance Officer • Long-Term (Ongoing): o Conduct continuous monitoring and compliance reviews o Maintain quarterly reporting until full and sustained compliance is achieved VII. Monitoring and Ongoing Compliance The Internal Audit function will provide ongoing monitoring and validation of FFATA reporting compliance. Quarterly reports will include status updates, identified issues, corrective actions, and recommendations for continuous improvement. VIII. Conclusion The University is committed to addressing the deficiencies identified in Finding 2025-003 through enhanced oversight, improved processes, and strengthened internal controls. These actions will ensure timely and accurate subaward reporting, uphold compliance with FFATA requirements, and reinforce the University’s commitment to transparency and accountability in federal grant management. Anticipated Completion Date: September 1, 2026

View Audit 397073

Finding 1205371 (2025-001)

Material Weakness 2025

Council for Jewish Elderly and Subsidiaries

IL

HUD Housing Programs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Finding: The company did not implement the HUD approved rent adjustments for October 2024 in a timely fashion. Corrective Actions Taken: Management subsequently made the retroactive adjustments to HUD which have been approved by and paid to HUD. In addition, management has implemented a formal revie...

Finding: The company did not implement the HUD approved rent adjustments for October 2024 in a timely fashion. Corrective Actions Taken: Management subsequently made the retroactive adjustments to HUD which have been approved by and paid to HUD. In addition, management has implemented a formal review and corss-verification process to ensure that rent adjustments are completed accurately and in a timely manner.

View Audit 397066

Finding 1205370 (2025-101)

Material Weakness 2025

Cochise County

AZ

Subrecipient Monitoring Eligibility Procurement, Suspension & Debarment § 200.303

Cochise County Corrective Action Plan Year ended June 30, 2025 2025-101 Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award number and years: CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Departmen...

Cochise County Corrective Action Plan Year ended June 30, 2025 2025-101 Assistance Listings number and name: 10.557 WIC Special Supplemental Nutrition Program for Women, Infants, and Children Award number and years: CTR067930, October 1, 2023 through September 30, 2028 Federal agency: U.S. Department of Agriculture Pass-through grantor: Arizona Department of Health Services Compliance requirement: Eligibility Questioned costs: Unknown The County did not perform eligibility certification requirements, resulting in an increased risk of program participants receiving benefits they are not eligible to receive Contact: Barbara Lang Completion date: March 2026 Corrective Action: Cochise County WIC leadership and staff are committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. This audit timeframe produced findings primarily related to issues that have already been corrected through the departure of staff that contributed to the findings (to include the previous Directors), hiring of new staff with a more thorough and comprehensive training plan implemented, and staff effort to retroactively collect all required signatures at subsequent appointments to ensure all WIC clients have current signatures and understanding of Rights & Obligations and Consents for their certification period. We recognize that these new processes were not put into plan until June 2025, due to the timing of the previous audit, and therefore did not reflect on the July 1, 2024 – June 30, 2025 audit period. In addition to the above resolved issues, a new WIC director was hired in September 2025 and new policies and procedures were immediately developed and put into place. These new policies and procedures that serve as our already implemented corrective action plan are as follows: Staff Training a. All staff are required to complete the full ADHS WIC-sponsored live cohort training courses upon hire, and every 3 years of their employment to ensure competencies are maintained over time. b. All staff complete their annual Civil Rights, Conflict of Interest, and Confidentiality upon hire and annually. Last annual training was completed Fall 2025. c. A staff dedicated as Training Coordinator monitors training logs and ensure all training requirements are met, with additional oversight by the WIC Director and the ADHS WIC State office. d. In-person staff meetings are held monthly, with a significant portion of time dedicated to staff training on programmatic expectations to ensure all staff obtain the same information so that tasks are carried out in a standardized method. e. Weekly team huddles to review any timely findings or discuss issues as a group. f. Weekly 1:1’s with each staff to discuss areas where the employee may need additional training or to discuss any deficiencies the WIC manager has noticed, (i.e. note-taking/documentation, single income verifications, chart review findings, etc.). Separation of Duties g. Cert List for Audits report run every 2 weeks for each clinic/staff person to review adherence to Separation of Duties. i. Follow up with certain percentage of clients per policy to assess how the certification went and verify client information. ii. Follow up with staff if any issues are identified. h. Staff have been training on during staff meetings in July 2025, August 2025, October 2025, and during new employee training on how to properly use the HANDS system to ensure the system accurately records who completed the 2nd income verification. i. Revision of Separation of Duties policy and implementation of new “protected time” procedure to ensure there is a staff person available at almost all times of day to complete the 2nd IV. *Since approval of this policy the ADHS WIC state office on 1/5/2026 and implementation of this policy/procedure, the Cert List for Audit report of single-income verifications has decreased substantially (from 60 in 2 weeks, to 5), all with documented reasons why 2nd IV was unable to be obtained during certification appointment and notes verifying 2nd IV was completed on another date. Rights and Obligations and Consent Forms a. All staff received a refresher training on 8/26/25, will be retrained annually, and are regularly reminded to obtain both required signatures at certification b. If staff are unable to obtain digital signatures due to tech issues, they are required to obtain e-document signatures via the clients email, or written signatures the staff then scans into the client file c. Chart reviews and staff observations are completed on a monthly-bimonthly basis to ensure ongoing staff compliance with policy and procedure

View Audit 397064

Finding 1205369 (2025-001)

Material Weakness 2025

Logan Elm Local School District

OH

Eligibility School Nutrition Programs Matching / Level of Effort / Earmarking

We have followed up with PaySchools and they have a target date of 4/30/26 for release of SOC Type II report, which should provide documentation on the effectiveness of their controls upon which we can rely when it comes to using their automated free and reduced application processing. In the meanti...

We have followed up with PaySchools and they have a target date of 4/30/26 for release of SOC Type II report, which should provide documentation on the effectiveness of their controls upon which we can rely when it comes to using their automated free and reduced application processing. In the meantime, our Food Service Supervisor will be reviewing all applications retroactive to the beginning of 2025-26.

View Audit 397060

Finding 1205366 (2025-005)

Material Weakness 2025

City of Alexandria

VA

Subrecipient Monitoring § 200.303 § 200.332 § 200.414

Home Investment Partnerships Program Assistance Listing No. 14.239 Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Explanation ...

Home Investment Partnerships Program Assistance Listing No. 14.239 Recommendation: The City should review and enhance its internal controls and procedures to ensure that all required information is included in subawards at the time of issuance and maintained in subsequent modifications. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City will undertake additional training for departments in FY 2026, to include providing departments with a grants responsibility checklist. Name(s) of the contact person(s) responsible for corrective action: Kevin Greenlief, Director of Finance. Planned completion date for corrective action plan: Q2, 2026.

View Audit 397053

Finding 1205363 (2025-004)

Material Weakness 2025

City of Alexandria

VA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Highway Planning and Construction Assistance Listing No. 20.205 Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor's suspension and debarment status is documented prior to contracting with the vendor. Explanation of disagreement with audit find...

Highway Planning and Construction Assistance Listing No. 20.205 Recommendation: We recommend that the City review and enhance current procedures to ensure that the vendor's suspension and debarment status is documented prior to contracting with the vendor. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The City's Transporation Department erroneously thought the City's Purchasing Department performed the suspension and debarment check. Purchasing reported that since we were riding the contract of another jurisdiction that they rely on that jurisdiction to check for debarment and the other jurisdiction confirmed that they only award contracts to active vendors on the State's eVA system, hence an indication of no debarment). Regardless, the City will conduct additional training in this area for prime award recipients and for Purchasing staff. The City will also check for suspensions and debarment even if riding contracts from other jurisdictions. Name(s) of the contact person(s) responsible for corrective action: Davidia Thompson, Wynndell Bishop, Department of Finance. Planned completion date for corrective action plan: Q2, 2026.

View Audit 397053

Finding 1205361 (2025-003)

Material Weakness 2025

City of Alexandria

VA

Subrecipient Monitoring Reporting Significant Deficiency § 200.303

HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation o...

HeadStart Assistance Listing No. 93.600 Recommendation: We recommend that DCHS review procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation of supporting compliance should be readily available for review. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The reporting has been completed. New employees will be trained in the procedures and internal controls to ensure that the required subawards are reported timely and accurately to FSRS no later than the end of the month following the month of issuance of each subaward. Documentation will be available for review during the audit period. Name(s) of the contact person(s) responsible for corrective action: Noah Abraham, DCHS Operations Director. Planned completion date for corrective action plan: Complete

View Audit 397053

Finding 1205360 (2025-003)

Material Weakness 2025

Lincoln County Health Department

MO

Procurement, Suspension & Debarment Internal Control / Segregation of Duties Subrecipient Monitoring

2025-003 Material Weakness Internal Control – Special Tests / Prevailing wages C. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for obtaining certified payrolls as needed in conjunction with construction projects. D. Actions Taken or Planned: Management will requ...

2025-003 Material Weakness Internal Control – Special Tests / Prevailing wages C. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for obtaining certified payrolls as needed in conjunction with construction projects. D. Actions Taken or Planned: Management will request certified payrolls for any future construction contracts as required by federal regulation. Anticipated completion date: Already implemented, ongoing Contact information for this finding: Michelle Walsh, 636-528-6117

View Audit 397052

Finding 1205359 (2025-002)

Material Weakness 2025

Lincoln County Health Department

MO

Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

2025-002 Material Weakness Internal Control / Noncompliance – Reporting A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for reporting program personnel cost. B. Actions Taken or Planned: Management will continue to evaluate their controls with respect to current...

2025-002 Material Weakness Internal Control / Noncompliance – Reporting A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for reporting program personnel cost. B. Actions Taken or Planned: Management will continue to evaluate their controls with respect to current federal awards and requirements to insure accurate information captured and reported in accordance with the required timelines by implementing additional oversight. Anticipated completion date: Already implemented, ongoing Contact information for this finding: Michelle Walsh, 636-528-6117

View Audit 397052

Finding 1205357 (2025-001)

Material Weakness 2025

Lincoln County Health Department

MO

Eligibility Subrecipient Monitoring Material Weakness

2025-001 Material Weakness Internal Control / Noncompliance – Eligibility A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for maintaining supporting documentation to provide evidence of LCHD’s compliance with requirements applicable to each program funded under ...

2025-001 Material Weakness Internal Control / Noncompliance – Eligibility A. Comments on Findings and Recommendations: We concur with the auditor’s suggestions for maintaining supporting documentation to provide evidence of LCHD’s compliance with requirements applicable to each program funded under Uniform Guidance requirements. B. Actions Taken or Planned: Management implemented changes to the capturing and files maintained for documenting a participant’s eligibility for participation in program services. Management will continue to evaluate their controls with respect to current federal awards and requirements to ensure accurate information captured, reported and maintained. Anticipated completion date: Already implemented, ongoing Contact information for this finding: Michelle Walsh, 636-528-6117

View Audit 397052

Finding 1205356 (2025-003)

Material Weakness 2025

Health Resources in Action, INC

MA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

2025-003 Program Name: Environmental Justice Thriving Communities Grantmaking Program; Assistance Listing Number: 64.615 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements mad...

2025-003 Program Name: Environmental Justice Thriving Communities Grantmaking Program; Assistance Listing Number: 64.615 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements made with federal funds. Disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented additional controls to ensure that each program has documented procedures to submit required reports timely and accurately. The untimely filing of reports in fiscal year 2025 resulted from a change in personnel. During fiscal year 2026, management identified all applicable reporting requirements and assigned responsibility to appropriate personnel. Additional procedures were implemented to ensure reports are reviewed and submitted in accordance with required deadlines. Name of the contact person responsible for corrective action: Beth Doreian, CFO Planned completion date for corrective action plan: March 1, 2026

View Audit 397051

Finding 1205354 (2025-002)

Material Weakness 2025

Health Resources in Action, INC

MA

Internal Control / Segregation of Duties Subrecipient Monitoring Reporting

2025-002 Program Name: Community-Based Violence Intervention and Prevention Initiative; Assistance Listing Number: 16.045 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements ma...

2025-002 Program Name: Community-Based Violence Intervention and Prevention Initiative; Assistance Listing Number: 16.045 Compliance Requirement Affected: Reporting: Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements made with federal funds. Disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented additional controls to ensure that each program has documented procedures to submit required reports timely and accurately. The untimely filing of reports in fiscal year 2025 resulted from a change in personnel. During fiscal year 2026, management identified all applicable reporting requirements and assigned responsibility to appropriate personnel. Additional procedures were implemented to ensure reports are reviewed and submitted in accordance with required deadlines. Name of the contact person responsible for corrective action: Beth Doreian, CFO Planned completion date for corrective action plan: March 1, 2026

View Audit 397051

Finding 1205352 (2025-001)

Material Weakness 2025

Health Resources in Action, INC

MA

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Allowable Costs / Cost Principles

2025-001 Program Name: Community-Based Violence Intervention and Prevention Initiative; Assistance Listing Number: 16.045 Compliance Requirement Affected: Procurement Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements m...

2025-001 Program Name: Community-Based Violence Intervention and Prevention Initiative; Assistance Listing Number: 16.045 Compliance Requirement Affected: Procurement Recommendation: HRIA should improve controls/processes around reporting to ensure documentation is retained related to procurements made with federal funds. Disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented additional procedures to ensure that required procurement documentation is appropriately retained for each vendor in accordance with Uniform Guidance requirements. These procedures were implemented and management considers the matter to be fully remediated during fiscal year 2026. Name of the contact person responsible for corrective action: Beth Doreian, CFO Planned completion date for corrective action plan: March 1, 2026

View Audit 397051

Finding 1205351 (2025-003)

Material Weakness 2025

Independent School District No. 548

MN

School Nutrition Programs

Finding 2025-003 Federal Agency Name: U.S. Department of Agriculture Program Name and FALN # : Child Nutrition Cluster Federal Financial Assistance Listing #10.555 National School Lunch Program Federal Financial Assistance Listing #10.553 School Breakfast Program Finding Summary: The Region Schools ...

Finding 2025-003 Federal Agency Name: U.S. Department of Agriculture Program Name and FALN # : Child Nutrition Cluster Federal Financial Assistance Listing #10.555 National School Lunch Program Federal Financial Assistance Listing #10.553 School Breakfast Program Finding Summary: The Region Schools do not have an internal control system designed to retain the appropriate review documentation for each meal count reported to the State of Iowa for reimbursement. Responsible Individuals: Bryan Jordan, Controller Corrective Action Plan: The Region Schools will retain a documented review of meal counts at each location completed prior to submission of the reports to the State of Iowa. Anticipated Completion Date: Fiscal year ended June 30, 2026

View Audit 397048

Finding 1205348 (2025-002)

Material Weakness 2025

Independent School District No. 548

MN

School Nutrition Programs

Finding 2025-002 Federal Agency Name: U.S. Department of Agriculture Program Name and FALN # : Child Nutrition Cluster Federal Financial Assistance Listing #10.555 National School Lunch Program Federal Financial Assistance Listing #10.553 School Breakfast Program Finding Summary: The Region Schools ...

Finding 2025-002 Federal Agency Name: U.S. Department of Agriculture Program Name and FALN # : Child Nutrition Cluster Federal Financial Assistance Listing #10.555 National School Lunch Program Federal Financial Assistance Listing #10.553 School Breakfast Program Finding Summary: The Region Schools do not have an internal control system designed to retain the appropriate review documentation related to student eligibility within the student file. Responsible Individuals: Bryan Jordan, Controller Corrective Action Plan: The Region Schools will retain documentation related to the review of eligibility of the students participating in the Program within the student file going forward. Anticipated Completion Date: Fiscal year ended June 30, 2026

View Audit 397048

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