Corrective Action Plans

Finding 1176392 (2025-003)

Material Weakness 2025

WI

Procurement, Suspension & Debarment § 200.318

Finding Reference Number: Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement – Child Nutrition Cluster Corrective Action: The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service depart...

Finding Reference Number: Finding 2025-003: Significant Deficiency - Internal Control and Compliance Over Procurement – Child Nutrition Cluster Corrective Action: The District acknowledges this finding. Due to its size, it is not cost effective to have more than one person in the food service department working with the procurements. The District will assign someone in the District office to review procurement requirements and ensure contracts meet the District’s policies. The Business Manager will work with the Food Service Director on a process to review procurement requirements and to ensure the contracts meet the District’s policies. This will include language to ensure that a person in the business office will review purchases submitted by the food service department to ensure they are meeting policy requirements. Responsible Person: Shannon Grindell, Susan Mayer

View Audit 390213

Finding 1176386 (2025-001)

Material Weakness 2025

St. Sharbel's Maronite Housing Corporation II Project No. 072-Ee135

IL

Internal Control / Segregation of Duties HUD Housing Programs

Jeff Cottingham, Management agent, and Father Elia, sponsor of the project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.

View Audit 390202

Finding 1176384 (2025-001)

Material Weakness 2025

St. Sharbel's Maronite Housing Corporation Project No. 072-11136ref

IL

Internal Control / Segregation of Duties HUD Housing Programs

Jeff Cottingham, Management agent and Father Elia, sponsor of project, will be responsible for monitoring monthly financial results and accounting information as correction is not practical.

View Audit 390201

Finding 1176382 (2025-001)

Material Weakness 2025

Hanna City Home Association D/b/a Heritage Senior Homes

IL

Internal Control / Segregation of Duties HUD Housing Programs

Jeff Cottingham, Management agent and Wes Clanton, board president of project will be responsible for monitoring monthly financial results and accounting information as correction is not practical.

View Audit 390200

Finding 1176380 (2025-008)

Material Weakness 2025

Madison Commuity Unit School District #12

IL

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the ...

Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the expenditure reports against the budget items before submitting. Management Response: The District will add a verification process to reconcile the general ledger to the budget and expenditure reports before submitting. The District will consider implementing a detailed grant tracking sheet to ensure the general ledger expenditures agree to the expenses reported to ISBE by grant. Anticipated Date of Completion: June 30, 2026

View Audit 390196

Finding 1176377 (2025-007)

Material Weakness 2025

Madison Commuity Unit School District #12

IL

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the ...

Condition: It was noted that there was an inconsistency when comparing the general ledger to what was reported on the expenditure reports. Recommendation: We recommend that steps are taken, including oversight by a second employee, to reconcile the general ledger to the expenditure reports, and the expenditure reports against the budget items before submitting. Management Response: The District will add a verification process to reconcile the general ledger to the budget and expenditure reports before submitting. The District will consider implementing a detailed grant tracking sheet to ensure the general ledger expenditures agree to the expenses reported to ISBE by grant. Anticipated Date of Completion: June 30, 2026

View Audit 390196

Finding 1176376 (2025-006)

Material Weakness 2025

Madison Commuity Unit School District #12

IL

Equipment & Real Property Management

Condition: Equipment records with all required information were not maintained for all items purchased with federal funds. Recommendation: We recommend that the District begins the process of maintaining a capital asset log for all equipment purchased with federal funding. Management Response: Manag...

Condition: Equipment records with all required information were not maintained for all items purchased with federal funds. Recommendation: We recommend that the District begins the process of maintaining a capital asset log for all equipment purchased with federal funding. Management Response: Management agrees to take the necessary steps to ensure compliance requirements are met and will discuss implementing an inventory record-keeping process for all equipment purchased with federal funds. Anticipated Date of Completion: June 30, 2026

View Audit 390196

Finding 1176375 (2025-005)

Material Weakness 2025

Madison Commuity Unit School District #12

IL

Reporting Internal Control / Segregation of Duties

Condition: We noted that two of the five required expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Mana...

Condition: We noted that two of the five required expenditure reports were not filed in a timely manner. Recommendation: We recommend that steps are taken, including oversight by a second employee, to ensure that all quarterly expenditure reports are filed by the due dates. Management Response: Management will take the necessary steps to file all quarterly reports on time in the future. Anticipated Date of Completion: June 30, 2026

View Audit 390196

Finding 1176373 (2025-001)

Material Weakness 2025

Harlan County Community Action Agency, Inc.

KY

Allowable Costs / Cost Principles § 200.403

The entity has implemented new procedures for the preparation and review of reimbursement requests.

View Audit 390192

Finding 1176366 (2025-001)

Material Weakness 2025

Delaware Valley University

PA

Student Financial Aid Reporting Significant Deficiency

Recommendation: The University should review its policies and procedures on determining student's withdrawals and timely communication among departments to ensure timely returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action...

Recommendation: The University should review its policies and procedures on determining student's withdrawals and timely communication among departments to ensure timely returns of Title IV funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University automated the process of communicating withdrawals between departments a few years ago. Unfortunately, an individual responsible for communicating withdrawals failed to use the system in that instance. When the delay in process was discovered, the offices of Student Support, Registrar, Financial Aid, and Bursar met to review communication and documentation processes. Meetings occurred in Summer 2025 to implement a cohesive process. The corrective action is that dismissals related to student conduct follow the same agreed upon process that hiatus and withdrawal follow. The responsible individual no longer works at the University, and their replacement will be fully trained and using the system in place. Name(s) of the contact person(s) responsible for corrective action: Andrew Moyer Planned completion date for corrective action plan: March 31, 2026

View Audit 390188

Finding 1176364 (2025-002)

Material Weakness 2025

Volunteers of America Colorado Branch

CO

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Fina...

Condition: The Organization lacked adequate controls to ensure reviews were performed by a different individual than the one responsible for preparing monthly financial reporting, calculations of per-unit activity, and requests for reimbursement. Planned Corrective Action: 1. Standardization of Financial Reporting Workflow: A formal segregation of duties for all federal and pass-through reimbursement requests and financial reports has been implemented. Effective immediately, the individual responsible for accumulating cost data and calculating per-unit activity (preparer) is prohibited from being the reviewer. 2. Implementation of Approval Process: All reports must now be submitted by the preparer to the designated reviewer for approval via email prior to submission. An approval response from the reviewer is required prior to submission to the awarding agency. 3. Staff Training: All grants management and accounting personnel have been briefed on the requirements of 2 CFR 200.303, specifically regarding the necessity of documented internal controls to provide reasonable assurance of compliance. Contact person responsible for corrective action: Erin Nordmann (Controller) Chiyoko Yokota (Chief Financial Officer) Anticipated Completion Date: Fully Corrected

View Audit 390182

Finding 1176360 (2025-001)

Material Weakness 2025

Volunteers of America Colorado Branch

CO

Reporting Subrecipient Monitoring § 200.303

Condition: The Organization lacked adequate controls to ensure the SEFA was complete and accurate. Planned Corrective Action: 1. Federal Award Classification Review: Federal versus non-federal classification will be reviewed by the program manager, Director of Internal Control, and CFO based on the ...

Condition: The Organization lacked adequate controls to ensure the SEFA was complete and accurate. Planned Corrective Action: 1. Federal Award Classification Review: Federal versus non-federal classification will be reviewed by the program manager, Director of Internal Control, and CFO based on the executed agreement. Any reclassification will require documented CFO approval. 2. Annual Cross-System Reconciliation: An annual reconciliation between the contract management system and the general ledger will be performed to ensure all federal awards are captured for SEFA reporting. 3. SEFA Format Standardization: The SEFA preparation schedule will be reverted to a prior-year rollover format that retains carryforward data and enables year-over-year comparison to improve completeness review and anomaly detection. 4. General Ledger Tagging Controls: General ledger dimensional tagging has been enhanced so federally funded activity is automatically identified and included in the preliminary SEFA. 5. Independent SEFA Review: The SEFA will undergo documented independent review and approval by the CFO prior to auditor submission, consistent with 2 CFR 200.303. Contact person responsible for corrective action: Ian Kile (Director of Internal Controls and Analysis) Chiyoko Yokota (Chief Financial Officer) Anticipated Completion Date: Fully Corrected

View Audit 390182

Finding 1176359 (2025-001)

Material Weakness 2025

City of Sterling Heights, Michigan

MI

Subrecipient Monitoring Allowable Costs / Cost Principles Eligibility

2025-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act, direct recipients of grants or cooperative agreements are required to report fir...

2025-001 – Federal Funding Accountability and Transparency Act (FFATA) Reporting Auditor Description of Criteria, Condition, and Effect: Under the requirements of the Federal Funding Accountability and Transparency Act, direct recipients of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Direct recipients must report key data elements by registering through the FSRS and reporting subaward data through that system. Direct recipients that are awarded a federal grant are required to file a FFATA sub-award report by the end of the month following the month in which the prime awardee awards any sub-grant equal to or greater than $30,000. The City did not submit the required key data elements through the FSRS reporting system as required by the Uniform Guidance and as a result has not completed the appropriate sub-award reporting that is required for direct recipients. Auditor Recommendation: We recommend that the City review its procedures for FFATA reporting through FSRS and ensure that all key data elements are reported timely moving forward. Corrective Action: Upon discovery of the issue in November 2025, City staff corrected the noncompliance by submitting the required report to the appropriate reporting system/entity. To prevent recurrence, management has strengthened internal controls over FFATA reporting and Single Audit preparation by (1) adding review and verification steps, (2) communicating expectations with key personnel, and (3) explicitly assigning submission responsibility to a designated submitter who is independent of the individual(s) responsible for monitoring compliance. These control enhancements are expected to identify and prevent similar deficiencies and, based on implementation to date, appear to be operating effectively. Responsible Person: Jason Denton, Controller Anticipated Completion Date: June 30, 2026

View Audit 390179

Finding 1176358 (2025-001)

Material Weakness 2025

Jamestown Community College

NY

Student Financial Aid Subrecipient Monitoring Equipment & Real Property Management

The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a re...

The College agrees with the finding. While many GLBA-required safeguards are operationally in place, documentation and a formal enterprise risk assessment have not been fully completed. The College will engage a qualified third party to perform a comprehensive GLBA-aligned risk assessment using a recognized framework such as NIST. Based on the results, the College will document identified risks, existing safeguards, and remediation plans. Additionally, the College will formalize and update its Written Information Security Program, including policies addressing vendor management, user access controls, data transmission and destruction, change management, and data inventory. Policies will be reviewed and approved through the College’s governance process. Responsible Party: Kyle Brown, Executive Director of Technology, Jamestown Community College, kylebrown@sunyjcc.edu, 716.338.1118 Anticipated Completion Date: August 31, 2026

View Audit 390178

Finding 1176354 (2025-001)

Material Weakness 2025

Lowndes County Board of Education

GA

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.303 § 200.403 § 200.430

FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Defici...

FA 2025-001 Strengthen Controls over Employee Compensation Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Questioned Costs: Allowable Costs/Cost Principles Significant Deficiency Nonmaterial Noncompliance U.S. Department of Education Georgia Department of Education 84.027 - Special Education Cluster Grant to States 84.173 - Special Education Cluster Preschool Grants H027A230073 (Year: 2024), H027A240073 (Year: 2025), H173A240081 (Year: 2025) $1,283 Description: The policies and procedures of the School District were insufficient to provide adequate internal controls over the employee compensation process as it relates to the Special Education Cluster. Corrective Action Plans: The District concurs with the finding and is committed to strengthening internal controls. While the identified discrepancies were isolated, we recognize the need for enhanced reconciliation during personnel transitions. The Human Resources and Finance departments will enhance our review process. This pre-payroll validation step will ensure that all salary adjustments and position changes align with Board authorized pay documentation prior to disbursement. Estimated Completion Date: 3/31/2026 Contact Person: Julie Wiley, Chief Financial Officer Telephone: 229-316-1878 Email: juliewiley@lowndes.k12.ga.us

View Audit 390177

Finding 1176347 (2025-001)

Material Weakness 2025

Easter Seals Metropolitan Chicago INC

IL

Management takes its responsibility to maintain effective internal control over the federal award that provides reasonable assurance that the agency is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award seriously and gave significan...

Management takes its responsibility to maintain effective internal control over the federal award that provides reasonable assurance that the agency is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the award seriously and gave significant consideration to what additional controls would be effective to ensure the proper amount of indirect costs are charged to all federal grants. To prevent another occurrence, the organization will: On the final report to HS, the agency refunded the indirect costs that were overbilled in error. Continue its current policy that no individual who prepares bill/draw should review their own calculation of the draw/billing. Another individual will review and approve costs allowable for the draw/billing and recalculate the indirect costs. Continue its current policy that the Director of Grants Management complete a detailed review of each grant reconciliation monthly, to ensure all costs charged to the grant are reasonable and necessary for the performance of the award. This review will include appropriate tests of indirect costs including ensuring the appropriate indirect cost base is used, all items required to be excluded from the indirect cost base are excluded, and the appropriate indirect cost rate is applied to the indirect cost base. Add additional step whereby the monthly grant reconciliations will be reviewed by the Controller or Chief Financial Officer.

View Audit 390168

Finding 1176346 (2025-001)

Material Weakness 2025

Communidad Del Retiro (a Project of the Municipality of San Juan)

PR

Matching / Level of Effort / Earmarking Material Weakness

Recommendation The Municipality must establish and implement a documented reconciliation process between the MIP and ORACLE accounting systems to ensure the accuracy and reliability of financial information used for federal compliance purposes. In addition, implement oversight procedures and periodi...

Recommendation The Municipality must establish and implement a documented reconciliation process between the MIP and ORACLE accounting systems to ensure the accuracy and reliability of financial information used for federal compliance purposes. In addition, implement oversight procedures and periodic monitoring to review and verify the WIOA expenditures to ensure they comply with the earmarking percentage limitations. View of responsible officials Management concurs with the findings as presented and notes that all corrective measures are already substantially implemented. The Municipality remains fully committed to maintaining strong internal controls and continuous improvement in federal grant administration. Responsible official Ana Maria Delgado WIOA Program Fiscal Agent Estimated completion date June 30, 2026

View Audit 390167

Finding 1176343 (2025-002)

Material Weakness 2025

City of Sundance Wyoming

WY

Internal Control / Segregation of Duties

The City has separated duties to the extent possible and has implemented compensating controls to monitor the account activities

View Audit 390160

Finding 1176329 (2025-003)

Material Weakness 2025

Hall County Housing Authority

NE

Subrecipient Monitoring HUD Housing Programs Material Weakness § 200.302

Finding 2025-003 See response to finding 2025-001.

View Audit 390146

Finding 1176328 (2025-002)

Material Weakness 2025

Dallas/fort Worth International Airport Board

TX

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303

Condition: The controls in place to review the final grant packet, including the grant draw-down template and the drawdown invoice detail, prior to final processing of the drawdown were not operating as designed. Planned Corrective Action: Treasury will work with PMM and DCC departments to out-line ...

Condition: The controls in place to review the final grant packet, including the grant draw-down template and the drawdown invoice detail, prior to final processing of the drawdown were not operating as designed. Planned Corrective Action: Treasury will work with PMM and DCC departments to out-line a process to ensure accurate reporting of eligible expenses when invoices are re-viewed for compliance with grant program requirements. The process will be documented and adhered to once agreed by all departments. A review process for the final drawdown submission will also be adopted to ensure costs that are identified as ineligible are appro-priately excluded from the final submission. Contact person responsible for corrective action: Sr. Grants Manager Anticipated Completion Date: 06/30/2026

View Audit 390144

Finding 1176327 (2025-001)

Material Weakness 2025

Dallas/fort Worth International Airport Board

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties

Condition: There were no controls in place for the annual report [FAA Form 5100-126] for the fiscal year ending September 30, 2025 to ensure the report contained accurate infor-mation and was sent timely to the appropriate FAA airports office. Planned Corrective Action: A review of FAA Form 5100-126...

Condition: There were no controls in place for the annual report [FAA Form 5100-126] for the fiscal year ending September 30, 2025 to ensure the report contained accurate infor-mation and was sent timely to the appropriate FAA airports office. Planned Corrective Action: A review of FAA Form 5100-126 will be conducted with ap-propriate personnel, such as the Controller or Vice President, Treasury Management prior to submitting to the FAA. Review and timely submission will be evidenced via time-stamped DocuSign or other electronic means such as an acknowledgment via email. Contact person responsible for corrective action: Sr. Grants Manager Anticipated Completion Date: 03/31/2026

View Audit 390144

Finding 1176309 (2025-005)

Material Weakness 2025

Oregon Food Bank, Inc.

OR

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency § 200.317 § 200.327

Since the prior audit period, management has taken steps to review and revise OFB’s procurement policy and procedures, in alignment with federal procurement standards. Finance will continue implementing the corrective actions and establishing the internal controls to ensure adherence to the policy, ...

Since the prior audit period, management has taken steps to review and revise OFB’s procurement policy and procedures, in alignment with federal procurement standards. Finance will continue implementing the corrective actions and establishing the internal controls to ensure adherence to the policy, retaining documentation of the procurement process to demonstrate compliance. These recent and planned improvements will enhance transparency, strengthen accountability, and reduce compliance risk, ensuring a more efficient and well-documented procurement process that supports the organization’s long-term financial integrity and operational effectiveness. The anticipated completion date remains June 30, 2026.

View Audit 390140

Finding 1176301 (2025-004)

Material Weakness 2025

Oregon Food Bank, Inc.

OR

Allowable Costs / Cost Principles Subrecipient Monitoring Reporting § 200.414

Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staf...

Since the prior audit period, management has taken steps to establish procedures and internal controls to ensure consistent application, billing, and reporting of indirect cost rates across all federal awards. Such steps include defining and documenting roles and responsibilities for applicable staff members during each phase of the grants management lifecycle, as well as implementing procedures and tools to ensure compliance with subrecipient monitoring requirements. These steps involve multiple levels of review for accurate and consistent application of indirect cost rates. Finance will continue implementing the corrective actions necessary to achieve effective controls over compliance with indirect cost rate requirements. Policy and procedures on allowable and allocable costs will be drafted to clearly document how direct and indirect costs will be billed to federal awards. Training will be provided to relevant staff members to ensure accurate implementation and ongoing compliance. These actions will improve our ability to manage indirect costs effectively and ensure compliance with federal requirements. The anticipated completion date remains June 30, 2026.

View Audit 390140

Finding 1176293 (2025-003)

Material Weakness 2025

Oregon Food Bank, Inc.

OR

Allowable Costs / Cost Principles Procurement, Suspension & Debarment Subrecipient Monitoring § 200.430

Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across dep...

Since the prior audit period, management has taken steps to develop and implement a time and effort reporting system that meets federal documentation standards, such as activating the electronic timekeeping system to track actual work performed and testing adoption of reporting procedures across departments and teams. Finance will continue implementing the corrective actions necessary to establish an effective and compliant time and effort reporting system, including providing training for employees and regularly monitoring for effective system utilization. These actions will strengthen internal controls and ensure personnel costs are accurately recorded and appropriately allocated. The anticipated completion date remains June 30, 2027.

View Audit 390140

Finding 1176285 (2025-008)

Material Weakness 2025

Cahokia Community Unit School District No. 187

IL

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

Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all exp...

Condition: The District claimed expenses on the June 30, 2025 expenditure report that were not paid untl after year end. Recommendation We recommend that steps are taken, including oversight by a second employee, to ensure that expenditure reports are reviewed for allowable expenses and that all expenses claimed are for expenses paid during the year. Managements Response: The District will take the necessary steps to only claim allowable expenses on future expenditure reports.

View Audit 390136

Corrective Action Plans

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