Corrective Action Plans

Finding 1156486 (2024-001)

Material Weakness 2024

The George E. Brown United States-Mexico Foundation for Science

DC

The Foundation pursued legal action because the way in which the IMPI withdrew from our agreement was found to be illegal. The Mexican court agreed with our position, and by the end of 2021, the Foundation had received a favorable resolution on the 2020 lawsuit. This led to initial meetings with IMP...

The Foundation pursued legal action because the way in which the IMPI withdrew from our agreement was found to be illegal. The Mexican court agreed with our position, and by the end of 2021, the Foundation had received a favorable resolution on the 2020 lawsuit. This led to initial meetings with IMPI's renewed top management, but unfortunately, we were unable to reset the funds. In June 2022, the Foundation formally requested that the IMPI reset the funds in order to continue functioning under the agreement, as a legally developed addendum had been created to supplement the original agreement. There were hectic changes in top management at the Mexican Ministry of Economy and the IMPI in 2022, resulting in unproductive efforts from previous negotiations. Then, in July 2023, the Foundation submitted a second lawsuit to enforce the one won in 2021, which was accepted by the court. On 13 September 2024, the Foundation was notified by the court of a favorable resolution regarding this second lawsuit. The IMPI still has one final opportunity to contest this resolution, although the probability of changing the outcome is minimal. Consequently, the Foundation's executives and its Board of Governors resumed communication with the IMPI's legal team to accelerate the resetting of the funds and the collaboration agreement. This was unsuccessful. Although the final ruling generally favored the Foundation, FUMEC filed a direct appeal for constitutional protection, claiming that the returns generated should not be limited to December 2022 but should instead be accumulated and calculated until IMPI actually made the payment; that is, until the month of 2024 in which IMPI complied with the ruling handed down on July 1, 2024. The court revoked the contested trial of July 1, 2024, and issued a new ruling, reiterating the considerations regarding the period and the amounts that IMPI is obliged to pay to FUMEC, in order to fully restore FUMEC's infringed subjective right. In compliance with this ruling, on September 8, 2025, the court issued a new ruling considering that the Collaboration Agreement was still in force and that IMPI had not demonstrated that it had fulfilled its obligations. Consequently, and reiterating its previous ruling, the court granted IMPI a period of no more than four months to comply with the Collaboration Agreement. IMPI was therefore required to reimburse the principal funds of $5 million USD to FUMEC’s endowment and pay the returns due for the period from August 2020 to May 2024. Proposed completion date – 2Q2026. Contact person – Eugenio Marin, Executive Director

View Audit 368844

Finding 1156484 (2024-001)

Material Weakness 2024

Northwest Youth Services

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this pol...

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this policy and procedure to ensure rental rates fall within federal grant compliance requirements at the time of each lease signing or renewal. Documentation of rent reasonableness certification will be performed by NWYS housing staff, reviewed by NWYS housing service leadership, and maintained in the client’s permanent file, as defined in the NWYS Rent Reasonableness Policy. Name(s) of Responsible Party:  NWYS Housing leadership staff – Luis Reyna, Addison Ausley, Daniel Pry Anticipated Completion Date:  9/5/25

View Audit 368841 Questioned Costs: $1

Finding 1156482 (2024-007)

Material Weakness 2024

Mission Edge San Diego

CA

Allowable Costs / Cost Principles

Condition Found During allowable cost testing, we noted that there was a lack of internal control over allowable costs. We noted items that did not include proper support, were outside the contract period, or were for the incorrect amount. Corrective Action Plan Continue to verify for every federal ...

Condition Found During allowable cost testing, we noted that there was a lack of internal control over allowable costs. We noted items that did not include proper support, were outside the contract period, or were for the incorrect amount. Corrective Action Plan Continue to verify for every federal charge: allowability, allocability, reasonableness, consistent treatment, and compliance with period of performance. Require source documentation supporting the nature, amount, and purpose. Responsible Person for Corrective Action Plan The Controller for Mission Edge San Diego and Accounting personnel. Implementation of Corrective Action Plan Policy adoption within 30 days of report. Management’s Statement of Concurrence Mission Edge concurs with the findings and has initiated the corrective actions described herein. Management is committed to timely implementation, continuous monitoring, and transparent communication with the pass-through entity, federal agencies, and auditors as required.

View Audit 368823

Finding 1156481 (2024-006)

Material Weakness 2024

Mission Edge San Diego

CA

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Condition Found During allowable cost testing, it was noted that one of the contracts with the vendors included a rate that exceeded the rate cap without prior approval. Upon inquiry no prior approval was obtained. Corrective Action Plan Before execution, route all vendor and subrecipient agreements...

Condition Found During allowable cost testing, it was noted that one of the contracts with the vendors included a rate that exceeded the rate cap without prior approval. Upon inquiry no prior approval was obtained. Corrective Action Plan Before execution, route all vendor and subrecipient agreements funded by federal awards to Controller/Accounting for verification of allowability, rate caps, prior approvals, and special terms. Additional review during the A/P process ensures compliance. Responsible Person for Corrective Action Plan The Controller for Mission Edge San Diego and Accounting personnel. Implementation of Corrective Action Plan Policy adoption within 30 days of report.

View Audit 368823 Questioned Costs: $1

Finding 1156480 (2024-005)

Material Weakness 2024

Mission Edge San Diego

CA

Questioned Costs Procurement, Suspension & Debarment

During procurement testing, it was noted that Mission Edge did not follow 2 CFR 200 required methods of procurement or its internal procurement policy for the purchase of goods or services using federal funds. Mission Edge did not obtain quotes or bids for certain expenditures as required by its pro...

During procurement testing, it was noted that Mission Edge did not follow 2 CFR 200 required methods of procurement or its internal procurement policy for the purchase of goods or services using federal funds. Mission Edge did not obtain quotes or bids for certain expenditures as required by its procurement policy. In addition, Mission Edge did not verify that vendors were not suspended, debarred, or otherwise excluded from participation in the program. Corrective Action Plan Review and confirm that each Project has Adopted a Uniform Procurement Policy. This policy will address: 1. Micro-purchases, small purchases, sealed bids, competitive proposals, noncompetitive proposals thresholds and methods. 2. Cost/price analysis for procurements above the Simplified Acquisition Threshold. 3. Ensure consistent applicability to fiscally sponsored projects. 4. Mandatory Debarment/Suspension Checks utilizing SAM.gov for all covered transactions and attached required verification to covered transactions. Responsible Person for Corrective Action Plan The Controller of Mission Edge San Diego (policy owner); Project Directors as applicable. Implementation of Corrective Action Plan Policy adoption within 30 days of report.

View Audit 368823 Questioned Costs: $1

Finding 1156479 (2024-001)

Material Weakness 2024

Grupo Nexos, Inc.

PR

Responsible Entity: Grupo Nexos, Inc. – Finance Department and Program Management Condition Reported: Late submission of Federal Financial Reports (SF-425), Quarterly Financial Status Reports, and subaward reports under the Federal Funding Accountability and Transparency Act (FFATA) for the followin...

Responsible Entity: Grupo Nexos, Inc. – Finance Department and Program Management Condition Reported: Late submission of Federal Financial Reports (SF-425), Quarterly Financial Status Reports, and subaward reports under the Federal Funding Accountability and Transparency Act (FFATA) for the following programs:  93.297 Adolescent Pregnancy Prevention Program (PROSa)  93.310 Trans – NIH Research Support Program Identified Cause:  Lack of internal monitoring procedures to ensure compliance with submission deadlines.  Resignation of the authorized staff responsible for submitting FFATA reports and delays in obtaining access to the SAM platform. Corrective Actions to be Implemented: Designation of Responsible Parties: o Develop a formal process to monitor the preparation, review, and submission of all financial and subaward reports, designating a responsible person for each activity and establishing backups to ensure operational continuity.  Compliance Calendar: o Implement an electronic calendar with the due dates of FFRs, quarterly reports, and FFATA submissions, with automated alerts 15 and 7 days prior to the deadlines.  Internal Review and Approval: o Require review and approval by the Chief Financial Officer prior to the submission of any report. Staff Training: o Provide annual training for finance and program staff on reporting requirements under 2 CFR 200 and FFATA.  Documentation and Filing: o Maintain evidence of submission and acknowledgments of receipt of all reports in a centralized electronic file accessible for future audits. Estimated Implementation Date: All actions will be fully implemented no later than December 31, 2025.

View Audit 368820

Finding 1156477 (2024-002)

Material Weakness 2024

Lifewire

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.430

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underly...

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underlying the attestations were erroneous. In addition, LifeWire was not able to secure an attestation from a former employee before they departed the organization. In 2025, LifeWire is revising their attestation procedure such that contract-supported staff members will attest to the nature of their work instead of amounts of time to contracts. This will simplify the administrative burden of attestations and reduce opportunities for errors while still meeting our audit and contract funders’ requirements. We anticipate this revised method will be rolled out by the end of Q3-2025. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: Procedure rollout will be completed by the end of Q3-2025. Anticipated full compliance with the requirement will be in evidence through the end of 2025 and beyond.

View Audit 368819

Finding 1156474 (2024-001)

Material Weakness 2024

Lifewire

WA

Subrecipient Monitoring HUD Housing Programs Reporting § 200.303

Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental...

Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental payment request made with public funds. LifeWire’s AP approval process requires review and approval by members of the Director team before payments can be issued. In 2025, all rental payments made with CoC funds now have documented evidence of internal approval and review. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: The new process was rolled out in November 2024.

View Audit 368819

Finding 1156471 (2024-001)

Material Weakness 2024

Emergency Food Network of Tacoma and Pierce County

WA

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

U.S. Department of Agriculture Food Distribution Cluster - The Emergency Food Assistance Program - Assistance Listing No. 10.565, 10.568, 10.569 Recommendation: We recommend that EFN incorporate a system of internal controls that clearly documents the time and effort that each individual employee sp...

U.S. Department of Agriculture Food Distribution Cluster - The Emergency Food Assistance Program - Assistance Listing No. 10.565, 10.568, 10.569 Recommendation: We recommend that EFN incorporate a system of internal controls that clearly documents the time and effort that each individual employee spends on each grant per month. This can be done by tracking and recording the actual hours each employee, regardless of position, spends working on each grant, on their time sheet or with a specific grant code, that specifies how many hours per day were spent on each federal and nonfederal activity. Alternatively, EFN can implement an after-the-fact review procedure to ensure the proper allocation of payroll expenditures to Federal and non-Federal awards, in accordance with 2 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Emergency Food Network (EFN) engaged a new audit firm for the 2024 audit. Before this year the EFN audit was administered by Johnson, Stone Pagano for 9 years. No deficiencies were previously reported or identified during those audits regarding time estimates for employees used for allocations including most of those specifically identified funding sources. In response to the 2024 audit finding by Clifton Larson Allen (CLA) in July of 2025, when the audit was conducted, EFN implemented an immediate individual employee time study that was approved by CLA to meet the recommendation. This time study methodology will be implemented twice per year on an ongoing basis with records retained and available for future audit verification. EFN has received written response from CLA that implementing this method meets all the requested requirements to be in compliance and mitigate future findings on this issue. Name of the contact person responsible for corrective action: Michelle Douglas, CEO Planned completion date for corrective action plan: August 2025 If anyone has questions regarding this plan, please call Michelle Douglas, CEO, at 253-208- 2962.

View Audit 368815 Questioned Costs: $1

Finding 1156467 (2024-002)

Material Weakness 2024

City of River Falls

WI

Reporting Significant Deficiency

Finding 2024-002: Internal Control Environment Condition The Federal Financial Report was submitted by the original preparer without review before submission. Corrective Action Plan Corrective Action Planned: The Finance Director will review and approve submittals of the annual grant applications an...

Finding 2024-002: Internal Control Environment Condition The Federal Financial Report was submitted by the original preparer without review before submission. Corrective Action Plan Corrective Action Planned: The Finance Director will review and approve submittals of the annual grant applications and reports, including from third-parties in the event of any pass-through grants the City facilitates. Name(s) of Contact Person(s) Responsible for Corrective Action: Josh Solinger Anticipated Completion Date: Immediate and ongoing

View Audit 368802

Finding 1156466 (2024-001)

Material Weakness 2024

Council Towers Housing Development Fund Corporation

NY

Questioned Costs Allowable Costs / Cost Principles Subrecipient Monitoring

We are planning to close the current policy. We are opening a separate policy for Council Towers II, Council Towers III and Council Towers IV that we covered by that policy.

View Audit 368800 Questioned Costs: $1

Finding 1156465 (2024-001)

Material Weakness 2024

Wadhwani Institute for Artificial Intelligence Foundation

CA

Subrecipient Monitoring Reporting

Corrective Action Plan Finding Reference: Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting (FFATA) Date of finding: Financial Audit 2024 Responsible Parties: Amy Frizzi and David Mangene 1. Management's Response Management accepts the finding and agrees with the a...

Corrective Action Plan Finding Reference: Finding No. 2024-001 – Federal Funding Accountability and Transparency Act Reporting (FFATA) Date of finding: Financial Audit 2024 Responsible Parties: Amy Frizzi and David Mangene 1. Management's Response Management accepts the finding and agrees with the auditor's recommendations and further acknowledges that a subaward contract under which FFATA reporting was required was not submitted within the required 30 days after the subaward was executed. 2. Corrective Action FFATA Reporting: Wadhwani Institute for Artificial Intelligence Foundation (WIAI) is working to gain access to the SAM.gov reporting capabilities for the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) to ensure proper reporting for any and all required FFATA reporting is met for new federal subawards. Process Enhancement: WIAI will ensure comprehensive reporting processes for federal grants are in place prior to engaging as a prime or subrecipient, including tracking reporting and other significant deadlines. 2024 Finding Resolution: The specific grant referenced in this finding was terminated in January 2025. The awarding agency (USAID) has since been functionally dismantled by the Trump administration, with 83% of programs eliminated as of March 2025 and remaining functions transferred to the State Department. Given the agency's operational dissolution and the grant's termination, late FFATA reporting for the 2024 subaward is not feasible through normal channels. Management will monitor for any guidance from the State Department regarding reporting obligations for grants from the former USAID structure. 3. Timeline FSRS Access: Target completion by December 2025 (pending SAM.gov registration resolution) Process Documentation: Within 60 days of FSRS access being obtained Full Implementation: Upon receipt of next federal subaward requiring FFATA reporting Ongoing Monitoring: Monthly grant reviews and comprehensive year-end validation Prepared by: Ann Marie Ilibasic, Grants & Compliance Consultant Reviewed by: David Martin, Audit Committee Chair Next Review Date: Fiscal Year End 2025

View Audit 368798

Finding 1156463 (2024-001)

Material Weakness 2024

King County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contra...

The Facilities Management Division will develop and implement a training program for key personnel that procure goods and services. The training curriculum will include assessment of purchasing and procurement activities related to federal financial assistance, procedures involving routing of contract requests through established King County Procurement processes, and timelines to submit similar requests through central procurement with sufficient time to allow central procurement to perform all the necessary legal and compliance checks necessary for the associated transactions. After initial training, all existing key personnel will receive repeat training every 2 years; all new staff will receive training as part of onboarding procedures.

View Audit 368796

Finding 1156462 (2024-001)

Material Weakness 2024

Housing Authority of the City of Sheboygan

WI

Internal Control / Segregation of Duties

Corrective Action Planned: Due to the Authority’s size, it is cost-prohibitive and impractical to achieve the ideal level of segregation of duties. The Authority has implemented as many controls and segregation of duties as practically possible for an organization of this size.

View Audit 368787

Finding 1156461 (2024-001)

Material Weakness 2024

Homeless No More, Inc. 122-Hd085-Wdd-Np

CA

HUD Housing Programs Reporting

Department of Housing and Urban Development Homeless No More, Inc., HUD Project No. 122-HD085-WDD-NP, respectfully submits the following Corrective Action Plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Suchan & Associates, An Accountancy Corporatio...

Department of Housing and Urban Development Homeless No More, Inc., HUD Project No. 122-HD085-WDD-NP, respectfully submits the following Corrective Action Plan for the year ended December 31, 2024. Name and address of independent public accounting firm: Suchan & Associates, An Accountancy Corporation, 8588 Utica Ave. Suite 100, Rancho Cucamonga, California 91730. Audit Period: January 1, 2024 through December 31, 2024 The finding from the 2024 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. Section A of the Schedule, Summary of Audit Results does not include findings and is not addressed. FINDINGS-FINANCIAL STATEMENTS AUDIT None FINDINGS AND QUESTIONED COSTS-MAJOR FEDERAL AWARD PROGRAMS AUDIT DEPARTMENT OF HOUSING AND URBAN DEVELOPMENT FINDING NO. 2024-001 Section 811 (Capital Advance Loan), AL No. 14.181 Recommendation: The Project should fund the replacement reserves shortage as soon as possible and make the required monthly deposits in accordance with the regulatory agreement. Action Taken: As of the current date the delinquent deposits have not been brought up to date due to ongoing cash flow issues. The Project is negotiating for a rent increase and is in the process of renewing its contract with HUD. Once both the rent increase and contract renewal are approved the replacement reserve account will be funded as soon as the HUD assistance payments are received. If you have any questions regarding the plan, please call Dan O’Brien, Treasurer (213) 251-3410. Sincerely, Dan O’Brien Treasurer

View Audit 368785

Finding 1156460 (2024-001)

Material Weakness 2024

Power Forward Communities, Inc.

MD

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.180

Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will streng...

Management’s Corrective Action Plan PFC Management Corrective Action Plan: Debarment Strict adherence to procurement regulations and compliance with required suspension and debarment checks are already represented within PFC’s compliance policies and procedures. Power Forward Communities will strengthen its internal controls around debarment checks for vendors in both its procurement and contracting processes to address the finding as follows: Procurement • PFC will use a process checklist for its procurements, similar to the checklist PFC developed for its coalition members. • The checklist will include an additional step for a debarment search on SAM.gov and require internal confirmation and documentation that this debarment check is valid. • This process checklist will be reviewed and signed off when complete by PFC management for each procurement. • PFC will include completed checklists to accompany each procurement memo. Contracting • PFC will continue including debarment language in each of its vendor contracts to ensure adherence to 2 CFR Section 180.300. • For vendors with contracts above $25,000, PFC will implement quality control by running a debarment search twice annually, once in June and once in December every year. This documentation will be saved to the vendor file.

View Audit 368780

Finding 1156459 (2024-002)

Material Weakness 2024

Southwestern Christian College

TX

Questioned Costs Reporting Significant Deficiency § 200.328 § 200.329

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the...

Emergency Relief Fund (HEERF) Programs (significant deficiency) Condition (per audit): Non-compliance noted regarding untimely filing of quarterly and annual report. SwCC’s Explanation: The HEERF department and reporting systems were closed, and Grants personnel were unable to retrieve a copy of the required reports from the ESF Data Collection System by the suggested deadline of May 19, 2025. Corrective Actions (overseen by the President): 1. Grant Reporting Calendar o A compliance calendar with all DOE reporting deadlines was created in August 2025. o Internal deadlines are set two weeks before federal due dates. o Responsible Official: Director of Grants 2. Dual Review & Submission Tracking o All grant quarterly and annual reports must be reviewed and signed off by the Director of Grants, President, and Comptroller before submission. o Submission confirmations will be saved in the respective grants folder of the electronic filing system. o Responsible Officials: President, Director of Grants & Comptroller 3. Centralized Filing & Audit Readiness o Grant reports (quarterly, annual, and related correspondence) will be stored in the centralized electronic filing system for continuity and audit review. o Responsible Officials: Director of Grants & Business Office 4. Quarterly Compliance Checks o The President and Director of Grants will conduct quarterly compliance reviews to confirm all required reports are submitted timely. o Responsible Officials: President & Director of Grants 5. Time and Effort Reporting in Populi o Effective August 2025, time and effort reporting for all Title IV-funded student workers and grant-funded employees will be completed in Populi, capturing descriptions of duties and percentage of time worked, aligned with payroll and funding sources. o Responsible Officials: Director of Grants & Comptroller/Business Office Completion Date: Reporting calendar implemented August 2025; all future reports will be submitted timely under this protocol. Southwestern Christian College is committed to full compliance with federal regulations and the highest standards of financial accountability. The corrective actions outlined above address both Title IV and HEERF audit findings with immediate steps, ongoing monitoring, and strengthened internal controls. With the implementation of new reconciliation processes, expanded staffing in the Business Office, centralized electronic filing, enhanced verification and reporting protocols, and a structured compliance calendar, SwCC has established sustainable safeguards to prevent recurrence of deficiencies.

View Audit 368771 Questioned Costs: $1

Finding 1156458 (2024-001)

Material Weakness 2024

Southwestern Christian College

TX

Questioned Costs Student Financial Aid

Finding 2024-001: U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiency): Condition (per audit): Non-compliance with Title IV requirements, including missing reconciliations, inaccurate/untimely NSLDS reporting, incomplete Work-Study files, missing refu...

Finding 2024-001: U.S. Department of Education (USDE), Title IV Student Financial Aid Programs (significant deficiency): Condition (per audit): Non-compliance with Title IV requirements, including missing reconciliations, inaccurate/untimely NSLDS reporting, incomplete Work-Study files, missing refund documentation, incomplete FAFSA verification records, and unavailable FISAP reconciliation documentation. Questioned Costs: $29,087 Corrective Actions (overseen by the President): 1. Monthly Title IV Reconciliations o Beginning August 2025, monthly reconciliations between the Business Office and Financial Aid Office will be conducted and logged in the new centralized electronic filing system in Populi for audit readiness and continuity during staff transitions. o To further strengthen the process, two additional staff members, a new Accounts Payable Manager and Comptroller, with extensive audit and business office management and grants management/reconciliation experience, and has been added to the Business Office. o Reconciliation logs will be retained in the centralized electronic filing system in Populi. o Responsible Official: Comptroller/ Business Office Staff 2. Electronic Filing System o To address missing FISAP, refund, and Work-Study documentation, SwCC implemented an organized electronic filing system in Populi by funding stream, year, and document type. o Includes FISAP, Work-Study timesheets, NSLDS reports, and refund documentation. o Responsible Official: Financial Aid Director and Business Office. 3. Enrollment Reporting to NSLDS o To address untimely/incorrect reporting, weekly enrollment status reports will be submitted through Populi and verified with the Registrar. o SwCC is finalizing its agreement with the National Student Clearinghouse to further improve accuracy. o Responsible Official: Registrar. 4. Work-Study Documentation o To address missing student files, all Work-Study records (award letters, timesheets, disbursement records) will be scanned and retained in each student’s electronic file. o Responsible Official: Financial Aid Director. 5. Refund Documentation o To address missing refund testing documentation, all refund calculations will be cross-verified by the Business Office and Financial Aid Office, and approved by the President before posting. o Records will be stored in the filing system. o Responsible Official: Comptroller/ Business Office and Financial Aid Office 6. FAFSA Verification o To address incomplete verification documentation, SwCC uses a standardized verification checklist. The Populi system does not allow disbursement of student files selected for verification. A manual override is required, and these overrides will continue to be managed within the Office of Financial Aid for disbursement. o Responsible Official: Financial Aid Director. 7. FISAP Retention o To address unavailable FISAP records, annual FISAP submissions will be stored in the electronic filing system for future testing and audit review. o Responsible Official: Comptroller/ Business Office and Financial Aid Office Completion Date: Initial corrective actions completed by August 31, 2025. Ongoing monitoring monthly/quarterly as required.

View Audit 368771 Questioned Costs: $1

Finding 1156454 (2024-002)

Material Weakness 2024

Connections to Success

MO

Cash Management Reporting Significant Deficiency § 200.303

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Recommendation: The Organization should update and strengthen their policies to match UG and DOL guidelines, and create...

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Significant Deficiency in Internal Control Over Compliance – Cash Management and Reporting Recommendation: The Organization should update and strengthen their policies to match UG and DOL guidelines, and create an internal control for drawdown request and report approval and review. The Organization should ensure these policies are followed for all drawdowns, reports and that documentation related to these policies are maintained. Views of Responsible Officials: Management agrees with the finding and recommendation. To address this, the Organization will update its Cash Management Policy to implement a documented, two-level review and approval process for all drawdown requests and reports, requiring both preparer and approver sign-off and develop a standard checklist to ensure each drawdown is supported by allowable, documented expenditures prior to submission. The Grants Manager will conduct quarterly internal reviews to ensure this process is being followed. Contact information for this finding: If the U.S. Department of Labor has questions regarding this schedule, please call Brandi Janke at (816) 520-4404. Completion Date: September 2025

View Audit 368768

Finding 1156453 (2024-001)

Material Weakness 2024

Connections to Success

MO

Procurement, Suspension & Debarment Material Weakness § 200.214

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Material Weakness in Internal Control Over Compliance – Suspension and Debarment ● Other Matter Recommendation: The Organization should strengthen controls and adherence over their policy and the UG and DOL gui...

Federal Agency: U.S. Department of Labor Assistance Listing No. 17.270 Type of Finding: ● Material Weakness in Internal Control Over Compliance – Suspension and Debarment ● Other Matter Recommendation: The Organization should strengthen controls and adherence over their policy and the UG and DOL guidelines and ensure a control is in place for verifying vendors are not suspended, debarred, or otherwise excluded per UG guidelines prior to use of the vendor. The Organization should ensure these policies are followed for all applicable vendors and that documentation related to these controls are maintained and documented. Views of Responsible Officials: Management agrees with the audit finding. Effective immediately, the Organization will update the Procurement and Vendor Management Policy to explicitly require suspension and debarment checks for all applicable vendors in accordance with 2 CFR 200.214 and 2 CFR Part 180. The Organization is implementing a standardized vendor verification form and will require procurement staff to document SAM.gov checks prior to contracting with any vendor. In addition, all staff involved in procurement will be trained on the updated requirements and documentation procedures. The CEO will perform quarterly monitoring to ensure compliance with federal procurement standards and internal policy. These corrective actions will strengthen internal controls and ensure compliance with federal regulations. Contact information for this finding: If the U.S. Department of Labor has questions regarding this schedule, please call Brandi Janke at (816) 520-4404. Completion Date: September 2025

View Audit 368768

Finding 1156452 (2024-001)

Material Weakness 2024

Unleashing Potential

MO

Allowable Costs / Cost Principles Subrecipient Monitoring Material Weakness § 200.430

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hour...

Personnel Responsible for the Corrective Action Plan: Darlene Sowell, President/CEO Anticipated Completion Date: December 31, 2025 Corrective Action Plan: Unleashing Potential will modify its internal procedures to track actual hours devoted to the program and perform a monthly review of actual hours incurred compared to the estimated amounts by individuals assigned to federal grant programs prior to requesting reimbursement from the funding course. The review will be performed by an individual other than the preparer of the reimbursement request, with knowledge of the federal grant program and will be formally documented.

View Audit 368766

Finding 1156451 (2024-001)

Material Weakness 2024

Illinois Network of Charter Schools

IL

Procurement, Suspension & Debarment Subrecipient Monitoring Reporting

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member ...

Joyanna Smith, Chief Program & Operations Officer (CPOO), will develop and implement written internal procedures for FFATA compliance. These will include a step- by-step checklist for reporting subawards in SAM.gov. Allison Jack, CSP Grant Project Director, will designate a responsible staff member - the CSP Grant Manager - to oversee FFATA reporting and maintain a comprehensive log of all qualifying subawards. The CSP Grant Manager will provide training to finance and grants management staff on FFATA reporting requirements and timelines. Joyanna Smith, CPOO, will conduct monthly reviews of subaward activity to ensure all required reporting is completed by the end of the month following the obligation date. FFATA reporting will be incorporated into INCS’s quarterly internal compliance monitoring process to sustain ongoing compliance.

View Audit 368752

Finding 1156450 (2024-002)

Material Weakness 2024

Lincoln Senior Housing, INC

CT

Questioned Costs HUD Housing Programs Cash Management

Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request ...

Recommendation – The Project should ensure the surplus cash calculation is made in a manner that allows for a timely deposit of any required deposit to the residual receipts account. If there are cash flow issues preventing the deposit from taking place, the Project needs to contact HUD and request a waiver if allowed. Views of Responsible Officials and Planned Corrective Actions – Management will calculate an estimated surplus cash calculation amount and deposit them into the residual receipts account within the required time frame. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – Once the funds are received.

View Audit 368750 Questioned Costs: $1

Finding 1156449 (2024-001)

Material Weakness 2024

Lincoln Senior Housing, INC

CT

Questioned Costs HUD Housing Programs Significant Deficiency

Recommendation – The reserve account was underfunded as of 12/31/24. We recommend that management discuss this issue with HUD and request approval retroactively to fund the reserve account at a lower amount until the funds due to the Project are paid in full by HUD. Views of Responsible Officials an...

Recommendation – The reserve account was underfunded as of 12/31/24. We recommend that management discuss this issue with HUD and request approval retroactively to fund the reserve account at a lower amount until the funds due to the Project are paid in full by HUD. Views of Responsible Officials and Planned Corrective Actions – Management will reach out to HUD and request approval retroactively to fund the reserve account at a lower amount. Once the approval has been granted and the remainder of the funds have been received, management will pay the reserve account in full. Name and Title of Responsible Official – Sabine Cox, Comptroller Anticipated Completion Date – unknown

View Audit 368750 Questioned Costs: $1

Finding 1156446 (2024-001)

Material Weakness 2024

Housing Opportunities, Inc.

NC

Reporting

HOUSING OPPORTUNITIES, INC. P.O. Box 10248 Greensboro, North Carolina 27404 CORRECTIVE ACTION PLAN September 24, 2025 Single Audit Clearinghouse 1201 East 10th Street Jeffersonville, Indiana 47132 Housing Opportunities, Inc. (the "Organization"), respectfully submits the following Corrective Action ...

HOUSING OPPORTUNITIES, INC. P.O. Box 10248 Greensboro, North Carolina 27404 CORRECTIVE ACTION PLAN September 24, 2025 Single Audit Clearinghouse 1201 East 10th Street Jeffersonville, Indiana 47132 Housing Opportunities, Inc. (the "Organization"), respectfully submits the following Corrective Action Plan for the year ended December 31, 2024. Bernard Robinson & Company, L.L.P. 1501 Highwoods Blvd., Suite 300 Greensboro, North Carolina 27410 Audit period: Year ended December 31, 2024 The finding from the December 31, 2024 Schedule of Findings and Questioned Costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Findings and Questioned Costs: Finding 2024-001: Section III - Findings and questioned costs relating to the major programs which are required to be reported as defined by the Uniform Guidance [2 CFR 200.516(a)] Recommendation: The Organization should continuously monitor cash balances to ensure that funds are always covered by FDIC insurance limits, collateral agreements are obtained, or funds are invested in government securities. Management's Response: Management reviews the financial stability of the banking institutions which hold the Organizations' funds on an ongoing basis and will continue to do so. Management does not feel at this time that the funds are truly at risk based on current market conditions and the reviews they continually do on the financial stability of the banking institutions holding these funds. Management will transfer the funds at any point they believe the funds are truly at risk. If you have questions regarding this plan, please call Eliza Haynes at 336-544-2300. Sincerely yours, Eliza Haynes Partnership Property Management

View Audit 368722

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