Corrective Action Plans

Finding 1240446 (2025-008)

Material Weakness 2025

GU

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

Finding No.: 2025-008 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families 84.403 Consolidated Grants Federal Award No.: H181A220008, H181A230008, H181A240008 S403A220002, S403A230002, S403A240002 Area: Cash Management Questioned Costs: ...

Finding No.: 2025-008 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families 84.403 Consolidated Grants Federal Award No.: H181A220008, H181A230008, H181A240008 S403A220002, S403A230002, S403A240002 Area: Cash Management Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE does not agree with the finding. The requirement that vendors for federal expenditures are paid either on the same day or within 24 hours after the funds had been received, was a requirement for the TPFA. This requirement was removed in reference to the letter from US Department of Education dated July 19, 2024, wherein the requirement for vendor payments within 24 hours was removed. Management recognizes the importance of maintaining written procedures that accurately reflect the Department's current operating environment and clearly establish responsibilities for requesting federal funds, confirming receipt of funds, releasing related payments, monitoring applicable cash management requirements, and documenting exceptions. Plan of action and completion date: GDOE will revisit existing SOP on Cash Disbursement Procedures to reflect the Department's current responsibilities following the transition from the TPFA and incorporate applicable U.S. Department of Education Special Conditions and other cash management requirements into GDOE’s written procedures. Plan to monitor and responsible officials: The Federal Programs Division and Financial Affairs Accounts Payable will be responsible for monitoring the implementation of corrective actions. The SOP will be updated during FY 2026 with monitoring and compliance procedures ongoing thereafter.

View Audit 414946

Finding 1240445 (2025-006)

Material Weakness 2025

Guam Department of Education

GU

Internal Control / Segregation of Duties Subrecipient Monitoring Period of Performance § 200.303

Finding No.: 2025-006 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) 84.181 Special Education – Grants for Infants and Families 84.403 Consolidated Grants Federal Award No.: H027A230013 H181A220008, H181A230008 S403A220002, S403A230002 Area: Period o...

Finding No.: 2025-006 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) 84.181 Special Education – Grants for Infants and Families 84.403 Consolidated Grants Federal Award No.: H027A230013 H181A220008, H181A230008 S403A220002, S403A230002 Area: Period of Performance Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE does not agree with the condition that “GDOE does not have internal control to ensure that liquidation of the obligation occurs within the allowable period of time”. GDOE has existing procedures which includes bi-weekly / weekly monitoring meeting of the program team and financial affairs. The meeting agenda would always include the expiration and liquidation dates of the grants. However, GDOE acknowledges the need to include the controls and procedures addressing liquidation deadlines in the Standard Operating Procedure (SOP) 200-034 for Accounts Payable and Cash Disbursement Procedures. Plan of action and completion date: SOP 200-034 will be updated to include the controls and procedures addressing liquidation deadlines. Federal Programs, program managers, Accounts Payable, and Financial Affairs will maintain a grant closeout schedule identifying each awards period of performance end date, liquidation deadline and outstanding obligations. Periodic review will be performed before liquidation deadlines, with aging items escalated for resolution. Closeout procedures will document required coordination among program, procurement, receiving, accounts payable, and Financial Affairs. Plan to monitor and responsible officials: Federal Programs Division and Financial Affairs/Accounts Payable, with applicable program managers. Additionally, the Internal Audit Office will monitor federal grant statuses and identify associated risks to include period of performance and report any deficiencies to respective divisions and GDOE leadership.

View Audit 414946

Finding 1240444 (2025-009)

Material Weakness 2025

Guam Department of Education

GU

Subrecipient Monitoring Period of Performance § 200.344

Finding No.: 2025-009 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Federal Award No.: H181A220008 Area: Period of Performance Questioned Costs: $32,733 Views of Auditee and Corrective Actions GDOE agrees with the condition but do...

Finding No.: 2025-009 Federal Agency: U.S. Department of Education AL Program: 84.181 Special Education – Grants for Infants and Families Federal Award No.: H181A220008 Area: Period of Performance Questioned Costs: $32,733 Views of Auditee and Corrective Actions GDOE agrees with the condition but does not agree with the cause. Management notes that the exception represented one of 36 transactions selected for testing and was identified as an isolated instance. The 2022 grant was approved for a late liquidation and was only opened for a short period of time. Nevertheless, GDOE recognizes that all federal expenditures must be liquidated within the applicable timeframe and that adequate controls should be maintained to identify and resolve outstanding obligations before the expiration of the liquidation period. Management will strengthen its grant closeout monitoring procedures to reduce the risk of outstanding obligations remaining unresolved beyond applicable federal liquidation deadlines. Plan of action and completion date: GDOE will strengthen controls over the monitoring and timely liquidation of federal award obligations. GDOE will: 1. Perform periodic reviews of outstanding obligations and unpaid expenditures in advance of applicable liquidation deadlines. 2. Coordinate among Federal Programs Division, applicable program personnel, Procurement, receiving personnel, Accounts Payable, Financial Affairs and office in-charge of the drawdown to identify and resolve outstanding transactions before the liquidation deadline. 3. Establish escalation procedures for obligations that remain outstanding as the liquidation deadline approaches so that responsible personnel and management can take timely corrective action. 4. Evaluate the need for an extension request when circumstances prevent timely liquidation and an extension is permitted under applicable federal requirements. 5. Document the resolution of outstanding obligations and retain supporting documentation demonstrating that expenditures were liquidated within the applicable timeframe. 6. Periodically review grant closeout activity to identify recurring processing delays and implement additional corrective measures when necessary. Plan to monitor and responsible officials: The Federal Programs Division, applicable program management, and Financial Affairs Accounts Payable will be responsible for monitoring the implementation of corrective actions. Corrective actions will be initiated with the FY2026 grant closeout cycle, with ongoing monitoring thereafter.

View Audit 414946

Finding 1240441 (2025-007)

Material Weakness 2025

Guam Department of Education

GU

Procurement, Suspension & Debarment § 200.318 § 200.320

Finding No.: 2025-007 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) Federal Award No.: H027A230013, H027A240013 Area: Procurement and Suspension and Debarment Questioned Costs: $538,090 Views of Auditee and Corrective Actions GDOE agrees with the fi...

Finding No.: 2025-007 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) Federal Award No.: H027A230013, H027A240013 Area: Procurement and Suspension and Debarment Questioned Costs: $538,090 Views of Auditee and Corrective Actions GDOE agrees with the finding and recommendations regarding procurement and suspension and debarment requirements. GDOE recognizes the need to strengthen procurement procedures to ensure the appropriate procurement method is selected required documentation is maintained, and applicable contract modifications are properly supported. GDOE also acknowledges that its existing procedures did not require suspension and debarment verification on a per covered transaction basis or provide sufficient documentation of the verification performed. Although the vendors selected for the transactions identified in the finding were not suspended or debarred as of September 30, 2025, GDOE recognizes that the required verification was not performed and documented prior to entering into the covered transactions. GDOE will strengthen its policies and internal controls to address these requirements. Plan of action and completion date: GDOE recognizes that procurement activities should be planned and reviewed sufficiently in advance to ensure that the appropriate procurement method is selected required approvals and documentation are completed, and services are not initiated before the procurement is properly executed. The GDOE Supply Management Office will: 1. Review and update procurement procedures to address applicable federal procurement requirements, including procurement methods, documentation, and contract modifications. 2. Establish procedures to evaluate similar or related services when determining the appropriate procurement method, regardless of funding source. 3. Establish a formal process requiring suspension and debarment verification before entering into each covered transaction. 4. Require documentation of the verification, including the vendor, date, method and results, to be retained in the procurement file. 5. Provide training to applicable procurement and program personnel on these requirements. 6. Periodically review procurement policies and files to monitor compliance with federal requirements. Corrective actions will be completed by December 2026. Plan to monitor and responsible officials: GDOE Office of Supply Management will be responsible for implementing and monitoring the corrective actions. Periodic procurement file reviews will verify compliance with procurement requirements and completion and documentation of suspension and debarment verifications.

View Audit 414946

Finding 1240439 (2025-005)

Material Weakness 2025

Guam Department of Education

GU

Matching / Level of Effort / Earmarking

Finding No.: 2025-005 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) Area: Matching, Level of Effort, Earmarking Questioned Costs: $578,698 Views of Auditee and Corrective Actions GDOE agrees with the finding and recognizes the need to strengthen its...

Finding No.: 2025-005 Federal Agency: U.S. Department of Education AL Program: 84.027 Special Education Cluster (IDEA) Area: Matching, Level of Effort, Earmarking Questioned Costs: $578,698 Views of Auditee and Corrective Actions GDOE agrees with the finding and recognizes the need to strengthen its monitoring of Maintenance of State Financial Support (MFS) and the classification of IDEA administrative and State-level activities. GDOE will strengthen its MFS monitoring process by conducting quarterly reviews of State financial support for special education and related services throughout the fiscal year. The Special Education Division (SPED), SPED CMO, and GDOE Business Office will coordinate with applicable State agencies to obtain expenditure information, compare current-year support with the prior-year level, and identify potential shortfalls before year-end. The MFS calculation and supporting documentation will be reviewed and maintained annually to ensure timely identification and correction of potential deficiencies. GDOE will also strengthen its review and classification of IDEA expenditures to ensure State Administration, other State-level activities, and program costs are appropriately identified. The Special Education Division, SPED CMO, and Business Office will conduct quarterly reviews of administrative expenditures, including training, conferences, technical assistance, and travel, to ensure costs are properly classified and monitored against the applicable administrative cost limitation. Staff responsible for IDEA expenditures will receive guidance on the appropriate classification and documentation of these costs. Transactions identified as potentially misclassified will be reviewed and corrected, as appropriate. Plan of action and completion date: Initial corrective actions, including implementation of the monitoring procedures and staff guidance, will be completed within 90–120 days. Thereafter, MFS and IDEA administrative cost monitoring will be conducted and documented quarterly throughout each fiscal year. Plan to monitor and responsible officials: The Special Education Division (SPED), SPED CMO, and GDOE Business Office will be responsible for implementing and monitoring the corrective actions described above.

View Audit 414946

Finding 1240438 (2025-004)

Material Weakness 2025

Guam Department of Education

GU

Reporting Subrecipient Monitoring School Nutrition Programs

Finding No.: 2025-004 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Reporting Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE acknowledges the finding. The corrective action addresses the variances in th...

Finding No.: 2025-004 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Reporting Questioned Costs: $0 Views of Auditee and Corrective Actions GDOE acknowledges the finding. The corrective action addresses the variances in the first and third quarter FY 2025 FNS-777 reports, related accounting records and reconciliations, and the subawards that were not reported as required by the Federal Funding Accountability and Transparency Act. Plan of action and completion date: The GDOE Business Office will reconcile applicable MUNIS expenditures against CNP claim and reimbursement records, draw requests, ASAP draw confirmations, bank receipts, MUNIS revenue entries, accounts receivable and other applicable receivable records, and documented adjustments. Differences among amounts requested, drawn, received, and recorded in MUNIS will be documented and resolved. Each quarterly FNS-777 will be supported by a line-by-line workpaper prepared by the GDOE Business Office and provided to GDOE FNSMD CNP, identifying the authoritative source for prior-period amounts, current period outlays, valid unliquidated obligations, federal funds authorized, adjustments, and the unobligated balance. An ASAP draw alone will not determine whether an amount is reported as an outlay or an unliquidated obligation. An earned reimbursement that has not yet been drawn may be recorded as a receivable for reconciliation purposes but will not automatically be reported as an unliquidated obligation. Separately, the GDOE Business Office will establish its controls under 2 CFR part 170 to identify and timely report each CNP subaward of $30,000 or more in the applicable federal system (FSRS). In coordination with GDOE FNSMD CNP, the GDOE Business Office review the FY 2025 subawards, submit any permitted late or corrective reports, and retain evidence of submission or final disposition. Plan to monitor and responsible officials: GDOE FNSMD CNP will conduct monthly follow-ups with the GDOE Business Office to monitor progress and ensure that activities remain on track for completion within the established timelines. Reconciliations will be performed quarterly to ensure that all financial transactions for the quarter are accurately recorded, supported, and ready for required reporting. The GDOE FNSMD CNP Administrator, Anthony S. Monforte and CNP Program Coordinator, Franklin J. Cruz will oversee the reconciliation and reporting controls. The Controller or designated GDOE Business Office official will be responsible for ASAP draws, MUNIS records, cash receipts, receivables, draw confirmations, federal subaward reporting, and supervisory review. The corrective actions will be implemented by October 1, 2026, and first applied to the FY 2027 first quarter reporting cycle. For each quarterly filing, GDOE FNSMD CNP will retain the completed reconciliation, preparer and reviewer sign-offs, and evidence of supervisory review, including supporting documentation provided by the GDOE Business Office, as applicable. The responsible officials will also document an annual review of the control process.

View Audit 414946

Finding 1240437 (2025-003)

Material Weakness 2025

Guam Department of Education

GU

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding No.: 2025-003 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Procurement and Suspension and Debarment Questioned Costs: $744,643 Views of Auditee and Corrective Actions GDOE acknowledges the finding. The finding co...

Finding No.: 2025-003 Federal Agency: U.S. Department of Agriculture AL Program: 10.555 Child Nutrition Cluster Federal Award No.: 7GU300GUB Area: Procurement and Suspension and Debarment Questioned Costs: $744,643 Views of Auditee and Corrective Actions GDOE acknowledges the finding. The finding concerns the lack of documented exclusion verification before GDOE entered into or renewed covered transactions although the verifications were conducted. GDOE also notes the auditors’ determination that, as of September 30, 2025, none of the entities were suspended or debarred. Plan of action and completion date: GDOE Food and Nutrition Services Management Division (FNSMD), Child Nutrition Programs (CNP) will implement an internal control procedure consistent with 2 CFR 200.214, 2 CFR Part 180, and 2 CFR Part 417. Before entering into or renewing a covered transaction, we will document one of the verification methods permitted under 2 CFR 180.300. The standard procedure will be to check the entity and its applicable principals in SAM.gov Exclusions and retain the dated search results. If GDOE utilizes another permitted method, such as obtaining a certification or including an agreement clause, the agreement file will identify the method used and retain the supporting documentation. We will maintain a register identifying the entity, program, transaction type, agreement and renewal dates, verification date, method and result. Verification will be completed and independently reviewed before execution or renewal. When applicable, GDOE FNSMD CNP will also check the CACFP National Disqualified List as a separate program-integrity control under 7 CFR part 226; the NDL check will not substitute for the federal suspension and-debarment verification. The procedure and agreement register will be implemented by October 1, 2026. The GDOE FNSMD CNP Administrator will review the register at least annually and document corrective follow-up for any missing or untimely verification. Plan to monitor and responsible officials: The GDOE FNSMD CNP Administrator, Anthony S. Monforte and Program Coordinator, Franklin J. Cruz will be responsible for corrective action implementation and ongoing monitoring.

View Audit 414946

Finding 1240436 (2025-002)

Material Weakness 2025

Asante Health System

OR

Allowable Costs / Cost Principles Special Tests & Provisions § 200.303 § 200.305 § 200.403 § 200.514

Asante Health System Corrective Action Plan for FY25 Single Audit Fiscal year end: 09/30/2025 Audit period: 10/01/2024-09/30/2025 Finding 2025-002 Federal Program: FEMA funding is federal financial aid from the Federal Emergency Management Agency’s Disaster Relief Fund (DRF), providing money for com...

Asante Health System Corrective Action Plan for FY25 Single Audit Fiscal year end: 09/30/2025 Audit period: 10/01/2024-09/30/2025 Finding 2025-002 Federal Program: FEMA funding is federal financial aid from the Federal Emergency Management Agency’s Disaster Relief Fund (DRF), providing money for communities to recover from disasters, rebuilding infrastructure, mitigating future risks, and covering essential needs. Duplicate expenditures submitted for FEMA reimbursement resulting in unallowable costs being claimed under the program. Statement of Condition: In six of 40 sample items selected for testwork over activities allowed or unallowed and allowable costs/cost principles related to the program, $469,054 in expenditures out of a total of $1,368,522 expenditures (or 34%) were submitted for reimbursement to the Federal Emergency Management Agency (FEMA) but were related to the same invoices and therefore were duplicate expenditures. Upon further investigation, management identified that a total of $2,636,044 expenditures out of a total of $14,470,349 expenditures related to the program were duplicate expenditures. Further, management’s review that was performed over the underlying program details was not designed at a sufficient level of precision that enabled the identification of the duplication errors. Further, in management’s review for the completed project certification for one of two projects for the program these duplication errors were not identified. Actions Taken and Status: To address this deficiency, the organization has implemented the following corrective actions: 1. Recovery and Adjustment of Duplicate Claims o A complete review of all FEMA reimbursement submissions was performed to identify duplicate expenditures. o Management will work with FEMA to adjust previous reimbursement requests and return any funds received for duplicate expenditures, as required. 2. Enhanced Reconciliation Controls o A detailed reimbursement tracking log has been implemented to identify each invoice: payment date, reimbursement request number, and reimbursement status. o All expenditures submitted for reimbursement will be reconciled against prior submissions before inclusion in a reimbursement request. 3. Training o Finance personnel responsible for federal grant administration and reimbursement submissions have received training on Uniform Guidance requirements, allowable costs, and reimbursement documentation controls. Corrective action training has been completed as of 9/30/2026. Responsible Contact Person: Name: Heather Rowenhorst Title: Chief Financial Officer Department: Administration Phone/Email: 541-789-5098 / Heather.Rowenhorst@asante.org

View Audit 414944

Finding 1240434 (2025-001)

Material Weakness 2025

The Experimental Station: 6100 Blackstone

IL

Cash Management § 200.305 § 200.407

We modified the current policy to include that future advance drawdowns be limited to immediate cash needs. Any alternative payment arrangement must comply with applicable federal requirements and award terms and receive written awarding-agency approval where required. Board approval alone does not ...

We modified the current policy to include that future advance drawdowns be limited to immediate cash needs. Any alternative payment arrangement must comply with applicable federal requirements and award terms and receive written awarding-agency approval where required. Board approval alone does not authorize an exception to those requirements. Each drawdown will be supported before it is requested to be in line with the updated policy, tying the request to expenditures paid or due shortly. Each drawdown will be approved in advance by the Executive Director. The Executive Director will be responsible for obtaining written approval from the awarding agency before any request outside of the normal reimbursement cycle. The approval will be kept on file. In this instance, Experimental Station placed drawn federal funds in a segregated interestbearing account. Earned interest on the account, in the amount of $54,333.50, was remitted to the federal government on August 1 3, 2026, prior to the 2025 audit completion, and all funds on the federal awards were expended on the awarded program prior to the award end dates on July 31 and September 14, 2026.

View Audit 414940

Finding 1240424 (2025-001)

Material Weakness 2025

Allen County

OH

Subrecipient Monitoring Allowable Costs / Cost Principles Period of Performance § 200.302 § 200.329

The SLFRF Project and Expenditure Report periods have been filed and no further reporting is required from these specific federal grant rewards. Future grants requiring reporting will be thoroughly reviewed for reporting specifications. Although no funds were misspent or inappropriately used, the Co...

The SLFRF Project and Expenditure Report periods have been filed and no further reporting is required from these specific federal grant rewards. Future grants requiring reporting will be thoroughly reviewed for reporting specifications. Although no funds were misspent or inappropriately used, the County understands the need for correct timing when reporting the grant funds held, encumbered, and expended. The County has since created a grant acceptance template, required to be used by all departments, which will be used to identify who is responsible for future grant reporting requirements. The County will work to ensure all affected departments are aware of specific reporting requirements and that those requirements are followed.

View Audit 414927

Finding 1240422 (2025-004)

Material Weakness 2025

THE BOSTONIAN FOUNDATION, INC.

MA

Internal Control / Segregation of Duties

Finding 2025-004: The Corporation has not been filing its annual Data Collection Form with the Federal Audit Clearinghouse since the system changed to requiring a Unique Entity Identifier (UEI). Name of Contact Person: Judith Lima, Chief Financial Officer Corrective Actions Plan: The Corporation is ...

Finding 2025-004: The Corporation has not been filing its annual Data Collection Form with the Federal Audit Clearinghouse since the system changed to requiring a Unique Entity Identifier (UEI). Name of Contact Person: Judith Lima, Chief Financial Officer Corrective Actions Plan: The Corporation is applying for its UEI. When it is received, the Corporation will file the Data Collection Forms for all years since 2021 with the Federal Audit Clearinghouse.

View Audit 414926

Finding 1240421 (2025-003)

Material Weakness 2025

THE BOSTONIAN FOUNDATION, INC.

MA

HUD Housing Programs Reporting

Finding 2025-003: The Corporation did not file its required 2024 and 2025 audit reporting packages by the required due dates. Name of Contact Person: Judith Lima, Chief Financial Officer Corrective Actions Plan: Management agrees with the finding. As stated, the transition to a new audit firm and th...

Finding 2025-003: The Corporation did not file its required 2024 and 2025 audit reporting packages by the required due dates. Name of Contact Person: Judith Lima, Chief Financial Officer Corrective Actions Plan: Management agrees with the finding. As stated, the transition to a new audit firm and the sale of the Corporation impacted management’s ability to file its 2025 financial statements timely. Management evaluated the circumstances noted above and plans to have the 2026 books and records closed and ready for the audit firm to complete the 2026 by the HUD due date.

View Audit 414926

Finding 1240420 (2025-001)

Material Weakness 2025

City of Stuart

FL

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.214

Finding 2025-001 Federal Program: Coronavirus State and Local Fiscal Recovery Funds COVID-19 (ALN 21.027) Contact Person Responsible for Corrective Action: Financial Services Director Corrective Action Planned: The City will revise procurement procedures to require retention of documentation support...

Finding 2025-001 Federal Program: Coronavirus State and Local Fiscal Recovery Funds COVID-19 (ALN 21.027) Contact Person Responsible for Corrective Action: Financial Services Director Corrective Action Planned: The City will revise procurement procedures to require retention of documentation supporting SAM.gov suspension and debarment verification for all covered transactions. A standardized procurement checklist will be implemented and reviewed by supervisory personnel prior to contract execution. Procurement staff will receive training on federal procurement requirements and documentation retention procedures. Anticipated Completion Date: September 30, 2027 Management Response: The City concurs with the finding and will implement the corrective actions described above.

View Audit 414923

Finding 1240418 (2025-004)

Material Weakness 2025

Wilmington Housing Authority

NC

HUD Housing Programs

Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Fi...

Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Housing Voucher Cluster to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.

View Audit 414907

Finding 1240416 (2025-003)

Material Weakness 2025

Wilmington Housing Authority

NC

Allowable Costs / Cost Principles Eligibility HUD Housing Programs § 200.516

Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe,...

Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.

View Audit 414907

Finding 1240415 (2025-002)

Material Weakness 2025

Wilmington Housing Authority

NC

Cash Management HUD Housing Programs Subrecipient Monitoring § 200.305 § 200.516

Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe,...

Authority's Response and Planned Corrective Action Plan: The Authority accepts the recommendation of the auditor. The Authority will increase oversight in the Public Housing Capital Fund Program to ensure that established internal control policies are being followed on a timely basis. Kinteh Darboe, Chief of Financial Operations & Management, is responsible for ensuring the deficiencies have been rectified by March 31, 2026.

View Audit 414907

Finding 1240414 (2025-003)

Material Weakness 2025

Pacific Housing Oahu Corporation Kapolei Residence

HI

HUD Housing Programs

We have instructed Hawaii Affordable Properties to withdraw $300,000 from the replacement reserve account and purchase two $150,000 6 month certificate of deposits, which are to be rolled over every six months until the funds are needed.

View Audit 414904

Finding 1240413 (2025-002)

Material Weakness 2025

Pacific Housing Oahu Corporation Kapolei Residence

HI

HUD Housing Programs

This issue occurred during Bob Tanaka, lnc.’s period of managing the project. Bob Tanaka, Inc. was replaced by Hawaii Affordable Properties, Inc. on January 1, 2025, and instructions have been given to the new property management company to maintain the tenant waiting list in accordance with 24 CFR ...

This issue occurred during Bob Tanaka, lnc.’s period of managing the project. Bob Tanaka, Inc. was replaced by Hawaii Affordable Properties, Inc. on January 1, 2025, and instructions have been given to the new property management company to maintain the tenant waiting list in accordance with 24 CFR Section 891.410(a). The wait list will be reviewed at quarterly site inspections.

View Audit 414904

Finding 1240412 (2025-001)

Material Weakness 2025

Pacific Housing Oahu Corporation Kapolei Residence

HI

HUD Housing Programs

The noncompleted replacement reserve contributions were due to the Project not receiving PRAC subsidies during 2025. This left the Project with not enough revenue to fund normal operations, and a replacement reserve withdraw was allowed by HUD to cover operating cash shortfalls. The issue with recei...

The noncompleted replacement reserve contributions were due to the Project not receiving PRAC subsidies during 2025. This left the Project with not enough revenue to fund normal operations, and a replacement reserve withdraw was allowed by HUD to cover operating cash shortfalls. The issue with receiving the PRAC subsidies was resolved by the property managers in April 2026 and the Project is now paying back the replacement reserve withdraw for the shortfall and catch up with replacement reserve contributions. Continuing monitoring of the Project’s financial statements and replacement reserve contributions will be performed on a monthly basis.

View Audit 414904

Finding 1240411 (2025-005)

Material Weakness 2025

CONFERENCE OF MINORITY TRANSPORTATION OFFICIALS

VA

Eligibility Reporting § 200.512 § 200.520

COMTO was not informed of anything outstanding related to the federal single audit until September 30, 2026, which is that this document must accompany the filing. It was greed between COMTO and Auditor that the review would be complete by 9/15/2026. COMTO has not received any correspondence from Au...

COMTO was not informed of anything outstanding related to the federal single audit until September 30, 2026, which is that this document must accompany the filing. It was greed between COMTO and Auditor that the review would be complete by 9/15/2026. COMTO has not received any correspondence from Auditor until late on 9/30/2026, informing us of an update which we agreed and that it took the COMTO staff less than 15 minutes to complete on our financials. Auditor was provided with signed document on 9/30/2026. Meanwhile, any updates forwarded to Auditor between 9/15/26 and 9/30/26 could not have been used towards changing Auditor’s opinion and, therefore, could not have caused a delay in this report, previously approved by our Board in July 2026. Auditor was provided with initial Management Response dated 10/1/2026 then responded by adding 2025-005 Federal Awards Submission as an additional penalty. On October 1, 2026, Auditor received signed Management Response and then would not accept it without further documentation. This will not happen next year as a joint effort between COMTO and any prospective auditor.

View Audit 414899

Finding 1240410 (2025-004)

Material Weakness 2025

CONFERENCE OF MINORITY TRANSPORTATION OFFICIALS

VA

Procurement, Suspension & Debarment § 200.214 § 200.317 § 200.318 § 200.327

The discrepancy noted by the auditors relates to vendor procurement for the USDOT Thriving Communities Program. COMTO has not procured any vendors which were not previously authorized by the USDOT for participation in this program. COMTO has established procurement procedures for purchased services ...

The discrepancy noted by the auditors relates to vendor procurement for the USDOT Thriving Communities Program. COMTO has not procured any vendors which were not previously authorized by the USDOT for participation in this program. COMTO has established procurement procedures for purchased services in excess of $15,000, in which Auditor participated and was subsequently provided with the procurement operations and results, complete with Auditor’s own competitors. Vendor/Partner Contracts: The specific vendors and subcontractors were evaluated, vetted, and formally approved by the U.S. Department of Transportation (USDOT) during the competitive application and award phase of the Thriving Communities program. The Regulation: Under 2 CFR 200 (specifically regarding procurement by non-federal entities), if a federal awarding agency explicitly approves specific subrecipients or contractors as part of the federal award, it generally waives the requirement for subsequent competitive procurement for those designated roles. See USDOT-approved budget line items showing the named vendors (see USDOT Approved Budget” attached). All records are on file with the USDOT. Subrecipient/Contractor Monitoring: COMTO provided clear, signed agreements with these preapproved vendors that pass down all federal compliance requirements (e.g., Title VI, civil rights compliance, reporting metrics) required by the Thriving Communities program. Auditor has not clarified exactly which federal or local regulation they believe requires a rebid of USDOT-approved project partners (see executed contracts attached). COMTO does not run a competitive bidding or procurement process to select a subrecipient. They were selected as collaborative partners/sub-awardees and their status as subrecipients was explicitly authorized by the USDOT when they approved our grant award. All records are on file with the USDOT.

View Audit 414899

Finding 1240409 (2025-003)

Material Weakness 2025

CONFERENCE OF MINORITY TRANSPORTATION OFFICIALS

VA

Reporting § 200.510

With the exception of prepaid travel expenses, there were no differences between COMTO’s general ledger, grant agreements, or reimbursement requests. The discrepancy noted by the auditors relates to Material Weaknesses 2025-001 and 2025-002 with appropriate actions taken.

View Audit 414899

Finding 1240408 (2025-001)

Material Weakness 2025

The Mount St. James Housing Development Fund Company, Inc.

NY

Subrecipient Monitoring Reporting § 200.512

Finding #2025-001 Current Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: The Mount St. James Apartments agrees wit...

Finding #2025-001 Current Year Reporting Package and Data Collection Not Filed Timely: Recommendation: We recommend that management implement procedures to ensure that reporting packages and data collection forms are filed timely in the future. Action taken: The Mount St. James Apartments agrees with the auditor’s recommendations and will implement procedures to ensure timely filing in the future. For questions regarding this corrective action plan, please contact John Lutz, Vice President of Financial Strategy, at (315) 424-1821.

View Audit 414898

Finding 1240407 (2025-004)

Material Weakness 2025

NONTRADITIONAL EMPLOYMENT FOR WOMEN

NY

Allowable Costs / Cost Principles

Management agrees with the finding and will implement procedures to periodically reconcile allocation methodologies to actual expenditures and program activity.

View Audit 414897

Finding 1240406 (2025-003)

Material Weakness 2025

NONTRADITIONAL EMPLOYMENT FOR WOMEN

NY

Reporting § 200.510

Management agrees with the finding and will implement procedures to ensure the SEFA is prepared and reviewed internally prior to the commencement of future audits.

View Audit 414897

Corrective Action Plans

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