Corrective Action Plans

Finding 1172832 (2025-001)

Material Weakness 2025

IA

Subrecipient Monitoring Reporting Allowable Costs / Cost Principles

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA within 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreeme...

We have reviewed procedures and plan to make the necessary changes to improve reporting timeliness. Staff will update its internal policy to submit the FFATA within 30 days of execution of the CDBG annual budget, Annual Action Plan, and subaward agreements, along with any amendments to these agreements. Contact Person, Title, Phone Number Christopher Gibbons, Interim Director of Community Development, (712) 890-5358 Anticipated Date of Completion January 30, 2026

View Audit 386178

Finding 1172831 (2025-002)

Material Weakness 2025

Michigan Women's Foundation D/b/a Michigan Women Forward

MI

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Condition The internal controls over compliance were not operating effectively as a loan was disbursed to a business which operates outside of the approved county listing set by the SBA. Corrective Action Plan Corrective Action Planned: The Foundation had 26 approved counties across the lower half o...

Condition The internal controls over compliance were not operating effectively as a loan was disbursed to a business which operates outside of the approved county listing set by the SBA. Corrective Action Plan Corrective Action Planned: The Foundation had 26 approved counties across the lower half of Michigan for businesses eligible to be funded by SBA loan capital. MWF assigned SBA funding to an applicant that was initially identified as being in an eligible county. However, by the time of the loan closing, the applicant had settled on a brick and mortar store located in a county that is not on MWF’s SBA approved list. MWF has created a procedure for loans assigned to SBA as the loan capital funding source to verify before closing that the county for the business is in an SBA approved county. The Foundation has also received approval from the SBA to fund loans for business in the previously unapproved county subsequent to year end. Name(s) of Contact Person(s) Responsible for Corrective Action: Tamara Jackson, the director of lending, will verify all loans assigned to SBA loan capital prior to closing the county of the business and confirm it is an eligible county for MWF Anticipated Completion Date: The procedure described above was created, MWF’s credit policy and MWF’s closing checklist reflect this procedure which was implemented in the first quarter of FY2026.

View Audit 386159

Finding 1172830 (2025-001)

Material Weakness 2025

Rural Health Corporation of Northeastern Pennsylvania

PA

Material Weakness Significant Deficiency

RHC of NEPA has taken significant steps to improve and rectify their sliding fee deficiency over its last 3 audits. RHC of NEPA has improved from 2 consecutive material weakness findings to having substantial improvement and reduced its status to a significant deficiency. It is important to note tha...

RHC of NEPA has taken significant steps to improve and rectify their sliding fee deficiency over its last 3 audits. RHC of NEPA has improved from 2 consecutive material weakness findings to having substantial improvement and reduced its status to a significant deficiency. It is important to note that 2 of the outstanding claims identified had timely sliding fee documents completed, however they were out of compliance due to human error of calculation of the sliding fee percentage. Education and internal audits which were implemented throughout the organization which have driven the marked improvement will continue to be disseminated throughout the organization. Clearly based on the improvement that has occurred, current processes and level of attention are the correct items to rectify and become fully compliant with sliding fee requirements. These policies will be the focus of additional training with a separate session being dedicated to the updated sliding fee implementation in February of 2026.

View Audit 386157

Finding 1172828 (2025-001)

Material Weakness 2025

Belvidere Cusd No. 100

IL

Internal Control / Segregation of Duties Cash Management Reporting § 200.303

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (chief financial & operations officer) compares the meal counts in the claim to...

Condition: The same individual is responsible for preparing and submitting monthly reimbursement claims for the Child Nutrition Program without an independent review or approval prior to submission. Plan: A second person (chief financial & operations officer) compares the meal counts in the claim to the Skyward daily meal count reports, monthly participation summary, eligibility rosters (free, reduced, paid) and USDA reimbursement rates. The reviewer will then sign and date a reconciliation sheet before submission. Anticipated date of completion: December 7, 2025. Name of contact person: Cassandra Schug, Superintendent. Management response: The corrective action plan was discussed with the business services coordinator and the chief financial & operations officer. After discussion, the plan was approved.

View Audit 386144

Finding 1172805 (2025-001)

Material Weakness 2025

Catholic Charities USA

VA

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking

Criteria: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulation...

Criteria: In accordance with §200.303(a), Internal Controls, a non-federal entity must establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. In accordance with §200.213 and §180.300, Suspension and Debarment, nonfederal entities cannot enter into awards, subawards, or contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs or activities. Nonfederal entities must either check for exclusions in the System for Award Management (SAM); collect a certification from the entity, or add a clause or condition to the covered transaction with the entity prior to entering into a covered transaction with a non-federal entity. In addition, in accordance with §180.415(b), non-federal entities cannot renew or extend covered transactions (other than no-cost time extension) with any excluded person, or under which an excluded person is a principal, unless the non-federal entity obtains an exception under §180.135. Condition: During our review of procurement, suspension, and debarment compliance requirements for the selected vendor sample, we observed that while management conducted a suspension and debarment check prior to contracting with the vendor, documentary evidence of this check was not retained. Although management has maintained an ongoing working relationship with this vendor over several years and indicated that the required check was performed, they were unable to provide documentation confirming that the check was completed at the time the most recent contract was executed on April 1, 2025. Cause: The Organization’s current policies, procedures, and internal controls do not require the retention of documentation evidencing that suspension and debarment checks have been performed. Corrective Action: CCUSA Finance team will ensure that all contractors on federal grants certify that they are not suspended or debarred, and CCUSA Finance team will also verify that information on third-party and/or government websites. CCUSA will retain all documentation of the certification and verification. In addition, CCUSA will attend uniform guidance training either provided by an outside company, or by BDO. Anticipated Completion Date and Contact Details Anticipated Completion Date: March 31, 2026 Contact Person: Katie Spillane Title: Chief Financial Officer Phone Number: (703) 236 6250

View Audit 386137

Finding 1172804 (2025-001)

Material Weakness 2025

Housing Authority of Hopkinsville

KY

HUD Housing Programs Internal Control / Segregation of Duties

The non-compliance resulted primarily from operational and system limitations rather than the absence of policy or guidance. The PHA had inspection procedures and documentation expectations in place and communicated to inspection staff; however, the inspection software that we use, Tenmast, currentl...

The non-compliance resulted primarily from operational and system limitations rather than the absence of policy or guidance. The PHA had inspection procedures and documentation expectations in place and communicated to inspection staff; however, the inspection software that we use, Tenmast, currently does not adequately support printing, retention, tracking and follow-up of former HQS inspection documentation and present NSPIRE documentation, reinspection deadlines or enforcement actions. As HUD oversight expectations increased and NSPIRE requirements were implemented, reliance on manual tracking and workarounds created a risk of incomplete documentation and delayed follow-up. While inspections were conducted as required, system constraints limited the PHA's ability to consistently document failed items, record actual passing dates and initiate timely enforcement actions, including HAP abatement. To further strengthen compliance and address these risks, the PHA updated its Administrative Plan effective July 1, 2025, to more clearly define NSPIRE compliance standards, documentation requirements, reinspection timelines, enforcement procedures and abatement actions. STEPS TO IMPROVE: 1. Reinforce NSPIRE inspection procedures previously issued to inspectors, including documentation, notification, reinspection and enforcement requirements. 2. Implement refresher training for inspection staff to ensure consistent application of HUD and PHA NSPIRE policies, including life-threatening and non-life-threatening deficiencies. 3. Require retention of complete HUD-52580 inspection reports for all failed and passed inspections, including accurate documentation of deficiency correction dates. 4. 4. Strengthen review of inspection files to ensure timely follow-up, reinspection scheduling and enforcement actions by the Section 8 Director. 5. Transition inspection tracking and compliance enforcement from our current software company, Ten mast, to a new software company, Yardi, to improve system controls, documentation retention and monitoring capabilities. This implementation should occur in 2026. 6. Apply the updated Administrative Plan effective July 1, 2025, to ensure consistent enforcement of HAP abatement and contract termination requirements. Effective December 1, 2024, the PHA began utilizing NSPIRE to support a more modernized inspection system. Existing landlords were formally notified of the new inspection and enforcement requirements on September 1, 2024. The Section 8 Director will conduct periodic supervisory file reviews to verify that inspection notices, HUD- 52580 reports, reinspection documentation and enforcement actions are properly maintained and timely. The PHA is currently in the process of implementing Yardi as its primary inspection and case-management system. Once fully operational, Yardi will provide enhanced capabilities for tracking failed inspections, monitoring reinspection deadlines, documenting compliance and enforcing HAP abatement in accordance with HUD and NSPIRE requirements. Management will utilize system-generated reports and ongoing internal reviews to identify and promptly address compliance issues. The Section 8 Director acknowledges the deficiencies identified and is committed to strengthening NSPIRE enforcement through improved system controls, clarified policy, staff training and ongoing monitoring. These corrective actions are intended to ensure program integrity, protect tenant safety and maintain compliance with HUD regulations. Additional Remarks: Under our finding, the finding was reported for HOS Enforcement. Our agency changed to the NSPIRE Protocol for inspections as of 12/1/2024. Out of the 25 failed inspections sampled, 7 fell under the previous HQS protocol and the other 18, NSPIRE

View Audit 386135

Finding 1172803 (2025-001)

Material Weakness 2025

Esperanza United

MN

Procurement, Suspension & Debarment § 200.318

2025-001 Lack of Documentation for Procurement, Suspension, and Debarment Testing Federal Departments: Department of Health and Human Services, Administration for Children and Families Assistance Listing #: 93.496 Compliance and Internal Controls Significant Deficiency Category of Finding – Procurem...

2025-001 Lack of Documentation for Procurement, Suspension, and Debarment Testing Federal Departments: Department of Health and Human Services, Administration for Children and Families Assistance Listing #: 93.496 Compliance and Internal Controls Significant Deficiency Category of Finding – Procurement, Suspension and Debarment Name of contact person: Vivian Huelgo, President and CEO Corrective Action: Finance staff will be responsible for maintaining and safekeeping all procurement documentation for requisite amount of time in accessible location in an accounting folder explicitly marked on the Esperanza United secured drive for finance staff and executive team. Completion Date: January 1, 2026

View Audit 386132

Finding 1172802 (2025-004)

Material Weakness 2025

Independent School District #2909, Rock Ridge Public Schools

MN

Internal Control / Segregation of Duties Cash Management Reporting

Contact Person – Dr. Noel Schmidt, Superintendent Corrective Action Plan – The District will establish procedures to review meal reimbursement submissions. Completion Date – January 31, 2026

View Audit 386106

Finding 1172798 (2025-001)

Material Weakness 2025

MacOn County

NC

Eligibility

Name of Contact Person: Amy Mason, IMS III Corrective Action: Significant Deficiency, non-material non-compliance Eligibility Macon County has conducted policy training regarding "State Residency and County Transfers" for all Medicaid units. All caseworkers have received Medicaid policy documents, N...

Name of Contact Person: Amy Mason, IMS III Corrective Action: Significant Deficiency, non-material non-compliance Eligibility Macon County has conducted policy training regarding "State Residency and County Transfers" for all Medicaid units. All caseworkers have received Medicaid policy documents, NC Fast job aid procedures, NC Fast Learning Gateway PowerPoint presentations, steps for end dating evidence, and documentation templates. Each worker can access and review these resources at their convenience. All caseworkers are required to adhere to the guidelines and policies that have been provided to them. Medicaid Supervisors, Team Lead, and Trainer will persist in performing second-party reviews in accordance with NC State Team Lead, and Trainer will persist in performing second-party reviews in accordance with NC State guidelines. Proposed Completion Date:November 18, 2025

View Audit 386093

Finding 1172797 (2025-003)

Material Weakness 2025

Fredericksburg Independent School District

TX

Procurement, Suspension & Debarment § 200.318

Federal regulations required full and open competition in procurement, equitable distribution of micro-purchases, cost/price analysis for formal contract, and proper contract management (2 CFR 200.318-326). Micro-purchases were not equitably distributed, cost/price analyses were not conducted prior ...

Federal regulations required full and open competition in procurement, equitable distribution of micro-purchases, cost/price analysis for formal contract, and proper contract management (2 CFR 200.318-326). Micro-purchases were not equitably distributed, cost/price analyses were not conducted prior to formal contracts, and full and open competition was restricted by unreasonable requirements. Sealed bids were not properly opened or evaluated, and contract management was insufficient. Purchsing staff attended a training during the Summer of 2025 that covered cumulative spend tracking, appropriate procurement methods, and required documentation for the various procurement methods. All documentation, including analyses, quotes, and vendor selection rationale, are uploaded within the purchasing module to ensure appropriate supporting documentation is kept with the purchase. Documentation is reviewd by the purchasing staff at the time each purchase order is requested.

View Audit 386088

Finding 1172796 (2025-002)

Material Weakness 2025

Fredericksburg Independent School District

TX

Eligibility School Nutrition Programs

Federal regulations require that verification of applications be conducted by separate officials and that proper documentation and procedures are followed (7 CFR 245.6a). The same individual served as both the confirming and determining/reviewing official. The District did not maintain documentation...

Federal regulations require that verification of applications be conducted by separate officials and that proper documentation and procedures are followed (7 CFR 245.6a). The same individual served as both the confirming and determining/reviewing official. The District did not maintain documentation of confirmation reviews, and some applications were not verified correctly, resulting in incorrect eligibility determinations. The ensure adherence to the separation-of-duties requirement outlinked in 7 CFR 245.6a, the District has designated a separate confirmining official. The verification process will now follow a two-step reivew; the Child Nutrition Secretary will conduct the initial verification of selected applications, and the Child Nutrition Director will complete the independent confirmation review. This structure ensures that two distinct individuals verify the accuracy of eligibility determinations and that proper oversight is maintained. Both the Child Nutrition Secretary and the Child Nutrition Director attended formal verification training in September 2025. This training reinforces correct procedures and supports proper documentation of all confirmation reviews moving forward.

View Audit 386088

Finding 1172795 (2025-001)

Material Weakness 2025

Fredericksburg Independent School District

TX

School Nutrition Programs

Federal regulations require that eligibility determinations for free and reduced-priced meals be accurate and that benefit issurance documents are updated timely and accurately (7 CFR 245.6, 245.10). Several student applications were incorrectly approved. Additionally, benefit issuance documents wer...

Federal regulations require that eligibility determinations for free and reduced-priced meals be accurate and that benefit issurance documents are updated timely and accurately (7 CFR 245.6, 245.10). Several student applications were incorrectly approved. Additionally, benefit issuance documents were not updated in a timely manner for students newly eligible through Direct Certification. To ensure full compliance with 7 CFR 245.6 and 245.10, the Child Nutrition Director and Child Nutrition Secretary will jointly review each Direct Certification (DC) list to verify that all eligible students are accurately identified and that eligibility status in the point-of-sale (POS) system is update promptly. This dual-review process will service as a verificaiton measure to prevent omissions and ensure the benefit issuance document remains current and accurate. In August 2025, both the Child Nutrition Director and Secretary completed formal training on eligibility determination procedures. Moving forward, detailed notes- including dates and explanations of status changes- will be documented in each student's account to ensure clear tracking of all updates to support accurate recordkeeping for future reviews.

View Audit 386088

Finding 1172788 (2025-001)

Material Weakness 2025

Iowa Healthiest State Initiative

IA

Cash Management Allowable Costs / Cost Principles

Iowa Healthiest State Initiative respectfully submits the following corrective action plan for the year ended September 30, 2025. Audit period: October 1, 2024 – September 30, 2025 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently...

Iowa Healthiest State Initiative respectfully submits the following corrective action plan for the year ended September 30, 2025. Audit period: October 1, 2024 – September 30, 2025 The finding from the schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. Finding – Federal Award Programs Audits United States Department of Agriculture Finding 2025-001: Cash Management Recommendation: BerganKDV recommends Management review compliance requirements for understanding and developing procedures to ensure adherence to cash management requirements. Action Taken: Management acknowledges the finding related to the timing of federal drawdowns and updated procedures to ensure that funds are only drawn after allowable expenses have been incurred. If the United States Department of Agriculture has questions regarding this plan, please contact Jami Haberl at (515) 650-6854. Sincerely, Jami Haberl, MPH, MHA Executive Director Iowa Healthiest State Initiative

View Audit 386085

Finding 1172786 (2025-002)

Material Weakness 2025

Mt. San Antonio Community College District

CA

Subrecipient Monitoring Student Financial Aid Significant Deficiency

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were tempor...

Views of Responsible Officials and Corrective Action Plan During Fall 2024, the Financial Aid Office experienced the departure of two key senior staff members who were primarily responsible for Return to Title IV (R2T4) processing and the reversal of federal funds. As a result, new staff were temporarily assigned to manage these responsibilities during the transition period, which contributed to delays in returning funds within the required regulatory timeframe. A comprehensive review of all R2T4 calculations completed during the 2024–2025 aid year determined that records processed prior to mid-November 2024 had over awarded funds returned within the applicable 45- and 30-day regulatory timeframes. This timeframe aligns with the period when the responsible staff members announced their retirements. To resolve this matter and prevent recurrence, the District has implemented the following corrective measures. Targeted R2T4 Training: Staff responsible for Return to Title IV (R2T4) processing and disbursement reversals are in the process of completing the National Association of Student Financial Aid Administrators (NASFAA) R2T4 credential training. This certification will ensure staff possess consistent, up-to-date knowledge of federal requirements around the R2T4 process to include the timelines required to return over-awarded funds to the department. Automated Monitoring Report: A recurring monitoring report has been established to identify students with pending Returns of Title IV (R2T4) funds. The report automatically flags cases exceeding 30 days and, for students who withdrew prior to the start of the term, those exceeding 20 days. Department managers will generate and review this report on a weekly basis to ensure timely compliance with federal return requirements. In instances where pending returns are identified as being past the alert threshold, Financial Aid management will promptly coordinate with Fiscal Services to expedite the return of funds and document resolution actions. Cross-Training for Continuity of Operations: Ongoing cross-training has been implemented among Financial Aid staff to ensure sufficient coverage during vacations, extended leaves, or unexpected absences. At least two designated staff members will be fully trained and authorized to perform R2T4 calculations and return processing to prevent delays in compliance during personnel transitions. These measures strengthen accountability, monitoring, and collaboration between the Financial Aid and Fiscal Services departments to ensure full compliance with federal cash management and return regulations.

View Audit 386075

Finding 1172779 (2025-001)

Material Weakness 2025

Mt. San Antonio Community College District

CA

Student Financial Aid

Views of Responsible Officials and Corrective Action Plan The discrepancies noted during the 2024–2025 Financial Aid Audit were found to be attributable to a separate system configuration issue, distinct from the discrepant records identified in the 2023–2024 annual audit, which involved incorrect r...

Views of Responsible Officials and Corrective Action Plan The discrepancies noted during the 2024–2025 Financial Aid Audit were found to be attributable to a separate system configuration issue, distinct from the discrepant records identified in the 2023–2024 annual audit, which involved incorrect reporting of effective enrollment status dates. To resolve this matter and prevent recurrence, the District has implemented the following corrective actions: 1. Root-Cause Analysis: Conducted a comprehensive review with IT, Admissions & Records, Financial Aid, and third-party consultants to isolate and correct the specific system errors. 2. Update Systems Settings: Updating systems settings to accurately select records for reporting along with the perspective effective date and accurately report the three-quarter time enrollment level. 3. Manual Verification: Financial Aid staff responsible for Return to Title IV (R2T4) processing will manually review all student enrollment records in NSLDS (approximately 2,400 annually) to ensure accuracy. 4. Ongoing Compliance Monitoring: Established quarterly joint compliance reviews with IT, Admissions and Financial Aid leadership to verify continued accuracy of NSC/NSLDS reporting and to ensure timely detection of anomalies.

View Audit 386075

Finding 1172772 (2025-006)

Material Weakness 2025

Carlyle Community Unit School Dist. #1

IL

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties

Condition: Costs included on the 6/30/25 2025 Title I ISBE expenditure report included costs paid after 6/30/25. Recommendation: We recommend implementing an additional process to reconcile the budgeted amount to the general ledger totals and reconciling those to expenditure reports before submissio...

Condition: Costs included on the 6/30/25 2025 Title I ISBE expenditure report included costs paid after 6/30/25. Recommendation: We recommend implementing an additional process to reconcile the budgeted amount to the general ledger totals and reconciling those to expenditure reports before submission of ISBE grant reports. Management Response: The District will consider implementing an additional reconciliation process and will take necessary steps to review expenditures in the general ledger against expenditures reported to ISBE. Anticipated Date of Completion: June 30, 2026

View Audit 386055

Finding 1172771 (2025-005)

Material Weakness 2025

Carlyle Community Unit School Dist. #1

IL

Reporting Internal Control / Segregation of Duties

Condition: The final 2024 Title I grant report at 8/31/24 includes an expenditure that should have been claimed in the first report. Recommendation: We recommend implementing an additional reconciliation process in grant reporting that compares the budgeted cost of items to the amount recorded in th...

Condition: The final 2024 Title I grant report at 8/31/24 includes an expenditure that should have been claimed in the first report. Recommendation: We recommend implementing an additional reconciliation process in grant reporting that compares the budgeted cost of items to the amount recorded in the general ledger against the grant reports before submission. Management Response: The District will take the necessary steps to review expenditure reports to ensure they capture expenses within the appropriate quarterly report. Anticipated Date of Completion: June 30, 2026

View Audit 386055

Finding 1172770 (2025-004)

Material Weakness 2025

Carlyle Community Unit School Dist. #1

IL

Allowable Costs / Cost Principles Cash Management Reporting

Condition: The District submitted budgeted expenditures for reimbursement instead of actual expenditures in Title I, Grant Year 2024. Questioned costs of $5,448. Recommendation: We recommend reconciling the budgeted amount to the general ledger totals and reconciling those to expenditure reports bef...

Condition: The District submitted budgeted expenditures for reimbursement instead of actual expenditures in Title I, Grant Year 2024. Questioned costs of $5,448. Recommendation: We recommend reconciling the budgeted amount to the general ledger totals and reconciling those to expenditure reports before submitting. Management Response: The District will take necessary steps to review the budgeted cost of items and the amount recorded in the general ledger against the expenditure reports before submitting the final grant reports. Anticipated Date of Completion: June 30, 2026

View Audit 386055

Finding 1172769 (2025-001)

Material Weakness 2025

Moore College of Art & Design

PA

Student Financial Aid Subrecipient Monitoring

Management recognizes that staff had incorrectly interpreted the length of break that would necessitate a change in the refund calculation. Staff are now aware of the correct interpretation of the rule and will use it for all future calculations. Management will also identify a consultant to work wi...

Management recognizes that staff had incorrectly interpreted the length of break that would necessitate a change in the refund calculation. Staff are now aware of the correct interpretation of the rule and will use it for all future calculations. Management will also identify a consultant to work with the College’s Director of Financial Aid, Controller and Registrar to review all rules regarding return to title IV calculations so a guide can be created to lessen the chance of incorrect calculations going forward.

View Audit 386042

Finding 1172738 (2025-003)

Material Weakness 2025

Southeast Iowa Regional Housing Authority

IA

HUD Housing Programs Internal Control / Segregation of Duties Special Tests & Provisions

HQS inspections will be documented in each tenant’s file in accordance with applicable standards, along with the corresponding inspection log maintained by the PHA. Any required reinspection will also be completed and documented accordingly in the tenant’s file.

View Audit 386037

Finding 1172737 (2025-001)

Material Weakness 2025

City of Charleston, West Virginia

WV

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.1 § 200.303

Finding 2025-001 Reporting Federal Agency- U.S. Department of the Treasury Program Name - Coronavirus State and Local Fiscal Recovery Funds (SLFRF} Federal Assistance Listing Number: 21.027 2 CFR 200.303 requires that a non-federal entity must "(a) establish and maintain effective internal control o...

Finding 2025-001 Reporting Federal Agency- U.S. Department of the Treasury Program Name - Coronavirus State and Local Fiscal Recovery Funds (SLFRF} Federal Assistance Listing Number: 21.027 2 CFR 200.303 requires that a non-federal entity must "(a) establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States and the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO)." The terms and conditions of the funding require the recipient to submit quarterly Project and Expenditure Reports to the U.S. Department of the Treasury {Treasury). Information required to be included in these quarterly reports includes projects funded, expenditures, obligations, and other information. Treasury's Coronavirus State and Local Fiscal Recovery Guidance requires that "Reporting must be consistent with the definition of expenditures pursuant to 2 CFR 200.1." Responsible Officials: The City of Charleston utilizes an outside agency to compile and submit the required quarterly reports to the Department of Treasury for the State and Local Fiscal Recovery Funds. City officials provide the details of the projects funded, expenditures, obligations, and all other required information to the outside agency, who will then compile and submit the report. Upon review of prior period reports, City officials discovered that the expenditure amount for one of the projects was less than the amount provided to the outside agency for the report. The City brought this to the attention of the outside agency, then increased the project expenditures of the report in question so that the project to-date.

View Audit 386032

Finding 1172730 (2025-001)

Material Weakness 2025

Transcend Inc.

NY

Procurement, Suspension & Debarment

EIR Program – Early-Phase Grants Assistance Listing No. 84.411 Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncom...

EIR Program – Early-Phase Grants Assistance Listing No. 84.411 Recommendation: After these procurements management implemented federal grant policies which include controls related to suspension/debarment compliance. We recommend management utilize these policies going forward to avoid future noncompliance and develop controls to ensure compliance with policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: (1) Management incorporated new proactive suspension/debarment certification clause into contractor agreements for vendors providing services on federally-funded projects. (2) Management may also supplement certification clause above with additional manual sam.gov search for select larger vendor contracts. (3) Plan to incorporate regular reminders and/or trainings re: these ongoing compliance requirements to select team members working on federally-funded projects and responsible for major purchasing, ops, and/or contracting activities. Name(s) of the contact person(s) responsible for corrective action: Trevor Bynoe, Managing Director of Finance, 571-435-4816

View Audit 386012

Finding 1172727 (2025-001)

Material Weakness 2025

Towpath Trail High School

OH

Subrecipient Monitoring Reporting Significant Deficiency § 200.208 § 200.328

Finding Number: 2025-001 Planned Corrective Action: Towpath Trail High School will comply with all federal grant compliance requirements – including reporting requirements and deadlines. Anticipated Completion Date: 2/14/2026 Responsible Contact Person: Dave Massa, Treasurer

View Audit 385998

Finding 1172725 (2025-001)

Material Weakness 2025

California Baptist University

CA

Student Financial Aid Reporting

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment status change is reported timely to NSLDS as required by regulations. Action taken in response to finding: The University’s enrollment verification process includes reviewing a sample of students wh...

Recommendation: We recommend the University review its reporting procedures to ensure that enrollment status change is reported timely to NSLDS as required by regulations. Action taken in response to finding: The University’s enrollment verification process includes reviewing a sample of students whose enrollment status changes were submitted to the National Student Clearinghouse to confirm that NSLDS was updated as expected. This process identified the issue noted in the finding, and it was corrected prior to the audit. To further strengthen controls, the University has implemented additional ad hoc NSLDS reporting to confirm that submitted data is processed after NSC transmission, while continuing the established verification process. Names of the contact persons responsible for corrective action: Shawnn Palmer, Director of Academic Technology and Reporting Planned completion date for corrective action plan: As of January 9, 2026, the student record in the finding has already been corrected. The additional audit report is in draft and will be validated prior to the April reporting. If the Department of Education has questions regarding this plan, please call Joshua Morey, Senior Director of Financial Aid, at (951) 343-4236.

View Audit 385983

Finding 1172719 (2025-001)

Material Weakness 2025

Waypoint Services for Women, Children, and Families & Subsidary

IA

Cash Management Reporting Internal Control / Segregation of Duties

Recommendation: We suggest management ensure the monthly reconciliation are prepared timely and reconciled to ensure that federal awards agree without error. Additionally, we suggest management document reviews of the reconciliation reports. Response: Management will perform the monthly reconciliati...

Recommendation: We suggest management ensure the monthly reconciliation are prepared timely and reconciled to ensure that federal awards agree without error. Additionally, we suggest management document reviews of the reconciliation reports. Response: Management will perform the monthly reconciliations in a timely manner to ensure that all federal awards are in agreement with what is sent in for reimbursable reports. Additionally, management will review the reconciliation reports in a timely manner. Conclusion: Response accepted.

View Audit 385974

Corrective Action Plans

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