Corrective Action Plans

Finding 565391 (2024-002)

Significant Deficiency 2024

DC

Procurement, Suspension & Debarment

U.S. and Department of Treasury 2024-001 and 2024-002 Coronavirus State and Local Fiscal Recovery – Assistance Listing No. 21.027 Recommendation: We recommend CSC update procurement policies to ensure they align with federal requirements. This includes clear guidelines on competitive bidding and ...

U.S. and Department of Treasury 2024-001 and 2024-002 Coronavirus State and Local Fiscal Recovery – Assistance Listing No. 21.027 Recommendation: We recommend CSC update procurement policies to ensure they align with federal requirements. This includes clear guidelines on competitive bidding and documenting the rationale for vendor selection. Also, the policy should ensure consistent application of its policies and procedures so that an adequate verification process is in place to review potential contractors to determine they are suspended or debarred before entering into a covered transaction. Explanation of disagreement with audit findings: See below action taken in response to findings. Action taken in response to findings: CSC disagrees with the classification of 2004-001 as a significant finding rather than receiving management recommendations on improving our procedures from the auditors because there was only one item where CSC could not retrieve the proof that at least three bids were sought prior to the signing of the contract. CSC does not consider the three other items that the auditors flagged as clear procurements because two of the items were disbursements of funds on behalf of clients for vocational education that those clients had already signed up for and were preapproved by the funder in question. CSC had no option but to disburse funds for those educational activities. The rational for the disbursements can be found in the grant agreement. Similarly in the case of the third item, CSC had to disburse funds based on the criteria provided by the grantor and the grantor approved the transaction prior to its signing. These are grey areas that deserve no more than formal management recommendations. Regardless, based on the results of the audit, CSC has updated its procurement policy for grant related purchases to align with federal requirements by increasing the spending threshold that requires obtaining bids from at least three vendors or service providers from $5,000 to $10,000. CSC’s updated procurement policy as of April 2025 states in part that price or rate quotations must be obtained from an adequate number of qualified sources for the procurement of services, supplies, or other property that cost more than $10,000 but no more than $250,000. Generally, a minimum of three bids should be obtained and documented. Procurements over $250,000 require the use of Competitive Proposals. Additionally, under the caption of “Debarment and Suspension, CSC’s policy states that a contract or subgrant must not be made to parties listed on the government-wide exclusions in the System for Award Management (SAM). CSC must confirm that all new contractors, consultants, and subrecipients are not listed in SAM Exclusions. The revised policy is attached. Name of the contact person responsible for corrective action: Tayo Coker Planned completion date for corrective action plan: June 3, 2024. If the U.S. and Department of Treasury has questions regarding this plan, please call: Tayo Coker 202-603-3259.

View Audit 359270

Finding 565389 (2024-001)

Significant Deficiency 2024

Collaborative Solutions for Communities

DC

Procurement, Suspension & Debarment

U.S. and Department of Treasury 2024-001 and 2024-002 Coronavirus State and Local Fiscal Recovery – Assistance Listing No. 21.027 Recommendation: We recommend CSC update procurement policies to ensure they align with federal requirements. This includes clear guidelines on competitive bidding and ...

U.S. and Department of Treasury 2024-001 and 2024-002 Coronavirus State and Local Fiscal Recovery – Assistance Listing No. 21.027 Recommendation: We recommend CSC update procurement policies to ensure they align with federal requirements. This includes clear guidelines on competitive bidding and documenting the rationale for vendor selection. Also, the policy should ensure consistent application of its policies and procedures so that an adequate verification process is in place to review potential contractors to determine they are suspended or debarred before entering into a covered transaction. Explanation of disagreement with audit findings: See below action taken in response to findings. Action taken in response to findings: CSC disagrees with the classification of 2004-001 as a significant finding rather than receiving management recommendations on improving our procedures from the auditors because there was only one item where CSC could not retrieve the proof that at least three bids were sought prior to the signing of the contract. CSC does not consider the three other items that the auditors flagged as clear procurements because two of the items were disbursements of funds on behalf of clients for vocational education that those clients had already signed up for and were preapproved by the funder in question. CSC had no option but to disburse funds for those educational activities. The rational for the disbursements can be found in the grant agreement. Similarly in the case of the third item, CSC had to disburse funds based on the criteria provided by the grantor and the grantor approved the transaction prior to its signing. These are grey areas that deserve no more than formal management recommendations. Regardless, based on the results of the audit, CSC has updated its procurement policy for grant related purchases to align with federal requirements by increasing the spending threshold that requires obtaining bids from at least three vendors or service providers from $5,000 to $10,000. CSC’s updated procurement policy as of April 2025 states in part that price or rate quotations must be obtained from an adequate number of qualified sources for the procurement of services, supplies, or other property that cost more than $10,000 but no more than $250,000. Generally, a minimum of three bids should be obtained and documented. Procurements over $250,000 require the use of Competitive Proposals. Additionally, under the caption of “Debarment and Suspension, CSC’s policy states that a contract or subgrant must not be made to parties listed on the government-wide exclusions in the System for Award Management (SAM). CSC must confirm that all new contractors, consultants, and subrecipients are not listed in SAM Exclusions. The revised policy is attached. Name of the contact person responsible for corrective action: Tayo Coker Planned completion date for corrective action plan: June 3, 2024. If the U.S. and Department of Treasury has questions regarding this plan, please call: Tayo Coker 202-603-3259.

View Audit 359270

Finding 565386 (2024-001)

Significant Deficiency 2024

Medical Device Innovation Consortium

VA

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

Finding The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed, however the evidence of the search of sam....

Finding The Organization established policies and procedures over suspension and debarment, including checking all vendors against the government suspension and debarment listing. The policies and procedures for suspension and debarment were being followed, however the evidence of the search of sam.gov was not retained. Corrective Actions Taken or Planned MDIC acknowledges the importance of retaining documentation to demonstrate compliance with federal procurement requirements, specifically those related to suspension and debarment under 2 CFR 200.214. While SAM.gov checks were consistently conducted prior to vendor engagement, the absence of retained search documentation was due to internal oversight and not a failure in performing the checks. As a small organization without a centralized procurement department, we had not previously formalized the documentation requirement in our procedures. Our contracts are also reviewed by the Legal team and each contract has a language around debarment and suspension of firms. To address this finding, MDIC has taken the following corrective actions: Policy and Procedure Update As of June 2025, our procurement procedures have been updated to require documentation (PDF printout or screenshot) of each SAM.gov search to be retained in the corresponding vendor file. Procurement Checklist Enhancement Our internal procurement checklist now includes a mandatory step confirming that the SAM.gov verification has been completed and documented. Training Implementation All staff involved in procurement and contracting processes received targeted training in June 2025 to reinforce the importance of documenting compliance steps, particularly suspension and debarment verifications. Ongoing Monitoring A periodic internal review process has been introduced whereby a sample of vendor files will be reviewed quarterly to ensure documentation of SAM.gov checks is properly maintained. Contact Person Responsible Tariq Bahich Senior Director Finance Anticipated Completion Date Corrective actions were completed as of June 4, 2025, and are now fully integrated into MDIC's procurement process.

View Audit 359249

Finding 565385 (2024-001)

Material Weakness 2024

Dearborn Housing Commission

MI

HUD Housing Programs Allowable Costs / Cost Principles Cash Management

Corrective Action Plan: The Accounts Receivable of $1.6 million for the Capital Fund Program was drawn down from eLOCCS on November 27th, 2024. Additionally, the new Executive Director has gained access to eLOCCS.

View Audit 359245

Finding 565381 (2024-002)

Significant Deficiency 2024

Municiapilty of Isabela

PR

Reporting

Corrective Action: The Municipality will review the procedures to implement and correct the finding.

View Audit 359242

Finding 565380 (2024-001)

Material Weakness 2024

Regional Water

IA

Reporting Internal Control / Segregation of Duties

We will double check these in the future to avoid missing any payable transactions

View Audit 359239

Finding 565378 (2024-002)

Significant Deficiency 2024

George J. and Hilda Meyer Foundation, Inc.

MO

Internal Control / Segregation of Duties Significant Deficiency Matching / Level of Effort / Earmarking

U.S. Department of Agriculture 2024-002 Communities Facilities Loans & Grants – Assistance Listing No. 10.766 Recommendation: We recommend the Foundation design controls to ensure that the calculation is completed in accordance with the loan agreement and funded in full prior to the end of each fisc...

U.S. Department of Agriculture 2024-002 Communities Facilities Loans & Grants – Assistance Listing No. 10.766 Recommendation: We recommend the Foundation design controls to ensure that the calculation is completed in accordance with the loan agreement and funded in full prior to the end of each fiscal year. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The USDA has waived this requirement in past years. The community obtained a waiver for the current period. Name(s) of the contact person(s) responsible for corrective action: Tiffany Goetz Planned completion date for corrective action plan: June 2, 2025

View Audit 359225

Finding 565377 (2024-001)

Material Weakness 2024

George J. and Hilda Meyer Foundation, Inc.

MO

Internal Control / Segregation of Duties

Material Misstatements Detected By the Audit Recommendation: Management should evaluate monthly and year-end closing procedures to ensure appropriate recognition of accruals, revenue, and expenses. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Actio...

Material Misstatements Detected By the Audit Recommendation: Management should evaluate monthly and year-end closing procedures to ensure appropriate recognition of accruals, revenue, and expenses. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A comprehensive review of monthly and year-end closing procedures will be completed by FMI Kansas to ensure appropriate recognition of accruals, revenue, and expenses. Name(s) of the contact person(s) responsible for corrective action: Tiffany Goetz Planned completion date for corrective action plan: Ongoing

View Audit 359225

Finding 565375 (2024-001)

None 2024

Umass Memorial Health Care, Inc.

MA

Procurement, Suspension & Debarment Subrecipient Monitoring Allowable Costs / Cost Principles § 200.318 § 200.324

2024-001 Procurement Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Congressionally Directed Spending Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Dire...

2024-001 Procurement Cluster: Not applicable Grantor: Department of Health and Human Services (DHHS) Award Name: Congressionally Directed Spending Award Number: 6 CE1HS52894‐01‐04, 6 CE1HS52345‐01‐05 Award Year: FY2024 Assistance Listing Number: 93.493 Assistance Listing Title: Congressional Directives Pass-through Entity: Not applicable In accordance with 2 CFR 200.318 the System must maintain procurement records of sufficient detail that include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. For two of two of the auditors’ selections sufficient documentation was not retained from the time of procurement during fiscal year 2023 to demonstrate sole source justification or the competitive bidding process for these samples. For one mammography technology asset, documentation of sole source vendor justification was not documented and retained by the System following Policy HA-50-42, Capital Equipment Requests. For the second selection, while competitive bids were obtained, management did not adequately retain documentation to support the vendor ultimately selected for the selected hardware component and the other bids obtained. Management has reviewed the Capital Equipment Request policy and the related capital request process and will reinforce the need to adhere to existing policies and the importance of retaining appropriate documentation during fiscal year 2025. Primary responsibility of implementing the Corrective Action Plan for this finding rests with Brian Huggins, Senior Vice President of Finance, Corporate Controller, (508) 334-0252.

View Audit 359222

Finding 565372 (2024-002)

Significant Deficiency 2024

Summit County Colorado

CO

Eligibility Subrecipient Monitoring

Finding 2024-002 Federal Agency Name: U.S. Department of Health and Human Services Passed-through Colorado Department of Health Care Policy and Financing Program Name: Medical Assistance Program CFDA # 93.778 Initial Fiscal Year Finding Occurred: 2024 Finding Summary: Our auditors, Eide Bailly, test...

Finding 2024-002 Federal Agency Name: U.S. Department of Health and Human Services Passed-through Colorado Department of Health Care Policy and Financing Program Name: Medical Assistance Program CFDA # 93.778 Initial Fiscal Year Finding Occurred: 2024 Finding Summary: Our auditors, Eide Bailly, tested eligibility determination and controls over this process for sixty case files. They noted the following in our testing: • One instance of non-compliance in which the County did not complete the eligibility determination and approve/deny the case within 45 days and no notice of action was sent to the client within the required timeframe. • Two instances of non-compliance in which the County did not ensure removal from the Medicaid program due to cases being ineligible because of over income or being undocumented. Responsible Individuals: Joanne Sprouse, Human Services Director Corrective Action Plan: Summit County Human Services has successfully retrained all case managers on application processing protocols, utilizing state-approved training modules administered through the Staff Development Department. Summit County Human Services strictly follows state-mandated guidelines for processing Medical Assistance applications and ensures that all cases are approved or denied within the 45-day timeframe established by state regulations. To enhance the accuracy of eligibility determinations for all household members, case managers will also complete the "Case Wrap-Up Training" through CoLearn, an online training platform developed by the State's Staff Development Department. Completion of this training ensures that eligibility determinations are accurate, and that appropriate client correspondence is issued. In instances where eligibility errors are identified in Medicaid applications submitted via Connect for Health Colorado, a third-party agency operating independently from the county, Summit County will notify the agency within 24 hours. While such errors fall outside the county's control, the county is committed to promptly communicating corrections to ensure accurate application outcomes. Anticipated Completion Date: Ongoing

View Audit 359213

Finding 565370 (2024-001)

Significant Deficiency 2024

Seattle Children's Hospital

WA

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.320

FINDING 2024-001: The entity did not have a control in place to review cost transfers to federal awards to ensure the entity followed the appropriate procurement policies for these costs. Without adequate controls over cost transfers, there is an increased risk of non-compliance with procurement ...

FINDING 2024-001: The entity did not have a control in place to review cost transfers to federal awards to ensure the entity followed the appropriate procurement policies for these costs. Without adequate controls over cost transfers, there is an increased risk of non-compliance with procurement policies. Corrective Action Plan: Management will design and implement a control to review cost transfers from non-federal awards to federal awards to ensure we follow our procurement policies. This will be achieved by adding a new step to the non-payroll cost transfer form that requires the requestor to include a copy of the Procurement authorization form if the procurement policies apply. The Procurement authorization form documents the process, rationale, and justification for procurements. If the purchase being transferred did not go through the appropriate procurement procedures at the time of purchase, then the transfer from the non-federal award to the federal award will not be allowed. Management will also provide additional training around procurement and our related policies and ensure staff involved in this area are aware of the new step embedded in the non-payroll cost transfer form. Remediation Date: July 2025

View Audit 359210 Questioned Costs: $1

Finding 565360 (2024-001)

Significant Deficiency 2024

Path

WA

Subrecipient Monitoring Reporting Significant Deficiency

Finding 2024-001 PATH’s Response and Corrective Action Plan PATH has an established process for completing FFATA reporting in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) in compliance with the requirements of the Federal Funding Accountability and Transp...

Finding 2024-001 PATH’s Response and Corrective Action Plan PATH has an established process for completing FFATA reporting in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) in compliance with the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109‐282) (FFATA) that are codified in Title 2 U.S. Code of Federal Regulations, Part 170 ‐ Reporting Subaward and Executive Compensation Information. Although PATH complied with all other FFATA reporting requirements, reports for two subawards were not filed by the end of the month following the month in which PATH awarded these sub‐grants greater than or equal to $30,000. For the FFATA filings that were submitted late, the cause was that an employee new to PATH that year who assumed FFATA reporting did not realize her entries were not saving in the system correctly. This issue was discovered as part of a routine management review of PATH’s FFATA reporting. When the issue was discovered, management repeated the training on the Office of Grants and Contract’s (OGC) business process for FFATA reporting with that staff member and assigned another member of the team to review entries in the last week of each month, preventing future late filings. In 2025, OGC Management will add the following actions to the FFATA reporting business process strengthen to ensure all filings are submitted in a timely manner. Action Responsible staff member Due date Repeat training on OGC’s business process for FFATA reporting with the two OGC staff members responsible for FFATA reporting for PATH OGC Management June 30, 2025 Provide monthly report to OGC management by the last day of each month confirming timely reporting OGC Staff responsible for FFATA reporting Throughout 2025

View Audit 359204

Finding 565358 (2024-001)

Significant Deficiency 2024

Community Loan Fund of New Jersey, Inc.

NJ

Reporting Internal Control / Segregation of Duties § 200.303 § 200.502

Corrective Action Plan Year Ended September 30, 2024 Findings Related to Federal Awards 2024-001 SEFA Control Deficiency Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Program (ALN 21.033) Federal Gra...

Corrective Action Plan Year Ended September 30, 2024 Findings Related to Federal Awards 2024-001 SEFA Control Deficiency Federal Agency: U.S. Department of Treasury Program Titles and Assistance Listing Numbers (ALN): Community Development Financial Institutions Program (ALN 21.033) Federal Grant Numbers: 22ERP061418 Contact Person: Steven Kaczynski, Controller; skaczynski@newjerseycommunitycapital.org; 732-640-2061 Corrective Action: As noted by our auditor, the submitted expenditures were allowable under the grant. The condition exists such that these expenditures were included within the current period SEFA report because that is when they were determined to be applicable, rather than the period when they were actually incurred (the prior period SEFA report). Going forward, management will ensure to report expenditures in the period they were incurred rather than the period they were applied. Anticipated Completion Date: September 30, 2025

View Audit 359200

Finding 565357 (2024-001)

Material Weakness 2024

The Crest at Lakeshore, Llc. Dba: the Crest at Lakeshore

MN

HUD Housing Programs Material Weakness Internal Control / Segregation of Duties

Material Weakness in Internal Control over Compliance Recommendation: We recommend management ensure they are properly calculating surplus cash and distributing in accordance with the calculation. Action taken in response to finding: Management will review and establish procedures to properly calcul...

Material Weakness in Internal Control over Compliance Recommendation: We recommend management ensure they are properly calculating surplus cash and distributing in accordance with the calculation. Action taken in response to finding: Management will review and establish procedures to properly calculate surplus cash and distribute these funds timely after year end audit. Name of the contact person responsible for corrective action: Thomas Krolak Planned completion date for corrective action plan: December 31, 2024

View Audit 359185

Finding 565356 (2024-001)

Significant Deficiency 2024

White Bear Lake Senior Housing, Inc. Dba: Willow Wood Apartments

MN

Questioned Costs HUD Housing Programs Significant Deficiency

Significant Deficiency in Internal Control over Compliance Recommendation: Recommend that a catchup payment is made as soon as possible to make the replacement reserve whole. Action taken in response to finding: A payment of $16,979 was deposited into the account as of March 31, 2025. Automatic paym...

Significant Deficiency in Internal Control over Compliance Recommendation: Recommend that a catchup payment is made as soon as possible to make the replacement reserve whole. Action taken in response to finding: A payment of $16,979 was deposited into the account as of March 31, 2025. Automatic payments were re-established to ensure no further issues due to lack of payment. Name of the contact person responsible for corrective action: Thomas Krolak Planned completion date for corrective action plan: March 31, 2025

View Audit 359184 Questioned Costs: $1

Finding 565351 (2024-001)

None 2024

Family Centered Services of Ct, Inc.

CT

Procurement, Suspension & Debarment § 200.318 § 200.326

U.S. Department of the Treasury AUDIT FINDINGS: Finding Reference Number: 2024-001 Description of Finding: Family Centered Services of CT, Inc. had not updated its procurement policy to conform to requirements in accordance with the Uniform Guidance. The policy in effect during fiscal 2024 did ...

U.S. Department of the Treasury AUDIT FINDINGS: Finding Reference Number: 2024-001 Description of Finding: Family Centered Services of CT, Inc. had not updated its procurement policy to conform to requirements in accordance with the Uniform Guidance. The policy in effect during fiscal 2024 did not specify a micro-purchase or small purchase threshold above which written quotes would be required. Additionally, a written policy for ensuring vendors are not suspended or debarred was not included in the existing policy and therefore this process was not being executed in a consistent manner. Statement of Concurrence or Nonconcurrence: Family Centered Services of CT, Inc. concurs with this audit finding. Corrective Action: A new Uniform Guidance-compliant procurement policy, including a process to ensure vendors are not debarred, was prepared and implemented in January 2025. Relevant staff have been and continue to be trained appropriately regarding execution of related procedures to ensure all aspects are being properly performed, Name of Contact Person: Jacquelyn Farrell, LCSW Executive Director 203-624-2600x204 jfarrell@familyct.org Projected Completion Date: Immediately

View Audit 359179

Finding 565350 (2024-009)

Material Weakness 2024

City of Thomasville Alabama

AL

Procurement, Suspension & Debarment § 200.318

Management agrees with the finding. The City will implement procedures to ensure all purchases over $15,000 are formally approved by the City Council and are documented in the minutes.

View Audit 359169

Finding 565343 (2024-002)

Material Weakness 2024

Housing Authority of the County of Dauphin

PA

Questioned Costs HUD Housing Programs Eligibility

Finding Number: 2024-002 Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all clients complete an annual family income reeaxaminat...

Finding Number: 2024-002 Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure all clients complete an annual family income reeaxamination in accordance with Eligibility, Reporting and Housing Assistance Payment Requirements. Anticipated Completion Date: 6/30/2025 Responsible Contact Person: Kristen Runion, HCV Supervisor

View Audit 359165 Questioned Costs: $1

Finding 565340 (2024-001)

Material Weakness 2024

Housing Authority of the County of Dauphin

PA

Questioned Costs Special Tests & Provisions HUD Housing Programs

Finding Number: 2024-001 Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure the completion and accuracy of the inspection protocol. ...

Finding Number: 2024-001 Planned Corrective Action: Applicable staff will be briefed on the finding and training will be provided on both written policy and procedure. The Housing Authority has a quality assurance program to monitor and ensure the completion and accuracy of the inspection protocol. The Housing Authority will continue to implement its 30-day review system for the HCV Inspection Program. Although the system cannot ensure 100% compliance, its effectiveness is demonstrated in the high percentage of compliance. Anticipated Completion Date: 6/30/2025 Responsible Contact Person: Kristen Runion, HCV Supervisor

View Audit 359165 Questioned Costs: $1

Finding 565339 (2024-003)

Significant Deficiency 2024

Cook County, Illinios

IL

Reporting § 200.332

To prevent recurrence and ensure timeliness, the following corrective actions have been implemented as of May 29, 2025. Revised Internal Deadlines: Internal monthly reporting deadlines are now set ﬁve business days before the funder’s due date to allow for review and contingency time. Party(ies) re...

To prevent recurrence and ensure timeliness, the following corrective actions have been implemented as of May 29, 2025. Revised Internal Deadlines: Internal monthly reporting deadlines are now set ﬁve business days before the funder’s due date to allow for review and contingency time. Party(ies) responsible for overseeing the corrective action plan for the grant program: Wynetta L. Scales, Associate Director, Financial Planning & Analysis Juandalynn Johnson, Associate Director, Grants Management The Justice Advisory Council completed the above corrective action on May 29, 2025.

View Audit 359160

Finding 565338 (2024-002)

Significant Deficiency 2024

Cook County, Illinios

IL

Subrecipient Monitoring § 200.303 § 200.332 § 200.339 § 200.521

To address this issue, the department will be taking the following corrective actions: 1. Training: Staff responsible for sub-recipient monitoring will complete updated training focused on federal Uniform Guidance requirements, as well as best practices for oversight and documentation. 2. Policy Rev...

To address this issue, the department will be taking the following corrective actions: 1. Training: Staff responsible for sub-recipient monitoring will complete updated training focused on federal Uniform Guidance requirements, as well as best practices for oversight and documentation. 2. Policy Review and Clarification: The department will review and revise its internal policies and procedures to align more closely with federal guidelines and institutional expectations. Clear protocols for sub-recipient monitoring activities will be disseminated to relevant personnel. 3. Ongoing Oversight: Upon implementation, the Department will conduct periodic reviews of sub-recipient monitoring activities to ensure compliance and for purposes of identifying any areas requiring further improvement. These actions are intended to strengthen compliance efforts and prevent similar issues in the future. Party(ies) responsible for overseeing the corrective action plan for the grant programs: - Nader Abusumayah, Chief Accountant, nader.abusumayah2@cookcountysao.org, 312.603.1840 - Nicole Kramer, Director of Programs and Development, nicole.kramer@cookcountysao.org, 312.603.1879 The department plans on completing the above corrective action on 8/30/2025

View Audit 359160

Finding 565337 (2024-001)

Significant Deficiency 2024

Cook County, Illinios

IL

Subrecipient Monitoring Allowable Costs / Cost Principles Cash Management § 200.208 § 200.305

To address the identified non-compliance with timely subrecipient payments, the Cook County State’s Attorney Ofﬁce has implemented an internal invoice submission form designed to streamline and formalize the invoice processing workflow. This form is now utilized by all business managers and program ...

To address the identified non-compliance with timely subrecipient payments, the Cook County State’s Attorney Ofﬁce has implemented an internal invoice submission form designed to streamline and formalize the invoice processing workflow. This form is now utilized by all business managers and program managers, who have been trained and granted functional access to ensure consistent and accurate usage. Additionally, a dedicated SharePoint site has been established to manage and monitor the invoice submission process. This platform allows for real-time tracking of invoice numbers, amounts, vendor names, and payment statuses, thereby enhancing transparency and accountability. These measures collectively aim to strengthen internal controls, improve communication among parties involved, and ensure compliance with federal cash management requirements moving forward. Party(ies) responsible for overseeing the corrective action plan for the grant programs: - Nader Abusumayah, Chief Accountant, nader.abusumayah2@cookcountysao.org, 312.603.1840 The department plans on completing the above corrective action on 6/1/2025.

View Audit 359160

Finding 565324 (2024-001)

Significant Deficiency 2024

Bath Housing Development Corporation

ME

Eligibility HUD Housing Programs Significant Deficiency

Finfing Number: 2024-001: Eligibility Planned Corrective Action: 1. All 2024 reexamination files will be reviewed to confirm a corresponding file is present and social security income is accruately reflected. File findings will be noted accordingly. 2. Moving forward, a Quality Control audit will ...

Finfing Number: 2024-001: Eligibility Planned Corrective Action: 1. All 2024 reexamination files will be reviewed to confirm a corresponding file is present and social security income is accruately reflected. File findings will be noted accordingly. 2. Moving forward, a Quality Control audit will occur monthly to include: - Confirmation of corresponding file for every annual reexamination completed. - 50% of all reexamination files will be audited to confirm the following: > Verification of income and assets. > Gross income is accurately reflected. > An EIV report is present; social security income reported is accurate. > A signed 50059 is present in the file. The audit will be conducted by a staff member that did not complete the reexam. Anticipated Completion Date: 1. July 31, 2025; 2. Ongoing Responsible Contact Person: Jessica Irish

View Audit 359147

Finding 565322 (2024-001)

Material Weakness 2024

Agency for Substance Abuse Prevention, Inc.

AL

Internal Control / Segregation of Duties Reporting Subrecipient Monitoring

Management of The Agency for Substance Abuse Prevention, Inc. hereby submits the following corrective action plan in response to the single audit findings for the fiscal year ending September 30, 2024: Finding 2024-001 – Segregation of Duties: Description of Finding: The auditor found that duties ...

Management of The Agency for Substance Abuse Prevention, Inc. hereby submits the following corrective action plan in response to the single audit findings for the fiscal year ending September 30, 2024: Finding 2024-001 – Segregation of Duties: Description of Finding: The auditor found that duties were not segregated in a number of areas where small adjustments to the policies of the Entity could help to further facilitate this important control. Statement of Concurrence or Nonconcurrence: Management concurs with this finding. Corrective Action: Management has issued written policies and required training of all employees that handle financial transactions and will continually evaluate processes to find ways to segregate duties where possible. Management and the board of directors will continue to oversee operations closely requiring approvals for all transactions.

View Audit 359146

Finding 565304 (2024-002)

Significant Deficiency 2024

Big Cities Health Coalition

MD

Allowable Costs / Cost Principles § 200.430

Views of Responsible Officials: Our Federal funds from January 1 to July 31, 2024, were subcontracts with two partners, NACCHO and ASTHO. Each was a flat fee agreement where we were not required to maintain timesheets for contracted work. Where more work was needed than covered by a contract, BCHC u...

Views of Responsible Officials: Our Federal funds from January 1 to July 31, 2024, were subcontracts with two partners, NACCHO and ASTHO. Each was a flat fee agreement where we were not required to maintain timesheets for contracted work. Where more work was needed than covered by a contract, BCHC used other funds to cover salary. As of August 1, 2024, when we were in receipt of a direct Federal award, we did implement timesheets for effort tracking. While we do track hours work in accordance with what has been budgeted, we continue to supplement all projects (Federal and nonFederal) with additional funds. That said, we have revisited time tracking with our staff and anticipate enhanced accuracy of time capture. Further, from August to December we used a standardized 160 hours for monthly allocations as the denominator to determine payroll percentage per project. We have now started using actual hours per period for those pay periods that have more than 80 hours or months that have more than 160 hours. The implementation of a new allocation format is now in effect, and along with increased diligence on effort tracking across our team, we believe we will enhance accuracy.

View Audit 359141

Corrective Action Plans

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