Corrective Action Plans

Finding 1227459 (2025-007)

Material Weakness 2025

DC

Internal Control / Segregation of Duties Material Weakness Reporting § 200.512

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management a...

Identifying Number: 2025-007 Data Collection Form (DCF) Late Filing Finding: The Institute did not submit the fiscal year 2024 Data Collection Form (DCF) and related reporting package to the Federal Audit Clearinghouse within the required time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Uniform Guidance reporting requirements: 1. Establish Formal Single Audit Reporting Procedures • The Institute will develop and maintain written procedures governing the annual Single Audit reporting process, including the preparation, review, approval, and submission of the Data Collection Form and reporting package. Procedures will clearly identify filing deadlines, responsible personnel, required approvals, and submission requirements. 2. Assign Responsibility and Accountability • Management will formally designate responsibility for coordinating the annual audit reporting process, including monitoring auditor requests, gathering required documentation, preparing the Data Collection Form, obtaining management approvals, and ensuring timely submission to the Federal Audit Clearinghouse. 3. Implement an Audit and Compliance Calendar • The Institute will establish a compliance calendar that includes all critical audit and federal reporting deadlines. Key milestones will include audit preparation activities, auditor request completion, draft financial statement review, issuance of the auditor's reports, Data Collection Form preparation, management certification, and FAC submission deadlines. 4. Strengthen Management Review Controls • Management will implement documented review procedures for the reporting package and Data Collection Form prior to submission. Review controls will verify the accuracy, completeness, and timeliness of information reported and ensure compliance with Uniform Guidance requirements. 5. Monitor Audit Requests and Submission Readiness • A tracking mechanism will be implemented to monitor the status of auditor requests, outstanding items, and reporting package preparation throughout the audit process. Periodic status meetings will be conducted to identify potential delays and ensure timely resolution of open items. 6. Maintain Evidence of Filing and Review • The Institute will retain documentation supporting preparation, review, approval, and submission of the Data Collection Form and reporting package, including filing confirmations, management approvals, submission receipts, and related correspondence. 7. Ongoing Oversight and Compliance Monitoring • Senior management will periodically review compliance with federal reporting deadlines and monitor the effectiveness of implemented controls. Any compliance issues identified will be evaluated and addressed promptly to prevent future late filings. Responsible Officials: • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr. Thelbert Snowden Anticipated completion date: The Institute will implement formal reporting procedures, deadline tracking tools, management review controls, and accountability measures by December 31, 2026. These procedures will be incorporated into all future Single Audit reporting cycles.

View Audit 409492

Finding 1227458 (2025-006)

Material Weakness 2025

The Institute of World Politics

DC

Subrecipient Monitoring Special Tests & Provisions Allowable Costs / Cost Principles

Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance Finding: - The Institute does not have a written information security program that addresses the seven required elements under the Gramm-Leach-Bliley Act. Corrective Actions Taken or Planned: Management agrees with the ...

Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance Finding: - The Institute does not have a written information security program that addresses the seven required elements under the Gramm-Leach-Bliley Act. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with the Gramm-Leach-Bliley Act and Department of Education requirements: 1. Comprehensive Review and Revision of the Written Information Security Program (WISP) • The Institute will conduct a comprehensive review of its existing Written Information Security Program (WISP) to ensure that all required elements of the GLBA Safeguards Rule are incorporated. The revised program will be approved by senior management and maintained as a formal institutional policy. 2. Formal Risk Assessment Process • The Institute will develop and implement a documented risk assessment process to identify reasonably foreseeable internal and external risks to the security, confidentiality, and integrity of student information. Risk assessments will be performed periodically and updated as significant operational, or technology changes occur. 3. Implementation of Required Security Safeguards • Management will document and implement administrative, technical, and physical safeguards designed to mitigate identified risks and protect student information. Safeguards will be reviewed periodically to ensure continued effectiveness. 4. Ongoing Monitoring and Testing of Controls • The Institute will establish procedures for ongoing monitoring of information security controls, including periodic evaluations of the effectiveness of safeguards, review of security incidents, vulnerability assessments, and corrective action tracking. Results will be documented and retained for review. 5. Vendor and Service Provider Oversight • The Institute will strengthen oversight procedures for third-party service providers that have access to protected student information. Contracts and vendor management procedures will be reviewed to ensure appropriate security expectations and monitoring requirements are established. 6. Security Awareness Training • Annual information security and data privacy training will be provided to employees with access to student information. Training will address GLBA requirements, cybersecurity risks, data protection responsibilities, incident reporting procedures, and institutional security policies. 7. Designation of Responsible Personnel • Management will formally designate individual(s) responsible for coordinating and overseeing the Information Security Program, including risk assessment activities, monitoring efforts, policy updates, and compliance reporting. 8. Periodic Reporting to Senior Management and the Board • The Information Security Program Coordinator will provide periodic reports to senior management and the Board or appropriate governing committee regarding information security risks, monitoring activities, cybersecurity incidents, and the status of GLBA compliance efforts. 9. Annual Review of the Information Security Program • The Institute will conduct an annual review of its Information Security Program to ensure continued alignment with GLBA requirements, Department of Education guidance, emerging cybersecurity risks, and institutional operations. Identifying Number: 2025-006: Special Tests—Gramm-Leach-Bliley Act Noncompliance (Continued) Responsible Officials: • Executive Vice President – Ariane Sweeney • Chief Information Officer - Dean Lane • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Director of Financial Aid – Dr Thelbert Snowden Anticipated completion date: The revised Written Information Security Program, formal risk assessment process, monitoring procedures, and training program will be fully implemented by December 31, 2026. Ongoing monitoring, risk assessments, and annual reviews will continue thereafter.

View Audit 409492

Finding 1227457 (2025-005)

Material Weakness 2025

The Institute of World Politics

DC

Special Tests & Provisions Student Financial Aid Allowable Costs / Cost Principles

Identifying Number: 2025-005: Special Tests—Credit Balances Noncompliance Finding: - During our testing of the Student Financial Assistance Cluster, we identified an instance in which the Institute did not refund a Title IV credit balance within the required 14-day time frame. Corrective Actions Tak...

Identifying Number: 2025-005: Special Tests—Credit Balances Noncompliance Finding: - During our testing of the Student Financial Assistance Cluster, we identified an instance in which the Institute did not refund a Title IV credit balance within the required 14-day time frame. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen compliance with Title IV credit balance requirements: 1. Development of Written Policies and Procedures • The Institute will develop and maintain formal written policies and procedures governing the identification, tracking, review, approval, and refunding of Title IV credit balances. Procedures will clearly define responsible personnel, required timelines, supervisory review requirements, and documentation retention standards. 2. Implementation of Credit Balance Tracking Process • Management will implement a standardized tracking process to identify Title IV credit balances immediately upon creation and monitor outstanding balances through refund issuance. The tracking log will include the student name, credit balance amount, date created, refund due date, refund date, and reviewer approval. 3. Monitoring of 14-Day Compliance Requirement • The Institute will establish controls to monitor compliance with the 14-day refund requirement, including periodic review of open credit balances and automated or manual reminders for approaching refund deadlines. Any overdue items will be escalated to management for immediate resolution. 4. Documentation of Review and Approval • Evidence of review and approval will be maintained for all Title IV credit balance refunds. Documentation will include supporting reports, refund calculations, processing dates, and supervisory approval demonstrating that refunds were processed accurately and timely. 5.Monthly Management Review • Management will perform monthly reviews of all Title IV credit balances and refund activity to verify compliance with Department of Education requirements. Review procedures will include verification that all refunds were issued within required timeframes and that supporting documentation has been retained. 7. Staff Training • Financial Aid, Student Accounts, and Finance personnel involved in processing Title IV funds will receive training on federal credit balance requirements, documentation standards, and internal control responsibilities. Training will emphasize the importance of timely refund processing and compliance monitoring. 8. Ongoing Compliance Monitoring • The Institute will periodically review credit balance activity and related controls to ensure procedures are operating effectively. Any exceptions identified will be documented, investigated, and corrected timely, with results reported to senior management. Responsible Officials: • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: The Institute will fully implement credit balance tracking procedures, documentation requirements, management review controls, and staff training by December 31, 2026. Ongoing monitoring and periodic compliance reviews will continue thereafter.

View Audit 409492

Finding 1227456 (2025-004)

Material Weakness 2025

The Institute of World Politics

DC

Allowable Costs / Cost Principles Material Weakness Reporting

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its intern...

Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records Finding: - During our testing of the Student Financial Assistance Cluster, we noted that the Institute did not perform monthly reconciliations between its internal records and COD system data. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions to strengthen controls over COD reporting and reconciliation activities. 1. Implementation of Monthly Reconciliation Procedures • The Institute will establish formal monthly reconciliation procedures requiring comparison of: o COD system data to internal financial aid records; o Student financial aid records to the student information system; and o COD activity to the general ledger and related financial reporting records. • The reconciliation process will be designed to verify that all aid originated, disbursed, adjusted, and reported to the Department of Education is complete and accurate. 2. Development of Written Policies and Procedures • Management will develop and maintain formal written policies and procedures governing COD reconciliation activities. These procedures will identify responsible personnel, reconciliation timelines, required documentation, review expectations, and procedures for investigating and resolving discrepancies. 3. Timely Investigation and Resolution of Differences • Any discrepancies identified during the reconciliation process will be reviewed, documented, and resolved timely. Management will maintain documentation explaining the nature of reconciling items, corrective actions taken, and the date of resolution. 4. Documentation and Retention Requirements • The Institute will maintain completed reconciliation workpapers each month, including supporting reports, reconciliations performed, explanations of variances, and documentation of corrective actions taken. Reconciliation records will be retained in accordance with federal record retention requirements. 5. Management Review and Approval • Completed reconciliations will be reviewed by supervisory personnel independent of the preparation process. Evidence of review will be documented through signed and dated approvals, electronic workflow approvals, or other documentation demonstrating that reconciliations were reviewed for completeness and accuracy. 6. Staff Training • Financial Aid and Finance personnel responsible for COD reporting and reconciliation activities will receive training regarding Department of Education requirements, reconciliation procedures, documentation standards, and internal control responsibilities. 7. Ongoing Monitoring and Compliance Oversight • Management will perform periodic monitoring of reconciliation activities to ensure procedures are operating effectively and reconciliations are completed on a timely basis. Compliance results and any significant reconciliation issues will be communicated to senior management and tracked through resolution. Identifying Number: 2025-004: Reconciliation Between Common Origination and Disbursement (COD) System and The Institute’s Internal Records (Continued) Responsible Officials: • Director of Financial Aid 0 Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Executive Vice President – Ariane Sweeney Anticipated completion date: Formal reconciliation procedures, documentation standards, and management review controls will be fully implemented by December 31, 2026. Monthly reconciliations will be performed and documented on an ongoing basis thereafter.

View Audit 409492

Finding 1227455 (2025-003)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Reporting Special Tests & Provisions

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken o...

Identifying Number: 2025-003: Special Test-National Student Loan Data System (NSLDS) Enrollment Reporting Noncompliance. Finding - Instances of noncompliance have been identified where student enrollment changes were not reported to the NSLDS within the 60-day requirement. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Formal Written Procedures • The Institute will develop and maintain formal written policies and procedures governing NSLDS enrollment reporting. These procedures will clearly define reporting requirements, timelines, responsible personnel, supervisory review responsibilities, and documentation retention requirements to ensure compliance with Department of Education regulations. 2. Establishment of Reporting Calendars and Tracking Controls • Management will implement a formal reporting calendar and tracking mechanism to monitor NSLDS reporting deadlines. The tracking process will identify enrollment status changes requiring reporting and ensure all submissions occur within the required 60-day timeframe. 3. Enhanced Monitoring and Reconciliation Procedures • The Institute will perform periodic reconciliations between student enrollment records and NSLDS submissions to verify that all enrollment status changes have been reported accurately and timely. Any discrepancies identified during reconciliation will be investigated and corrected promptly. 4. Documented Review and Approval Process • Management will require documented evidence of supervisory review for each NSLDS submission. Review documentation will include dated approvals, electronic workflow approvals, or other evidence demonstrating that submissions were reviewed for completeness, accuracy, and timeliness prior to certification. 5. Staff Training and Cross-Training • Financial Aid personnel responsible for enrollment reporting will receive training on NSLDS reporting requirements and internal control procedures. Cross training will be implemented to ensure coverage during staff absences and reduce the risk of reporting delays due to personnel changes. 6. Ongoing Compliance Monitoring • Management will conduct periodic reviews of NSLDS reporting performance and maintain monitoring documentation to verify ongoing compliance with federal requirements. Any exceptions identified will be addressed through corrective action and management follow-up. 7. Oversight and Accountability • The Director of Financial Aid and senior administration will review compliance monitoring results periodically and track remediation efforts until the finding has been fully resolved. Management will maintain documentation supporting the operation of controls and timely reporting activities. Responsible Officials • Director of Financial Aid – Dr Thelbert Snowden • Executive Vice President – Ariane Sweeney • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Registrar (as applicable) – Adele Hartswick Anticipated completion date: The Institute will implement formal policies, reporting calendars, monitoring controls, reconciliation procedures, and review documentation requirements by December 31, 2026. Ongoing compliance monitoring and periodic review activities will continue thereafter.

View Audit 409492

Finding 1227454 (2025-002)

Material Weakness 2025

The Institute of World Politics

DC

Student Financial Aid Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Mana...

Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance Finding: We noted that controls identified by management over all material compliance requirements lack sufficient documentation to conclude application of controls is in place. Corrective Actions Taken or Planned: Management agrees with the finding and has implemented, or is in the process of implementing, the following corrective actions: 1. Development of Written Policies and Procedures • The Institute will perform a comprehensive review of all applicable Student Financial Assistance compliance requirements and develop formal written policies and procedures documenting the processes and controls for each material compliance area. Procedures will include the individual responsible, required documentation, review requirements, and retention standards. 2. Documentation of Internal Controls • Management will establish standardized control documentation requirements for all compliance activities. Evidence of review and approval will be maintained through signatures, initials, electronic approvals, checklists, reconciliations, or other documented support sufficient to demonstrate that controls were performed and reviewed. 3. Compliance Monitoring Checklists • The Institute will implement compliance monitoring checklists covering all direct and material compliance requirements identified in the audit, including: o Cash Management o Reporting o Student Eligibility o Student Disbursements o Credit Balance Processing o NSLDS Reporting o Gramm-Leach-Bliley Act Information Security Requirements • The checklists will be completed and reviewed periodically to provide evidence of compliance and supervisory oversight. 4. Training and Cross-Training • Financial Aid and Administrative personnel will receive training on federal student aid compliance requirements, documentation expectations, and internal control responsibilities. Cross training will be performed to mitigate risks associated with employee turnover and ensure continuity of operations. 5. Management Review and Oversight • Management will implement periodic supervisory reviews of compliance activities and supporting documentation to verify controls operating as designed. Results of compliance monitoring activities and any identified deficiencies will be reported to senior administration, and corrective actions will be tracked to completion. 6. Annual Compliance Review • The Institute will conduct an annual review of Student Financial Assistance policies, procedures, and internal controls to ensure continued compliance with Department of Education regulations, Uniform Guidance requirements, and changes in federal program requirements. Identifying Number: 2025-002: Documentation of Internal Controls Over Compliance (Continued) Responsible Officials: • Executive Vice President – Ariane Sweeney • Director of Financial Aid – Dr Thelbert Snowden • Controller/Outsourced Accounting Partner – YPTC Associates Melissa McGuire & Samantha Glass • Compliance and Information Security Personnel, as applicable Anticipated completion date: The written policies and procedures, compliance monitoring tools, and documentation standards will be fully implemented by December 31, 2026. Ongoing monitoring, training, and annual reviews will continue thereafter.

View Audit 409492

Finding 1227453 (2025-001)

Material Weakness 2025

Columbia Borough School District

PA

Subrecipient Monitoring Cash Management Reporting § 200.303

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will...

Views of Responsible Officials: The District will implement formal internal control procedures requiring review and documented approval of all SNP Claim for Reimbursement Summary reports prior to submission in PEARS. The following procedures will be implemented: 1. The Director of Food Services will prepare the monthly SNP Claim for Reimbursement Summary report and compile all supporting meal count documentation. 2. Prior to submission, the Administrative Assistant to the Director of Food Services or another designated individual independent of the preparation process will: a. Review the claim for mathematical accuracy; b. Verify meal counts against supporting documentation; c. Confirm claims are submitted within required timelines; and 3. Evidence of the review and approval will be documented through: a. Signature or electronic approval on the reimbursement summary report; and b. Retention of supporting documentation in accordance with federal and state record retention requirements. 4. A written standard operating procedure (SOP) outlining these review and approval responsibilities will be developed and communicated to applicable personnel. The Business Manager will periodically monitor compliance with the procedure to ensure controls remain effective.

View Audit 409490

Finding 1227450 (2025-001)

Material Weakness 2025

Search for Common Ground

DC

Reporting Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.302 § 200.303

We will strengthen our controls around reporting of expenses on consolidated SEFA report for our subsidiary and related organizations. We will exclude expenses that exceed the total budget and recommend posting adjustments in the books so that these are not included in grant expenses.

View Audit 409488

Finding 1227449 (2025-004)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

Internal Control / Segregation of Duties

Uniform Guidance Written Policies and Procedures CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will establish written policies and procedures for Uniform Guidance. Officia...

Uniform Guidance Written Policies and Procedures CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will establish written policies and procedures for Uniform Guidance. Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227448 (2025-003)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

HUD Housing Programs

Signatures on Checks CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will make sure that all checks have the proper signatures that are required Official Responsible for Ens...

Signatures on Checks CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will make sure that all checks have the proper signatures that are required Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227447 (2025-002)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

HUD Housing Programs Special Tests & Provisions

Control Finding over Special Provisions CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will implement a checklist for documentation required to be obtained regarding specia...

Control Finding over Special Provisions CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will implement a checklist for documentation required to be obtained regarding special provisions compliance. They will also implement a formal review process of tenant files. Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227446 (2025-001)

Material Weakness 2025

Housing and Redevelopment Authority of the City of Worthington

MN

HUD Housing Programs

Rent Reasonableness CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will include rent reasonableness documentation in all required tenant files. Official Responsible for Ens...

Rent Reasonableness CORRECTIVE ACTION PLAN (CAP): Explanation of Disagreement with Audit Finding: There is no disagreement with the audit finding. Actions Planned in Response to Finding: The HRA will include rent reasonableness documentation in all required tenant files. Official Responsible for Ensuring CAP: Tanner Rogers, Executive Director, is the official responsible for ensuring corrective action. Planned Completion Date for CAP: The planned completion date is December 31, 2026. Plan to Monitor Completion of CAP: The Board will be monitoring this corrective action plan and believes the Executive Director will remedy this finding.

View Audit 409486

Finding 1227395 (2025-002)

Material Weakness 2025

Southern Minnesota Regional Legal Services Inc.

MN

Allowable Costs / Cost Principles

Corrective Action Planned: Management agrees with the auditor’s findings. The Director of Litigation, Lisa Hollingsworth, will meet with the Regional Leaders and ensure that they remind their staff about the necessity of obtaining a written statement of facts from clients in each relevant case. Name...

Corrective Action Planned: Management agrees with the auditor’s findings. The Director of Litigation, Lisa Hollingsworth, will meet with the Regional Leaders and ensure that they remind their staff about the necessity of obtaining a written statement of facts from clients in each relevant case. Name(s) of Contact Person(s) Responsible for Corrective Action: Director of Litigation – Lisa Hollingsworth Southeast Regional Leader – Brian Lipford Southwest Regional Leader – Peter Hemberger Anticipated Completion Date: On or before December 31, 2026

View Audit 409471

Finding 1227394 (2025-001)

Material Weakness 2025

Southern Minnesota Regional Legal Services Inc.

MN

Subrecipient Monitoring

Corrective Action Planned: Management agrees with the auditor’s findings and has completed the revision of the Organization’s accounting manual to align with the regulatory requirements. The former Director of Finance, Vannam Khen, worked directly with the Organization’s assigned Fiscal Compliance A...

Corrective Action Planned: Management agrees with the auditor’s findings and has completed the revision of the Organization’s accounting manual to align with the regulatory requirements. The former Director of Finance, Vannam Khen, worked directly with the Organization’s assigned Fiscal Compliance Analyst from Legal Services Corporation (LSC) to ensure policies and procedures are aligned with LSC’s Financial Guide. Name(s) of Contact Person(s) Responsible for Corrective Action: Former Director of Finance – Vannam Khen CEO – Micaela Schuneman Anticipated Completion Date: On or before December 31, 2026

View Audit 409471

Finding 1227385 (2025-010)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Subrecipient Monitoring Equipment & Real Property Management Procurement, Suspension & Debarment § 200.313

The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inven...

The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inventory taken. In addition, if prescribed by other funding sources the organization may do an annual inventory and reconcile it with the previous year as well. Disposal policies will include methods of disposition as required by the various funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: Fourth Quarter - ending Dec. 2026

View Audit 409469

Finding 1227384 (2025-009)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Equipment & Real Property Management § 200.313

The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inven...

The organization will develop a policy on inventory acquisition, maintenance and disposal. Inventory will be conducted a prescribed by the funding source for Head Start it will be every two years in June of odd years, or when classrooms are relocated. Inventory will be reconciled with the last inventory taken. In addition, if prescribed by other funding sources the organization may do an annual inventory and reconcile it with the previous year as well. A form will be created to ensure that all requirements of inventory are met: date of purchase, description of item, purchase price, vendor, location, grant award number. Responsible Individual: Program Directors Estimated Completion Date: December 2026, thereafter June of odd years

View Audit 409469

Finding 1227383 (2025-008)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Cash Management Allowable Costs / Cost Principles Material Weakness

The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: Octob...

The organization will develop a procedure for the review and approval of adjusting journal entries, and attaching supporting documentation ensuring entries are being charged to the correct funding sources. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date: October 31, 2026

View Audit 409469

Finding 1227382 (2025-007)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Cash Management Allowable Costs / Cost Principles § 200.305 § 200.403

The organization will develop a process of checks and balances to ensure that supporting documentation is provided and attached to justify the draw down requests. A reconciliation of expenditures recorded on the books and submitted request for reimbursement. All excess funds will be returned to the ...

The organization will develop a process of checks and balances to ensure that supporting documentation is provided and attached to justify the draw down requests. A reconciliation of expenditures recorded on the books and submitted request for reimbursement. All excess funds will be returned to the funding source. Responsible Individual: Chief Financial Officer - Scott Korba Estimated Completion Date:

View Audit 409469

Finding 1227381 (2025-006)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.331

The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization...

The auditor compares being a beneficiary to being a sub-recipient instead of is the secondary institution a contractor or a sub-recipient. The organization agrees that policies and procedures should be put in place in the event that funds are going to be passed-through. In addition, the organization feels that it was able to show the funds that were passed-through to the contractor. Responsible Individual: Chief Financial Officer– Scott Korba Estimated Completion Date

View Audit 409469

Finding 1227380 (2025-005)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Reporting Significant Deficiency Matching / Level of Effort / Earmarking § 200.303

The regulation speaks to submitting quarterly reports within a given time frame. The regulation does not require formal evidence that the required reports were verified before submission. The organization is of the opinion that once complete the CFO reviews the report and verifies before submission....

The regulation speaks to submitting quarterly reports within a given time frame. The regulation does not require formal evidence that the required reports were verified before submission. The organization is of the opinion that once complete the CFO reviews the report and verifies before submission. The organization CEO may review be included in the review process. Responsible Individual: Chief Financial Officer- Scott Korba Estimated Completion Date: End of next quarter – September 2026

View Audit 409469

Finding 1227379 (2025-004)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Procurement, Suspension & Debarment Subrecipient Monitoring Eligibility

Under the state of Pennsylvania, contractors doing home repairs in excess of $5000 a year must register with the state of Pennsylvania and receive their Home Improvement Contractor Certification. Applications are reviewed by the Attorney General’s Office , anyone who is debarred is not issued and HI...

Under the state of Pennsylvania, contractors doing home repairs in excess of $5000 a year must register with the state of Pennsylvania and receive their Home Improvement Contractor Certification. Applications are reviewed by the Attorney General’s Office , anyone who is debarred is not issued and HIC Certification. In addition, the Program Director has a list of debarred contractors that he reviews periodically to ensure that contractors are not on the list. The organization will take the auditors recommendation of copying the debarred alphabetical page indicating that the contractor is not on the debarred or suspended listing and placing it in the contractors file. Responsible Individual: Energy Director Zack Porrecca and Housing Director Vickie Bucker Estimated Completion Date: September 30, 2026

View Audit 409469

Finding 1227378 (2025-003)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Procurement, Suspension & Debarment § 200.318 § 200.326

The organization has a procurement procedure that has been followed, Price comparisons are done, quotes have been received from various vendors, there have been no purchases that required sealed bids. Auditor may provide recommendations for the revision of the policies. The organization will provide...

The organization has a procurement procedure that has been followed, Price comparisons are done, quotes have been received from various vendors, there have been no purchases that required sealed bids. Auditor may provide recommendations for the revision of the policies. The organization will provide training to management staff on the procurement policies. Responsible Individual: Chief Financial Officer – Scott Korba Estimated Completion Date: October 2026-December 2026

View Audit 409469

Finding 1227377 (2025-002)

Material Weakness 2025

Community Action Partnership of Mercer County

PA

Allowable Costs / Cost Principles § 200.431

While the organization has a written leave policy it does not address specific leave benefits for the CEO. The CEO has drafted a CEO Compensation and Benefits Policy to be reviewed by the Board and revised or approved at the October 21, 2026 Board of Directors meeting. Responsible Individual: Chief ...

While the organization has a written leave policy it does not address specific leave benefits for the CEO. The CEO has drafted a CEO Compensation and Benefits Policy to be reviewed by the Board and revised or approved at the October 21, 2026 Board of Directors meeting. Responsible Individual: Chief Executive Officer – Wilma Torres Estimated Completion Date: October 21, 2026

View Audit 409469

Finding 1227376 (2025-003)

Material Weakness 2025

County of Hidalgo, Texas

TX

Reporting

Corrective Action Plan – Hidalgo County Urban County Program (UCP) concurs with the recommendation and has taken steps to strengthen its internal controls to ensure the timely preparation, review, submission, and documentation of Section 3 quarterly reports and other State Program reporting requirem...

Corrective Action Plan – Hidalgo County Urban County Program (UCP) concurs with the recommendation and has taken steps to strengthen its internal controls to ensure the timely preparation, review, submission, and documentation of Section 3 quarterly reports and other State Program reporting requirements. The untimely reports identified in the finding occurred during a period of significant personnel turnover within the State Division. Management recognizes that regulatory compliance and reporting continuity should not depend upon the knowledge or availability of any one employee.Accordingly, UCP has begun transitioning from individually maintained deadline tracking to a more centralized and transparent reporting-control process. Approximately six months ago, UCP implemented a requirement that State Programs staff enter all grant-related reporting deadlines and other critical compliance dates into the County/Urban County shared electronic calendar. This calendar is accessible to State Programs staff and management and provides department-wide visibility of upcoming deadlines, thereby reducing reliance on individual calendars or institutional memory. In addition to this existing control, UCP will implement the following measures specifically for Section 3 reporting: • Establish internal preparation deadlines at least 5 calendar days before each required Section 3 submission date. • Assign primary responsibility for preparation and submission of each Section 3 report to the applicable State Grant Coordinator, with supervisory review by the State Programs Manager/Coordinator or other designated supervisor prior to submission. • Designate and cross-train at least one additional State Programs employee as backup personnel for Section 3 reporting to ensure continuity during vacancies, leave, employee transitions, or other absences. • Maintain a centralized reporting log for each applicable grant documenting the reporting period, regulatory or contractual due date, internal preparation deadline, responsible employee, supervisory review date, actual submission date, and confirmation or other evidence of submission. • Maintain supporting Section 3 reporting documentation within the applicable grant's official administrative file in accordance with applicable record-retention requirements. • Include upcoming reporting deadlines as a standing compliance item during State Programs staff meetings so that approaching deadlines, assignments, and outstanding reporting requirements can be reviewed collectively. • Require supervisory follow-up when a report has not reached the review stage by its established internal deadline, allowing management sufficient time to intervene before the external submission deadline. • Periodically review the shared reporting calendar and reporting log to verify that required reports have been submitted timely and that supporting documentation has been retained. These controls are intended to establish multiple levels of accountability—deadline visibility, assigned responsibility, supervisory review, backup coverage, documentation of submission, and management oversight—so that required reporting continues timely despite employee turnover or other staffing changes. UCP will also incorporate Section 3 reporting procedures into written State Programs standard operating procedures and employee cross-training materials so that the reporting process becomes documented institutional knowledge available to current and future staff. Proposed Completion Date - Existing shared calendar control (implemented and currently in use); Remaining corrective measures (September 30, 2026 - Implementation will begin immediately and be incorporated into State Program operating procedures and reporting practices). Contact Person - Steven De La Cruz, Assistant Director, Urban County Program

View Audit 409465

Finding 1227374 (2025-004)

Material Weakness 2025

SOLAR FAITHFUL

MI

Subrecipient Monitoring Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.302 § 200.303 § 200.318 § 200.331 § 200.430

2025-004 – Lack of Written Policies and Procedures Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have bee...

2025-004 – Lack of Written Policies and Procedures Auditor Description of Condition and Effect. Although the Organization has processes in place to cover these areas, and drafts of formal written policies covering the above items that address all of the area required by the Uniform Guidance have been developed, these policies have not yet been formally approved and adopted by the Organization. As a result of this condition, the Organization did not fully comply with the Uniform Guidance applicable to the above noted grants. Auditor Recommendation. We recommend that the Organization review and approve the draft policies as soon as practical, but no later than the end of fiscal year 2026. Corrective Action. The Organization has prepared a policies and procedures manual for the federal grant programs, which will be approved by the Board of Directors before the end of fiscal year 2026. Responsible Person. Rob Rafson, Executive Director Anticipated Completion Date: December 2026

View Audit 409461

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