Corrective Action Plans

Finding 1171537 (2025-016)

Material Weakness 2025

MD

Subrecipient Monitoring § 200.303 § 200.332

Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an inte...

Finding 2025-016 U.S. Department of Health and Human Services AL No. 93.914 HIV Emergency Relief Project Grants Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-025 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Created Subrecipient vs. Contractor determination checklist required to be completed by staff when submitting contract request to Contracts unit. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheet, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Developed fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. If either one is missing from the template, the contract package will be returned to the staff who initiated the contract process and instruct to include those items or the contract process will not move forward. • During bi-weekly fiscal office hours remind staff of the requirement to include both the FAIN and UEI in all agreements. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: May 31, 2026

View Audit 384683

Finding 1171514 (2025-015)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring § 200.303 § 200.332

Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed...

Finding 2025-015 U.S. Department of Health and Human Services AL No. 93.686 Ending the HIV Epidemic: A Plan for America Significant Deficiency in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-022 Auditee’s Corrective Action Plan: In FY 2025 BCHD developed an internal subrecipient monitoring policy awaiting final approval from the department’s executive leadership. Due to the appointment of a new Health Commissioner and changes in leadership, the approval process within the department restarted. The following steps were completed in 2025. • Subrecipient vs. Contractor determination checklist that are required to be completed by staff when submitting contract request to Contracts and Compliance team. • Compliance team created and managed the comprehensive subrecipient monitoring tracker via Smartsheets, which houses SAM.gov verifications, subrecipients’ audit reports and final monitoring reports. • Created fiscal and programmatic baseline monitoring tools based on 200 CFR standards. • Updated subrecipient contract agreement budget templates to include the Federal Award Identification Number (FAIN) and subrecipient’s UEI. • BCHD’s Director of Contracts and Compliance began conducting meetings with program directors to discuss monitoring processes and clarify federal requirements. • Hired a Compliance Analyst. Specific activities BCHD plans on executing to remediate this finding in FY 2026 are as follows: • Retrain contract administrators to thoroughly review subrecipient budget templates to ensure both the FAIN and subrecipient’s UEI are included. • Conduct separate workshops with division leaders and programs directors to review all grant awards and compliance requirements for each award. BCHD will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, BCHD will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. BCHD will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. BCHD will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: Nkenge Williams, Director of Audits Completion Date: June 30, 2026

View Audit 384683

Finding 1171506 (2025-013)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.332

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengt...

Finding 2025-013 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: No Auditee’s Corrective Action Plan: Notice of Award (NOA): To strengthen internal controls, MOED will establish separate grant worktags for all parts of the grant award to ensure the grant reference number is unique within the Workday award setup. UEI Subaward Validation: As a corrective action, Contracts Specialist training has been updated to require verification and documentation of the sub-recipient’s Unique Entity Identifier (UEI) through SAM.Gov as part of the subaward setup process. MOED will require grant staff to familiarize themselves with Administrative Manual policy 413- 21 Federal Grant Registration and Unique Entity Identifier, which requires UEI verification and identification in the City’s financial system of record for all subrecipients. Subrecipient Monitoring: MOED does maintain a standardized sub-recipient monitoring checklist designed to ensure subawards are administered in compliance with applicable federal statutes, regulations, and the terms and conditions of the subaward as well as relevant supporting documentation. FY2025 subrecipient monitoring was not scheduled in accordance with the monitoring timeframes outlined in the terms and conditions of the grant award. Management acknowledges this oversight and will ensure that all subrecipient monitoring is scheduled and conducted timely in accordance with the monitoring timeframes outlined in the award. Review of Subrecipient Single Audit Report: MOED performs a review of subrecipient Single Audit reports during the technical proposal evaluation and confirms the subrecipient’s inclusion on the State of Maryland’s Eligible Training Provider List (ETPL). Due to document volume size, this documentation has not historically been included in BOE-approved subrecipient agreements or retained within Workday award files. As a corrective action, MOED will formally incorporate ETPL verification into subrecipient agreements. Single Audit reports will be retained separately from the BOE approval package and uploaded to the applicable Grant Award record in Workday to ensure consistent documentation and accessibility. MOED will utilize the GMO’s subrecipient monitoring templates provided on the centralized SharePoint Grants Management platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reports are completed. Additionally, MOED will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOED will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all City-wide requirements for subrecipient monitoring. MOED will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system of record. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: September 30, 2026

View Audit 384683

Finding 1171505 (2025-012)

Material Weakness 2025

City of Baltimore, Maryland

MD

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

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting ...

Finding 2025-012 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: MOED will strengthen its fiscal reporting controls to ensure all required fiscal reports are submitted timely and in accordance with the grantor’s established timetable. This corrective action includes formal distribution of the grantor’s fiscal reporting schedule to responsible staff, implementation of internal calendar tracking for all fiscal reporting deadlines, and enhanced monitoring procedures to ensure deadlines are met and escalated when necessary. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: June 30, 2026

View Audit 384683

Finding 1171504 (2025-011)

Material Weakness 2025

City of Baltimore, Maryland

MD

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.430

Finding 2025-011 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Auditee’...

Finding 2025-011 U.S. Department of Labor AL No. 17.258, 17.259, 17.278 Workforce Innovation and Opportunity Act (WIOA) Cluster Significant Deficiency in Internal Controls and Noncompliance over Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Payroll) Repeat Finding: No Auditee’s Corrective Action Plan: MOED follows the standard process and employees’ clock in/out at timeclock or enter their time; prior to pay period close, that time is reviewed and approved as required. MOED currently runs a report named "Audit TT - Workers with Time Submitted but Not Approved" two hours prior to the final payroll submission deadline to identify timesheets that have been submitted by employees but not yet approved as of the morning following the close of the payroll period. MOED HR will run the “Audit TT - Workers with Time Submitted but Not Approved” report 30 minutes prior to the payroll submission deadline and will ensure that all timesheets are reviewed and approved by supervisors prior to final payroll processing. Contact Person: David Hagans, Chief Financial Officer Jasmine Armstrong, Fiscal Operations Director Riley Grant, Chief Contracts Officer Completion Date: March 31, 2026

View Audit 384683

Finding 1171473 (2025-010)

Material Weakness 2025

City of Baltimore, Maryland

MD

Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.303 § 200.330 § 200.331 § 200.332 § 200.501

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and ...

Finding 2025-010 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Subrecipient Monitoring Repeat Finding: Yes; 2024-014 Auditee’s Corrective Action Plan: MOHS will enhance and formalize subrecipient monitoring procedures to ensure full compliance with Uniform Guidance requirements. Subrecipient agreement templates will be revised to require inclusion of the subrecipient’s Unique Entity Identifier (UEI) and Federal Award Identification Number (FAIN) for all subawards, in accordance with 2 CFR §§25.300 and 200.332. MOHS has previously developed subrecipient risk assessment and monitoring tools for the Continuum of Care (CoC) program. These tools and procedures will be reviewed, updated as needed, and expanded to apply to all MOHS grants, including HOPWA. This includes documented risk assessments, monitoring plans, and verification that required Single Audit reports are obtained, reviewed, and retained when applicable. MOHS will maintain centralized subrecipient monitoring files containing executed agreements, audit reviews, monitoring documentation, and follow-up actions. Program and fiscal staff will receive training on updated subrecipient monitoring policies and documentation standards to ensure consistent implementation across all funding sources. MOHS will utilize the GMO’s subrecipient monitoring templates provided on their centralized SharePoint platform which include risk assessments, reporting forms, expenditure forms, and metrics forms to ensure all required subrecipient monitoring reporting is completed. Additionally, MOHS will require all grant staff to attend GMO monthly trainings and quarterly grant monitoring meetings to ensure subrecipient monitoring is being conducted and completed. MOHS will also require all grant staff to familiarize themselves with Administrative Manual policy 413-51 Subrecipient Monitoring and Management, which specifies all city-wide requirements for subrecipient monitoring. MOHS will maintain copies of all subrecipient monitoring documents in Workday, the City’s financial system. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: September 30, 2026

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Finding 1171472 (2025-009)

Material Weakness 2025

City of Baltimore, Maryland

MD

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal contro...

Finding 2025-009 U.S. Department of Housing and Urban Development (HUD) AL No. 14.241 Housing Opportunity for Persons with AIDS Material Weakness in Internal Controls and Noncompliance over Reporting Repeat Finding: Yes; 2024-013 Auditee’s Corrective Action Plan: MOHS will strengthen internal controls over federal reporting to ensure accuracy, completeness, and compliance with HUD and Uniform Guidance requirements. Specifically, MOHS will implement a documented reconciliation process requiring all HOPWA expenditures reported in the Federal Financial Report (FFR) to be reconciled to the general ledger prior to regular submission, with supervisory review and approval documented. MOHS will establish a formal reporting calendar and standardized checklist to ensure timely preparation, review, and submission of all required HUD reports, including the FFR, Federal Funding Accountability and Transparency Act (FFATA) Subaward Reporting (FSRS), and the Consolidated Annual Performance and Evaluation Report (CAPER). • Written procedures will be developed to clearly define staff roles and responsibilities for federal reporting and FFATA compliance, including identification of reportable first-tier subawards and documentation of FSRS submissions. MOHS will also provide targeted training to program and fiscal staff responsible for federal reporting and will conduct periodic internal monitoring to verify compliance with 2 CFR §200.303 and 2 CFR Part 170. MOHS will require grant staff to attend GMO monthly training sessions and review GMO provided training materials pertaining to grant management, grant reporting, and subrecipient monitoring and will require grant staff to review and comply with Administrative Manual policies 413-00 through 413-70 pertaining to all aspects of City-wide grant management. • Per the GMO’s guidance, MOHS will add award reporting tasks to all grant awards in Workday, the City’s financial system of record, to ensure timely completion of all grant reporting as well as upload regular reports into Workday. Contact Person: Sade Creighton-Wade, Chief of Fiscal Services Completion Date: June 30, 2026

View Audit 384683

Finding 1171413 (2025-008)

Material Weakness 2025

City of Baltimore, Maryland

MD

Matching / Level of Effort / Earmarking HUD Housing Programs Reporting § 200.303

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, t...

Finding 2025-008 U.S. Department of Housing and Urban Development (HUD) AL No. 14.218 Community Development Block Grants/Entitlement Grants Significant Deficiency in Internal Controls and Noncompliance over Reporting Repeat Finding: No Auditee’s Corrective Action Plan: Over the past several years, the Consolidated Planning Division has been conducting a widespread effort to ensure programmatic compliance with all City and Federal requirements. To date, it has prioritized: • Reducing the grant’s at-risk financial exposure from approximately $28M in FY23 to $1.03M in FY25. • Implemented moving all NPO operating contracts to the same Period of Performance (July 1 – June 30 of the grant year) to ensure timely expenditure of funds and reduce compliance burden on staff. • Implemented the use of a form agreement approval process for the Board of Estimates (BOE) which reduced the lag time for contract execution and subsequent reimbursement from over 12 months, to approximately 2 months once the executed grant agreement has been received from HUD and approved by the BOE. • Standardized required subrecipient activity reporting and requests for reimbursement in Neighborly (the City’s reporting system of record for the CDBG grant program) to a quarterly basis. • Required all supporting documentation be submitted and reviewed quarterly to eliminate the possibility of overpayment or reimbursement for ineligible activities. • Hired a Director of CDBG finance to improve fiduciary and compliance oversight of federal funds. • Ensured the HUD-required Cash-on-Hand report is entered into a new screen in HUD’s system of record - Integrated Disbursement and Information System (IDIS) - (reporting that was previously collected through Federal Financial Report (FFR)/Standard Form 425 (SF-425) on a timely basis. Corrective Action Plan: • A new Director of CDBG Finance will be hired before the end of FY26. • The new Director of CDBG Finance will be provided training to complete the Cash on Hand Report and will cross-train additional staff on the completion of this report to ensure redundancy. • Supporting documents will be kept on the divisional shared drive in a clearly named subfolder. Contact Person: Mary Correia, Deputy Commissioner David Fielder, Assistant Commissioner Completion Date: June 30, 2026

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Finding 1171399 (2025-002)

Material Weakness 2025

Greater Community Housing, Inc.

IN

Management will renew PRAC contract in a timely manner as to not allow contract to expire.

View Audit 384672

Finding 1171398 (2025-001)

Material Weakness 2025

Greater Community Housing, Inc.

IN

Management will make the delinquent deposit to the replacement reserve of $2,500 and establish transfers for the monthly deposit amount.

View Audit 384672

Finding 1171397 (2025-101)

Material Weakness 2025

Good Shepherd Food Bank of Maine

ME

Reporting

Federal Agency: U.S. Department of Agriculture. Award Names: Commodity Supplemental Food Program and. Emergency Food Assistance Program. Program Year: July 1, 2024 – June 30, 2025. Assistance Listing Numbers: 10.565 and 10.568. Repeat Finding: This is not a repeat finding. Criteria: The USDA has spe...

Federal Agency: U.S. Department of Agriculture. Award Names: Commodity Supplemental Food Program and. Emergency Food Assistance Program. Program Year: July 1, 2024 – June 30, 2025. Assistance Listing Numbers: 10.565 and 10.568. Repeat Finding: This is not a repeat finding. Criteria: The USDA has specific guidelines which need to be followed when reporting receipt of product for TEFAP and CSFP. The Company is required to notify the USDA of receipt of product within two working days. Condition: For four selections tested, notification from the Company to USDA was not within the two working days requirement. Context: For four selections tested, notification from the Company to USDA did not occur timely. Effect: As a result of the condition, receipt of product for TEFAP and CSFP was not in accordance with USDA requirements. Cause: Cause is due to a lack of administrative timeliness to notify USDA of the Company's receipt of product. Recommendation: We recommend the Company reinforce the importance of timely notification of product receipt to the USDA. Contact: Heather Paquette, President. Status: Management has introduced a new process in which a member of the team will create dedicated scan folders for USDA receipts, daily verification of documents by the Inventory Management team, and daily uploads of finalized paperwork to NetSuite before forwarding to DACF. Additionally, management will implement Daily Exception Reporting to ensure compliance by generating alerts for missing paperwork and delayed submissions.

View Audit 384669

Finding 1171387 (2025-001)

Material Weakness 2025

The Arc of Cape May County, INC and Affiliate

NJ

HUD Housing Programs

CFO concurs with the finding and agrees with the auditors' recommendation. We are working on implementing policies and procedures to ensure compliance requirements are being met in a timely manner. Management made a deposit of $3,168 on September 29, 2025. No further action is required.

View Audit 384668

Finding 1171385 (2025-002)

Material Weakness 2025

Contra Costa Community College District

CA

Student Financial Aid Significant Deficiency Internal Control / Segregation of Duties

Views of Responsible Officials and Corrective Action Plan The District has reviewed the current R2T4 procedures and taken corrective measures to strengthen internal controls over the Return of Title IV calculations to ensure that funds are returned in a timely manner. 1. Process Review: All Financia...

Views of Responsible Officials and Corrective Action Plan The District has reviewed the current R2T4 procedures and taken corrective measures to strengthen internal controls over the Return of Title IV calculations to ensure that funds are returned in a timely manner. 1. Process Review: All Financial Aid staff involved in the R2T4 process have reviewed the Overpayments-R2T4 Policy and Procedure to ensure a full understanding of each step and to continue to comply with federal timelines and documentation requirements. 2. Monitoring and Accountability: The Financial Aid Office will conduct a review of the return of Title IV calculations and ensure that the funds are returned to the ED within 45 days after the institution determines that the student withdrew. 3. Ongoing Evaluation: The Overpayments-R2T4 Policy and Procedure will be reviewed periodically by the Districtwide Financial Aid Directors Workgroup to ensure continued compliance and effectiveness of internal controls.

View Audit 384667

Finding 1171380 (2025-001)

Material Weakness 2025

Contra Costa Community College District

CA

Student Financial Aid

Views of Responsible Officials and Corrective Action Plan Due to programmatic update requirements mandated by state initiative AB 789, previously reported academic programs required recalculated timeframes. Concurrently, the District undertook a data cleanup initiative to ensure that each student de...

Views of Responsible Officials and Corrective Action Plan Due to programmatic update requirements mandated by state initiative AB 789, previously reported academic programs required recalculated timeframes. Concurrently, the District undertook a data cleanup initiative to ensure that each student declares only one active program of study, instead of multiple active programs. These adjustments, while essential for compliance and data accuracy, resulted in data discrepancies within the enrollment reporting files. Although the District has been diligently working to resolve these issues, the NSLDS reporting process requires all prior-term errors to be fully resolved before a subsequent term’s file can be submitted. As a result, the time required to correct all identified errors in the prior term caused delays in successful transmission to NSLDS within the required timeframe. The District has completed a comprehensive review to identify the causes of these reporting errors and is implementing an improvement plan with a defined timeline. Specifically, the programming logic used to generate the NSLDS upload file has been rewritten to ensure compliance with updated reporting parameters. Additionally, Admissions and Records offices have established a post-upload review process to conduct spot checks of enrollment data after each NSLDS submission to verify accuracy and prevent future delays. As the District gains more experience with the updated process and completes the backlog of pending submissions, the District is confident that future enrollment reports will be transmitted to NSLDS accurately within the required timeframe.

View Audit 384667

Finding 1171375 (2025-001)

Material Weakness 2025

Ehdoc Teamsters Residences, Inc.

FL

HUD Housing Programs

Oversight Agency for Audit, EHDOC Teamsters Residences, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 ...

Oversight Agency for Audit, EHDOC Teamsters Residences, Inc. respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: July 1, 2024 through June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the numbers assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AND FINANCIAL STATEMENT AUDITS FINDING No. 2025-001: Section 207/223(f) Mortgage Insurance for the Refinancing of Existing Multifamily Housing Projects, ALN 14.155 Recommendation: Management should implement procedures to ensure that HUD required tenant eligibility procedures are adhered to, and that all documentation is retained in the tenant files. Action Taken: Staff training has been provided with additional HUD training inclusive of recertification deadlines and background check documentation. Tenant file maintenance is stressed and included in monthly reporting procedures. If the audit Oversight Agency has questions regarding these plans, please call Irene Phillips at 954-835- 9200. Sincerely yours, Irene Phillips CFO

View Audit 384665

Finding 1171369 (2025-003)

Material Weakness 2025

Sheltercare

OR

Allowable Costs / Cost Principles Period of Performance Significant Deficiency

--Corrective Action Plan: Management has prepared a written procedure for the process used to bill payroll and related costs to the federal award programs. This process will be followed in the future to ensure this same mistake is not made. Once it was brought to management’s attention, they adjuste...

--Corrective Action Plan: Management has prepared a written procedure for the process used to bill payroll and related costs to the federal award programs. This process will be followed in the future to ensure this same mistake is not made. Once it was brought to management’s attention, they adjusted their process to get back “on track”, such that the correct two-week period is being billed each time and none are being repeated. Further, management will implement a more robust review of this process in case similar errors still exist. --Person Responsible: Phoebe Benjamin, Associate Finance Director --Date Implemented: 1/1/2026

View Audit 384658

Finding 1171367 (2025-002)

Material Weakness 2025

Sheltercare

OR

Reporting Significant Deficiency Matching / Level of Effort / Earmarking

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustmen...

--Corrective Action Plan: As part of the significant turnover within the accounting department in FY24-25, the individual preparing the current year SEFA this year had no previous experience with doing so. Management will take better care to prepare it next year so that it does not require adjustment, and has prepared a written procedure to follow for preparation of the SEFA. --Person Responsible: Phoebe Benjamin, Associate Finance Director --Date Implemented: 1/1/2026

View Audit 384658

Finding 1171365 (2025-004)

Material Weakness 2025

South Putnam Community School Corporation

IN

Allowable Costs / Cost Principles School Nutrition Programs § 200.303 § 200.403

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program(s): School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Numbers: 10.553, 10.555, 10.5...

FINDING 2025-004 Finding Subject: Child Nutrition Cluster - Allowable Costs/Cost Principles Federal Agency: Department of Agriculture Federal Program(s): School Breakfast Program, National School Lunch Program, Summer Food Service Program for Children Assistance Listing Numbers: 10.553, 10.555, 10.559 Federal Award Numbers and Years: FY2024, FY2025 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Allowable Costs/Cost Principals Audit Finding: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the School Corporation in order to ensure compliance with requirements related to the grant agreement and the Allowable Costs/Costs Principles compliance requirement. The School Corporation entered into a Fixed Price meal Contract with a food service management company (FSMC). For each meal type, a fixed price was established and billed by the FSMC based on meal counts served. The School Corporation failed to compare the invoices received from the FSMC to the School Corporations software reports to ensure the number of meals invoiced agreed to the meals served. Two invoices with the FSMC were selected for testing totaling $213,048.96. . Contact Person Responsible for Corrective Action: Erin Roach Contact Phone Number and Email Address: 765-653-3119 eroach@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The food service director will compare the invoices received from the FSMC to the School Corporations software reports prior to submission for payment. Anticipated Completion Date: February, 2026

View Audit 384655

Finding 1171360 (2025-003)

Material Weakness 2025

South Putnam Community School Corporation

IN

Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

FINDING 2025-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Number(s) and Year(s) (or Other Identifying Numbers): S425...

FINDING 2025-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listing Numbers: 84.425D, 84.425U Federal Award Number(s) and Year(s) (or Other Identifying Numbers): S425D200013, S425U200013 Audit Finding: Significant Deficiency This is a repeat finding from the immediately prior audit report. The prior finding number was 2023-003. Condition and Context The School Corporation had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. The School Corporation was required to submit annual data reports to the Indiana Department of Education via JotForm, a form/report builder. Data to be submitted included, but was not limited to, current period expenditures, prior period expenditures, and expenditures per activity. During the prior audit period, the School Corporation submitted two ESSER I reports, two ESSER II reports, and two EESER III reports, for a total of six reports. The Superintendent of Schools submitted all the reports without an oversight or review process in place to prevent, detect and correct errors. As a follow up in the current audit period, it was found that this issue was not resolved. The lack of internal controls was a systematic issue throughout the audit period. . Contact Person Responsible for Corrective Action: Erin Roach Contact Phone Number and Email Address: 765-653-3119 eroach@sputnam.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The grants director will print out the reports for review and approval prior to submission. Anticipated Completion Date: February, 2026

View Audit 384655

Finding 1171345 (2025-002)

Material Weakness 2025

East Valley Institute of Technology School District No. 401

AZ

Student Financial Aid Special Tests & Provisions Significant Deficiency

2025-002: SPECIAL TESTS AND PROVISIONS – GRAMM-LEACH-BLILEY ACT Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Fe...

2025-002: SPECIAL TESTS AND PROVISIONS – GRAMM-LEACH-BLILEY ACT Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Questioned Costs: N/A Repeat Finding: No Condition/Context: During our review of the District’s information security policies and procedures, it was noted that the District did not have formally written information security policies and procedures. The District did not have a process to evaluate and maintain a data inventory, ensuring sensitive data is at a higher risk profile and prioritized for security protocols. The District did not limit administrative privileges to dedicated administrator accounts; instead system administrators utilized their administrative accounts for all their job function, rather than just the functions requiring higher levels of access. Criteria: Title IV-eligible institutions are subject to the Gramm-Leach-Bliley Act (the ‘‘Act’’). The Act requires financial institutions to explain their information sharing practices to their customers and to safeguard sensitive data. The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as ‘‘financial institutions’’ and subject to the Act because they appear to be significantly engaged in wiring funds to consumers. Institutions agree to comply with the Act in their Program Participation Agreement with ED. Institutions must protect student financial aid information, with particular attention to information provided to institutions by ED or otherwise obtained in support of the administration of the Federal student financial aid programs. Institutions are required to develop, implement and maintain a written comprehensive information security program. Corrective Action: The District will implement policies and procedures over information technology to properly comply with the provision of the Gramm-Leach-Bliley Act. The District will prepare a security policy that addresses data classifications that ensure sensitive data is protected. In addition, administrator accounts will be restricted. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edith Perez, Chief Financial Officer

View Audit 384637

Finding 1171342 (2025-001)

Material Weakness 2025

East Valley Institute of Technology School District No. 401

AZ

Student Financial Aid Reporting Significant Deficiency

2025-001: REPORTING Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education T...

2025-001: REPORTING Program: Federal Supplemental Educational Opportunity Grants, Federal Pell Grant Program, Federal Direct Student Loans Cluster Title: Student Financial Assistance Cluster Federal Assistance Listing Numbers: 84.007, 84.063, and 84.268 Federal Agency: U.S. Department of Education Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: L. Reporting Questioned Costs: N/A Repeat Finding: No Condition/Context: Total tuition and fees as reported in the FISAP report was $3,228,909 while the District’s underlying accounting records showed $2,883,823, for a difference of $345,086. Total Federal Pell grant expenditures were reported as $362,929 on the FISAP report while the underlying accounting records and schedule of expenditures of federal awards showed $408,614, for a difference of $45,685. Criteria: The Student Financial Assistance cluster requires that the District submit the Fiscal Operations Report and Application to Participate (FISAP) annually. The amount should agree to the underlying accounting records. Corrective Action: The District will implement procedures to ensure the FISAP revenues and expenditures as posted within the general ledger match with the corresponding application. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Edith Perez, Chief Financial Officer

View Audit 384637

Finding 1171339 (2025-001)

Material Weakness 2025

Senior Citizens Housing Dev CORP of Chicago Dba Senate Apartments

FL

HUD Housing Programs Reporting

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Chicago respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Cor...

Oversight Agency for Audit, Senior Citizens Housing Development Corporation of Chicago respectfully submits the following corrective action plan for the year ended June 30, 2025. Name and address of independent public accounting firm: Bellows Associates, P.A., 5401 N University Drive, Suite 201, Coral Springs, Florida 33067 Audit period: July 1, 2024 through June 30, 2025 The finding from the June 30, 2025 schedule of findings and questioned costs is discussed below. The finding is numbered consistently with the number assigned in the schedule. SECTION III – FINDINGS AND QUESTIONED COSTS – MAJOR FEDERAL AWARD PROGRAMS AUDIT FINDING No. 2025-001: Section 202 Supportive Housing for the Elderly, ALN 14.157 Recommendation: Management should implement procedures to ensure the correct amount is deposited into the replacement reserve account each month. Action Taken: We will ensure that RR is fully funded on a monthly basis. New procedures have been implemented to review the deposits each month to ensure proper amounts. If the Oversight Agency for Audit has questions regarding the plan, please call Irene Phillips at 954-835-9200. Sincerely yours, Irene Phillips, CFO Irene Phillips CFO

View Audit 384633

Finding 1171338 (2025-002)

Material Weakness 2025

Spartanburg Community College

SC

Special Tests & Provisions Student Financial Aid Subrecipient Monitoring

COMPLIANCE FINDING 2025-002 SFA Cluster: Disbursement to or on Behalf of Students Contact Person: Missy Hughes, Director of Finance Corrective Action Plan: The Business Office is currently seeking an AP/Payroll Manager who will supervise the outstanding check process. The process will be performed a...

COMPLIANCE FINDING 2025-002 SFA Cluster: Disbursement to or on Behalf of Students Contact Person: Missy Hughes, Director of Finance Corrective Action Plan: The Business Office is currently seeking an AP/Payroll Manager who will supervise the outstanding check process. The process will be performed and maintained by the Financial Coordinator, Kyle Burnett. 1. Track all Title IV disbursements issued by check, including the issuance date and applicable return deadlines. During monthly bank and check reconciliations, any outstanding check related to Title IV funds will be reviewed by Kyle Burnett, Financial Coordinator. 2. Perform periodic (at least monthly) reviews of outstanding Title IV checks to identify uncashed items approaching the 240-day return requirement. The process of reviewing outstanding Title IV checks will be performed and maintained by the Financial Coordinator, Kyle Burnett. Kyle will review the outstanding checks related to student refunds monthly. 3. Ensure uncashed Title IV checks are returned to the U.S. Department of Education within 240 days of issuance when checks are not cashed or otherwise negotiated. Kyle Burnett, Financial Coordinator, will work with Linda Briggs, Student Account Coordinator and Financial Aid to be sure Title IV checks are returned to the U.S. Department of Education within 240 days of issuance, if still outstanding. 4. Assign clear responsibility for monitoring outstanding checks and returning funds and provide training to staff involved in Title IV disbursement and reconciliation processes. Kyle Burnett, Financial Coordinator, will be trained in Title IV disbursement and reconciliation processes and will work with the Accounts Receivable staff as well as Financial Aid to determine appropriate actions regarding the stale dated check items. 5. Retain documentation evidencing timely monitoring, review, and return of Title IV funds to support compliance and audit review. A SharePoint has been established that is currently maintained by Linda Briggs, Student Account Coordinator and Jeremy Elam, Controller. Kyle Burnett, Financial Coordinator, will be added to this SharePoint. This will be monitored and updated regarding check statuses related to Title IV funds.

View Audit 384632

Finding 1171337 (2025-001)

Material Weakness 2025

Spartanburg Community College

SC

Student Financial Aid Special Tests & Provisions Subrecipient Monitoring

MW 2025-001 SFA Cluster: R2T4 Corrective Action Plan Contact Person: Jeff Boyle, Director of Financial Corrective Action Plan: 1. Have at least two staff members enroll and complete the R2T4 training module conducted by NASFAA. Tonja Suttles and Melissa Satterwhite completed the course and passed th...

MW 2025-001 SFA Cluster: R2T4 Corrective Action Plan Contact Person: Jeff Boyle, Director of Financial Corrective Action Plan: 1. Have at least two staff members enroll and complete the R2T4 training module conducted by NASFAA. Tonja Suttles and Melissa Satterwhite completed the course and passed the credential exam. Suzanne Bonner sat in on a few of the sessions. 2. Make changes to the R2T4 spreadsheet. a. Maintain a separate tab for each calculation group to make tracking and internal reviews easier. Process has been completed and started being used during the 2025 fall semester. b. Add additional columns to the spreadsheet that will provide the necessary data to perform the R2T4 calculation within Colleague and act as a check and balance as the calculation is being performed. There are several columns with calculated data or data coming from a source outside of Colleague. These data values can then be compared to the values Colleague calculates and the two should match. Columns have been added and began being used with the 2025 fall semester. 3. It will be established that one staff member will do the R2T4 calculation and a second staff member will do a spot check of a spot check to ensure the calculation was done properly using the correct data. The number of students checked will depend on the number of students within the calculation groups. The number of students in a group can range from 2 to several hundred. This process was put into practice starting with the 09/17/25 calculation group. Jeff Boyle, Director of Financial Aid, performed all the R2T4 calculations for the 2025 fall term and Tonja Suttles, Assistant Director of Financial Aid, performed 100% review of all the calculations. This will change once we are assured this process is working the way we expect it. 4. The external spreadsheets and charts used for the R2T4 calculation contain a tremendous amount of data elements and are created two years in advance of being used. A process will be established where various staff members within the office will review the data prior to our using it for the R2T4 calculation. This has been implemented as of the 2025 fall semester. All the 2025-2026 terms have been reviewed. A secondary review will be done on each term just prior to the data being used for that term’s R2T4 calculations. The data will be reviewed again at any point we determine the data may not be correct.

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Finding 1171332 (2025-001)

Material Weakness 2025

Mental Health Mental Retardation Authority of Brazos Valley

TX

Reporting Internal Control / Segregation of Duties

Audit Finding 2025-1: During the audit it was noted that certain general ledger accounts were not analyzed and reconciled on a timely basis. Management Response: The Center has continued to experience turnover in key accounting positions. New programs with new software updates have required addition...

Audit Finding 2025-1: During the audit it was noted that certain general ledger accounts were not analyzed and reconciled on a timely basis. Management Response: The Center has continued to experience turnover in key accounting positions. New programs with new software updates have required additional staff training. The Medicaid Eligibility Renewal process by the State now has Renewals required every 12 months while prior to covid the Medicaid Program Renewals were required every 24 months. This has caused serious issues with the reconciliation process for Several of our Medicare, Medicaid, HCS and TXHMLV Accounts. We booked conservatively what we thought we could anticipate for Revenues assuming that we would begin receiving Reinstatement of Benefits at a somewhat regular Renewal Rate. We are allowed to back bill at least 90 days once approval is given. The Renewal Process is taking way longer than it used to, significantly complicating the reconciliation process, especially at year end with the need for separation of Revenue by Fiscal Years (matching process of Revenue with the same period Expenditures) Management will continue to train existing employees on significant accounting issues and IDD Management has recently begun using the Medicaid Lost Report to better anticipate lapses in upcoming Renewals of Consumers. We will also begin closing out our billings for the prior Fiscal Year earlier than we currently do. Any prior billings (Rebills) occurring after this established cutoff date (Medicare/Medicaid) will be reflected in the current year’s revenue and receivable balances. Name and Title of contact person responsible for corrective action: Dan Monson, CFO, 1504 S Texas Avenue. Bryan, TX 77802, 979-361-9802, Employer Identification Number: 74-1793265

View Audit 384621

Corrective Action Plans

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