Corrective Action Plans

Finding 1223976 (2024-002)

Material Weakness 2024

WA

Subrecipient Monitoring § 200.332

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and o...

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: This was the first and only grant Housing Hope has administered that required subrecipient monitoring. The grant has since ended and the organization does not anticipate entering any future agreements that would require subrecipient monitoring. To ensure compliance should such an agreement arise again, Housing Hope adopted a Subrecipient Monitoring Policy. This policy outlines the criteria for identifying subrecipient relationships and establish a standardized process for monitoring subrecipients, if any are engaged in the future. Anticipated completion date: The Subrecipient Monitoring Policy was adopted October 2025 by the Board.

View Audit 407369

Finding 1223974 (2024-003)

Material Weakness 2024

Housing Hope and Subsidiaries

WA

Subrecipient Monitoring Allowable Costs / Cost Principles Significant Deficiency § 200.303

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Beginning July 1, 2025, ...

Contact Person(s): Brianna Mariani - BriannaMariani@housinghope.org Kathryn Opina - KathrynOpina@housinghope.org Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): N/A Corrective action planned: Beginning July 1, 2025, the Payroll Specialist began saving physically signed timesheets that document allocations to grants. Beginning August 1, 2025, allocations to grants are captured within the payroll system, ADP, along with the supervisor approval. The Payroll Specialist verifies each line on the timesheet is approved, which the system requires for the employee to receive payment. Anticipated completion date: Corrective action of signed allocation timesheets was implemented July 1, 2025. Corrective action of allocations to grants within ADP was implemented August 1, 2025.

View Audit 407369

Finding 1223954 (2024-002)

Material Weakness 2024

International Journalism Defense, Inc.

DC

Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.512

Views of Responsible Officials: Management has made significant changes in staffing and processes to ensure future Single Audit reports are completed within the required timeframes. Name and Title of Responsible Official: Oliver Rivers, Chief Operating Officer Anticipated Completion Date: September ...

Views of Responsible Officials: Management has made significant changes in staffing and processes to ensure future Single Audit reports are completed within the required timeframes. Name and Title of Responsible Official: Oliver Rivers, Chief Operating Officer Anticipated Completion Date: September 30, 2026

View Audit 407357

Finding 1223953 (2024-001)

Material Weakness 2024

International Journalism Defense, Inc.

DC

Cash Management § 200.305

Views of Responsible Officials: IJD acknowledges that at the Statement of Financial Position date it was holding Federal funds in excess of immediate operational need. This situation was rectified shortly after, in February 2025, when the funds were used to finance IJD’s risk pool to protect investi...

Views of Responsible Officials: IJD acknowledges that at the Statement of Financial Position date it was holding Federal funds in excess of immediate operational need. This situation was rectified shortly after, in February 2025, when the funds were used to finance IJD’s risk pool to protect investigative journalists. This use of funds was exactly in line with the proposal originally submitted to the Federal funder (USAID), and with the risk pool in place and fully financed IJD is able to continue recruiting new members and credibly offer them the protection envisioned in the original grant proposal. Name and Title of Responsible Official: Oliver Rivers, Chief Operating Officer Anticipated Completion Date: Not applicable

View Audit 407357

Finding 1223948 (2024-002)

Material Weakness 2024

Action Pathways, Inc.

NC

Reporting Material Weakness § 200.512

The Organization is actively recruiting qualified candidates to fill vacant finance positions to strengthen its accounting and financial reporting functions. Filling these positions will help ensure that year-end financial reporting, audit schedules, and the Single Audit are completed in a timely ma...

The Organization is actively recruiting qualified candidates to fill vacant finance positions to strengthen its accounting and financial reporting functions. Filling these positions will help ensure that year-end financial reporting, audit schedules, and the Single Audit are completed in a timely manner and submitted to the Federal Audit Clearinghouse by the required deadline.

View Audit 407344

Finding 1223932 (2024-002)

Material Weakness 2024

Native Village of Kivalina

AK

§ 200.512

MANAGEMENT HAS STARTED WORK ON THEIR 2025 AUDIT PREPARATION AND WILL ENSURE THAT IT IS SUBMITTED TIMELY.

View Audit 407340

Finding 1223911 (2024-003)

Material Weakness 2024

Municipality of Ciales

PR

Reporting

Management acknowledges the finding and concurs with the recommendation. The delay in submitting the Single Audit Reporting Package and the Data Collection Form to the Federal Audit Clearinghouse (FAC) resulted from delays in completing the annual audit and finalizing the financial statements. Conse...

Management acknowledges the finding and concurs with the recommendation. The delay in submitting the Single Audit Reporting Package and the Data Collection Form to the Federal Audit Clearinghouse (FAC) resulted from delays in completing the annual audit and finalizing the financial statements. Consequently, the Municipality was unable to submit the required reporting package within the timeframe established under 2 CFR §200.512. To prevent future occurrences, the Municipality has strengthened its internal procedures over the Single Audit reporting process. Management will establish a comprehensive compliance calendar that identifies all regulatory reporting deadlines, including the submission of the Data Collection Form and Reporting Package to the Federal Audit Clearinghouse. The Federal Programs Director, Finance Department, and the Municipality's independent auditors will coordinate throughout the audit process to monitor progress, identify potential delays, and ensure that all required documentation is completed and submitted within the prescribed deadlines. Management is committed to complying with the reporting requirements established under 2 CFR Part 200, Subpart F, and will continue to improve its monitoring and oversight procedures to ensure timely submission of all future Single Audit reporting requirements.

View Audit 407316

Finding 1223907 (2024-007)

Material Weakness 2024

Municipality of Ciales

PR

To address this deficiency, the Municipality has implemented enhanced internal control procedures to ensure compliance with all reporting requirements. A compliance calendar has been established to identify all required reports, submission deadlines, and responsible personnel. The Federal Programs D...

To address this deficiency, the Municipality has implemented enhanced internal control procedures to ensure compliance with all reporting requirements. A compliance calendar has been established to identify all required reports, submission deadlines, and responsible personnel. The Federal Programs Director, in coordination with the Finance Department and program staff, will monitor reporting deadlines, perform periodic reviews of reporting requirements, and verify that all financial reports are completed, reviewed, and submitted within the timeframes established by the grant agreement and applicable regulations. Management is committed to strengthening its reporting and monitoring processes and to ensuring full compliance with the reporting requirements established under the Child Care and Development Block Grant Program and the terms and conditions of the agreement with ACUDEN.

View Audit 407316

Finding 1223906 (2024-006)

Material Weakness 2024

Municipality of Ciales

PR

Management acknowledges the finding and concurs with the recommendation. The Municipality recognizes that certain obligations outstanding at the end of the fiscal year were not liquidated within the required 90-day period established under the terms and conditions of the Child Care and Development B...

Management acknowledges the finding and concurs with the recommendation. The Municipality recognizes that certain obligations outstanding at the end of the fiscal year were not liquidated within the required 90-day period established under the terms and conditions of the Child Care and Development Block Grant (CCDBG) Program. The delays resulted from deficiencies in the monitoring process over outstanding obligations and the timely processing of related disbursements. To address this deficiency, the Municipality has strengthened its internal control procedures by implementing a monitoring process to track all outstanding obligations and their applicable liquidation deadlines. The Federal Programs Director, in coordination with the Finance Department and program personnel, will conduct periodic reviews of open obligations to ensure that all expenditures are processed and disbursed within the required period established by the grant agreement and applicable federal requirements. In addition, management will reinforce staff training regarding the period of performance requirements and the importance of timely liquidation of obligations. Management is committed to maintaining compliance with the requirements of the Child Care and Development Block Grant Program, including the provisions of the agreement with ACUDEN, and will continue to strengthen its internal controls to ensure that all future obligations are liquidated within the required 90-day period.

View Audit 407316

Finding 1223904 (2024-005)

Material Weakness 2024

Municipality of Ciales

PR

Management acknowledges the finding and concurs with the recommendation. The required Annual Project and Expenditure (P&E) Report was not submitted by the established due date because the Municipality did not have adequate procedures in place to monitor all federal reporting deadlines and ensure the...

Management acknowledges the finding and concurs with the recommendation. The required Annual Project and Expenditure (P&E) Report was not submitted by the established due date because the Municipality did not have adequate procedures in place to monitor all federal reporting deadlines and ensure the timely completion of the reporting requirements for the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Program. To address this deficiency, the Municipality has implemented corrective measures that include establishing a comprehensive compliance calendar identifying all required federal reports and their respective due dates. The Federal Programs Director will be responsible for monitoring these deadlines and coordinating with the Finance Department and other program personnel to ensure that all required information is completed, reviewed, and submitted on a timely basis. In addition, personnel responsible for administering the CSLFRF Program will receive additional training on the federal reporting requirements and applicable guidance issued by the U.S. Department of the Treasury. Management is committed to strengthening its internal controls over federal reporting and ensuring compliance with the reporting requirements established under 2 CFR § 200.328, 31 CFR Part 35, and the applicable Treasury guidance.

View Audit 407316

Finding 1223903 (2024-004)

Material Weakness 2024

Municipality of Ciales

PR

Allowable Costs / Cost Principles

Management acknowledges the finding and concurs with the recommendation. The Municipality recognizes that certain expenditures totaling $80,000 were charged to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) that were subsequently determined not to meet the program's allowable use req...

Management acknowledges the finding and concurs with the recommendation. The Municipality recognizes that certain expenditures totaling $80,000 were charged to the Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) that were subsequently determined not to meet the program's allowable use requirements. Management has evaluated the questioned costs and has initiated the necessary actions to ensure that the Coronavirus State and Local Fiscal Recovery Funds are reimbursed from non-federal sources, as applicable, and that the program funds are restored for eligible activities. In addition, the Municipality has strengthened its internal control procedures over the administration of federal awards. Going forward, all expenditures charged to the CSLFRF program will be subject to an enhanced review process by the Federal Programs Director and the Finance Department to verify eligibility and compliance with the applicable federal requirements before payment or reimbursement is processed. Management will also provide additional training to personnel responsible for the administration of federal programs regarding allowable costs and applicable federal regulations. The Municipality is committed to maintaining compliance with the requirements governing the Coronavirus State and Local Fiscal Recovery Funds and will continue to improve its internal controls to prevent similar findings in the future.

View Audit 407316

Finding 1223896 (2024-002)

Material Weakness 2024

Municipality of Ciales

PR

Management acknowledges the finding and concurs with the recommendation. The delay in submitting the unaudited and audited financial statements through HUD's Financial Assessment Subsystem (FASS) for the fiscal year ended June 30, 2024, resulted from delays in the completion of the financial reporti...

Management acknowledges the finding and concurs with the recommendation. The delay in submitting the unaudited and audited financial statements through HUD's Financial Assessment Subsystem (FASS) for the fiscal year ended June 30, 2024, resulted from delays in the completion of the financial reporting process and the availability of the information required to finalize the audit. Consequently, the Municipality was unable to meet the reporting deadlines established by HUD regulations. To address this deficiency, management has strengthened its internal monitoring procedures over the financial reporting process. The Federal Programs Director, in coordination with the Finance Department and the Municipality's independent auditors, will establish a reporting calendar that includes key deadlines for the preparation, review, completion, and submission of both the unaudited and audited financial statements. Management will also perform periodic follow-up meetings to monitor the status of the audit and ensure that all required supporting documentation is prepared and provided on a timely basis. The Municipality is committed to complying with the reporting requirements established under 24 CFR § 5.801, the Single Audit Act, and 2 CFR Part 200, Subpart F, and will implement these corrective actions to ensure that future financial statements are submitted within the required deadlines.

View Audit 407316

Finding 1223792 (2024-001)

Material Weakness 2024

Comite Gericola Regional De Mayaguez, Incorporado-Ciudad Del Retiro

PR

Management currently evaluating the alternative.

View Audit 407274

Finding 1223790 (2024-009)

Material Weakness 2024

Wilkin County

MN

Material Weakness Reporting Internal Control / Segregation of Duties § 200.303

Finding Number: 2024-009 Finding Title: Reporting Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Tarah Yaggie Corrective Action Planned: I was hired on 4/17/2024 and didn’t know about Covid 19 recovery funds. I r...

Finding Number: 2024-009 Finding Title: Reporting Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Tarah Yaggie Corrective Action Planned: I was hired on 4/17/2024 and didn’t know about Covid 19 recovery funds. I reached out to ABDO for assistance going forward. Anticipated Completion Date: 6/12/2026

View Audit 407264

Finding 1223789 (2024-006)

Material Weakness 2024

Wilkin County

MN

Allowable Costs / Cost Principles Reporting Internal Control / Segregation of Duties § 200.303 § 200.403

Finding Number: 2024-006 Finding Title: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Program: 93.778 Grants to States for Medicaid Name of Contact Person Responsible for Corrective Action: LaRae Kuhfal, Fiscal Officer and Deb Sjostrom, Director. Corrective Action P...

Finding Number: 2024-006 Finding Title: Activities Allowed or Unallowed, Allowable Costs/Cost Principles, and Reporting Program: 93.778 Grants to States for Medicaid Name of Contact Person Responsible for Corrective Action: LaRae Kuhfal, Fiscal Officer and Deb Sjostrom, Director. Corrective Action Planned: LaRae has taken over the report starting with quarter 4 of 2025 and is keeping all records used for the LCTS report. We plan to make sure that the quarterly reports are reviewed and approved by the director. Anticipated Completion Date: Completed as of quarter 4, 2025 and continuing.

View Audit 407264

Finding 1223788 (2024-008)

Material Weakness 2024

Wilkin County

MN

Procurement, Suspension & Debarment § 200.303

Finding Number: 2024-008 Finding Title: Suspension and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Tarah Yaggie Corrective Action Planned: We understand we need to look at sam.gov and will do so goin...

Finding Number: 2024-008 Finding Title: Suspension and Debarment Program: 21.027 COVID-19 – Coronavirus State and Local Fiscal Recovery Funds Name of Contact Person Responsible for Corrective Action: Tarah Yaggie Corrective Action Planned: We understand we need to look at sam.gov and will do so going forward. Anticipated Completion Date: 6/12/2026

View Audit 407264

Finding 1223787 (2024-007)

Material Weakness 2024

Wilkin County

MN

Eligibility Material Weakness Internal Control / Segregation of Duties § 200.303

Finding Number: 2024-007 Finding Title: Eligibility – MAXIS Program: 93.778 Grants to States for Medicaid Name of Contact Person Responsible for Corrective Action: Cindy Noetzelman Corrective Action Planned: Cases have been corrected and there was a discussion with staff on the process and the need ...

Finding Number: 2024-007 Finding Title: Eligibility – MAXIS Program: 93.778 Grants to States for Medicaid Name of Contact Person Responsible for Corrective Action: Cindy Noetzelman Corrective Action Planned: Cases have been corrected and there was a discussion with staff on the process and the need for correct entries. We will continue to review at monthly staffing meetings to ensure correct procedures continue to be followed. Anticipated Completion Date: Cases have been corrected as of Dec 31, 2025

View Audit 407264

Finding 1223786 (2024-003)

Material Weakness 2024

City of Santa Maria

CA

Procurement, Suspension & Debarment

U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend the City perform suspension and debarment procedures on all vendors with which it plans to enter into a covered transaction and maintain the documentation as evi...

U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Funds - Assistance Listing No. 21.027 Recommendation: We recommend the City perform suspension and debarment procedures on all vendors with which it plans to enter into a covered transaction and maintain the documentation as evidence that the requirement was fulfilled. Action planned/taken in response to the finding: The Finance Department will ensure that all departments are aware of this compliance requirement and perform vendor verification before the City enters into a covered transaction. All departments will verify and have a printout of the vendor verification printed from SAM.GOV that an entity is not debarred, suspended, or otherwise excluded before the City enters into a covered transaction. Name(s) of the contact person(s) responsible for corrective action: Rebecca Campbell, Finance Director Planned completion date for corrective action plan: July 2026 If the State Controller’s Office has questions regarding this plan, please call Rebecca Campbell, Finance Director, at 805-925-0951.

View Audit 407251

Finding 1223784 (2024-002)

Material Weakness 2024

City of Santa Maria

CA

Subrecipient Monitoring Allowable Costs / Cost Principles Reporting § 200.303

U.S. Department of Housing and Urban Development Community Development Block Grant – Assistance Listing No. 14.218 Recommendation: We recommend the City implement policies and procedures to ensure that the Federal Funding Accountability and Transparency Act (FFATA) reporting occurs for all subawards...

U.S. Department of Housing and Urban Development Community Development Block Grant – Assistance Listing No. 14.218 Recommendation: We recommend the City implement policies and procedures to ensure that the Federal Funding Accountability and Transparency Act (FFATA) reporting occurs for all subawards of $30,000 or more for all federal awards and that the reporting be performed timely. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to the finding: The Finance Department will ensure that all departments are aware of this compliance requirement and ensure reporting requirements are performed timely in relation to subawards. Name(s) of the contact person(s) responsible for corrective action: Rebecca Campbell, Finance Director Planned completion date for corrective action plan: July 2026

View Audit 407251

Finding 1223769 (2024-005)

Material Weakness 2024

CENTER OF EXCELLENCE FOR EDUCATOR PREPARATION & INNOVATION, INC.

SC

Allowable Costs / Cost Principles Cash Management § 200.302 § 200.305 § 200.414

Root Cause Analysis: The root cause of this finding was a misapplication of the approved indirect cost rate to the appropriate Modified Total Direct Cost (MTDC) base in connection with drawdown calculations. Although The EPI Center had an approved indirect cost rate and related policy in place, the ...

Root Cause Analysis: The root cause of this finding was a misapplication of the approved indirect cost rate to the appropriate Modified Total Direct Cost (MTDC) base in connection with drawdown calculations. Although The EPI Center had an approved indirect cost rate and related policy in place, the operational procedures and system configurations necessary to consistently apply the methodology were still being refined and operationalized. The EPI Center notes that a formal, written Indirect Cost Rate Policy consistent with Uniform Guidance (2 CFR Part 200) was in place at the time of award. However, during the initial year of administering a federal award as fiscal agent, the procedures outlined in the policy were not fully operationalized. This resulted in a misapplication of the approved indirect cost rate. The overdraw resulted from applying the indirect cost rate to budgeted, rather than actual, direct expenditures. Management has since recalculated allowable indirect costs based on actual expenditures and has implemented enhanced controls to ensure accurate application of the MTDC base and compliance with federal requirements going forward. Response, with details: ☒Corrective Action Plan ☐Clarification Management acknowledges the misapplication of the approved indirect cost rate and has taken immediate steps to correct the calculation and ensure full alignment with federal requirements. Specifically, The EPI Center has recalculated indirect costs based on allowable expenditures within the Modified Total Direct Cost (MTDC) base and is actively engaging with the U.S. Department of Education to determine the appropriate resolution of the overdrawn amount. Management confirms that all underlying expenditures charged to the program were allowable, allocable, and supported by appropriate documentation, and no unallowable costs were identified. Corrective Actions Management has implemented the following corrective actions to address the issue and strengthen internal controls: 1. Training and Capacity Building (Completed - April 2026) Finance staff and senior leadership have completed targeted training on the application of indirect cost requirements under Uniform Guidance to reinforce compliance expectations. 2. Recalculation and Resolution of Overdraw (Implementation Initiated) The EPI Center has recalculated allowable indirect costs by applying the restricted 8 percent indirect cost rate for Teacher and School Leader Incentive Program (TSL) grants to actual expenditures incurred during the reporting period. The program officer has been informed of the miscalculation and resulting overdraw. The EPI Center will follow all applicable agency protocols upon receiving formal guidance from the U.S. Department of Education. Management is actively coordinating with the U.S. Department of Education to resolve the calculated overdraw and will comply with all agency guidance, including repayment of any amounts determined to be unallowable. Controls are now in place to ensure that all future drawdowns are calculated based on the approved indirect cost rate applied to the MTDC base and are subject to documented review prior to submission. 3. Standardized Indirect Cost Calculation Worksheets (Completed - April 2026) A standardized indirect cost calculation worksheet will be required and reviewed prior to approval of all drawdown requests. 4. Independent Oversight (Completed – June 2025) The EPI Center has engaged a third-party controller who will review and independently validate indirect cost calculations prior to submission, providing an added layer of oversight and control. Responsible Party: Finance and Compliance Manager, Third-party Controller, CEO Timeline for Completion: May 2026

View Audit 407243

Finding 1223768 (2024-004)

Material Weakness 2024

CENTER OF EXCELLENCE FOR EDUCATOR PREPARATION & INNOVATION, INC.

SC

Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles Significant Deficiency

Root Cause Analysis: The condition resulted from a lapse in the execution of an established control rather than the absence of a control framework. The EPI Center had formal memoranda of understanding in place with participating districts that defined match requirements, including in-kind contributi...

Root Cause Analysis: The condition resulted from a lapse in the execution of an established control rather than the absence of a control framework. The EPI Center had formal memoranda of understanding in place with participating districts that defined match requirements, including in-kind contributions of personnel time and effort, and contemplated periodic certification of those contributions. While the MOUs indicated that districts would confirm match contributions on a quarterly basis, The EPI Center did not consistently obtain those confirmations during the audit period. Since the audit period, The EPI Center has obtained written attestations from participating districts confirming the source and amount of the personnel contributions used as match and has implemented procedures to ensure that such certifications are collected and retained based on funder requirements. Response, with details: ☒Corrective Active Plan ☒Clarification 46 Management believes the match contributions reported are valid, reasonable, and allocable to the program. Match was calculated using verifiable district salary schedules and a consistently applied methodology (e.g., 25% effort allocation tied to program outcomes, participation, and service delivery). No evidence was identified indicating that federal funds were used to meet match requirements or that match contributions were applied to other federal programs. Importantly: There is no evidence that these salaries were charged to federal funds, mitigating the risk of double counting or supplanting. All personnel included as match were employees of public-school districts, whose compensation structures are governed by transparent, state- and locally- funded salary schedules. Services provided by these personnel supported program implementation and intended outcomes (e.g., coaching, mentoring, instructional support aligned with grant objectives). This finding reflects a documentation and control execution gap rather than a deficiency in the allowability or validity of match contributions. Corrective Actions The EPI Center has implemented, or is in the process of implementing, the following corrective actions to ensure full compliance moving forward: 1. Retroactive Certification (Completed - March 2026) Developed standardized district attestation forms for match contributions. Initiated collection of retroactive certifications from all participating districts to formally validate previously reported match. 2. Match Verification Process (Completed - April 2026) Established a certification process requiring district-level verification of match contributions. Management will align match verification with financial reconciliation and reporting in accordance with funder requirements. 3. Strengthened Partner Guidance and Agreements (Completed - April 2026) Updated MOUs and partnership agreement templates to include explicit federal documentation requirements for match that align to reporting requirements. Provided technical assistance to district partners to ensure consistent understanding and compliance. While the reported questioned cost exposure (approximately $3.4M) is acknowledged, The EPI Center notes that the condition relates to documentation rather than the underlying validity of the costs. There is no indication of unallowable costs, fraud, or misuse of funds, and no evidence that federal funds were used to meet match requirements. 47 All match contributions are based on public school district salary structures, which are subject to established oversight and accountability. Accordingly, the underlying match amounts are supported by objective and verifiable data sources. This finding reflects a documentation and timing matter, rather than concerns related to allowability, allocability, or program integrity. The EPI Center requests that this distinction be considered in assessing the overall severity and classification of the finding. Responsible Party: Project Lead, Finance Specialist Timeline for Completion: Ongoing with an expected completion date for all items by April 2026

View Audit 407243

Finding 1223767 (2024-003)

Material Weakness 2024

CENTER OF EXCELLENCE FOR EDUCATOR PREPARATION & INNOVATION, INC.

SC

Procurement, Suspension & Debarment § 200.214 § 200.327

Root Cause Analysis: During the initial startup phase of federal program implementation, The EPI Center utilized existing partner and vendor contract templates to support rapid program launch and continuity of services. At that time, procurement processes had not yet been fully centralized, and stan...

Root Cause Analysis: During the initial startup phase of federal program implementation, The EPI Center utilized existing partner and vendor contract templates to support rapid program launch and continuity of services. At that time, procurement processes had not yet been fully centralized, and standard federal contract provisions required under 2 CFR Part 200, Appendix II were not consistently incorporated across all agreements. This condition reflects a timing and process alignment issue during organizational scaling, rather than a lack of procurement oversight or intent to circumvent federal requirements. Response, with details: ☒Corrective Action Plan ☐Clarification The EPI Center conducted a comprehensive review of all contractors subject to testing and verified, through alternative procedures, that none were suspended or debarred (e.g., verification through SAM.gov and documented vendor validation processes). As a result, all costs associated with these contracts were determined to be allowable, reasonable, and allocable to the federal award. Importantly, the auditor confirmed that there were no questioned costs associated with this finding. Accordingly, this matter reflects a documentation and process alignment issue related to federal contract provisions rather than a deficiency affecting the allowability or eligibility of expenditures. Corrective Actions The EPI Center has taken immediate and proactive steps to strengthen procurement compliance and ensure full alignment with federal requirements: 1. Federal Contract Addendum (Implemented – April 2026) A standardized addendum incorporating all required provisions under 2 CFR Part 200, Appendix II has been developed and will be required for all applicable contracts upon Board approval. 2. SAM.gov Verification Embedded (Completed – February 2026) A formal suspension and debarment verification step has been incorporated into the procurement checklist, with documentation retained for audit purposes. Verification will be completed and retained in the procurement file prior to contract execution. 3. Centralized Contract Approval Workflow (Implementation Initiated) A revised procurement and contract approval process has been implemented to ensure all agreements undergo centralized review for federal compliance prior to execution. The revised process will be submitted to the Board for approval April 23, 2026. 45 4. Procurement Process Standardization (Implementation Initiated) Templates and procedures have been updated to ensure consistent inclusion of required federal clauses across all applicable vendor agreements. Management revised its processes upon becoming aware of these matters and created systems to ensure compliance going forward. The revised procurement protocol will be submitted to the Board for approval April 23, 2026. Management emphasizes the following validated conclusions: ● Auditor confirmed $0 questioned costs ● All vendors were verified as eligible and not debarred ● All expenditures were allowable, reasonable, and properly supported Accordingly, this finding represents a documentation and process standardization matter rather than a deficiency in allowability, eligibility, or financial integrity. Responsible Party: Project Lead, Finance Specialist, Finance and Compliance Manager Timeline for Completion: April 2026

View Audit 407243

Finding 1223731 (2024-007)

Material Weakness 2024

CITY OF WAYNOKA

OK

Management is taking steps to improve the timeliness of financial reporting and audit completion by establishing internal deadlines for year-end close and audit preparation. Responsbilities for key tasks are being clearly assigned, and progress toward completion will be monitored regularly by manage...

Management is taking steps to improve the timeliness of financial reporting and audit completion by establishing internal deadlines for year-end close and audit preparation. Responsbilities for key tasks are being clearly assigned, and progress toward completion will be monitored regularly by management and reported to the City Council. Whyle the City has experienced delays due to prior years backlogs, management is actively working to bring all audits current and epects improved timeliness in future reporting periods.

View Audit 407239

Finding 1223716 (2024-012)

Material Weakness 2024

CITY OF BLUE RIDGE

GA

Cash Management Reporting Matching / Level of Effort / Earmarking § 200.305

The City agrees with this finding and will train their project manager and/or department supervisor on the requirements of federal programs currently underway as well as require such training before a project commences in the future.

View Audit 407222

Finding 1223715 (2024-011)

Material Weakness 2024

CITY OF BLUE RIDGE

GA

Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.305

he City agrees with this finding. The delay in vendor payments resulted from the absence of formal written procedures governing the administration of federally funded projects and the responsibilities of project management staff. To address this finding, the City will develop and implement a compreh...

he City agrees with this finding. The delay in vendor payments resulted from the absence of formal written procedures governing the administration of federally funded projects and the responsibilities of project management staff. To address this finding, the City will develop and implement a comprehensive Project Management Policies and Procedures Manual establishing standardized processes for federal grant and loan administration, including cash management, documentation requirements, approval responsibilities, payment processing, and compliance with applicable federal regulations. The City will also require training for all employees and department supervisors responsible for administering federally funded projects before assuming project management responsibilities. Finance staff will monitor compliance with these procedures to help ensure timely payment of vendor invoices and adherence to federal cash management requirements.

View Audit 407222

Corrective Action Plans

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