Corrective Action Plans

Finding 1156528 (2024-002)

Material Weakness 2024

Porter County

IN

Procurement, Suspension & Debarment

Contact Person Responsible for Corrective Action: Porter County Auditor Contact Phone Number: 219-465-3445 1.) Finding: Internal control material weakness associated with not completing the required Suspension & Debarment checks associated with vendors utilized within the ARPA federal program Views ...

Contact Person Responsible for Corrective Action: Porter County Auditor Contact Phone Number: 219-465-3445 1.) Finding: Internal control material weakness associated with not completing the required Suspension & Debarment checks associated with vendors utilized within the ARPA federal program Views of Responsible Official: County concurs with audit finding Description of Corrective Action Plan: County will collaborate with commissioner attorneys to include additional language confirming suspension and debarment checks to be confirmed by any entity signing a contract with the county. Anticipated Completion Date: 12/1/2025

View Audit 368878

Finding 1156527 (2024-003)

Material Weakness 2024

Sustainable Fisheries Partnership Foundation

HI

Procurement, Suspension & Debarment § 200.212 § 200.318

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends SFP perform suspension and debarment checks prior to entering into the covered transactions paid for with federal funding and to retain documentation evidencing that those checks were perfor...

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends SFP perform suspension and debarment checks prior to entering into the covered transactions paid for with federal funding and to retain documentation evidencing that those checks were performed timely. Increased training may help reinforce the polices and requirements regarding suspension and debarment checks and documentation retention. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SFP will ensure that suspension and debarment checks are conducted and documented as per the applicable regulations. SFP will ensure all relevant staff receive updated training on procurement policies, including suspension and debarment checks. Name(s) of the contact person(s) responsible for corrective action: Annie Haylon Planned completion date for corrective action plan: October 31, 2025

View Audit 368873

Finding 1156526 (2024-002)

Material Weakness 2024

Sustainable Fisheries Partnership Foundation

HI

Subrecipient Monitoring § 200.332

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends amending existing subaward agreements to include the award information required by CFR 200.332(b) and to verify all future subawards agreements include all necessary information prior to iss...

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends amending existing subaward agreements to include the award information required by CFR 200.332(b) and to verify all future subawards agreements include all necessary information prior to issuance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: SFP will revise its subaward agreement template to include all necessary award information as required by CFR 200.332(b). Name(s) of the contact person(s) responsible for corrective action: Annie Haylon Planned completion date for corrective action plan: October 31, 2025

View Audit 368873

Finding 1156525 (2024-001)

Material Weakness 2024

Sustainable Fisheries Partnership Foundation

HI

Cash Management Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties § 200.303

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence obtained and retained by SFP as proof of oversight of expenditure of federal funds. This could includ...

USAID Foreign Assistance for Programs Overseas – Assistance Listing No. 98.001 Recommendation: CLA recommends that additional emphasis of documentary evidence of approvals be made, and such evidence obtained and retained by SFP as proof of oversight of expenditure of federal funds. This could include: signatures on reports, emails indicating review and approval from appropriate individuals, retention of meeting agendas and minutes to corroborate that review occurred during the meetings, etc. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Effective immediately, the COO (or the Director of Finance, once hired) will conduct a documented review and written approval of all federal draw requests prior to submission to USAID. This review will be evidenced by either1. A signed and dated approval on the draw request form, or 2. A saved electronic record (e.g., email approval) in the grant’s shared compliance folder. SFP will also retain relevant meeting minutes or other supporting documentation demonstrating review in accordance with 2 CFR §200.303(a) requirements for internal controls. Name(s) of the contact person(s) responsible for corrective action: Anna Gabis Planned completion date for corrective action plan: October 31, 2025

View Audit 368873

Finding 1156518 (2024-001)

Material Weakness 2024

Tyonek Tribal Conservation District

AK

Cash Management Subrecipient Monitoring § 200.1 § 200.305

Federal Award Finding: 2024-001 Material Weakness in Internal Control over Cash Management Name and Contact Person: Laurie Stuart, Executive Director Corrective Action: The Organization has evaluated and revised the processes and procedures regarding cash management and reporting, in efforts to mini...

Federal Award Finding: 2024-001 Material Weakness in Internal Control over Cash Management Name and Contact Person: Laurie Stuart, Executive Director Corrective Action: The Organization has evaluated and revised the processes and procedures regarding cash management and reporting, in efforts to minimize the time elapsing between the transfer of funds from the awarding agency and disbursement by the Organization. The Organization also has processes in place for maintaining detailed records supporting all grant payments, disbursements to vendors, and tracking of grant advances still outstanding. Additionally, the Organization is monitoring interest earned on grant advances and has processes in place to remit interest as appropriate when required in accordance with Uniform Guidance. Management has appointed an individual to oversee these processes for each grant. Management will also submit a revised annual financial report [FFR] for USFWS Agreement No. F23AC02320 to correct any errors related to cash on hand amounts reported. Proposed Completion Date: December 31, 2025

View Audit 368872

Finding 1156516 (2024-002)

Material Weakness 2024

Kama'aina Care, Inc.

HI

Subrecipient Monitoring Reporting Significant Deficiency § 200.329

Management concurs with the finding and will ensure that records are maintained to indicate timely submission of reports.

View Audit 368868

Finding 1156515 (2024-001)

Material Weakness 2024

Texas Biomedical Research Institute

TX

Cash Management Subrecipient Monitoring § 200.303 § 200.305

Corrective Action Plan Year Ended December 31, 2024 Finding 2024-001 – Cash Management – Pass-Through Entities Condition: Texas Biomed Research Institute (Texas Biomed) did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by Texas Biomed within 30 days ...

Corrective Action Plan Year Ended December 31, 2024 Finding 2024-001 – Cash Management – Pass-Through Entities Condition: Texas Biomed Research Institute (Texas Biomed) did not provide evidence of effectively designed internal controls to ensure subrecipients are paid by Texas Biomed within 30 days of requests for reimbursement received by Texas Biomed. In 18 instances, Texas Biomed paid subrecipients after 30 days of receipt of the request for reimbursement from the subrecipient, resulting in noncompliance with 2 CFR 200.305(b)(3). Corrective Action Plan: Effective June 1, 2023 Texas Biomed implemented enhanced controls to ensure timely entry of subrecipient invoices into the financial system and timely approvals by Principal Investigators (PIs) of invoices. While these controls were operating effectively after the implementation date, turnover within the Accounts Payable team had not been anticipated and led to delayed payment processing. In mid-2024, Texas Biomed implemented a new electronic AP/invoice system as part of a comprehensive Enterprise Resource Planning system (and associated supporting systems) conversion to enhance efficiencies and functionality. With implementation of new systems, control enhancements enabled by the systems were implemented. This included setting up subawards as Purchase Orders, which enabled automation of a previously manual process to secure PI approval of invoices. Accounts Payable staff have been trained on how to properly enter subaward invoices into the system to trigger electronic routing to the PI for approval. While these steps will streamline the approval process, a further mitigating control will be implemented, with Accounts Payable staff periodically tracking approvals of pending subrecipient invoices and notifying the appropriate Sponsored Program Administrator for follow up with PIs in the event of delayed approvals. Responsible Parties: Eva Zepeda, Director, Finance; Michelle Hyde, Controller Completion Date: September 30, 2024

View Audit 368866

Finding 1156514 (2024-002)

Material Weakness 2024

Texas Biomedical Research Institute

TX

Questioned Costs Procurement, Suspension & Debarment § 200.1 § 200.303 § 200.317 § 200.318 § 200.319

Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texa...

Finding 2024-002 – Procurement and Suspension and Debarment Condition: Texas Biomed did not comply with procurement requirements per the Uniform Guidance. Specifically, Texas Biomed did not comply with informal procurement methods for small purchases and noncompetitive procurement requirements. Texas Biomed also did not comply with its own procurement policy in relation to procurements of small purchases and noncompetitive procurements. Additionally, Texas Biomed did not maintain records for certain procurements sufficient to detail the history of procurement, including the rationale for the method of procurement, selection of contract type, contractor selection or rejection, the basis for the contract price, and the performance of a cost or price analysis, when required. Three of the four procurements noted as findings were, in fact, sole source procurements but lacked timely documentation of sole source rationale. Corrective Action Plan: Texas Biomed made a change in management over the procurement function and hired an experienced and knowledgeable Assistant Director of Supply Chain Management on September 15, 2025 to oversee procurement and ensure compliance with the necessary requirements. To ensure compliance and adherence to purchasing policies and procedures, Texas Biomed will introduce a Purchasing Compliance Program. This program will include training and oversight procedures for the purchasing program. The training will include: new hire training, ongoing quarterly purchasing training for end users and purchasing staff. The purchasing team will maintain training documents and ensure new and existing employees have the most current policy, procedures, and requirements to guide them through the purchasing process. The oversight procedures will be performed by the Assistant Director of Supply Chain Management and shall include auditing purchase orders over the micro-purchase threshold to ensure proper documentation is present. The Assistant Director of Supply Chain Management will also lead efforts of continuous improvement to update and communicate the Purchasing Compliance Program to all Texas Biomed staff. Key dates shall include: • Enhanced new hire training October 2025 • Quarterly training session January 2026 • Oversight procedures developed November 2025 Responsible Parties: Eva Zepeda, Director, Finance; Eric McGowin, Assistant Director, Supply Chain Management Completion Date: October 31, 2025

View Audit 368866 Questioned Costs: $1

Finding 1156504 (2024-001)

Material Weakness 2024

Romulus Housing Commission

MI

Questioned Costs Subrecipient Monitoring Eligibility

Report period: 12/31/2024 Title of result and comment FY24 Audit Corrective Action Plan Contact person Responsible for Sabrina Bollinger Corrective Action: Contact's Phone Number 248-593-4611 Contact's Email Address: sbollinger@fourmidable,com Views of Responsible Official: Management agrees with th...

Report period: 12/31/2024 Title of result and comment FY24 Audit Corrective Action Plan Contact person Responsible for Sabrina Bollinger Corrective Action: Contact's Phone Number 248-593-4611 Contact's Email Address: sbollinger@fourmidable,com Views of Responsible Official: Management agrees with the auditor's finding and will implement the auditor's recommendations. Description of Corrective Action Plan The Commission should implement internal controls over tenant files to ensure accountability. Allcertifications and the required documentation should be maintained in the tenant's current file. Additionally,in order to ensure certifications are performed timely and tenant information is input correctly, theCommission should have a second party review files in a timely manner. Anticipated Completion Date: The plan is to implement the corrective action within six months of the audit date. If applicable: Document reason issue will NOT be corrected with 6 months: N/A

View Audit 368862 Questioned Costs: $1

Finding 1156503 (2024-002)

Material Weakness 2024

City of Tacoma

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

Subrecipient Monitoring and Suspension & Debarment. Neighborhood & Community Services (NCS) has existing processes to ensure subrecipient monitoring requirements and suspension and debarment requirements. While not all JAG subrecipients had previously been included, beginning in 2025, all subrecipie...

Subrecipient Monitoring and Suspension & Debarment. Neighborhood & Community Services (NCS) has existing processes to ensure subrecipient monitoring requirements and suspension and debarment requirements. While not all JAG subrecipients had previously been included, beginning in 2025, all subrecipients of JAG funding are being included in NCS processes. Specifically, one position (Contract/Program Auditor) is assigned to each contract and is responsible for verifying and documenting suspension and debarment at award and at the annual renewal and also for ensuring monitoring is completed. Prior to the audit, NCS had begun scheduling with the subrecipient that had not been monitored, consistent with NCS processes. NCS is currently also developing a grant handbook to ensure that all staff are aware of general and specific grant requirements and processes for managing grants. Procurement. The City’s procurement policies and procedures outline the process for the competitive procurement of services using federal funds, in alignment with federal regulations. However, the City acknowledges that certain aspects of the current policies maybe unclear or inconsistence with existing procedures. Additionally, the City recognizes that its internal controls are not fully effective in ensuring that all departments consistently comply with these policies and procedures. To strengthen internal control, the City will revise its procedure and develop and implement training around federal grants for staff responsible for managing or overseeing these contracts.

View Audit 368860

Finding 1156500 (2024-001)

Material Weakness 2024

City of Tacoma

WA

Subrecipient Monitoring

To meet Federal Funding and Transparency Act (FFATA) reporting requirements, the City will take the following actions: Update training material for all accounting staff and City departments managing federal grants. Update and distribute monthly email to departments to clarify the required informatio...

To meet Federal Funding and Transparency Act (FFATA) reporting requirements, the City will take the following actions: Update training material for all accounting staff and City departments managing federal grants. Update and distribute monthly email to departments to clarify the required information for FFATA filing and require responses with supporting documentation for review. If responses are not received in a timely manner, a second email will be sent to those individuals, requiring an immediate action. Periodically review federal reporting requirements for any updates and adjust the reporting process as needed, utilizing resources such as the State Auditor’s Office (SAO) Newsletter, conferences, and trainings.

View Audit 368860

Finding 1156495 (2024-001)

Material Weakness 2024

Serve Wyoming, Inc.

WY

Questioned Costs

Implemented corrective actions and updated internal procedures, as outlined in the financial management section of the handbook. Staff have received additional training on proper disbursement procedures, coaching and monitoring. In addition, a full review of all checks for FY25 have been completed a...

Implemented corrective actions and updated internal procedures, as outlined in the financial management section of the handbook. Staff have received additional training on proper disbursement procedures, coaching and monitoring. In addition, a full review of all checks for FY25 have been completed and noted. Going forward, checks will be prepared and submitted to the Executive Director in two expense batches prior to processing by the indepdendent bookkeeper. An additional control step has also been added to the Executive Director's review, requiring the indvidual mailing the checks to verify the presence of two signatures.

View Audit 368857 Questioned Costs: $1

Finding 1156494 (2024-002)

Material Weakness 2024

Cambridge Housing Authority

MA

HUD Housing Programs

Management will document its’ review of the utility allowances annually for each category and will adjust its allowance schedule with an effective date of January 1st for each calendar year.

View Audit 368854

Finding 1156493 (2024-001)

Material Weakness 2024

Cambridge Housing Authority

MA

HUD Housing Programs

Management will re-emphasize its staff and document on new admissions that rent reasonableness was properly determined prior to lease-up.

View Audit 368854

Finding 1156488 (2024-002)

Material Weakness 2024

Transform 1012 N. Main Street

TX

Reporting Significant Deficiency Internal Control / Segregation of Duties

2. In response to Finding 2024-002: Reporting – significant deficiency in internal controls over compliance Economic Development Initiative, Community Project Funding and Miscellaneous grants, please note the following: Cause of Internal Control Issue: Transform 1012’s grant reporting procedures inc...

2. In response to Finding 2024-002: Reporting – significant deficiency in internal controls over compliance Economic Development Initiative, Community Project Funding and Miscellaneous grants, please note the following: Cause of Internal Control Issue: Transform 1012’s grant reporting procedures included a verbal approval of reports and therefore, management approval could not be confirmed or reperformed. The effect of this is that bi-annual reporting was not fully documented in accordance with internal control procedures over compliance. Actions To Rectify Internal Control Issue: Management’s Response: Carlos Gonzalez-Jaime, Executive Director, will ensure his written documentation of review and approval of all grant reports is kept on file by using electronic signature to indicate review and approval and storing signed copies of the documentation. • This will be completed by October 31, 2025, for 2025 reports through October 31, 2025. Going forward, signed documentation will be stored within seven days of the report being issued.

View Audit 368849

Finding 1156487 (2024-001)

Material Weakness 2024

Lynchburg Community Action Group, INC

VA

CLIENT TO PROVIDE

View Audit 368846

Finding 1156486 (2024-001)

Material Weakness 2024

The George E. Brown United States-Mexico Foundation for Science

DC

Matching / Level of Effort / Earmarking

The Foundation pursued legal action because the way in which the IMPI withdrew from our agreement was found to be illegal. The Mexican court agreed with our position, and by the end of 2021, the Foundation had received a favorable resolution on the 2020 lawsuit. This led to initial meetings with IMP...

The Foundation pursued legal action because the way in which the IMPI withdrew from our agreement was found to be illegal. The Mexican court agreed with our position, and by the end of 2021, the Foundation had received a favorable resolution on the 2020 lawsuit. This led to initial meetings with IMPI's renewed top management, but unfortunately, we were unable to reset the funds. In June 2022, the Foundation formally requested that the IMPI reset the funds in order to continue functioning under the agreement, as a legally developed addendum had been created to supplement the original agreement. There were hectic changes in top management at the Mexican Ministry of Economy and the IMPI in 2022, resulting in unproductive efforts from previous negotiations. Then, in July 2023, the Foundation submitted a second lawsuit to enforce the one won in 2021, which was accepted by the court. On 13 September 2024, the Foundation was notified by the court of a favorable resolution regarding this second lawsuit. The IMPI still has one final opportunity to contest this resolution, although the probability of changing the outcome is minimal. Consequently, the Foundation's executives and its Board of Governors resumed communication with the IMPI's legal team to accelerate the resetting of the funds and the collaboration agreement. This was unsuccessful. Although the final ruling generally favored the Foundation, FUMEC filed a direct appeal for constitutional protection, claiming that the returns generated should not be limited to December 2022 but should instead be accumulated and calculated until IMPI actually made the payment; that is, until the month of 2024 in which IMPI complied with the ruling handed down on July 1, 2024. The court revoked the contested trial of July 1, 2024, and issued a new ruling, reiterating the considerations regarding the period and the amounts that IMPI is obliged to pay to FUMEC, in order to fully restore FUMEC's infringed subjective right. In compliance with this ruling, on September 8, 2025, the court issued a new ruling considering that the Collaboration Agreement was still in force and that IMPI had not demonstrated that it had fulfilled its obligations. Consequently, and reiterating its previous ruling, the court granted IMPI a period of no more than four months to comply with the Collaboration Agreement. IMPI was therefore required to reimburse the principal funds of $5 million USD to FUMEC’s endowment and pay the returns due for the period from August 2020 to May 2024. Proposed completion date – 2Q2026. Contact person – Eugenio Marin, Executive Director

View Audit 368844

Finding 1156484 (2024-001)

Material Weakness 2024

Northwest Youth Services

WA

Questioned Costs Special Tests & Provisions Subrecipient Monitoring

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this pol...

Corrective Action:  Housing service leadership staff have developed a HUD‐compliant Rent Reasonableness Policy to ensure that each lease served through NWYS will have documentation supporting compliance with federal reasonable rental rates. NWYS housing service leadership staff will follow this policy and procedure to ensure rental rates fall within federal grant compliance requirements at the time of each lease signing or renewal. Documentation of rent reasonableness certification will be performed by NWYS housing staff, reviewed by NWYS housing service leadership, and maintained in the client’s permanent file, as defined in the NWYS Rent Reasonableness Policy. Name(s) of Responsible Party:  NWYS Housing leadership staff – Luis Reyna, Addison Ausley, Daniel Pry Anticipated Completion Date:  9/5/25

View Audit 368841 Questioned Costs: $1

Finding 1156482 (2024-007)

Material Weakness 2024

Mission Edge San Diego

CA

Allowable Costs / Cost Principles

Condition Found During allowable cost testing, we noted that there was a lack of internal control over allowable costs. We noted items that did not include proper support, were outside the contract period, or were for the incorrect amount. Corrective Action Plan Continue to verify for every federal ...

Condition Found During allowable cost testing, we noted that there was a lack of internal control over allowable costs. We noted items that did not include proper support, were outside the contract period, or were for the incorrect amount. Corrective Action Plan Continue to verify for every federal charge: allowability, allocability, reasonableness, consistent treatment, and compliance with period of performance. Require source documentation supporting the nature, amount, and purpose. Responsible Person for Corrective Action Plan The Controller for Mission Edge San Diego and Accounting personnel. Implementation of Corrective Action Plan Policy adoption within 30 days of report. Management’s Statement of Concurrence Mission Edge concurs with the findings and has initiated the corrective actions described herein. Management is committed to timely implementation, continuous monitoring, and transparent communication with the pass-through entity, federal agencies, and auditors as required.

View Audit 368823

Finding 1156481 (2024-006)

Material Weakness 2024

Mission Edge San Diego

CA

Questioned Costs Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Condition Found During allowable cost testing, it was noted that one of the contracts with the vendors included a rate that exceeded the rate cap without prior approval. Upon inquiry no prior approval was obtained. Corrective Action Plan Before execution, route all vendor and subrecipient agreements...

Condition Found During allowable cost testing, it was noted that one of the contracts with the vendors included a rate that exceeded the rate cap without prior approval. Upon inquiry no prior approval was obtained. Corrective Action Plan Before execution, route all vendor and subrecipient agreements funded by federal awards to Controller/Accounting for verification of allowability, rate caps, prior approvals, and special terms. Additional review during the A/P process ensures compliance. Responsible Person for Corrective Action Plan The Controller for Mission Edge San Diego and Accounting personnel. Implementation of Corrective Action Plan Policy adoption within 30 days of report.

View Audit 368823 Questioned Costs: $1

Finding 1156480 (2024-005)

Material Weakness 2024

Mission Edge San Diego

CA

Questioned Costs Procurement, Suspension & Debarment

During procurement testing, it was noted that Mission Edge did not follow 2 CFR 200 required methods of procurement or its internal procurement policy for the purchase of goods or services using federal funds. Mission Edge did not obtain quotes or bids for certain expenditures as required by its pro...

During procurement testing, it was noted that Mission Edge did not follow 2 CFR 200 required methods of procurement or its internal procurement policy for the purchase of goods or services using federal funds. Mission Edge did not obtain quotes or bids for certain expenditures as required by its procurement policy. In addition, Mission Edge did not verify that vendors were not suspended, debarred, or otherwise excluded from participation in the program. Corrective Action Plan Review and confirm that each Project has Adopted a Uniform Procurement Policy. This policy will address: 1. Micro-purchases, small purchases, sealed bids, competitive proposals, noncompetitive proposals thresholds and methods. 2. Cost/price analysis for procurements above the Simplified Acquisition Threshold. 3. Ensure consistent applicability to fiscally sponsored projects. 4. Mandatory Debarment/Suspension Checks utilizing SAM.gov for all covered transactions and attached required verification to covered transactions. Responsible Person for Corrective Action Plan The Controller of Mission Edge San Diego (policy owner); Project Directors as applicable. Implementation of Corrective Action Plan Policy adoption within 30 days of report.

View Audit 368823 Questioned Costs: $1

Finding 1156479 (2024-001)

Material Weakness 2024

Grupo Nexos, Inc.

PR

Responsible Entity: Grupo Nexos, Inc. – Finance Department and Program Management Condition Reported: Late submission of Federal Financial Reports (SF-425), Quarterly Financial Status Reports, and subaward reports under the Federal Funding Accountability and Transparency Act (FFATA) for the followin...

Responsible Entity: Grupo Nexos, Inc. – Finance Department and Program Management Condition Reported: Late submission of Federal Financial Reports (SF-425), Quarterly Financial Status Reports, and subaward reports under the Federal Funding Accountability and Transparency Act (FFATA) for the following programs:  93.297 Adolescent Pregnancy Prevention Program (PROSa)  93.310 Trans – NIH Research Support Program Identified Cause:  Lack of internal monitoring procedures to ensure compliance with submission deadlines.  Resignation of the authorized staff responsible for submitting FFATA reports and delays in obtaining access to the SAM platform. Corrective Actions to be Implemented: Designation of Responsible Parties: o Develop a formal process to monitor the preparation, review, and submission of all financial and subaward reports, designating a responsible person for each activity and establishing backups to ensure operational continuity.  Compliance Calendar: o Implement an electronic calendar with the due dates of FFRs, quarterly reports, and FFATA submissions, with automated alerts 15 and 7 days prior to the deadlines.  Internal Review and Approval: o Require review and approval by the Chief Financial Officer prior to the submission of any report. Staff Training: o Provide annual training for finance and program staff on reporting requirements under 2 CFR 200 and FFATA.  Documentation and Filing: o Maintain evidence of submission and acknowledgments of receipt of all reports in a centralized electronic file accessible for future audits. Estimated Implementation Date: All actions will be fully implemented no later than December 31, 2025.

View Audit 368820

Finding 1156477 (2024-002)

Material Weakness 2024

Lifewire

WA

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Subrecipient Monitoring § 200.303 § 200.430

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underly...

Corrective Action: After receiving finding 2023-005 in mid-2024, LifeWire implemented a procedure wherein staff were required to attest to their percentages of time worked to LifeWire’s various contracts. Unfortunately, this procedure is heavily manual, and a small number of the calculations underlying the attestations were erroneous. In addition, LifeWire was not able to secure an attestation from a former employee before they departed the organization. In 2025, LifeWire is revising their attestation procedure such that contract-supported staff members will attest to the nature of their work instead of amounts of time to contracts. This will simplify the administrative burden of attestations and reduce opportunities for errors while still meeting our audit and contract funders’ requirements. We anticipate this revised method will be rolled out by the end of Q3-2025. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: Procedure rollout will be completed by the end of Q3-2025. Anticipated full compliance with the requirement will be in evidence through the end of 2025 and beyond.

View Audit 368819

Finding 1156474 (2024-001)

Material Weakness 2024

Lifewire

WA

Subrecipient Monitoring HUD Housing Programs Reporting § 200.303

Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental...

Rent Reasonableness forms for rental payments made with CoC funds were not always completed in a timely fashion. Additionally, there was inadequate evidence of internal review and approval. In late 2024, LifeWire’s Controller began requiring Rent Reasonableness forms to be provided with every rental payment request made with public funds. LifeWire’s AP approval process requires review and approval by members of the Director team before payments can be issued. In 2025, all rental payments made with CoC funds now have documented evidence of internal approval and review. Name of Responsible Individual(s): E. Jeannette Biffle, Controller Anticipated Completion Date: The new process was rolled out in November 2024.

View Audit 368819

Finding 1156471 (2024-001)

Material Weakness 2024

Emergency Food Network of Tacoma and Pierce County

WA

Questioned Costs Matching / Level of Effort / Earmarking Allowable Costs / Cost Principles § 200.430

U.S. Department of Agriculture Food Distribution Cluster - The Emergency Food Assistance Program - Assistance Listing No. 10.565, 10.568, 10.569 Recommendation: We recommend that EFN incorporate a system of internal controls that clearly documents the time and effort that each individual employee sp...

U.S. Department of Agriculture Food Distribution Cluster - The Emergency Food Assistance Program - Assistance Listing No. 10.565, 10.568, 10.569 Recommendation: We recommend that EFN incorporate a system of internal controls that clearly documents the time and effort that each individual employee spends on each grant per month. This can be done by tracking and recording the actual hours each employee, regardless of position, spends working on each grant, on their time sheet or with a specific grant code, that specifies how many hours per day were spent on each federal and nonfederal activity. Alternatively, EFN can implement an after-the-fact review procedure to ensure the proper allocation of payroll expenditures to Federal and non-Federal awards, in accordance with 2 CFR 200.430. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Emergency Food Network (EFN) engaged a new audit firm for the 2024 audit. Before this year the EFN audit was administered by Johnson, Stone Pagano for 9 years. No deficiencies were previously reported or identified during those audits regarding time estimates for employees used for allocations including most of those specifically identified funding sources. In response to the 2024 audit finding by Clifton Larson Allen (CLA) in July of 2025, when the audit was conducted, EFN implemented an immediate individual employee time study that was approved by CLA to meet the recommendation. This time study methodology will be implemented twice per year on an ongoing basis with records retained and available for future audit verification. EFN has received written response from CLA that implementing this method meets all the requested requirements to be in compliance and mitigate future findings on this issue. Name of the contact person responsible for corrective action: Michelle Douglas, CEO Planned completion date for corrective action plan: August 2025 If anyone has questions regarding this plan, please call Michelle Douglas, CEO, at 253-208- 2962.

View Audit 368815 Questioned Costs: $1

Corrective Action Plans

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