Corrective Action Plans

Finding 1238524 (2025-001)

Material Weakness 2025

SC

HUD Housing Programs Eligibility Reporting

Corrective Action Plan Section III - Federal Award Findings and Questioned Costs Finding 2025-001 Name of Contact Person: Alissa Collington, Executive Director Corrective Action:Mangement will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediat...

Corrective Action Plan Section III - Federal Award Findings and Questioned Costs Finding 2025-001 Name of Contact Person: Alissa Collington, Executive Director Corrective Action:Mangement will review the recertification process and plan to monitor recertifications. Proposed Completion Date: Immediately

View Audit 413405

Finding 1238523 (2025-003)

Material Weakness 2025

Little River Band of Ottawa Indians

MI

Allowable Costs / Cost Principles Procurement, Suspension & Debarment

2025-003 – Eligibility for Purchased/Referred Care (PRC) Auditor Description of Condition and Effect: During our audit, we noted for one of forty health service selections, the Tribe was unable to provide the vendor invoice and check for a PRC service to support the amount paid and type of service t...

2025-003 – Eligibility for Purchased/Referred Care (PRC) Auditor Description of Condition and Effect: During our audit, we noted for one of forty health service selections, the Tribe was unable to provide the vendor invoice and check for a PRC service to support the amount paid and type of service the patient received. However, the Tribe was able to provide support for who the service was for and support that the particular individual was in fact eligible to receive such service under this grant program. As a result of this condition, the Tribe did not fully comply with the requirements of the Uniform Guidance and is exposed to an increased risk that future noncompliance could occur and not be prevented or detected by the Tribe's internal controls. Auditor Recommendation: We recommend that the Tribe implement necessary internal controls to ensure documentation of its compliance with the requirements of the Uniform Guidance is maintained. Corrective Action: Due to HIPPA Laws, accounting is creating a form to send to the Clinic with each AP check run for them to complete indicating that they have attached all documents to the check stub and filed in the correct client’s folder as well as indicating that the client is a member, or descendent. This report will be returned within 24 business hours to the accounting department for auditing records. Responsible Person: Judy Trucks Accounts Payable and in Clinic Gina Dahlke, or Ronda Koon Anticipated Completion Date: 12/31/2026

View Audit 413404

Finding 1238521 (2025-002)

Material Weakness 2025

City of Richmond

IN

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Material Weakness § 200.303 § 200.339

FINDING 2025-002 Finding Subject: Economic Development Cluster - Reporting Contact Person Responsible for Corrective Action: Tracy McGinnis Contact Phone Number and Email Address: tmcginnis@richmondindiana.gov 765-983-7222 Views of Responsible Officials: We concur with the finding. Description of Co...

FINDING 2025-002 Finding Subject: Economic Development Cluster - Reporting Contact Person Responsible for Corrective Action: Tracy McGinnis Contact Phone Number and Email Address: tmcginnis@richmondindiana.gov 765-983-7222 Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Management will ensure that the preparation and review internal controls process has been changed will be followed and thoroughly documented to detect and prevent material misstatements to the Revolving Loan Fund (RLF) reports. Anticipated Completion Date: The Controller and Deputy Controller and will review all current and past due reports and uploads to the appropriate site. The corrective action will take place immediately (Sept 2026). Note: the monthly reports are completed with each monthly receipts and closeouts and future reporting of the ED-209 will be processed and uploaded by the Deputy Controller bi-annually.

View Audit 413403

Finding 1238520 (2025-004)

Material Weakness 2025

Godman Guild Association and Subsidiaries

OH

Subrecipient Monitoring

Finding Number: 2025-04 Condition: Four out of five monthly invoices tested were identified as being submitted to the pass-through grantor after the required 15-day deadline. In addition, the April 2025 Program Outcome Report and Cumulative Payroll Report were not submitted. Planned Corrective Actio...

Finding Number: 2025-04 Condition: Four out of five monthly invoices tested were identified as being submitted to the pass-through grantor after the required 15-day deadline. In addition, the April 2025 Program Outcome Report and Cumulative Payroll Report were not submitted. Planned Corrective Action: The Association will make every reasonable effort to prepare, review, and submit required documentation within the deadlines established by the grant agreement. The Association will also work with the pass-through grantor to ensure that grant agreements and related reporting requirements are finalized and accessible in sufficient time to meet established deadlines. In instances where execution of the agreement or access to the grant reporting system is delayed by the grantor, the Association will document the circumstances and request written confirmation of any resulting changes to invoicing or reporting deadlines. Moving forward, the Godman Guild Association will request formal addenda from grantors to document any changes to invoicing deadlines or reporting requirements and will make every reasonable effort to secure these addenda. Contact Person Responsible for Corrective Action: Solonas Karoulla, Chief Advancement Officer, solo.karoulla@godmanguild.org Completion Date: December 31, 2026

View Audit 413395

Finding 1238518 (2025-003)

Material Weakness 2025

Godman Guild Association and Subsidiaries

OH

Subrecipient Monitoring § 200.303

Finding Number: 2025-03 Condition: For one of twenty-five participants selected for testing, the Association did not provide formal documentation demonstrating the participant’s eligibility for the program was determined in accordance with applicable program requirements. Planned Corrective Action: ...

Finding Number: 2025-03 Condition: For one of twenty-five participants selected for testing, the Association did not provide formal documentation demonstrating the participant’s eligibility for the program was determined in accordance with applicable program requirements. Planned Corrective Action: The Godman Guild Association has strengthened its existing eligibility documentation process by implementing an additional review to confirm that all required eligibility forms are complete, accurate, and retained for federally funded participants. The Enrollment Team, which manages the eligibility process at intake, is responsible for completing this review and ensuring required documentation is obtained and maintained. The Association will also conduct periodic reviews of participant files to identify and address any missing or incomplete documentation. Contact Person Responsible for Corrective Action: Solonas Karoulla, Chief Advancement Officer, solo.karoulla@godmanguild.org Completion Date: September 30, 2026

View Audit 413395

Finding 1238514 (2025-002)

Material Weakness 2025

Godman Guild Association and Subsidiaries

OH

Allowable Costs / Cost Principles Subrecipient Monitoring § 200.303 § 200.403

Finding Number: 2025-02 Condition: During the audit, it was noted that the Association was unable to provide formal support for the internal review and approval of costs relating to stipends paid that were submitted to the pass-through grantor under the major program. Planned Corrective Action: The ...

Finding Number: 2025-02 Condition: During the audit, it was noted that the Association was unable to provide formal support for the internal review and approval of costs relating to stipends paid that were submitted to the pass-through grantor under the major program. Planned Corrective Action: The Godman Guild Association has an existing process for reviewing and approving stipend payments. The Association has shored up existing processes by implementing a consistent documentation format that identifies the applicable participant and payment period and includes supporting participation records, the stipend calculation, and reviewer approval. As an additional internal review procedure, program participant listings submitted to grantors will be periodically reconciled to supporting enrollment and eligibility documentation to provide an additional level of oversight of participant eligibility and grant reporting. The Association will retain all documentation with the applicable grant records to maintain a consistent record of the review and approval process. Contact Person Responsible for Corrective Action: Solonas Karoulla, Chief Advancement Officer, solo.karoulla@godmanguild.org Completion Date: September 30, 2026

View Audit 413395

Finding 1238513 (2025-006)

Material Weakness 2025

Interstate Renewable Energy Council, Inc.

NY

Allowable Costs / Cost Principles Subrecipient Monitoring Cash Management § 200.430

Management Response: Management and the outsourced accounting firm will establish documented procedures to reconcile personnel costs included in reimbursement requests to actual allowable compensation costs. When budgeted or agreed-upon rates are used for billing, the outsourced accounting firm will...

Management Response: Management and the outsourced accounting firm will establish documented procedures to reconcile personnel costs included in reimbursement requests to actual allowable compensation costs. When budgeted or agreed-upon rates are used for billing, the outsourced accounting firm will perform periodic after-the-fact reconciliations to actual payroll and time-and-effort support and will identify any differences requiring adjustment. Management will review and approve the reconciliation before submission of subsequent reimbursement requests and will promptly adjust future billings or arrange repayment with the pass-through entity, as appropriate. Evidence of reconciliation, review, approval, and resolution of any excess reimbursement will be retained in the grant files. Management will also ensure that agreed-upon billing rates are documented in writing and maintained with the award support. Proposed Completion Date – October 01, 2026 Contact – Ronny Sandoval, Board Chair Email: ronnys@irecusa.org

View Audit 413394

Finding 1238512 (2025-005)

Material Weakness 2025

Interstate Renewable Energy Council, Inc.

NY

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.302 § 200.303

Management Response: Management will retain a complete support package for each Federal financial report, including the accounting records used at the time of preparation which will be provided by the outsourced accounting firm, the completed report, a reconciliation of reported amounts to the under...

Management Response: Management will retain a complete support package for each Federal financial report, including the accounting records used at the time of preparation which will be provided by the outsourced accounting firm, the completed report, a reconciliation of reported amounts to the underlying accounting records, and explanations for any reconciling items. The preparer will assemble and document the support package before submission. A knowledgeable individual other than the preparer, which may include management or the outsourced accounting firm, will review the report and reconciliation for completeness, accuracy, and consistency with award requirements. Evidence of review, approval, and resolution of any differences will be retained with the support of reporting. Management will also evaluate subsequent accounting adjustments to determine whether previously submitted reports require correction or follow-up with the Federal agency. Proposed Completion Date – October 01, 2026 Contact – Ronny Sandoval, Board Chair Email: ronnys@irecusa.org

View Audit 413394

Finding 1238511 (2025-004)

Material Weakness 2025

Interstate Renewable Energy Council, Inc.

NY

Cash Management § 200.303 § 200.305

Management Response: Management will formalize procedures requiring documented review and approval of each cash drawdown or reimbursement submission before submission. The preparer, which is intended to be someone from management will work with the outsourced accounting firm to assemble the supporti...

Management Response: Management will formalize procedures requiring documented review and approval of each cash drawdown or reimbursement submission before submission. The preparer, which is intended to be someone from management will work with the outsourced accounting firm to assemble the supporting documentation, including the reimbursement request or drawdown support, related cost detail, and any applicable reconciliations. The Organization intends 0to have either the head of Finance or CEO review the submission for completeness, accuracy, and compliance with award requirements, and will document approval through sign-off, email approval, or other retained evidence prior to submission. Evidence of review and approval will be maintained with the supporting documentation for each submission. Management and the outsourced accounting firm will monitor compliance with this process through periodic review of grant submission files. Proposed Completion Date – October 01, 2026 Contact – Ronny Sandoval, Board Chair Email: ronnys@irecusa.org

View Audit 413394

Finding 1238510 (2025-001)

Material Weakness 2025

County of Delaware, New York

NY

Eligibility

Name of Auditee: County of Delaware, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2025 CAP Prepared by: Roxanne Ellsworth, Director of Fiscal Affairs Phone: (607) 832-5090 (1) Audit Finding 2025-001 - Program Eligibility - Noncompliance (a)...

Name of Auditee: County of Delaware, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2025 CAP Prepared by: Roxanne Ellsworth, Director of Fiscal Affairs Phone: (607) 832-5090 (1) Audit Finding 2025-001 - Program Eligibility - Noncompliance (a) Implementation Plan of Actions - The County will determine eligibility over its programs. (b) Implementation Date - This will be implemented by December 31, 2026. (c) Persons Responsible for Implementation - The Director of Fiscal Affairs.

View Audit 413389

Finding 1238509 (2025-002)

Material Weakness 2025

County of Cambria, Pennsylvania

PA

Student Financial Aid Reporting

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support exist...

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department prioritized accuracy and completeness, ensuring required audit components were included. Please note: Reviewing the audit findings and reporting processes from FY2024 & FY2025 demonstrates a significant improvement in the department’s fiscal operations and compliance efforts as well as to ensure federal audit standard. The accounting team has shown a strong commitment to improving the accuracy, timeliness, and quality of fiscal reporting. Through increased oversight, enhanced monitoring of reporting deadlines, and ongoing collaboration with administrative staff, the department has strengthened its internal controls and reporting practices.

View Audit 413383

Finding 1238508 (2025-001)

Material Weakness 2025

County of Cambria, Pennsylvania

PA

Student Financial Aid Reporting

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support exist...

Cambria County has continued with the following actions which include: maintaining a list of reporting due dates for all fiscal and administrative staff; engagement of external consultants and temporary fiscal staff to support reporting functions if there is staff departure; retain and support existing County staff to maintain institutional knowledge until a dedicated competent Fiscal Officer who is invested in child welfare and county government employment is identified. The department will continue to ensure audit components are included for submissions. The department maintained and will continue communication with oversight entities to ensure transparency regarding reporting timelines, submission delays, fiscal status and corrective actions taken to uphold integrity. These delays were not due to negligence, but rather a strategic and collaborative effort to ensure accuracy and completeness of all required documentation. The department prioritized the integrity of submissions to meet federal audit standards and reimbursement eligibility. These submissions were completed to ensure compliance and to position the CYS department for improved timeliness in the 2025 audit year. The department prioritized accuracy and completeness, ensuring required audit components were included. Please note: Reviewing the audit findings and reporting processes from FY 2024 & FY 2025 demonstrates a significant improvement in the department's fiscal operations and compliance efforts as well as to ensure federal audit standard. The accounting team has shown a strong commitment to improving the accuracy, timeliness, and quality of fiscal reporting. Through increased oversight, enhanced monitoring of reporting deadlines, and ongoing collaboration with administrative staff, the department has strengthened its internal controls and reporting practices.

View Audit 413383

Finding 1238507 (2025-002)

Material Weakness 2025

Minot Housing Authority

ND

HUD Housing Programs

Contact Person Tom Alexander, Executive Director Corrective Action Plan The Authority will be more diligent in completing HQS quality control re-inspections on a sample of tenant units each year, as required. Completion Date Effective immediately

View Audit 413382

Finding 1238505 (2025-003)

Material Weakness 2025

Housing Authority of Trempealeau County

WI

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

Eligibility – Lack of Internal Controls Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We agree that implementing an independent review process will strengthen accuracy and compliance with Rural Development requirements. Actions t...

Eligibility – Lack of Internal Controls Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. We agree that implementing an independent review process will strengthen accuracy and compliance with Rural Development requirements. Actions taken or planned The organization will assign preparation and review of RD Form 3560-8 and HUD Form 50058 to different staff members. Anticipated completion date September 30, 2026

View Audit 413381

Finding 1238504 (2025-002)

Material Weakness 2025

Housing Authority of Trempealeau County

WI

Internal Control / Segregation of Duties

Segregation of Duties Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. Actions taken or planned The Board of Commissioners and management have reviewed the current duties of the Authority staff and segregated as much as possible wit...

Segregation of Duties Comments on findings and recommendations The organization concurs with the finding and the auditor’s recommendation. Actions taken or planned The Board of Commissioners and management have reviewed the current duties of the Authority staff and segregated as much as possible with limited staff. Additionally, the Authority contracts with a 3rd party fee accountant to reconcile the bank statements monthly ( in addition to the Executive Director). The Board of Commissioners receives and reviews the monthly disbursement listing. The Board of Commissioners will continue to monitor rental and cash flow activities reported by accounting personnel monthly. Anticipated completion date September 30, 2026

View Audit 413381

Finding 1238503 (2025-002)

Material Weakness 2025

National Fund for Excellence in American Indian Education

TX

Subrecipient Monitoring Procurement, Suspension & Debarment § 200.208 § 200.332 § 200.334 § 200.337 § 200.344

2025-002 – Subrecipient Monitoring Corrective action plan: 1. The subaward template was corrected in September 2026 and is in use. The corrected form was used for the subaward executed September 18, 2026 and carries the full set of federal award identification elements required by 2 CFR 200.332(b)(1...

2025-002 – Subrecipient Monitoring Corrective action plan: 1. The subaward template was corrected in September 2026 and is in use. The corrected form was used for the subaward executed September 18, 2026 and carries the full set of federal award identification elements required by 2 CFR 200.332(b)(1). 2. Obtain the current unique entity identifier for each subrecipient from SAM.gov and confirm it against subrecipient records. 3. Issue Modification No. 1 to each of the seven Round 1 subaward agreements, adding the Assistance Listing Number and title, the subaward budget period start and end dates, and the unique entity identifier where it was omitted, and issue an amended award notification supplying the same information for the Round 1 award made by award letter. Article IV, Section 6.11 of each subaward agreement permits NFEAIE to issue non-substantive modifications unilaterally in writing, so issuance is not contingent on subrecipient countersignature. Each modification will be transmitted to the subrecipient's authorized official and fiscal contact by email and the transmittal retained in the subaward file. 4. Issue Modification No. 1 on the same basis to Round 2 subawards R201 through R206, which were executed on the prior template. 5. Adopt a written subaward issuance procedure incorporating a checklist of the information required by 2 CFR 200.332(b)(1), completed, signed, and retained in the subaward file before execution, with CFO review of the executed instrument required before any disbursement. Personnel responsible for corrective action: Nicholas Cunningham, CFO Estimated corrective action completion date: November 30, 2026

View Audit 413380

Finding 1238501 (2025-001)

Material Weakness 2025

National Fund for Excellence in American Indian Education

TX

Cash Management Subrecipient Monitoring Allowable Costs / Cost Principles § 200.1 § 200.102 § 200.305

2025-001 – Cash Management Corrective action plan: 1. Remittance of $116,558.82 to the Department of Health and Human Services Payment Management System. Completed September 21, 2026. 2. Adopt a written cash management and drawdown procedure as an amendment to NFEAIE’s Financial Management Policies ...

2025-001 – Cash Management Corrective action plan: 1. Remittance of $116,558.82 to the Department of Health and Human Services Payment Management System. Completed September 21, 2026. 2. Adopt a written cash management and drawdown procedure as an amendment to NFEAIE’s Financial Management Policies and Procedures Manual, requiring that each request be limited to disbursements expected within a defined period not to exceed 45 days, that the request identify the disbursements it supports, that the Chief Financial Officer (CFO) approve the request before submission, that the request and its supporting schedule be retained in the award file, and that any direction from an awarding agency to draw on a different schedule, or any award term authorizing a different payment basis, be documented in writing and retained in the award file. 3. Amend the manual to assign the CFO responsibility for computing interest earned on federal advances not less than semiannually, to prescribe the allocation of interest between federal and non-federal funds where accounts are commingled, to apply the $500 annual retention threshold, to require the amount payable to the federal government to be recorded in the period earned, and to require remittance through the Payment Management System. Interest on federal advances is currently being accrued as a payable in the period earned, as reflected in journal entry JE-INT-2026H1 recorded at June 30, 2026, and will continue to be recorded on at least a semi-annual basis. 4. Evaluate holding federal advances in a separate account so that an allocation between federal and non-federal funds is not required, and implement if operationally feasible. 5. Present both procedures to the Finance Committee and the Board of Directors for adoption at the Board's fourth quarter 2026 meeting. Personnel responsible for corrective action: Nicholas Cunningham, CFO Estimated corrective action completion date: December 31, 2026

View Audit 413380

Finding 1238499 (2025-001)

Material Weakness 2025

Northwestern Illinois Community Action Agency

IL

Internal Control / Segregation of Duties

The finding identified during the FY2025 financial audit is a repeat finding from FY2024 related to material audit adjustments. NICAA began corrective action in response to the FY2024 finding; however, full implementation required additional time due to the transition from outdated accounting proces...

The finding identified during the FY2025 financial audit is a repeat finding from FY2024 related to material audit adjustments. NICAA began corrective action in response to the FY2024 finding; however, full implementation required additional time due to the transition from outdated accounting processes to a new financial management system and the need to ensure accurate grant reporting and system integration. Since the FY2024 financial audit, NICAA has made significant progress toward addressing the underlying causes of the finding. The agency has successfully implemented MIP as its new financial management and accounting system, replacing previous processes that contributed to inconsistencies in financial reporting. NICAA has also contracted with the Illinois Association of Community Action Agencies (IACAA) to provide fiscal technical assistance and support. IACAA is working with NICAA's fiscal team to develop and integrate accurate financial and grant reporting within the MIP system. This partnership is intended to strengthen financial reporting, improve grant-level tracking, and ensure reports generated through the new system meet the agency's financial management and oversight needs.

View Audit 413378

Finding 1238498 (2025-008)

Material Weakness 2025

Alpha Tower

OH

HUD Housing Programs

a. Finding 2025-008.

View Audit 413375

Finding 1238498 (2025-008)

Material Weakness 2025

Alpha Tower

OH

HUD Housing Programs

Waiting List

View Audit 413375

Finding 1238498 (2025-008)

Material Weakness 2025

Alpha Tower

OH

HUD Housing Programs

Condition:

View Audit 413375

Finding 1238498 (2025-008)

Material Weakness 2025

Alpha Tower

OH

HUD Housing Programs

In nine (9) out of nine (9) applicants/tenants selected for testing, there was no documentation provided, indicating that the tenant was placed on the waiting list.

View Audit 413375

Finding 1238498 (2025-008)

Material Weakness 2025

Alpha Tower

OH

HUD Housing Programs

(1) Comments on the Finding and Each Recommendation. Management concurs with the finding and the auditor’s recommendation that a waiting list be maintained in accordance with the guidelines established in the HUD Handbook 4350.3 REV..

View Audit 413375

Finding 1238498 (2025-008)

Material Weakness 2025

Alpha Tower

OH

HUD Housing Programs

(2) Actions Taken on the Finding.

View Audit 413375

Finding 1238498 (2025-008)

Material Weakness 2025

Alpha Tower

OH

HUD Housing Programs

Management concurs with the finding and the auditor's recommendation.

View Audit 413375

Corrective Action Plans

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