Corrective Action Plans

Finding 1191809 (2025-002)

Material Weakness 2025

Government of Puerto Rico Department of Corrections and Rehabilitation

PR

The DCR's management acknowledged the delay in preparing and retaining OP-15 documentation and stated that the Department's immediate priority was to ensure that employees received their authorized salary increases in a timely manner. To address this priority, management updated the internal payroll...

The DCR's management acknowledged the delay in preparing and retaining OP-15 documentation and stated that the Department's immediate priority was to ensure that employees received their authorized salary increases in a timely manner. To address this priority, management updated the internal payroll database by developing an electronic listing of affected employees and implementing approved salary changes directly within the system. Management indicated that this approach ensured that employees were compensated in accordance with approved salary adjustments, although the supporting documentation in personnel files lagged behind. Management further indicated that corrective efforts are currently underway to address a more recent, similar personnel action involving fewer than 50 employees and that, upon completion, the Department intends to proceed with preparing the OP-15 forms related to the broader population of over 4,000 employees. Management expects to complete the preparation and filing of the outstanding OP-15 documentation prior to the end of fiscal year 2026.

View Audit 395624

Finding 1191808 (2025-003)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management a...

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-003 Compliance Finding - Eligibility Views of Responsible Officials Management acknowledges the eligibility determination error involving a two-unit dwelling and agrees that eligibility verification procedures were not sufficiently applied in accordance with DOE requirements for multiunit properties. The Organization takes this finding seriously and is committed to strengthening controls to prevent recurrence. The Organization is actively working with the pass-through entity to resolve the questioned costs of $4,048.39 and will repay any disallowed costs as required. Corrective Action Plan 1. Multi-Unit Eligibility Control Protocol A new Multi-Unit Eligibility Determination Checklist has been implemented requiring: • Individual income verification for each unit • Calculation worksheet demonstrating compliance with: o 66% rule, OR o 50% rule (where applicable), OR o HUD categorical eligibility per WPN 22-5 • Written supervisory approval prior to job authorization No multi-unit property may proceed to audit or production until eligibility documentation is approved. 2. Pre-Service Supervisory Approval Requirement • All multi-unit eligibility determinations must be reviewed and signed by: o Will Eberle (Weatherization Director) • Documentation must be verified before work order issuance. This adds a preventive control prior to expenditure of funds. 3. Executive Oversight Review • Will Eberle (Weatherization Director) will receive a monthly eligibility compliance report. • Any exceptions will trigger immediate review. • Quarterly summary reporting will be presented to senior leadership. 4. Targeted Eligibility Training • Staff will complete focused training on: o DOE WAP multi-family eligibility requirements o Income documentation standards o HUD categorical eligibility • Training will be conducted within 45 days and annually thereafter. • Attendance logs and materials will be maintained by Scott Hall. 5. File Audit & Continuous Monitoring • Will Eberle (Weatherization Director) will conduct monthly random sampling of: o 100% of multi-unit approvals for the next 6 months o Minimum 20% thereafter • Findings will be documented and tracked. 6. Resolution of Questioned Costs • The Organization is in communication with the pass-through entity regarding the $4,048.39 in questioned costs. • Repayment will occur promptly if required. • A repayment tracking file will be maintained by finance and reviewed by Chris Locarno. Implementation Timeline Summary Action, Responsible Party, Completion Target: Multi-unit checklist implemented, Scott Hall, Completed Supervisory sign-off requirement, Scott Hall, Immediate Staff eligibility training, Scott Hall, Within 45 days Executive reporting framework, Chris Locarno Completed Monthly sampling audits, Will Eberle, Ongoig Resolution of questioned costs WX Finance / Chris Locarno, Within 90 days Statement of Commitment The Organization is committed to restoring and maintaining full compliance with all federal and state Weatherization program requirements. Leadership, including, but not limited to: Will Eberle (Weatherization Director), Scott Hall (Weatherization Associate Director), and Chris Locarno (Business Manager), has implemented structural safeguards, enhanced supervisory review, and reinforced a culture of compliance and accountability to ensure that these deficiencies do not recur. Management believes the corrective actions outlined above address both the immediate deficiencies and the underlying control weaknesses identified in the audit. Responsible Person: Will Eberle Date of Completion: April 1, 2026

View Audit 395614

Finding 1191799 (2025-002)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Community Services Block Grant (ALN 93.569) U.S. Department of Health and Human Services State of Vermont Department for Children and Families Finding 2025-002 Compliance Finding - Special Tests and Provisions Corrective Action Plan Board Composition Matrix In response to the audit comment concernin...

Community Services Block Grant (ALN 93.569) U.S. Department of Health and Human Services State of Vermont Department for Children and Families Finding 2025-002 Compliance Finding - Special Tests and Provisions Corrective Action Plan Board Composition Matrix In response to the audit comment concerning the need for a Board Composition Matrix, we reviewed our current Board Roster. This review indicates our Roster meets the requirements listed (sector designation, term start and end dates, public official designation expiration, as applicable, and vacancy status). The board is sent an updated roster upon request. and it is updated each time a board member and/or seat is changed. The Board Development and Governance Committee reviews this most of the months that they meet, especially when discussing board recruitment, which is an ongoing agenda item while a seat is vacant. Current Procedure Currently, the Board Chair (Abby White) and Governance Committee Chair (Karen Lowry Reed) are both regularly consulted about board vacancies by the Executive Director (Alison Calderara), both to commit to outreach, and to review current candidates for the board. The Board Bylaws currently reference that the Board Development & Governance Committee is responsible for "[filling] any vacancies on the Board as soon as reasonably Possible." Additionally, all Board members sign an acknowledgement of the Bylaws annually, which reference the board composition. Recruitment is the responsibility of the Development and Governance Committee. Proposed Update of Procedure With the assistance of associated staff, the Development & Governance Committee will create a procedure to follow when vacancies arise, that covers unforeseen vacancies, as well as planned ones (such as when a board member's term limit is approaching). This will also include reference for different sectors, each of which have slightly different requirements for coming on the board. Capstone will complete this written procedure within 90 days. Current Status The Board seat that resulted in the organizational standard finding was filled November 2025. Three of the four required public sector seats are now filled. Responsible Person: Alison Calderara Date of Completion: June 28, 2026

View Audit 395614

Finding 1191798 (2025-001)

Material Weakness 2025

Capstone Community Action, Inc.

VT

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Inter...

Weatherization Assistance Program (ALN 81.042) Low-Income Home Energy Assistance (ALN 93.568) U.S. Department of Energy U.S. Department of Health and Human Services State of Vermont Agency of Human Services Finding 2025-001 Compliance Finding - Special Tests and Provisions Material Weakness in Internal Control Over Compliance Views of Responsible Officials Management acknowledges the deficiency identified in the Quality Control Inspection (QCI) process. While questioned costs were not identified, we recognize that the breakdown in controls represents a material weakness requiring immediate and sustained corrective action. Since the Office of Economic Opportunity (OEO) monitoring review, the Organization has undergone structural and cultural changes within the Weatherization Department. Leadership has taken decisive steps to reinforce compliance expectations, supervisory accountability, and documentation integrity. Corrective Action Plan 1. Immediate Structural Oversight Enhancement • Will Eberle (Weatherization Director) is designated as the primary responsible official for QCI program compliance. • Scott Hall (Weatherization Associate Director and Quality Control Lead) is responsible for direct oversight of all QCI staff and inspection standards. • Chris Locarno (Business Manager) will provide executive-level oversight and ensure crossdepartmental accountability and reporting to senior leadership and the Board. Effective immediately: • No weatherization unit may be reported or invoiced until: o QCI documentation is fully complete, o All required test results (blower door, combustion safety, final inspection) are included, o Client signature is present, o Secondary supervisory review is completed. 2. Secondary File Review Control A new Two-Tier Review Process has been implemented: Tier 1 - QCI Review (Performed by Certified BPI QCI) • Full compliance with Vermont Weatherization Program Standards • Documentation of all required final tests • Verification that QCI was not performed by supervising crew members or project participant Tier 2 - Supervisory File Review • Conducted by Scott Hall • Random sampling at minimum 25% of completed units monthly • Monthly summary report submitted to Will Eberle • Quarterly compliance summary reviewed with Chris Locarno No unit will be considered production-complete until Tier 2 review confirms documentation sufficiency. 3. Mandatory QCI Refresher Training • All QC I-certified staff will complete refresher training on: o DOE and HHS requirements o Vermont Weatherization Program Standards o Documentation standards o Independence requirements • Training will occur semi-annually at minimum. • Scott Hall will document attendance and maintain training logs. • Chris Locarno will verify annual compliance training completion as part of management review. Additionally, peer case reviews will be incorporated quarterly to reinforce quality standards. 4. Cultural and Performance Accountability • QCI compliance metrics will be incorporated into staff performance evaluations. • Repeated documentation failures will result in retraining or removal of QCI approval authority. • Monthly compliance meetings led by Scott Hall will include trend review and corrective tracking. 5. Monitoring & Reporting Timeline Action Two-tier review implemented, Will Eberle, Completed Refresher training session, Scott Hall, Within 60 Days Executive compliance review structure , Chris Locarno, Completed Quarterly internal audit sampling, Scott Hall / Will Eberle, Ongoing Responsible Person: Scott Hall Date of Completion: April 1, 2026

View Audit 395614

Finding 1191789 (2025-003)

Material Weakness 2025

Bloom Vernon Local School District

OH

The District will add in another level of review to ensure that meals reported to DEW agree to the point-of-sale system CN-6 and CN-7 reports.

View Audit 395609

Finding 1191788 (2025-002)

Material Weakness 2025

Bloom Vernon Local School District

OH

The District will ensure that proper semi-annual certifications or other time and effort documentation are prepared timely and properly maintained.

View Audit 395609

Finding 1191785 (2025-001)

Material Weakness 2025

Elk City Independent School District No. 06

OK

Elk City Public Schools will ensure that on all future construction contracts that deal with federal awards, requirements of the Davis-Bacon Act will be included. Prevailing wages will be inserted into the language of the contract and shall be signed by contractors and subcontractors. All contracts ...

Elk City Public Schools will ensure that on all future construction contracts that deal with federal awards, requirements of the Davis-Bacon Act will be included. Prevailing wages will be inserted into the language of the contract and shall be signed by contractors and subcontractors. All contracts will also spell out weekly reporting requirements of certified wages paid by contractors and subcontrators. In addition, ECPS will ensure that Davis-Bacon information is posted at all job sites. These policy changes will be implemented immediately and be in place as of October 9, 2025.

View Audit 395599

Finding 1191784 (2025-002)

Material Weakness 2025

Western Michigan University

MI

Condition: Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Planned Corrective Action: Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associa...

Condition: Out of 40 students tested for Return to Title IV, we identified 3 students whose calculations were not performed timely. Planned Corrective Action: Financial Aid has reviewed our current practices and will implement centralized accountability processes, using the Banner system and associated reports, to monitor all types of student withdrawal and drop determinations, as well as the corresponding R2T4 deadlines. Standardized procedures and a comprehensive processing checklist will be developed to ensure accuracy and timely completion. Staff in both offices will be trained on the updated procedures. Financial Aid will also continue working with the Registrar’s Office to ensure the receipt of accurate and timely enrollment data necessary to meet all Title IV requirements and deadlines. Contact person responsible for corrective action: Shashanta S James, Director Lana Greaves, Sr. Associate Director Anticipated Completion Date: April 15, 2026

View Audit 395596

Finding 1191783 (2025-001)

Material Weakness 2025

Western Michigan University

MI

Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Root Cause: Manual NSC updates were overwritten by subsequent certified enrollment files. Planned Corrective Action: Western M...

Condition: Of the 40 students selected for enrollment reporting testing, the University did not properly update the student enrollment information for 3 students accurately. Root Cause: Manual NSC updates were overwritten by subsequent certified enrollment files. Planned Corrective Action: Western Michigan University has discontinued the use of manual enrollment status updates in the NSC Student Look-Up tool for unofficial withdrawals. The Registrar’s Office now records last date of attendance and withdrawal status directly in the SIS for all students who earn all E and X grades and are determined to have unofficially withdrawn. All unofficial withdrawal records are included in the final enrollment submission for the term, ensuring that withdrawal status and effective dates are transmitted through certified batch files to NSC and NSLDS. Contact person responsible for corrective action: Registrar, Carrie Cumming Assistant Registrar of Academic Records, Nicole Miller Anticipated Completion Date: 08/20/2025 (This is the day we sent summer II 2025 final enrollment to the NSC. Summer II 2025 LDA changes were completed directly into the SIS.)

View Audit 395596

Finding 1191780 (2025-001)

Material Weakness 2025

Campbellsville University INC

KY

Campbellsville University acknowledges the reporting deficiency that occurred when certain clock-hour technical programs (Cosmetology, Barbering, Esthetics) were converted to a standard-term structure, and the Jenzabar extraction query was not updated. The University has updated affected student enr...

Campbellsville University acknowledges the reporting deficiency that occurred when certain clock-hour technical programs (Cosmetology, Barbering, Esthetics) were converted to a standard-term structure, and the Jenzabar extraction query was not updated. The University has updated affected student enrollment records, revised the extraction query and data mappings, and implemented a cross-department pre-reporting reconciliation between Institutional Research and Student Records. As part of this reconciliation, the Registrar’s Office completes a monthly internal check prior to sending the initial report, and any omitted students are reported directly to the National Student Clearinghouse (NSC). Additionally, Financial Aid and Student Records perform a post-NSLDS reporting audit on a random sample of students initially reported to NSC. All involved departments have instituted a temporary manual verification step while automated checks are finalized, and provided targeted staff training and updated procedures to strengthen change control for future program model changes. The Office of Financial Aid and Student Records will collaborate to resolve any student record discrepancies within NSLDS to make the necessary updates.

View Audit 395594

Finding 1191776 (2025-002)

Material Weakness 2025

Archway Station, Inc.

MD

Views of Responsible Officials and Planned Corrective Actions: We agree with the recommendation and will 1) develop and adopt written policies, procedures, and standards of conduct in compliance with the Uniform Guidance, and 2) initiate ongoing grant training for applicable personnel.

View Audit 395592

Finding 1191775 (2025-001)

Material Weakness 2025

City of Martinez

CA

Internal Control / Segregation of Duties

The Finance Department has implemented an additional Accounts Payable control requiring departments to verify the invoice date and provide written justification for any invoices submitted to Finance more than ninety days after the invoice date. This additional step strengthens internal controls and ...

The Finance Department has implemented an additional Accounts Payable control requiring departments to verify the invoice date and provide written justification for any invoices submitted to Finance more than ninety days after the invoice date. This additional step strengthens internal controls and helps ensure timely invoice processing and payment.

View Audit 395583

Finding 1191774 (2025-006)

Material Weakness 2025

Northeastern Illinois University

IL

Student Financial Aid

Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS). Planned Corrective Action: Registrar’s office to...

Condition: Northeastern Illinois University (University) did not have adequate procedures and controls in place to ensure student that unofficially withdrew during the semester were accurately reported to the National Student Loan Data System (NSLDS). Planned Corrective Action: Registrar’s office to utilize the financial aid’s last date of attendance report and withdrawal determinations at the end of each semester to back date the effective enrollment reported date for unofficially withdrawn students at the end of each term. Contact person responsible for corrective action: Enrollment Management: Rahshida Walker, Registrar’s Office and Maureen Amos, Financial Aid Office Anticipated Completion Date: 6/30/2026

View Audit 395581

Finding 1191772 (2025-007)

Material Weakness 2025

Northeastern Illinois University

IL

Subrecipient Monitoring Reporting

Condition: Northeastern Illinois University (University) did not report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for the Higher Education Institutional Aid grants. Planned Corrective Action: The University wil...

Condition: Northeastern Illinois University (University) did not report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) for the Higher Education Institutional Aid grants. Planned Corrective Action: The University will review applicable guidelines and assign the responsibility to the appropriate office. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026

View Audit 395581

Finding 1191771 (2025-008)

Material Weakness 2025

Northeastern Illinois University

IL

Subrecipient Monitoring Cash Management Reporting § 200.305

Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective act...

Condition: Northeastern Illinois University (University) did not pay reimbursements within 30 days for certain subrecipients in the Research and Development Cluster. Planned Corrective Action: The University will explore procedures to address this issue. Contact person responsible for corrective action: Jannica Henry, Controller’s Office Anticipated Completion Date: 6/30/2026

View Audit 395581

Finding 1191769 (2025-003)

Material Weakness 2025

Northern Manhattan Improvement Corporation

NY

Reporting

Management agrees with the finding. Although reports were submitted timely, certain required programmatic data (units completed) was not included, resulting in unsupported expenditures and disallowed costs. This reflects a breakdown in coordination between program and finance, and the absence of a s...

Management agrees with the finding. Although reports were submitted timely, certain required programmatic data (units completed) was not included, resulting in unsupported expenditures and disallowed costs. This reflects a breakdown in coordination between program and finance, and the absence of a structured process to ensure complete and accurate reporting prior to submission. The root cause is lack of defined roles, standardized workflows, and formal review controls governing integration of programmatic and financial reporting. The corrective actions are: (1) Define roles and responsibilities across program, finance, and Controller; (2) Implement standardized reporting checklists by program; (3) Establish pre-submission review and signoff process with cross-functional validation; (4) Formalize handoffs between program and finance, including timelines and escalation protocols; and (5) Provide training on grant reporting requirements and compliance. The parties responsible are the CFAO, Director of Finance, and Program Leadership. We expect to complete initial implementation in 30 days and full implementation in 120 days.

View Audit 395580

Finding 1191768 (2025-001)

Material Weakness 2025

Gwynedd Mercy University

PA

Student Financial Aid

Action Taken: The Registrar's Office is working with the NSC administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with IT on updated internal reports to track and review the statu...

Action Taken: The Registrar's Office is working with the NSC administrator to address concerns with submitted reports being updated in NSLDS. Each error was corrected within the system. Going forward, the Registrar's Office is working with IT on updated internal reports to track and review the status changes and start dates to ensure they are being accurately reported. Responsible Individual for Corrective Action: Registrar - Jennifer Melon Anticipated Completion Date: June 30, 2026 If there are any questions regarding this corrective action plan, please call Jennifer Ginnetti, Sr. Associate VP/ Deputy CFO, at 215-641-5506 or email Ginnetti.j@gmercyu.edu.

View Audit 395574

Finding 1191766 (2025-001)

Material Weakness 2025

Illinois Housing Development Authority

IL

Subrecipient Monitoring HUD Housing Programs § 200.303 § 200.332

The Authority agrees with the finding. The Authority will implement additional internal controls, including quality control of completed inspection, documentation, and inspection scheduling. Additionally, the Authority recognizes that the volume of required annual inspections has increased beyond ex...

The Authority agrees with the finding. The Authority will implement additional internal controls, including quality control of completed inspection, documentation, and inspection scheduling. Additionally, the Authority recognizes that the volume of required annual inspections has increased beyond existing Full Time Equivalent (FTE) capacity; therefore, an RFP for the third-party inspection vendor has been issued to supplement internal resources and support timely completion of inspections.

View Audit 395570

Finding 1191764 (2025-001)

Material Weakness 2025

City of Huntington Park

CA

Reporting Procurement, Suspension & Debarment Internal Control / Segregation of Duties

Management Response and Corrective Action Plan City’s Response: The City concurs with the recommendation. Corrective Action Plan: The City’s finance department has taken over reporting duties and has ensured all reporting related to CSLFRF is done on a timely basis. Planned Implementation Date: Reso...

Management Response and Corrective Action Plan City’s Response: The City concurs with the recommendation. Corrective Action Plan: The City’s finance department has taken over reporting duties and has ensured all reporting related to CSLFRF is done on a timely basis. Planned Implementation Date: Resolved, implemented in December of 2024. Responsible Person: Director of Finance

View Audit 395569

Finding 1191763 (2025-001)

Material Weakness 2025

Dawn Center for Independent Living

NJ

Internal Control / Segregation of Duties Subrecipient Monitoring Allowable Costs / Cost Principles

Responsible Executive: CEO – Carmela Slivinski Implementation Status: Effective Immediately Full Implementation Date: No later than June 30, 2026 Finding — Compliance (Period of Performance) Significant Deficiency Condition: Auditor noted while testing period of performance, 1 of the 10 expenses rec...

Responsible Executive: CEO – Carmela Slivinski Implementation Status: Effective Immediately Full Implementation Date: No later than June 30, 2026 Finding — Compliance (Period of Performance) Significant Deficiency Condition: Auditor noted while testing period of performance, 1 of the 10 expenses recorded in June 2025 pertained to subsequent months outside of the contract period. Effect: One expense was included in the expenditure report under the incorrect grant period ending June 30, 2025. Cause: The Organization noted that this finding came about due to a clerical error. The bookkeeper inadvertently recorded a July invoice on June 30th and this led to an incorrect charge to the grant period ending June 30th. Recommendation: Auditor recommends management continue to perform a second review on the grant submission especially towards the end of the grant period. Management’s Response: Management concurs with the finding regarding deficiencies in grant period-of-performance compliance. Corrective Action Plan - Review existing Accounts Payable and Accounting Controls processes and revise as needed to ensure expenses are recorded as required. - Staff Training and Competency Development conducted annually to review accounting controls and ensure accounting personnel understand period of performance grant compliance requirements. - Ongoing Monitoring and Internal Compliance Review conducted periodically to ensure oversight of financial controls and grant compliance.

View Audit 395564

Finding 1191761 (2025-003)

Material Weakness 2025

County of Los Angeles

CA

Subrecipient Monitoring Internal Control / Segregation of Duties Special Tests & Provisions

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Deputy Director, Department of Public Health 2. Corrective action plan: DPH agrees with the finding and recommendation. VPDCP will develop and implement written procedures for the centralized and secure storage of do...

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Deputy Director, Department of Public Health 2. Corrective action plan: DPH agrees with the finding and recommendation. VPDCP will develop and implement written procedures for the centralized and secure storage of documentation supporting grant deliverables and required progress reports. The procedures will include, at a minimum, the following: • Define required documentation, storage location, staff responsibilities, and retention requirements. • Require all supporting documentation to be maintained in a designated centralized repository and ensure documentation is complete, organized, and readily accessible for review. • Detail the steps during staff transitions that new staff must follow to access, maintain, and update grant-related documentation, ensuring consistency and completeness of records. VPDCP will perform periodic reviews of the centralized repository and formally document and sign-off on the reviews to verify that required documentation is maintained. 3. Anticipated implementation date: June 19, 2026

View Audit 395559

Finding 1191760 (2025-002)

Material Weakness 2025

County of Los Angeles

CA

Subrecipient Monitoring § 200.332 § 200.425 § 200.513 § 200.521

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Administrative Deputy, DCBA 2. Corrective action plan: DCBA concurs with the findings and the recommendation, however, the total expenditure amount of $5,917,341 is inclusive of expenditures from a different contract...

Views of Responsible Officials and Planned Corrective Action 1. Person responsible: Administrative Deputy, DCBA 2. Corrective action plan: DCBA concurs with the findings and the recommendation, however, the total expenditure amount of $5,917,341 is inclusive of expenditures from a different contract held by the same agency who was identified as a contractor and not a sub-recipient. As such, expenditures under that contract would not be subject to monitoring as set forth in 2 CFR § 200.332. Therefore, the total expenditures for the four (4) subrecipient agreements that are missing monitoring reports are $585,756. To address the finding, DCBA will establish a formal monitoring plan that will include a monitoring checklist, monitoring schedule, and a detailed tracking log to ensure timely monitoring of its subrecipients. DCBA will work with CEO and/or the Auditor-Controller to identify resources to implement ongoing monitoring of subrecipients, with clear documentation and reporting. Additionally, DCBA already implemented a risk assessment process to ensure an assessment of all subrecipients is completed at least once a year. This process will be formalized in writing. The process involves identifying risk areas, including reviewing financial stability, legal risks, capacity, and performance history. The assessment process uses a risk scoring model that rates organizations using a risk level scale between 1-5 that takes into consideration operating reserves, program and fundraising efficiency, and their ability to meet financial obligations. 3. Anticipated implementation date: September 30, 2026.

View Audit 395559

Finding 1191758 (2025-003)

Material Weakness 2025

United Tribes Technical College

ND

Special Tests & Provisions Significant Deficiency Matching / Level of Effort / Earmarking

Recommendation: We recommend the College not disburse funds from the debt service reserve fund without the approval of USDA in accordance with the loan agreement. Action Taken: The USDA loan was paid in full on December 10, 2025.

View Audit 395558

Finding 1191751 (2025-009)

Material Weakness 2025

School District of the City of St. Louis

MO

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement p...

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures and controls to ensure pre-approval in accordance with the Uniform Guidance compliance requirements.

View Audit 395555

Finding 1191750 (2025-008)

Material Weakness 2025

School District of the City of St. Louis

MO

Subrecipient Monitoring Cash Management Reporting

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement p...

Personnel Responsible For Corrective Action: Kelly Dobell, Controller, Square Watson, Chief Operations Officer, and Spencer Winn, Director of Food and Nutrition Services Anticipated Completion Date: June 30, 2026 Corrective Action Plan: Food and Nutrition Services along with Finance will implement procedures for review and reconciliation of lunch count data with claims reports in accordance with the Uniform Guidance.

View Audit 395555

Corrective Action Plans

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