Corrective Action Plans

Finding 1162697 (2024-001)

Material Weakness 2024

Lincoln Hall

NY

Allowable Costs / Cost Principles Material Weakness

Finding Number: 2024-001 Cost Allocations (Material Weakness) Planned Corrective Action: The auditors noted that payroll and the related personnel costs are not being charged directly or allocated to the correct cost center in the Serenic Navigator accounting system monthly. The Finance team perform...

Finding Number: 2024-001 Cost Allocations (Material Weakness) Planned Corrective Action: The auditors noted that payroll and the related personnel costs are not being charged directly or allocated to the correct cost center in the Serenic Navigator accounting system monthly. The Finance team performed manual calculations of all allocations in Excel at the end of the fiscal year to update the allocations. Beginning in FY 2025, personnel costs are being manually recorded to the correct cost centers in Serenic Navigator each month. A parallel review of employee setups in ADP, our payroll system, led to the reassignment of staff to appropriate cost centers as needed. Going forward, ADP cost center assignments will be reviewed monthly to reflect any departmental changes. These steps are expected to reduce manual adjustments, improve the accuracy of interim financials, and ensure more precise federal and program drawdowns. Person Responsible: The Executive Director and Chief Financial Officer Completion Date: July 2024

View Audit 372336

Finding 1162696 (2024-001)

Material Weakness 2024

Town of Southold

NY

Subrecipient Monitoring § 200.332

Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requir...

Finding 2024-001 Audit Finding: In accordance with 2 CFR § 200.332(a) of the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), pass-through entities are required to “clearly identify to the subrecipient” certain information and requirements at the time of subaward, including the Federal award identification, all compliance requirements, and any additional terms and conditions imposed by the pass-through entity. The Town did not execute a formal subrecipient agreement with Fishers Island Ferry District, to whom federal funds were passed through during the audit period. Specifically, no written agreement was in place outlining the subrecipient’s responsibilities, applicable compliance requirements, or the terms and conditions of the award. Recommendation: We recommend that the Town develop and implement procedures to ensure that formal written subrecipient agreements are executed prior to the disbursement of federal funds. These agreements should contain all elements required by 2 CFR § 200.332(a), including the identification of the federal award, applicable compliance requirements, and any additional terms and conditions. Corrective Action Plan: In coordination with the Supervisor’s office, Town Attorney’s office, and Comptroller’s office, formal subrecipient agreements will be prepared and executed, with adoption of Town Board resolutions, between the Town of Southold and pass-through entities concurrently as Federal grant contracts are awarded, as applicable. Responsible Individual: Albert J. Krupski Jr., Town Supervisor Paul DeChance, Town Attorney Michelle Nickonovitz, Town Comptroller Planned Date of Implementation: Corrective action plan procedures have already been communicated and implemented to ensure that formal written subrecipient agreements with pass-through entities are executed prior to the disbursement of federal funds.

View Audit 372332

Finding 1162691 (2024-003)

Material Weakness 2024

City of New Rochelle

NY

HUD Housing Programs Reporting

Name of Auditee: City of New Rochelle, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Edward Ritter, Commissioner of Finance Phone: (914) 654-2000 (3) Audit Finding 2024-003 - the City did not timely submit the Federal D...

Name of Auditee: City of New Rochelle, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Edward Ritter, Commissioner of Finance Phone: (914) 654-2000 (3) Audit Finding 2024-003 - the City did not timely submit the Federal Data Collection Forms to the appropriate authorities. (a) Implementation Plan of Actions - Management has contracted with a third party to assist with entering and submitting the required years of the Federal Data Collection Form for the City’s Section 8 Housing Choice Voucher Program for fiscal years ended December 31, 2021 and 2022. Management has contracted with their external auditors to perform the submissions of the Federal Data Collection Forms for fiscal years ended December 31, 2024 and 2023. These forms will be submitted in chronological order once they are processed by the U.S. Department of Housing and Urban Development. Additionally, management has contracted with another third party to provide assistance with the year-end closing procedures. Such assistance may enable management to ensure that the Federal Data Collection Form is submitted to the Federal Audit Clearinghouse by the required deadline. (b) Implementation Date - This will be implemented during the year ended December 31, 2025. (c) Persons Responsible for Implementation - The Commissioner of Finance, Commissioner of Development and the City Council.

View Audit 372331

Finding 1162690 (2024-002)

Material Weakness 2024

City of New Rochelle

NY

Eligibility

Name of Auditee: City of New Rochelle, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Edward Ritter, Commissioner of Finance Phone: (914) 654-2000 (2) Audit Finding 2024-002 - The City did not follow controls for eligibi...

Name of Auditee: City of New Rochelle, New York Name of Audit Firm: EFPR Group, CPAs, PLLC Period Covered by the Audit: Year ended December 31, 2024 CAP Prepared by: Edward Ritter, Commissioner of Finance Phone: (914) 654-2000 (2) Audit Finding 2024-002 - The City did not follow controls for eligibility certifications of individuals enrolled in the HIPP-RAP. (a) Implementation Plan of Actions - Management has initiated a full review and recertification of all participants in the HIPP-RAP to determine if any additional participants were missing eligibility determinations. (b) Implementation Date - This will be implemented and completed for the year ended December 31, 2025. (c) Persons Responsible for Implementation - The Commissioner of Development and the City Council.

View Audit 372331

Finding 1162689 (2024-005)

Material Weakness 2024

American Indian Higher Education Consortium

VA

Subrecipient Monitoring

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator

View Audit 372326

Finding 1162679 (2024-004)

Material Weakness 2024

American Indian Higher Education Consortium

VA

Procurement, Suspension & Debarment § 200.303 § 200.320

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator

View Audit 372326

Finding 1162669 (2024-003)

Material Weakness 2024

American Indian Higher Education Consortium

VA

Reporting Subrecipient Monitoring

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator

View Audit 372326

Finding 1162666 (2024-002)

Material Weakness 2024

American Indian Higher Education Consortium

VA

Reporting Internal Control / Segregation of Duties

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a...

Management Response We accept the recommendations and have acted as follows: Training: Provided mandatory Uniform Guidance and grant-compliance training for all program and finance staff. Post-Award Grant Management System: Implemented an integrated post-award grant management system that includes a built-in reporting calendar with automated deadline notifications to ensure timely and accurate submissions. Personnel: Grants Administrator started in March 2025, and a dedicated Grants Compliance Officer to oversee all federal program requirements, is actively being recruited by the end of 2025. These measures will ensure ongoing compliance with OMB Uniform Guidance. Estimated Completion Date January 1, 2026 Responsible Party Kathy De Palma, Grants Coordinator

View Audit 372326

Finding 1162656 (2024-001)

Material Weakness 2024

The Baltimore Station, Inc.

MD

Reporting Subrecipient Monitoring

1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accura...

1. Maintained and refined the shared federal financial reporting calendar to ensure all relevant deadlines and submission dates are consistently tracked and communicated. 2. Expanded and updated reporting checklists to incorporate additional compliance requirements and ensure completeness and accuracy prior to submission. 3. Assigned dedicated staff oversight for federal financial reporting, with cross-training implemented to strengthen continuity and mitigate risk in the event of staff turnover. 4. Conducted periodic evaluations of the reporting process, incorporating feedback and lessons learned from prior submissions, monitoring visits, and audit findings to drive ongoing improvements. 5. Reviewed and updated internal financial policies and procedures to align with current federal reporting requirements and best practices, with updates formally documented and disseminated to staff.

View Audit 372318

Finding 1162655 (2024-003)

Material Weakness 2024

MORGAN COUNTY, MISSOURI

MO

Subrecipient Monitoring Reporting § 200.510

We are taking steps to address the ongoing issue by coordinating with department heads and the Treasurer to ensure all grant paperwork is properly received and documented.

View Audit 372315

Finding 1162648 (2024-001)

Material Weakness 2024

City of Columbia Falls

MT

Subrecipient Monitoring

FINDING 2024-001: Audit Report Deadline (Repeated 2023-001) Response: Following turnover in the City Manager (June 2024) and Finance Director (November 2024) positions, city staff have been actively working to ensure compliance regarding the delayed audit submission. The Finance Director, who joined...

FINDING 2024-001: Audit Report Deadline (Repeated 2023-001) Response: Following turnover in the City Manager (June 2024) and Finance Director (November 2024) positions, city staff have been actively working to ensure compliance regarding the delayed audit submission. The Finance Director, who joined the city in November 2024, postponed issuing RFPs to audit firms until the new City Manager assumed the role in April 2025. By July 2025, the City Manager and Finance Director engaged Nexus to complete the 2024 audit in the fall of 2025. To ensure compliance, the city will work with Nexus to have the 2025 Audit completed by March of 2026.

View Audit 372311

Finding 1162645 (2024-005)

Material Weakness 2024

Refuge And Restoration

MO

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.430

Corrective Action Plan: The Organization will implement a formalized process for the review and approval of payroll transactions, including the allocation of payroll costs to grants. We will do this by adding the proper software tools in place within our financial accounting software. This process w...

Corrective Action Plan: The Organization will implement a formalized process for the review and approval of payroll transactions, including the allocation of payroll costs to grants. We will do this by adding the proper software tools in place within our financial accounting software. This process will also involve establishing clear guidelines outlining the steps for reviewing and approving payroll transactions to ensure accuracy and compliance with grant requirements and financial processes. Designated personnel, the finance manager, will be assigned the specific responsibility of preparing payroll and the CEO will review the payroll report and sign off prior to payroll execution. This will be in the system of documented processes to track and document these approvals as well as written within the policies and procedures handbook. Anticipated Completion Date: November 30, 2025

View Audit 372308

Finding 1162643 (2024-002)

Material Weakness 2024

Lakes and Pines Community Action Council, Inc.

MN

Reporting § 200.510 § 200.512 § 200.520

Finding 2024-002: Submission of the Reporting Package and Data Collection Form Management Response: Agreement with Finding: Management acknowledges and concurs with the finding. Root Cause: The agency experienced unanticipated delays in the preparation and submission processes for the Schedule of Ex...

Finding 2024-002: Submission of the Reporting Package and Data Collection Form Management Response: Agreement with Finding: Management acknowledges and concurs with the finding. Root Cause: The agency experienced unanticipated delays in the preparation and submission processes for the Schedule of Expenditures of Federal Awards (SEFA) and related audit documentation, resulting in the audit reporting package and Data Collection Form not being submitted within the required timeframe. Management Plan: Lakes and Pines has engaged a professional accounting firm to assist with comprehensive process improvements for financial reporting. The agency will work with the firm to establish enhanced procedures and internal controls for the timely preparation of the SEFA and all required audit materials. New processes will include earlier preparation timelines and milestone checkpoints to ensure submission deadlines are met Responsible Party: Dawn van Hees, Fiscal Controller Implementation Timeline: Improvements will be implemented during the 2025/2026 fiscal year, with the enhanced processes fully operational for the next audit cycle reviewing that fiscal year. Current Status (as of November 5, 2025): The professional accounting firm has been engaged and process improvement work is underway.

View Audit 372306

Finding 1162635 (2024-001)

Material Weakness 2024

City of Rockport

IN

Procurement, Suspension & Debarment § 200.303 § 200.317 § 200.318 § 200.319 § 200.320

FINDING 2024-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: K. Rochelle Seneff Contact Phone Number and Email Address: (812)649-2242 ct@rockportin.gov Views of Responsible Offici...

FINDING 2024-001 Finding Subject: Water and Waste Disposal Systems for Rural Communities - Procurement and Suspension and Debarment Contact Person Responsible for Corrective Action: K. Rochelle Seneff Contact Phone Number and Email Address: (812)649-2242 ct@rockportin.gov Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: Procurement As Clerk-Treasurer, I will educate all parties involved on the requirements that were found to be unfulfilled through this Federal Audit. For the duration of any federally funded projects, a discussion will be held during a public board meeting, detailing the rationale behind the City's decision to work with the vendors selected for small purchases and simplified acquisitions. This will be done to verify that all vendors, even when bids are not required, were retained through appropriate methods. A procurement policy that outlines the City's procedures and conforms to applicable federal, state, and local laws will be developed and taken to the Common Council for approval. Suspension and Debarment All vendors who participate in the project will receive a Suspension and Debarment Certificate provided by the City that must be signed by a representative of the vendor and filed with the vendor's contract or in the project folder. Anticipated Completion Date: December 23, 2025

View Audit 372304

Finding 1162634 (2024-002)

Material Weakness 2024

Municipal Authority of the Borough of Orwigsburg

PA

Procurement, Suspension & Debarment § 200.318

Corrective action plan to address finding 2024-002 – No Written Procurement Policy The following steps will be taken to bring the Authority into compliance. 1. A draft policy will be developed by the manager 2. The draft policy will be shared with Authority members in November 3. At the next Authori...

Corrective action plan to address finding 2024-002 – No Written Procurement Policy The following steps will be taken to bring the Authority into compliance. 1. A draft policy will be developed by the manager 2. The draft policy will be shared with Authority members in November 3. At the next Authority meeting (12/8/2025) the policy will be formally presented for adoption. 4. The policy will be effective upon completion of the vote at the December meeting.

View Audit 372303

Finding 1162629 (2024-004)

Material Weakness 2024

MONITEAU COUNTY, MISSOURI

MO

Subrecipient Monitoring Reporting § 200.510

The SEFA information needed for this finding was from the 2025 budget. The 2025 budget can be amended up to 12/31/2025. Even though the ARPA funds in question were not reported on the SEFA page of the 2025 budget, it was reported within the budget within its own fund, which would show actual expendi...

The SEFA information needed for this finding was from the 2025 budget. The 2025 budget can be amended up to 12/31/2025. Even though the ARPA funds in question were not reported on the SEFA page of the 2025 budget, it was reported within the budget within its own fund, which would show actual expenditures of the year ended December 31, 2024. Going forward the County Clerk will have the Treasurer review the SEFA report for accuracy.

View Audit 372298

Finding 1162626 (2024-012)

Material Weakness 2024

Mental Health Association of Columbia-Greene Counties Inc.

NY

Allowable Costs / Cost Principles Procurement, Suspension & Debarment

Finding 2024-012 – Allowable and Unallowable Costs (Material Weakness) Finding: The Organization did not have sufficient controls to ensure that the allowable and unallowable costs requirement was met due to staff turnover. Management Response: Management agrees. Corrective action plan: •Develop an ...

Finding 2024-012 – Allowable and Unallowable Costs (Material Weakness) Finding: The Organization did not have sufficient controls to ensure that the allowable and unallowable costs requirement was met due to staff turnover. Management Response: Management agrees. Corrective action plan: •Develop an allowable cost checklist for all federal programs. •Management will expand controls to ensure that they are able to demonstrate that all expenses meet their procurement policy and are allowable under the grant. •Staff training will be completed by the end of 2025, and a cost allowability checklist is now used for all expenditures charged to grants. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

View Audit 372297

Finding 1162623 (2024-011)

Material Weakness 2024

Mental Health Association of Columbia-Greene Counties Inc.

NY

Procurement, Suspension & Debarment § 200.317 § 200.326

Finding 2024-011 – Procurement and Suspension and Debarment (Material Weakness) Finding: The Organization did not have sufficient controls to ensure that the procurement requirement was met due to staff turnover. Management Response: Management agrees. Corrective action plan: •All procurements now r...

Finding 2024-011 – Procurement and Suspension and Debarment (Material Weakness) Finding: The Organization did not have sufficient controls to ensure that the procurement requirement was met due to staff turnover. Management Response: Management agrees. Corrective action plan: •All procurements now require documentation of vendor eligibility verification (SAM.gov) and compliance with competitive bidding rules. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

View Audit 372297

Finding 1162619 (2024-010)

Material Weakness 2024

Mental Health Association of Columbia-Greene Counties Inc.

NY

Procurement, Suspension & Debarment Period of Performance § 200.1 § 200.308 § 200.309 § 200.344

Finding 2024-010 – Period of Performance (Material Weakness) Finding: The Organization did not have good controls to ensure the period of performance requirements was met due to staff turnover. Management Response: Management concurs. Corrective action plan: •Implement a grant compliance checklist a...

Finding 2024-010 – Period of Performance (Material Weakness) Finding: The Organization did not have good controls to ensure the period of performance requirements was met due to staff turnover. Management Response: Management concurs. Corrective action plan: •Implement a grant compliance checklist and training for staff by the end of 2025 to ensure expenditures are within the grant period. •Require pre-approval for all expenditures near grant end dates. •Quarterly compliance reviews. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

View Audit 372297

Finding 1162615 (2024-009)

Material Weakness 2024

Mental Health Association of Columbia-Greene Counties Inc.

NY

Matching / Level of Effort / Earmarking

Finding 2024-009 – Matching, Level of Effort, Earmarking (Material Weakness) Finding: The Organization did not have sufficient controls to ensure that the matching and earmarking requirements was met Management Response: Management agrees with the finding. Corrective action plan: •A compliance contr...

Finding 2024-009 – Matching, Level of Effort, Earmarking (Material Weakness) Finding: The Organization did not have sufficient controls to ensure that the matching and earmarking requirements was met Management Response: Management agrees with the finding. Corrective action plan: •A compliance control checklist and quarterly monitoring process will be implemented to document matching and earmarking requirements by the end of 2025. •Provide grant compliance training to staff. Responsible Party: CFO Completion Date/Status: Expected to be Implemented by end of 2025; ongoing review.

View Audit 372297

Finding 1162599 (2024-001)

Material Weakness 2024

Aids United

DC

Material Weakness Reporting Internal Control / Segregation of Duties § 200.512

AIDS United submits the following corrective action plan for the identified findings for the audit period January 1, 2024 through December 31, 2024: Finding 2024-001 Material Adjusting Journal Entries and Late Filing of Data Collection form Corrective Action: Action 1: Implement a Formal Month-End a...

AIDS United submits the following corrective action plan for the identified findings for the audit period January 1, 2024 through December 31, 2024: Finding 2024-001 Material Adjusting Journal Entries and Late Filing of Data Collection form Corrective Action: Action 1: Implement a Formal Month-End and Year-End Close Process • Develop a plan with the Executive to onboard additional accounting support at both the staff and senior accountant levels. • Require all reconciliations to be completed within 15 business days of month-end. Responsible Party: Controller Completion: Date12/31/2025 Status: Planned Action 2: Strengthen Review Controls Over Journal Entries • Implement system-based controls where available in Intacct. Responsible Party: Controller Completion Date: 12/31/2025 Action 3: Improve Financial Statement Preparation Procedures • Develop a documented process for drafting, reviewing, and finalizing financial statements prior to sending them to external auditors. • Incorporate a pre-audit internal review meeting to validate account balances and disclosures. Responsible Party: Controller Completion Date: March 2026 Action 4: Ensure Timely Federal Audit Clearinghouse Submission • Start audit process earlier in 2026 no later than end of Q1 Responsible Party: Controller Completion Date: Next audit cycle

View Audit 372285

Finding 1162584 (2024-006)

Material Weakness 2024

Douglas County

IL

Reporting Subrecipient Monitoring

Inadequate Grant Recordkeeping The County will work to improve grant documentation and will consider having someone review grant reports prior to their submission. In the absence of necessary knowledge and expertise, the County will continue to rely on the auditors to assist with prepration of the S...

Inadequate Grant Recordkeeping The County will work to improve grant documentation and will consider having someone review grant reports prior to their submission. In the absence of necessary knowledge and expertise, the County will continue to rely on the auditors to assist with prepration of the Schedule of Expenditures of Federal Awards and reconciling the financial records to the Consolidated Year-End Financial Report.

View Audit 372262

Finding 1162583 (2024-005)

Material Weakness 2024

Douglas County

IL

Lack of Appropriate Personnel The County has not implemented procedures that would allow them to properly prepare the financial statements and related notes without the assistance of the auditor.

View Audit 372262

Finding 1162582 (2024-007)

Material Weakness 2024

Douglas County

IL

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

Insufficient Grant Monitoring The County will work to improve grant documentation and will consider implementing a review process to ensure the grant records agree to the grant reports that are filed.

View Audit 372262

Finding 1162579 (2024-004)

Material Weakness 2024

Douglas County

IL

Allowable Costs / Cost Principles Internal Control / Segregation of Duties Material Weakness

Insufficient Understanding of Federal Compliance Requirements The County will work to improve their understanding of federal compliance requirements for each grant award and documentation of procedures implemented to ensure compliance.

View Audit 372262

Corrective Action Plans

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