Corrective Action Plans

Finding 562080 (2024-001)

Material Weakness 2024

MI

Subrecipient Monitoring Material Weakness Reporting § 200.303

Condition: The Township did not have controls in place surrounding the review of annual performance reporting. Planned Corrective Action: The Township has implemented a formal review process within the Finance and Budget Department to ensure the integrity of annual performance reporting. One staff m...

Condition: The Township did not have controls in place surrounding the review of annual performance reporting. Planned Corrective Action: The Township has implemented a formal review process within the Finance and Budget Department to ensure the integrity of annual performance reporting. One staff member has been designated to compile and complete the performance reports,while a separate finance team member is responsible for conducting an independent review prior to submission. To support this process, an internal timeline has been established to allow sufficient time for thorough review and validation of all performance data before final submission. Contact person responsible for corrective action: Wendy Hillman Anticipated Completion Date: 04/15/2025

View Audit 357711

Finding 562079 (2024-101)

Material Weakness 2024

Cochise County

AZ

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

Cochise County WIC leadership and staff is committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. The County immediately corrected this issue by conducting a mandatory training sessio...

Cochise County WIC leadership and staff is committed to full adherence with WIC policy and will continue to implement training, monitoring, and communication to ensure compliance with federal and state regulation. The County immediately corrected this issue by conducting a mandatory training session for all WIC staff regarding the Rights and Obligations policy. During this session, the policy was read aloud and distributed in written form to all attendees. Staff were directed to inform all participants of their rights and responsibilities to include having the rights and responsibilities form signed by the participants, prior to issuing benefits, during the participant’s initial certification, and recertifications for ongoing benefits. Staff received the Rights and Obligations Pledge for review and reference. Procedures for obtaining signatures from participants not physically present in the office were reviewed. Acceptable alternatives include sending the form via email for electronic or physical signature, scheduling a follow-up in-office visit for signature collection. All staff questions were addressed to ensure clarity and consistent understanding. Ongoing reminders have been disseminated through emails and during regular staff “huddles” since the training. In addition to the immediate actions taken to correct the finding, the County also implemented long-term action steps. These steps include annual training of all WIC Staff on the Rights and Obligations policy the 2nd Monday of January. Each employee will sign an attestation confirming their understanding and compliance post-training. This attestation will be stored in the employee’s personnel record. Monthly, the WIC Manager, or designee, will review the WIC Cert. for Audit Report the last Friday of each month to identify and address any instances of missing client signatures. Additionally, the WIC Manager will manually audit 3% of the total WIC members for the month. Continuous actions implemented by County staff to correct this finding includes consistent reinforcement of signature collection protocols and policy reminders during monthly meetings and weekly “huddles”. Of note, a request was submitted to the Arizona WIC Service Desk to determine whether a report could be generated identifying all participants lacking a signed Rights and Obligations form to strengthen monitoring efforts. The response received indicated that generating this type of report is extremely complex, and at this time it is not possible.

View Audit 357695 Questioned Costs: $1

Finding 562078 (2024-001)

None 2024

Carbondale Senior Housing Corporation Phase II

CO

HUD Housing Programs Special Tests & Provisions

Carbondale Senior Housing Corporation Phase II, dba Crystal Meadows II (“CSHC Phase II”) respectfully submits the following corrective action plan for the year ended June 30, 2024. Reference Number: 2024-001 Program Name: Supportive Housing for the Elderly – Section 202 Capital Advance Program Feder...

Carbondale Senior Housing Corporation Phase II, dba Crystal Meadows II (“CSHC Phase II”) respectfully submits the following corrective action plan for the year ended June 30, 2024. Reference Number: 2024-001 Program Name: Supportive Housing for the Elderly – Section 202 Capital Advance Program Federal Assistance Listing Number: 14.157 Compliance Requirement: Special Tests and Provisions Questioned Costs: None Corrective Action: CSHC Phase II agrees that the insurance coverage deficiency is correct. Moving forward, management will review insurance coverage with annual renewals to verify it is in compliance with HUD requirements. Personnel Responsible for Corrective Action: Jerilyn Nieslanik, Executive Director Anticipated Completion Date: In August 2024, CSHC Phase II adjusted its employee dishonesty insurance coverage to the HUD-required minimum of $50,000.

View Audit 357683

Finding 562077 (2024-001)

Material Weakness 2024

Tacoma-Pierce County Chamber of Commerce

WA

Questioned Costs Procurement, Suspension & Debarment § 200.214 § 200.318 § 200.319

Corrective Action Plan for Annual Audit 2024 Finding One: 2024-001 Procurement, Suspension and Debarment Auditor’s Recommendations: Tacoma-Pierce County Chamber of Commerce should conduct research and keep records for procurements not secured using a competitive process. Corrective Action: TPCC S...

Corrective Action Plan for Annual Audit 2024 Finding One: 2024-001 Procurement, Suspension and Debarment Auditor’s Recommendations: Tacoma-Pierce County Chamber of Commerce should conduct research and keep records for procurements not secured using a competitive process. Corrective Action: TPCC Staff will continue to use a competitive procurement process for vendors when possible, per TPCC procurement policy. CEO, Andrea Reay, will amend the current procurement policy to include a process for when competitive procurement is not possible due to unique needs/benefits. This will include a process documenting research conducted that demonstrates the unique benefits to the program/participants for any vendor that is not secured using a competitive process. Documentation includes dates discussed, names of individuals involved in the discussion and decisions made. The debarment check with sam.gov will be included in the documentation packet. Timing of remediation completion: CEO, Andrea Reay, will complete by May 31, 2025.

View Audit 357681 Questioned Costs: $1

Finding 562071 (2024-001)

Significant Deficiency 2024

Issaquah School District No. 411

WA

Procurement, Suspension & Debarment School Nutrition Programs

Finding caption:The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Moriah Banasick, CPA Executive Director of Finance & Budget 5150 220th Ave SE Issaquah, WA 98029 (425) 837-713...

Finding caption:The District did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of District contact person: Moriah Banasick, CPA Executive Director of Finance & Budget 5150 220th Ave SE Issaquah, WA 98029 (425) 837-7139 Corrective action the auditee plans to take in response to the finding: • Staff training: The District is providing targeted training on federal procurement requirements, internal controls, and accountability practices to all federal program leads and purchasing staff. This includes comprehensive orientation for new purchasing leadership to support continuity and compliance. The recent incident is being used as a case study to strengthen shared understanding and reinforce best practices across departments. • New protocols: The District is developing updated emergency procurement protocols that include required documentation, vendor outreach logs, and pre-approval processes to ensure adherence to federal and District requirements. Anticipated date to complete the corrective action: Immediate

View Audit 357675

Finding 562065 (2024-001)

Material Weakness 2024

City of Ingleside, Texas

TX

Reporting

Finance staff will reconcile the SEFA on a quarterly basis to ensure accurate and complete grant files.

View Audit 357670

Finding 562064 (2024-003)

Significant Deficiency 2024

La Casa De Buena Salud, Inc.

NM

Reporting Allowable Costs / Cost Principles Cash Management § 200.302 § 200.303 § 200.305

The reconciliation process implemented in Finding 2024-001 includes a formal method of matching drawdowns to allowable expenditures. Each grant will continue to be tracked in a separate cost center and La Casa will document the reconciled expenditures in the general ledger to amounts drawn from eac...

The reconciliation process implemented in Finding 2024-001 includes a formal method of matching drawdowns to allowable expenditures. Each grant will continue to be tracked in a separate cost center and La Casa will document the reconciled expenditures in the general ledger to amounts drawn from each grant. The monthly reconciliation will be reviewed by the CFO to ensure that revenue is recognized in accordance with ASC 958-605 and that federal expenditures reported on the SEFA and financial statements comply with 2 CFR §§200.302, 200.303, and 200.305. The CFO will utilize the reconciliations to prepare the SF-425 filings and confirm that cumulative drawdowns reconcile to allowable costs and recorded revenues. All supporting documentation will be retained electronically and included in monthly close procedures.

View Audit 357668

Finding 562061 (2024-002)

Significant Deficiency 2024

Roosevelt University

IL

Questioned Costs Special Tests & Provisions Student Financial Aid

University awarded Subsidized Federal Direct Loans to one student in excess of their Subsidized Federal Direct Loan eligibility, and therefore did not comply with all requirements associated with excess loan proceeds. Corrective Actions Taken or Planned: This finding is considered an isolated occurr...

University awarded Subsidized Federal Direct Loans to one student in excess of their Subsidized Federal Direct Loan eligibility, and therefore did not comply with all requirements associated with excess loan proceeds. Corrective Actions Taken or Planned: This finding is considered an isolated occurrence and is not indicative of Roosevelt University’s standard administrative practices or institutional policies. The University has taken the following corrective actions to address the issue and prevent recurrence Student Account Adjustment: A reallocation of $2,900 from the Federal Direct Subsidized Loan to the Federal Direct Unsubsidized Loan was completed to correct the student’s account. All necessary updates were submitted to the U.S. Department of Education on May 16, 2025. Root Cause Analysis and System Improvements: The University will conduct a thorough root cause analysis to determine the underlying factors that led to the overaward. This analysis will be completed within 30 days. Preventative Measure and On-going Monitoring: Based upon the outcome of the root cause analysis, Roosevelt will implement appropriate system controls and develop an on-going monitoring plan to prevent similar issues in the future. These preventative measures will be established within 45 days. Roosevelt University remains committed to maintaining compliance with federal regulations and to continuously strengthening its internal controls to ensure accurate administration of Title IV funds. Anticipated Completion Date: July 15, 2025 Contact Person: Michelle Hayes, Senior Director, Financial Aid and Compliance // Michelle Stipp, Associate Vice President, Enrollment Management

View Audit 357660 Questioned Costs: $1

Finding 562059 (2024-002)

Significant Deficiency 2024

Wagner College

NY

Student Financial Aid Reporting Significant Deficiency

Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Tara Kent tara.kent@wagner.edu 718-390-3121 Corrective action: The College has made great strides in working through its historical data to correct and upd...

Finding 2024-002 – Special Tests and Provisions – Enrollment Reporting Name of contact person responsible for corrective action: Tara Kent tara.kent@wagner.edu 718-390-3121 Corrective action: The College has made great strides in working through its historical data to correct and update students’ program begin dates. There has been significant improvement in the accuracy of this data being reported to the NSLDS, and we expect final completion of this manual process during the College’s next fiscal year. The College also recognizes the importance of reporting all enrollment changes timely to the NSLDS. In order to address the cause of the late enrollment reporting finding, the College has now implemented a process of reporting to the National Student Clearinghouse every 45 days, to ensure that the 60-day timeframe required by the ED is always met. Proposed Completion Date: August 2026 (Item 1) and August 2025 (Item 2)

View Audit 357654

Finding 562058 (2024-001)

Significant Deficiency 2024

Project Vida

TX

Reporting Cash Management

Management’s view: Management adopted the recommendations from last fiscal year to record at the end of each month all grant receivables and other receivables, in accordance with the accrual basis of accounting. The organization has continued to see a growth in program complexity and activities. Thi...

Management’s view: Management adopted the recommendations from last fiscal year to record at the end of each month all grant receivables and other receivables, in accordance with the accrual basis of accounting. The organization has continued to see a growth in program complexity and activities. This procedure is more in line with the recommendations of the auditors. In response to this increase in complexity, Management has provided additional training of staff responsible for entering receivables in the General Ledger. Proposed corrective action: Management will review outstanding grant receivables and revenue accounts on a monthly basis in detail, which includes ensuring that the date of the receivable corresponds to the date the reimbursement submitted, as well as to ensure that the correct payer source codes are reflected in the finance system. Any discrepancies found during the review should be documented through a journal entry. Management will ensure the journal entry correction is done promptly and has resolved the discrepancy identified. In addition, Management will name a responsible person that will oversee this internal control each month and will incorporate the review and adjustments needed as part of the monthly accounting process. To ensure the accuracy of accounts receivable, management will conduct monthly reviews of outstanding receivables with each responsible Program Director and will investigate all receivables outstanding for more than ninety days. Last, Management will review outstanding receivables with the external auditor periodically, and at least once, during an interim date near the end of the fiscal year. Management continues to train additional staff, in order to assist with entering information into the General Ledger and will ensure the responsible individual for monitoring accounts receivable and approving proposed adjustments, is overseeing this internal control process each month. Anticipated correction date: The completion of this process will be done by August 31, 2025. Responsible official: CEO, Tim Davenport-Herbst is responsible for these actions.

View Audit 357653

Finding 562052 (2024-001)

None 2024

Healthy Start Coalition of Southwest Florida, Inc.

FL

Reporting

Plan of Corrective Action: The Coalition will initiate the audit process earlier next year. It is not likely that the Coalition will face the same staffing issues in the future. The Coalition is also working toward involving more staff with grants and Single Audit related matters.

View Audit 357647

Finding 562048 (2024-003)

Material Weakness 2024

Brazos Valley Council of Governments

TX

HUD Housing Programs Material Weakness Reporting

In evaluating appropriate corrective action, management separately considered the audited and the unaudited submissions to the HUD REAC system. While the internal controls over these submissions are very similar, differing circumstances affect future corrective actions. Audited Submissions - With re...

In evaluating appropriate corrective action, management separately considered the audited and the unaudited submissions to the HUD REAC system. While the internal controls over these submissions are very similar, differing circumstances affect future corrective actions. Audited Submissions - With respect to the audited submissions, we believe that corrective action was already sufficiently taken during FY24. We note that this finding is a repeat finding from 2023; the focus of that finding was the untimely submission of the 2021 and 2022 submissions. In response to that finding, management increased oversight over the REAC process and engaged an outside CPA firm to provide technical assistance that would increase the speed and accuracy of the submission process. However, the 2023 audit was not completed until July 2024, which was already past the deadline for the 2023 audited submission. Because the audit’s completion is a prerequisite to the audited REAC submission, the delays to the audit’s completion precluded timely submission of the 2023 audited information. We agree with the auditor’s assessment of a state of noncompliance, as this was the only audited submission required to be made during fiscal year 2024. However, we note that no audited submissions have been required to be made since that time, and as such, no additional corrective action has been implemented since the 2023 audit and the corrective action contemplated in that audit’s corrective action plan. Unaudited Submissions - With respect to the unaudited submission, management believes that the submissions were untimely not because of a deficiency in internal control but rather a purposeful delay as a matter of practice. BVCOG has, for several years, held off submitting each year’s unaudited data until after the acceptance of the prior year’s audited submission. This was historically done to help ensure that amounts between REAC, VMS, and BVCOG’s financial system reconciled as closely as possible, and that HUD’s acceptance comments on the audited submission were implemented in the very next submission. BVCOG has not received communication from the granting agency with respect to this practice. However, BVCOG recognizes the importance of regulatory deadlines, and in future years, BVCOG will proceed with the submission of the unaudited information regardless of whether or not a previous year’s audited submission is not yet approved by HUD. We will modify our practices accordingly to ensure that HUD comments on any submission are addressed as timely as possible, with a resubmission when necessary.

View Audit 357642

Finding 562039 (2024-002)

None 2024

Stanford University

CA

Student Financial Aid Eligibility Reporting

– Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Numb...

– Enrollment Reporting Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program and Federal Direct Student Loans Award Number: Various Assistance Listing Title: Federal Pell Grant Program and Federal Direct Student Loans Assistance Listing Number: 84.033 and 84.268 Award Year: 2023-2024 Pass-through entity: Not applicable Stanford agrees with this finding and will be taking proactive steps to ensure that similar issues do not arise in the future. For the issue affecting 6 out of 25 students, whose status change effective dates did not match their program level information, the Academic Records and Compliance Officer will work closely with systems staff to perform tests to identify a cause and ensure accuracy between the enrollment file extract and records themselves. Expected completion by December 31, 2025. For the issue affecting 2 out of 25 students, whose graduated status was not accurately reflected in their enrollment history, the Academic Records and Compliance Officer is leading a system enhancement currently in progress to replace the ‘G from DV’ file to a ‘Grads Only’ file to report degrees, which is expected to be completed by December 31, 2025. The new and improved file type will ensure the third-party servicer applies graduated statuses for students enrolled in multiple programs. Until the system enhancement is completed, the Academic Records and Compliance Officer will begin carefully reviewing ‘G Not Applied’ error files for manual correction after degrees are reported at the end of each quarter.

View Audit 357625

Finding 562035 (2024-001)

None 2024

Stanford University

CA

Student Financial Aid Subrecipient Monitoring

Verification status code within the Common Origination and Disbursement System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.033 ...

Verification status code within the Common Origination and Disbursement System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.033 Award Year: 2023-2024 Pass-through entity: Not applicable Stanford agrees with this finding and will take steps to prevent these types of errors from happening in the future. Specifically regarding the case of the applicant for whom verification was not completed until after federal aid funds had been disbursed, the Director of Compliance and Technology in the Central Financial Aid Office has adjusted the existing report of verification selections to include students from the three professional schools, as of January 01, 2025, and will work closely with the financial aid offices of each professional school to ensure that selected applicants are verified prior to disbursement of federal aid funds. This communication will be ongoing and occur quarterly at a minimum. Regarding the issue of verification status codes not being updated correctly, the Central Financial Aid office has made two enhancements to our procedures in an effort to avoid future errors: • First, the Director of Compliance and Technology will emphasize to aid application reviewers the importance of correctly setting the verification field values in the PeopleSoft system as part of annual training, which occurs at the beginning of each academic year cycle typically in November, and when new team members arrive. The status of these values will be monitored throughout the year using a database query beginning May 01, 2025 and ongoing on a monthly basis. • Second, the Assistant Director of Technology will regularly request and review a report from the federal Common Origination & Disbursement (COD) system that shows the verification status codes for all selected applicants, to ensure that the codes in the COD system accurately reflect the verification status of aid recipients on a monthly basis beginning on May 01, 2025. We will also double-check the values in all COD records as part of the year-end reconciliation process at the end of each award year, typically in September.Verification status code within the Common Origination and Disbursement System Cluster: Student Financial Assistance Sponsoring Agency: Department of Education Award Name: Pell Grant Program Award Number: Various Assistance Listing Title: Federal Pell Grant Program Assistance Listing Number: 84.033 Award Year: 2023-2024 Pass-through entity: Not applicable Stanford agrees with this finding and will take steps to prevent these types of errors from happening in the future. Specifically regarding the case of the applicant for whom verification was not completed until after federal aid funds had been disbursed, the Director of Compliance and Technology in the Central Financial Aid Office has adjusted the existing report of verification selections to include students from the three professional schools, as of January 01, 2025, and will work closely with the financial aid offices of each professional school to ensure that selected applicants are verified prior to disbursement of federal aid funds. This communication will be ongoing and occur quarterly at a minimum. Regarding the issue of verification status codes not being updated correctly, the Central Financial Aid office has made two enhancements to our procedures in an effort to avoid future errors: • First, the Director of Compliance and Technology will emphasize to aid application reviewers the importance of correctly setting the verification field values in the PeopleSoft system as part of annual training, which occurs at the beginning of each academic year cycle typically in November, and when new team members arrive. The status of these values will be monitored throughout the year using a database query beginning May 01, 2025 and ongoing on a monthly basis. • Second, the Assistant Director of Technology will regularly request and review a report from the federal Common Origination & Disbursement (COD) system that shows the verification status codes for all selected applicants, to ensure that the codes in the COD system accurately reflect the verification status of aid recipients on a monthly basis beginning on May 01, 2025. We will also double-check the values in all COD records as part of the year-end reconciliation process at the end of each award year, typically in September.

View Audit 357625

Finding 562030 (2024-001)

Significant Deficiency 2024

Fife School District No.417

WA

School Nutrition Programs Subrecipient Monitoring Cash Management

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oa...

Finding ref number: 2024-001 Finding caption: The District did not have adequate internal controls for ensuring compliance with federal eligibility and paid lunch equity requirements. Name, address, and telephone of Fife School District contact person: Dany Wanner, Business Services Director 1720 Oak St, Milton, WA 98354 (253) 517-1000 ext 29121 Corrective action the auditee plans to take in response to the finding: The Fife School District implemented the following to Ensure Adequate Internal Controls for Compliance with Federal Eligibility: The Business Services team and Nutrition Services staff have conducted a thorough review of the process of monthly paid lunch equity and modified its procedures including developing a checklist for the process to ensure that it is completed in a timely manner, signed/dated and saved both electronically and in hard copy on a shared district server folder. The Fife School District implemented the following to Ensure Adequate Internal Controls for the annual completion of the Paid Lunch Equity Tool. The Business Services team and Nutrition Services staff have conducted a thorough review of the process of completing both the PLE tool and GL 828 reconciliation and modified its procedures to ensure that it is completed, signed and saved both electronically and in hard copy on a shared district server folder. Further, the Business Services team and Nutrition Services staff have developed a checklist for the completion of the tool and the checking of the box that indicates that we will be opting not to increase meal prices, but instead to demonstrate using the GL 828 Reconciliation (signed and dated) that we have sufficient fund balance to offset the paid lunches and not utilize Federal funds, including calendar reminders and a shared Google Drive to hold all related documents and procedures. Anticipated date to complete the corrective action: 5/16/2025

View Audit 357621

Finding 562025 (2024-002)

Material Weakness 2024

Harriett Buhai Center for Family Law

CA

HUD Housing Programs Material Weakness Reporting

Management has already implemented several new processes and controls related to this finding. These include a change in third party accounting firm to a firm with more robust knowledge of non-profit accounting. Management is also focusing on improving donor documentation, especially for pledges, to...

Management has already implemented several new processes and controls related to this finding. These include a change in third party accounting firm to a firm with more robust knowledge of non-profit accounting. Management is also focusing on improving donor documentation, especially for pledges, to ensure donor intent for the year of use is explicit.

View Audit 357619

Finding 562024 (2024-001)

Significant Deficiency 2024

Harriett Buhai Center for Family Law

CA

Significant Deficiency Internal Control / Segregation of Duties

Management concurs with the recommendation for monthly review of volunteer hours. Management has already implemented a process in which the appropriate Buhai staff member reviews all volunteer hours entered or received on at least a monthly basis. When case hours are received from a volunteer via ti...

Management concurs with the recommendation for monthly review of volunteer hours. Management has already implemented a process in which the appropriate Buhai staff member reviews all volunteer hours entered or received on at least a monthly basis. When case hours are received from a volunteer via time sheet or other method (as opposed to being entered by the volunteer directly into the Buhai Center’s time management system), on a monthly basis, the appropriate Buhai staff member will enter the volunteer’s case hours and reconcile the hours recorded and the underlying time sheet or other supporting information. Further, volunteers are reminded routinely about the importance of timely submissions of hours worked.

View Audit 357619

Finding 562023 (2024-005)

Significant Deficiency 2024

Emerson-Hubbard Community Schools District No. 561

NE

Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring

Management acknowledges the oversight and is implementing corrective measures, including requiring certified payroll documentation, enhancing monitoring procedures, and assigning personnel to oversee Davis-Bacon compliance. The District is working with contractors and state officials to resolve the ...

Management acknowledges the oversight and is implementing corrective measures, including requiring certified payroll documentation, enhancing monitoring procedures, and assigning personnel to oversee Davis-Bacon compliance. The District is working with contractors and state officials to resolve the issue and improve internal controls.

View Audit 357616

Finding 562022 (2024-004)

Significant Deficiency 2024

Emerson-Hubbard Community Schools District No. 561

NE

Subrecipient Monitoring Reporting Internal Control / Segregation of Duties

The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews schedule of expenditures of federal awards and approves all adjustments.

View Audit 357616

Finding 562010 (2024-001)

Material Weakness 2024

High Valley Manor Apartments (an Operating Component of Slvhc, Inc.)

CO

Internal Control / Segregation of Duties Material Weakness Reporting

CORRECTIVE ACTION PLAN Name of Entity: High Valley Manor Apartments Audit Firm: SVA Certified Public Accountants, S.C. Audit Period: Year ended December 31, 2024 Corrective Action Plan Prepared by: Name: Dawn Melgares Position: Executive Director of San Luis Valley Housing Coalition, Inc. Tele...

CORRECTIVE ACTION PLAN Name of Entity: High Valley Manor Apartments Audit Firm: SVA Certified Public Accountants, S.C. Audit Period: Year ended December 31, 2024 Corrective Action Plan Prepared by: Name: Dawn Melgares Position: Executive Director of San Luis Valley Housing Coalition, Inc. Telephone Number: 719-587-9807 1. 2024-001 Finding – Internal control over financial reporting a. Comments on findings and recommendations There is a lack of controls over financial reporting to ensure material misstatements are detected and corrected in a timely manner and the project relies on its auditors to assist in the preparation of the financial statements in accordance with generally accepted accounting principles. b. Actions taken or planned i. Management agent to review processes to ensure transactions are recorded in proper accounts. ii. Management agent will review all audit adjustments and create processes to perform annual account reconciliation of year end balances agree to supporting schedules. c. Anticipated completion date July 31, 2025

View Audit 357607

Finding 561982 (2024-005)

Material Weakness 2024

Colorado Legal Services, INC

CO

Matching / Level of Effort / Earmarking HUD Housing Programs Material Weakness

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization implement a control process to ensure that it meets its matching requirements within the grant period. Explanation of Disagreement With Audit Finding...

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization implement a control process to ensure that it meets its matching requirements within the grant period. Explanation of Disagreement With Audit Finding: Management does not agree with this finding. LSC program letter 22-5 emphasizes the importance of reconciliations of timekeeping reports with labor costs, distribution report or alternative reports. CLS prioritizes this practice of reconciliation and used it during the last months of 2024 to improve internal controls and minimize potential errors. We do not believe that CLA fully and fairly considered CLS’s thorough and complete reconciliation. A “material weakness” is defined as a deficiency “such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected, on a timely basis.” Given that reconciliation is part of our internal control process used to prevent and detect/correct any errors, it should have been fully considered and is unfairly excluded from the review. For this reason, CLS considers that this is not a material weakness as the reconciliation caught and corrected these errors. Finally, the total amount of this finding is very low and should not rise to the level of material weakness. Action Taken in Response to Finding: The Organization is updating the segregation of duties in order to improve the preparation, review and sign steps of the process. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

View Audit 357595

Finding 561981 (2024-004)

Material Weakness 2024

Colorado Legal Services, INC

CO

Questioned Costs Allowable Costs / Cost Principles HUD Housing Programs § 200.403

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization consider updating its salaries and wages cost allocation methodology and process to reduce the frequency of manual adjustments based on review of indi...

Aging Cluster – Special Programs for the Aging, Title III, Part B – Assistance Listing No. 93.044 Recommendation: We recommend that the Organization consider updating its salaries and wages cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Explanation of Disagreement With Audit Finding: Management does not agree with this finding. LSC program letter 22-5 emphasizes the importance of reconciliations of timekeeping reports with labor costs, distribution report or alternative reports. CLS prioritizes this practice of reconciliation and used it during the last months of 2024 to improve internal controls and minimize potential errors. We do not believe that CLA fully and fairly considered CLS’s thorough and complete reconciliation. A “material weakness” is defined as a deficiency “such that there is a reasonable possibility that a material misstatement of the entity’s financial statements will not be prevented, or detected and corrected, on a timely basis.” Given that reconciliation is part of our internal control process used to prevent and detect/correct any errors, it should have been fully considered and is unfairly excluded from the review. For this reason, CLS considers that this is not a material weakness as the reconciliation caught and corrected these errors. Finally, the total amount of this finding is very low and should not rise to the level of material weakness. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

View Audit 357595 Questioned Costs: $1

Finding 561974 (2024-006)

Material Weakness 2024

Colorado Legal Services, INC

CO

Procurement, Suspension & Debarment § 200.318

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization document and maintain evidence of:  its completion of the required steps of its procurement policy for applicable transactions, and  suspension and debarment checks and procedur...

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization document and maintain evidence of:  its completion of the required steps of its procurement policy for applicable transactions, and  suspension and debarment checks and procedures the Organization performs over vendors.Documentation and evidence of these procedures should be maintained to help show that the Organization in compliance with requirements specified in the Uniform Guidance. Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. Regarding suspension and debarment, CLS agrees on improving the documentation to comply and demonstrate compliance with this requirement, though CLS disagrees with the characterization of material weakness. Regarding the two procurement transactions, CLS disagrees strongly that these transactions were procurements subject to the CLS accounting manual procurement section. CLS provided documentation to the auditors demonstrating that these were not procurements but were, in fact, required by existing leases. In one instance, our Denver landlord required us to pay a “catch-up” payment for operating expenses it had underbilled us previously; this cannot conceivably have been a procurement as we did not have discretion not to pay it and it was required by an existing lease. The second instance was a payment related to the expansion of leased office space in Colorado Springs; that also was not a procurement as there was no alternative but to pay the existing landlord for increased space, and it could not conceivably have been conducive to third-party bidding etc. We understand that the auditors may prefer to have a sole source letter in these instances, but we disagree with any finding that this is required by our accounting manual and the auditors have pointed to no specific language in the accounting manual for this requirement. Action Taken in Response to Finding: The Organization will maintain evidence of the performance of its suspension and debarment checks and procedures performed. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026 If the Legal Services Corporation has questions regarding this schedule, please call Silvia Zelaya at 303-449-7575 or szelaya@colegalserv.org.

View Audit 357595

Finding 561973 (2024-003)

Material Weakness 2024

Colorado Legal Services, INC

CO

Allowable Costs / Cost Principles

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its salaries, wages, employee benefit, and general expense cost allocation methodology and process to reduce the frequency of manual adjustments based on review ...

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its salaries, wages, employee benefit, and general expense cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations based on employees’ time and effort records, effective compensation during work periods, and that are calculated in a consistent manner. We also recommend that the Organization maintain contemporaneous documentation supporting all cost allocations. Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. CLS recognizes manual miscalculations due to human errors but considers that the allocation methodology is correct. CLS is undertaking improvements oriented toward automatization of the process while recognizing that complete automatization is not possible without an expensive and complete overhaul of our systems. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

View Audit 357595

Finding 561972 (2024-002)

Material Weakness 2024

Colorado Legal Services, INC

CO

Questioned Costs Allowable Costs / Cost Principles Material Weakness § 200.403 § 200.430

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximiz...

Legal Services Corporation Grants – Assistance Listing No. 09.706060 Recommendation: We recommend that the Organization consider updating its cost allocation methodology and process to reduce the frequency of manual adjustments based on review of individual time records and expense data and maximize the use of automated allocations that are calculated in a consistent manner that ensure costs are applied uniformly to respective benefited activities, and that are reflective on employees’ time and effort records Explanation of Disagreement With Audit Finding: Management partially agrees with this finding. First, 45 CFR Part 1635 codifies the timekeeping requirement. CLS keeps track of every case and time dedicated by staff in strict compliance with this requirement. Additionally, the distribution of expenses in the general fund, which includes LSC and two other funding sources, represents a fair method and allocation. Regarding the questioned costs, CLS disagrees with the finding of material weakness given the extremely low total dollar value. Action Taken in Response to Finding: The Organization will review this finding and current methodology and propose corrections as part of a broader review of its technologies. Name of the Contact Person Responsible for Corrective Action: Silvia Zelaya, Finance Director Planned Completion Date for Corrective Action Plan: January 2026

View Audit 357595 Questioned Costs: $1

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