Corrective Action Plans

Finding 1237945 (2025-005)

Material Weakness 2025

City of Vincennes

IN

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.303

FINDING 2025-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov Views of Responsible Officials: We...

FINDING 2025-005 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Suspension and Debarment Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The clerk’s office will verify that vendors are not excluded or disqualified by checking the SAM’s website, addressing the vendor or adding a clause or condition to the contract to be signed by the vendor. Any documentation will be retained in the city’s grant files. Anticipated Completion Date: The corrective action plan will be implemented by December 31, 2026.

View Audit 412721

Finding 1237944 (2025-004)

Material Weakness 2025

City of Vincennes

IN

Allowable Costs / Cost Principles § 200.300 § 200.302 § 200.303 § 200.328 § 200.329

FINDING 2025-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Allowable Costs/Cost Principles and Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov V...

FINDING 2025-004 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Allowable Costs/Cost Principles and Period of Performance Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-677-3959 clane@vincennes.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The clerk’s office will work with the grant administrators and departments to assist in identifying non-compliant activities to ensure that funds are being used appropriately and according to the federal guidelines for the grant. We will consult with the relevant personnel to ensure understanding of allowable and disallowed costs as well as period of performance and help departments who may need additional training. Anticipated Completion Date: The corrective action plan will be implemented by December 31, 2026.

View Audit 412721

Finding 1237943 (2025-003)

Material Weakness 2025

City of Vincennes

IN

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness § 200.303

FINDING 2025-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Offici...

FINDING 2025-003 Finding Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds – Activities Allowed or Unallowed Contact Person Responsible for Corrective Action: Catherine MM Lane Contact Phone Number and Email Address: 812-882-6426 clane@vincennes.in.gov Views of Responsible Officials: We concur with the findings. Description of Corrective Action Plan: The Clerk-Treasurer’s office will prepare APV for all claims, including those related to payroll benefits. The APVs will be included on the claims docket which will be presented to the City Council for their review and approval. Additionally, the Clerk-Treasurer will certify each claim prior to payment. Anticipated Completion Date: The corrective action plan will be implemented by December 31, 2026.

View Audit 412721

Finding 1237942 (2025-001)

Material Weakness 2025

Elbert County, Colorado

CO

Reporting § 200.100 § 200.510

Finding 2025-001: Material Weakness, Inaccurate Schedule of Expenditures of Federal Awards (SEFA) Person(s) Responsible: Tiffany Hermes, Finance Director Anticipated Completion Date: 12/31/2026 Corrective Action Plan: The Finance Department has implemented quarterly meetings with other departments t...

Finding 2025-001: Material Weakness, Inaccurate Schedule of Expenditures of Federal Awards (SEFA) Person(s) Responsible: Tiffany Hermes, Finance Director Anticipated Completion Date: 12/31/2026 Corrective Action Plan: The Finance Department has implemented quarterly meetings with other departments that maintain grants to discuss and reconcile all grants. This includes Department Heads as well as their admin to enhance conversations to ensure we are tracking any new obligated grants as well as maintaining the current grants.

View Audit 412719

Finding 1237941 (2025-005)

Material Weakness 2025

Aitkin-Itasca-Koochiching Community Health Board

MN

Cash Management Significant Deficiency

REVIEW OF REPORTS Federal Agency: U.S. Department of Agriculture Federal Program Title: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing Number: 10.557 Pass-Through Agency: Minnesota Department of Health Federal Award Identification and Year: 252MN0004W1...

REVIEW OF REPORTS Federal Agency: U.S. Department of Agriculture Federal Program Title: WIC Special Supplemental Nutrition Program for Women, Infants, and Children Assistance Listing Number: 10.557 Pass-Through Agency: Minnesota Department of Health Federal Award Identification and Year: 252MN0004W1003, 2025 Pass-Through Numbers: 252MN0004W1003 Award Period: Year-Ended December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matter Recommendation: It is recommended the Agency implement policies and procedures to ensure that there are adequate controls overall all compliance requirements for federal grants. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The Agency will review policies and procedures and implement change as necessary.. Name of the contact person responsible for corrective action plan: Maggie Rothstein, Administrator Planned completion date for corrective action plan: December 31, 2026

View Audit 412717

Finding 1237940 (2025-009)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Allowable Costs / Cost Principles Internal Control / Segregation of Duties § 200.303 § 200.334 § 200.430

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that employee compensation approvals were not consistently performed in accordance with documented procedures. To strengthen segregation of...

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that employee compensation approvals were not consistently performed in accordance with documented procedures. To strengthen segregation of duties and oversight, responsibility for review and approval of employee compensation changes will be reassigned to appropriate executive leadership personnel independent of payroll processing responsibilities, consistent with the requirement under the Uniform Guidance (2 CFR 200.303) that the Organization establish and maintain effective internal control over federal awards. All pay raises will be initiated upon the recommendation of the respective department directors and must be approved by the Chief Executive Officer (CEO) or Chief Financial Officer (CFO) prior to processing. All compensation changes will be made in accordance with the Organization's Board-approved written compensation policies and will be reasonable and consistent with compensation paid for similar work, as required by the compensation standards for personal services under the Uniform Guidance (2 CFR 200.430). Human Resources will be responsible for ensuring that all pay raise documentation, including department director recommendations and CEO/CFO approvals, is properly completed and filed in the employee’s personnel record. Documentation of all compensation approvals will be maintained in accordance with the record retention requirements of the Uniform Guidance (2 CFR 200.334) and periodically reviewed to ensure compliance with established policies and procedures. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30, 2027

View Audit 412715

Finding 1237938 (2025-008)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Allowable Costs / Cost Principles § 200.303 § 200.334 § 200.403

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that evidence of review and approval was not consistently retained and that documentation supporting reimbursement requests was not maintai...

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that evidence of review and approval was not consistently retained and that documentation supporting reimbursement requests was not maintained at a level sufficient to demonstrate compliance with federal requirements. To address this deficiency, management is implementing formal documentation standards requiring each reimbursement request to be supported by a reconciliation of amounts requested to actual allowable expenditures recorded in the general ledger, together with documented evidence of reviewer approval. Each reconciliation will be prepared by grant and budget category and will compare cumulative expenditures recorded in the general ledger to cumulative amounts previously drawn through the Payment Management System, with any differences investigated and resolved before the request is submitted. The Chief Financial Officer (CFO) or the Chief Executive Officer (CEO) will then review and approve each Request for Reimbursement form and related reconciliation before submission, consistent with the approval process described in the responses to Findings 2025-003 and 2025-006. Evidence of this review will include the approver’s handwritten or electronic signature and the approval date on both the Request for Reimbursement form and the supporting reconciliation. In addition, all expenditures will require documented preapproval by the respective department director or other designated personnel before costs are incurred. Original receipts, invoices, and other supporting documentation will be submitted to the Accounting Department, which will review each expenditure to verify that it is properly authorized, adequately supported, accurately coded, and incurred for a legitimate business purpose of the Organization. Prior to the submission of any reimbursement request, expenditures charged to federal awards will be reviewed for allowability, allocability, reasonableness, and adequate documentation in accordance with the cost principles of the Uniform Guidance (2 CFR Part 200, Subpart E). All reconciliations, approvals, and supporting documentation will be retained in accordance with federal record retention requirements and made readily available for review. Supporting documentation will be maintained in a centralized location, organized by grant and reimbursement period, and retained in accordance with the Uniform Guidance record retention requirements (2 CFR 200.334). The Organization will incorporate these review and approval procedures into its written financial policies and procedures, and finance staff involved in preparing reimbursement requests will receive training on them. In addition, management will periodically perform a secondary review of a sample of completed reimbursement requests to verify that reconciliations, approvals, and supporting documentation are complete, and any exceptions identified will be promptly corrected and documented. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

View Audit 412715

Finding 1237936 (2025-007)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Allowable Costs / Cost Principles § 200.334 § 200.430

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges deficiencies in controls over payroll allocation processes and recognizes the importance of ensuring compensation costs charged to federal ...

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges deficiencies in controls over payroll allocation processes and recognizes the importance of ensuring compensation costs charged to federal programs are supported by records reflecting actual work performed. Management is implementing revised payroll allocation procedures requiring allocations to be supported by approved time records and documented review processes. Specifically, compensation charged to each federal award will be based on timesheets or other time and effort records that reflect the actual hours worked on each program, are signed by the employee, and are approved by the employee’s direct supervisor, in accordance with the standards for documentation of personnel expenses under the Uniform Guidance (2 CFR 200.430(g)). Overtime will require advance supervisory approval and will be charged only to the program on which the overtime hours were worked. Additional training will be provided to employees and supervisors regarding timekeeping and grant coding requirements, and management will periodically review payroll allocations to verify compliance with federal requirements. Each pay period, the Accounting Department will reconcile payroll allocations recorded in the payroll system to approved time records before posting related costs to the general ledger and charging them to federal programs, and will investigate and correct any discrepancies before including the costs in a reimbursement request form. Where budgeted allocations are used for interim purposes, they will be compared to actual effort at least quarterly and adjusted as necessary so that final amounts charged to federal awards reflect actual work performed. The Chief Financial Officer (CFO) will review the results of these reconciliations, and all time records, approvals, and reconciliations will be retained in accordance with the record retention requirements of the Uniform Guidance (2 CFR 200.334). Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

View Audit 412715

Finding 1237935 (2025-006)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Procurement, Suspension & Debarment Allowable Costs / Cost Principles § 200.334

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization recognizes that documentation supporting certain expenditures charged to federal programs was not adequately maintained and that review procedures over ...

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization recognizes that documentation supporting certain expenditures charged to federal programs was not adequately maintained and that review procedures over reimbursement requests were not sufficient to ensure expenditures were fully supported and accurately reflected. Management is implementing enhanced procedures requiring all expenditures included in reimbursement requests to be supported by source documentation and reconciled to accounting records prior to submission. The Accounting Department will collect original invoices, receipts, payroll registers, and other source documents when costs are incurred, and will prepare reconciliations using final invoices rather than estimates, quotes, or purchase orders. In limited circumstances where an estimate must be used for anticipated expenses, the basis for the estimate will be documented and approved prior to submission, and the estimated amount will be reconciled to actual expenditures in a timely manner, no later than the subsequent reimbursement request, with any differences promptly adjusted and supporting documentation retained. In addition, independent review procedures will be performed to verify allowability, accuracy, and completeness before federal reimbursement requests are submitted. Each reimbursement request will then be reviewed and approved by the Chief Financial Officer (CFO) or the Chief Executive Officer (CEO) before submission, consistent with the approval process described in the response to Finding 2025-003. The Organization will organize supporting documentation by grant and reimbursement period and retain it in accordance with the record retention requirements of the Uniform Guidance (2 CFR 200.334). Additionally, the Chief Financial Officer (CFO) will perform periodic sample-based reviews of expenditures charged to federal awards to verify that documentation standards are consistently followed, and any exceptions identified will be promptly corrected, including adjustment of amounts previously requested where necessary. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

View Audit 412715

Finding 1237934 (2025-005)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Subrecipient Monitoring Eligibility Significant Deficiency § 200.303

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that controls intended to ensure annual renewal of sliding fee discount applications were not consistently operating as intended. Managemen...

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that controls intended to ensure annual renewal of sliding fee discount applications were not consistently operating as intended. Management is strengthening monitoring procedures by implementing tracking mechanisms to identify expiring applications and requiring verification of eligibility documentation prior to continued application of discounts, consistent with the requirement under Section 330(k)(3)(G) of the Public Health Service Act (42 U.S.C. 254b(k)(3)(G)) that health centers establish systems for sliding fee eligibility determination. In addition, management will provide additional training to all billing and front-desk staff on the sliding fee discount program, including eligibility determination, income and household-size documentation requirements, application renewal procedures, and the proper application of discounts in the practice management system. Periodic supervisory reviews will be performed to ensure compliance with the Board-approved sliding fee discount policy, consistent with the internal control requirements of the Uniform Guidance (2 CFR 200.303). Management will also review the sliding fee discount schedule on a regular basis, no less than annually, and will update it in a timely manner whenever necessary, including upon publication of the annual Federal Poverty Guidelines, so that discounts continue to be adjusted on the basis of each patient’s ability to pay as required by 42 CFR 51c.303(f), with all updates presented to the Board of Directors for approval and communicated promptly to billing staff. Documentation of staff training, schedule reviews, and Board approvals will be retained to demonstrate compliance with HRSA Health Center Program requirements, including Chapter 9 (Sliding Fee Discount Program) of the HRSA Health Center Program Compliance Manual. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: December 31st, 2026

View Audit 412715

Finding 1237933 (2025-004)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Procurement, Suspension & Debarment § 200.317 § 200.327

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization recognizes that procurement procedures and related documentation requirements were not consistently followed and that adequate controls were not in plac...

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization recognizes that procurement procedures and related documentation requirements were not consistently followed and that adequate controls were not in place to ensure compliance with federal procurement standards. Management will conduct a comprehensive review of procurement policies and procedures and will implement formal review requirements for procurement method determinations. To support these efforts, management is hiring a Purchasing Coordinator who will be responsible for all aspects of the Organization’s procurement function and for ensuring that all purchases are conducted in accordance with the Organization’s written procurement policies and the procurement standards of the Office of Management and Budget (OMB) Uniform Guidance (2 CFR 200.317 through 200.327). Additional procedures will require documentation of price reasonableness, competitive quotations, sole-source justifications, and aggregate vendor purchase evaluations, as applicable. The Purchasing Coordinator will determine and document the appropriate procurement method for each purchase, obtain and retain required quotations, and maintain complete procurement files for all purchases charged to federal awards. Personnel involved in purchasing activities will receive additional training on Uniform Guidance procurement requirements, and management will implement monitoring procedures to verify compliance on an ongoing basis. To maintain appropriate segregation of duties, the Accounting Department will independently review procurement files before payment to verify that documentation is complete and that the selected procurement method is appropriate and compliant with federal requirements. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

View Audit 412715

Finding 1237932 (2025-003)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Cash Management § 200.305

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that reimbursement requests were not consistently supported by reconciliations to actual expenditures and that existing review procedures d...

There is no disagreement with the audit finding. Action planned/taken in response to finding: Management concurs with the finding. The Organization acknowledges that reimbursement requests were not consistently supported by reconciliations to actual expenditures and that existing review procedures did not provide sufficient assurance that draw requests complied with federal cash management requirements. Management is implementing revised procedures requiring all draw requests to be supported by detailed expenditure reconciliations, payroll reports, invoices, and other supporting documentation prior to submission. In addition, management has formally instituted a policy requiring all reimbursement requests to be submitted on an official Request for Reimbursement form, accompanied by a written statement describing the purpose of the reimbursement and the related expenditures, and supported by appropriate source documentation. The Organization will also establish an enhanced review process requiring independent verification of supporting documentation before reimbursement requests are submitted. Each completed Request for Reimbursement form, together with the related expenditure reconciliation and supporting documentation, must be reviewed and approved by the Chief Executive Officer (CEO) before any drawdown or reimbursement request is submitted. Evidence of the CEO’s review and approval will be retained with each request to demonstrate compliance with federal cash management requirements under the Uniform Guidance (2 CFR 200.305). Management is committed to ensuring future draw-down requests (including those already submitted during the subsequent year) are based solely on actual allowable expenditures incurred and are submitted in compliance with federal cash management requirements. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

View Audit 412715

Finding 1237930 (2025-002)

Material Weakness 2025

Cincinnati Health Network, Inc.

OH

Material Weakness Reporting Internal Control / Segregation of Duties § 200.303

There is no disagreement with the audit finding. Action planned in response to finding: Management concurs with the finding. The Organization recognizes that documentation and reconciliation procedures supporting the Uniform Data System (UDS) submission were not sufficient to demonstrate the accurac...

There is no disagreement with the audit finding. Action planned in response to finding: Management concurs with the finding. The Organization recognizes that documentation and reconciliation procedures supporting the Uniform Data System (UDS) submission were not sufficient to demonstrate the accuracy and completeness of all reported data elements. During 2026, management will implement formal procedures requiring each UDS reporting element to be supported by documented source data, reconciled to underlying records, and independently reviewed prior to submission. These procedures will include a pre-submission review checklist and internal timeline so that all reconciliations and supporting documentation are completed and reviewed in advance of the UDS reporting deadline. Responsibility for preparation, review, and approval of UDS reporting will be formally assigned and documented. To strengthen this review, management plans to hire additional senior management personnel, including an Accounting Manager, to support the Accounting Department and oversee reconciliation of the UDS financial tables (Tables 8A, 9D, and 9E) to the general ledger and audited financial statements. In addition, management plans to hire a Director of Risk and Compliance, who will be responsible for overseeing the Organization's compliance with HRSA Health Center Program requirements, including the UDS reporting process. The Director of Risk and Compliance will perform an independent review of the completed UDS submission prior to certification, verifying that each reported data element is supported by documented source data and reconciliations, and will periodically monitor adherence to the procedures described in this response, with results reported to the Chief Executive Officer (CEO) and the Board of Directors. Any discrepancies identified before or after submission will be documented, investigated, and corrected in a timely manner, including through the HRSA UDS review and revision process where applicable. Management will also provide additional training to all staff involved in collecting, preparing, and reviewing UDS data, covering HRSA UDS reporting requirements, data definitions, and documentation standards. In addition, management will establish document retention procedures to ensure all supporting schedules, reconciliations, and reports are maintained in a centralized location and readily available for future review. New policies requiring timely account reconciliations and the retention of supporting records will be monitored and reviewed regularly by the Chief Financial Officer (CFO) to ensure they are consistently followed. Name(s) of the contact person(s) responsible for corrective action: Edward Murphy, Asante Muyungga, Charity Gutierrez, Anthony Parker, Bennett Baber, Jannell Robinson. Planned completion date for corrective action plan: June 30th, 2027

View Audit 412715

Finding 1237929 (2025-002)

Material Weakness 2025

Town of North Liberty

IN

Subrecipient Monitoring Internal Control / Segregation of Duties

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has taken the steps to implement controls surrounding federal reporting for future grants to ensure accuracy in reporting. Responsible party and timeline for completion: Clerk Treasurer Vicki Kitche...

Views of Responsible Officials and Planned Corrective Actions: Management agrees with the finding and has taken the steps to implement controls surrounding federal reporting for future grants to ensure accuracy in reporting. Responsible party and timeline for completion: Clerk Treasurer Vicki Kitchen will get the sub-recipient removed for submittal for the final 2026 report that is filed in 2027. A work ticket was filed to correct the subrecipient but the Town of North Liberty was never contacted by the SLFRF. This is the only way I could get the annual report completed. I will work on the final SLFRF report submitted. The work can't be completed until the next required report is due in 2027.

View Audit 412700

Finding 1237927 (2025-158)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237926 (2025-157)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237925 (2025-156)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237924 (2025-155)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237923 (2025-154)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237922 (2025-153)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237921 (2025-152)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237920 (2025-151)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237919 (2025-150)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237918 (2025-149)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

Finding 1237917 (2025-148)

Material Weakness 2025

The Geneva Foundation

WA

Procurement, Suspension & Debarment § 200.303

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and ...

The Geneva Foundation (Foundation) submits the following corrective action plan in response to the finding identified during the audit for the year ending December 31, 2025. 1. Finding 2025-001: Research and Development Cluster - Suspension and Debarment; U.S Department of Defense/War (DoD/DoW) and U.S. Department of Health and Human Services (HHS) – Various R&D Assistance Listings Questioned Costs: None Condition: The Foundation did not follow internal control procedures designed to ensure compliance with suspension and debarment requirements for covered contracts. During our testing of procurement transactions subject to suspension and debarment requirements, we noted that the Foundation did not retain documentation demonstrating that it had reviewed the System for Award Management (SAM.gov) exclusion records prior to entering into contractual agreements. Specifically, there was no evidence that a SAM.gov printout was reviewed or approved to verify that vendors were not suspended or debarred at the time of contract execution. In conjunction with the audit, we reviewed the SAM Exclusions for all transactions in our sample and we noted that no transactions were with entities that were suspended or debarred. 2. Corrective Action: The Foundation will review and update its procurement and vendor eligibility procedures to ensure compliance with federal suspension and debarment requirements under 2 CFR Part 180 and applicable Uniform Guidance requirements. The revised procedures will: a. Define when SAM.gov exclusion verification is required. b. Identify personnel responsible for performing and documenting the verification. c. Require retention of date-stamped evidence of the SAM.gov review within the procurement file prior to contract execution. d. Establish supervisory review procedures to confirm required documentation is present before procurement approval is granted. e. Incorporate suspension and debarment verification requirements into procurement checklists, vendor onboarding procedures, and procurement approval workflows. f. Require that covered procurement actions cannot proceed to contract execution without documented evidence of suspension and debarment verification. g. Incorporate periodic compliance monitoring to assess adherence to the revised procedures and identify any exceptions requiring corrective action. These actions are designed to strengthen the Foundation's internal control environment, enhance documentation practices, and ensure consistent compliance with federal suspension and debarment requirements. Management believes these corrective actions adequately address the root cause of the finding and will reduce the risk of recurrence in future audit periods. 3. Responsible Party: The Director and Financial Controller will jointly oversee the policy review, procedural updates, and ongoing monitoring to ensure compliance with federal requirements. Day-to-day implementation and monitoring will be coordinated by the Procurement Manager, with oversight and periodic compliance review performed by the Financial Controller. 4. Anticipated Completion Date: December 31, 2026. Key milestones include: a. Revised procedures drafted and approved by October 31, 2026 b. Procurement workflow and checklist updates completed by November 15, 2026 c. Staff training completed by November 30, 2026 d. Updated controls and workflow requirements implemented by November 30, 2026 e. Compliance review completed by December 31, 2026 5. Implementation Details: To implement the updated procedures, the Foundation will incorporate SAM.gov suspension and debarment verification requirements into its procurement workflow, vendor onboarding process, and procurement file review procedures. Prior to execution of any covered contract subject to federal requirements, designated personnel will perform a SAM.gov exclusion search and retain date-stamped evidence of the search within the procurement file. Procurement approvals will not be finalized until the required documentation has been obtained and reviewed. In addition, Finance personnel processing covered transactions will verify that required suspension and debarment documentation is maintained within the procurement file before payments are processed. Transactions lacking required suspension and debarment documentation will be returned to Procurement for correction and completion prior to contract execution or payment processing, as applicable. The Procurement Manager will conduct periodic reviews of procurement files to verify compliance with documentation requirements. Any exceptions identified will be documented and reported to the Director and Financial Controller for resolution and corrective action. Additionally, procurement personnel and other employees involved in vendor onboarding, contracting, and accounts payable activities will receive training regarding federal suspension and debarment requirements, documentation standards, and revised approval procedures. During FY27, management will conduct and document quarterly reviews of a sample of covered procurement transactions to verify compliance with the revised controls. Any deficiencies identified will be evaluated and corrective actions implemented as necessary. Sincerely, Matt Rueckert Chief Operating Officer (COO)

View Audit 412698

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